EPA Superfund Record of Decision Amendment; Keystone Sanitation Landfill EPA ID: PAD054142781 OU01 Union Township PA


EPA/AMD/R03-00/065
2000
EPA Superfund
Record of Decision Amendment:
KEYSTONE SANITATION LANDFILL
EPA ID: PAD054142781
OUOl
UNION TOWNSHIP, PA
09/14/2000

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
1650 Arch Street
Philadelphia, Pennsylvania 19103-2029
SUBJECT: Record of Decision Amendment Transmittal Memo
Keystone Sanitation Landfill Superfund Site
Union Township, Adams County, Pennsylvania
FROM: Peter Set
Chief,	BfaJich
TO: Abraham Ferdas, Director
Hazardous Site Cleanup Division (3HS001
THRU: Anthony Dappolone (3HS21)
Chief, Eastern Pennsylvania Remedial Section
Attached, for your signature, is the Record of Decision ("ROD") Amendment for the Keystone
Sanitation Superfund Site ('"Site") for Operable Unit One ("OU-1"). The selected remedy involves an
Alternate Source Control Remedy which employs an enhanced gas extraction system to remove and
destroy volatile organic contaminants (VOCs) and methane from the landfill rather than the impermeable
cap, selected in the 1990 ROD. In addition to the installation of the gas extraction system, the remedy
includes: upgrades to tile existing soil cover; monitoring to ensure proper functioning of the gas extraction
system and to measure VOC removal from the landfill; monitoring of the leachate to ensure that the
landfill is not a continued source of VOC contamination to the groundwater; use of surface water
management controls to minimize soil erosion and sedimentation; maintenance of the existing fence; and
institutional controls on the use of the property.
This Amendment does not address and/or otherwise pertain to the groundwater remedy selected
in the OL'-I ROD. The response actions for the groundwater selected in September 1990, as amended on
June 25, 1999 remained unchanged. The response actions discussed in this Amendment, in conjunction
with response actions for the groundwater contamination, will comprehensively address the threats posed
by the release or potential release of hazardous substances from this Site.
The Commonwealth of Pennsylvania Department of Environmental Protection has concurred
with the selected amendment to the remedy.
Customer Service Hotline 1-800-438-2474

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SUPERFUND PROGRAM
RECORD OF DECISION
AMENDMENT
f ^ i
Keystone Sanitation Landfill Superfund Site
Hanover, Adams County, Pennsylvania
September 2000
DECLARATION
SITE NAME AND LOCATION
Keystone Sanitation Landfill Superfund Site
Union Township, Adams County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
Record of Decision ("ROD") for the Keystone Sanitation Superfund ("Site") for Operable Unit One
("OU-1") was issued on September 30, 1990. The primary components of the ROD were the
construction of a groundwater extraction and treatment system and installation of an impermeable cap and
gas collection system over the landfill. The ROD was amended on June 25, 1999 to address impacts from
the landfill on groundwater, surface water, and sediments in the areas beyond the landfill boundaries; the
June 25, 1999 Amendment also changed certain performance standards for the previously selected
groundwater treatment system.
This decision document presents the selected remedial action to amend the OU-1 ROD for the Site. The
remedial action was selected 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 the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the Administrative Record for the Site.
The Commonwealth of Pennsylvania Department of Environmental Protection (PADEP) has concurred
with the selected amendment to the remedy.

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ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine pursuant to Section 106 of CERCLA,
42 U.S.C. § 9606, that actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this Amendment to the ROD, may present an
imminent and substantial endangerment to the public health, welfare, or environment.
DESCRIPTION OF SELECTED REMEDY AMENDMENTS
The selected remedy amendment described below involves an Alternate Source Control Remedy which
employs an Enhanced Landfill Gas Extraction (ELGE) system to remove and destroy volatile organic
contaminants (VOCs) and methane from the landfill rather than the impermeable cap, selected in the 1990
ROD, which would have decreased the mobility of VOCs in the landfill. In addition to the installation of
the ELGE system, the Alternate Source Control Remedy includes: upgrades to the existing soil cover,
monitoring to ensure proper functioning of the ELGE system and to measure VOC removal from the
landfill; monitoring of the leachate to ensure that the landfill is not a continued source of VOC
contamination to the groundwater; use of surface water management controls to minimize soil erosion and
sedimentation; maintenance of the existing fence; and institutional controls on the use of the property.
This Amendment does not address and/or otherwise pertain to the groundwater remedy selected in the
OL'-l ROD. The response actions for the groundwater selected in September 1990, as amended on June
25. 1999 remain unchanged. The remedial response actions discussed in this Amendment, in conjunction
with response actions for the groundwater contamination, will comprehensively address the threats posed
by the release or potential release of hazardous substances from this Site.
The selected amendment to the remedy includes the following major components:
• Upgrades to the existing landfill soil cover;
Installation and operation of an ELGE system to actively remove VOCs and methane from the
landfill waste;
Monitoring to ensure proper functioning of the ELGE system and to evaluate VOC removal from
the landfill;
Monitoring to determine the impact of the ELGE system on the quality of the leachate within the
landfill;
Use of surface water management controls to minimize soil erosion and sedimentation;
Maintenance of the existing fence; and
Use of institutional controls on the landfill property.
2

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STATUTORY DETERMINATIONS
The amended remedy is protective of human health and the environment and is cost effective. EPA
believes that the selected remedy will comply with all Federal and State requirements that are legally
applicable or relevant and appropriate to the remedial action. The selected remedy utilizes a permanent
solution to the maximum extent practicable and satisfies the statutory preference for a remedy that
employs treatment that reduces toxicity, mobility, or volume.
Because this remedy will result in hazardous substances remaining on-Site above health-based levels, a
review by EPA will be conducted within five years after initiation of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment.

Abraham Ferdas, Director
Hazardous Site Cleanup Division
Region m
Date
3

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TABLE OF CONTENTS
[. INTRODUCTION	1
II.	SITE DESCRIPTION, HISTORY, CONTAMINATION AND SELECTED OLTI
REMEDY 	2
III.	REASONS FOR ISSUING THE ROD AMENDMENT 	4
IV.	DESCRIPTION OF THE NEW ALTERNATIVE	5
A.	General Description of the Selected Alternate Source Control Remedy 	6
B.	Performance Standards	II
C.	Contingent Remedies 	15
D.	Estimated Cost	16
E.	Explanation of ARARs	16
F.	Five Year Reviews	18
V.	EVALUATION OF THE ALTERNATE SOURCE CONTROL REMEDY AND THE
CONTINGENT REMEDIES USING THE NINE CRITERIA 	18
VI.	STATUTORY DETERMINATIONS	25
A.	Protection of Human Health and the Environment	25
B.	Compliance with Applicable or Relevant and Appropriate Requirements	25
C.	Cost Effectiveness 	25
D.	Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable 	26
E.	Preference for Treatment as a Principal Element 	26
VII.	PUBLIC PARTICIPATION 	26
VIII.	DOCUMENTATION OF SIGNIFICANT CHANGES 	27
APPENDIX A - TABLES
Table 1 - Leachate Quality Performance Standards
Table 2 - Cost Estimate
APPENDIX B - FIGURES
Figure 1 - Site Location Map
Figure 2 - Conceptual Gas Extraction System
APPENDIX C - GLOSSARY OF TERMS

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AMENDMENT TO THE RECORD OF DECISION
OPERABLE UNIT ONE
KEYSTONE SANITATION LANDFILL SUPERFUND SITE
I. INTRODUCTION
Site Name: Keystone Sanitation Superfund Site
Site Location: Union Township, Adams County, Pennsylvania
Lead Agency: U.S. Environmental Protection Agency, Region ("EPA" of "the Agency")
Support Agency: Pennsylvania Department of Environmental Protection ("PADEP")
Statement of Purpose
A Record of Decision (ROD) for the Keystone Sanitation Superfund Site (Site) for Operable Unit
One (OU-l) was issued on September 30, 1990. The primary components of the ROD were the
construction of a groundwater extraction and treatment system and installation of an impermeable cap and
gas collection system over the landfill. The ROD was amended on June 25. 1999 to address impacts from
the landfill on groundwater, surface water, and sediments in the areas beyond the landfill boundaries; the
June 25, 1999 Amendment also changed certain performance standards for the previously selected
groundwater treatment system.
This Amendment involves an Alternate Source Control Remedy which employs an Enhanced
Landfill Gas Extraction (ELGE) system to remove and destroy volatile organic contaminants (VOCs) and
methane from the landfill rather than the impermeable cap, selected in the 1990 ROD, which would have
decreased the mobility of VOCs in the landfill. In addition to the installation of the ELGE system, the
Alternate Source Control Remedy includes: upgrades to the existing soil cover: monitoring to ensure
proper functioning of the ELGE system and to measure VOC removal from the landfill; monitoring of the
leachate to ensure that the landfill is not a continued source of VOC contamination to the groundwater;
use of surface water management controls to minimize soil erosion and sedimentation; maintenance of the
existing fence; and institutional controls on the use of the property.
This Amendment to the ROD is issued in accordance with Section 117(c) of the Comprehensive
Environmental Response, Compensation and Liability Act, as amended by the Superfund Amendments
and Reauthorization Act of 1986 (CERCLA), 42 U.S.C. § 9617(c), and 40 C.F.R. § 300.435(c)(2)(ii).
This Amendment has been prepared to document the nature of the change made to the selected remedy
identified in the 1990 ROD; to summarize the information that led to the making of the change; and to
affirm that the revised remedy complies with the statutory requirements of CERCLA § 121, 42 U.S.C. §
9621. This Amendment fundamentally alters the remedy selected in the 1990 ROD with respect to scope,
performance, and cost.

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This Amendment does not address and/or otherwise pertain to the groundwater remedy selected
in the OU-1 ROD. The response actions for the groundwater selected in September 1990, as amended on
June 25, 1999 remain unchanged. The remedial response actions discussed in this .Amendment, in
conjunction with response actions for the groundwater contamination, will comprehensively address the
threats posed by the release or potential release of hazardous substances from this Site
This Amendment is incorporated into the Administrative Record for the Site1. The Administrative
Record File is available at the following locations:
Hanover Public Library EPA Region III
Library Place 1650 Arch Street
Hanover, PA 17331 Philadelphia, PA 19103
(717) 632-5183 (215) 814-3157
The Administrative Record File is no longer available at St Mary's Christ Church of Christ
located at 1441 East Mayberry Street, Westminister, Maryland.
II. SITE DESCRIPTION, HISTORY, CONTAMINATION AND SELECTED OU1-ROD
REMEDY
A. Site Description and Location
The Site is an inactive, privately owned facility that operated from 1966 to April 1990. The landfill
received household and municipal wastes and certain types of industrial and construction debris. The
landfill is located on a 40-acre tract in Union Township, Adams County, Pennsylvania, southwest of
Hanover, Pennsylvania. See Figure I. The landfill property is bordered to the south by Line Road, to the
north by Clouser Road, and is approximately 800 feet north of the Pennsylvania-Maryland border. The
entire landfill property has been fenced, in accordance with requirements of the 1990 ROD.
The landfill was constructed without a liner or leachate collection system. Wastes were deposited
an average depth of 30 feet. The landfill has a maximum elevation of approximately 780 feet and a
vertical relief of approximately 200 feet within 2,000 feet of the Site. Perennial grass covers the Site.
The landfill is situated on top of a ridge. The topography of the area consists of gently rolling hills
and valleys formed by elongated, northeast-trending ridges and valleys. Numerous small springs within the
vicinity of the Site discharge to surface water bodies.
1 This Amendment pertains only to the specified portions of the ROD for OU-1.

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The Site is located in a rural residential/agriculture area. Groundwater is the only source
of potable water in the area and residents near the Site are dependent on private wells. During the 1997
OU-2 Remedial Investigation, it was estimated that there were approximately 75 residences within
one-mile of the Site. This number is increasing due to residential development in the vicinity of the Site.
B. Site History
In 1982, in accordance with State permitting requirements, groundwater monitoring for VOCs
was conducted. VOC contamination was detected in on-site monitoring wells and in a nearby spring,
Mundorff Spring, which is located east of the Site.
In April 1984, an EPA Field Investigation Team performed a Site investigation in response to
citizens' complaints of groundwater contamination in residential wells. Sampling results from the
Pennsylvania Department of Environmental Resources (PADER), the predecessor to the Pennsylvania
Department of Environmental Protection (PADEP), and EPA confirmed the presence of low levels of
VOC contamination in some of the residential wells.
In August 1984, the owners of the landfill installed a spray irrigation system in the most
contaminated groundwater area to prevent the migration of contaminants off-site and to remove VOC
from the groundwater. Spray irrigation is a practice consisting of spraying contaminated groundwater on a
field and allowing VOCs to evaporate into the air. The spray irrigation system was operated until 1992. In
addition, leachate collection was attempted on the southern side of the landfill along Line Road. Two
perforated pipes were located at the base of the landfill. The pipe ran parallel to Line Road and
discharged into a storage tank. The storage tank was pumped periodically, and the contents were disposed
off-site.
In the spring 1985, the State of Maryland installed monitoring wells at the Maryland border to
monitor potential contaminant migration. Low levels of VOC contamination have been consistently
detected in at lag one of these wells.
The Keystone Sanitation Landfill Site was placed on the Superfiind National Priorities List (NPL)
in July 1987. This list includes sites where uncontrolled hazardous substance releases present the most
significant potential threats to human health and the environment.
In 1987, EPA began a Remedial Investigation (Rl) and Feasibility Srudv (FS) at the Site. The RI
field activities began in the spring of 1989. The RI/FS reports were issued in July 1990 and finalized in
September 1990. EPA issued the OU-1 ROD on September 30.1990. The remedy selected in the OU-1
ROD included:
• Installation and maintenance of an impermeable cap and gas collection system over the 40-acre
landfill;

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• Installation and maintenance of on-site groundwater extraction wells and a treatment plant to
capture, contain and reduce the concentrations of VOCs and metals in groundwater;
Provision of a point-of-use groundwater treatment system to on-site residents;
Installation and maintenance of a fence around the Site;
• Monitoring of the groundwater in monitoring and residential wells:
Monitoring of surface water and sediments;
Initiation of institutional controls regarding present and future activities on the landfill property.
To date, the fence and the on-site point-of-use groundwater treatment system have been
completed. Construction of the extraction wells and groundwater treatment plant has recently been
completed. EPA expects the plant will begin operating later this year.
In addition, the 1990 ROD included a requirement to perform another RJ to further study the
groundwater contamination in the off-site residential wells and off-site monitoring wells. This RI was
completed in January 1998 During the second investigation. EPA collected groundwater samples from 72
monitoring wells, sampled 74 residential wells, and sampled surface water and sediment at numerous
locations. Based on the results of the second RJ, the ROD was amended on June 25, 1999 to address
groundwater contamination outside the boundaries of the landfill. As required by the June 25, 1999
Amendment, carbon filtration units have been offered to residents within 3/4 miles of the landfill. To date,
filters have been installed to all eligible residents who accepted the ofTer.
III. REASONS FOR ISSUING THE ROD AMENDMENT
While under a Unilateral Administrative Order ("Order") to conduct the EPA-approved
Remedial Design/Remedial Action ("RD/RA")of the landfill cap, the owner/operators, petitioned EPA to
allow them to conduct a pilot test at the Site to evaluate the feasibility of utilizing an ELGE system to
remove VOCs and methane from the landfill. The purpose of the pilot test, conducted at the Site in
November 1998, was to demonstrate the feasibility of ELGE as a means to remove VOCs from the
landfill mass and to control landfill gas migration, as part of the Alternate Source Control Remedy. The
findings of the pilot test are documented in the ELGE Pilot Test Report for the Keystone Sanitation
Landfill Site, dated January 1999.
The ELGE system is similar to a soil vapor extraction (SVE) system for treatment of VOCs in
contaminated soil. VOCs and methane will be extracted from the refuse zone, and the combination of
reduced vapor pressure and increased advection imparted by the system blower will induce further
volatilization of remaining VOCs from the refuse. At the time the 1990 FS and ROD were drafted,
technologies such as SVE were not considered to be technically feasible at this Site due to the
non-homogeneous nature of the landfill waste. Therefore, SVE was not considered during the final
analysis of remedial alternatives. Additionally, since sampling within

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the landfill was not performed during the RI. 110 waste characterization was available (other than historical
data) at the time the remedy was selected.
Since 1990. technical developments in the field of SVE have led to this technology being
considered a potential alternative for remediation at the Keystone Sanitation Landfill Site, These
developments include significant new methods of characterizing landfill permeability and gas
concentration. After considering these recent advances in SVE technologies, the EPA approved plans to
conduct a pilot test at the Site. The pilot test provided additional information necessary to evaluate the
viability and effectiveness of ELGE at the Site. The results of the pilot test have suggested the feasibility
of ELGE as a means to remove VQCs from the landfill and to control landfill gas migration. Based on the
findings of the pilot test, a focused feasibility study (FFS) was prepared to supplement the Administrative
Record by evaluating the Alternate Source Control Remedy for the Site.
The FFS concluded that the Alternate Source Control Remedy, combined with the remedy for
groundwater selected in the 1990 ROD, as amended on June 25, 1999, will satisfy the remedial action
objectives for this Site. The combined remedies will be effective in capturing, containing, and remediating
contamination from the waste fill and groundwater, and they will achieve the cleanup standards
established by EPA and protect both human health and the environment. The overall remedial action
objectives of the Alternate Source Control remedy are consistent with those identified in the 1990 ROD.
EPA issued a Proposed Remedial Action Plan (PRAP), dated June 1, 2000, which summarized
the findings of the FFS report, provided the details on EPA's preferred remedy, and explained the reasons
for this preference. The PRAP was released for public comment as part of the Administrative Record file
on June 5, 2000.
IV. DESCRIPTION OF THE NEW ALTERNATIVE
Following review and consideration of the information in the Administrative Record file, the
requirements of CERCLA, the National Contingency Plan (NCP), and public comment, EPA has selected
the following remedial response action to be implemented at this Site in conjunction with the groundwater
remedy selected in the OL'-l ROD of September 1990 and amended on June 25, 1999. The response
action will be incorporated as an amendment to the OL'-l ROD of September 1990. The main
components of the selected amendment (hereafter the selected amendment to the OL'-l ROD will be
referred to as the "Alternate Source Control Remedy") are described below:
Based on new methods of characterizing landfill permeability and gas concentrations, since the
1990 ROD was signed, the owners/operators, under the oversight of EPA and in consultation with the
PADEP, developed an Alternate Source Control Remedy that meets the remedial action objectives
presented in the 1990 ROD and provides protection of human health and the environment.

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A. General Description of the Selected Alternate Source Control Remedy
The primary components of the Alternate Source Control Remedy are described below.
• Upgrades to the existing landfill soil cover;
• Installation and operation of an ELGE system to actively remove VOCs and methane from the landfill
waste;
• Momtoring to ensure proper functioning of the ELGE system and to evaluate VOC removal from the
landfill;
• Monitoring to determine the impact of the ELGE system on the quality of the leachate within the
landfill;
• Use of surface water management controls to minimize soil erosion and sedimentation;
Maintenance of the existing fence; and
• Use of institutional controls on the landfill property.
1. Upgrades to the Existing soil Cover
Upgrades to the existing landfill cover shall include;
• Addition of low permeability cover soil to maintain a minimum 2-foot thick soil cover across the
landfill;
• Regrading of the landfill surface to repair minor erosion gullies, improve drainage, and ensure
adequate slope stability; and
• Removal of woodv vegetation.
A comprehensive investigation of the landfill cover thickness will be performed. Areas of the landfill soil
cover having a thickness of less than 2 feet will be increased to at least 2 feet using compacted soils. The
cover will then be re-vegetated. A waste investigation will be performed to verify the boundaries of the
landfill. The cover upgrades will also address waste discovered outside the boundaries of the landfill.
Areas of the landfill where surface water ponding has occurred will be regraded to promote positive
drainage of surface water off the landfill. .Areas where erosion has occurred will be repaired with cover
soil which will be re-vegetated to prevent future erosion. These areas will be inspected and evaluated to
determine whether specific additional surface water management controls are needed. Woody plants
from the small tree-covered portion of the landfill will bfe removed via flush cutting or controlled
application of herbicides, and new cover soil will be re-vegetated. The steeper areas of the landfill
(exceeding 15 degrees slope angle) will be evaluated for slope stability.
A comprehensive inspection, maintenance and monitoring (O&M) plan will be implemented to assure that
the upgraded cover will continue to function effectively in the future.

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2. Enhanced Landfill Gas Extraction
The 1990 ROD requires installation of a methane collection system, and treatment of the methane using a
flare. Pursuant to the 1990 ROD, the approved design provides for methane to be collected through a
series of gas extraction wells. The system is designed to control migration of methane. In the currently
approved landfill cap/methane control design, 16 wells are proposed in order to capture methane gas
generated by the landfill. The Alternate Source Control Remedy proposes the following enhancements:
• The installation of additional and deeper wells for the removal of VOCs and control of methane;
• Increased blower and flare capacities;
• Iterative design and installation of the well network;
• Innovative site characterization and optimization of well design and locations using a combination
of recently developed technology, site reconnaissance (e.g.. soil borings), and results of previous
studies;
• Installation of landfill gas monitoring points;
• Optimization of ELGE well operation using techniques such as flow balancing, staggering
operation of wells, and cycling of wells;
• Condensate collection and treatment by injection into the flare; and
• Evaluation of bioventing as a future modification.
The Alternate Source Control Remedy will extract VOCs and methane gas from the landfill. The removal
of the landfill gas (methane) will help to further remove some of remaining VOCs from the landfill waste.
Each of these enhancements is farther described below and a conceptual design for the initial ELGE
system is presented in Figure 2. The initial design is based upon the approved methane management
system design with additional ELGE wells in the area of the pilot test. The proposed location for the
blower and flare building is south of the current groundwater treatment building. Alternate locations
adjacent to the landfill may be considered. Also, the location and number of wells may change during the
ongoing design process. During the design of the selected remedy, an evaluation will be performed to
determine the number and location of the ELGE wells, associated monitoring wells and leachate
monitoring points.
System Expansion
The installation of additional gas extraction wells will provide increased VOC removal in areas with
elevated contaminant concentrations. Each well shall be equipped with its own flow control valve, so that
extraction vacuums and flow rates can be individually monitored and modified. To some extent, gas
removal can be increased by increasing the flow rate at an individual well, thereby expanding the gas
capture zone. However, potential infiltration of ambient air through the soil cover and sidewalls of the
landfill may limit the practical radius of influence of a well.

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The horseshoe shape of the landfill contributes to this constraint, due to the proximity of any point in the
landfill to the landfill walls. Excessive air infiltration is undesirable for three reasons:
1. The current oxygen poor/methane rich environment of the landfill supports microbes that degrade
the waste within the landfill, inducing oxygen into the landfill may disrupt this degradation process;
2. Excessive oxygen may cause the landfill temperature to rise and increase the potential for fire
within the landfill: and.
3. The introduction of air into the system will add volume and dilute the gas being collected and
treated. The consequent reduction in the heating value of the gas may necessitate the use of
supplemental fuel at the flare.
Therefore, the provision of additional wells will allow increased extraction rates while reducing the
intrusion of ambient air into the landfill and the gas extraction system. The pilot test showed that 25
standard cubic feet per minute can be sustained in an extraction well without excessive ambient air
infiltration. The blower and flare system shall be approriatelv sized to extract and treat the increased
VOC removal.
System Design
The iterative approach to well installation shall consist of initially installing a group of methane
management wells which will likely be similar to the currently approved design that included a total of 16
methane management wells. Additionally, the first phase (as shown in Figure 2) shall involve additional
ELGE wells in the vicinity of the pilot test location and other areas determined to contain elevated levels
of VOCs. Subsequent phase(s) may involve additional wells or increased extraction rates based on the
first phase.
Innovative Site Investigation
The use of enhanced site investigation techniques will allow the study of gas flows and VOC
concentrations with depth in each well. This will yield important information as to the composition and
physical characteristics of the waste to be treated. Other relevant information, such as the previous soil
gas grid survey for methane and any available historical records, may yield information about VOC
source areas and the types, locations, and deposition practices for waste. This information will guide the
design of subsequent phases in terms of locating VOC and/or methane removal wells, targeting specific
areas within the waste, and optimizing well depths in order to enhance methane/VOC removal while
limiting air infiltration.
System Optimization
Gas flow rates and vacuums shall be monitored and balanced in wells in order to enhance the methane
and VOC content in the extracted gas, thereby increasing the overall system efficiency.

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Additional measures may include staggering the operation of wells or cycling wells on and off. Staggered
operation would allow the temporary or permanent shutdown of wells that have substantially completed
VOC and or methane removal in their associated capture zones. Cycling would allow the entire well field
or portions thereof to be temporarily shut off in order to allow additional diffusion of VOCs into the landfill
gas for subsequent removal.
Condensate Treatment
The gas treatment flare is proposed to be equipped with a condensate injection system. Such systems are
operating at about 15 sites in the United States, most of which are landfills. Using compressed air, the
condensate is injected via a nozzle into the flare, slightly above the flame level. Recent stack test data
indicate that the addition of condensate injection to an enclosed flare has no adverse effect on the
operation of the flare or the emissions from the flare. During the design phase, estimated VOC emissions
from the flare shall be calculated based on expected flare destruction efficiency and the concentrations of
VOCs in the extracted gas and condensate measured during the pilot test.
Evaluation of Bioventing
The use of bioventing as an additional innovative system enhancement will be considered as operational
experience is gained. Bioventing is an innovative technology that has been employed mostly at petroleum
contaminated sites and involves the use of existing subsurface microorganisms to biodegrade orgamcs
under oxygen rich conditions. The process typically involves the addition of air (oxygen), nutrients, and
water to the system. It is most often used at sites contaminated with mid-weight petroleum products, since
lighter products will volatilize easily under SVE and heavier products tend to take longer to biodegTade. If
operational data indicates bioventing may be applicable, it will be evaluated.
3. Monitoring to determine the impact of the ELGE system on the quality of the leachate
within the landfill
ELGE extraction wells shall create capture zones where the VOC contamination is removed from the
landfill and shall prevent migration of VOCs to the groundwater beneath the landfill. Leachate monitoring
points shall be installed in the landfill to monitor the impact of the ELGE system on the quality of the leachate
within the landfill. The ELGE system shall reduce VOC contamination in the leachate within the landfill to the
selected performance standards for the contaminants of concern (COC). The performance standards for
the COC are listed in Table 1.
4. Upgrades to the Storm Water Management System
Surface water drainage improvements, such as channels on and around the landfill, shall be designed and
constructed to convey the peak runoff from a 25-year 24-hour storm event safely away from the landfill
to protect the cover and reduce infiltration in and around the landfill.

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Over 2.000 linear feet of additional rip-rap lined channel and an additional detention basin, or similar
measures to be evaluated during design, would be placed on the southern side of the Site. The surface
water drainage improvements will also address runoff onto adjacent properties.
5. Maintenance of the existing fence.
The existing fence shall be maintained. However, in areas where the limits of the waste in the landfill may
extend beyond the existing fence, the fence shall be relocated to the true perimeter of the landfill.
6. Use of institutional controls on the landfill property.
The 1990 ROD called for institutional controls on the Site without specifying the exact
institutional controls were to be placed. This Amendment specifies that the institutional
to the landfill itself and not extend to other portions of the Site, including those portions
residential purposes.
7. Post-Construction Monitoring
As part of the remedy, an Operations and Maintenance Plan (O&M) shall be developed. Monitoring
components of the O&M Plan shall include annual inspections of the upgraded soil cover to determine the
adequacy of erosion controls, surface water runoff controls, and vegetation. The O&M Plan shall also
include maintenance of the vegetative cover, including mowing and seeding as necessary. In addition, the
O&M plan shall include details for maintaining and monitoring the ELGE system to ensure that all systems
are operating properly. Additional monitoring will be conducted on the leachate near the ELGE wells to
evaluate the effectiveness of the Alternate Source Control Remedy. For the ELGE system, monitoring
shall include the following components:
1. Monitoring at individual extraction wells and monitoring points, as appropriate, for vacuum, flow rate,
temperature, and concentrations of methane, oxygen, carbon dioxide, nitrogen, water content, and
individual VOC constituents;
2. Sampling of the combined extracted gas for analysis of individual VOC constituents and methane;
3. Flare VOC emissions based on calculations using the analyzed influent stream and the destruction
efficiency of the flare;
4. Regular inspections and maintenance to ensure that the flare is operating at its designed destruction
capacity;
5. Condensate generation rates, total accumulation, and injection rates to the flare;
6. VOC analysis of condensate;
7. Calculated mass removals of VOCs; and
8. Monitoring of leachate within the landfill.
location where the
controls be limited
of the Site used for

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Remedial Action Objectives
The selected remedy shall actively remove VOCs from the landfill. The main goals of this remedy arc to:
1) prevent migration of site-related contaminants from the landfill that could result in groundwater
concentrations in excess of performance standards; 2) prevent future releases of contamination into
surface water and sediments; 3) prevent direct contact with contaminated soil and waste; and 4) control
methane build-up and migration in the landfill. In combination with the planned remedial actions selected in
the 1990 ROD (that are not being changed by this Amendment), this remedy will satisfy the remedial
objectives for this Site and be effective in capturing, containing, and cleaning up the contaminants in the
landfill and the groundwater to the performance standards, while protecting human health and the
environment.
The Alternate Source Control Remedy and previous remedial actions shall be evaluated during each Five
Year Review.
In addition, this Amendment includes performance standards for the Alternate Source Control Remedy.
Each of the components of the remedy and its performance standards are described in detail below.
Monitoring of each performance standard shall be conducted as set forth below. A detailed schedule for
the performance standard monitoring shall be included in the remedial design.
B. Performance Standards
1. ELGE
The installation of an ELGE system is expected to significantly increase V'OC removal rates over
groundwater extraction alone. The VOC concentrations observed during the pilot test, however, are not
necessarily representative of the entire landfill, and it is, therefore, not appropriate to establish a VOC
removal performance standard based on those values. Further, it is expected that the rate of VOC
removal will decline over time as the source is depleted. The following performance standards for the
cessation of enhanced VOC removal (continued system operation for methane migration control shall be
required, see Methane Extraction below):
VOC Removal
Based on baseline sampling of monitoring points prior to startup, the ELGE system shall achieve a 90%
reduction2 in concentration of selected target VOC compounds, at the monitoring points, at least 48 hours
after the extraction system has been shut down to allow for concentration rebound.
2Not to be less than the Practical Quantitation Limits (PQLs)

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Leachate Monitoring
ELGE extraction wells shall create capture zones where the VOC contamination is removed from the
landfill in vapor phase and shall prevent migration of VOCs from the landfill to the groundwater in excess
of performance standards. Leachate monitoring points shall be installed in the landfill near ELGE wells to
monitor the impact of the ELGE system on the quality of the leachate within the landfill. The ELGE
system shall reduce VOC contamination in the leachate within the landfill to the selected performance
standards for the contaminants of concern (COC). The performance standards for the COC are set forth
in Table 1.
The potential impact of leachate on groundwater contaminant levels was assessed by USEPA via
modeling. USEPA's BIOCHLOR model was used to estimate acceptable leachate concentrations at
anticipated ELGE leachate monitoring points. The goal was to determine leachate concentrations that
would not result in exceedances of the groundwater performance standards at the points of compliance.
Lack of field data regarding leachate quality and quantity required that several assumptions be made in
the modeling effort. These include, but are not limited to. assumptions: that I) no unsaturated zone exists
between leachate and the groundwater; 2) groundwater monitoring data from Well K.1 is indicative of
leachate concentrations in the landfill; and 3) there will be a two hundred foot distance from the ELGE
leachate monitoring points to the point of compliance. Field conditions shall be investigated and evaluated
during the remedial design. To the extent that actual conditions differ from the modeling assumptions, it
may be appropriate to re-evaluate the leachate performance standards Therefore, after four quarters of
field data have been collected, this data may be re-entered into the BIOCHLOR model (or substantially
similar model) to develop revised leachate performance standards. Revised leachate performance
standards at ELGE monitoring points, based on the above field data and modeling, shall be subject to the
approval of EPA in consultation with PADEP. Leachate performance standards may be made more
stringent, if EPA determines, based on reasons other than failure to meet groundwater standards, that
more stringent standards are necessary to protect human health or the environment.
The leachate performance standards apply only to leachate. The groundwater is subject solely to
performance of the groundwater remedy and attainment of groundwater performance standards at points
of compliance. Based on field observations made during the pilot tests and on historical data, in certain
portions of the landfill which require treatment using ELGE, measurable leachate may not be present at
the leachate monitoring points. To the extent no measurable leachate is present at leachate monitoring
points, leachate performance standards may be waived at those locations. EPA's decision to waive
leachate performance standards shall be based upon the results from the monitoring network established
during design. Further, if after field investigation, EPA determines that it is not possible to distinguish
leachate from groundwater, the leachate performance standards may be waived. In no event will ELGE
be required to address source areas located below the water table.
Leachate samples shall be collected and analyzed quarterly in year one and semi-annually thereafter.
Based upon the results, collection and analysis of these data may be modified as

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determined by EPA, in consultation with PADEP. The monitoring locations shall be determined by EPA,
in consultation with PADEP, during future design activities. The ELGE system shall operate until
performance standards are achieved for all selected COCs at the leachate monitoring points.
The preceding performance standards may be used for cessation of enhanced VOC removal in individual
wells, clusters of wells, or ultimately the entire ELGE system.
2.	Methane Extraction
The 1990 ROD stated that as part of the selected remedy, "an active gas extraction system would be
installed in compliance with 25 PA Code Section 273.292." For the methane extraction and control portion
of the ELGE system, a demonstration of compliance with the following state standards is required:
Following shutdown of the system or portions thereof, four consecutive sets of methane monitoring at the
landfill perimeter, spaced no less than three months apart, show that:
a.	25% of the lower explosive limit for methane is not exceeded within nearby structures; and;
b.	The lower explosive limit for methane is not exceeded at the landfill boundaries.
The "nearby structures" in this case will comprise existing on-site buildings and the Groundwater
Treatment Plant building.
3.	Soil Cover
The Alternate Source Control Remedy requires upgrading the existing soil cover to a minimum 2 foot
thickness across the landfill with soils of similar properties to those of the existing cover. Analyses by
Golder on the existing cover indicate that the average permeability of current cover soils is 2.2 x 10'6
cm/sec. At a minimum, areas having a thickness of less than two feet shall be upgraded to 18 inches of
soils having an average permeability no greater than 2.2 X 10-6 cm/sec, and a maximum permeability no
greater than two times this value, overlain with a minimum 6 inch erosion layer.
4.	Surface Water/Drainage
Surface water drainage improvements, such as channels on and around the perimeter of the landfill, shall
be designed and constructed to convey the peak runoff from a 25-year 24-hour storm event safely away
from the landfill to protect the cover and reduce infiltration in and around the landfill.

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5. Post-Construction Monitoring
As part of the Remedial Action, an Operations and Maintenance Plan (O&M) shall be developed.
Monitoring comments of the O&M Plan shall include annual inspections of the upgraded soil cover to
determine the adequacy of erosion controls, surface water runoff controls, and vegetation. The O&M
Plan shall also include maintenance of the vegetative cover, including mowing and seeding as necessary.
For the ELGE system, monitoring would include the following components:
1.	Monitoring at individual extraction wells and/or monitoring points, as appropriate, for vacuum, flow
rate, temperature, and concentrations of methane, oxygen, carbon dioxide, nitrogen, water content,
and individual VOC constituents to evaluate compliance with performance standards;
2.	Sampling of the combined extracted gas for analysis of individual VOC constituents and methane;
3.	Flare VOC emissions based on calculations using the analyzed influent stream and the destruction
efficiency of the flare;
4.	Regular inspections and maintenance to ensure that the flare is operating at its designed destruction
capacity;
5.	Condensate generation rates, total accumulation, and injection rates to the flare;
6.	VOC analyses of condensate;
7.	Calculated mass removals of VOCs; and
8.	Monitoring of leachate within the landfill.
6. Periodic Monitoring and ELGE System Shutdown
Once the ELGE system is operational and functional, individual ELGE extraction wells, ELGE monitoring
points, and leachate monitoring points shall be sampled and analyzed quarterly in year one and semi-
annually thereafter
Based upon the results, collection and analysis of these data may be modified as determined by EPA, in
consultation with PADEP. Monitoring shall be conducted at the ELGE extraction wells, nearby ELGE
monitoring points, and leachate monitoring points to provide information as to the effectiveness of the
ELGE system. The monitoring locations will be determined by EPA during future design activities.
The decision to discontinue operation of an individual ELGE extraction well, or to discontinue operation of
the entire ELGE system, shall be made as follows:
a. If an ELGE extraction well, related ELGE monitoring points and leachate monitoring points all meet
the respective performance standards during two consecutive semi-annual

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monitoring events, the operation of that particular ELGE extraction well may be temporarily
discontinued, upon approval by EPA in consultation with PADEP, and subject to the confirmatory
monitoring requirements detailed in subparagraph b below. (Continued system operation for
methane migration control shall be required, see Methane Extraction above.)
b.	Once an ELGE extraction well, related ELGE monitoring points, and leachate monitoring points all
meet the respective performance standards for two consecutive semi-annual monitoring events,
monitonng of these sampling locations shall increase to quarterly. If the performance standards
continued to be achieved for eight consecutive quarters and no statistically significant trends are
observed in the data indicating a future exceedance of the performance standards could occur,
then that particular ELGE extraction well may shut down, upon approval by EPA in consultation
with PADEP. If at anytime during the eight quarters of sampling, the ELGE system fails to
achieve performance standards or statistically significant trends are observed in the data
indicating a future exceedance of the performance standards could occur, then the ELGE
extraction well shall be reinitiated. (Continued system operation for methane migration control
shall be required, see Methane Extraction above.)
c.	The system may be shut down in a phased manner as portions of the ELGE system achieve
compliance with performance standards. (Continued system operation for methane migration
control shall be required, see Methane Extraction above.) A long-term monitonng program, which
will be approved by EPA, shall be instituted.
C. Contingent Remedies
In order to optimize the efficiency of the ELGE Remedy additional measures to augment or supplement
the ELGE Remedy may be implemented. Such measures may include, but are not limited to: installing
additional ELGE wells, expanding the blower capacity, balancing the extraction flow rates at individual
wells, and modifying the off-gas treatment system.
In the event that ELGE Remedy fails to meet the performance standards specified above, a Contingent
Remedy shall be implemented at the Site. The Contingent Remedy shall be equally protective of human
health and the environment as the ELGE Remedy and shall be either an Enhanced Containment Remedy
or an Enhanced In-situ Treatment Remedy. The performance data that are used to determine ELGE
Remedy failure shall also be used, in conjunction with other relevant data, to determine which of the
Contingent Remedies below will be implemented. A short description of each of the Contingent Remedies
and their anticipated performance at the Site is provided below.

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Enhanced Containment Remedy
The first potential Contingent Remedy involves enhanced containment. Pursuant to this Contingent
Remedy, a further upgrade to the landfill closure cover would be constructed in areas of the landfill that
receive most infiltration of storm water, in order to reduce the quantity of leachate generated from the
landfill. This shall be achieved by placing a geosynthetic membrane overlain by a drainage layer and
vegetated layer on the top portion of the landfill where slopes are less than 15 percent and infiltration is
potentially greatest. Construction of such a cover shall reduce infiltration by approximately 75% of the
present values. The methane management system shall continue to function as part of this contingent
remedy.
Enhanced In-Situ Treatment Remedy
A second Contingent Remedy involves enhanced in-situ treatment. Pursuant to this Contingent Remedy,
enhanced in-situ treatment will be achieved by leachate recirculation and/or addition of water and air to
the landfill. Leachate shall be extracted from the existing ELGE wells or other collection systems
constructed expressly for this purpose. This approach is expected to result in enhanced biodegradation of
VOCs in the landfill. The methane management system shall continue to function as part of this
Contingent Remedy as long as required.
D. Estimated Cost
Table 2 provides the estimated cost for implementing all of the components for the Alternate
Source Control Remedy. The total estimated present worth cost for the remedy is 55,500,000.
E. Explanation of ARARs
Section 121 (d) ofCERCLA requires that remedial actions at CERCLA sites at least attain
legally applicable or relevant and appropriate cleanup standards, standards of control, and other
substantive environmental protection requirements, criteria or limitations promulgated under Federal or
State law, which are collectively referred to as "ARAils", unless such ARARs are waived under
CERCLA§ 121(d)(4).
"Applicable" requirements are those cleanup standards, standards of control, and other substantive
environmental protection requirements, criteria or limitations promulgated under Federal or State law that
specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site. "Relevant and appropriate" requirements are those requirements that,
while not legally "applicable", address problems or situations sufficiently similar to those encountered at
the site that their use is well suited to the particular site. Only those State standards that are promulgated,
are identified by the State in a timely manner, and are more stringent than federal requirements may be
applicable or relevant and appropriate. ARARs may relate to the substances addressed by the remedial
action

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(chemical-specific), to the location of the site (location-specific), or the manner in which the remedial
action is implemented (action-specific).
In addition to applicable or relevant and appropriate requirements, the lead agency may, as
appropriate, identify other advisories, criteria, or guidance to be considered for a particular release. The
"'to be considered" (TBC) category consists of advisories, criteria, or guidance that were developed by
EPA, other federal agencies or states that may be useful in developing CERCLA remedies.
The identification of ARARs in this Amendment supplements the discussion of ARARs
developed in the FS, the September 1990 ROD, and the 1999 ROD Amendment for Groundwater. The
ARARs identified in this .Amendment relate only to the response actions addressed in this document;
ARARs relating to response actions selected in the 1990 ROD or the 1999 ROD Amendment for
Groundwater but not addressed in this Amendment are not discussed. Furthermore, ARARs identified in
the 1990 ROD or the 1999 ROD Amendment for Groundwater, are incorporated by reference herein
except that Pennsylvania Municipal Waste Landfill Regulations. Pennsylvania Code Title 25, Section
273.234(a)(l),(2),(d) which relates to municipal landfill cap requirements does not apply to the ELGE
Remedy or the Enhanced In Situ Treatment Contingent Remedy. This Section does apply to the Enhanced
Containment Contingent Remedy. Reference should be made to the discussion of Site ARARs in the 1990
ROD and the 1999 ROD .Amendment for Groundwater for a complete discussion of all chemical-,
location- and action-specific ARARs for the Site.
The following discussion identifies the ARARs and TBCs identified by EPA (after submission to
the Commonwealth of Pennsylvania for review and comment) relating to the remedy identified herein.
On-site actions (i.e., within the areal extent of contamination and all suitable areas in very close proximity
to the contamination necessary for implementation of the response action) need comply only with the
substantive aspects of ARARs. not with the corresponding administrative requirements (e.g., consultation,
issuance of permits, documentation, record keeping and enforcement).
Action Specific ARARs
a. Air Resources, Pennsylvania Code, Title 25, Sections 121.1, 121.7, 121.9, 123.1, 123.2, 123.21,
123.31, 123.41-123.43. and 127.1 which are applicable to fugitive dust control, use of Best Available
Technology (BAT), emissions of specific air pollutants. These regulations are applicable to the air
pollution control measures to be employed during work associated with the upgrading of the soil cover
as part of the Alternate Source Control Remedy or the Contingent Remedies, as well as emissions
from the ELGE system or the Contingent Remedy treatment system.
b. Pennsylvania Municipal Waste Landfill Regulations, Pennsylvania Code Title 25, Sections
273.234(a)(3),(c),(e), 273.235, 273.236, 273.241-244 which are applicable to the work

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associated with the upgrading the soil cover as part of the Alternate Source Control Remedy or the
Contingent Remedies.
c. Pennsylvania Municipal Waste Landfill Regulations, Pennsylvania Code Title 25, Section 273.292.
This regulation is applicable to the operation of the Alternate Source Control Remedy as a methane
control system and to the methane control system that is part of the Contingent Remedies.
d. Erosion and Sedimentation Controls, Pennsylvania Code Title 25, Sections 102.1, 102.2, 102.4, 102.11,
102.22 which are applicable to work associated with the upgrading of the soil cover and other earth
moving activities conducted during installation of the Alternate Source Control Remedy or the
Contingent Remedies.
To Be Considered (TBO
a. Pennsylvania's Erosion and Sediment Control Manual, dated January 1996, sets standards for
erosion and sediment control associated with the upgrading of the soil cover and other earth moving
activities conducted during installation of the Alternate Source Control Remedy or the Contingent
Remedies.
F. Five-year Reviews
Five-year reviews shall be conducted pursuant to Section 121(c) of CERCLA U.S.C. Section 9621
(c) and as provided in OSWER Directive 9355.7-02. Structure and Components of Five-Year Reviews,
May 23. 1991, and OSWER Directive 9355.702A, Supplemental Five-Year Review Guidance. July 26,
1994 to assure that the remedy continues to protect human health and the environment.
V. EVALUATION OF THE ALTERNATE SOURCE CONTROL REMEDY AND THE
CONTINGENT REMEDIES USING THE NINE NCP CRITERIA
The ROD Remedy, the selected Alternate Source Control Remedy, and the selected Contingent
Remedies have been evaluated according to the nine criteria in the NCP 40 C.F.R. 300.430(e)(9) as set
forth in "Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA"
(EPA, October 1988), and "Guidance on Preparing Superfund Decision Documents: The Proposed
Plan, The Record of Decision, Explanation Significant Differences, and the Record of
Decision Amendment " (EPA/540/6-89/007, July 1989 Interim Final). The alternative described in this
Amendment was evaluated using the nine criteria set forth in 40 C.F.R. § 300.430(e)(9)(iii), as a
supplement to the evaluation performed in connection with the 1990 ROD, as amended in June 1999.
These nine criteria can be further categorized into three groups: threshold criteria, primary balancing
criteria, and modifying criteria, as follows:

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Threshold Criteria
•	Overall protection of human health and the environment
•	Compliance with applicable or relevant and appropriate requirements (ARARs)
Primary Balancing Criteria
•	Long-term effectiveness
•	Reduction of toxicity, mobility or volume through treatment
Short-term effectiveness
Implementability
Cost
Modifying Criteria
•	Community Acceptable
•	State Acceptance
These evaluation criteria relate directly to requirements in Section 121 of CERCLA, 42 U.S.C. § 9621.
Threshold criteria must be satisfied in order for a remedy to be eligible for selection. Primary balancing
criteria are used to weigh major trade-offs between alternatives. Acceptance by the State and
Community are modifying criteria formally considered after public comment is received on the PRAP. A
discussion of each criterion relative to both the 1990 ROD Cap Remedy, the Alternate Source Control
Remedy and the Contingent Remedies is presented below.
Overall Protection of Human Health and the Environment
The overall protectiveness criterion evaluates whether or not an alternative provides adequate
protection to human health and the environment by eliminating, conn-oiling or reducing the current and
potential exposures to levels established as remediation goals.
Both the 1990 ROD Cap Remedy and Alternate Source Control Remedy are expected to achieve
overall protection of human health and the environment The 1990 ROD Cap Remedy, construction of an
impermeable cap, would reduce dermal exposure risks and groundwater contamination through
containment of the waste.
In combination with the other components of the 1990 ROD, as amended on June 25, 1999, the
Alternate Source Control Remedy is expected to achieve overall protection of human health and the
environment because removal and treatment of VOCs from the landfill will effectively prevent the
migration of VOCs from the landfill that could result in groundwater concentrations in excess of
performance standards and, thereby, provide control of the source. Further, removal and treatment of
VOCs in the gas phase from the landfill will remove these contaminants as a potential source of
contamination of other pathways.

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The Contingent Remedies, in combination with the groundwater collection and treatment remedy, will
also provide protection by enhancing containment or treatment of contaminants so as to prevent migration
that could result in groundwater concentrations in excess of cleanup standards.
The 1990 ROD Cap remedy and the Alternate Source Control Remedy are protective of human
health and the environment. The Alternate Source Control Remedy relies upon removal of the source
whereas the 1990 ROD Cap Remedy relies upon source containment through the installation of the
impermeable cap.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
The compliance with ARARs criterion evaluates whether the alternatives would meet all of the
applicable or relevant and appropriate requirements of other environmental statues and/or provide grounds
for involving a waiver. Under Section 121 (d) of CERCLA, 42 (i.S.C. Section 9621 (d), remedial actions
must attain ARARs unless such ARARs may be waived under CERCLA Section 121 (d) (4), 42 U.S.C.
Section 9621 (d)(4).
The following discussion identifies the ARARs and TBCs identified by EPA (after submission to the
Commonwealth of Pennsylvania for review and comment) relating to the remedy identified herein. On-
site actions (i.e., within the areal extent of contamination and all suitable areas in very close proximity to
the contamination necessary for implementation of the response action) need comply only with the
substantive aspects of ARARs, not with the corresponding administrative requirements (e.g., consultation,
issuance of permits, documentation, record keeping and enforcement).
Action Specific ARARs
a. Air Resources, Pennsylvania Code, Title 25, Sections 121.1, 121.7, 121.9, 123.1. 123.2, 123.21,
123.31. 123.41-123.43. and 127.1 which are applicable to fugitive dust control, use of Best Available
Technology (BAT), emissions of specific air pollutants. These regulations are applicable to the air
pollution control measures to be employed during work associated with the upgrading of the soil cover
as part of the Alternate Source remedy of the Contingent Remedies, as well as emissions from the
ELGE system or the Contingent Remedy treatment system.
b. Pennsylvania Municipal Waste Landfill Regulations, Pennsylvania Code Title 25, Sections
273.234(a)(3),(c),(e), 273.235, 273.236, 273.241-244 which are applicable to the work associated with
the upgrading of the soil cover as part of the Alternate Source Control Remedy or the Contingent
Remedies.
c. Pennsylvania Municipal Waste Landfill Regulations, Pennsylvania Code Title 25, Section
273.292. This regulation is applicable to the operation of the Alternate Source Control

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Remedy as a methane control system and to the methane control system that is part of the Contingent
Remedies.
d. Erosion and Sedimentation Controls, Pennsylvania Code Title 25, Sections. 102.1, 102.2, 102.4,
102.11, 102.22 which are applicable to work associated with the upgrading of the soil cover and
other earth moving activities conducted during installation of the Alternate Source Control
Remedy or the Contingent Remedies.
To Be Considered (TBC)
a. Pennsylvania "s Erosion and Sediment Control Manual, dated January 1996, sets standards for
erosion and sediment control associated with the upgrading of the soil cover and other earth moving
activities conducted during installation of the Alternate Source Control Remedy or the Contingent
Remedies.
The selected remedy and the contingent remedies will comply with all relevant ARARs set forth in this
ROD Amendment, and the 1990 ROD, as amended on June 25, 1999.
Long- Term Effectiveness and Permanence
The long-term effectiveness criterion evaluates the long-term protection of human health and the
environment over time, once the remedial action goals have been achieved. It focuses on the magnitude
of residual risk and the adequacy and reliability of controls of the alternatives.
The 1990 ROD Cap Remedy and the Alternate Source Control Remedy provide for long-term
effectiveness equally with respect to contact with contaminated landfill waste and soils.
Both remedies include the soil cover, which provides long-term protection against contact with
contaminated landfill waste and soils.
The impermeable cap required by the 1990 ROD Cap Remedy would reduce the amount of VOC
contamination reaching the groundwater in the short-term but would not significantly reduce the mass of
VOCs at the Site over time since most of the VOCs would remain under the cap.
The Alternate Source Control Remedy would be more effective in the long-term than the 1990 ROD
Cap Remedy for several reasons. The Alternate Source Control Remedy provides long-term and
effective protection of human health and the environment because it provides for the effective removal
and treatment of VOC from the landfill, thereby, eliminating these compounds as potential contaminants.
In addition, operation, inspection, monitoring, and maintenance will be regularly conducted to ensure the
components of the Alternate Source Control Remedy perform effectively in the future.

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Thus, because more VOCs would ultimately be removed from the landfill under the Alternate Source
Control Remedy, it provides greater long-term effectiveness and permanence. Additionally, the landfill
would be covered with 2 feet of soil and deed restrictions placed on those areas to control future contact
with contaminated landfill material. The overall time frame to restore the ground water is not expected to
be significantly different for the 1990 ROD and the Alternate Source Control Remedy.
The Contingent Remedies also provide long-term and effective protection by enhanced containment
or treatment of VOCs.
Reduction of Toxicity, Mobility, or Volume, Through Treatment
This criterion evaluates the performance of the alternatives to reduce the toxicity, mobility, and
volume of waste by assessing the degree of irreversibility and the types and quantity, of residuals remaining.
Under the 1990 ROD Cap Remedy, the mobility of VOCs in the landfill waste would be decreased by
placement of the impermeable cap. The 1990 ROD Cap Remedy did not address the CERCLA statutory
preference for treatment of the waste as, at the time of the ROD, it was determined to be impracticable.
The Alternate Source Control Remedy satisfies the CERCLA statutory preference for treatment
technologies to be used in a remedial action to a much greater extent than does the impermeable cap
source control remedy selected in the 1990 ROD. The removal and treatment of VOCs via the ELGE
system will provide a significant reduction of the toxicity, mobility and volume of contaminants within the
landfill. In combination with the groundwater remedy the Alternate Source Control Remedy is expected to
dramatically reduce the concentration of contamination in the groundwater to levels that at least meet
groundwater clean up standards.
Thus, the Alternate Source Control Remedy is superior to the 1990 ROD Cap Remedy in terms of
reduction in toxicity. The Alternate Source Control Remedy more effectively reduces volume through
treatment while allowing a limited, but controlled increase in mobility.
The Contingent Remedy which utilized the Enhanced In-Situ Treatment Remedy option satisfies the
statutory preference for treatment. The Enhanced Containment Remedy in combination with the
groundwater collection and treatment remedy will satisfy the statutory preference for treatment.
Short-Term Effectiveness
Short-term effectiveness evaluates the alternatives against the period of time needed to achieve
protection of human health and the environment and any adverse impacts that may be posed during the
construction and implementation period, until clean-up goals are achieved.

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The Alternate Source Control Remedy involves a limited amount of heavy construction, as a result,
there is a much reduced level of environmental impact, quality of life impact and aesthetic concerns for
nearby residents, and worker health and safety risks associated with the Alternate Source Control
Remedy compared to the 1990 ROD Cap Remedy. The remaining impacts are expected to be low level
and short-term and can be properly controlled during construction so as to not anticipated to result in
adverse long-term effects.
The 1990 ROD Cap Remedy, construction of an impermeable cap, would likely take longer to achieve
protectiveness due to the estimated construction time for the cap. It would also involve more intrusive
activities during construction.
The Enhanced Containment Contingent Remedy will involve greater short-term risks than the
Alternate Source Control Remedy due to the greater extent of heavy construction. The Enhanced In-Situ
Treatment Contingent Remedy will minimize short term impacts in the same manner as the Alternate
Source Control Remedy.
Implementability
The Implementability evaluation criterion consists of several sub-components, including those which
evaluate the compatibility of remedial measures with site conditions, availability of materials and services,
ability to undertake further remedial actions if necessary, and regulatory considerations.
The implementation of the Alternate Source Control Remedy is considered to be straightforward. The
cover upgrades, storm water controls, vegetation repairs, and landfill gas extraction and treatment
technologies are well-established practices and the services and materials to construct these facilities are
standard in the industry and readily available. Although aspects of ELGE are considered innovative, the
recent pilot test at the Site confirms that it can be effectively installed and operated. Other innovative
aspects of the project, such as the use of PneuLog™ and evaluation of bioventing, may further enhance
the speed and success of the remedy but do not affect the overall Implementability. Overall, no technical
or administrative problems are envisioned which would adversely affect the construction or schedule for
implementation of this alternative. Similarly, long-term operation and maintenance requirements can be
easily performed.
Even though there are engineering concerns related to the implementation of the Alternate Source
Control Remedy, they are far less complicated than the 1990 ROD Cap Remedy which requires the
installation of an impermeable cap. Based on the above, the Alternate Source Control Remedy is
preferred on the basis of Implementability.

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No technical or administrative problems are envisioned which would adversely affect the construction
or schedule for implementation of the Contingent Remedies and long-term operation and maintenance can
be readily performed.
Cost
The cost evaluation criterion considers the estimated cost for the capital and operation and
maintenance (O&M) of the alternatives on a present worth basis. Table 2 provides the estimated cost for
implementing all of the components for the Alternate Source Control Remedy. The total estimated present
worth cost for this alternative is 55.500,000.
The remedy is cost-effective in providing overall protection in proportion to cost, and meets all other
requirements of CERCLA. Section 300.430(f) (ii) (D) of the NCP requires EPA to evaluate
cost-effectiveness by comparing alternatives which meet the threshold criteria - protection of human
health and the environment and compliance with ARARs - against three additional balancing criteria:
long-term effectiveness and permanence; reduction of toxicity, mobility or volume through treatment; and
short-term effectiveness. The selected remedy meets these criteria and provides for overall effectiveness
in proportion to its cost.
State Acceptance
This criterion indicates whether the state concurs with, opposes, or has no comment on the preferred
remedy. PADEP has assisted EPA in the review of the reports related to the Alternate Source Control
Remedy. PADEP agrees with the approach of EPA's selected amendments to the 1990 ROD as
described in the Declaration above. The Maryland Department of the Environment (MDE) has also
reviewed and provided comments to EPA on this Amended ROD and agrees with the approach,
however, MDE has indicated that it has no jurisdiction in regards to the ROD Amendment for the
Alternate Source Control Remedy.
Community Acceptance
A public meeting on the PRAP was held on June 22, 2000 in Abbottstown, Pennsylvania. Comments
received orally at the public meeting and in writing during the public comment period are referenced in the
Responsiveness Summary attached to this Amendment. The public comment period originally began on
June 5, 2000 and was to close on July 5, 2000, however, EPA extended the comment period to August 4,
2000 based on a request from a member of the community. The comments indicated that the residents do
not object to the implementation of the Alternate Source Control Remedy.
Summary of the Nine Criteria Evaluation
Based upon the above evaluation, this remedy in combination with the planned remedial actions
selected in the 1990 ROD (that are not being changed by this Amendment), will satisfy

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25
the remedial objectives for this Site and be effective in capturing, containing, and cleaning up the
contaminants in to landfill and the groundwater to the performance standards, while protecting human
health and the environment.
VI. STATUTORY DETERMINATIONS
EPA has determined that the selected response action complies with the statutory requirements of
Section 121 of CERCLA, 42. U.S.C. § 9621. Considering the new information that has been developed
and the changes that have been made to the selected remedy, EPA believes that the remedy remains
protective of human health and the environment, complies with Federal and State requirements that are
applicable or relevant and appropriate to this Remedial Action, and is cost-effective. In addition, the
revised remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable for this Site.
A. Protection of Human Health and the Environment
In combination with the other components of the 1990 ROD. as amended on June 25, 1999, the
Alternate Source Control Remedy is expected to achieve overall protection of human health and the
environment because removal and treatment of VOCs from the landfill will effectively prevent the
migration of VOCs from the landfill that could result in groundwater concentrations in excess of
performance standards and, thereby, provide control of the source. Further, removal and treatment of
VOCs in the gas phase from the landfill will remove these contaminants as a potential source of
contamination of other pathways.
The Contingent Remedies, in combination with the groundwater collection and treatment remedy, will
also provide protection by enhancing containment or treatment of contaminants so as to prevent migration
that could result in groundwater concentrations in excess of cleanup standards.
B. Compliance ARARs
The selected Alternate Source Control Remedy and the Contingent Remedies will comply with all
relevant ARARs set forth in this ROD Amendment, and the 1990 ROD. as amended on June 25, 1999.
C. Cost-Effectiveness
The Alternate Source Control Remedy is cost-effective in providing overall protection in proportion to
cost, and meets all other requirements of CERCLA. Section 300.430(0 (ii) (D) of the NCP requires EPA
to evaluate cost-effectiveness by comparing alternatives which meet the threshold criteria - protection of
human health and the environment and compliance with AJIARS - against three additional balancing
criteria: long-term effectiveness and permanence; reduction

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26
of toxicity, mobility or volume through treatment; and short-term effectiveness. The selected remedy
meets these criteria and provides for overall effectiveness in proportion to its cost.
D.	Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized while providing the best balance among the other
evaluation criteria. The remedy selected in this Amendment, along with the previously selected measures,
in the 1990 ROD, as amended on June 25, 1999. provides a high degree of long-term effectiveness and
permanence reduces mobility and reduces risk to human health and the environment.
E.	Preference for Treatment as a Principal Element
The selected remedy satisfies the CERCLA statutory preference for treatment as a principal
element. The removal and treatment of VOCs via the ELGE system will provide a significant reduction of
the toxicity, mobility and volume of contaminants within the landfill. In combination with the groundwater
remedy the Alternate Source Control Remedy is expected to dramatically reduce the concentration of
contamination in the groundwater to levels that at least meet groundwater clean up standards.
The Contingent Remedy which utilizes public Enhanced In-Siru Treatment Remedy option satisfies
the statutory preference for treatment. The Enhanced Containment Remedy in combination with the
groundwater collection and treatment remedy will satisfy the statutory preference for treatment.
VII. PUBLIC PARTICIPATION
The PRAP was released for public comment as part of the Administrative Record file on June 5,
2000. The Administrative Record also includes the 1990 ROD, as previously amended on June 25, 1999,
and all documents that formed the basis for EPA's selection of the cleanup remedy in the 1990 ROD and
amendments. This Amendment and other related documents and the information upon which it is based
have been included in the Administrative Record file and the information repository for this Site. The
Administrative Record is available for public review at the locations listed below:
Hanover Public Library	U.S. EPA, Region III
Library Place	1650 Arch Street
Hanover, PA i7331	Philadelphia, PA 19103-2029
(717) 632-5183	(215) 814-3157

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The notice of availability of these documents was published in the Getty sburg Times on June 5, 2000.
A public meeting on the PRAP was held on June 22, 2000 in Abbottstown, Pennsylvania. Comments
received orally at the public meeting and in writing during the public comment period are referenced in the
Responsiveness Summary attached to this Amendment. The public comment period originally began on
June 5. 2000 and was to close on July 5, 2000, however. EPA extended the comment period to August 4,
2000 based on a request from a member of the community.
VIII. DOCUMENTATION OF SIGNIFICANT CHANGES
The PRAP incorporated by reference, but did not identify the following ARAR which was identified
with greater specificity during the comment period by PADEP. In addition, the PRAP did not identify the
following TBC which was identified during the comment period by PADEP:
Action Specific ARAR
Erosion and Sedimentation Control Pennsylvania Code Title 25. Sections. 102.1, 102.2, 102.4, 102.11,
102.22 which are applicable to work associated with the upgrading of the soil cover and other earth
moving activities conducted during installation of the Alternate Source Control Remedy or the Contingent
Remedies.
To Be Considered (TBC)
Pennsylvania's Erosion and Sediment Control Manual, dated January 1996. sets standards for erosion
and sediment control associated with the upgrading of the soil cover and other earth moving activities
conducted dunng installation of the Alternate Source Control Remedy or the Contingent Remedies.
Aside from the listing this ARAR with greater specificity and including the TBC listed above, there
are no other significant changes to the remedy since the PRAP was issued.

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APPENDIX A

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TABLE 1

LEACHATE QUALITY PERFORMANCE STANDARDS

Groundwater
Leachate

Performance
Performance
Contaminants
Standards
Standard
of Concern
(ug/L)
(ugfL)
Tnchloroethylene
5
20
Tetrachloroethylene
5
15
Vinyl Chlonde
1
20
cis-1,2-Dichloroethylene
25
50
Note.
1.	Leachate Performance Standards based on USEPA BIOCHLOR model: specific input assumptions subject to field verification
(see text).
2.	Leachate Performance Standards not required for ethanes and other groundwater constituents of concern (based on maximum
detected concentrations and L'SEPA BIOCHLOR model, specific input assumptions subject to field verification (see text)).
3. Leachate Performance Standards will not be required for Iron and Manganese.

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TABLE 2
COST ESTIMATE
KEYSTONE SANITATION LANDFILL
UNION TOWNSHIP, PENNSYLVANIA
ACTIVITY
QUANTITY UNIT
UNIT PRICE
ACTIVITY COST
Performance Bond
1 Lump
S50.000.00
S50.000
Mobilization; Demobilization
1 Lump
S95.000.00
S95.000
Surveying
1 Lump
S45.000.00
S45.000
Design Engineering (5%)
1 Lump
SI 60.000.00
SI 60.000

Erosion & Sediment Control
1 Lump
SI 15.000.00
SI 15.000
Clearing & Grubbing
20 Acres
S2.250.00
S45.000
Vegetation Disposal (Organics Only)
1 Lump
S22.000.00
S22.000
i
Subgrade Preparation
1 Lump
S55.000.WJ
S55.000 I
Vegetative Laver
12500 CY
SI 0.00
SI25.000 '
Swale
12500 CY
SI 0.00
S125.000
Access Road
1250 CY
534.00
S42.500
Stormwater Management System
1 Lump
S395.000.00
S395.000
Detention Basin
I Lump
S85.000.00
S85.000
Gas Extraction Svstem
1 Lump
SI.082.000.00
SI.082.000

Seed. Sod & Re-Vegetation
1 Lump
S3S.000.00
S38.000
Fence Repairs
1000 LF
SI 7.96
S44.000
Health & Safety/Construction QC
1 Lump
S48.000.00
S48.000

CAPITAL COST TOTAL
S2.571.500

CONTINGENCY 15%
S383.000


CONTRACTOR


GENERAL OVERHEAD &
PROFIT (15%)
S3 83.000

CONSTRUCTION



OVERSIGHT
SI 35.000

30 YEARS OPERATION &
MAINTENANCE
S2.000.000

(Present Worth Value)



TOTAL COST
S5.500.000
I. The costs presented are based on a cost estimate prepared by de maximis in September 1997.
2. Property acquisition costs not included.

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APPENDIX B

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APPENDIX C
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GLOSSARY OF TERMS
Administrative Record - An official compilation of site-related documents data, reports, and other
information that is considered important to the status of and decisions made relative to a Superfund site.
The public has access to this material.
Applicable or Relevant and Appropriate Requirements (ARARs) - The federal and state
requirements that a selected remedy must attain, unless they are waived. These requirements may vary
among sites and remedial alternatives.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) - A
federal law passed in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization Act
(SARA). The Act created a trust fund, known as Superfund. to investigate and clean up abandoned or
uncontrolled hazardous substance facilities.
Focused Feasibility Study (FFS) - A feasibility study that identifies and evaluates alternatives for
addressing contamination at a hazardous substance facility. The FFS is a streamlined study that evaluates
a limited number of alternatives for a specific problem at the facility.
Groundwater - Water found beneath the earth's surface in geologic formations that are fully saturated.
When it occurs in sufficient quantity, groundwater may be used as a water supply.
Leachate - A liquid that results from water-collecting contaminants as it percolates though waste and
may result in hazardous substances entering surface water, groundwater, or soil.
National Priorities List (NPL) - EPA's list of the nation's top-priority hazardous substance facilities
that may be eligible to receive federal money for response under CERCLA.
Operable Unit (OU) - A discrete portion of a site or a discrete action representing an incremental step
in the investigation and remediation of hazardous substances at a facility.
Present Worth - A term used to indicate the discounting of sums to be received in the future to their
present value equivalent or the amount that will accumulate to that sum if invested at prevailing interest
rates.
Record of Decision (ROD) - A legal document that describes the remedy selected for a Superfund
facility, why the remedial actions were chosen and others not, how much they cost, and how the public
responded.
Remedial Investigation (RI) - A study performed to identify the nature and extent of contamination at
a hazardous substance facility. The RI is used in conjunction with the feasibility study to support the
selection of a remedy for the site.
Scientific Notation - Method used to express numerical values. For example, one million (1,000,000) is
expressed as 1.0E+06. One, one-millionth (or one in one million) (0.000001) is
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expressed as 1.0E-06.
Superfund - See CERCLA.
Volatile Organic Compounds (VOCs) - Organic liquids [e.g., trichloroethene (TCE)] that readily
evaporate under atmospheric conditions.
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RESPONSIVENESS SUMMARY
KEYSTONE SANITATION LANDFILL
COMMENTS ON FOCUSED FEASIBILITY STUDY .AND PROPOSED PLAN
FOR THE ALTERNATE SOURCE CONTROL REMEDY
This Community Relations Responsiveness Summary is divided into the following sections:
Overview: This section discusses EPA's preferred alternative for remedial action.
Responses—Part One: This section provides a summary of commentors" major issues and concerns,
and expressly acknowledges and responds to those raised by the local community at the public meeting on
June 22, 2000. "Local community" here means those individuals who have identified themselves as living
in the immediate vicinity of a Superfund site and are potentially threatened from a health or environmental
standpoint. These may include local homeowners, businesses, the municipality, and potentially responsible
parties.
Responses -- Part Two: This section provides a comprehensive response to all significant written
comments received by the EPA. Where necessary, this section elaborates with technical detail on
answers covered in Part One.
EPA's responses include clarification of the proposed amended remedy, and where appropriate,
policy issues. It should be noted that the comments on the Proposed Plan have been considered and
included in the Amended Record of Decision where appropriate; however, the Proposed Plan itself has
not been revised.
Any points of conflict or ambiguity between information provided in Parts One and Two of this
Responsiveness Summary will be resolved in favor of the detailed technical and legal presentation
contained in Pan Two.
Overview
On June 1, 2000 EPA issued the Proposed Plan to amend the Operable Unit One (OU-l) Record
of Decision for the Keystone Sanitation Landfill Site located in Union Township, Adams County,
Pennsylvania. EPA's public comment period for the Site was originally scheduled to run from June 5
through July 5, 2000. EPA extended this comment period to August 4, 2000 in response to a request for
an extension. EPA conducted a pubic meeting on June 22, 2000 to present the Proposed Plan to the
public
On June 5, 2000, EPA announced the public meeting, the opening of the public comment period,
and the availability of the Proposed Plan, in a public notice placed in the Gettysburg Times newspaper. In
addition, EPA mailed a fact sheet, which explains the proposed remedy change, to approximately 400
individuals on its mailing list and mailed copies of the Proposed Plan to concerned residents, Federal,
State, and local officials.
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2
EPA held the public meeting on the Proposed Plan on June 22, 2000. EPA announced the
extension of the public comment period to August 4, 2000 at the public meeting and in a notice placed in
the Gettysburg Times newspaper.
EPA had established Site information repositories at the Hanover Public Library in Hanover,
Pennsylvania, and at St. Mary's Church of Christ in Westminster, Maryland. The repositories contain
EPA's Administrative Record file for the Site, which encompasses the key documents the Agency used
in selecting the Site remedy, and other relevant documents. At the request of St. Mary's Church of Christ
in the Fall of 1998, the church no longer serves as an information repository.
In addition to the comments provided at the public meeting, comments were received on the
Focused Feasibility Study (FFS) and Proposed Plan for the ROD Amendment during the public comment
period. Lengthy comments read at the public meeting were submitted in writing to EPA and are
addressed in Part Two of this Responsiveness Summary.
At the public meeting, the public was given an opportunity to ask questions and to comment, on
the cleanup alternative outlined in the Proposed Plan. The Proposed Plan summarized the findings of the
FFS Report, which includes the findings of the Enhanced Landfill Gas Extraction Pilot Test, and provided
details on EPA's preferred remedial alternative which modified the OL'-l ROD. giving consideration to
nine key evaluation criteria:
•	Threshold criteria, including
Overall protection of human health and the environment
Compliance with Federal, State, and local environmental and health laws
•	Balancing criteria, including
Long-term effectiveness
Short-term effectiveness
Reduction of mobility, toxicity, or volume
Ability to implement
Cost, and
•	Modifying criteria, including
State acceptance, and
Community acceptance.
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3
EPA carefully considered State and Community acceptance of the remedy prior to reaching the
final decision regarding the remedy. The Amended ROD for OU-1 details EPA's final cleanup decision
None of the comments received during the comment period suggest significant changes
to the Alternate Source Control Remedy or indicate that EPA should not select the Alternate
Source Control Remedy.
The primary components of the Alternate Source Control Remedy are described below.
•	Upgrades io the existing landfill soil cover;
Installation and operation of an Enhanced Landfill Gas Extraction (ELGE) system to actively
remove VOCs and methane from the landfill waste:
•	Monitoring to ensure proper functioning of the ELGE system and to evaluate VOC removal from
the landfill;
Monitoring to determine the impact of the ELGE system on the quality of the leachate within the
landfiU;
•	Use of surface water management controls to minimize soils erosion and sedimentation;
Maintenance of the existing fence; and
Use of institutional controls on the landfill property.
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4
Part One - Summary of Commentors' Major Issues and Concerns During the
Public Meeting
Comments Concerning the Amended Remedy
I. The proposed remedy will treat the volatile portion of the chemicals, but some portion of the
solvents may remain in the landfill. How much of the compounds are recoverable in this system
and is there the possibility that volatile organic contaminants can migrate a large distance and
impact other groundwater wells.
EPA Response: The remediation goals of the enhanced landfill gas extraction system are to achieve a
90% reduction of volatile organic contaminants and to improve the quality of the leachate in the landfill.
The volatile organic contaminants in the landfill will respond well to the proposed system. The metals that
are present in the landfill will not volatilize, but will be treated by the groundwater extraction system. In
addition, a large volume of methane will also be extracted during the early stages of system operation.
The enhanced landfill gas extraction system will work in combination with the groundwater extraction
system to prevent the further migration of contaminants from the Site. In addition, water filters have been
provided for people residing within '<> mile of the Site, North of Pinev Creek, to clean the water to the
performance standards.
J. Where in the Focused Feasibility Study tFFS) is the safety information in case of explosion,
accident, or spill7
EPA Response: The FFS is a preliminary document that evaluates whether various remediation options
are feasible. The next step, when the remedy is selected, will be to prepare design documents that discuss
the design of the system and how the work will be carried out. The work plan for the design will include
safety information for workers and residents.
3.	Please detail the clean-up work that has occurred since 1990.
EPA Response: Since 1990, a fence was erected to limit access; groundwater investigations have been
ongoing; residential filters were installed; and the groundwater treatment plant has been constructed and
should begin operating soon.
4.	What is the permeability of the soil cover currently on the landfill and where will the soil come
from that meets the permeability requirements of the remedy
EPA Response: At this point EPA does not have enough site-specific data to determine the thickness and
permeability of the existing cover. A detailed investigation including gridding will be conducted, during the
design of the remedy, to determine the thickness of the cover and the extent of the upgrades that need to
be performed. A 2-foot cover
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5
layer is required and in any areas with less than 2 feet of cover, additional low-permeability soils will be
added. For a more detailed discussion see CURE'S written comments dated 6/22/00 and EPA's response.
5.	If soil is removed for construction of riprap channels how will that be handled as far as cover
material?
EPA Response: Additional soil would be brought in to assure that adequate cover is in place and that the
2-foot minimum soil cover is maintained across the landfill.
6.	With respect to the soil cover. is the objective of the remedy to get water into the ground or
keep water out of the ground?
EPA Response: The objective of the soil cover requirement is to reduce infiltration, manage the runoff
from the landfill, and prevent direct contact with landfill wastes. The gas extraction system will remove
volatile organic contaminants from the landfill and will eliminate them as a future source to groundwater.
In addition, the gas extraction system may require some improvements to the cover to help manage air
intrusion.
7.	Should there be standards for the soil cover that have to do with the operation of the gas
extraction system.'
EPA Response: EPA has run pilot tests that showed that the system ran effectively at 25 standard cubic
feet per minute, which is three to four times greater than a typical landfill active gas extraction system.
Currently, there am no standards regarding the construction of the cover that specifically address the
operation of the gas extraction system. Based on the operation of the gas extraction system, EPA may
consider improvements to the soil cover to manage air intrusion and help the system run more effectively.
8.	Why don't we want air introduced into the landfill to help volatilize the solvents?
EPA Response: The landfill, although relatively young, has not been vented and, therefore, likely contains
a lot of methane. The presence of methane will help draw out the contaminants through the operation of
the enhanced landfill gas extraction system. In its present state however, introduction of oxygen would
create a dangerous environment because oxygen in combination with methane may cause the temperature
of the landfill to increase which could lead to combustion within the landfill. The FFS considers the
possibility of biodegradation, which would include adding oxygen to the landfill to help volatilize the
contaminants if, in the future, methane levels in the landfill have been significantly reduced.
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6
9 A statement was read by a local property owner (see written comments in this Responsiveness
Summary). Concerns were raised about the health assessment, the results from groundwater
well EW-6. the number of groundwater wells needed south of the Site, the schedule for the
remedial design, the applicability of bioventing, and EPA s consideration of methane as a
hazardous substance.
EPA Response: A response to each question posed in the statement may be found in the response to
written comments.
10. How can EPA be sure of the proper depth of the gas extraction wells7
EPA Response: Wells will be installed to the bottom of the waste-fill. The proper depth for the gas
extraction wells will be determined during design. During well construction, the depth can be determined
through to use of downhole cameras and evaluation of soil borings in conjunction with data collected
during the pilot test.
Comments Concerning Community Relations
1.	In the past, the community has suggested that EPA consider other remedies besides capping,
but EPA has not been receptive to these suggestions. Therefore, how will EPA determine the
community acceptance criterion for this remedy }
EPA Response: Community acceptance is one of the nine criteria that EPA must consider when
selecting a remedy. EPA will review all community responses, written responses, and the points discussed
during the public meeting and evaluate feedback from the community. As far as considering alternative
technologies in the past, a great deal of progress has been made in soil vapor extraction technology since
it was first discussed in the 1990 Feasibility Study. The advancements and results of the pilot testing
indicate that the enhanced landfill gas extraction system is now be a viable treatment alternative for the
Site.
2.	How does the public get copies of EPA's response to comments?
EPA Response: EPA's response to comments will be included in the Responsiveness Summary section
of the ROD Amendment. This will be placed in the Administrative Record, a copy of which may be found
in the information repository at the Hanover Public Library. Copies of the ROD Amendment and
Responsiveness Summary are available to the public upon request.
J. Were notices of the public meeting for the Proposed Plan sent out to everyone on the mailing
list?
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7
EPA Response: Yes, approximately 400 names are on the mailing list and they all received notices.
4. Why was the public meeting held in Abottstown. rather than closer to the communities closer to
the Site
EPA Response: EPA believes the meeting location was appropriate, however, EPA will consider
locations closer to the site. EPA requests the community provide suggestions of appropriate facilities in
the area which could accommodate the number of people expected at such meetings. In addition, EPA
notes that not all facilities meet all its requirements including fees and availability.
Comments Concerning Legal Issues
/. What are deed restric tions?
EPA Response: The ROD .Amendment includes institutional controls, which include deed restrictions, to
limit the installation of new groundwater wells and the extraction of groundwater on the landfill property
itself. These controls would also limit disturbance to the upgraded landfill soil cover and any activity on the
landfill which could impair the integrity of the remedy. Residential buildings and properties, located on the
Site, are excluded from the institutional controls.
2.	Who is paying for the remedy ?
EPA Response: It is EPA's policy to pursue the responsible panics for clean-up costs. EPA is currently
negotiating with the owner/operators to perform the remedy and pay for its costs.
3.	Wh v is EPA hesitating to move the fence to where the waste is ?
EPA Response: The ROD Amendment specifically calls for the delineation of the boundary of the waste
and requires that if waste is detected outside the existing fence that the fence must be moved to the true
perimeter of the landfill. This work is part of the Alternate Source Control Remedy and will be included in
the design of the remedy following the issuance of the ROD Amendment.
4.	How often can be the potentially responsible parties (PRPs) change their decision and go to
court requesting another plan? What will happen if the PRPs do not go through with the
remedy ? Will the remedy change back to placement of the cap ?
EPA Response: The process of remedy selection and the issue of who performs the remedy are
separate. EPA and PADEP have evaluated the remedial alternatives and EPA
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8
has published a Proposed Plan which recommends the implementation of the Alternate Source Control
Remedy which includes enhanced landfill gas extraction system. EPA will evaluate the comments on the
Proposed Plan and feedback from the community. If based on its final evaluation, EPA selects the
Alternate Source Control Remedy, then it will issue a ROD Amendment
In addition, EPA will continue to pursue a settlement with the PRPs to perform the remedy. If the PRPs
do not agree to perform the remedy, EPA can order the PRPs to perform the remedy, or EPA can take
the lead on the construction and litigate to recover costs. EPA does not have control over how many-
times the PRPs may go to Court to propose another cleanup plan for the Site. However, EPA believ es
that it is close to reaching a settlement with the owner/operators to implement the source control remedy.
Comments Concerning the Groundwater Remedy
The following comments do not address the Alternate Source Control Remedy, but are related to the
groundwater potion of the remedy. The major comments and responses are included here. For a more
detailed response to comments related to the groundwater remedy please refer to the June 1999 ROD
.Amendment for groundwater.
1.	How often will the residential filtration systems be checked0
EPA Response: Maintenance of the residential filtration units wiil include replacing one of the dual
carbon units in each home annually. In addition, to monitor system performance. 15% of the residential
wells will be sampled annually. Based on the results of analytical testing, if necessary, the procedures may
be changed. EPA will be monitoring the remedy to evaluate the effectiveness at capturing the
groundwater plume. The groundwater monitoring wells will be sampled quarterly. With plume capture,
concentrations of contaminations should decrease.
2.	Will results from the test wells be made available'
EPA Response. The results of the groundwater sampling from the test wells will be reported to EPA.
EPA will make the monitoring well sampling results available to the public. EPA anticipates making the
monitoring well data available to the public at the Union Township Municipal Building.
3.	ts it safe for children to play in Willow Spring?
EPA Response: EPA feels that them is not a significant risk to children playing in the spring EPA's
health assessment did not show significant risks for exposure to surface water. The health assessment
did, however, indicate that these are risks associated with ingestion of contaminated water. Willow Spring
was sampled as part of the OU-2 RI in
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9
September 1994 (identified as Spring 1 in the RJ). Results from sediment samples did not show any
site-related contaminants greater than background. The aqueous sample showed low levels of some
site-related VOCs, similar in concentration to the nearby well (RW-1). The levels observed do not present
an unacceptable cancer risk, although the non-carcinogenic risk to children is slightly greater than the
acceptable Hazard Index of 1.0. It should be noted, however that this increased non-carcinogenic risk is
primarily due to ingestion for a resident child and not the incidental ingestion and dermal contact expected
in a recreational scenario.
4.	Regardless what happens with the ROD Amendment for source control, will the groundwater
extraction system start operating this summer?
EPA Response: Yes, the groundwater treatment plant has been constructed. Testing of the plant is being
conducted and the groundwater treatment system is expected to begin full time operation shortly. The
treatment system began initial batch operation with discharge to an on-site storage tank on August 22.
2000. Continuous operation and discharge to the stTeam will commence pending sampling results for the
discharge of the treated water.
5.	From which wells is groundwater going to be extracted9
EPA Response: The groundwater extraction system includes *7 extraction wells (these were shown on
Figure 5-2 at the public meeting and are available for review in the April 2000 Sampling and .Analysis
Plan). The well locations were selected based on the OU-2 R.I which characterized groundwater flow at
the Site. The groundwater extraction wells will be sampled quarterly to evaluate their efficiency.
6.	How many people refused filters?
EPA Response: Residential water filters were offered to 46 homeowners. Of these 46 owners, 36
accepted the filter offer and 3 did not respond.
7.	Questions were raised regarding groundwater Jlow direction in the Humbert Schoolhouse
Road Area
EPA Response: As determined in the OU-2 RJ, groundwater flow direction is determined by hydraulic
head measurements. This evaluation showed that groundwater from the Site is not impacting that area.
8.	Does EPA expect water levels in residential wells to drop during pumping of the groundwater
extraction wells?
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EPA Response: Drawdown of the aquifer is an indication that capture of the groundwater contamination
is occurring. Monitoring wells, located between the extraction wells and home wells, will be checked for
water levels to assure that home wells will not run dry due to operation of the extraction wells and the
groundwater treatment system.
9.	A document states the groundwater treatment system is scheduled for testing in the summer of
2000. What does that mean?
EPA Response: The statement refers to mechanical testing of the groundwater treatment plant. Some
mechanical testing of the treatment plant did take place; however, additional work has to be performed
before the system is fully operational. This work was required, in pan, due to the presence of methane in
the groundwater well vaults. Additional testing of the system took place in August 2000. EPA expects the
system to begin continuous operation once it has been determined that all discharge limits are being met.
10.	Is methane being vented out of each well0
EPA Response: Methane was not detected in all groundwater extraction wells. Methane has been vented
from the extraction wells. The well vaults have been modified to be explosion-proof.
PART 2 - Summary of Commentors' Written Questions
Comments from CURE (June 22. 2000) on the Proposed Plan
1. Why is the deed restriction listed in the Proposed Plan limited to the landfill and not the entire
site?
EPA Response: The purpose of the institutional controls, which include deed restrictions, is to ensure the
integrity and protectiveness of the clean up of the Site, in particular, to ensure that no activities take place
at the Site that would damage the landfill soil cover, the groundwater pump and treat remedy or the
Alternate Source Control Remedy.
The 1990 ROD called for deed restrictions on the Site without specifying the exact location where the
restrictions were to be placed. The ROD Amendment for the Alternate Source Control Remedy includes
institutional controls on the landfill itself. These controls do not extend to other portions of the Site,
including those portions of the Site used for residential purposes. In order to achieve the purpose of the
institutional controls, it is only necessary to apply them to the landfill property itself.
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2.	The Proposed Plan calls for adding soil to establish a minimum of 2 feet of cover that has an
average permeability no greater than 2.2 X 10-6 cm/sec. We believe that this is 0.005 inch per
hour. If this is a correct translation of the centimeters per second, we are confused as to where
this figure came from. The original soil was listed as a Glenelg silt loam in the L'SDA soil
survey. Glenelg soil has a range in permeability 
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Under the NCP, community acceptance is one of the nine criteria EPA uses to select remedial
actions. Community acceptance is considered a modifying criteria. The other types of criteria are
threshold criteria (utilized in identifying protective, ARAR-compliant alternatives eligible for
selection) and the primary balancing criteria (utilized in balancing tradeoffs among alternatives
with respect to other pertinent criteria). In the final step in the remedy selection process, after
factoring in comments received from the State and community, EPA reassesses its initial
determination that the preferred alternative provided the best balance of trade-offs. The state and
community comments may prompt EPA to "modify" the preferred alternative or select another
alternative that provides a more appropriate balance.
As discussed at the public meeting, the process of evaluating community acceptance includes
EPA's evaluation of the comments received from the community to determine if the people in the
area understand the remedial actions EPA is considering and to determine if there are no
overwhelming objections in the community to the type of technology being employed. A correct
assessment of community acceptance necessarily is based on hearing from the community as a
whole. Community acceptance is not defined in the NCP as a majority vote from the community.
It has been EPA's experience that when citizens are satisfied with a remedy they are generally
not vocal regarding their satisfaction. In conclusion, there is no precise formula for the evaluation
of community acceptance. EPA must necessarily apply and assess all of the remedy selection
criteria under the facts and circumstances of each specific Site, which it believes it has done
appropriately at this Site."
Comments from CURE (August 2. 2000) on the Focused Feasibility Studv and the Proposed
Plan
Comments of the Focused Feasibility Studv (FFSV.
/. FFS. page I - Why wasn't soil vapor extraction (Sl'E) or other innovative technologies
considered earlier in the process?
EPA Response: SVE was reviewed as a possible treatment alternative as part of the 1990 Feasibility
Study (FS). However, the FS concluded that due to the heterogenous nature of the wastes in the landfill
and the fine grain nature of the landfill soils the effectiveness of SVE at the Site was uncertain. As a
result, SVE was not retained for further consideration. At the time the FS was prepared, treatment
technologies such as SVE were considered to be fairly innovative and were primarily used to treat soils
contaminated with volatile and semi-volatile organics. SVE technologies were generally not considered for
treatment of landfilled wastes.
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Since 1990, technical developments in the field of SVE have led to this technology being considered a
potential alternative for remediation at the Keystone Sanitation Landfill Sue. These developments include
significant now methods of characterizing landfill permeability and gas concentration. After considering
these recent advances in SVE technologies, the EPA approved plans to conduct a pilot test at the Site
The pilot test provided additional information necessary to evaluate the viability and effectiveness of
ELGE at the Site. The results of the pilot test have suggested the feasibility of ELGE as a means to
remove VOCs from the landfill and to control landfill gas migration. Based on the findings of the pilot test,
a focused feasibility study (FFS) was prepared to supplement the Administrative Record by evaluating the
Alternate Source Control Remedy for the Site.
The FFS concluded that the Alternate Source Control Remedy, combined with the remedy for
groundwater selected in the 1990 ROD, as amended on June 25, 1999, will satisfy the remedial action
objectives for this Site. The combined remedies will be effective in capturing, containing, and remediating
contamination from the waste fill and groundwater, and they will achieve the cleanup standards
established by EPA and protect both human health and the environment. The overall remedial action
objectives of the Alternate Source Control remedy are consistent with those identified in the 1990 ROD.
2.	FFS. page 2 - What "point of use treatment " was written in the 1990 Record of Decision
(ROD) '.' Please identify reference information.
EPA Response: EPA issued the OU-1 ROD on September 30. 1990 for the Keystone Sanitation Landfill
Superfiind Site The remedy selected in the 1990 ROD included the provision of a point-of-use
groundwater treatment system to on-site residents. The point-of-use groundwater treatment system is a
whole house water filtration system for the residents located on the Site.
3.	FFS. page 2 - In the phrase, "through the installation of an additional diversion channel and a
detention bastn or similar measures to be evaluated during design" piease explain "similar
measures. "
EPA Response: One of the components of the Alternate Source Control Remedy is the implementation
of a storm water management system at the Site. The ROD Amendment requires that surface water
drainage improvements, such as channels on and around the landfill, be designed and constructed to
convey the peak runoff from a 25-year 24-hour storm event safely away from the landfill to protect the
cover and reduce infiltration in and around the landfill. The remedy must comply with Pennsylvania's
regulations pertaining to the implementation of erosion and sedimentation controls sited in the ROD
Amendment. The FSS discusses the use of surface water management controls at the Site including an
"additional diversion channel and a detention basin or similar measures to be evaluated dunng design."
EPA will fully evaluate and approve a surface water
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management system for the Site during the design of the remedy. The system will be designed to
effectively control runoff and erosion from the Site while meeting the requirements of the ROD. If
"similar measures" in terms of surface water control are deemed necessary, they will be specified in the
design of the remedy.
4.	FFS. Pages 3 and 5 - CURE would like to clarify for the record the permitting history- discussed
in the FFS. The public record should indicate that the landfill was permitted by PADEP but not
until 1980 and the original permit did not allow industrial waste or construction debris. These
materials were accepted by permit modification. In addition. CURE'S review of PADEP files
show that not all trenches had a certified renovating base and the renovating layer and final
cover was rippedphyllite. not silty clay soil. According to the file review. PADEP did not
consider this effective for protecting groundwater. CURE would also tike to put on the record
that their review of PADEP records indicates that PADEP staff indicated that the site would
need a leachate collection and treatment system in order to protect groundwater.
EPA Response: CL'RE's comments regarding the history of the landfill are noted for the record. The
purpose of the FFS was to evaluate whether the Alternate Source Control Remedy would be effective in
treating the volatile organic contaminants at the Site. References to the landfill's permitting history are not
relevant to the remedy selection and. therefore, have been removed from the ROD Amendment for the
Alternate Source Control Remedy.
5.	FFS, page 3 - Please explain the Conestoga Limestone Ridge
EPA Response: Page 3 of the FFS states that the "landfill is situated on top of a ridge." This statement
was intended to provide general background information regarding the topography of the Site. CL'RE has
asked for an explanation of the significance of this ridge. Data collected from the groundwater monitoring
wells during the OL'-2 investigation revealed that groundwater flows from Humbert Schoolhouse Road,
the approximate crest of a ridge, down into the valley that contains the tributary to Pinev Creek. This
comment pertains to hvdrogeologic conditions at the Site and, therefore, is related to the groundwater
remedy and does not directly relate to the selection of the Alternate Source Control Remedy.
6.	FFS. page 3 - CURE would like to note that some residents near the site use springs for water
supply. In addition. CURE would like a correction to the FFS which indicates that Xfundorjf
Spring is used as a water supply.
EPA Response: CURE'S comments regarding the residential use of springs for water supply are noted
for the record. Specifically, EPA notes that the Mundorff Spring is used as a water supply in the area by
some area residents. However, EPA does not
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believe that this issue is relevant to the selection of the Alternate Source Control Remedy. Please see the
June 1999 ROD Amendment for groundwater for specific information regarding the use of groundwater
and springs in the area.
7. FFS. page 3 - Is EPA confident there are "75 residents (sic) within one-mile of the Site'.' " What
is the basis for this statistic?
EPA Response: During the U-2 RJ (NUS, 1997), it was estimated, through a field survey conducted by
the parties responsible for implementing the groundwater remedy, that there were approximately 75
residences within one-mile of the Site. This estimate included residents within one-mile of the Site, both to
the North and South of Piney Creek.
Based on the findings of the off-site groundwater investigation, the June 1999 ROD Amendment for
groundwater addresses treatment for home is north of Piney Creek. Based on recent surveys; there are
currently 45 homes within Zone 1 (includes homes located within 3 J- mile north of Piney creek measured
from center of the landfill) which have been offered water filters as part of the performance of the
groundwater remedy. In addition, there are 22 homes within Zone 2 (includes homes located within 1 mile
north of Piney creek measured from center of the landfill) which will be monitored as part of the
performance of the groundwater remedy. One of these homes was offered a filter in addition to the
monitoring.
However, the number of homes within one mile of the center of the landfill may continue to increase due
to residential development in the vicinity of the Site. EPA and the responsible parties will continue to
monitor the development in the area. N'ew homes will be included in the monitoring program and will be
offered filters as appropriate. Please see the June 1999 ROD Amendment for groundwater for specific
requirements regarding provision of residential filters and monitoring of residential wells.
¦3. FFS. page 4 - CURE would like the record to show that EPA identified the site on its "Open
Dump Inventory " prior to citizen's complaints and had confirmed the presence of I'OCs prior
to the EPA Field Investigation Team.
EPA Response: EPA cannot currently identify an "Open Dump Inventory" that included the Site prior to
citizen's complaint. EPA's Field Investigation Team conducted an investigation because VOCs were
identified at the Site. EPA acknowledges that the FFS does not provide a detailed discussion of all
previous site investigations, but includes information necessary to evaluate the Alternate Source Control
Remedy.
9. FFS. page 4 - CURE would like the record to show that groundwater was sprayed into a
wooded area between the landfill and nearby homes.
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EPA Response: According to EPA's records, in August 1984, as a result of the volatile organic
contamination, the owner/operators of the landfill installed a spray irrigation system in the most
contaminated area of the landfill to prevent the migration of contaminants and to remove volatile organic
contaminants from the groundwater. Water from Keystone groundwater monitoring well K1 was pumped
to a series of sprayers located at the edge of the landfill, within the radius of the influence of the well.
10 FFS. page 4 - In the phrase, "and the contents were disposed off-site. " where was "off-site"
water disposed?
EPA Response: The comment refers to leachate collection which was attempted by the owner/operators
of the landfill on the southern side of the landfill along Line Road. Leachate was collected at the base of
the landfill via a perforated pipe which discharged into a storage tank. The contents of the storage tank
were disposed of off-site. This occurred prior to EPA's initiation of the remedial action at the Site. Any
historic information in EPA's possession related to the landfill's operation, relevant to EPA's, remedy
selection, is included in the Administrative Record for the Site.
I I. FFS. page 4 - CURE would like to note that the OL'-l ROD was an Interim ROD
EPA Response: In the Responsiveness Summary to the 1990 ROD EPA recognized that the action called
for in the ROD was an interim action EPA. However, does not consider the 1990 ROD to be an
"Interim ROD." The first Proposed Plan was issued on July 20. 1990 to address contamination of all
media {i.e., soil, groundwater, surface water, sediments) affected by the Site. Based on public comment,
in the September 30, 1990 ROD. EPA determined that it would address contamination from the Site by-
dividing EPA's response activities into two operable units. The remedy selected in the 1990 ROD
required, among other things, placement of an impermeable cap on the landfill, construction of a
groundwater extraction and treatment system and monitoring of residential wells, surface water and
sediments. The purpose of the groundwater extraction system was to prevent contaminated groundwater
originating under the landfill from migrating to areas outside the landfill boundaries and to reduce
groundwater contamination to established cleanup goals.
The 1990 ROD also required an additional study of contamination outside the boundaries of the landfill,
the subject of the second Proposed Plan. These studies were labeled Operable Unit Two (Oli-2) to
distinguish them-from the previous studies. However, EPA later decided to address the Site as one
operable unit, OL'-l. On June 25, 1999, EPA amended the OL'-l ROD to address groundwater
contamination outside the boundary of the landfill.
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12. FFS-Attachment- It should be noted that the waste depth is 40 feet.
EPA Response: The FFS and PRAP state that wastes were deposited to a depth of approximately 30
feet in the landfill. EPA recognizes that in portions of the landfill wastes maybe at depths grater than 30
feet. The design of the Alternate Source Control Remedy will provide additional information regarding the
waste profile in the landfill.
Comments on the Proposed Plan (PPk
1.	PP, page I - What is required for normal closing of a landfill according to PADEP
regulations?
EPA Response: PADEP's requirements for "normal closing of a landfill" depend upon several factors,
most notably the date on which the landfill ceased to accept wastes. In this case, because the landfill
ceased to accept wastes prior to October 1990. a cap is not required. If this landfill were not a Superfund
site, PADEP regulations would require that the landfill have a soil cover of at least two feet, meet
specified erosion and sedimentation criteria, as well as meeting storm water runoff regulations.
Furthermore, PADEP regulations would require that this landfill install a methane control system to ensure
that methane levels do not exceed the lower explosive level at the boundary of the landfill, or 25% of the
lower explosive level in nearby structures.
All of these requirements are included as ARARs in the ROD Amendment for the Alternate Source
Control Remedy. Therefore, in addition the implementing the remedy, the Alternate Source Control
Remedy will meet the requirements for "normal" closing of the landfill.
2.	CURE would like to state for the record that a carbon filtration unit has been offered to one
resident greater than '/* mile from the site.
EPA Response: EPA notes CURE's comment for the record. Please see the June 1999 ROD
Amendment for Groundwater for a detailed discussion regarding provision of residential filters.
3.	PP. page 5 - In reference to the phrase, "and to evaluate VOC removal from the landfill. " will
you also evaluate the methane removal?
EPA Response: The Alternate Source Control Remedy will include monitoring of methane gas extracted
from the landfill in addition to the VOCs. Furthermore, the ROD Amendment specifically includes
performance standards for methane extraction. Following shutdown of the system or portions thereof,
four consecutive sets of methane monitoring at the landfill perimeter, spaced no less than three months
apart show that:
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25% of the lower explosive limit for methane is not exceeded within nearby structures; and the lower
explosive limit for methane is not exceeded at the landfill boundaries. The "nearby structures" in this case
will comprise existing on-site buildings and the Groundwater Treatment Plant building
4.	PP. page 5 - In reference to the phrase, "use of deed restrictions on the landfill property, "
please explain deed restrictions, using Executive Summary form and any other information
needed.
EPA Response: The purpose of the deed restrictions is to ensure the integrity and protectiveness of the
clean up of the Site, in particular, to ensure that no activities take place at the Site that would damage the
soil cover, the pump and treat remedy or the Alternate Source Control Remedy.
5.	PP. page 5 - In reference to the phrase, "addition of low permeability cover soil to maintain a
minimum 2-foot thick soil cover across the landfill, " will present cover soils be delineated (bv
scientific tests) to determine existing permeability conditions before "addition of permeability
cover soil? "
EPA Response: The existing cover will be tested to determine its thickness across the landfill. EPA does
not anticipate performing permeability testing on the existing cover. As part of the remedy, areas having a
cover thickness of less than 2 feet shall be upgraded to 18 inches of soils having an average permeability
no greater than 2.2 x 10" cm sec. and a maximum permeability no greater than two times this value,
overlain with a minimum 6 inch erosion layer
6.	PP. page 6 - In paragraph one, please describe comprehensive investigation of the landfill
cover thickness to be performed. Will this consist of a grid system or grab samples.9 IVhere will
soil be obtained - from the site ?
EPA Response: An investigation of the existing soil cover will be conducted as part of the design of the
Alternate Source Control Remedy. The soil cover investigation will involve collection of a representative
number of samples utilizing a grid system sampling approach. A detailed sampling plan will be developed
as put of the design of the remedy. The design will specify which areas will require upgrades and the
estimated volume of soil require to upgrade the cover. The design will specify the requirements in the
terms of permeability and quality of the soils to be used in upgrading the cover. The design will also
indicate where the soils for upgrading the cover will be obtained.
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7. PP. page 6 - Describe the method of waste investigation.
EPA Response: A sampling plan will be developed as part of the design of the remedy. This plan will
include the approv ed approach to the waste investigation to identify the boundaries of the landfill.
8 PP. page 6 - What quality soils are to be used (note: sewage sludge had to be used in the
past)?
EPA Response: The design will specify the quality of the soils to be used for upgrading the cover. EPA
will require that clean soils be used to upgrade the cover.
9. PP. page 6 - In reference to the phrase, "tree covered portion of the landfill will be removed
via flush cutting or controlled application of herbicides. " describe the types of herbicides to be
used.
EPA Response: If during the design of the remedy, herbicides are determined to be necessary, the
specific type of herbicides and procedures for application will be discussed in detail in the design
documents.
10 PP. page 7 - In reference to the phrase, "use of supplemental fuel at the fare. " what
supplemental fuel? Be specific.
EPA Response: The use of supplemental fuels will be investigated during the design of the remedy.
II. PP. page 9 - In reference to the phrase, "and any available historical records. " who produced
these historical records?
EPA Response: The statement regarding historical records refers generally to any historical information
associated with the site that may aid in the design of the Alternate Source Control Remedy. No specific
records were indicated by the reference.
12. PP. page 9 - Under the heading, "Condensate Treatment. " would the records of the other 15
operating sites in the United States (where such gas treatment systems are in use) be a source
of information that would reveal any data regarding ambient are emissions of a nature that
might harm people living nearby? Concerns exist for any possible effects to life around the site.
What if estimated VOC emissions are erroneously reported, etc.?
EPA Response: All available relevant information will be available during design to evaluate the possible
effects related to ambient air emissions from the condensate treatment system. More importantly,
however, during the design phase EPA will require
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a Site specific evaluation to ensure that the condensate treatment system does not pose a threat to human
health and the environment surrounding the Site.
13. PP. page 9 - CURE has indicated thai a minimum of 2 feet of soil should be maintained from
the lowest elevation of the detention basin and the rip-rap lined channel.
EPA Response: The surface water management system will be designed to comply with Pennsylvania's
regulations pertaining to the implementation of erosion and sedimentation controls sited in the ROD
Amendment. In addition to the surface water management system, the existing soil cover will be upgraded
to maintain a minimum of 2 feet of cover across the entire landfill.
14 PP. page 9 - In reference to the phrase. "Proposed Plan recommends that the deed restrictions
be limited to the landfill itself and not extend to other portions of the sue. " why not the entire
property? How can deed restrictions reasonably cease at actual landfill boundaries?
EPA Response: The purpose of the deed restrictions is to ensure the integrity and protectiveness of the
clean up of the Site, in particular, to ensure that no activities take place at the Site that would damage the
soil cover, the pump and treat remedy or the ELGE remedy. In order to achieve the purpose of the deed
restrictions, it is only necessary to apply them to the landfill property itself.
15.	PP. page 12 - Where will soil be obtained that meets the permecthilitv ot this 2.2 x 10-6 cm/sec (if
this is correct)? How does Glenelg soil meet the stated criteria '
EPA Response: The ROD Amendment states that areas having a cover thickness of less than 2 feet
shall be upgraded to 18 inches of soils having an average permeability no greater than 2.2 x 10"* cm/sec,
and a maximum permeability no greater than two limes this value, overlain with a minimum 6 inch erosion
layer. The remedial design will specify where the soils for upgrading the cover will be obtained and will
specify the details regarding placement of the soils to meet the requirements of the ROD Amendment.
The soils to be used in upgrading the cover will likely be obtained from an off-site source.
16.	CURE requests that at a minimum, monthly reports be prepared identify ing progress and /or
potential problems with the remedv.
EPA Response: EPA will require regular progress reports. The frequency ok the reporting requirements
will be specified in the remedial design work plan. The progress reports will be available to the public.
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Comments bv local property owner
1.	Is the health assessment for the site accurate? Does it take into account all the compounds
detected in the gas extraction well during the pilot testing.' Does it consider synergistic effects
of alcohols with other site contaminants of concern?
EPA Response: EPA believes that the Site health assessment is accurate. EPA's Final Baseline Risk
Assessment concluded that the risk to public health or the environment associated with potential exposure
to surface soil, including the existing landfill cover soils, or surrounding surface water discharges and
sediment are below EPA's acceptable risk range. The primary risks associated with the Site are due to
potential residential potable use of untreated groundwater. The findings of the OU-2 RJ confirmed these
conclusions through additional invesngation of potential migration pathways beyond the landfill including
storm water runoff, landfill gas migration, and groundwater. Further, the OU-2 RJ narrowed the
chemicals of potential concern to the 14 compounds identified in the June 1999 ROD .Amendment for
groundwater.
The presence of pans per billion levels of alcohols in conjunction with parts per billion of chlorinated
hydrocarbons is not a situation similar to that where notable synergistic effects have been documented in
the literature for chlorinated hydrocarbons. It is known that consumption of alcoholic beverages can
produce an adverse synergistic effect on toxicity of chlorinated hydrocarbons because metabolic
processes in the liver are substantially altered during the process of detoxifying gross quantities of alcohol.
However, the effects on the liver from consumption of several liters of an alcoholic beverage containing,
for example, 12 percent alcohol or 120,000,000 ug/ L cannot be expected to be a predictor of effects on
the liver from consumption of water containing only a few dozen micrograms per liter of alcohol — over a
million times lower concentration.
2.	Has EW-6 been sampled, and if not, why?
EPA Response: EW-6 was not sampled because the groundwater treatment plant was not on line at the
time of the sampling event. This comment is related to groundwater remedy and does not impact the
selection of the Alternate Source Control Remedy.
J. Is the design for the groundwater recovery system adequate for the entire site?
EPA Response: EPA believes that the groundwater recovery system is adequate for the entire Site. The
FFS indicates that the groundwater recovery system, in conjunction with, the Alternate Source Control
Remedy will be protective of human health and the environment. This comment, however, is more directly
related to groundwater remedy and does not impact the selection of the Alternate Source Control
Remedy.
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4.	How many more wells will be needed south of the sire'
EPA Response. This comment is related to groundwater remedy and does not impact the selection of the
Alternate Source Control Remedy. EPA will evaluate the efficiency of the groundwater extraction and
treatment system. This will include a determination if the plume is being "captured" as well as monitoring
existing wells to evaluate if contaminant levels are decreasing. Based on the results of the system
monitoring it may be necessary to install additional wells either for groundwater recovery or plume
monitoring; however, a specific number cannot be determined at this time. If the system shows optimal
performance, there may not be the need to install additional wells off-site to the south of the landfill.
5.	Can the schedule for the remedial design include a "stepped-up " timeframe9
EPA Response: EPA will make every effort to expedite the remedial design of the Alternate Source
Control Remedy. The planned iterative approach to well installation consists of initially installing a group
of methane management wells which will likely be similar to the currently approved design that included a
total of 16 methane management wells. Additionally, the first phase will involve additional ELGE wells in
the vicinity of the Pilot Study location and other area s determined to contain elevated levels of VOCs.
The data obtained during the performance of the pilot test is expected to aid in speeding up the design
process.
6.	Is bioventing a viable alternative in supplementing the remedy'
EPA Response: As discussed in the Proposed Plan, the use of bioventing as an additional innovative
system enhancement will be considered as operational experience is gained. Bioventing is an innovative
technology that has been employed mostly at petroleum contaminated sites and involves the use of
existing subsurface microorganisms to biodegrade organics under oxygen rich conditions. The process
typically involves the addition of air (oxygen), nutrients, and water to the system. It is most often used at
sites contaminated with mid-weight petroleum products, since lighter products will volatilize easily under
SVE and heavier products tend to take longer to biodegrade. In its present state, the landfill is still
producing methane, and as a result is not currently suited to bioventing technology. However, if
operational data indicates bioventing may be applicable, it will be evaluated.
7.	Can EPA give more consideration to methane as a hazardous substance during Superfund
investigations?
EPA Response: In stnct legal terms, methane is not a "hazardous substance" as defined by the
Superfund law. Nevertheless, EPA recognizes methane as a hazard associated with municipal landfills
that must be addressed in implementing a Superfund clean up.
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The standards for dealing with methane at a landfill such as Keystone are proscribed by PADEP
regulations. Those regulations require that a methane management system be put in place to ensure that
methane levels do not exceed the lower explosive level at the boundary of the landfill, or 25% of the
lower explosive level in nearby structures. Those methane regulations have been incorporated into the
ROD Amendment as ARARs and will be enforced during the clean up of the Site
Comments bv Pennsylvania Department of Environmental Protection on the FFS (5/31/001
/. The Department's 25 PA Code Chapter 102.2-102,24 should he added as an action-specific
ARAR for earth moving activities during installation of the source control remedy. The
Department's Erosion and Sediment Pollution Control Manual, 1990 should be listed as a TBC
document.
EPA Response: The PRAP incorporated by reference, but did not identify the following ARAR which
was identified with greater specificity during the comment period by PADEP. In addition, the PRAP did
not identify the following TBC which was identified during the comment period by PADEP:
Action Specific ARAR
Erosion and Sedimentation Controls, Pennsylvania Code Tide 25. Sections. 102.1. 102-22 102.4. 102.11,
102.22 which are applicable to work associated with the upgrading of the soil cover and other earth
moving acttvities conducted during installation of the Alternate Source Control Remedy or the Contingent
Remedies.
To Be Considered (TBC)
Pennsylvania's erosion and Sediment Control Manual, dated January 1996, sets standards for erosion
arid sediment control associated with the upgrading of the soil cover and other earth moving activities
conducted during installation of the Alternate Source Control Remedy or the Contingent Remedies.
Comments bv Maryland Department of the Environment. Waste Management Administration
on the Proposed Plan (6/21/001
MDE Comment I. "Based on the premise that the primary contaminants of concern at the site are
methane and volatile organic compounds (VOCs). the proposed enhanced landfill gas extraction
(ELGE) system seems to he a more aggressive approach to landfill management than the classic
method of capping, leachate collection and monitoring. There does appear to be an increased
potential for the release of liquid contamination to groundwater during the installation of the
numerous deep ELGE wells that will be installed under this plan. "
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EPA Response: The 1990 Record of Decision (ROD) required installation of a landfill cap and methane
collection system. Pursuant to the 1990 ROD, the approved landfill cap/methane control design provides
for a series of gas extraction wells to control migration of methane. The landfill cap/methane control
design calls for 16 wells, approximately 15 to 22.5 feet deep to capture methane gas generated by the
landfill. The maximum depth of the waste in the upper portion of the landfill is estimated to be 30 feet.
The first phase of the conceptual ELGE design, which is described in the Vlav 2000 Focused Feasibility
Study, is based upon the currently approved design for methane management with additional ELGE wells,
approximately 15 to 25 feet deep, in the vicinity of the Pilot Study location. Based on the data collected
during the first phase, subsequent phases may involve the installation of additional wells and/or increased
rates of gas extraction.
During the design of the remedy, an evaluation will be performed to determine the number and location of
the ELGE wells, associated monitoring wells and leachate monitoring points. Although the ELGE wells
are expected to be somewhat deeper than the methane wells, all of the gas extraction wells and
associated monitoring wells/probes will be installed in the zone of the waste and will not penetrate into the
bedrock and the groundwater aquifer beneath the landfill.
Regardless whether the 1990 ROD landfill cap/methane management design or the ELGE design is
implemented, care will be taken during the design and installation of the wells to ensure they do not create
a pathway for the release of contamination to the groundwater during construction.
MDE Comment 2. "Page 11. VOC Removal - If there is potential for the release of liquid
contaminants during the installation of the ELGE wells, then the timing of the baseline sampling of
VOCs should be more clearly stated in the document. .45 proposed, it is unclear whether the
baseline will be conducted "prior to the startup " of the remedial action or "prior to the startup " of
the ELGE system. The Record of Decision (ROD) requires the reduction of 90% in the
concentration of selected target VOCs. Consequently, it is to the advantage of the Responsible
Parties to maximize the baseline measurement of the target VOCs. A high baseline measurement of
target VOCs will result in a greater mass of contamination left behind in the landfill. "
EPA Response: Baseline VOC sampling data will be collected at each individual extraction well and
associated monitoring points prior to startup of that particular ELGE well. Prior to initiation of construction
activities, a remedial design work plan will be developed and will be subject to EPA approval. The work
plan and final design documents will fully define the sampling and monitoring requirements for the ELGE
remedy. During the design of the remedy, EPA will determine the appropriate sampling
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25
protocol, including the timing of sample collection, for the baseline sampling required to meet
the ROD Amendment performance standards.
The ROD Amendment requires that monitoring be conducted to determine whether the various
performance standards have been met. The performance standards may be used for cessation of
enhanced VOC removal in individual extraction wells, clusters of wells, or ultimately the entire ELGE
system. Performance monitoring will be conducted at each individual extraction well and associated
monitoring points. The performance standard for the landfill gas states that the ELGE system must
achieve a 90% reduction in the concentration of selected target VOC compounds at the monitoring points.
The 90% reduction of target VOCs will be compared against the baseline VOC sampling for each
individual extraction well and associated monitoring points.
MDE Comment J. "Page II, Leachate Monitoring - Again, it would be helpful if the meaning of
"year I "could be clarified. Is "year I " the first year of system operation or the first year following
the ROD7
EPA Response: "Year 1" refers to the first year of system operation. As discussed above, monitoring will
be conducted at the ELGE extraction wells, nearby ELGE monitoring points, and leachate monitoring
points to provide information as the effectiveness of the ELGE system. The monitoring locations will be
determined by EPA during the remedial design. The schedule for monitoring will also be defined by EPA
in the design.
MDE Comment 4. "Page 13. Post-Construction Monitoring, item J ¦ Flare VOC emissions will be
based on calculations using analyzed influent rates and the destruction efficiency of the flare. It
would probably be more accurate to directly measure the VOC emissions from the Jlare.
EPA Response: Both the 1990 ROD landfill cap/methane control design, and the ELGE design, must
comply with all applicable or relevant and appropriate requirements (ARARs). The ARARs which apply
to the emissions from the flare are identified in the Air Resources, Pennsylvania Code, Title 25, Sections
121.7, 121.9, 123.1, 123.2, 123.21, 123.31, 123.41-123.43, and 127.1. These requirements are applicable to
fugitive dust control, use of Best Available Technology (BAT), and emissions of specific air pollutants.
These regulations are applicable to the air pollution control measures to be employed during work
associated with the upgrading of the soil cover as part of the Alternate Source Control Remedy or the
Contingent Remedies, as well as emissions from the ELGE system or the Contingent Remedy treatment
system.
The ARARs require that the system be designed to meet BAT to treat emissions from the flare and do
not require direct monitoring of the emissions. During the design of the remedy, EPA will review the pilot
test data and additional Site data to determine if the
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26
system is properly designed and meets the requirements of BAT. Furthermore, EPA will determine if
BAT provides adequate protection to human health and the environment at the Site.
In addition to complying with the regulations identified above, the ROD Amendment requires that an
operations and monitoring plan be developed which will include the details for maintaining and monitoring
plan ELGE system to ensure that a systems are operating properly. Monitoring requirements will include:
sampling of the combined extracted gas for analysis of individual VOC constituents and methane; flare
VOC emissions based on calculations using the analyzed influent stream and the destruction efficiency of
the flare; and regular inspection and maintenance to ensure that the flare is operating at its designed
destruction capacity. During the design of the system EPA will determine whether direct sampling of the
emissions will be required as part of the operations and monitoring plan. In addition, EPA will determine
the appropriate air monitoring requirements necessary to protect human health on and near the landfill
property.
MDE Comment 5 "Page 20. Short Term Effectiveness - As discussed earlier, the installation of
numerous ELGE wells through the waste has the potential to release liquids that are either
contained or otherwise trapped within the fill to groundwater. The discussions of short-term
effectiveness does not seem to address this potential threat "
EPA Response: The short-term effectiveness criteria evaluates the alternatives against the period of time
needed to achieve protection of human health and the environment and any adverse impacts that may be
posed during the construction and implementation period, until clean-up goals are achieved.
As discussed in Response #1, there is not a significant difference between the conceptual design of the
ELGE system and the 1990 ROD remedy design for the methane control with respect to the number and
depth of the gas extraction wells. Therefore, EPA does not believe that the short term effectiveness of
the ELGE remedy is significantly different from the 1990 ROD remedy design for the methane control
system.
In addition, as discussed above, whether the 1990 ROD landfill cap/methane design or the ELGE design is
implemented, care will be taken during the installation of the wells to minimize short term impacts and
ensure that the construction of the wells does not create a pathway for the release of contaminants to the
groundwater.
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Warner Norcross & Judd hp
ATTORNEYS AT LAW
900 FIFTH THIRD CENTER
1 1 1 LYON STREET N W
GRAND RAPIDS. MICHIGAN 49503-248 7
TELEPHONE 616 752 2000
FAX 6 1 6 752 2500
JOHN D. DUNN
616 752 2142
Direct Fax 616 222 2142
jdunn@wnjcom
January 15, 2004

: I
Mr. Stuart P. Hersh (14-J)
Associate General Counsel
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago, Illinois 60604
Re West KL Landfill
Dear Stu:
This firm is co-counsel to Oshtemo Township concerning the remedial action for
the West KL Landfill. Mike Ortega and Pat Mason also represent the Township in this matter.
Based upon our discussion with you and Tim Prendiville on December 18, 2003,
we understand that the US EPA staff s position is that the West KL Group must proceed with the
construction of an impermeable cap as provided in the Record of Decision ("ROD"). In
particular, the US EPA staff does not support the West KL Group's long-standing request for
additional time to run pilot tests on treatment technologies which the Group believes will provide
effective source control and a superior alternative to the impermeable cap. The proposed
treatment methods are sulfate injection and Enhanced Landfill Gas Extraction C'ELGE").
In view of our inability to reach agreement with the US EPA staff on this issue,
we are submitting this letter to obtain the US EPA management's review of our request for
deferment of the start of cap construction to allow the pilot tests to proceed for 18 months after
the Group and the US EPA agree upon appropriate performance criteria for the pilot tests. If the
pilot tests are successful, the Group will implement the treatment systems at the site and upgrade
and repair the existing cap as necessary to address direct contact, erosion, and surface water
management issues. If the pilot tests do not demonstrate the effectiveness of the proposed
treatment technologies, the Group will proceed with constniction of the impermeable cap as
reflected in the current Remedial Design prepared by the Group.
We are also submitting this letter to provide notice that the Township is invoking
the informal dispute resolution process pursuant to the Consent Decree. This letter initiates the
thirty day period for informal dispute resolution pursuant to Paragraph 39 of the Consent Decree.
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Mr. Stuart P. Hersh
U.S. Environmental Protection Agency
January 15, 2004
Page 2
With respect to the cap issues, the West KL Group believes that the previous
studies and site data indicate that the best remedy for this site is the use of active treatment and
source control rather than installation of an impermeable cap. The use of an impermeable cap
will entomb the waste and retard the biodegradation activity that is occurring at the site. In
contrast, the Group's proposal would allow the biodegradation activity to continue while
providing active treatment for the contamination in the waste mass and the groundwater. In
basic terms, we believe that the Group's proposal will treat and eliminate the contamination,
while the US EPA's proposal will simply preserve the waste mass and contamination in the
source area for an indefinite time.
The Group's proposal is not driven by an effort to minimize the cost of the
remedy. The pilot tests will cost approximately SI.2 million, and the long term implementation
of the treatment systems will cost $20 million. Consequently, the issue is not cost avoidance.
Instead, the issue is whether the Group's proposal provides a better remedy for the environment
and the local community when all of the facts and circumstances are given full consideration.
Based upon the Group's prior work with the agencies on this issue, the Township
is somewhat puzzled by the US EPA staff s unwillingness to allow time to test the treatment
technologies. The Group's earlier discussions with the US EPA and MDEQ indicated that there
was consensus that these technologies could provide effective treatment for the contamination at
this site. In May 2002, the Group met with MDEQ Director Harding and his staff to discuss
alternatives to the impermeable cap approach. Director Harding agreed that treatment was
preferable to capping the waste, and he directed his staff to work with the Group to determine
whether any treatment options would provide an effective alternative. The Group subsequently
worked with the MDEQ and the US EPA staff to review treatment options and sulfate injection
and ELGE were identified as potentially viable options.
As part of the process of reviewing treatment options, the Group met with MDEQ
and the US EPA on October 15, 2002 to discuss ELGE as an alternative method for source
control. As stated in a US EPA briefing memo, the result of that meeting was that "all agreed
that the technology showed promise." (Regional Administrator Briefing Memo, December 11,
2002). During the meeting that was the subject of the Briefing Memo, Administrator Skinner
and Director Harding expressed support for the use of treatment rather than an impermeable cap.
Similarly, in the most recent written communication from the agencies on this
issue, the MDEQ stated that "a properly designed ELGE system could effectively remove
volatile organic chemicals (VOC's), including benzene and THF, from the landfill and the
vadose zone beneath it." (Jim Sygo letter to West KL Group dated May 2, 2003). Mr. Svgo's
letter further states that MDEQ's concern is that the ELGE system will not treat inorganics such
as ammonia, total dissolved solids and iron. This concern is surprising and misplaced since
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Mr. Stuart P. Hersh
U.S. Environmental Protection Agency
January 15, 2004
Page 3
inorganics have not been a significant issue at this site and the data shows steadily declining
trends that will meet the criteria within 10 years without treatment. In addition, based upon our
prior discussions with the US EPA, we understand that the US EPA concurs that inorganics are
not a significant issue at this site.
Contrary to Mr. Sygo's statement regarding inorganics, the primary issue at this
site is organic contamination. The vast majority of that contamination has biodegraded to the
point that it meets the applicable criteria. The remaining constituents of concern are benzene and
THF. As noted above, the agencies have recognized the likely effectiveness of the treatment
technologies to address the organics, and yet agency staff opposes the Group's request for time
to test and confirm that the treatment will work.
There is no material downside to allowing the additional time as requested. The
plume of groundwater contamination is stable based upon extensive monitoring data over the
past ten years. The Group recently further extended the municipal drinking water system and
agreed to provide hookups in the area to provide an additional buffer area beyond the plume
area. The County adopted an Ordinance that will prohibit the use of groundwater in the affected
area. Consequently, there are no receptors at risk of exposure. In addition, as noted earlier in
this letter, the Group is committed to proceed with the impermeable cap if the pilot tests are not
successful.
In contrast, there are significant potential downsides to proceeding with the
impermeable cap before testing the treatment technologies. If the treatment is effective,
proceeding with the cap will provide an inferior remedy that prolongs the existence of the
contamination. It will also unnecessarily impose significant burdens on the local community
related to the clear-cutting of the site and the nearby borrow site, and two years of cap
construction requiring innumerable truck shipments of cover material. The site is currently
aesthetically attractive since it resembles a wooded nature area rather than a landfill. If a cap is
built, the site will consist of 80 acres of ecologically blighted land in the midst of the community.
More importantly, the construction and related truck traffic will expose the community to
significant risks during the two year construction period for the cap. The high volume of truck
traffic will place the residents at risk of serious vehicle and pedestrian accidents. The dust and
other emissions from the construction process will degrade the air quality and heighten the risk
of respiratory ailments. The enclosed documents indicate the depth of the local community's
opposition to the construction of the impermeable cap.
At this point, the Township is not asking for a final determination on the
treatment versus cap issue. The Township simply asks for an opportunity to prove that the
treatment systems are an effective and acceptable alternative to an impermeable cap. The US
EPA's own policies require agency staff to update and modify ROD's when new information and
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Mr. Stuart P. Hersh
U.S. Environmental Protection Agency
January 15, 2004
Page 4
technologies indicate that a superior option is available. (E.g., OSWER Directive 9200.0-22,
Superfund Reforms: Updating Remedy Decisions.) In this case, the ROD was issued in 1990
and clearly did not consider the types of treatment technologies available today. The US EPA
should follow its policies and take the time to determine whether treatment is better than
capping.
In these circumstances, we believe that the US EPA will act arbitrarily and
capriciously if it refuses to allow the Group to test the treatment systems before requiring the
construction of the impermeable cap. The agency will also act contrary to CERCLA's statutory
preference for treatment. There is no risk that requires the immediate construction of the cap.
There is, however, a considerable risk that refusing the Township's request will result in the
wrong remedy for this site, while imposing significant burdens on the surrounding community.
We request a written response from you describing Region 5 management's
position regarding the Township's request for additional time to perform the pilot tests. In view
of the thirty day limit on the informal dispute resolution process, we would appreciate receiving
your response as soon as possible. If you believe that a meeting would be productive as part of
Region 5's review of this request, we will meet at the US EPA's offices in Chicago to facilitate
the process.
Yours very truly,
f
John D. founn
/kks
Enclosures
c: Mr. Thomas V. Skinner
Mr. Timothy Prendiville
Oshtemo Township Board
Mr. Michael B. Ortega
Ms. Patricia R. Mason
West KL Group
759806-5
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01/19/04 08:58 F\1 16167522000
warner
4J UU J
&
Regional Administrator Briefing
West KL Avenue Landfill Snperfund Site
Kalamazoo, Ml
December 11,2002
Purpose	i
Pre-briefing for December12.2002 meeting with MDEQ's Director to discuss the State's
current position concerning the requirement for an impermeable RCRA-type cap at this
landfill
la sues
Is a RCRA-type impermeable cap relevant and appropriate for this landfill?
Is it possible, under Superfiind, to select the alternate remedy proposed by the PRPs?
Background/Summary
1990 ROD identified Michigan's Part 111 landfill closure requirements as relevant and
appropriate requirement (ARAR) for the site.
Groundwater plume has migrated approximately 1 mile downgradient forcing many homes
onto alternate water supplies. Additional homes will be hooked up under a draft ROD
Amendment now under review.
Since 1992, with the RD/RA on hold, SFD, U.S. EPA- ORD. and MDEQ have worked
with the PRPs on multiple pre-design studies of the natural attenuation of both groundwater
contamination and source materials in the landfill.
The studies have shown several contaminants have diminished significantly over time
either through natural attenuation or dilution, and those same factors may be controlling the
migration of the plume.
However, benzene and tetrahydrofuran continue to be released to the aquifer with no
evidence of decline in their concentrations. Methane migration may also be a concern.
The PRPs position is that a RCRA-type cap is not appropriate because it will interfere with
the natural attenuation occurring within the waste.
SFD's position has been that the current cover is ineffective in controlling benzene or THF.
Without controlling leachate generation these contaminants will continue to impact the
aquifer for an indeterminate time period. A RCRA-type cap is therefore appropriate.
In March 2002 branch chiefs met with the PRPs; no new information was presented and
subsequently there was no change in the Agency's position.
On April 22,2002 branch chiefs met with Fran Kremer and John Wilson. Fran and John
are the ORD scientists involved with the evaluation of a permeable cover and MNA since
1992. Fran and John confirmed that they believe that natural attenuation is not working for
benzene and THF and an impermeable cap is warranted.
In April, EPA sent a letter to the PRPs requiring them to begin design and construction of
the impermeable RCRA-type cap as required by the 1990 ROD. Also gave them until
April 2004, to provide any new information to convince the Agency that a cap is not
appropriate.
On May 22,2002, the PRPs met with Mr. Harding to present their case. At that meeting
Mr. Harding stated that an impermeable cap might not be appropriate and that the PRPs
should work with his staff on an alternate plan that would provide an "equivalent degree of
protection".
\
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-4-x
WAR.VER
21003
On October 15,2002, branch chiefs met with MDEQ and PRPs to discuss new proposal to
use Enhanced Landfill Gas Extraction (ELGE) as an alternate source control technology.
All agreed that the technology showed promise. Agreed to move forward with pilot test if
ARAR issue can be resolved.
Future Actions
Teleconference with Director Harding and PRPs to discuss the site and the MDEQ's ideas
on how to meet the ARARs for the site.
PRPs are moving ahead with both the landfill cap design and the pilot studies for the
groundwater sulfate addition, and enhanced landfill gas extraction technologies.
Option and Recommendations
Agency should maintain its position that a permeable cap has not been shown to be
effective in addressing all contaminants. Because benzene and THF continue to be released
into the aquifer at levels which arc not adequately addressed by natural attenuation,
reducing leachate production is an appropriate measure for this site. The RCRA-type cap
should be considered relevant and appropriate. The design and construction should
continue. This position does not preclude the PRPs, before construction begins, from
presenting new information from the ELGE pilot study that might change our position.
The PRP's proposed alternate plan may provide an equally protective approach for
addressing the site based on the pilot study results. However, the ARAR issue remains
unaddressed. Current Michigan regulation provides MDEQ with the option of approving
the PRPs proposed alternate remedy based on a standard of "equivalent performance". To
date MDEQ has only indicated a willingness to say that the PRPs proposed alternate
remedy may provide an "equivalent level of protection*1. Without MDEQ agreeing that
the PRPs proposed alternate remedy provides equivalent performance, there is no basis
under state law to set aside the impermeable cap ARAR. MDEQ has asked whether EPA
could waive the impermeable cap ARAR under CERCLA. An initial analysis of the
ARAR waivers under CERCLA indicates that none of the ARAR waivers would apply.
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JAN-12-2004 HON 02:58 PH LEUISALLEN
FAX NO. 6165531439
P. 02
cbawtciw tofx)nsh?ip
IMEEDM
December 8,2003
i ^C:; C 2003 -i
7275 W. MAIN STREET, KALAMAZOO. Ml 49009-9334
269-375-4260 FAX 375-7180 TDD 375-7198
www oshtemo.org
Governor of Michigan
LiLoO'Ll'Li Lj L~:| b
The Honorable Jennifer Graitholm
State Capital
P.O. Box 30013
Lansing Ml 48909
RE: Request of the People ofOshtemo Township, Kalamazoo, Michigan, to
"Leave the KL Landfill Alone."
Dear Governor,
The West K.I, Avenue Landfill was built and closed under the Supervision of the Department of
Environmental Quality (DEQ). The DF.Q used our landfill as a show place and stated it was a state of the art
Restriction from getting well permits, on thewcstsiceofOsluemo, resulted in theTownship installing
municipal water in the area where the DEQ claims well water contains contaminates. City water was installed
and available to residents in the spring of2003, but now the EPA is delaying the process of hooking up to the
system.
The total fee for the water system was approximately 1.6 Million. At that time 350K was supplied by
Pharmacia. 99K. by ihe DEQ and more than a Million remained left to be an enormous burden for the Charter
Township of Oshlemo.
The reason the DEQ spent 99K was the result of a 250 (\. deep test well atthe back of the '"Dougherty
property" installed at the request of the DEQ, which was clean of contaminates from the landfill and proved
another source was at fault. This property abuts Dustin Lake, which also has proven clean of contaminates.
About two years ago, I received a call from Mr. TJm Prendiville (Environmental Protection Agency,
EPA). He slated five (5) other possible contaminating sources. We now know one of those sites is responsible
for contaminating the 4"* Street area, yet the DF.Q has failed to search it out and try to collect money for repair
or obtain money from the State Superfund.
The Minnoit property is another possible source. The West end of this property showed contamination
and j large area completely void of vegetation . Over a year ago, Mark Ilenry (DEQ) stated they would be
doing farther testing on this properly in a few months. As of this date, no further testing has occurred.
As you can see from the map, the flow is generally West or just South of West. This would indicate
to me the Springwood Hills development could be contaminated by the 4* Street source. Springwood Hills
was the original reason for the KL Group (Now consisting of Pfizer, Kalamazoo City, Kalamazoo County and
Oshtcmo Township) to bring water to this area, but has been expanded well beyond ihe contaminated area.
landfill.
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-12-2004 MON 02:58 Ftl LEU IS ALLEN
FAX NO. 6165531439
P, 0
The testing reports provided to us from UpJohn (then Pharmacia and now Pfizer), indicate the KL
plume is now stable, not expanding, and most of the contaminates have been eaten by the natural enzymes
in the ground. To remedy lhe two contaminates remaining, it is believed by Pfizer, the groundwater can be
treated with sulfide. This would cause the enzymes To be more aggressive in eating the remaining chemicals.
The "cap" over the existing landfill the DEQ is requesting would cost 20 Million dollars or more. A
liner of clay must be installed, drainage material and finally top dirt. The landfill is 87 acres in size. A 20-acre
parcel across from the landfill will be used, and this would devastate lhe appearance of both parcels.
A!I trees would be removed and not allowed to grow on the landfill's 87 acres, as the roots could
puncture the liner. The traffic from hauling din and the dust caused from uncovering the landfill will be more
dangerous than leaving the landfill as it is. It is better, in my opinion, to clean the landfill rather than
encapsulate contaminates, especially when the process will last only 25-50 years with no guarantee.
According to lhe F.PA.the level of the contaminates for safe drinking water standards should be below
3,900 parts per billion. The results of wells tested regarding lhe landfill have been between 50 and 150 parts
per billion. According to lhe State Health Department, filling your gas tank, putting on hair spray or driving
in heavy traffic have a more dangerous effect.
Another reason supporting inv opinion is, a few months ago the EPA & DEQ invited the Michigan
State Health Dept. to talk to the Oshtemo people. The Health Department spokesperion sated the landfill has
never caused a health issue in this area, and if this is so. the Township of Oshtemo and the K.L Group have
exceeded what was necessary by installing a water system and paying the cost to hook the people up to this
service.
The people of Oshtemo have requested we leave the landfill as it is. The cap that is being required
could cause more harm 10 the people and totally defoliate more than 100 acres. The landfill and adjacent
property are now a very beautiful area and would make a nice passive park as it contains much wildlife.
Communications we have had with U.S. Representative, Mr. Fred Upton. Slate Representatives. Mr.
Jacob W. Hoogendyk, Jr. and Mr. Alexander C. Lipscy, and Michigan Senator, Tom George show they are
supportive of our position.
iMeasc help us with the request of the people who live in the "so called contaminated area."
The support from Oshtemo residents has been unanimous. Please see the attached signature cards.
John P. Van Dyke
Supervisor
JV/li
c. Steven E. Chester
Fred S. Upton
Jacob W. Hongendyke, Jr.
Alexander C. Lipsey
l oin George
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JAN-12-20G4 HON 02:53 PH LEW ISALLEN
FAX NO. 6165531439
P.
February 21, 2003
Mr. Steven E. Chester, Director
Michigan Department of Environmental Quality
Constitution H:iU
6th Floor, South Tower
525 West Allegan Street
Lansing, MI 43933
Re: West KL Avenue Landfill
Dear Mr. Chester:
The West KL Avenue Landfill Group consists of the County of Kalamazoo, the Charter
Township of Osluemo, the City cf Kalamazoo, and Pharmacia Corporation. These
parties aro responsible for implementation of requirements set forth in a Federal Consent
Decree with respect to the We.sc KL Avenue Landfill located in Oshtemo Township,
County of Kalama200. We request the opportunity to meet with you to discuss certain
specific matters relating to the site that we have not yet been able to bring to closure.
The Group has proposed to EPA an alternative remedy to the Record of Decision
prescribed RCRA equivalent landfill cap. We believe this alternative will provide
superior long-term environmental protection, minimization ofadver.se long and short
term impact to the community, and improvement.? in aesthetics and opportunities for
future use of the land than those that would otherwise exist. Our proposal is not contrary
to Michigan law since all waste at the KLA site was disposed of prior to 1980 and it
provides a better resolution than strict application of the rules applicable to post 19S0
disposal. While MDEQ is not u party to the Consent LX'crec, EPA has requested that the
Group work with the Siarc to seek agreement on appropriate criteria and end points in
order for us to 50 forward with our request for modification to the Record of Decision.
I11 summary, the Group's proposal calls for an upgrade to the existing landfill cap.
implementation of enhanced landfill gas extraction for source removal, and the addition
of sulfate/nutrient to accelerate already occurring biodegradation.
The Group met with then Director Harding and some of his senior staff in Lansing on
May 22, 2002. At lhal time, the Director expressed interest in the concept proposed and
instructed us to work with the siaff and "think out of the box" to bring the matter to
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JAN-12-2004 KON 02:59 PM LEUISALLEN
FAX HO. 6165531439
P. 05
Mr. Steven E. Chester, Director
Michigan Department of Environmental Quality
February 21, 2003
Page 2
resolution. See the attached letter dated May 23, 2002 from Kevin M. Walsh to Director
Harding regarding that meeting. We followed through with this request, added at this
time the gas extraction concept, and have proposed implementing pilot programs for each
of these technologies with defined end points that would evidence the long-term viability
of this alternative.
On December 12. 2002, we met with Assistant Director Nash and senior DEQ staff to
seek MDEQ's concurrence. Director Harding, along with the EPA Region 5 Regional
Administrator and some of his senior staff participated in the meeting from Chicago via
conference call. At rhe conclusion of that meeting, the Director indicated he would
attempt to provide us with a response by December 23, 2002, but as you may be aware,
he was unable to do 50. Also at the end of that meeting, letters were sent on behalf of the
Kalamazoo County Commission and the Oshtemo Township Board specifically
supporting the parties' request for an opportunity to establish its alternative remedy.
Copies of those 'letters r.rc attached.
The Group continues to believe ihat our proposed remedy is superior to that currently
contained in the Record of Decision. The cost of implementing the proposed pilot
programs, however, would make it impendent to proceed without some assurance of
acceptance if agreed upon results are obtained.
The Group has proceeded with pursuit of this option while at the same time undertaking
the design of the RCRA equivalent cap in accordance with the EPA established timetable.
That timetable calls for design completion for of the impermeable cap in April, 2004.
Approximately two years is required for us to hope to obtain sufficient data to reach
technically sound conclusions from the pilot projects. Consequently, if we are to go
forward with these pilot projects, we will need not only the agreement of the MDEQ, but
also an extension of time of the cap timetable from EPA. We have requested such an
extension from the EPA, and have been advised that EPA will consider that request if we
are able to bring the issue with the MDEQ to conclusion in a short time. Given the
elimination of exposure pathways in the area, there is no risk, arising out of reasonable
scliedulc extension.
Consequently, the Group requests the opportunity to meet with you, and such of your
staff as you desire, in order to review this matter more thoroughly with you. Our
approach, while not unique (a similar remedy is currently being implemented at another
Superfund site in Pennsylvania), is not commonly utilized despite what we believe to be
significant advantages give site specific factors. We would appreciate such a meeting as
soon as feasible not only to attempt to put this matter to rest, but also to minimize any
delay in the ongoing schedule of implementation.
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JAN-12-2004 HON 02:59 Ptl LEW1SALLEN
FAX NO. 6165531439
P.
Mr. Steven H. Chester. Director
Michigan Department of Environmental Quality
February 21, 2003
Page 3
Please feel free to direct any questions or responses you niay have to any of the
undersigned.
Very truly yours,
i



^ / £ [ / >1 A
Ja/n VanlSyke
Suoarvisor
Donald H. Gilmer
County Administrator
CITY OF KALAMAZOO
PHARMACL\ CORPORATION
"fovin M. Walsh
£",-^7 ATT*t.;C
Director, Global Auditing and Remediation
Hncs
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JAN-12-2004 HON 02:59 PH LEWISALLEN
FAX HO. 6165531439
P. 07
Mr. Steven E. Chester, Director
Michigan Department of Environmental Quality
February 21, 2003
Page 4
Bcc: Bob Cinabro
Mike Ortega
Duane Tricmstru
Kevin Walsh
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, i* c c>) 5	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:

Signature	-T 
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i, _IhiLjL&o£a	 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature

, am a citizen residing in
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
OsKtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I.rsj/laAo?		, am a citizen residing in
Oshtemo Charter Town^ip, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, A/-0	—	
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
, am a citizen residing in
Signature £/
My comments

>>'—
it
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
GL6 u v v\. e.
I,	(q	—¦	, am a citizen residing in
Oshtkmo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signatun
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-63
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, £( r\-e. Sc-gyxcK	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue landfill.
. ,	ii	4-V>o
My comments are:	\\ seem* v.W«.
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Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, N ortYxg^ . Bi-^vncK	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
1 support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	b«_ -Sow**.o«">•*-> s»«*N«.wV\e-rt.,	^*Y% ^
W Vo.—JLCA\	Oo ¦=««• ***•	uM\
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Signature	I
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i, Df. 7#6>m S F-
am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:\$Ux Avjlaa**-
\S	U->i EPP stc	Cr^^cLu^JZrv.
Ph.L
Signature	u
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. IJkFf RucX/ifa		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	1/1
f/m k/ tW. >"*	h*
\te
tyreat fating paw^,
-------
Tim Prendivllle
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
1/		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	•
UX
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
1/
¦V6
[rqiAia
iartei
J-
Oshtemo Charter Township, Kalamazoo! County, Michigan
, am a citizen residing in
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		t am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort, of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		, am a citizen residing in
Oshtemo Charter Townshi^fKalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendlville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, -fcmaiWiUi f uvp	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		' am a citizen residing in
Oshtemo Charte£>Townsftip, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature

Signature ^ \
-------
Tim Prendiville
USEPA Region 5
Super-fund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, Don) AtO		 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
ofil£/TYu
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,

£j>L
, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill
Aw OOCtW^ ST"\
My comments are:
10
o
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
am a citizen residing in
Oshtemo Charter Yownship, Kalamazoo County/Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
C\ \ •
V. JtX	V.
Signature >
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590			
, am a citizen residing in
Oshtemo Charter Township, Kafa&azoo Count^Michigan.
I support the effort of the Township and the KLA Group to amend.the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are: ^ 
-------
Tim Prendlville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, /~/6 n r-y Dunoey	, am a citizen residing in
Oshtemo Charter Townshftf, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
,¦»	+u
0„ -He KL
Signature '	/ /
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, ~77aa	Du		< am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	, e f- fo c,rd
X Jo not Support	/- an4T''''
ature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. If ill(2^ T Dfjwm	 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and
Decision as to the impermeable cap on tt
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
ChicagjcMfc-60604-3590
St£tf	 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
My comments are:

-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		f am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
LQtb
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I. ntm
, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	^
UM r* Clnn		
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
h	??? i—	 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are;
Signature
Tim Prendiville
USEPA Region S
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, 1160604-3590
I#	ft	am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:

_	' ' 
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
log r-i- ^S~€yiL&Q	 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:'~P| ease cLo ncrb d.R3iro^ 0«,r tithborhcc
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, f		, am a citizen residing in
Oshtemo Charter Unship, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Chartef Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, I). 60604-3590
I, (	l~lar»~iS	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the Impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, AI 1 K]-££sc>*J- ^	am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	.
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, L/\e>u	/V. •U-A-W 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signal
i
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	C cV\. A C*	t am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
Signature
My comments are:
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
ti)	7/
I,		, am a citizen residing in
Oshtemo Charter Towns tftp, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature

Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township,'^Calamazoo County, Michigan.
I support the effort, of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
i
-------
Tim Prendlville
USEPA Region 5
Superfund Dlv. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		, am a citizen residing in
Osht^mo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
fijhviA 1
Signature

Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, PAc O I ^ ^ourMAU	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are: p$(2 L\5fEkJ> TV
lUCflOCR reCUOOLGG^ ^ Clr^^CS J -
Png JL ^
Signature

-------
Tim Prendiville
USEPA Region 5
Supetfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	k H* ^ 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I. ShibUvi jhithtaH 	, am a citizen residing in
Oshtemo Charted/Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
ignature
-puloMxy	WAV
TJjuv ft
Signature
Signature Cj

-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Sidnature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	^uc-	t am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision ^-te^the impermeable cap on the KL Avenue Landfill.	/
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
1	J _, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, (Jm'		, am a citizen residing in
Oshtemo Chartqi^ownship, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Signature J?
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	/
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, Wcwxde^ fV		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
., am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:

Signature
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Dlv. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	t am a Cjtjzen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
d /2a	-5r^c=rzr?
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:		
^ &TT^>vlS7 A 
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	;r		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort, of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature v

£
111
, ^
v-
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are;
BE1 >*?L
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, lb 60604-3590^	-
I, rx^y	, am a citizen residing in
Oshfemo garter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	/
-------
Tim Prendiville
USEPA Region 5
Super-fund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590	Sfc
I, ^CYCxr-v, r\—		, am a-Citieen residing in	(Xs3\&s
Oshtemo Charter Township, Kalamazoo County, Michigan.
1 support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:



Signature

Tlm Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I. .
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
T). /yuUu	 	, am a citizen residing in
Oshtemo Charter Township, KalarKazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, ^A/Jg		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:


3 JUlLo
I
-------
"Tim Prendlville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, HI a ^/ff u ) mi Ji	, am a citizen residing in
Oshfemo Charter Township, Kalamafoo County7Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are: ~r n it ^ „	/	/	/
J. pe-r<-,o*o4lj <,e£ Ko food reo£&\. "To Castrocr A.
Cop ,f Ae Con fowl no.kofi piumt IS	SyaJkjp/	//V*
2¦- «	/TiMifiOfJLs
Signature
Tim Prendiviile
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, / wcLLA			, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
1
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div, SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
1/ A OnkA* Q j/Hc	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
iignature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590	#
, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	t am a CitjZen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.


Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. Mo/pry Hilled	
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, foGOCU frll	t am a dtjzen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. QWm tfl. llWdli man I	 	, am a citizen residing in
Oshter^o Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, <,o.^ P Alpfrs cl	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort, of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
L/o&m
ilgnature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, SL {hr/./)h.LuiA\ /dUugtL. am a citizen residing in
O^fitemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Dtv. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, ScPff		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan,
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
11 West Jackson Blvd.
Chicacjo, IL 60604-3590
t Vm
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicaao, IL 60604-3590
I. hJicUIas fkbocL
Oshtemo Charter Township, Kalamazc
	, am a citizen residing in
Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
/?- cc \Tf7X
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i,.	fcl
-------
Tim Prendiviile
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago^IL 60604-3590
vt	-Imp-v'*
I, ' lffrXx4 r~ rft'lJtPS	f am a CjtiZen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
fUL
Tim Prendiviile
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, -K3*	^ am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendlville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, i?	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
k&Tj, /a/ trie.	4/
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
_, am a citizen residing in
Oshtemo Cnarter Township, KalamazCcfCounty, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Signatui
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, s4ys?/)r^		, am a citizen residing in
Oshfemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort, of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
, am a citizen residing in
Signature
i
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	pA. Sctwrr	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, k Hcm~ °^f\cruO	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Signature
-------
Tim PrendMlle
USEPA Region 5
Superfund Dlv. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
, am a citizen residing in
femo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
' 9nature

Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I. hi	In If	 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, Brioin -3". ToVV-cn	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan,
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
ignature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	""J" " /£)u?hi	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are;	A'
11 ^
I
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
_, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, ,i(A.., 1 i -tZZj*		 am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590 ,
iA1- l/lfg'fs'faeA , am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	^ q oo ^s
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I. Rot**		 	, am a citizen residing in
Oshtemotharter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	n n C--/t<4 L-	_, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort, of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
/y? ^ ^ /sJ^
Ignature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	^ am a Cj^zen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
'j
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, f?g>7	U// J it <	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	,
¦The.
whZl Us	*> ^	¦
Old /tr-y	CV
Signaturey
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort, of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	rt nrsoKjv^ .
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. NiH 2-OhBV/frT		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Jeanni V.ZuniSurd)
, am a citizen residing in
author y yrnUA
Slanah irp
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
QPP09
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I.	f?ecjb(V^/	 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:

, am a citizen residing in
TKt! LM\&FilL~
C&V ^ A <,E>£Ar ,
Signature
-------
1L 80604^0?
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rT-y\\i%l
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Mi (pbmrfients are:
| nature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, 100604-3590/^
¦ /
, am a citizen residing in
Township, Kalamazoo County, Michigan.
I support th^ffort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are;
Slgnature
-------
Tim Prendiville
USEPA Region 5
Superfund Dlv. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Dedsion as to the impermeable cap on the KL Avenue Landfill.
My comments are:
A yoo	^		
cm )$
SignaturTv_^/
\/0> "iHiST	~TH^ LDM6>
T TH iM£- THAT LOC^O- AT Mft>	oT*®- pgne6VSS
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
rf£*. sLJC R*. ¦"«*-
My comments are: I
US dlC.					a /	.
»o ^f*i A-t
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div, SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
OshtemtKlharter Township, Kalamazoo County, Michigan.
I |Dw^rt the effort of the Township and the KLA Group to amend the Record of
Decisiorl as to the impermeable cap on the KL Avenue Landfill.
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	1/J		 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
My comments are:

-------
Tim Prendiville
USEPA Region 5
Super-fund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	, am a citizen residing in
OsKtemo Charter'Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
y	. v -	'
(JO2— ^	^ ^
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	, am a citizen residing in
Oshtemo Charter township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
	dOlr'A*
Signature '
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. "Tk 0 rr\&- 5 D. K" o£r\ i a	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo^County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
TL I O-rv	xv C Wo*. % nj
^$$'¦"3 "t ^ H Slgnatu?e
ca- cXiy Co| w.H	^ re»^Ae<'
ex U o uo , rsjj V^)jV "V6	C C *"**5 £ •
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I# Ln i £BaPuj-??	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I. tV/HCMf U ) .		 	, am a citizen residing in
Oshtemo Crfarter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
1,7 ^ cj ft	, am a citizen residing in
Oshtemo Charter Township, K&lamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are: 4 ¦( ^0

-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago/lL 60604-3590 v
I,	C/t~TT£ LL ^ am a Cjtlzen residing jn
Oshte^o Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,		, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	iQfcJJfl-i'D	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL'60604-3590
	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, "W-V (V \/fcinAp f foes V	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
Oshtemo
, am a citizen residing in
arter Township,Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signatyre
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, Tc&J/si		 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, 7-a-aj^£ L&tJl**.	/ am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature"^
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
	CulP	 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. £k7 L STaFPoSD _, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Mnnahirp	v
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, Omluvuc	0I3 / , am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Dlv. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
Cu<}//A-~	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, P..	/JeeoasS*-	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
T) "S-HrrVj
, am a citizen residing in
7
Signature f )
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. Yla^-^ <3L>	am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KU\ Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
RECEIVED
Signature
DEC 12 200}
	J TOXJSHIP

B -
_ _ ...	$£ v"	o
Tim Prendiville	<.•
USEPA Region 5	>J*il "
Superfund Div. SR-6J	QS*®
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, 7?%
-------
received
Tim Prendiville
USEPA Region 5	QEC 12 2003
Superfund Div. SR-6J
77 West Jackson Blvd.	' ITR/10 TG7,\ iSHi?
Chicago, IL 60604-3590
I,	/-C	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
RECEIVED
Tim Prendiville	q£C 1 2 2003
USEPA Region 5
Superfund Div. SR-6J	OSHTEMO TOWNSHIP
77 West Jackson Blvd.
Chicago, IL 60604-3590
i. & c.uohy CqoC£ 	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, 0. /JeeuvS*-	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	^ S+qti e,	^ gm g Cjtizen residing jn
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:
Signature ( )
-------
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I, Ay fljvLUj (_l&rC	, am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
I support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:	A'Lu^jlv ^	1
tQjUL	u^bta (Zu.rreM NJ&aStJL	,
^\ ^ f )
no	//>		
"S. 20£>*-j
OuQ O	U3frufl<^ lo£-
& CcM	cA 'tSte xin.o&j&a
^ U3er €_ k)£- 4i5Tn <3j^£) •
Tim Prendiville
USEPA Region 5
Superfund Div. SR-6J
77 West Jackson Blvd.
Chicago, IL 60604-3590
I,	/J/i^	t am a citizen residing in
Oshtemo Charter Township, Kalamazoo County, Michigan.
1 support the effort of the Township and the KLA Group to amend the Record of
Decision as to the impermeable cap on the KL Avenue Landfill.
My comments are:

Signature
-------
-------
*10000004
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Bofors-Nobel Site
Muskegon, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Bofors-Nobel site, in Muskegon, Michigan, chosen in accord-
ance with CERCLA, as amended by SARA and, to the extent practic-
able, the National Oil and Hazardous Substances Pollution
Contingency Plan. This decision is based on the administrative
record file for this site.
V
The State of Michigan concurs on the selected remedy.
ASSESSMENT OF THE SITS
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
This operable unit is the first of two operable units for the
soils in the lagoon area, a major source of contamination at the
site. The second operable unit will involve remediation of
contaminated soils in the vicinity of the operating manufacturing
facility and remediation of the contaminated groundwater. The
response action for this operable unit addresses the principal
threat remaining at the site by treating the most highly contami-
nated sludge. Treatment residuals, less-contaminated sludge, and
soils contaminated at low levels will be disposed of in an on-
site landfill that will meet the intent of RCRA subtitle C
requirements.
The major components of the selected remedy include:
Excavation and treatment, via on-site thermal treatment, of
approximately 101,000 cubic yards of the most-contaminated
sludge from the lagoon area;
Disposal of approximately 19,000 cubic yards of less-
contaminated sludge, approximately 353,000 cubic yards of
contaminated soils, and solid treatment residuals in an
on-site RCRA Subtitle C landfill; and
-------
Upgrading of existing groundwater pumping and treatment
system.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element. Because this remedy
will result in hazardous substances remaining on-site above
health-based levels, a review will be conducted within five years
after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
Valdas V. Adamkiis
Regional Administrator
Date
-------
DECISION SUMMARY FOR THE RECORD OF DECISION
SITE NAME. LOCATION. AND DESCRIPTION
The Bofors-Nobel (Bofors) site is located 6 miles east of down-
town Muskegon on Evanston Road in Egelston Township, Muskegon
County, Michigan (see Figure 1). This 85-acre site includes a
currently operating specialty chemical production facility, an
unused landfill, a currently operating groundwater pumping and
treatment system, and 10 abandoned sludge lagoons. The southern
portion of the site is bounded by Big Black Creek. Pertinent
site features are shown on Figure 2. There are wetlands on
either side of Big Black Creek, within the Big Black Creek flood-
plain. The approximate location of wetlands within the site
boundary is shown in this figure. A lacustrine aquifer underlies
the site and is contaminated from previous site activities. The
existing groundwater pumping and treatment system prevents off-
site migration of the contaminated groundwater into Big Black
Creek. This portion of the aquifer is not currently being used.
A clay till approximately 150 feet thick underlies this lacus-
trine aquifer and separates it from the underlying Marshall
Sandstone, a drinking water aquifer. There appears to be an
upward hydraulic gradient through the till.
Big Black Creek is currently being used for recreational pur-
poses. This includes fishing and swimming. In addition, there
is evidence of transient residences on the south side of the
creek.
Approximately 1,800 people live within a 1.25-mile radius of this
site. The primary route of exposure for this population is
nated groundwater will not migrate off-site assuming the existing
pumping and treatment system remains operational.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Lakeway Chemicals began producing industrial chemicals at the
site in 1960. Throughout the 1960s and early 1970s, ten on-site
lagoons were used for disposal of sludge, wastewater, and various
waste liquids. This practice resulted in contamination of the
groundwater underneath the site and, subsequently, Big Black
Creek. Because of this contamination, the State of Michigan
placed various restrictions on wastewater disposal from the site.
In 1976, wastewater from the plant was accepted at the Muskegon
County Wastewater Treatment Plant, and purge wells were installed
at the site to extract contaminated groundwater.
-------
IAKETW *0
Ift LAKE
AO
SUMMIT
Figure 1 Site Location Map
rrp>-. -v ;	—v'W-Vctr^'iH • ¦> >yr"7 \ rr. ¦
-------
EVANS TON ROAO
LOWAC PLANT
V
uNUSfcO
LANOmLL
LAGOONS
QEhMS
LOU.
0OUNOARY
LAGOONS-

APPROXIMATE
WCTVANO
QOUNr'AO* "M
VICINITY OF
AREA rO
-80*0*5
SITE 0OUNOARY
BlC 8LACX CREEK
NUM8ERS*SOURCE AREAS
N
Figure 2 Site Detail Map
-------
Bofors Industries, Inc., merged with Lakeway in 1977 and with
Nobel Industries in 1981. In 1985, Bofors-Nobel (Bofors) filed
Cor bankruptcy for reasons including reported environmental
expenditures in excess of $60 million. As part of the bankruptcy
settlement, the State of Michigan received 515 million and the
U.S. Environmental Protection Agency (U.S. EPA) received
$5 million to be used toward site remediation. As a result of
legal action in bankruptcy court, Bofors was allowed to sell the
operating chemical plant to Lomac, Inc. (Loraac). As part of the
sale, agreements were reached between Lomac, the Michigan
Department of Natural Resources (MDNR) , and U.S. EPA that Lomac
would not be liable for cleanup of contamination existing prior
to the sale of the plant area property. These agreements allowed
Lomac to operate the plant independently of previous site activi-
ties. The site was nominated for the National Priorities List
(NPL) and was placed on the NPL in March 1989. The Remedial
Investigation/Feasibility Study {RI/FS) was initiated in
August 1987.
Bofors Lakeway, Inc., was a wholly-owned subsidiary of Bofors
America, Inc. (BAI). BAI was a wholly-owned subsidiary of Nobel
Industries Sweden A.B. (Nobel). Nobel is a Swedish corporation.
On May 18, 1990, U.S. EPA sent CERCLA Statute 104(e) information
requests to BAI and to Nobel. BAI responded to those CERCLA
Statute 104(e) information requests in part on June 21, 1990.
BAI filed a supplemental response on August 27, 1990. U.S. EPA
is currently evaluating those responses. U.S. EPA is planning to
fund the Remedial Design (RD) immediately.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS and Proposed Plan for the Bofors site were released to
A.h ij \a * j	ilicat:	^ w«_ u..,o • i C S	dVa. .dblfi
to the public in both the administrative record and an informa-
tion repository maintained at the U.S. EPA Docket Room in
Region 5 and at the Hackley Public Library in Muskegon, Michigan.
The notice of availability for these two documents was published
in the Muskegon Press on July 21, 1990. A public comment period
was held from July 23 through August 23, 1990. In addition, a
public meeting was held on August 1, 1990. At this meeting,
representatives from U.S. EPA and MDNR answered questions about
problems at the site and the remedial alternatives under consi-
deration. A response to the comments received during this period
is included in the Responsiveness Summary, which is part of this
Record of Decision (ROD). This decision document presents the
selected remedial action for the Bofors site in Muskegon,
Michigan, chosen in accordance with CERCLA, as amended by SARA
and, to the extent practicable, the National Contingency Plan
(NCP). The decision for this site is based on the administrative
record.
2
-------
SCOPE AND ROLE OF OPERABLE UNIT WITH SITE STRATEGY
As with many Superfund sites, the problems at the Bofors site are
complex. As a result, U.S. EPA organized the work into two
operable units (OUs). These are:
o Lagoon Area Operable Unit (L.O.U.): contamination in the
sludges, in the lagoons, in the soils under and around the
lagoons, and upgrading of the existing groundwater pumping
and treatment system.
o Groundwater and Plant Area Operable Unit (GW/PA O.U.):
contamination of the groundwater under the site and contami-
nation in the soils in the plant area.
This ROD concerns the first of these two operable units. This
operable unit addresses the principal threat through source
control. The location of the L.O.U. is shown in Figure 2.
As shown in Figure 2, the L.O.U. includes eight of the 10 lagoon
contaminant source areas investigated. The remaining two lagoons
did not contain detectable levels of contamination. The southern
portion of the L.O.U. is bounded by a groundwater extraction
systen that controls the groundwater contaminant plume.
This area of the site poses a principal threat to human health
and the environment because of the risks from contaminant Migra-
tion from the sludges and soils into the lacustrine aquifer
directly under site, that is a potential source of drinking
water. The contaminated groundwater, if it discharges into Big
Black Creek, also poses risk from ingestion of contaminated creek
water. There is also a threat because of the risks from lnhala-
i/ji	contaminants troni tne siuuges and soils. i'ne
purpose of this response is to reduce contaminant migration into
the groundwater, surface water, and air, and prevent direct
contact with the contaminants.
SUMMARY OF SITE CHARACTERISTICS
The RI included the following tasks:
o	Lagoon sludges and soils characterization
o	Plant area soil characterization
o	Air sampling and analysis
o	Surface water and sediaent characterization
o	Surficial soil characterization
o	Aquifer characterization
o	Groundwater sampling and analysis
o	Wetlands survey
o	Baseline risk assessment
o	Treatability studies
3
-------
The results are summarized as follows.
Contamination and Affected Media
The lagoon area sludges and soils and the groundwater showed
detectable levels of contaminants related to the site. The
surface water sampling and analysis showed no detected contamina-
tion. The air analysis indicated contamination only from the
operating plant. Therefore, only a summary of contamination for
the lagoon area sludges and soils and the groundwater is pre-
sented.
Lagoon Area Sludges and Soils
In the lagoon area, 10 potential source areas were identified.
In these 10 source areas, the sludge from the lagoons, the soil
beneath the lagoons, and the soil around the lagoons were sampled
and analyzed. The organic compounds detected for the lagoon
sludges and soils beneath and around the lagoons are presented in
Table 1. As discussed previously and as shown in Table 1, detec- w
table levels of contamination were found in eight of the
10 lagoon areas. These source areas were subdivided into four
possible subareas: lagoon sludge, contaminated soil ber.eath the
lagoon sludge, contaminated soil around the lagoon sludge, and,
in some cases, a berm. These source areas and subareas are shown
in Figure 2. The source areas were subdivided because the magni-
tude of contamination varies considerably among the eight source
areas and their subareas. From a treatment standpoint, risks
were calculated for each source area and subarea separately to
aid in selecting the most cost-effective remedial alternatives
which provide the greatest protection of human health and the
environment. Contaminated soils around the laqoons were identi-
[i«u Laxity results from a i-acre grio sampling interval; cms
explains the irregular source area configurations shown in the
figure. The compounds of concern developed from the baseline
risk assessment are listed below:
o Methylene Chloride
o Benzene
o 3,3'-Dichlorobenz id ine (DCB)
o Aniline
o Azobenzene
o Benzidine
These six compounds of concern were chosen because they are
highly toxic and drive the risk assessment for this site.
Methylene chloride, DCB, aniline, and azobenzene are potential
human carcinogens. Benzene and benzidine are known human
carcinogens.
4
-------
The Toxicity Characteristic Leaching Procedure (TCLP) was
performed on selected lagoon area sludges and soils to evaluate
the potential mobility of metals in the waste material. The
results of TCLP testing were compared to TCLP standards which can
be used as a measure of metal mobility. The concentrations of
metals in the waste were found to be below the TCLP standards.
Therefore, metals in the sludges and soils are not anticipated to
be compounds of concern at this site.
As discussed previously, these lagoon area sludges and soils are
a major source of contamination to the groundwater under the site
and, therefore, a source of contamination for Big Black Creek if
the groundwater pumping and treatment system is turned off. The
lagoon sludges and soils are also a potential source of contami-
nation to air in the vicinity of the site.
The volume of each lagoon subarea was estimated using data
generated during Phase I and II RI activities. The volumes and
surface area associated with each lagoon subarea are shown in
Table 2. The volumes for the soils beneath the lagoons include
material extending from the bottom of the sludge to the average
water table depth. ' The soil volumes around each lagoon were also
calculated using a depth of contamination of five feet in each
area, except in the area between Lagoons 6, 8, and 9. In that
area, the soil around the lagoons is assumed to be contaminated
to the water table, because of the proximity of the lagoons to
each other and possible overlapping of the lagoon boundaries.
The assumption of contamination only in the top 5 feet for the
rest of the soil around the lagoons is based on evaluation of the
contaminant transport mechanisms by which the contamination
migrated to these soils. These soils are estimated to be
contaminated by surficial mechanisms such as trackout and
axi Li is *. i ic	nui ds»t>umpi_xuii wni need to be veciiitiu
during the remedial design. The berm volumes were calculated by
direct measurement off the site topographic map and only include
material above grade. Volumes calculated for soils around the
lagoons are based on limited information and should be considered
as approximate values only.
Approximately 4 54,200 yd3 of total contaminated media is
estimated to be at this site. Approximately 22 percent
(101,500 yd3) represents contaminated sludge; 34 percent
(156,200 yd3) represents contaminated soil beneath the lagoons;
39 percent (178,500 yd3) represents contaminated soil around the
lagoons; and 4 percent (18,000 yd-3) represents contaminated berms
around the lagoons. The volume of contaminated media may be
further refined prior to remedial design.
5
-------
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Groundwater
Monitoring and purge wells were sampled and analyzed during the
RI. The organic compounds detected in the groundwater are
presented in Table 3. The extent of contamination in the ground-
water appears to be bounded by the plant area to the north and
the groundwater pumping and treatment system to the south.
Contaminated groundwater at the site appears to be captured by
the groundwater pumping and treatment system. At the present
time, approximately 1 million gallons of groundwater per day is
collected by the existing groundwater pumping and treatment
system and is pumped to a biological/carbon (PACT) treatment
system owned by Lomac that also treats Loaac wastewater. The
treatment effluent is discharged to the Muskegon County
Wastewater Treatment Plant.
Based on historical data and groundwater modeling, if the
groundwater pumping and treatment system is turned off, the
contaminated groundwater will discharge into Big Black Creek, and
the creek will become contaminated.
Potential Routes of- Migration
Potential routes of migration and contaminant fate and transport
were evaluated for the Bofors site. Based on this evaluation,
the most significant pathways for release of contaminants at the
Bofors site are through the air, surface water, and groundwater
pathways. The Phase I baseline risk assessment indicated that
the risks associated with ingestion of the sludge and soils was
significantly less than the risks associated with the ground-
water, surface water, and air pathways. Fate and transport
mechanisms are summarized below for each of these three
*---••	J - •
Air Pathway
Contaminants can be released to the air in two ways, either by
particulate or volatile emissions. Risks from particulate
emissions were estimated for exposure by inhalation. These risks
were estimated as approximately 100 times less than the risks
from inhalation of volatile emissions. Therefore, volatilization
appears to be the primary release mechanism to the air pathway
from the lagoon area sludge and surficial soils surrounding the
lagoons. Benzene, methylene chloride, and azobenzene are classi-
fied as highly volatile compounds and may readily volatilize from
the sludge and contaminated surface soils. Aniline may also
volatilize from the sludges, but to a lesser extent, and DCB and
benzidine may volatilize to a limited extent. Even though these
moderate and low volatility compounds may volatilize to a lesser
degree, there may be significant mass loading to the atmosphere
because of the large surface area and high concentrations of
these compounds in the lagoons. Modeling of emission rates and
contaminant transport via the air pathway have shown that the
lagoon areas, due to their considerable surface area, present a
-------
TABLE 2
SOURCE AAEA VOLUMES (yd3)
SOPORS SITE
Muskegon, Michigan
Soil	Soil	Percent
Source	B«neatti	Around	Total	of Total
Area	Sludge	B»t»i	Lagoons	Lagoons	Voluae	Voluae
1	3.400	300	9,300	7,700	20,700	4.6
3	7,600	0	10,700	J,900	22,200	4.9
5	8,000	0	14,400	6,300	28,700	6.3
6	3,400	2,300	5,400	17,900	29.000	6.4
7	7.000	0	26,400	12,600	46,000	10.1
9	28.400	5,500	28,400	M.400	76,700	16.9
9	9,600	0	30,500	33,100	73.200	16.1
10	34,100	9,900	31,100	82,600	157,700	34.7
Total	101.500	18,000	156,200	178,500	454.200
Percent
of Tor 4 I
Voiuae	22.J	4.0	34.4	J9.3
Note: Soil volume around the lagoons was calculated assuaing only the top
5 feet of soil ts contaainated.
RP/BFRSROD/AA3
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significant source of volatile contaminant transfer to the air.
Even though air analysis indicated contamination only from the
operating plant, sampling and analysis of this medium contains
uncertainties.
Photolysis, or the breakdown of compounds through exposure to
light, may also be a loss mechanism for benzidine, azobenzene,
and DCB in the sludge and surficial soils. This mechanism may be
partially responsible for the general absence of benzidine in the
surficial soils. However, the breakdown products from photolysis
of these compounds are hazardous. Oxidation may be a loss
mechanism for benzene, benzidine, and aniline, especially in the
lagoons with high iron content such as Lagoons 3 and 9.
groundwater Pathway
Another contaminant migration route is through the groundwater
pathway. Contaminant release to the groundwater has occurred
from the lagoon sludge, soils beneath the lagoons, and contami-
nated soils around the lagoons due to infiltration of water
through these media into the groundwater.
Sorption significantly decreases the mobility of azobenzene and
DCB, especially in the sludge, because these compounds strongly
sorb to organic material. This may be the reason these chemicals
are currently present in such large concentrations in the lagoon
sludges. Methylene chloride and benzene sorb to the sludge but
less strongly. Benzidine and aniline do not appear to strongly
sorb to lagoon sludges. Sorption has a lesser effect in soils
beneath the sludge due to the	"roan?'- content of these soils.
However, even if soils have low organic content, sorption nay be
significant for DCB and azobenzene because of the hiah affinity
01 tnese compounds to even smoii amounts ot soil organic
material.
Dissolution and leaching of compounds from the sludge and soil
appear to be the primary transport mechanism to the groundwater
in the upper lacustrine aquifer. The contaminated groundwater in
this aquifer does not appear to be a potential source of contami-
nants to the Marshall Sandstone drinking water aquifer due to the
upward hydraulic gradient through the clay till that underlies
the upper lacustrine aquifer. Furthermore, diffusion of contami-
nants through the till is expected to be extremely slow.
Surface Water Pathway
During the RI, no surface water runoff was observed. The primary
route of contaminant releas* to the surface water appears to be
groundwater discharge. As noted previously, contaminated ground-
water is not presently being released to Big Black Creek since it
is being intercepted by the groundwater pumping and treatment
system. Therefore, groundwater discharge is not considered a
7
-------
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potential route for migration as long as the groundwater pumping
and treatment system is in operation. However, past site condi-
tions and computer modeling performed for the baseline risk
assessment have shown that, if the groundwater pumping and treat-
ment system is turned off, groundwater will be a major contamina-
tion migration route to the surface water.
Potential Receptors
Populations that could be affected, if exposed, include:
o Industrial workers (Lomac, Sun Chemical, Eagle, commercial
facilities north of Evanston Road),
o residents on i.'oli Lake, !.
-------
( (
Urtois: ppm
Compound
(.tqoon 1
TABLES
GROUNDWATER CO*C NTFVMlOMS OBTAJNEO FROM THE AT 1230 UOOEL (PPM)
Bo(«t Site
Muskegon, IAcaJqaa
Leooon 3 I qooa 5 lAOOon 6 leooon 7 Legoon 3
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The main health effects of these six compounds are as follows:
o Aniline: Attacks the blood, liver, kidneys, and cardiovascu-
lar system. Hay cause anoxemia, central nervous system
depression, or cyanosis. Headaches, irritability, dyspnea,
unconsciousness, and even death may result from cyanosis.
Aniline is considered a potential human carcinogen.
o Azobenzene: Can irritate the eyes, skin, and respiratory
tract. Azobenzene may also cause blood disorders. Azoben-
zene is considered a potential human carcinogen.
o Benzene: Acute exposures produce primarily central nervous
system effects such as dizziness, nausea, headaches, loss of
balance, narcosis, coma, and death. Benzene is also a known
human carcinogen and causes several forms of leukemia.
o Benzidine: Direct contact may cause contact dermatitis and
primary irritation or sensitization. Benzidine is also a
known urinary tract carcinogen with an average latency period
of 16 years.
o 3.3'-Dichlorobenzidine fDCB): Direct contact may cause
allergic skin reactions. DCB may contribute to bladder
cancer and is considered a potential carcinogen.
o Methylene Chloride: Repeated contact may cause dermatitis
and eye and upper respiratory irritation. Methylene chloride
is also a mild narcotic; effects include: headache, giddi-
ness, stupor, irritability, and numbness. Exposure may cause
elevated carboxyhemoglobin levels. Methylene chloride is
considered a potential human carcinogen.
Exposure Assessment
Based on the baseline risk assessment, several exposure pathways
were evaluated, including:
o air, as a result of volatilization of organic compounds from
the surface of the lagoons;
o wetland sediments through resolubilization of contaminants
and transport downstream in Big Black Creek;
o groundwater through direct use of the groundwater,
o surface water, through potential contamination of Big Black
Creek by contaminated groundwater;
o direct contact with waste, and
o ingestion of waste.
9
-------
Three of these pathways presented the most significant risks to
potentially exposed populations:
o ingestion of contaminated groundwater from infiltration of
contaminated precipitation from the lagoon area;
o ingestion of contaminated surface water;
o inhalation of contaminated air from volatilization of organic
compounds from the lagoon area surface.
Potentially exposed populations used in the baseline risk assess-
ment included adults living on- and off-site. Groundwater, air,
and unsaturated-zone transport modeling was performed for the
compounds of concern to characterize exposure point concentra-
tions. Modeling procedures were developfl to evaluate receptor
exposure to the chemicals of concern for the lagoon sludge,
berms, soil beneath the sludge, and soil around the lagoons for
each lagoon area. The emission rates into the air or water from
the sludge, soils and berms were first calculated, then the
transport through the air and groundwater was evaluated.
A computer program was developed to calculate volatile air
emission rates from each lagoon source area. A 70-year average
emission rate was determined for each source area. Air risks
were determined from the downwind concentrations at receptor
locations.
Risks from dust emissions were estimated for exposure by inhala-
tion. These risks were estimated as approximately 100 times less
than the risks from inhalation of volatile emissions. Risks from
inhalation of metals within the dust are expected to be less than
risks from inhalation of organic compounds adsorbed to dust
Darticles, because metals have hiaher settlina velocities *nri *r«»
not transported as easily.
Chemical emissions from the unsaturated zone to the groundwater
were also estimated. Simulations were run for each lagoon source
area to determine the contaminant mass input to the groundwater
from the sludge and soil beneath the lagoons, the sludge only,
the soil beneath the lagoons only, the berms, and the soils
around the lagoons. The 70-year average mass inputs were then
calculated and the results were used as input to a groundwater
model. The groundwater risks were then calculated using the
maximum groundwater concentrations determined with the ground-
water model.
Surface water risks were evaluated using average contaminant
concentrations in groundwater expected to enter Big Black Creek,
accounting for dilution by clean upstream water and groundwater
on the opposite side of Big Black Creek. The dilution rate was
estimated to be approximately 100, therefore, the surface water
concentrations are 100 times lower than the corresponding ground-
water concentration.
10
-------
The major assumptions used In these models were:
o The contamination is uniformly distributed within the soil or
sludge matrix.
o The contaminant of interest is assumed to be bound to either
the soil or the sludge,
o The waste does not flow within the carrier matrix,
o The adsorption isotherm of the constituent of interest Is
linear within the depth of the waste and does not change with
time.
o No flow of gas is Induced within the waste matrix,
o The diffusion coefficient does not vary with either concen-
tration or time.
o The concentration of the constituent of interest in the gas
phase at the surface of the lagoon is much lower than the
concentration of the constituent of interest in the gas phase
within the waste matrix,
o No diffusion of the contaminant into depths below the waste
layer is assumed,
o Contaminant vapor, waste, solid, and water equilibrium is
established at all times within the waste matrix,
o Hydrolysis, biodegradation, and ligand formation were assumed
to be insignificant mechanisms at this site,
o The aquifer is infinitely wide.
The assumptions made for the risk assessment include:
o People would be exposed to areas where the highest levels of
contamination were found, i.e., maximum concentrations were
used during the risk assessment to generate risks.
o 70-kg adult resident is exposed daily over a 70-year
± x l. e a me .
o Daily intake is 2 liters per day of groundwater or surface
water and 20 cubic meters per day of air.
o 100 percent absorption is assumed.
o The groundwater pumping and treatment system is turned off.
These conservative assumptions allow the risk assessment to
emphasize health protection.
Toxicity Assessment
All of the six compounds of concern are known or potential human
carcinogens. Cancer potency factors (CPFs) have been developed
by U.S. EPA's Carcinogenic Assessment Group for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic.chemicals. CPFs, which are expressed in units of
(mg/kg-day) , are multiplied by the estimated intake of a poten-
11
-------
tial carcinogen, in mg/kg-day, to provide an upper-bound estimate
of the excess lifetime cancer risk associated with exposure at
that intake level. The term "upper bound" reflects the conserva-
tive estimate of the risks calculated from the CPF. use of this
approach makes underestimation of the actual cancer risk highly
unlikely. Cancer potency factors are derived from the results of
human epidemiological studies or chronic animal bioassays to
which animal-to-human extrapolation and uncertainty factors
been applied. The cancer potency factors for these compounds are
presented in Table 7, RFDs were not used because the carcino-
genic toxic effects of the compounds of concern far exceeded the
non-carcinogenic toxic effects.
This cable also presents information or. wncctier the compound is a
known or potential carcinogen. As shown m the table, benzene
and benzidine are known human carcinogens (A),« the other com-
pounds of concern are potential human carcinogens {b2)¦ Benzi-
dine is the most carcinogenic compound and DCB is the second most
carcinogenic compound of the compounds of concern. Benzidine and
DCB are several orders of magnitude more carcinogenic than the
other compounds. These two compounds, and particularly benzi-
dine, therefore, provide the highest risks at the site and drive
the level of remediation required.
RISK CHARACTERIZATION
Excess lifetime cancer risks are determined by multiplying the
Intake level with the cancer potency factor. These risks are
probabilities_that are generally expressed in scientific notation
(e.g., 1 x 10" ). An excess lifetime cancer risk of 1 x 10
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developinq cancer as a result of
a A vc-i enuu expusuie to a Cdi c-inogen uvci' u 
-------
TABLE 7
COMPOUNDS Of CONCERN ANO CARCINOGENICITY
BofenSfte
Mutkogon, Mtehtqan
Compound	PotfKV Slop* fmoAq/doyl	EPA ClMtfflcttfon
Aniline	0.0057	&j
Azoboraene	0.17
Benzene	0.039	A
Be«Iid'ne	A
3.)'-OfchkMob*««rkfln» (DCS)	3.5	Bj
Methylene Chiend#	0 0079	B>
A
Ba
Known humen carcinogen.
Known tnlmeJ eercinogen; Probeble humeri cereinogen (from Risk AitnmtfX Guidenee (or Superfund. 1969)
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Groundwater Ingestion Risks
Groundwater ingestion risks are presented in Table 9. These
risks range from 9.9 x 10 to 3.4jX 10 . Overall, the sludge
presents a total risk of 9.9 * 10 , the soil beneath the lagoons
has a total risk of 6.6 x 10 , and the soil around the lagoons
presents a totalrisk of 1.7 x 10 and the berms present a total
risk of 1.2 x 10	The sludge and soil beneath the sludge pose
the greatest overall risk for groundwater ingestion. Total
groundwater ingestion risks resulting from sludge, soil beneath
lagoons, soil around lagoons, or berms are all above acceptable
limits. The highest magnitude of risk is associated with
benzidine. DCB poses the next highest risk.
Surface water ingestion Risks
Surface water ingestion risks are presented in Table 10. These
risks assume that the groundwater pumping and treatment system is
turned off. The calculated risks range from 1 x 10 to
3.4 x 10" . Benzidine is the chemical which drives the overall
risk for surface waterl2 Benzidine's combined risk for all source
areas exceeds 2.5 x 10 . Thus, even though the surface water
poses risks substantially lower than the groundwater, the risks
from surface water ingestion are above the acceptable range by at
least four orders of magnitude.
Combined Risks
The highest excess cancer risks developed were associated with
the groundwater exposure pathway. The combined carcinogenic
risks reflecting all the contaminants of concern and all exposure
pathways of concern are estimated to be approximately 10 excess
Cditcbi risn.. Non-carcinogenic effects die estimated to be
insignificant in this operable unit, since the metals in the
sludges and soils do not appear to exhibit significant mobility.
If mobile, the non-carcinogenic effects would become significant.
Therefore, non-carcinogenic effects were not used to estimate the
level of remediation required.
Risks and risk-based cleanup criteria should be considered
approximations due to the limitations and uncertainties of the
manner in which these concentrations are computed. When modeling
contaminant transport, when estimation was necessary, a value was
chosen to provide the most conservative realistic risk estimate.
Tests with the model have shown that contaminant concentrations
within the soil and sludge have the greatest effect on overall
risks. Other parameters, such as permeability, organic carbon
content, surface area, and volumes may have significant effects
on calculated risks.
13
-------
1ASUE 9
Compound
L»on 1
EXCESS C" cNi»oi*ruMir»
5BI«
84E4M
J IE-03
22E04
$4&04

1 0C-01
3 5E-CO
Anlim*
< I£
ND
NO
NO
NO
NO
3«e
NO
NP
?6£-&»
NP
7.SE-06
AieMnitn*
NO
NP
NP
22E*7
NP
S.9E-0:
Nf»
t 6E-06
teuton*
w
te
NP

NP
8 BE-f '
MB
2 5E02
Tolfti
4 4E-06
NP
NP
1 2E-02
NP
tx<
NP
2SE<»
SOHA«OU«OtW>OONS








tMififtmw Chi
NO
NO
NO
NO
WO
NO
NO
NO
Dcmtna
NO
NO
VO
NO
NO
NO
3JE-04
NO
J.J- DMMMOtW 01 >ttn*
1 4E-C3
1 «E10
ND
NO
3»E-0-
ND
136-0?
taotwnnn*
NO
2 2E06
!2E-06
3 9ES6
4*E4?
2.7£ is
3 16-06
4 3E45
BtniiOiiw
NP
lit£2
'10. _
HP
NO
ae_
13E-W
w
Toltl
l 4E-C3
26E03
ISES4
1 5€ 03
? 4E-03
80S ¦
1 ?e«2
iae-0?
nC	Goma>rTitfVKAi not dtttcitd In	Irom m*% 1*900"
NP	Med * net (NiMm in	Ugoon »>¦«
(
(
-------
Environmental Risks
Based on the preliminary evaluation performed for the preliminary
risk assessment, site contamination does not appear to have
affected critical habitats or endangered species. The State
completed a qualitative evaluation of the likelihood and magni-
tude of each identified exposure pathway on endangered species.
No adverse affects on wildlife were identified in this prelimi-
nary assessment.
The wetlands on this site are located in the floodplain on both
sides of Big Black Creek. A portion of these wetlands are
located within the L.O.U., as shown in Figure 2. These wetlands
consist of .i variety of plant communities with good species
diversity. The entire valley area is composed of a complex
mosaic of different wetlands, ranging from forested wetlands to
small ponds. There are mature communities as well as recently
developed wetlands, and wetland formation is still occurring
within this active floodplain area. These wetlands appear to be
relatively undisturbed by site contamination. However, U.S. EPA
believes that, if the extraction system were turned off, impact
to wetlands might occur from discharge of contaminated
groundwater.
Although an animal study was not conducted on the site, past
experience indicates that these types of wetlands would support
good populations of various animal species. The relatively
isolated and undisturbed nature of these wetlands, their
proximity to upland woods, and the continuous band they form
along Big Black Creek indicate potential for supporting good
populations of deer, fur bearers, songbirds, migratory water
fowl, herons, eqrets, reptiles, amphibians, and a variety of
xnvei lcui . Musi	tins wetidiiu udiiu ciiau serves dS a
pathway for local movement of animals.
None of the wetland types or species encountered on the project
site are unique or rare in the Upper Midwest. It is possible,
however, that individual plant or animal species occurring in
these wetlands may be federally protected or state protected
species.
Summary
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
14
-------
I
LxCESSCAK
Mtttyter* CMofU*
Bantar*
3.3D*cM»oOtnzi6io«
Asuhn*
Ajot*nMA4
Bamioma
Total
SlUPGE ONLY
MatftytoM Ok*«da
BatUtnc
3.3 Dkhtoiobwuldew
ArtAr*
AlO&MMM
ToUl
SOIL BENEATH LAQOONS
Compound
Lagoo i
Ljqooo 3
SOt. AND SlUDGE
UerofeanxMl/*
Anknt
AlOtofUan*
B*ntkUna
fo4*J
Mathytana CNor«)a
Bafuana
3,3-QKhlorobaniidma
tottina
Ato6«Ai«r*
iBanndina
Total
SOIL AftQUNO LAGOONS
M«ihyt«n« ChkMidi
Bantar*
X>Dictkyot*njtdif%9
Anifcna
Aiofr^ruana
Uaniidtfta
Total
NO
NO
3	9E-07
4	l£49
2 7E-C6
NO
6 26-07
NO
NO
9BE47
NO
NO
N2	
5 96-07
NO
NO
NO
4.1E-09
2 7EO®
NO
3i£oe
NO
NO
4 4E-M
ND
NO
NO	
44g«0*
NO
NO
1 4EOS
NO
NO
NO	
1 «e os
NO
S.2E-06
94E-06
ND
2.4E-06
I-Of#
IDE-02
NO
2.2E-00
1.26-06
NO
3 ftE-00
3AC-03
1AC09
NO
7.46-10
l.3E«
9.»E«6
24EOO
$.46-03
NP
HP
NP
NP
NP
NP
NP
NO
NO
1	4E-06
4.1E 10
226-06
LZE55
2	6* 05
NO
NP;
Coniarrtnaot net datactad in »*mpla(i) from fr»t lagoon
Madu noi paaaot m apaafcad 1*9000 am
table to
fl F*SX5 FROM SU^ACE WAT EH t*36STlON
Bolcwa $l|a
Mottkgot, MichtQin
lagoon 5	Ljqooo 6	Lagoon 7	Lajooft t	LAQooo 0	Laooon 10
0E-10	49E 10	1.16-11
9E-U	NO	NO
IE-OS	2.2E-06	04E-O6
JD	NO	NO
7 £-06	5 7E-09	1 2E-06
2E-Q}	1-06-03	Nfi	
3E-05	1.0E43	6 4E-0B
0E-10	4.9E-10	1.16-11
*6-11	NO	NO
4t07	2JE-07	1.76-06
10	NO	NO
66-09	1JE46	t.26-06
iO		4.06*04	NO	
16-07	4JE-04	1.7646
06-10	NO	NO
0	ND	ND
fiE-06	31E-06	I4E<0C
NO	NO	NO
7E<»	I0IC9	NO
SE-0&	i.16^5	Nfi	
JE-W	&4EC5	14E-06
P	6 6E-06	NP
P	NO	NP
' °	4 6E-07	NP
r5	NO	NP
°	2 2E-09	NP
°	I-2E-04	NP
5	12E-04	NP
3	ND	NO
0	NO	NO
dE-06	1.SE-0S	2 4E-05
D	NO	NO
?tO«	39E06	4 96-09
	1		NO _	NO
SE-06	1 SEOi	2.4E-Q&
4.1E-C9	NO	NO
3 46-08	3 66-09	2.96-11
2	66-OS	106-03	3.3645
NO	3 At-06	J.lE-06
6.9E-08	S0EO9	9 4EOS
tfi		tTE-03	2X41
2.6E-05	6.7E-01	2JE-61
4.16-09	NO	NO
J4E-06	3BE-00	I.7E-10
J<6-00	2.4E-M	4JE-M
3(^09	3.4E-06	SSE-08
i^toe	•££-<»	i.7E-o«
1.364H	8BE-03	XE-03
i.JC-03	SJE-03	J«E<»
NO	NO	NO
NO '	NO	1.9E-I0
rte-oi	stE-os	<»€<»
NO	12E-0S	8 4E-09
9*tOe	8 9E-CH	IJE«7
NO		4 7E-04	?4E
-------
FEASIBILITY STUDY ISSUES
Remedial Action Objectives
To evaluate the effectiveness of the technologies assessed in the
treatability study, the groundwater ingestion risks were used to
estimate the post-treatment chemical concentrations necessary to
meet specified risk levels. As described previously, the ground-
water ingestion route of exposure poses the greatest risks to human
health and the environment.
The cleanup criteria developed in the RI using EPA guidance,for
risk basedcleanup criteria are presented in Tables 11 (10~ Risk)
and 12 (10 Risk). However, on July 11, 1990, State of Michigan
administrative rules ueie promulgated pursuant to Act 307, p.a.
1982 that require a modification of these levels. The Act 307
cleanup criteria for the sludge, bems and soil are based upon a
10-6 risk concentration calculated using methods presented in Act
307 rules. The concentrations for the compounds of concern are:
Methylene Chloride, 100.0 ug/1; Benzene, 20.0 ug/1; 3,3' -
Dichlorobenzidine, 2.0 ug/1; Aniline, 120.0 ug/1; Azobenzene, 6.0
ug/1; Benzidine, .004 ug/1.
In the event the analytical detection limit for these compounds is
above Act 307 risk based cleanup level, the analytical method that
can achieve the lowest method detection limit which can be measured
and reported with 99% confidence, will be used to deternine the
cleanup criteria. If the compound is not detected the criteria
slidil bt: tunsiucuu i-u uo dciuevtiu. I tie modified cleanup criteria
are not expected to have an effect on the scope or cost of the
remedy.
lne mass ot each contaminant in each lagoon subarea was calculated
from the RI data and the distribution of each compound in each of
the four types of subareas were calculated, as presented in
Table 13. As shown in this table, the sludge and bems account for
64 percent of the contamination by the compounds of concern. The
soils under and around the sludge account for 36 percent of the
contamination by the compounds of concern. Benzidine drives the
remediation because of its extremely high toxicity. Of the total
benzidine distribution at the site, 83 percent is present in the
sludges and berms. These figures clearly indicate that the
majority of the contamination is present in the sludges and berms
and that the soils beneath and around the sludge are significantly
less contaminated than the sludges and berms.
Applicable or Relevant and Appropriate Requirements
Section 121(d) of SARA mandates that, for all remedial actions
conducted under the CERCLA, cleanup activities must be conducted in
a manner that complies with applicable or relevant and appropriate
requirements (ARARs). The NOP and SARA have defined both
applicable requirements and relevant and appropriate requirements
as follows:
-------
-------
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-------
Untoi: rngAg tpprn)
Si
430
7712.J
27123330
367704
iu«raa
KMft15
6)5%
LEGEND.
Si:	Sludo*.
SB.	Son bMHtti toffoon
B:	EWfm.
SA.	Sol AfOMTtd IftQOOO.
kWthytiM CNortt*
6m«m
oca
AnMto*
Aiot*«u*ft«
toe** of loul Mm*
TAfiLE 13
COHTAf NAKI MASS DtSTFU&UTOfJ BY SU6AAEA
BotortSlM
MuiMpon, MkfvgftA
Tool Uu> 	 	P* otni Uj»
SB	 	 b		SA	SL	SB	8		SA
01
3 t
-
924%
02
• 0
00
20
-
10209®
43.0%
-co
00
57.0
241710
.>0906 0
253913.0
4i 0%
40
4,0
440
626 6
M.t
132 J)
NO %
16
"00
03
(•193 4
2204ft
42*03
M.4%
IS
11
20
n»fi

121,1
BM1
ifi_S
ai
JU
57 %
26\
30.1%




-------
o Monitoring groundwater and surface water. Samples from
existing monitoring wells would be collected to assess the
effectiveness of the remedial action, if applicable. Samples
would be collected four times during the first year of
monitoring and twice annually in subsequent years. To
monitor surface water quality, samples from two locations
would be collected in Big Black Creek. The surface water
samples would be collected on four occasions during the first
year of monitoring and twice annually in subsequent years.
Remedial Alternatives 2, 3, and 4 contain the following addi-
tional components:
o Constructing on-site roads. About 4,500 feet of roads would
be constructed on the site, primarily near the sludge
lagoons, to accommodate truck traffic on the site during the
remedial action cleanup.
o Monitoring air. Air samples would be collected from the work
zone and perimeter of this site during excavation of the
contaminated material. Air samples would also be collected
to measure the potential emissions from the treatment facili-
ties. These samples would be collected from the facility
stack and from the site perimeter. The frequency of sampling
would be determined prior to construction.
o Groundwater pumping and treatment. The groundwater is
currently being pumped using the existing groundwater extrac-
tion system. For this remediation, the pumping system would
be upgraded and the distribution system would be relocated to
accommodate excavation and treatment of the lagoons. A new
treatment system would be built. Treatability studies
iiiuivui.eu t.uu utuiic treatment will dcjueve ectiuent concen-
trations below detection limits. Therefore, the groundwater
would be treated using an ozone oxidation treatment system or
a system that achieves equivalent performance. The treated
effluent wouLd then be discharged to Big Black Creek.
Although a National Pollutant Discharge Elimination System
(NPDES) permit is not required because treatment and dis-
charge of the effluent occurs on-site, the substantive
requirements of the permit will be met. The proposed Best
Available Technology (BAT) discharge standards for the
indicator chemicals are as follows: Methylene Chloride, 5.0
ug/1; Benzene, 5.0 ug/1; DCB, .06 ug/1; Aniline, 4.0 ug/1;
Benzidine, .04 ug/1; discharge standards for Azobenzene are
in the process of being developed. The groundwater treatment
system will be operated to achieve these standards.
18
-------
Alternative 1:—Ho ftgtl
-------
To reduce water and wind-born# migration of contaminants off-
site, erosion controls will be used. As needed, dust suppression
techniques will be used to reduce airborne contaminant transport.
After the initial grading of the site, the area to be capped will
be further prepared. Initially, a foundation layer will be
formed using local or imported material capable of structurally
supporting the weight of the cap. This material will be spread
and graded to form a smooth subgrade prior to cap placement.
Final grading of the subgrade will be performed in accordance
with the proposed cap grades to provide positive surface drainage
off the cap. A drainage system will be constructed to collect
consolidation leachate.
The minimum post-compaction slopes for the cap will be 5 percent
where attainable; the maximum cap slope will be 25 percent. The
final capped area will rise approximately four feet above
existing grade. Stability of the soils on-site is not expected
to be a problem for the cap design for most of the site.
However, based on geotechnical testing, the sludges consist of
low-strength, highly compressible materials. These construction
concerns have been taken into account in the cap design and cost
estimate. After final grading is complete, the cap will be
fertilized, seeded, and mulched to promote vegetative growth.
Drainage pathways will be established to divert surface water
runoff away from the capped area on a permanent basis.
Groundwater Components
The groundwater is currently being pumped using an existing
groundwater extraction system. For this remediation, the pumping
system would be upgraded to increase performance efficiency and
the distribution system would be relocated to accommodate excava-
tion and treatment of the lagoons. As previously mentioned, a
new treatment system would be built, using an ozone oxidation
treatment system or equivalent system to treat the groundwater.
The treated effluent would then be discharged to Big Black Creek.
In this alternative, the groundwater will be pumped and treated
perpetually to contain the groundwater plume.
General Components
This alternative addresses all of the contaminated soils and
sludges in this operable unit through containment using capping
and groundwater extraction. Capping the eight source areas will
reduce air emissions and reduce infiltration of precipitation and
contaminants into the groundwater. However, the reduction in
infiltration will not be sufficient to achieve 10~ risks for
groundwater or surface water ingestion. Therefore, the existing
pump and treat system will be operated perpetually and will
contain the groundwater contaminant plume to prevent groundwater
migration off-site and subsequent surface water contamination.
Institutional controls limiting on-site access and groundwater
20
-------
Figure 3
C< mporients of Alternative 2
At Some* atms:
23 Aaas of
Contami naiad
Skjdg* & Soil
Cappng with
RCHA Subtitle
Cap
' Organic Com pounds (ppb):
Methylene Chtonde: ND-2200
Baruan*: NO-MO.OOO
Anina: ND-J.900.000
Azoberuana. ND-12.000.000
Benzidine: ND-3.400.000
OCB N0-3.500,000
1 10-' Carcinogenic Rltk leval
Grading
Cap Connor ion
Upgrade Present
System
' Perpetual Op«ration
10 Contain Plume
Cleanup Cnttna
lor Groundwater
Deierqi.ned m Final
Operable Units
Laachata Qeneratad
from
compact on dunng
corsiixictnn
•	longHerm O&M - groundwater monitonng
- cap iniegnty monitonng
•	Institutional
Controls - deed rennctions on groundwater uxa
- access restrictions
•	10-* carcinogenic rtsk level assuming no laiun of pjiya wal system,
cap or institutional control*
•	S12.091.000 Capital
•	$429,000 Annual O&M
•	Jl 9.690.000 Present Woctn
Contaminated

Ground* alar

Ore
anon
r
Groundwater

Enraaion

Equ
Tre;
aleni
nam
El'luon:
Discnarge Standards
Determined »1 Final
Ope'.aole unit
Disci .:rg8 tc
Big Black
C< #k
tcr* Caicinogemc level
St.218.000 Capua)
$357,000 Annual 04M
¦rrva Until Cleanup Goals Met
	1	
Capping
• ? years
Groundwater
(
(
-------
use will also be incorporated to prevent future development, site
access, and use of the contaminated groundwater. Placement of
the cap will involve alterations to the wetlands in source area
10.
This alternative is estimated to achieve a risk of 10 6, assuming
the cap, groundwater extraction and treatment system, and
institutional controls are successfully maintained. This
represents a five order-of-magnitude reduction in risk from the
10 initial risk.
The cap will require periodic inspection and repair. Periodic
sampling, inspection, and maintenance of groundwater monitoring
wells and the groundwater extraction system will be required. As
noted previously, the cap will be constructed to meet the intent
of RCRA Subtitle c. Although RCRA is not applicable or relevant
and appropriate for this operable unit, the level of technology
required by RCRA is proposed to be used to provide an increased
level of protection.
Institutional controls on groundwater use and site access may be
difficult to enforce-over an extended time period. There is
significant uncertainty over the likelihood that the institu-
tional controls, the cap, and the groundwater extraction and
treatment system will be operated, maintained, and enforced
forever.
The costs and estimated implementation tine frame for Alterna-
tive 2 are:
Capital:	S12 million
Annual OiM:	$429,000
i	nui wit.	9^^ ntiiiion
Estimated Implementation Time:	2 years
ARARs
Alternative 2 will comply with the substantive requirements of an
NPDES permit (Clean Water Act), which is an applicable ARAR.
Since wetlands on the north side of Big Black Creek will be
impacted during the construction of this alternative, the
substantive requirements of a 404 permit will need to be satis-
fied, as well as the requirements of the State Wetland Protection
Act, also applicable ARARs. The State Soil and Erosion Act is
relevant and appropriate to this alternative, which is expected
to comply with the requirements of this ARAR. The Clean Air Act
and State Air Pollution Control Act are applicable to this
alternative during construction of the cap. This alternative is
expected to comply with the requirements of these ARARs. The
Safe Drinking Water Act is a relevant and appropriate ARAR and
the State Water Resources Commission Act is an applicable ARAR to
this alternative because of discharge of treated groundwater to
21
-------
Big Black Creek. The requirements of these ARARs are anticipated
to be net by this alternative. According to the State of
Michigan, the Michigan Act 307 requirements may not be met.
Alternative 3:	On-Site Incineration/Low Temperature Theoial
Desorption. Cap. Pump and Treat Groundwater
Alternative 3 consists of combined treatment and containment
technologies directed toward removal and treatment of the most
contaminated sludges, and capping of less contaminated sludges
and soils. The components of this alternative are presented in
Pigure 4. The components presented in this figure are approxi-
mate and may be modified during design or construction.
Treatment Components
Source Areas 3 and 9; Sludge, berms, and soils under the sludge
will be excavated and incinerated on-site. Low-temperature
thermal desorption (LTTD) may be used on either or both of these
source areas or subareas if pilot-scale testing indicates accep-
table performance by achieving the cleanup criteria. LTTD is a
volume reduction technology that removes contaminants from the
sludge or soil by volatilization and concentrates the contami-
nants in an aqueous phase which is then treated. This technology
can provide a less-expensive alternative to incineration when
there is sufficient performance to achieve cleanup criteria.
Source Areas 6 and 8: Sludge and berms will be excavated and
incinerated. On-site LTTD may also be used on either or both of
these source areas or subareas if pilot scale testing indicates
acceptable performance.
Source Area 10: Slnrlm	— v'1' bo exc: • 1 .. . 	ic-
on-site using LTTD.
Fluids generated during the construction of the cap from sludge
compaction in Source Areas 1, 5, and 7 will be treated in the	w
groundwater treatment system.
Fluids generated during LTTD will be treated on-site using the
groundwater treatment system. Scrubber water from the incinera-
tor will be treated by precipitation or equivalent treatment.
Filter cake from filtering the LTTD wastewater will be incine-
rated in the on-site incinerator. The groundwater beneath the
site will be collected and treated using ozone or equivalent
treatment.
22
-------
i
>»n V—> 1 )M'

>trm «CM)
0C« mO-»»CB0
*«*¦-« *0 XQ
«Otynx mCVi^QOOO
IkHm «A>M09
--r1
Iwn «0-»»00l
x» no*-in»oM
A0^4 900 000
Mr« «o-J*ceoce
*w»»iiw k too- ¦} oeo ooo

O ix
K&* f
•	5f<
•	tyllXOdUli^
Tim# uou C'ti«vq Oont Met
(
Figure 5
C omponents of Alternative 4
10*Q~M"t (MM
-	ground**)* T>oo*onr>9
-	CM) md
inugpvy mornonng
10-* wcrogtrtc n** i«vfi
US. 752.000 Cj«4*
UO.OOO AftOMJOAM
170474 000 Pr*««ct Wof*
•	c*
•	SI t'lWCiM
•	UST0BO4**stf0)V
mC'f^morA. nO l inflt4brq
- 5
**»«• Pf«03
-------
The costs and estimated implementation time frame for Alterna-
tive 3 are:
Capital:	$74 million
Annual OSM:	$344,000
Present Worth:	$80 million
Estimated Implementation Time:	5 years
ARARs
The ARARs presented for Alternative 2 also are pertinent to this
alternative. In addition, air emissions requirements concerning
construction of equipment that may be a source of air emissions
in the Clean Air Act and Michigan Air Pollution Control Act are
applicable to this alternative. RCRA is a potential ARAR for
this alternative if the ash tests positive as a RCRA characteris-
tic waste. According to the State of Michigan, this alternative
does not satisfy Michigan Act 307 requirements.
Alternative 4: On-site Incineration/Low Temperature Thermal
Deaorptlon. On-Site Landfill. Pump and Treat Groundwater
Alternative 4 also consists of combined treatment and containment
technologies directed to treatment of the most contaminated
sludges and landfilling of less contaminated sludges and soils.
The components of Alternative 4 are presented in Figure 5. The
components presented in this figure are approximate and may be
modified during design or construction.
Treatment Components
Source Areas 3. 6. 8. and 9: Sludge and berms will be excavated
if pilot-scale testing indicates acceptable performance.
Source Area 10: Sludge and berms will be excavated and treated
on-site using LTTD.
Fluids generated during LTTD will be treated on-site using the
groundwater treatment system. Filter cake generated during LTTD
will be incinerated on-site. Scrubber water from the incinerator
will be treated by precipitation or equivalent treatment.
Landfill leachate will be treated in the groundwater treatment
system.
The groundwater from beneath the site will be pumped and treated
using ozone or equivalent treatment.
24
-------
Containment Components
All material in Source Areas 1, 5, and 7, including sludge,
bens, and soils, will be excavated and placed in an on-site
RCRA-type landfill. The ash from incineration and LTTD (Source
Areas 3, 6, 8, 9, and 10) will be placed in the on-site RCRA
landfill. Soils beneath and around the lagoons in these source
areas will be excavated and also placed in the landfill. The
approximate location of the landfill is presented in Figure 6.
Groundwater Components
The groundwater component for this alternative is the same as
described in Alternative 3.
General Components
This alternative also addresses all the contaminated sludges and
soils in this operable unit through a combination of treatment
and containment. The risks remaining after remediation using
this alternative are estimated to be 10~ . This alternative will
require the excavation and treatment of approximately 100,800 vd3
of sludge and berms and landfilling of approximately 18,700 yd3
of sludge. The approximate volume of soil to be landfilled is
334,700 yd3. The volume of ash from incineration and LTTD that
will be landfilled is 73,100 yd3. The total volume of material
that will be landfilled is approximately 426,506 yd3. The
landfill will occupy approximately 8 acres. A minimum of 12-feet
separation between the landfill base and the water table will be
provided. Landfilling of soils in source area 10 will impact the
existing wetlands.
~>i^^o	AinuxmpxcmeiilacwAiUt. frame for Alterna-
tive 4 are:
Capital:	$65,752,000
Annual OSM:	$313,000
Present Worth:	$70,874,000
Estimated Implementation Time:	5 years
ARARs
The ARARs presented for Alternative 3 also are pertinent to this
alternative except Michigan Act 307 requirements would be met.
SUMMARY OF COMPARATIVE ANALYSIS OP ALTERNATIVES
The following nine criteria were used to evaluate the four
alternatives:
1. Overall protection of huaan health and the environment:
addresses whether a remedy provides adequate protection and
25
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Approximata landfill Location
Figure 6 Location of RCRA Landfill
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describes how risks posed through each pathway are elimi-
nated, reduced, or controlled through treatment, engineering
controls, or institutional controls.
2.	Compliance with applicable or relevant and appropriate
requirements (ARARs): addresses whether a remedy will meet
all of the ARARs of other Federal and State environmental
laws and/or justifies a waiver.
3.	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 goals have been met.
4.	Reduction of toxicity, mobility, or volume through treatment:
is the anticipated performance of the treatment technologies
a remedy may employ.
5.	Short-term effectiveness: addresses the period of time
needed to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period, until clean-up goals
are achieved.
6.	Implementability: is the technical and administrative feasi-
bility of a remedy, including the availability of materials
and services needed to implement a particular option.
7.	Cost: includes estimated capital and O&M costs, as well as
present-worth costs.
8.	State Acceptance: is used to indicate the state's comments.
y. Community Acceptance: summarizes the public's general
response to the alternatives described in the Proposed Plan
and RI/FS Report. The specific responses to public comments
are addressed in the Responsiveness Summary section of the
ROD.
Threshold Criteria
Overall Protection of Hunan Health and the Environment
Alternative 1 provides no protection, since,no action is taken.
Alternative 2, even though it attains a 10~ risk, is the next
least protective because no treatment of the principal threat is
included in the alternative. If failure of the cap, institu-
tional controls, or pump and treat system occurs because the
original source is still present, the site could return to
currentgrisk levels. In addition, in this alternative, achieving
the 10" risk estimate assumes that institutional controls and
groundwater pumping and treatment will be maintained forever, an
26
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unlikely event. Alternative 3 is more protective than Alterna-
tive 2 because of the treatment of sludge, bems, and soils, and
the finite groundwater pumping and treatment period. However,
Alternative 3 presents a 10~ risk, two orders of magnitude
greater excess cancer risk than Alternatives 2 and 4. This
greater residual risk is due to the use of capping only as a
containment technology, rather than in combination with perpetual
groundwater pumping and treatment. Alternative 4 is the most
protective because it provides treatment of highly contaminated
materials, high degree of containment of less contaminated
materials through landfilling rather than capping, and does not
require perpetual pumping and treatment of groundwater.
Compliance with ARARs
The substantive provisions of the following have been identified
as ARARs for this operable unit:
Federal:
o Clean Water Act (33 O.S.C. 1251)
o Clean Air Act (42 U.S.C. 7401)
o Flood Plain Management and Protection of Wetlands (42 U.S.C.
4321)
State:
o Water Resources Commission Act (ACT 24 5)
o Goemaere-Anderson Wetland Protection Act (ACT 203) •
o Michigan Environmental Response Act (ACT 307)
o Soil Erosion and Sedimentation Act (ACT 347)
o Air Pollution Act (ACT 348)
The following have been identified as potential ARARS for this
operable unit:
o Resource Conservation and Recovery Act (42 U.S.C.6901)
o Safe Drinking Water Act (42 U.S.C. 300(f)
Federal
The Clean Water Act (CWA) regulates the chemical, physical, and
biological integrity of surface waters. Under Title III and IV
of this act, effluent standards and permits are required to be
established and applied to discharges to surface waters.
Section 404 of Title IV specifically regulates the discharge of
dredged or fill material into surface waters, including adjacent
wetlands. Title 40, Part 129 of the Code of Federal Regulations
(40 CFR 129) establishes effluent standards and ambient water
criteria for certain toxic pollutants, including benzidine.
27
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Alternative 1, the no action alternative, will affect the water
quality of Big Black Creek, a recreational-use stream, since this
alternative involves the discontinuation of the groundwater
pumping and treatment system. Alternatives 2, 3, and 4 include
pumping, treating, and discharging groundwater on-site to the Big
Black Creek. Therefore, this regulation is applicable to all the
alternatives for the L.O.U. 40 CFR 122, 125 and 136 establish
guidelines and procedures for the National Pollutant Discharge
Elimination System (NPDES). The NPDES program is a national
program for issuing, monitoring, and enforcing permits for direct
discharges. The substantive requirements of these regulations
must be met for on-site discharges. Therefore, the substantive
requirements of these regulations are applicable to Alterna-
tives 2, 3, and 4.
40 CFR 230 regulates the disposal of dredged or fill material in
surface water and wetland areas. Alternatives 2, 3, and 4
involve excavation and other remedial activities in the wetland
area. Therefore, the substantive requirements of this regulation
are applicable to these alternatives. The MDNR has assumed
administration over the wetlands in the State of Michigan because
of Act 203 and several other environmental statutes which
incorporate these Federal requirements. However, the Federal
government retains the authority to review and comment.
Section 10 of the Federal River and Harbor Act, as amended,
regulates the obstruction or alteration of any navigable water in
the United States. The jurisdiction of navigable waters includes
connected wetlands. Alternatives 2 and 3 include activities
which will cause alterations in the wetland area of the Big Black
Creek by capping the wetlands in Source Area 10. Alternative 4
includes activities which will cause alterations in the wetlands
by excavating the wetlands in Source Area 10. Therefore, the
suhstsntivo ro^nro-orft; n f •> •>	-> ~ q t!". :'Dugh 330 nay be
applicable to these alternatives.
The Safe Drinking Water Act (SDWA) of 1974, as amended, was
enacted to assure high water quality in public water systems.
The National Primary Drinking Hater Regulations specify the
maximum contaminant levels (MCLs) and the maximum contaminant
level goals (MCLGs) for public water systems for inorganic and
organic chemicals. The surface water in Big Black Creek is not
currently distributed through the public water supply systems.
Therefore, these regulations are not applicable to the site.
However, the surface water is a potential source of drinking
water. Therefore, these standards may be relevant and
appropriate for Alternatives 1, 2, 3, and 4. Benzene is the only
compound of the compounds of concern which has a MCL and MCLG.
According to the final NCP, MCLGs which have values of zero are
not relevant or appropriate at CERCLA sites (55 FR 8751) .
Since the MCLG for benzene is zero, this standard is not
relevant or appropriate to the L.O.U. The MCL for benzenefiis
5 ppb, which is equivalent to an excess cancer risk of 10~ .
28
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Lagoon 3 soil and sludge and Lagoon 9 soil around the lagoon may
result in an excess cancer risk of benzene in surface water at
the sane order of magnitude as the MCL. Based on this informa-
tion, Alternative 1, the no action alternative, may not comply
with MCLs. However, Alternatives 2, 3, and 4 are expected to
comply with MCLs.
The Clean Air Act (CAA) was enacted to protect and enhance air
quality. 40 CFR 6 ref""'""; that al' '"Moral projects, licenses,
permits, plans, and financial assistance activities conform to
any State Air Quality Implementation Plan (SIP). This require-
ment is action specific and therefore, is applicable to Alterna-
tives 2, 3, and 4. 40 CFR 50 establishes primary and secondary
ambient air quality standards. Since these requirements regulate
ambient air quality, these rules are applicable to all the
alternatives. It is expected that all the alternatives, except
Alternative 1, will be able to attain primary and secondary air
quality standards. 40 CFR 60.50-54 specify emission standards
for newly constructed incinerators. These rules are only
applicable to Alternatives 3 and 4 which include incineration of
soil and/or sludge and berms as part of the remedial alternative.
These alternatives are expected to comply with 40 CFR 60.50-54
rules. 40 CFR 61 specifies national emission standard for
hazardous air pollutants from stationary sources. The hazardous
air pollutant at this site specified under these regulations is
benzene. This regulation is applicable to Alternatives 3 and 4
which contain treatment systems for the groundwater, soil, and/or
sludge and berms which may emit hazardous air pollutants.
U.S. EPA's policies and procedures for implementing Executive
Orders 11988 (Floodplain Management) and 11990 (Wetlands Protec-
tion) and the Fish and Wildlife Coordination Act are provided in
40 CFR fi. The nrnpffrjuroc nrni.i/lnJ	' *	->••••
suostantively require that U.S. EPA conduct its activities to
avoid long- and short-term adverse impacts associated with
actions in the wetland or floodplain areas. Because Alterna-
tives 2 and 3 involve capping in a portion of the wetland area
and Alternative 4 involves excavation in a portion of the wetland
area, compliance with tha Wetland Act must be met for these
alternatives and will require close interaction with the appro-
priate regulatory agencies.
The Resource Conservation and Recovery Act (RCRA) is a potential
ARAR for Alternatives 3 and 4. After treatment in these alterna-
tives, the resulting ash may exhibit the characteristic of
toxicity for metals through TCLP testing, since metals may be
concentrated in the ash and their mobility increased. This will
be confirmed during the design phase. If the ash is a RCRA
characteristic waste, then Alternatives 3 and 4 must comply with
RCRA regulations concerning disposal.
29
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State	f	• •
The Water Resources Commission Act was established to protect the
water quality of Michigan. Part 4 rules establish surface water
quality standards and regulate discharge to surface water bodies.
Since surface water quality would be affected by the no action
alternative, Alternative 1 does not comply with these water
quality requirements. Alternatives 2 through 4 include ground-
water pumping and treatment followed by discharge to Big Black
Creek, a recreational-use stream. Rule 323.1057 (Rule 57) of
Part 4 establishes standards for toxic substances. Standards for
toxic substances are established on a site-specific basis.
NPDES permits are regulated by the State under the Part 4 Water
Quality rules. Because all remedial activities occur on-site,
permits are not required; however, the substantive requirements
of the NPDES permit will be met.
Act 203, the Goemaere-Anderaon Wetland Protection Act, applies to
activities that result in discharge to the wetland area that
drains to the Big Black Creek. In Michigan, the MDNR has juris-
diction over the wetlands. All the alternatives result in
discharge to, excavation, or grading of a portion of the wetland
area of the Big Black Creek south of Lagoon 10 in some form. The
no action alternative may detrimentally affect the wetland area
by natural discharge of contaminated groundwater into the
wetlands. Therefore, this alternative may not comply with the
Wetland Protection Act. Alternatives 2, 3, and 4 include
remedial activities, i.e. excavation and/or filling in the
wetland area. These activities must meet the substantive
requirements of the Wetlands Protection Act. Compliance with the
substantive standards of the Wetland Act must be met for
Alternatives 2, 3, and 4 and will require close interaction with
the appropriate regulatory agencies.
The substantive provisions of Parts 6 and 7 of the rules
promulgated under the Michigan Environmental Response Act {Act
307) are considered an ARAB for the remedial action to be
undertaken at this site. These rules provide, inter alia,
that remedial action be protective of human health, safety and
the environment, (Rule 299.5705 (1)). The rules specify that
this standard is achieved by a degree of cleanup which conforms
to one or more of three cleanup types (Rule 299.5705(2)). A type
A cleanup generally achieve* cleanup to background (Rule
299.5707); a type B cleanup Beets specified risk-based levels in
all media (Rule 299.5709); and a type C cleanup is based on a
site-specific risk assessment which considers specified criteria.
The selected remedy meets this ARAR.
The Soil Erosion and Sedimentation Act establishes general soil
erosion and sedimentation control procedures and measures for
specified activities which disturb one or more acres of land or
is within 500 feet of a lake or stream. Because the activities
30
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specified in Part 17 rules are not the activities which directly
correspond to the remedial alternatives, these rules are not
applicable to the alternative* for the L.O.U. However, Alterna-
tives 2, 3, and 4 will disturb one or more acres of land and are
within 500 feet of a stream. Therefore, the requirements of
these rules are sufficiently similar to the site that they are
relevant and appropriate. It is expected that Alternatives 2, 3,
and 4 will comply with the requirements of Part 17 Soil Erosion
and Sedimentation rules.
The Air Pollution Control Act was enacted to control air pollu-
tion in Michigan. Part 2 Air Use Approval rules establishes
requirements for the installation or construction of equipment
which may be a source of an air contaminant. Alternatives 2, 3,
and 4 include ozonation for the groundwater. Alternatives 3 and
4 include LTTD and incineration of soil and/or sludges and berms.
These treatment systems may be sources of air contaminants
therefore, Part 2 rules are applicable. Alternatives 2, 3, and 4
are expected to comply with the requirements of these rules.
Part 3, Emissions Limitations and Prohibitions for Particulate
Matter, establishes standards for the density of emissions and
emission of particulate matter. Alternatives 2, 3, and 4 include
activities which are sources of particulate matter, i.e.
processing, using, storing, transporting and/or conveying bulk
materials. Therefore, these rules are applicable to Alterna-
tives 2, 3, and 4. It is expected that these alternatives will
comply with the requirements of these rules. Part 7, Emission
Limitations and Prohibitions for New Sources of Volatile Organic
Compound Emissions provides general provisions for new sources of
volatile organic compound emissions. Alternatives 2, 3, and 4
may provide VOC emissions. Therefore, these rules are applicable
to these alternatives. Tt im	:	 - -
ana * will comply with requirements of Part 7 rules. Part 9
Emissions Limitations and Prohibitions prohibits the emission of
an air contaminant or water vapor in a quantity that causes
injurious effects to human health and the environment. From the
risk assessment, the L.O.U. may provide an unacceptable risk to
human health and the environment via the air route of exposure.
Part 9 rules are applicable to the no action alternative, and
this alternative does not comply with the requirements of these
rules. With appropriate emissions controls, Alternatives 2, 3,
and 4 are expected to comply with these rules. Part 10, Inter-
mittent and Sampling rules give the commission the authority to
require performance tests of any source of an air contaminant.
Performance tests can be performed only on unit processes.
Therefore, these rules are applicable to Alternatives 2, 3, and 4
which include treatment systems. It is expected that these
alternatives will comply with intermittent testing and sampling
if and when the commission requires performance tests.
31
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Primary Balancing Criteria
Tong-Term Effectiveness and Permanence
The evaluation of alternatives under this criterion addresses the
risk remaining at the site after response objectives have been
aet. The primary focus of this evaluation is the extent and
effectiveness of the controls that may be required to manage the
risk posed by treatment residuals and/or untreated wastes.
Alternative 1 provides no long-term effectiveness and would
result in continuation of the evaluated 10 risk levels that
exist at the Bofors site. Alternative 2 provides for insti-
tutional controls and permanent extraction and treatment of
groundwater as a means of perpetually managing the site. The
reliability of controls for this alternative for the most part
depend on the successful implementation of institutional controls
on the use of groundwater as a drinking water source and
continuation of groundwater pumping and treatment forever. There
will likely be difficulties in implementing and maintaining these
institutional controls and perpetual groundwater remediation.
Alternative 3 remediates the more contaminated areas of the
Bofors Site. Alternative 3 requires a finite groundwater extrac-
tion and treatment period, but compromises the_cleanup level
attained in groundwater to 10 rather than 10 because of the
use of capping. Therefore, the residual risk of Alternative 3
must be recognized as two orders of magnitude greater than
Alternatives 2 and 4. Alternative 4 is the most comprehensive of
the alternatives relative to long-tern risks. This alternative
is projected to be able to attain 10 risk levels. This
alternative, like Alternative 3, minimizes long-term management
because the purge well and treatment system will be turned off
eventually. In addition. Alternative 4 uses a higher degree of
u
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All alternatives except Alternatives 1 and 2 provide, to varying
degrees, permanent and irreversible reduction of contaminants.
No significant destruction of toxic components or reduction in
total volume is achievable in Alternative 2. Alternatives 3 and 4
employ both containment and treatment technologies with treatment
of the principal threat.
Al'-^inativos 3 .md 4	un-site treatment technologies
(incineration and LTTD) capable of significantly and irreversibly
reducing the toxicity and volume of the untreated source wastes.
The landfill component of Alternative 4 provides only permanent
containment, not destruction or reduction in volume. However,
this containment is more protective than the capping in Alterna-
tive 3, because the landfill has a cap and a bottom liner system,
providing a greater degree of containment.
Short-Term Effectiveness
This evaluation criterion addresses the effects of the alterna-
tive during the construction and implementation phases until
remedial response objectives are attained. Under this criterion,
alternatives are evaluated with respect to their effects on human
health and the environment.
Short-term effectiveness is not applicable to Alternative l since
there is no remediation in this alternative. Alternative 2 does
not require excavation of contaminated material and therefore has
a lower potential risk to the on-site workers and the nearby
community. Some grading will be required that may generate some
air-borne contamination that must be controlled. Alternatives 3
and 4 both require excavation of contaminated material which
could generate air-borne contamination. Alternatives 3	4
also have the potential for air emissions from the incinerator
and LTTD units. Air emissions controls will be implemented on
these systems as needed and these alternatives would be subjected
to community health and safety work plans for controlling
fugitive dust and air emissions and potential exposures.
Considering the time required for protection and the time until
the remedial action objectives are met, Alternative 2 requires
perpetual groundwater extraction and treatment and is essentially
a management alternative that requires the establishment of a
permanent treatment facility, monitoring plan, site security,
etc. In contrast, Alternatives 3 and 4 require a finite period
of time for groundwater extraction and treatment. This can be
more easily managed. Both Alternatives 3 and 4 are expected to
33
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require approximately the sane remediation time period of S years
(riot including the time to pump and treat groundwater) ,
Implementability
This criterion addresses the technical and administrative
feasibility of implementing an alternative and the availability
of various services and materials required during its implemen-
tation.
Technically, all site alternatives are easily implemented and
readily constructed of available materials. The technologies
considered (which include incineration, LTTD, capping, and
pumping and treatment of groundwater) are available from
commercial vendors. Those alternatives which employ incineration
and LTTD simultaneously present moderate site restrictions. As a
result of space constraints, these processes must be separated,
therefore construction will occur on opposite aides of the Bofors
site, warranting careful coordination between these construction
phases.
Groundwater treatment systems and long-term monitoring will be
required for each remedial alternative and do not present
constraints on implementation. However, approval of institu-
tional controls placed on groundwater under Alternative 2 may be
difficult to obtain, and the long-term reliability of these
controls is questionable.
All remedial actions in Alternatives 2, 3, and 4 are proposed to
take place on-site. Therefore, no actual permits are required;
however, the substantive requirements of permits must bo met.
Coordination with the local community may be required to ensure
the acceptability of incineration and LTTD in Alternatives 3 and
4 and the substantive requirements of the air permit will need to
be met for air emissions from implementation of these two
alternatives.
QSSl.
Capital, annual oim, and present worth costs are summarized in
Table 14. Alternative 4 is the least expensive alternative of
the alternatives that provide treatment of the contaminated
material. Alternative 2 Is less expensive than Alternative 4 but
contains no treatment of the principal threat and requires
perpetual pumping and treatment of the groundwater for contain-
ment of the plume.
34
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TABLE 14
ALTER JATIVE COST SUMMARY
Bofors Site
H jskegon, Michigan
Alternative
Alternative
Descriptions
Capital Cost
O&M Cost
Total Present
Worth Cost*
Risk R malnlng
A er
Remi Jlation
Pathways
Remediated
Alternative 1
No Action.
	
$27,000
$484,000
1 H
None
Alternative 2
Capping, Groundwater Institutional
Controls, Pump & Treat Ground-
water Perpetually.
512.091,000
$429,000
$19,890,000
1 l-«
SW, A
Alternative 3
Capping, Incineration. LTTD, Pump
and Treat Groundwater (or Finite
Period.
574.416,000
$344,000
$79,912,000
1
GW, SW, A
Alternative 4
Incineration. LTTD, Landlill. Pump
and Treat Groundwater tor Finite
Period.
>65.752.000
$313,000
$70,874,000
1 -8
GW, SW. A
NOTES:
' < Present Worth based on perpetual pump and treat loi Atiemaiiv-	; 2 and 4; 43 years ot pump and (real lor other alternatives; van.	>le times lor flushing
options depending on time lo elleclively reduce contaminant coi	eniralcns, all present worm costs are calculated using an Intert	: rate 5 5%. Cap
and landfill options provide long-term O&M lor penoos equal lo t	a puinp and treat lanes. 43 year groundwater pump and treat p>	iod Is approximate
only and based on preliminary evaluations 1 nis mill bt evaluali	< turilie' in the Groundwater Operable Unit Feasibility Study
2 Trie present worth analysis is used to evaluate eipendiiures trio	accur over ddlerent tune periods by discounting all lulure costs l'	a common base
year I his allows the cost ot remedial acuon alternatives lo be i	rnpared on the basis at a single tigure representing Ilia amount ¦	money thai. H
invested in the base year and disbursed as needed, would be si	icient lo cover all costs associated wiin the remedial alternative	/er its planned
hie.
Alternative 1 costs represent long-term monitoring
Costs assume sludge, berms. and sois beneath Ihe lagoons are a llaminaied above 10-6 rlsx level lo the water table Soils arounc ire assumed
to be contaminated above 10-6 risk level only in iho tap 5 leet.
GW: Groundwater.
SW. Surface water	^	^
A: Air
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Modifying Criteria
State Acceptance
The State of Michigan has indicated it's acceptance of
Alternative 4 for remediation of the L.O.U. at the Bofors site
and a letter of concurrence is forthcoming.
community Acceptance
There were several comments received from the community during
the public comment period. In summary, two who commented
perceive that there is a high level of cancer mortality in the
area and that more needs to be done to protect the community.
The third expressed that money could be spent on "better
priorities" than expanding wastewater facilities, and suggested
the use of bacteria to "eat up" contaminants. Several conunenters
expressed objections to the use of incineration. However,
U.S. EPA is confident that the remedy will be protective of human
health and the environment. The complete comments are addressed
in the attached Responsiveness Summary.
THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, both
U.S. EPA and the State have determined that Alternative 4:
Excavation, On-site Incineration/Low-Temperature Thernal Desorp-
tion, On-site Disposal, and Pumping and Treatment of Groundwater
is the most appropriate remedy for the Bofors site in Muskegon,
Michigan.
Approximately luu, ouu	yatua lyu j ui iiiust-conLarainatea
sludge will be excavated from the lagoon area. The organic
compounds in the sludge will be treated using incineration and
low-temperature thermal desorption technologies. Approximately
64 percent of the organic compounds will be removed by this
treatment process. The treated sludges will be landfilled in an
RCRA landfill. It is estimated that 73,100 yd-1 of treated ash
will be landfilled. Approximately 334,700 yd3 of less-contami-
nated sludges and soils will also be excavated and placed in the
RCRA landfill. This landfill will occupy approximately 8 acres
in the lagoon area.
Remediation Goals
The purpose of this response action is to control risks posed by
migration of organic compounds to groundwater and surface water
and through air. Existing conditions at the site have been
determined to pose an excess lifetime cancer risk of 10 from
ingestion of contaminated groundwater. This risk relates to the
organic compound concentrations (primarily benzidine and DCB) in
35
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the sludges. Since no Federal or State chemical-specific ARARs
exist for sludge and soil that specify concentrations, the action
level for the organic compounds in sludge and soil was determined
through a site-specific analysis. This analysis used fate and
transport modeling to determine levels to which organic compounds
in sludges and soils should be reduced in order to ensure no
migration of contaminants to thg primary pathways of groundwater,
»ir abovp in
The excavated contaminated sludges and bems will be treated
using incineration and low-temperature thermal desorption which
will remove approximately 64 percent of the organic compounds
from the sludge and bems. The ash from treated sludge and berms
will be excavated and landfilled in a on-site landfill that will
meet the intent of RCRA subtitle C requirements, along with the
less contaminated soils beneath and around the sludge.
A breakdown of capital, annual O&M, and present-worth costs for
the selected remedy are presented in Table 15.
THE STATUTORY DETERMINATIONS	^
Under its legal authorities, U.S. EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that when
complete, the selected remedial action for this site must comply
with applicable or relevant and appropriate environmental
standards established under Federal and State environmental laws
unless a statutory waiver is justified. The selected remedy also
must be cost-effective and utilize permanent solutions
aiLcuiative treatment cecnnologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment
that permanently and significantly reduce the volume, toxicity,
or mobility of hazardous wastes as their principal element. The
following sections discuss how the selected remedy meets these
statutory requirements.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through treatment and landfilling of organic compound contami-
nated sludge, and landfilling the soils in the lagoon area. The
landfill will be constructed to meet the intent of RCRA Subtitle
C landfill requirements to reduce the likelihood of contaminant
migration.
Treatment of the most contgminated sludge also will reduce the
risks to less than 1 x 10 . This level is within,the range of
acceptable exposure levels of between 10 and 10~ . By land-
36
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filling the contaminated soils, the risks of ingestion of ground-
water contaminated from the soils will be further reduced. There
may be short-term threats associated with the selected remedy
during excavation; however, these can be controlled. No adverse
cross-media impacts are expected from the remedy.
Compliance with ARARs
The selected remedy of excavation, on-site thermal treatment, and
landfilling will comply with all chemical-, action-, and
location-specific ARARs. The ARARs are presented below.
Action-Specific ARARs:
Clean Water Act (CWA) of 1977, as amended [33 U.C.S. 1251]
40CRF122 + 40CRF125 - The National Pollutant Discharge
Elimination System (NPDES), which specifies the scope and
details of the NPDES permit applications, including limita-
tions, standards, and other permit conditions which are
applicable to all permits including specified categories of
NPDES permits. Also specifies schedules of compliance and
requirements for recording and reporting monitoring results.
Act 348 of the Public Acts of 1965, as amended: Air Pollu-
tion Act
Part 2 - Air Use Approval, which specifies information
required for a permit to install, construct, reconstruct,
relocate, or alter any process, fuel burning or refuse
burning equipment, or control equipment which may be a source
of an air contaminant.
Chemical-Specific ARARs:
Clean Water Act (CWA) of 1977, as amended [33 U.C.S. 125L]
4 0CFR129 - Toxic Pollutant Effluent Standards, which estab-
lishes toxic pollutant effluent standards and prohibitions of
specific compounds for specified facilities discharging into
navigable waters. 40CFR129.104 sets the ambient water
criterion for benzidine in navigable water as 0.1 ug/1.
Public Health Service Act: Title XIV, as amended by the Safe
Drinking Water Act [42 U.S.C. 300(f)] (Potential ARARs)
40CFR141 - National Primary Drinking Water Regulations, which
specify maximum chemical contaminant levels (MCLs) of public
water systems for inorganic and organic chemicals, maximum
contaminant level goals (MCLGs) of public water systems for
organic chemicals, and establishes national revised primary
drinking water regulations of MCLs for organic chemicals.
37
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TABLE IS
COST SWMARY FOR THE SELECTED REMEDY
CAPTIAL COSTS:
Cost
Site Work
1.	Sit* Preparation
2.	Soli Excavation
3.	Materials Transport
4.	Materials Processing/Size Reduction
5.	Site Monitoring
Treatment Component
1.	On-site Incineration
2.	On-site LTTD
3.	Puaplng and Treatment Systeas
Contamaent Coaponent
1.	On-site Secure Landfill
2.	Indirect Capital Costs
Subtotal
$ 2,090,400
S 4,731,000
S 2 . 752,400
S 555,400
$ 7,241,000
515,035,100
$11,347,000
S 1,218,200
S 6.387,600
5 14 ¦ 38 3 . 2C0
S65.752.000
OPERATION AHO MAINTENANCE COST:
L. Landfill OtM
Leacnate Puap t Treat; coabined
with groundwater puap t treat;
1.2 million gallons per year
Maintenance of Cap and Leachate Systea
Ut Hit ies
Environmental Monitoring
Subtotal
2. Puap and Treat 0*M
Subtotal
S 5,000/yr
S	22.000/yr
S	10,000/yr
S	;0,000/yr
S 47,j00/yr
S266¦JOO/yt
S31.3 , 000/yr
Note: Detail co«t breakdowns are In Appendix F of the Feasibility Study.
RP/8FRSR00/AA1
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Clean Air Act of 1963, as amended [42 U.S.C. 7401]
40CFR50 - National Primary and Secondary Ambient Air Quality
Standards, which establish national primary and secondary
ambient air quality standards. The appendices provide
methods and procedures for measuring specific air pollutants.
4 0CFR60 - Standards of Performance for New Stationary
Sources, which indicate applicability, sets particulate
matter effluent standards, specifies monitoring requirements,
and outlines test methods and procedures for incinerators.
4 0CFR61 - National Emission Standards for Hazardous Air
Pollutants, which identifies substances that have been
designated hazardous air pollutants, and for which a Federal
Register notice has been published, and specifies prohibited
activities, describes procedures for determining whether
construction or modification is involved, prescribes methods
of applying for approval, and covers manner in which start-up
notification is to be provided.
Act 245 of the Public Acts of 1929, as amended: Water
Resources Commission Act
Part 4, Rule 57 - Water Quality Standards (Surface Water
Quality Standards), which establishes limits for all waters
of the State for the following components: dissolved solids,
pH, taste and odor producing substances, toxic substances,
total phosphorous and other nutrients, and dissolved oxygen.
Act 348 of the Public Acts of 1965, as amended: Air Pollu-
tion ACt
Part 3 - Emission Limitations and Prohibitions - Particulate
Matter, which establishes standards for the density of
emissions and emission of particulate matter.
Act 307, Michigan Environmental Remediation Act, sets
requirements for remediation of hazardous waste sites in
Michigan. There are three types of remediation specified by
this act; Type A, B, and C.
Location-Specific ARARs:
Clean Water Act (CWA) of 1977, as amended [33 O.C.S. 1251]
33CFR322 - Permits for Structures or Work in or Affecting
Navigable Waters of the United States, which provide proce-
dures for the C.O.E. for reviewing permits to authorize
structures or work affecting navigable water, including
wetland areas.
38
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Floodplain Management, and 11990, Protection of Wetlands [42
U.S.C. 7401)
4 0CFR6 - Procedures for Implementing Requirements of the
Council on Environmental Quality on the National Environ-
mental Policy Act, which provide policies and procedures for
floodplain management and wetland protection.
Act 203 of the Public Acts of 1979: The Goemaere-Anderson
Wetland Protection Act - These rules apply to activities that
result in discharge to the wetland area that drains to the
Big Black Creek. These rules include permitting require-
ments, wetland determination, and mitigation.
Act 347 of the Public Acts of 1972: Soil Erosion and
Sedimentation Control Act
Part 17 - Soil Erosion and Sedimentation Control - Estab-
lishes general soil erosion and sedimentation control
procedures and measures. Also, specifies earth change
requirements and soil conservation district standards and
specifications.
Other Criteria. Advisories or Guidance to be Considered
USQSl:
None.
Cost-Effectiveness
The selected remedv is cost-effective because it has been
determined to provide overall errectiveneSs proportional to its
costs, the net present worth value being $70,000,000. The
estimated costs of the selected remedy are within an order of
magnitude of the costs associated with treatment of sludge and
on-site capping of the contaminated soils, and yet the selected
remedy assures a lower residual risk after remediation is
complete and higher degree of certainty that the remedy will be
effective in the long-term since more complete containment (land-
filling) is used.
Utilization of Permanent Solutions and Alternative Treatment
Technologies for Resource Recovery Technologies! to the Maximum
Extent Practicable
U.S. EPA and the State of Michigan have determined that the
selected remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-
effective manner for the lagoon area operable unit at the Bofors
site. Of those alternatives that are protective of human health
39
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and the environment and comply with ARARs, U.S. EPA and the State
have determined that this selected remedy provides the best
balance of tradeoffs in terms of long-term effectiveness and
peraanence, reduction in toxicity, mobility, or volume achieved
through treatment, short-term effectiveness, implementability,
cost, also considering the statutory preference for treatment as
a principal element and considering State and community accep-
tance.
The selected remedy offers a high degree of long-term effective-
ness and permanence since incineration is being used.
The selected remedy treats the principal threats posed by the
sludges, achieving significant organic compound reductions
(60 percent). The implementability of the selected remedy is
comparable to the nontreatment alternatives. The selected remedy
is also the least costly of the two alternatives.
The selection of treatment of the contaminated sludges is consis-
tent with program expectations that indicate that highly toxic
and mobile waste are a priority for treatment and often necessary
to ensure the long-term effectiveness of a remedy. Since the
selected remedy has the most complete containment, this remedy is
anticipated to have the best long-term effectiveness and
permanence and is therefore determined to be the most appropriate
solution for the contaminated sludges and soils at the Bofors
site.
Preference for Treatment as a Principal Element
By treating the contaminated sludges in a thermal destruction
unit and landfilling the ash and contaminated soils, the selected
leiicuj auuresses ujie 01 Che pixm-xpax Liueaia posea ay the sice
through the use of treatment technologies. Therefore, the
statutory preference for remedies that employ treatment as a
principal element is satisfied.
4 0
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RESPONSIVENESS SUMMARY
The Remedial Investigation/Feasibility Study (RI/FS) and the
Proposed Plan for the Bofora-Nobel site were made available to
the public in July, 1990. The notice of availability for these
two documents was published in the Muskegon Press on July 23,
1990. A public comment period was held from July 23 through
August 23 and a public meeting was held on August 1, 1990. At
this meeting, representatives from U.S.EPA and the Michigan
Department of Natural Resources (MDNR) answered questions about
problems at the site and the remedial alternatives under
consideration. Three comments were submitted at the public
meeting and several comments were received in the mail prior to
August 23, 1990, the last day of the public comment period.
Following are all the comments received and U.S. EPA's response
to each comment.
Comment
The first comment related to contamination in the air from the
chemical company and the fact that several people in the
community have died of cancer.
Response
There are several chemical companies and several Superfund sites
in the area and the Michigan Department of Public Health is
pursuing this issue.
Comment
The second coramentor felt the proposed alternative is not
protective enough, particularly concerning air exposure during
remediation. She indicated more should be done.
Response
U.S. EPA is very sensitive to the concerns of the public and
believes the selected remedy is the most protective and will
alleviate any air emissions from the lagoon site as part of the
remedy. Because of the highly toxic nature of the material on
site, the alternative uses incineration to destroy the most
hazardous waste. State of the Art technology will be used to
eliminate hazardous air emissions. Extensive air monitoring will
be performed to ensure control of air emissions during
construction.
Comment
The third commenter questioned if bacteria could be used to eat
up the contamination and suggested bioremediation was not
selected due to costs.
41
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Response	»-
In fact, biological treatment methods were considered and
screened out early because they will not work efficiently and
are not cost effective. 3,3'-Dichlorobenzidine (DCB), which is
one of the major contaminants at the site, is present at the site
in a crystalline form. DCB requires the transfer from a
crystalline form into an aqueous matrix which would require a
soil washing pretreatment step. Soil washing treatability
studies have indicated that this technology cannot adequately
remove DCB front soil. In addition, heavy petals such as 2inc,
chromium, and lead which are present at the site, can be toxic to
the microorganisms and additional treatment would probably be
needed for metal contamination. In both cases the concentrations
of contaminants are very high and the waste would be very
difficult to bioremediate.
Comment
Several commentors objected to incineration based on information
provided by the West Michigan Region Environmental network
concerning uncertainties, hazards and health risks associated
with incineration.
Response
As previously mentioned, U.S. EPA is very sensitive to the
concerns of the community. The agency believes the selected
remedy provides the best protection the U.S. EPA can provide.
Contrary to the information the citizens were given, incineration
will destroy the hazardous compounds and the incinerator will be
operated in such way to insure total destruction. Extensive
testing prior to start-up including treatability studies and
trial burns will be performed to determine the correct operating
procedures for the incinerator. This extensive testing is
designed to overcome the uncertainties involved in treatment of
hazardous waste. Extensive monitoring including air emissions
and other operating parameters will be performed to evaluate
incinerator performance and corrections will be made as
necessary.
Comment
Several commentors expressed concern over the fact the
groundwater will not be addressed until much later.
Response
In fact, the contaminated groundwater is currently being
controlled by a pump and treat system which will be upgraded
during this remedy. In addition, the groundwater Remedial
Investigation/Feasibility Study (RI/FS) is currently underway.
Comment
A few citizens were concerned that the pollutants will drift into
populated areas, especially the Carr Elementary School.
42
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Response
The response to the comment regarding objection to incineration
applies to this comment.
Comment
One comnentor stated that all landfills leak and does not want
the material landfilled on site. This commentor suggested we
excavate and transport the hazardous material to an offsite
(emphasis added) landfill.
Response
Because it is knovm that landfills may leak, the U.S. EPA has
selected technology that provides the most protective type of
landfill. The landfill design that will be used in this remedy
will consist of a double lined containment system with a leachate
collection system between the two liners to prevent migration of
any leachate that might be generated. In addition the landfill
cap will be constructed to prevent infiltration of any
precipitation so that leachate generation is minimized.
Furthermore, there will be a detection system below the bottom —'
liner to provide backup monitoring for the system. In addition,
the majority of contamination will be destroyed through the
incinerator and the less contaminated material will be
landfilled.
The Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA) states in
section 121(b)(1) that remedial actions in which treatment which
permanently and significantly reduces the volume, toxicity or
mobility of the hazardous substances, pollutants, and
contjmfnunts *re to preferred over rsmsdl ji
involving sucn treatment. The offsite transport and disposal of
hazardous substances or contaminated materials without such
treatment should be the least favored alternative remedial action
where practicable treatment technologies are available. U.S. EPA ^
does not recommend offsite landfilling of the hazardous material
because it would not comply with the law.
Comment
One person indicated it is a disgrace that the Responsible
Parties wriggle out of cleaning up the site.
Response
It has not been established that liable parties exist for this
site. U.S. EPA will continue to explore the possibility of
naming potentially Responsible Parties in the future.
Comment
Several commentors requested an extension on the second to the
last day of the comment period.
43
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Response
The National Contingency Plan (NCP) allows for a 30 day extension
to a public coimaent period if requested in a tinely Banner, The
NCP defines a "timely" request as generally being within 2 weeks
after the initiation of the public comment period. U.S. EPA does
not believe a delay in this project will benefit the community.
The protection of public health and the environment will better
be served by moving ahead with the design and clean-up of this
site.
44
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FEB 2 0 2004
John D Dunn, Esq.
Warner N'orcross & Judd. LLP
900 Fifth Third Center
111 Lyon Street. N'.W.
Grand Rapids, Michigan 49503-2487
Re; West KJL Avenue Landfill
Request to Extend Landfill Cover Construction Schedule and Informal Dispute
Dear Mr. Dunn:
This letter responds to your January 20. 200^ ierter. and our February 10. 2004 discussion,
through which Oshtemo Township is formally requesting that EPA extend the West KL sue
landfill cover construction start, currently scheduled for April. 2004. Concurrently. Gsr.temo is
invoking the Consent Decree's informal dispute resolution provisions, paragraph 39. isserung
that EPa staff are arbitrarily and capriciously rejecting Oshtemo's request to extend, for at least
18 months1, the landfill cover construction schedule. We have briefed our management on :he
issues presented. Oshtemo's claims, the relief requested and the staff responses, 3asea in tms
review and our management's endorsement of staff responses, this letter informs you :r.at E?A
staff is 11) declining Oshtemo's substantive request to extend the landfill cover construction
schedule, and (2) correspondingly informing you that we continue to disagree with Osnremo's
claimed dispute and requested relief.
Oshtemo requested that EPA extend the schedule for a iandfiil treatment technologies piiot test,
and to correspondingly extend for ' 8 months the landfill cover construction schedule, starting
from the date that EPA and Oshtemo agree on the pilot test performance criteria. Oshtemo's
letter does not identify the authority supporting its schedule extension request or the bases for
claiming that EPA staff s refusal to extend the schedule is arbitrary and capricious. Instead.
Oshtemo's letter supports its petition by providing: t!) Osntemo's observations from '.;-ears of
post-Consent Decree alternative remedy studies at this site, and (2) Oshtemo's optimism
regarding the outcome for its proposed pilot tests. Oshtemo claims that these pilot tests may
demonstrate that a different remedy, enhancing the groundwater natural attenuation immediately
adjacent to the landfill wastes, will have significant benefits over, and therefore should be
selected instead of. the ROD-selected landfill cover. Oshtemo ts requesting as its relief 'hat EPA
agree to allow the pilot tests to proceed, and that EPA agree to extend the landfill cover
construction schedule based on a pilot test schedule, starting from the panes' performance
Oshtemo proposes a schedule based on a contingent start date, starting from the iate that
the parties agree to the pilot test performance criteria. Oshtemo's proposal is siient on what
would happen if the parties do not agree, or if delays occur.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO. IL 60604-3590
SEP-. ' 'C *>-6 i—5.VT-CNC?
C-MJ
Reeyctecyfiecvciatiie	0«i »*** on 'GO'S 3#cvchk3 Pt&er 5C S tconsume*>
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criteria/standards agreement and concluding 18 months later. In our recent informal telephone
conference. Oshtemo added that EP.Vs decision requiring, as part of a groundwater natural
attenuation remedy, an impermeable landfill cover at the West KL site is arbitrary, capncious or
an abuse of discretion when compared to Bofors site remedy, which did not require such a cover
as a condition for selecting groundwater natural attenuation.
EPA has not and is not precluding Oshtemo from conducting the proposed pilot tests. The only
issue in dispute is whether EPA is acting arbitrarily and capriciously in refusing, after allowing
11 years of site studies resulting in numerous post-Consent Decree construction delays, to extend
once again the landfill cover construction schedule. Since EPA has not precluded Oshtemo from
conducting the pilot studies, it is apparent that Oshtemo is seeking the construction schedule
extension to preserve the landfill cover's status quo Once the pilot test results are available.
Oshtemo has indicated that it would seek to amend the site's ROD remedy, proposing Oshtemo's
treatment technology instead of the ROD-required landfill cover.
In this informal dispute review, it is also important to note that Oshtemo has failed to address a
number of issues that, on their own. would be critical to evaluating a schedule extension request
for any required Consent Decree activity.2 Since Oshtemo has not raised these issues, we will
not address them in this informal dispute response. Nonetheless, these issues are fundamental to
the dispute, and we reserve the right to address them shouid this dispute progress further.
Instead, we will take this opportunity to articulate responses to the assertions presented by
Oshtemo. For the reasons discussed below, we have determined that complying with the existing
agreed schedule, and proceeding with the ROD-selected landfill cover's construction in April
2004. is appropriate.
Before directly addressing Oshtemo's proposal, it is appropriate to put this proposal in a
historical context. In 1990. EPA issued the West KL Avenue Landfill site ROD and. in early
1992. entered into a consent decree with the PRPs requinng, inter alia, construction of a cover
over the landfill wastes and a pump and treat system for groundwater contamination. The
Consent Decree contains a pre-design study provision, allowing for limited site-specific studies
necessary to implement the ROD-selected remedies. For the past 11 years, the West KL Group
has extended this pre-design provision well beyond the Consent Decree authorization, with EPA
concurrence, conducting study after study to determine if the groundwater remedy could be
modified to natural attenuation or enhanced natural attenuation. The Group further extended
these studies to the landfill itself, claiming that natural attenuation of landfill contaminants is
2 For example. Oshtemo has not identified or addressed those considerations affecting any
failure to comply with a work obligation by the date required. See. e.g.. the criteria enumerated
in the Force Majeure provisions, found at Section VIII.. of ;he Consent Decree.
-------
occurring, and that constructing the ROD remedy cover would adversely affect these processes.3
EPA and MDEQ staff reviewed these studies and have, for the groundwater contamination,
concurred that natural attenuation ts occurring for some contaminants, and that for other
contaminants, enhanced natural attenuation may be appropriate if further studies prove its
effectiveness. In contrast, EPA and MDEQ have not found support for the Group's assertion that
natural attenuation adjacent to the landfill waste is an appropriate source control remedy for the
landfill waste, as discussed further below. We continue to see benzene and tetrahydrofuran
leaching from the waste into the groundwater at high concentrations near the landfill
demonstrating that the landfill is a continuing source of these contaminants to the groundwater.4
As a matter of policy, EPA will not approve natural attenuation for contaminants in both the
groundwater and the source of contamination where the contamination source is allowed to
migrate into the groundwater for an indefinite time period further degrading the resource. The
Group has proposed naturally attenuating contaminants in the groundwater and. as discussed
above, this proposal may be viable. However, EPA policy requires, among other things", source
control measures to prevent further releases of contaminants to the groundwater if the selected
groundwater remedy is natural attenuation. See, e.g.. Presumptive Response Strategy and Ex-
Notwithstanding the history of pre-design studies in this matter, the Consent Decree pre-
design provisions do not authorize the parties to conduct a treatment technology study of the
landfill. The Consent Decree Predesign Work Plan does not require or even authorize
investigations unrelated to implementing the ROD remedy and Consent Decree, including the
identified performance standards. The Consent Decree provides, at paragraph 13.a., and the
SOW further specifies at Section III. Task 1.. that the Settling Defendants shall conduct limited
and specified predesign work based on an approved Predesign Work Plan. The SOW at Task I.,
defines the purpose and the specific needs for the Predesign Work Plan: the "Settling Defendants
shall prepare and submit... [a] Predesign Work Plan and an RD'RA Work Plan . . which shall
document the overall management strategy for performing the RD/RA ... consistent with the
ROD and the Consent Decree." In contrast to the SOW"5 Predesign Work Plan limitations.
Oshtemo is seeking a new schedule to study remedy alternatives that are not consistent with the
ROD-selected remedy and the Consent Decree standards. Consequently, we do not have
authority under the Consent Decree to agree to Oshtemo's proposed pre-design studies. We note
that the Parties can agree, subject to court approval pursuant to paragraph 18 of the Decree
Modification bv Agreement, to conduct such studies, but Oshtemo has not made such a request.
"See footnote 5 and accompanying text.
The natural attenuation remedy policies require a demonstration that the natural
attenuation remedy will achieve cleanup standards in a reasonable time frame. Allowing
continued releases to the groundwater without source control prevents such a demonstration from
being made. See also, footnote 3 and accompanying text.
-------
4
Situ Treatment Technologies for Contaminated Ground Water at CERCLA Sites. Finai
Guidance. Directive 3283.1-12; EPA 540/R-96/023: 96-963608. at page 19 (October 1996). See
also. Handbook ofGroundwater Protection and Cleanup Policies for RCRA Corrective Action.
EPA/530/R-01/0I5 at page 11 (September 2002). Consequently, a West KL ROD selecting a
remedy change to only natural attenuation for both the groundwater contaminants immediately
adjacent to the landfill wastes and the groundwater contaminant plume, without source control,
would be inconsistent with EPA policy.
After ten years of incomplete or inconclusive studies, the West KL Group representatives met
with Regional Administrator Skinner and EPA staff over one year ago and obtained one last
extension to the cover construction deadline, until April 2004. to be implemented with a
concurrent completion of the site pre-design studies. At that time we had identified impediments
to the Group's landfill treatment technologies pilot test proposal that we were unable to resolve.
The Group and MDEQ agreed to try to resolve these impediments in further discussions. In
addition. EPA management was aware of the then 10-year history of studies, and was very
hesitant to grant any further extensions. However, since the Group agreed that these pre-design
studies could be completed in the agreed time, and the agreed time corresponded to completing
the landfill cover design. EPA management accepted the extension with the understanding that
no further extensions would be granted.
During the intervening year, the Group has had absolutely no progress in furthering its proposed
pilot tests or proposing, much less identifying, performance criteria and standards which would
comply with EPA and MDEQ requirements. It is our understanding from you that V1DEQ has
concluded, consistent with EPA's conclusion over one year ago. that it is unable to identify or
otherwise agree with Oshtemo on appropriate performance criteria and standards for the
proposed pilot tests. Given this history, we have no confidence that Oshtemo's proposed initial
activity (agreeing on performance criteria, standards, and where they would be measured) which
Oshtemo claims is contingent for all future landfill work including initiating work on Oshtemo's
proposed pilot study, could ever be met. In particular, contrary to EPA requirements. Oshtemo
continues to propose a pilot test treating contaminants and measuring performance immediately
adjacent to the landfill mass rather than in the landfill mass. As such. Oshtemo's proposed pilot
tests do not comply with EPA requirements for source control or source treatment. To some
degree we can understand Oshtemo's struggles in this direction, since it indicates their tacit
concurrence in our conclusion: we indicated over a year ago that we are unable to identify
appropriate performance criteria and standards measured within the West KL landfill mass
demonstrating treatment, much less an acceptable degree of treatment.
Even assuming arguendo that we were able to identify' acceptable performance criteria and
standards within the landfill mass, and assuming that the pilot tests show everything Oshtemo
hopes for', the Group would still be required to construct the landfill cover. In particular, the
only alternatives to negate the landfill cover ARAR requirements are: (1) treatment of the
"Which neither treats nor measures the treatment in the landfill mass.
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landfill waste mass, including standards measuring the treatment effectiveness in the waste mass
(effectuated by a new ROD with new ARAR requirements), or (2) a waiver, either by MDEQ or
EPA. of the landfill cover ARAR. In our meeting a year ago. we informed the Group that this
proposal could not meet the Superfund waiver criteria (see. 42 U.S.C. §9621(d)(4)). and EPA is
strongly disinclined to waive a state ARAR even when we can meet such criteria. In addition,
we understand that MDEQ informed you that it can not, or will not. waive Michigan's landfill
cover construction requirement. Therefore, we are left with evaluating your claim of treatment.
In general, and as we discussed in our telephone conference, we are denying Oshtemo's proposed
schedule extension because Oshtemo's objective, enhanced natural attenuation in the
groundwater plume and its pilot test in the groundwater immediately adjacent to the landfill
waste, fails to comply with EPA policy requiring a groundwater natural attenuation remedy to
have, inter alia, source control.
In response, Oshtemo is claiming that the proposed pilot technology is treatment of the landfill
waste, and therefore would comply with EPA policy. However, it is evident that the pilot test
fails to meet criteria for landfill waste treatment. In particular, it is clear from Oshtemo's
proposal that the pilot test is not intended to treat wastes in the landfill or even measure treatment
in the landfill waste. Instead. Oshtemo's proposal would, if it works, treat and sample in the
groundwater immediately adjacent to the landfill waste. As such, this is not treatment of the
source material; Oshtemo's proposal allows the hazardous materials to leach, uncontrolled and
indefinitely, into the groundwater before it is treated. Our review of the record for the proposed
pilot study demonstrates that Oshtemo's proposal is not source control, is not treatment of the
source material, and does not identify treatment standards measured in the landfill's waste mass,
or even sampling in the waste mass, to determine the treatment effectiveness in the source.
Therefore, Oshtemo's proposal is not treatment of the landfill waste mass, and does not eliminate
the requirement for source control. The source control selected for this site is a landfill cover as
specified in the ROD. Based on this review, we have determined that denying Oshtemo's request
to extend the landfill cover construction schedule, in order to conduct pilot tests that do not affect
the landfill cover remedy, is reasonable and appropriate, because Oshtemo's proposed pilot study
does not provide for source control or source treatment.
With regard to Oshtemo's claim that EPA statFs refusal to extend the schedule is arbitrary,
capricious or an abuse of discretion. Oshtemo's letter did not identify any Consent Decree, SOW,
ROD or other provision that imposes a non-discretionary requirement on EPA staff to approve
Oshtemo's requested schedule change, and we are unaware of any such requirement. At best, the
weight of Oshtemo's argument is that EPA staff are being unreasonable, rather than arbitrary or
capricious. As such. Oshtemo's position in this dispute is not persuasive.
However, in our telephone conference. Oshtemo's representatives articulated a basis for its
arbitrary and capricious claim: in the Bofors landfill remedy, EPA accepted a groundwater
natural attenuation remedy without requiring a hazardous waste landfill cover. Oshtemo's
assertion fails to acknowledge (1) that each site remedy is unique, based on the unique conditions
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6
presented and. (2) the site remedy must be viewed in its totality. While it is true that the Bofors
remedy required a less stringent landfill cover than required at West KL. the Bofors remedy
achieved the requirement for source control by, inter alia, requiring an impermeable slurry wall
encompassing the entire area around the waste, and by requiring an active pump and treat system
within the slurry wall to ensure an inward gradient within the landfill.
As discussed above, we have determined that for numerous reasons, we will not further extend
the landfill cover construction schedule. Oshtemo has not articulated any other bases or
argument supporting, much less demonstrating, that EPA's decision declining the schedule
change is arbitrary, capricious, or an abuse of discretion. In addition, as articulated above. EPA
has identified record and reasonable bases to decline Oshtemo's proposed schedule change. We
note that for the past 11 years. EPA has cooperatively acquiesced in one Consent Decree work
schedule extension after another enabling the Settling Defendants, including Oshtemo. to
conduct various site-specific studies. We also note that Oshtemo has made no progress on the
pilot tests since the fail of 2002. notwithstanding EPA's clear statements that the pilot tests must
be completed no later than April 2004.
In conclusion, we have determined that complying with the existing agreed schedule, and
proceeding with the ROD-selected landfill cover's construction in Apnl 2004. is appropriate.
Correspondingly, this letter transmits our determination that Oshtemo has not provided any basis
justifying a determination that EPA acted arbitrarily, capriciously or abused its discretion, when
EPA staff refused to extend the landfill cover's construction schedule. Your receipt of this
letter concludes the informal dispute resolution period. If Oshtemo Township wishes to
continue pursuing this dispute, whether or not you continue informal discussions, then
Oshtemo must submit a written "Formal Notice of Dispute" within 15 days from receiving
this letter, pursuant to paragraph 40 of the decree. If you wish to discuss this matter further,
please contact me at (312) 886-6235.
Associate Regional Counsel
cc: J. William Whitlock. Senior Corporate Counsel. Pfizer. Inc. (V\aa Pharmacia & L'pjo'nn)
Alan C. Zetterberg, Senior Corporate Counsel. Pfizer. Inc.
D.J. Buckholtz-Hiemstra. Chairperson, Kalamazoo County
Thomas Canny, Kalamazoo County
John VanDyke. Supervisor. Oshtemo Charter Township
Mike Ortega, for Oshtemo Charter Township
John D. Dunn, for Oshtemo Charter Township
Robert H. Cinabro. City Attorney, City of Kalamazoo
Mark Henry, Michigan Department of Environmental Quality
Sincerely.
Stuart P. Hersh
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WEST KL AVENUE LANDFILL GROUP'S REQUEST
FOR MODIFICATION OF THE ROD
I. INTRODUCTION
The West KL Avenue landfill Group (the "Group") consists of the City of Kalamazoo,
Oshtemo Township, the County of Kalamazoo and Pharmacia & Upjohn. The Group members are
the signatories to the RD/RA Consent Decree for the West KL Avenue Landfill (the "Site"), The
Group is performing the RD/RA with EPA oversight
The Group seeks to modify the 1990 Record of Decision (the "ROD") for the Site to adopt
the use of: (I) source control measures, institutional controls, and monitored natural attenuation
("MNA") to expedite the groundwater cleanup; and (2) semi-permeable capping material to enhance
the MNA while addressing any direct contact risk. Hie requested modification is based upon the
extensive technical information developed alter issuance of the RjOD demonstrating that MNA with
source control and a semi-permeable cap will expedite the remediation of groundwater
contamination, which is the principal remedial goal of flic ROD. The proposed ROD modification
will also result in very substantial cost-savings, which is particularly important because of the direct
involvement of several municipal PRPs. to view of the remedy enhancement and cost-savings, the
Group's request is consistent with EPA's Policy for Updating Remedy Decisions (OSWER Directive
9200.0-22, attached as Exhibit 1), and meets the statutory and regulatory requirements for remedy
selection.
At this stage, the prc-Design studies are substantially complete and the next phase is
Remedial Design. Consequently, this request is timely to allow a ROD modification before the
implementation of the RD.
n. SUMMARY OF PERTINENT Sill BACKGROUND
A, History of the Site and Conclusions of the 1989 Remedial Investigation/
Feasibility Study and Baseline Risk Assessment.
The Site comprises approximately 87 acres of land located seven miles west of
downtown Kalamazoo, Michigan. Oshtemo Township operated the Site as a township
landfill from the early 1960s until 196S. Kalamazoo County then operated the Site as a
county-wide landfill until 1979.
In 1980, Kalamazoo Countyimplemented a state-approved landfill closure plan at
the Site. The site closure included the placement of cover materials, regrading the landfill
cap to achieve three percent minimum slopes, installation of gas vents, and construction of
surface water diversion channels to limit erosion. Bentonite was added to the cover soils,
along with fertilizer and vegetation. Today the landfill supports a heavy vegetative cover
of grasses and some areas of trees and shrubs, with only isolated areas lacking vegetation,
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In 1982, EPA added the Site to the NPL. In 1986, EPA initiated a Remedial
Investigation/Feasibility Study ("RI/FS") at the Site. The RI/FS concluded, among other
things, that volatile and semi-volatile organic compounds from the landfill had impacted the
shallow groundwater at the Site, and that this groundwater contamination was migrating to
the west/northwest of the Site. The RI (CDM, 1989) also identified die ongoing occurrence
of biodegradation activity at the Site, and concluded that this biodegradation was reducing
the concentrations of the groundwater contaminants.
The Risk Assessment identified ingestion of Site groundwater as the primary
exposure pathway of concern. EPA determined that direct contact and inhalation risks were
within acceptable levels.
During the performance of the RI/FS and pre-Design work, the Group extended
municipal water service to all homes in the area exposed to unacceptable risks within the
landfill plume. In addition, the Group recently provided municipal water to more than 100
residents in the Springwood Hills subdivision, even though the source of the groundwater
contamination in this area does not appear to be from the landfill. The Group is also
monitoring groundwater near the plume to ensure that no other residences are exposed to
unacceptable risks. These measures have addressed the groundwater exposure risk during
the implementation of the RD/RA.
B. The 1990 ROD.
1.	The Groundwater Remedy.
Consistent with the conclusions set forth in die RI/FS, the ROD identified
"the presence of contaminants in... groundwater.. that exceed acceptable human
health risks" as the "principal threat" posed by the Site, with treatment of the Site
groundwater identified as the primary objective of the remedy. (ROD, p. 31.)
Accordingly, the remedy selected in the ROD required the use of a pump and treat
system, including die installation of purge wells and fixed film biorcactors to capture
and treat the VOCs in die site groundwater. The ROD, however, did not define the
specific requirements governing the handling and discharge of -die treated
groundwater. (ROD, pp. 25-27.) While identifying groundwater contamination as
the principal threat, the ROD noted that the plume was actually moving much slower
than estimated by groundwater modeling. The ROD attributed this phenomenon to
biodegradation processes occurring within the plume. (ROD, p. 4.)
2.	The Cap Remedy.
The ROD also required the construction of a new, impermeable landfill cap
to meet the requirements ofRCKA Subtitle C and Michigan Act 64. EPA based this
component of the remedy on two factors. First, the RCRA and Act 64 capping
requirements were deemed "relevant and appropriate" (but not applicable) due to die
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fact that the landfill accepted, material similar to hazardous waste prior to
promulgation of the RCRA Subtitle C rules in November 1980 and the effective date
of Michigan Act 64 on Jamiaiy 1, 1980. (ROD, p. 15.) Second, the ROD reflects
EPA's belief at the time that construction of an impermeable cap would complement
remediation of the groundwater by reducing leachate generation and the amount of
contamination reaching the shallow aquifer, (ROD, p. 28.)
C. Data and Information Developed After Issuance Of The ROD.
Since issuance of the ROD, the EPA and the Group have performed extensive
additional remedial investigation of the Site during the pre-Design phase, resulting in the
preparation of numerous reports. (A chronological summary of the additional investigative
work is provided in Section 3.0 of the Golder Associates Technical Basis for Alternate
Remedy Report ("Golder Remedy Report"), attached as Exhibit 2.) This work was directed
in part by EPA's research centers in Ada, Oklahoma, and Cincinnati, Ohio, with the
oversight of Region 5. The purpose of these investigations was to obtain pertinent data
before developing the Remedial Design for the Site, with a particular focus on further
measuring the biodegradation activity identified inthe RI and ROD. These studies collected
data about contaminant sources, Site hydrogeology, nature and extent of leachate
constituents, and the fate, transport and biodegradation of these constituents in the Site
groundwater. The additional data, in conjunction with the RI, have defined the horizontal
and vertical extent of the groundwater plume as depicted in Exhibit 2. The culmination of
these additional investigations was the "Focused Feasibility Study for the West KL Avenue
Landfill Site" ("FFS"), a draft of which the Group submitted to EPA in February 199E. The
Golder Remedy Report (Exhibit 2) summarizes major findings presented in the draft FFS
and concludes that the proposed ROD modification will significantly enhance the remedy
while reducing the costs.
1. Proposed Changes to the Groundwater Remedy Selected in the ROD.
The alternate remedy proposed in Exhibit 2 is a multi-component remedial
action which provides a coordinated approach to expedite die cleanup and take
advantage of the natural biodegradation occurring at the site. While MNA is a key
remedy component due to the bioactivjty at the site, the remedy also includes
extensive source control measures, the further extension of the municipal water
system, institutional controls, a comprehensive performance monitoring program,
and contingency measures for future implementation if necessary to address
unexpected contaminant migration.
Based on the extensive site-specific data developed in the pre-Design studies,
the FFS concludes that natural biodegradation processes in the waste mass and Site
groundwater are reducing groundwater contamination effectively and in a manner
that will outperform the "pump and treat" remedy selected in the ROD. These data
show that the groundwater plume is shrinking and the contaminant concentrations
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are dropping in the plume and in the source areas. This result is attributable to the
natural bioactive conditions at the Site, including microbial activity in the landfill
and groundwater media. In light of this information, the FFS identifies MNA as a
component of the best remedial approach to address the Site groundwater. (FFS, p.
E-1.) The proposed MNA component includes long-term performance monitoring
to confirm the continued effectiveness of biodegradation to address the
contamination and prevent any exposure to groundwater receptors.
In addition to the MNA component, Exhibit 2 proposes other remedial
measures to provide source control and enhance the remedial action for groundwater.
The proposed alternate remedy includes an extensive sulfate injection system to
accelerate the biodegradation of benzene and other organic compounds and provide
source control for these constituents. (Golder Remedy Report, p. 41, etseq.) The
alternate remedy also includes the further extension of municipal water to increase
the buffer zone beyond the plume limits and eliminate any risk to human health in
this area. (Golder Remedy Report, p. 46, et seq.) In connection with the extension
of the water supply, the Group will arrange for the proper abandonment of existing
private wells and the imposition of a municipal ordinance to prohibit the installation
or use of groundwater wells in the affected area. (Golder Remedy Report, p. 46.)
Finally, the alternate remedy includes contingency measures for potential future
implementation if appropriate based upon the performance monitoring data (Golder
Remedy Report, p. 47, etseq).
2. Proposed Changes to the Cap Remedy Selected in the ROD.
The Golder Remedy Report also concludes that changes to the ROD cap
requirements are necessary to facilitate the groundwater remediation through
biodegradation. Specifically, the FFS establishes that the rate of biodegradation of
contaminants is directly related to moisture and oxygen levels in the landfill: the
biodegradation rate increases as the moisture levels approximate natural infiltration.
Consequently, the biodegradation rate is enhanced by the natural infiltration
conditions at the She. Accordingly, construction of a new, impermeable RCRA cap
would actually hinder bioremediation of Site contaminants and- delay the
groundwater cleanup. These conclusions are supported by independent
biodegradation studies conducted by EPA-ORD and North Carolina State University.
(Golder Remedy Report, Section 4.2.1.) Consequently, the FFS concludes that an
impermeable cap is counter-productive at this Site. Instead, the FFS recommends
a semi-permeable cap to promote the ongoing biodegradation processes and
eliminate any direct contact exposure. (FFS, pp. E-l - E-3.) In addition, the
proposed alternate remedy includes appropriate institutional controls to address
potential exposure risks at the landfill. In particular, the Group will impose deed
restrictions on the landfill property to prohibit any on-site development, construction,
or excavation, as well as any inappropriate site uses.
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3. Benefits of the Proposed Changes to the ROD.
The alternate remedy provides a better, more reliable means of ensuring
treatment of contaminant source areas and the full extent of contaminants in the
groundwater plume. In that regard, die technical data show order of magnitude
reductions for the vast majority of contaminants. As a result, most contaminants now
meet applicable standards at the property boundary due to the natural biodegradation
that is occurring at the site. The proposed alternate remedy enhances the natural
biodegradation processes and provides source control through a comprehensive
sulfate injection system. The alternate remedy provides additional protection of
human health by further extending municipal water to increase the buffer zone
beyond the limits of groundwater contamination. The proposed remedy is also the
most cost effective. The updated cost estimate for the ROD remedy is approximately
S51 million (Golder Remedy Report, Section 2.2 and Tables 2 & 4.) In contrast, the
source control with MNA remedy cost is approximately S11 million. (Id.)
III. EPA POLICY AND CERCLA DEFINE THE CRITERIA FOR THE AGENCY'S
REVIEW OF A PROPOSED ROD MODIFICATION.
A. EPA Policy.
As part of the effort to reform the Superfund program, EPA has established a policy
for updating the remedy decisions in existing RODs. (OSWER Directive 9200.0-22,
Superfund Reforms: Updating Remedy Decisions, attached as Exhibit 1 and hereinafter
referred to as "Update Policy"). The purpose of the Update Policy is to "encourage
appropriate changes" to previously selected remedies (Update Policy, p. 1). In particular,
the Update Policy "encourages the Regions to take a close look at, and modify as
appropriate, past remedy decisions where those decisions are substantially out of date with
the current state of knowledge . . . and thus, are not as effective from a technical or cost
perspective as they could be." (Update Policy, p. 2.)
The Policy includes PRP-lead sites among the sites eligible for a remedy update.
The Policy also allows a PRP to initiate the specific request for a ROD modification.
(Update Policy, p. 2.) In fact, the majority of requests to modify a ROD have originated
from PRPs.
Under the Update Policy, a ROD modification is appropriate when information is
developed subsequent to the ROD that supports a change to the selected remedy. A change
in the remediation technique is appropriate "where new information indicates that another
remediation technology would perfonn significantly better than the selected remedy for
equivalent cost, or perfonn as veil as the selected remedy for significantly lower cost...
(Update Policy, p. 3.) In this context, die Update Policy expressly recognizes that natural
attenuation may be the appropriate groundwater remedy where site specific data indicates
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that cleanup levels will be met within a reasonable time through biodegradation or other
natural processes. (Update Policy, p. 3.)
As noted in the criteria described above, the Policy emphasizes technical criteria and
potential cost savings related to an alternative remedy. The Policy identifies potential cost
savings as one of the principal factors to evaluate when considering a proposed ROD
modification. In addition, the Policy directs the Regions to focus on potential cost savings
when prioritizing among pending requests for remedy modifications. (Update Policy, p. 4.)
If the Region determines that a proposed ROD modification meets the applicable
criteria, the Policy provides that the change should be implemented pursuant to existing NCP
requirements and EPA Guidance. The regulations and Guidance described in the Policy
govern whether a ROD modification is implemented through a work plan or SOW revision,
an Explanation of Significant Difference, or a ROD amendment (Update Policy, p. 5.)
These administrative requirements have not impeded the successful use of the
Update Policy. As stated by Administrator Browner, "the Updating Remedy Decisions
Reform is one of EPA's most successful reforms, based on its frequent use and the amount
of money saved. After three years of implementation, more than Si billion in future cost
reductions are estimated as a result of the Agency's review and update of remedies at more
than 200 sites." (Statement of Administrator Browner before the House Subcommittee on
Water Resources and Environment, May 12, 1999). This active pace has continued. The
Agency's statistics through Fiscal Year 1999 show cost savings of SI.4 billion for remedy
updates at 293 sites. (Superfiind Reforms Overview, FY 1999, Superfund Reforms
Homepage.)
B. CERCLA and NCP Criteria for Remedy Selection.
1. CERCLA Statutory Criteria.
While the Update Policy encourages the approval of appropriate remedy
changes, it does not waive or alter the statutory or regulatory requirements governing
remedy selection (Update Policy, p. 2). Consequently, these requirements apply to"
the agency's review of a remedy that is the subject of a proposed ROD modification.
Section 121 of CERCLA describes die statutory criteria for remedy selection.
(42 USC 3 9621.) Under Section 121, each remedy must meet the following general
requirements:
*	protective of human health and the environment;
•	the remedy must be cost effective; and
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• the remedy must incorporate permanent remedies and treatment to the
maximum extent practicable.
(42 USC 9 9621(bXi >.) Section 121 also specifies the required degree of cleanup for
CERCLA remedies. In that regard, each remedy must meet any federal legal
standard or requirement or more stringent state requirement that is either "applicable"
to lie hazardous substance involved or "relevant and appropriate" to the
circumstances of the release of the hazardous substance. (42 USC 3 9621(d).) These
requirements are referred to as "ARARs" in the remedy selection process. (Sec
CERCLA Compliance With Other Laws Manual, August 8,1988.)
2. NCP Criteria.
Based upon these statutory requirements, the NCP identifies nine evaluation
criteria for comparing remedial action alternatives and selecting the final remedy.
(40 CFR a 300.430(c)(9X«i)-) The NCP categorizes these criteria into three groups:
threshold criteria, primary balancing criteria, and modifying criteria. The "threshold
criteria" are protection of human health and the environment and compliance with
ARARs, and each selected remedy must meet these criteria. (40 CFR 3
300.430(f)(1)(A).) The "primary balancing criteria" are long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume through treatment; short-term
effectiveness; implementability; and cost. The "modifying criteria" are state and
community acceptance of the remedy.
3« Summary of CERCLA and NCP Criteria.
When read together, CERCLA and the NCP require a proposed remedy to
meet the following basic requirements:
1.	Protect human health and the environment;
2.	Meet the ARARs;
3.	Provide a cost effective cleanup; and
4.	Meet the preference for permanent remediation tor the extent
practicable,
4. ARABs Analysis in the Remedy Selection Process.
CERCLA and the NCP identify ARARs compliance as a key requirement in
the remedy selection process. EPA has described its process and criteria for making
these determinations. (CERCLA Compliance With Other Laws Manual, August
1988, hereinafter referred to as "Compliance With Other Laws Manual")
The beginning point in EPA's analysis is to determine whether the
requirement is applicable based upon the specific terms and jurisdictional
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prerequisites of the particular statute or regulation. (Compliance With Other Laws
Manual, pp. 1-60-61.) These prerequisites include the scope of the substances,
activities, and time period covered by the express language of the statute or
regulation. The statute or regulation is applicable only if the specific facts
concerning the site and the proposed remedial action trigger all of th© jurisdictional
prerequisites for that statute or regulation. In other words, a requirement is
applicable only if it would otherwise legally apply to the remedial action in the
absence of the CERCLA process.
The Guidance specifically provides that a RCRA requirement is applicable
only if: (1) the waste is a RCRA listed or characteristic waste; and (2) the waste was
treated, stored or disposed of after the effective date of the requirement, or the
CERCLA response activity constitutes RCRA treatment, storage or disposal.
(Compliance With Other Laws Manual, pp. 2-4, 5.) The Guidance clarifies that
certain response activities do not constitute RCRA disposal, such as consolidating
waste and constructing a cap. (Compliance With Other Laws Manual, p. 2-16.)
If a requirement is not applicable, it may still constitute an ARAR on the
basis that it is "relevant and appropriate." (Compliance With Other Laws Manual,
p. 1-65.) In order to determine relevance, EPA reviews whether the requirement
regulates circumstances which are "sufficiently similar" to those at the CERCLA
site. The requirement is considered appropriate if its use is "well suited to the
particular site." EPA recogni2es that these determinations are highly dependent on
the site specific factors and circumstances related to the remedial action. A careful
review of the site specific circumstances is particularly critical to determine whether
a requirement is appropriate to serve the overall remedial action objectives at a
particular site. (Compliance With Other Laws Manual, pp. 1-67,68.)
A requirement may be relevant but not appropriate for the circumstances of
the remedial action, in which case it is not an ARAR. (Compliance With Other Laws
Manual, p. 1-67.) For example, EPA Guidance recognizes that certain RCRA
requirements for landfill closure and capping are not appropriate for all disposal
sites. (Compliance With Other Laws Manual, p. 1-68.) In particular, the Guidance
recognizes that impermeable cover requirements are not appropriate in some
circumstances (e.g., the wastes are largely immobile, and there will be no direct
contact threat). (Id.)
5. EPA is Authorized to Waive ARAR*.
CERCLA and the NCP authorize EPA to waive an ARAR in a variety of
circumstances (42 USC 9621(d)(4); 40 CFR j 300.430(F)(l)(ii)(C).) These
circumstances include instances in which: (1) compliance with the requirement will
create a greater risk to human health and the environment; or (2) the alternative
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remedial action will attain an equivalent standard of performance when compared to
the ARAK (42 USC 3 9621(d)(4)(B)(D); 40 CFR 3 300.430(0(1 X»)(CX2), (4).)
EPA Guidance elaborates on the appropriate circumstances and procedures
for waiving an ARAR. (Compliance With Other Laws Manual, p. 1-71, gt seq.) This
Guidance clarifies that the "greater risk" waiver is appropriate when some aspect of
the ARAR creates a heightened risk to the environment or to site workers or local
residents. (Compliance With Other Laws Manual, p. 1-72.) With respect to the
"equivalent protection" waiver, the Guidance focuses on whether the alternative
remedial action is equal to or better than the ARAR in terms of its degree of
protection, level of performance, and time to achieve the remedial goals.
(Compliance With Other Laws Manual, p. 1-74.)
C. MNA is Now an Accepted Treatment Technology Under the Federal and State
Cleanup Regulations.
In evaluating the alternate remedy in light of the CERCLA and NCP remedy
selection criteria discussed above, it is important to note that MNA has gained wide
acceptance as the preferred groundwater treatment approach for certain types of
CERCLA sites. The EPA's Technology Innovation Office has determined that MNA
is the "most appropriate way" to remediate some contamination problems. (See A
Citizen's Guide to Natural Attenuation ("Citizen's Guide") EPA 542-F-96-015, p.2
(October 1996); See also April 21,1999 Final OSWER Directive, "Use of MNA at
Superfund, RCRA Corrective Action and Underground Storage Tank Sites" OSWER
Directive no. 9200.4 17P).) MNA should be considered particularly in cases where,
as is the case here, a site is well characterized and attenuation has been documented.
(Citizens Guide at 3.). The Michigan regulations governing cleanups of
contaminated sites also recognize natural attenuation as an acceptable approach to
remediating contaminated groundwater. See M.A.C. 3299.5705(6).
In this instance, the alternate remedy includes MNA as one component of a
multi-faceted remedial action for groundwater. The other components of the
alternate remedy include active source control, extension of municipal water
supplies, institutional controls, and a comprehensive performance monitoring
program. The combination of MNA with these other measures meets the applicable
EPA Guidance's preference for the inclusion of source control and related measures
as part of an MNA remedy. (OSWER Directive 9200.4-17P, 1999.)
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IV. THE PROPOSED ROD MODIFICATION MEETS THE APPLICABLE CRITERIA
AND MERITS APPROVAL
Based upon the foregoing discussion of the applicable criteria, the analytical framework for
reviewing a proposed ROD modification can be summarized as follows:
•	Does it meet the criteria in the Agency's Remedy Update Policy (i.e., does more recent
technical information show that the alternative remedy is either: (I) better technically
and as cost effective; or (2) as good technically but more cost effective)?
•	Does it meet the statutory and regulatory criteria for remedy selection (i.e., protective of
human health and the environment, meet ARARs or qualify for waiver, cost effective,
and meet the preference for permanence)?
As explained below, the Group's alternate remedy meets these criteria.
A. Application of the Update Policy to the Alternate Remedy Mandates
Modification of the ROD, because the Alternate Remedy is Better Technically
and much less Costly than the Remedy Selected in the ROD.
The fundamental purpose of the Update Policy is to facilitate implementation of
alternate remedies that are either (1) superior technically and as cost effective as Ac ROD
remedy, or (2) as good technically but less costly. Implementation of the alternate remedy
proposed here would go beyond these policy goals, since the alternate remedy actually offers
better overall technical performance at a substantially lower cost.
1. The Alternate Remedy Offers Superior Performance In Remediating Site
Groundwater.
The alternate remedy of source control coupled with MNA and the use of a
semi-permeable soil and vegetative cap is a better technical alternative to the
groundwater remedy delineated in die ROD. The ROD relies on groundwater
extraction and treatment, coupled with the leachate reduction resulting-from use of
an impermeable cap, to control and eventually reduce contaminants in Site
groundwater to target levels. During the ten years since the issuance of the ROD,
the Croup and EPA have collected data which establishes that contaminants in the
groundwater plume are naturally attenuating. With the addition of the proposed
sulfate injection system, the ongoing attenuation will be enhanced and continue at
a rate exceeding the rate of removal that could be expected through implementation
of the ROD remedy. This information is discussed in detail in the Golder Remedy
Report, attached as Exhibit 2. This information includes the following:
• An EPA study of refuse from the Site establishing that volatile organic
compounds ("VOCs") biodegraded more rapidly under moisture
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conditions approximating natural infiltration that in dryer conditions
associated with the use of an impermeable cap. (Golder Remedy Report,
Section 4.2.1.)
•	A study of site refuse by North Carolina State University establishing that
toluene biodegraded at a rate four times faster under moisture conditions
approximating natural infiltration than in low moisture conditions and
that acetone also biodegraded well in moist conditions. (Id.)
•	A feasibility evaluation by the University of Waterloo concluding that
MNA would continue to reduce contaminants in Site groundwater to
targeted levels at a rate that would prevent any significant (i.e. above
risk-based levels/MCLs) impact on residential wells or surface waters in
the area. (Golder Remedy Report, Section 4.3.3.) The Waterloo study
further concluded that MNA was the best remedial approach for
groundwater at the Site.
•	A study of biological activity in the landfill vadose zone demonstrating
that, because of moisture in the zone, substantial attenuation of source
area contaminants occurs there, corroborating the EPA and North
Carolina State studies. (Golder Remedy Report, Section 4.2.2.)
•	Historical data trends for the Site showing substantial attenuation of
groundwater contaminant sources and contaminants in the landfill plume,
with most contaminant levels now meeting applicable criteria at the
landfill boundary. (Golder Remedy Report, Section 4.3.1.)
•	Data from landfill gas surveys further documenting biodegradation of
chlorinated solvents in the landfill. (Golder Remedy Report, Section
4.2.4.)
•	A Technical Memorandum evaluating extensive site data and concluding
that sulfate facilitates the biodegradation of benzene and other organic
compounds in the landfill source areas and groundwater. (Golder
Remedy Report, Section 5.3.1.)
The foregoing data and reports demonstrate that natural attenuation is
occurring at rates that will attain target cleanup levels without further migration of
the groundwater plume. In fact, the data establish that the plume is shrinking with
respect to the vast majority of die contaminants. These studies also conclude that the
existing, semi-permeable cap is a key factor in promoting the biodegradation because
it allows the higher moisture levels conducive to biodegradation. The proposed
alternate remedy will further enhance the natural biodegradation through the use of
a sulfate injection system. Conversely, the foregoing information demonstrates that
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the remedy selected in the ROD will not reduce or treat contaminant levels
(especially chlorinated solvents) as effectively as MNA with source control and a
semi-permeable cap, since source areas within the landfill will not degrade as quickly
in a dry environment This fact, coupled with the feet that the sulfate injection will
enhance the natural groundwater bioreactor that is currently containing the
groundwater plume, establishes that the ROD remedy does not provide as effective
a long term groundwater remedy as the alternate remedy. (Golder Remedy Report,
Sections 5, 6.)
Under these circumstances, source control with MNA is the appropriate
remedy and meets the relevant federal and state technical criteria. (OSWER
Directive No. 9200.4 17P, Use of MNA at Superfund RCRA Corrective Action and
Underground Storage Tank Sites, April 21, 1999; M.A.C. 3 299.5705(6)). In
particular, the approval of the alternate remedy at this Site is consistent with the
goals of the Update Policy, and with the Superfund program's acceptance of MNA
as an effective remediation technique. (See, A Citizen's Guide to Natural
Attenuation, Technology Innovation Office, EPA 542-F-96-015).
2. The Alternate Remedy is Superior to the Capping Remedy Selected In
the ROD.
The current semi-permeable cap was constructed in 1980 as part of a state-
approved closure plan for the Site. This cap consists of a semi-permeable soil and
vegetative cover. The ROD implicitly recognized the effectiveness of this cover in
addressing direct contact/inhalation risks when it found that health risks associated
with those pathways "are within acceptable risk levels." (ROD, p. 6.) The direct
contact/inhalation risks have since been further reduced by construction of a
perimeter security fence in 1992. Therefore, the existing cover is performing well
in addressing direct contact and inhalation risks. The alternate remedy will further
address any residual risks stemming from the current conditions of the cap by
repairing and upgrading the cap and vegetation to ensure uniform coverage of the
waste.
While agreeing the direct contact/inhalation risks, the alternate remedy will
enhance the groundwater portion of the remedy. As the ROD itself makes clear, the
cap component of the remedy is integrally related to the groundwater component of
the remedy. The semi-permeable cap included in the alternate remedy is critical to
the continued reduction of contaminant sources within the landfill waste mass and
attenuation of the groundwater plume because it allows sufficient moisture to nurture
these biological processes. Placement of an impermeable cap will hinder these
processes. When the remedial action is viewed as an integrated approach, an
impermeable cap is inferior to improvement of the existing semi-permeable cap.
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In addition to impairing the groundwater remediation, constructing the
impermeable cap will temporarily increase direct contact and inhalation risks and
create nuisance conditions such as dust generation, noise and increased odors during
grading- (Golder Remedy Report, Section 4.2.5.) The transportation of the
approximate 96,000 cubic yards of capping material would also create a traffic
fatality risk of 3.1 x 10-1, out weighing the residual direct contact risks associated
with the existing cap. (Id.) These short-term risks associated with construction of
a new cap, coupled with its deleterious effect on groundwater remediation, render the
alternate remedy technically superior in every material way.
3. The Alternate Remedy Is Much Less Costly than the Remedy Delineated
in the ROD.
The alternate remedy is much more cost effective implementing the
remedy delineated in the ROD. The ROD estimated the cost of the selected remedy
at $16.5 million. But more detailed estimates based on the pre-design phase data
now project an updated cost of $51 million for the ROD remedy. (Golder Remedy
Report, Section 2.2.) The cost of implementing the alternate remedy is estimated at
approximately Si 1 million. Based upon these estimates, the proposed ROD
modification creates cost savings of approximately S40 million.
B. The Alternate Remedy Meets the Statutory and Regulatory Criteria for Remedy
Selection.
1. The Alternate Remedy Is Protective of Human Health and the
Environment
In the 1990 ROD, the Agency identified groundwater contamination as the
primary concern at the Site. During the ensuing ten years, biodegradation has greatly
reduced the severity of the groundwater contamination and the attendant risks to
human health and the environment As the University of Waterloo study makes
clear, the alternate remedy will continue to prevent any unacceptable groundwater
exposure for human and ecological receptors, and do so more effectively than the
current remedy. The protection of human health from groundwater exposure is
further ensured by the proposed source control measures and extension of the
municipal water supply. At the same time, the upgraded cap and vegetation will
address any direct contact and inhalation risk.
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2. Tie Alternate Remedy Meets ARARs For the Site.
The alternate remedy represents a better technical approach to a/Mr»«cing
both the "principal threat" at the Site (i.e., groundwater) and the residual direct
contact/inhalation risks presented by wastes at the Site. The only potential ARAR-
related obstacle to implementing the alternate remedy is EPA's conclusion in the
1990 ROD that use of an impermeable cap was an ARAR for the Site. This
conclusion, however, is no longer tenable in view of the proposed source control
measures and the compelling technical information, which demonstrates that use of
an impermeable cap would hinder the ongoing bioremediation of the groundwater.
At the outset, it must be emphasized that use of an impermeable cap was not
found to be an "applicable" requirement by EPA, only "relevant and
appropriate." EPA based this conclusion on two factors. First, RCRA and the
Michigan Act 64 impermeable capping requirements were deemed relevant and
appropriate because the landfill accepted materials similar to hazardous waste prior
to promulgation of the RCRA Subtitle C rules and the effective date of Michigan Act
64. Second, this conclusion reflected EPA's belief at the time that an impermeable
cap would complement remediation of the Site groundwater. (ROD, pp. 15,28.)
As the EPA makes clear in its ARAR guidance, however, potentially
"relevant" requirements at a CERCLA site may not be "appropriate" (and therefore
not an ARAR) if careful review of site-spccific circumstances indicates that the
requirement may not be the best way to advance the overall remedial objectives at
a site. (Compliance with Other Laws Manual, pp. 1-67, 1-68.) Indeed, EPA has
specifically recognized that site specific circumstances will arise in which
impermeable landfill caps are "relevant," but not "appropriate" for CERCLA sites.
(Compliance with Other Laws Manual, p. 1-68.) The National Remedy Review
Board has applied this analysis at other sites to question ROD requirements for
impermeable caps. (E.g., National Remedy Review Board Memorandum for
Continental Steel Site, Region 5, May 14,1997.) Region 5 has also recognized that
an impermeable cap is not "appropriate" at municipal landfills under some
circumstances. (Explanation of Significant Differences for Buttcrwotth Landfill,
Grand Rapids, Michigan, October 23,1998.)
The Group does not contest that the impermeable cap requirement is
"relevant" to the Site given the nature of some of the wastes placed there. In this
case, however, site specific information demonstrates that use of an impermeable cap
is not "appropriate" for the Site because it would undermine the best groundwater
remedy.
As explained above, a RCRA cap offers no significant advantages over repair
of die existing cap in terms of addressing direct contact/inhalation risks.
Consequently, the "appropriateness" question must be resolved in terms of the cap's
14
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impact on the principal remedial goal for the Site: treatment of site groundwater.
The extensive technical data developed since ROD issuance establish that use of an
impermeable cap would retard treatment and permanent elimination of contaminant
sources in the landfill refuse and inhibit attenuation of the groundwater plume.
Under these circumstances, the impermeable cap requirement is clearly not
appropriate for this Site and should no longer be considered an ARAR for the Site.
3. Even if Use of an Impermeable Cap is an ARAR for the Site, the
Requirement Should be Waived.
Even if an impermeable cap is still deemed an ARAR for the Site, the
extensive information about this Site developed since ROD issuance authorizes a
waiver of the cap requirement under CERCLA and the NCP.
Both CERCLA and the NCP provide several bases for ARAR waivers. See
42 U.S.C. a 9621(d)(4); 40 C.F.R. 3 300.430(f)(l)(ii)(c). The additional information
about this Site presents two bases for waiving the RCRA and Act 64 cap
requirements as ARARs. Specifically, these ARARs should be waived because (1)
compliance with the impermeable cap requirement will result in greater overall risk
to human health and the environment; and (2) a semi-permeable cap will provide an
equivalent standard of performance with respect to the direct contact risk. See 42
U.S.C. 3 9621(d)(4)(B)(D); 40 C.F.R. 3 360.430(f)(l)(ii)(c)(2X4).
(a) Compliance with the RCRA/Act 64 Impermeable Cap
Requirement Will Result in Greater Overall Risk to Human
Health and the Environment
When viewed in the context of the overall remedy and advancement
of the principal remedial goal at the Site (i.e., addressing groundwater
contamination), the RCRA/Act 64 cap requirements will clearly result in
greater risk to human health and the environment than upgrading the current
cap with semi-permeable materials. M explained above, the recent technical
formation establishes that reducing infiltration in the landfill's waste mass
will jeopardize bioremediation of contaminant sources and continued
attenuation of Site groundwater. This fact, coupled with the fact that
constructing a new, impermeable cap will significantly increase risks to
workers and adjacent properties, supports a waiver of the RCRA/Act 64 cap
requirement In fact, title excavation and construction activities of the type
that will be necessary to construct a new cap are specifically recognized by
EPA as grounds themselves for waivers based on the "greater risk" waiver
criteria. (See ARARs Manual, p. 72.)
15
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(b) Upgrading and Repairing the Existing Cap Will Achieve
an Equivalent Standard Performance with Respect to the
Direct Contact and Inhalation Risks.
Waiver is also justified to the extent a RCRA/Act 64 cap was selected
for this Site to address the direct contact risks (in addition to complementing
the groundwater remedy). Upgrading the existing cap with semi-permeable
material will provide equivalent performance in addressing the direct contact
risk. Waiver is particularly warranted in this case, where EPA has
determined that the current cap has reduced direct contact risks to acceptable
levels.
4.	The Alternate Remedy is Cost Effective.
The alternate remedy is more easily implemented and very cost effective,
with costs projected at approximately SI 1 million over die next 30 years. In contrast,
the most current cost estimate for the ROD remedy is approximately S51 million.
5.	The Alternate Remedy is a Permanent Remedy.
Most importantly, the alternate remedy meets the preference for permanence
in CERCLA remedies. The biodegradation facilitated by the alternate remedy is
irreversible. The studies conducted by EPA-ORD and North Carolina State
University demonstrate that MNA will ensure continuing permanent reduction of
contaminant levels in source areas within the landfill and in the groundwater plume.
(Golder Remedy Report, Section 4.0.) The proposed alternate remedy will provide
additional assurance of permanent remediation by supplementing and supporting the
natural biodegradation with a sulfate injection system.
V. CONCLUSION
The Group proposes to change die ROD to allow for source control with MNA and die repair
and upgrade of the existing landfill cap. The proposed ROD modification is consistent with EPA
Policy and would further the goals of the Agency's Superfiind Reform efforts. The alternate remedy
will achieve the remedial objectives for the Site faster than the remedy selected in the ROD and at
a much lower cost The alternate remedy is protective of human health and the environment and
meets all ARARs. Even if the EPA were to determine that an impermeable cap is still an ARAR for
the Site, this ARAR should be waived in favor of the alternate remedy since adherence to the cap
requirement would increase the groundwater-related risks to human health and the environment and
the alternate remedy offers equivalent protection in addressing direct contact risks.
451575-17-peantuLll. ;PQ3 Mr^KflDtcCTihfT2b S0«H«:49PM)
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Superiund Reforms: Updating Remedx.Decisions	^
EXHIBIT '
oEfflSr*' SuperfUnd
MEMORANDUM
OSWER Directive #9200.0-22
SUBJECT: Superfund Reforms: Updating Remedy Decisions
FROM: Stephen D. Luftig. Director - Office of Emergency and Remedial Response
Bany N. Breen. Director - Offic* of Site Remediation Enforcement -
TOi	Director, Office of Site Remediation and Restoration - Region I
Director, Emergency and Remedial Response Division - Region U
Director, Hazardous Waste Management Division • Regions HI, DC
Director, Waste Management Division - Region IV
Director, Superfund Division - Regions V, VI, VII
Assistant Regional Administrator. Office of Ecosystems Protection and
Remediation - Region VIII
Director, Environmental Cleanup Office - Region X
Regional Counsel, Office of Regional Counsel, Regions I - X
1.
Purpose
2.
Background
3.
Objective
4.
Implementation
5.
Conclusion
Purpose
[Go 5*c$]
The purpose of this Superfund Reform is to encourage appropriate changes to remedies
selected in existing Superfund Records of Decision (ROD*). These updates are intended to
bring post decisions into lio* with the current stata of knowledge with rapect to remediation
science and technology, and by doing so. improve the cost effectiveness of site remediation
while ensuring reliable short and long term protection of human health and ihe environment.
Remedy changes will be completed in accordance with existing regulations and guidance,
which call for a memorandum to the die. an Explanation of Significant Differences, or a ROD ¦
amendment, as appropriate for (he significance of the change. Cleanup levels an not expected
to change absent a showing thai remediation levels are unattainable.
Background
[do eecfc{
At the inception of the Superfund program in 19S0, few technologies existed for the
characterization and cleanup of hazardous waste sites, and relatively little was known
regarding the nature of subsurface contamination. Since that time, numerous technical
advances have been made which greatly improve our ability to characterize and remediate
hazardous waste sites. In addition, analysis of EPA and State program experience has led to a
greater undemanding of the difficulties involved in remediating certain types of
contamination problems.
The Agency recognizes that some remedy decisions made at Supcrftind sites in the past
should be modified to bring those decisions up to date with the current state of the science.
The best example of how knowledge and expectations have evolved in the Superfund
program is the case of contaminated ground water. At the outset of the program, it was
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anticipated that pa water contamination would migma in a relat / simple and
predictable manner, and that remediation using pumping well* coupled with above-ground
treatment would be straightforward and rapid. Today, we realize thai many of die
contaminants present la ground water at Superfaad sites wen derived from 'dense,
nonaqueous phase liquids" (DNAPLs) such as trichloroethylene (TCE). Such coatammants
behave in a manner that was not widely understood by the technical community until the hue
1980s. The migration, fate, and cleanup of DNAFL contamination in ground water is still die
subject of considerable research.
The Superfund program has evolved In response to scientific advancement and remediation
experience. For example, the 1993 "Guidance for the Evaluation of the Technical
Impracticability of Ground water Restoration'* followed the completion of an EPA study of
the efficacy of "pump and treat" cleanup at Superfund and other contamination sites. Tliii
guidance recognizes that numerous challenges may be faced cleaning up contaminated
ground water, and provides advice on how to demonstrate that required cleanup levels should
be waived in favor of a protective, but ks$*stringeat cleanup approach. The need for
flexibility In the implementation of ground water femedies will be discussed in detail In the
forthcoming EPA guidance "Presumptive Response Strategy and Ex'Situ Treatment
Technologies for Contaminated Ground Water at CERCLA Sites," which should be available
in late 1996.
Modification of a ROD is not a new concept in the Superfund. However, the need to modify
RODs to keep up to date with new technologies has grown as the complexity of Superfund
cleanups has become more apparent and national concern regarding the costs of such
cleanups has increased.
Objective
[Go Back]
This reform effort encourages (he Regions to take a close look au and modify as appropriate,
put remedy decisions where those decisions are substantially out of date with the current
state of knowledge in remediation science and technology, and thus are not as effective from
a technical or cost perspective as (hey could be.
Hiis Initiative does not signal any changes in Agency policies regarding site cleanup,
including policies based on the Superfund statute regarding remedy selection, treatment of
principal threats, preference for permanence, establishment of cleanup levels, waivers of such
cleanup levels, or the degree to which remedies must protect human health and the
environment It Is instead an effort to promote the use of the best science and most
appropriate technologies at Superfund sites.
Implementation
[Ooj|0c]
EPA is prepared to review and update existing RODrwhere appropriate. Eligibility for this
reform effort is open to Fund, other federal agency-lead, and potentially responsible party
(PRPHead "tes. Candidate sites for remedy updates may be identified by EPA or other
interested parties.
Modification of RODs generally is appropriate where significant new information has
become available (i.e., the information was not available at the time the ROD was signed)
that substantially supports the need to alter the remedy. This approach is in keeping with the
general expectation that updates will be based on program experience and new scientific
information.
Typti o/Rtmedy Updates Anticipated
We expect that the primaiy focus of these updates will be ground water sites, as the science of
ground water remediation has changed dramatically since the inception of the Superfund
program. Nonetheless, remedy updates miy be appropriate at other types of sites as well. We
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Superfund Reforms: Updating Remoj^ Decisions
expect chat remedy update* •'ill consist of three principal types:
•	Changes in the remediation technology employed, where a different technology would
result In a more cost effective cleanup;
•	Modification of the remediation objectives due to physical limitations posed by site
condition* or the nature of the contamination; and
•	Modification of the monitoring program to reduce sampling, analysis, and reporting
requirements, where appropriate.
These types of updates are discussed below in greater detail, particularly as they relate to
ground water remedies;
•	Changes ia the Remediation Technology: Sites where new information indicates
that another remediation technology would perform significantly better than the
selected remedy for equivalent cost or perform as well as the selected remedy for
significantly lower cost, would be good candidates for a remedy update. Note that
there should be sufficient information available to determine thai such a technology or
approach will perform as expected, given the conditions at the site. Given the
potential rides of technology failure and its consequent cost, only proven technologies,
or innovative technologies with well-understood performance capabilities, should be
considered for remedy updates.
•	Remediation Objectors Rcconsidtred: This category includes sites where
information gathered during remedial design or remedial action indicates that
achieving the selected cleanup levels (e.g., Maximum Contaminant Levels) is not
technically practicable from an engineering perspective. An example of such a site
would be one where DNAPLs have been directly identified or reliably inferred from
newly-acquired evidence, and where presence of the DNAPL will critically limit the
ability to achieve cleanup levels. This scenario also might include cases where the
physical attributes of the site (e.g., very complex hydrology) will prevent the selected
remedy from attaining the required cleanup levels in a reasonable time frame.
Another type of site that might be considered for an update under this general
category is a site where an existing ground water remediation system has reduced
contaminant levels, but contaminant recovery efficiency is so low that a concentration
"plateau* has effectively been reached. EPA expects that reasonable efforts will have
been made to refine any existing remediation systems, so that the loss of contaminant
recovery efficiency can be attributed with relative confidence to physical limitations
of the site, and not to inadequacy of remediation system design or its operation. A
determination regarding contaminant recovery efficiency may be made over portions
of sites, targeting for review and update only those areas of the site where remediation
has become demonstrably inefficient. For farther information on defining
concentration "plateaus." see "Statistical Methods for Evaluating Cleanup Standard*:
Volume IL Ground Water" (EPA Publication 230-R-92-014, 1992).
Where such a determination is made (i.e., that further active remediation with a given
technology is no longer practicable), alternative remedy options include: 1) use of a
different remediation technology or approach to enhance recovery rates; 2) use of
natural attenuation to complete the cleanup, but over a somewhat longer time frame;
and 3) recognition that complete cleanup U not technically practicable using either of
the first two options, and that modification of the cleanup levels may be required (e.g.,
ARAR waiver or alternate concentration limits). For fun her information on waiven of
cleanup levels, see "Guidance for Evaluating the Technical Impracticability of
Ground Water Restoration." OSWER Publication No. 9234.2-15 (September 1993).
Use of natural attenuation to complete ground water cleanup may be appropriate
where site characterization and remedy performance data indicate that required
cleanup levels will be attained within a reasonable lime frame through biodegradaiion.
dispersion, dilution, adsorption, or other natural processes. The "reasonableness" of
the time frame to achieve cleanup must be determined on a site-specific basis.
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considering i facton as use and value of Hie resource; the "ncy of the Bead for
the resource; M«e availability of other water supplies in (he area, and the ability 10
prevent human exposures and impacts to environmental receptors. State and local
input on these decisions therefore will be critical.
• Reduced Monitoring Data Nccdb: Sites where the ground water monitoring
program could be streamlined without compromising the effectiveness or
protectiveness of the remedy also may he considered for review. For example, sites
undergoing long-term remedial actions such as pump and treat may, after a period of
time, require less intensive monitoring than originally called for in the ROD or other
work plan document. Such a determination may be made after the remediation system
has been operational and functional for a period of time sufficient to determine
whether I) the remediation system is achieving the degree of contaminant plume
control sought; ami 2) there have been no short-term fluctuations in contaminant
concentrations or other phenomena that would justify the continuation of frequent
sampling.
When these conditions are met, it may be appropriate to consider streamlining the
ground water monitoring program. Such streamlining might, for example, reduce
sampling frequency from quarterly to semiannually or annually with no significant
change in data quality or monitoring effectiveness. Similarly. the number of
parameters tested for in each sample also may be reduced in certain cases. In other
cases, specific monitoring wells may be eliminated from the program entirely. For
example, wells formerly located In the contaminated plume which now comply with
cleanup levels, or wells that are sufficiently close to other monitoring points thai their
amission from the sampling program would not adversely impact overall data quality
may be eliminated from the monitoring program.
Facton to consider when contemplating changes to the monitoring program include
proximity to downgradient receptors (e,g., supply wells), the relative speed with
which ground water flows in the affected aquifer, and whether large seasonal changes
occur in the hydrologic system. And, as virtually all ground water sites have sane
type of monitoring program, regional review and modification of monitoring
programs should focus on those sites where such changes will produce significant cost
savings. Changes to a ground wain monitoring program often will not constitute a
significant change to the implementation of the remedy. Where this is the ease, such
changes may be documented through a memorandum to the post decision document
file or through modification of the specific documents) governing the monitoring
plan, as appropriate.
these example* of updates, while not exhaustive, are meant to he representative of the
types of sites where it may be appropriate to modify the remedy. In cases where a
change in remedial technology or approtch is proposed, remedy updates should be
based on site-specific information gathered or developed after the ROD was signed..
Rtmtdy Updates Process
Each Region should set up a process for reviewing requests for remedy updates submitted by
EPA staff or other parties. Hie process may consist of three phases:
1.	Mentificiuon and prioritization of RODs for review;
2.	Technical review (to determine whether changes to the remedy are warranted); and
3.	Implementation of die remedy update (changes documented in the post-ROD file, an
ixpianation of Significant Differences, or a ROD Amendment; or where the remedy
selected ROD u not altered, by revision of a work plan or other relevant document).
Prioritization- EPA will consider and evaluate potential remedy updates for Fund, other
federal agency, and responsible pany*kad sites. Requests for review of candidate RODs may
be sent to the Waste Management Division Director or the Remedial Project Manager
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. Sapcrfund Reforms: Updating Remedy Decisions
Page 5 of 7
assigned 10 the site. To ensure that the Region's rationale for prioritizing rt„.«dy reviews is
dear and equitable, all such requests should be carefully tracked. During the prioritization
phase, the Region shall assets the type of modification that may be called Tor, (he resources
needed to conduct the review and update, and the potential cost savings. Review and
consideration of potential remedy updates should not, however, result in any delays in the
completion of work products or other remediation activities required by the existing ROD and
enforcement instruments (UAOs/CDs). Work stoppage is not permitted except as authorized
in the enforcement instrument for PRP-lead sites.
Review and modification of RODs can be resource intensive. We therefore encourage the
Regions to establish priorities for ROD reviews and updates that balance the demands of this
reform effort with available Regional resources and the need lo meet other program targets. It
is recommended that in setting priorities among updates, the Regions should evaluate the
potential cost savings of the update. Furthermore, when factoring cost savings into priority'
setting for reviews. Regions should consider both the gross cost savings estimated far the
update (favoring large sites with potentially large cost savings), as well as the proportion of
total remedy cost which the savings would represent (fostering update opportunities for
smaller sites with large proportionate reductions in cast).
Estimation of the amount of cost savings expected for the proposed remedy change should
indudc consideration of the resources required to review and update the remedy decision, as
well as the resources required to implement the change in the remedy itself. As Superfund
decisions have evolved with program experience, we anticipate thai older RODs may be the
more likely candidates for updating than more recew RODs. However, another factor that can
affect remedy update cost savings is the stage of a remedy's construction. The costs of
implementing a change in remedial technology may be much lower, for example, if the
change is made during design as opposed to Airing or after construction. When estimating
cost savings associated with a potential remedy update, the Region therefore should consider
whether a given remedy is still in the design phase, or whether construction is underway or
already completed. In addition, the impact of any delays to the cleanup schedule should be
considered. Additionally, the Regions should consider the administrative costs of modifying a
remedy, which may include preparation of an ESD or ROD amendment, responding to the
concerns of pvties affected by the remedy change, and modifying or renegotiating UAOs or
consent decrees.
Technical Review. During the review phase. Regions will review the technical information
supporting the need to alter the response action. This should include detailed site-specific
information related to how the selected remedy has performed or can be expected to perform.
This information may be augmented by non-site-specific information such as published
reports regarding the efficacy of a particular remediation method under conditions similar to
those found at the site, or other widely-accepted technical information that was not available
at the time the ROD was signed. The Agency expects that PRPs and federal agencies
requesting remedy reviews will take responsibility for collecting and assembling relevant
information in a manner that supports an efficient review process. EPA will assume this
responsibility for Fund-lead sites.
Implementation. Sites that are selected for update would then pass on to the third phase,
implementation. Note that this reform initiative does not in any way change the manner in
which remedies are modified, as specified in the Much 8.1990 National Contingency Plan
(NCP). Where modifications to a ROD would represent a significant, but not fundamental,
change from the selected remedy, EPA (or the lead agency) is required to publish an
Explanation of Significant Difference (ESD), as outlined in NCP §300.435(cX2Xi). Where a
ROD modification would result in a fundamental difference from the selected remedy, a ROD
Amendment should be proposed, as discussed in NCP |300.433(cX2Xii\ Minor, or non-
significant. changes to a remedy must be recorded and explained in the poet decision
document file. Remedy changes that do not alter the remedy selected in the ROD (e.g., some
ground water monitoring program changes) may be documented by revision of the work plan
or other relevant document.
Community preferences an particularly important regarding any proposed changes to the
remedy. Regions must ensure that communities are involved in the remedy update process
and should provide an opportunity for public comment whenever the change will result in a
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ROD amendment; c notice of modification ot » kuu win bed qui in accordance
with the NCP and existing guidance. Where «n ESD is used, EPA (or UK lead agency)
generally provides • summary of the ESD in a local newspaper, and makes the ESD aad
supporting information available to the public ia the Administrative Record and iaihe site**
information repository (NCP 5300.i2S(aX2)). We also encourage the Regions or the lead
agency to solicit public comment on ESDs where appropriate. Public involvement for ROD
amendments is carried out in the same manner as for a ROD. including requirements far
public comment, response to comments, and update of the Administrative Record (refer to
OSWER Directive 9335.3-02). For minor, or non-significant changes, the public may access
documentation of the changes in die post decision document file ia the Administrative
Record. If the lead agency chooses, it also may publish an optional Fact Sheet describing the
minor changes to the ROD.
Further guidance on what may constitute a minor, significant, or fundamental change to a
ROD can be found in the Preamble to the above sections of the NCP, and in OSWER
guidance documents "Interim Final Guidance on Preparing Superfund Decision Documents*
(Directive 9355.3-01 October 1999) and "Guide to Addressing Pre-ROD and Post-ROD
Changes," (Publication No. 9355 J-02FS-4, April 1991).
State, Native Amtriam Tribe, or Supporting Agency Rote
States play a role in the modification of remedy decisions. Both CERCLA f 121(F) and the
Model CERCLA Consent Decree {which forms the basis for most consent decrees) provide
(hat the States be given the opportunity to review and comment on specified steps in remedy
selection. Further, (he Model Consent Decree requites that the State be given a reasonable
opportunity to review and comment on any proposed modifications. Agreements between
EPA and a State, including contracts, may require modification following a change to a
remedy. Funher information regarding the role of States and supporting agencies in Che
remedy modification process can be found in the "Interim Final Guidance on Preparing
Superfund Decision Documents," OSWER Directive 9335.3-02 (October 1989).
Native American Tribes are afforded substantially the same treatment as States with respect
to certain provisions of CERCLA (see CERCLA i 126; NCP §3005)- A tribe that is
federally-recogniied, has a governing body that is currently performing governmental
Auctions regarding environmental protection, and has jurisdiction over a Superfund site can
be treated substantially the same as stales under CERCLA 5104 (tee NCP §300.515). For
more information, please contact Dave Evans (Director, State, Tribal, and Site Identification
Center), at (703W03-88S5.
Modifications of RD/RA Consent Decrees
When a modified remedy is to be (or is being) implemented by PRPs pursuant to a Remedial
Design/Remedial Action (RD/RA) consent decree, modification of the consent decree may be
necessary. Most remedy updates will require modification of the Statement of Work (SOWX
which provides detail regarding implementation of the ROD. Most consent decrees follow the
Model Consent Decree which provides that any material modification to the Statement of
Work for the remedy requires the written approval of the United States, the settling PRPs, and
the court which entered the decree. Where remedy updates adopted pursuant to this
administrative reform proposal result in cost savings to the settling defendants, it is not
anticipated that (he Regions will have difficulty obtaining the cooperation (and assistance) of
PRPs in preparing the documents required to obtain coutt approval of the modified consent
decree.
Where the modified remedy requires a nonmaterial change in the SOW, the Model Consent
Decree language provides that the modification can be made upon written agreement between
EPA (after providing the State a reasonable opportunity to review and comment on the
modification) and the settling defendants. If the remedy update does not require a change to
the SOW, the Model Consent Decree modification provision does not require approval of lh$
settling parties. The Department of Justice should be consulted as soon as die Region believes
that modification of the consent decree would be required to accommodate a rcoiDdy chii|6.
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Sunerfund Reforms: Updating Remedy [decisions
Headquarters Coitsuiiaiian
Current policies regarding consultation with Headquarters on certain remedy selection issues
apply to this initiative. Current consultation policies are found in the memorandum entitled,
"Twenty Fifth Remedy Delegation Report - FY 1994," signed by Richard J. Guimcnd,
October 1.1993. However, in the future die Regions should refer to any relevant
Headquarters memoranda updating these consultation guidelines.
Conclusion
[Ga |*ek]
In closing, let me state that die success of this Superfund Reform will be contingent in pan on
how well the results of these reviews and updates are communicated among Regional and
Headquarters offices. Progress reports, including the number and type of remedies reviewed,
and this number and nature of the remedies updated, will be prepared periodically by my staff
with your involvement. Copies of these reports will be provided to you so that you may be
aware of national trends in this reform effort We expect to hold periodic conference calls to
coordinate the national implementation of this Superfund reform and to obtain results on the
progress in reviewing and updating RODs.
If you have any questions or wish to discuss these matters further, please contact Peter
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Remedial Response, Karen Harrison of the Office of Enforcement and Compliance Assurance
«202) 564-5121), or Brian Grant of the Office of Qenarai Counsel ((202) 260-6512).
eei Elliott Laws, OSWER
Tim Fields, OSWER
Jtra Woolford. FFRRO
Earl Salo, QGC
Craig Hooks. FFEO
Liz Couworth, OSW
Bruce Gelber, DOJ
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Comments; upetfw&iflfo&m*®?-
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ouo
DECLARATION FOR THE AMENDMENT TO THE RECORD OF DECISION
PURPOSE
This decision document presents the amendment to the Record of
Decision (ROD) for Operable Unit *1 (OU *1) at the Bofors-Nobel
site, in Muskegon, Michigan, chosen 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 Contingency Plan (NCP).
BASIS
The decision to amend the ROD is based upon the administrative
record. The index attached to the amended ROD identifies the items
that comprise the administrative record upon which the selection of
the remedial action is based.
DESCRIPTION OF THE AMENDMENT
The remedy selected in the ROD for OU *1 was a final remedial
action for the lagoon area soils and an interim action for site
ground water. The remedy consisted of on-site incineration and on-
site landfilling for the lagoon area sludges, on-site landfilling
of lagoon area soils, construction of an on-site ground-water
treatment facility with extraction and on-site treatment of
contaminated ground water. The amendment to the ROD eliminates
incineration as a treatment technology for the site. All hazardous
material will be placed in the on-site landfill that will be
constructed as part of the remedial action selected in the ROD.
STATUTORY DETERMINATIONS
The selected remedy in this amendment is protective of human health
and the environment, complies with Federal and State requirements
that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. However, because treatment
of the principal threats of the site was not found to be
practicable or cost-effective, this remedy does not satisfy the
statutory preference for treatment as a principal element. Because
this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted within five
years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and
the environment.
-------
The State of Michigan concurs on the selected remedy in this
amendment.

~v DMT
->

Valdas V. Adamkus
Regional Administrator
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INTRODUCTION
The Bofors-Nobel (Bofors) site is located 6 miles east of downtown
Muskegon on Evanston Road in Egelston Township, Muskegon County,
Michigan (see Figure *1) . This 85-acre site includes a currently
operating specialty chemical production facility, an unused
landfill, a currently operating ground-water pumping and treatment
system, and 10 abandoned sludge lagoons. The southern portion of
the site is bounded by Big Black Creek. There are wetlands within
the Big Black Creek floodplain on either side of the creek (see
Figure *2).
The Record of Decision (ROD) for Operable Unit *1 (OU *1) was signed
on September 17, 1990. It addressed contamination in the lagoon
sludges, in the soils under and around the lagoons, and in ground
water (see Figure *3) . Sludge remediation was addressed through
on-site incineration and on-site landfilling. Soil remediation was
addressed through on-site landfilling. An interim action for
ground-water was addressed through construction of an on-site
ground-water treatment facility and upgrading the existing pumping
and treatment system. The ground-water remedy was an interim
action because no risk based cleanup numbers were available under
Michigan Act 3 07 at the time the ROD was signed. The ground-water
extraction well system provides containment of ground water and
halts any potential migration off* contaminated ground water off
site. This document amends the OU *1 ROD and provides for
elimination of incineration as a treatment technology for the site.
All hazardous material that was originally intended for
incineration will be placed untreated in the on-site landfill.
This amendment is based on information from the United States Army
Corps of Engineers (Corps) pre-design study, 3 0% design document
for incineration and landfilling operations, and the Feasibility
Study for OU *1. The information contained in these documents
indicates that incineration is impracticable and not cost-effective
in dealing with the contamination in the lagoon area soils at this
site.
The lead agency for the remedial action at this site is the United
States Environmental Protection Agency (U.S. EPA). The State of
Michigan Department of Natural Resources (MDNR) is the support
agency. This ROD amendment will become part of the Administrative
Record File.
Under CERCLA § 117 and Section 300.435 (c) (2) (ii) of the NCP, the
lead agency is required to propose an amendment to the ROD and
allow the public the opportunity to comment on the proposed changes
if the differences in the remedial action alter the basic features
of the ROD. A public meeting for the original ROD was held on
August 1, 1990. The proposed amendment to the ROD was made
available to the public on April 6, 1992. The public meeting was
held April 16, 1992, at the Egelston Township Hall, Muskegon,
Michigan. A response to the comments received during this period
1
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FIGURE "l
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RO
SUMMIT
-------

EVANSTON ROAO
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-------
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is included in the Responsiveness Summary, which is part of this
Amendment to the Record of Decision.
The information repositories for this site are located at:
The administrative record, which contains the information upon
which remedy selection is based, is available at:
SITE HISTORY
From i960 to 1976, the plant produced alcohol-based detergents,
saccharin, pesticides, herbicides, and dye intermediates. The
lagoons were used for wastewater and sludge disposal until 1976.
A ground-water extraction and treatment system was installed in
1976. The site was placed on the National Priorities List in March
1989. The MDNR, with review by°U.S. EPA, conducted a Remedial
Investigation from the winter of 1987 to the summer of 1989. The
ROD for OU *1 for the site was signed on September 17, 1990, which
addressed source control in the lagoon area through construction of
a ground-water treatment facility, incineration of the lagoon
sludges (approximately 108,000 cubic yards), and construction of
RCRA-type secure landfill cells to hold non-incinerated material
(approximately 426,500 cubic yards) and the ash from the
incinerated sludges.
REASONS FOR ISSUING THE ROD MtEMPMEMT
Following the signing of the ROD on September 17, 1990, the Corps
was tasked by the U.S. EPA to perform the Remedial Design for OU *1
at Bofors. As part of the design effort, a pre-design site
investigation was performed to refine the Feasibility Study
estimate of the horizontal and vertical extent of contamination at
the site and to establish design parameters for the incineration
technology.	Information gathered during this pre-design
investigation has provided critical data which has caused the U.S.
EPA to re-evaluate the use of incineration as a treatment
technology at the site. Reasons for this re-evaluation include
that a much larger volume of contaminated material is present at
the site than was originally believed, that there would be
inconsistent treatment of contaminated material with the same level
of risk, and that the cost and logistics involved in incineration
are much greater than originally believed. Further, the large
Egelston Township Hall
5382 East Apple Avenue
Muskegon, MI 49442
Hackley Library
316 West Webster Street
Muskegon, MI 49440
Hackley Library
316 West Webster Street
Muskegon, MI 49440
2
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increase in volume significantly lessens the effective reduction in
risk achieved by incineration of those materials the ROD determined
should be incinerated.
The soil borings taken as part of the pre-design site investigation
established that the volume of contaminated soil that would need to
be contained in the on-site landfills is approximately 697,000
cubic yards. The original estimate from the Feasibility Study
report was 334,700 cubic yards. This large difference is due to
the fact that in the Feasibility Study, an assumption was made that
the contamination in soils around most of the lagoons only extended
to a depth of five feet. Soil borings taken during the pre-design
study indicated that most of the soil around the lagoon area was
contaminated down to the water table. In addition, the pre-design
investigation found that three hot spots (localized areas of highly
contaminated soils) identified in the Feasibility Study for OU *2
are actually contiguous to the contaminated soil in OU #1
(identified as HS1, HS2, and HS3 in Figure *4). OU *2 will address
the contaminated soils in the operating plant area and establish
the final clean-up objectives for ground water at the site. The
division of the site into operable units was based on the need to
subdivide the site into more manageable components and to address
the greatest threat to human health and the environment first. It
was not based on any physical requirements associated with the
site. The new information from the1 pre-design study indicates that
the contamination from the hot spots would be better defined as
part of the soil contamination from OU *1 and should be treated
with that material. The additional volume of soil from the hot
spots is approximately 70,000 cubic yards. Consequently, this
would bring the total volume of contaminated soils that would need
to be placed in the on-site landfills to approximately 767,000
cubic yards.
The evaluation of remedial actions in the Feasibility Study and ROD
defined the principal threat wastes as site material containing the
highest concentration of the "chemicals of concern". Based on
information from the Feasibility Study report, the determination
was made that incineration of 108,000 cubic yards of selected
sludges and berms would reduce the overall amount of contamination
at the site by approximately 64%. The pre-design study conducted
by the Corps has found that the Feasibility Study report
underestimated the volume of contaminated soils at the site. The
Feasibility Study identified 188,000 cubic yards of soil with a
risk greater than 10"* (1 in 100 additional risk of cancer) . The
estimate from the pre-design study was that there are approximately
390,000 cubic yards of soil with a risk greater than 10 . The pre-
design study also found that there were a total of approximately
697,000 cubic yards of contaminated soil that would need to be
contained in the on-site landfill cells instead of only 334,700
cubic yards as identified in the Feasibility Study. Based on this
information, only 38% of the contaminant mass would be destroyed by
incineration instead of 64% as estimated in the ROD. The majority
-------
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-------
of site contamination pursuant to the original ROD, approximately
58%, is in the site soils (as opposed to the sludges) and was to be
contained without treatment in the on-site landfills. For this
reason, incineration of site sludges is not an effective
remediation strategy to reduce the overall amount of contamination
at the site.
U.S. EPA policy (November 1991) recommends that risk levels play a
major consideration in determination of principal threat wastes.
The original ROD defined the principal threat wastes only as site
material containing the highest concentration of the "chemicals of
concern". An evaluation of site materials identified in the
Feasibility Study using levels of risk to identify principal threat
wastes revealed that, in addition to the 108,000 cubic yards of
contaminated sludges and berms, there are an additional 188,000
cubic yards of contaminated soils with a risk equal to that posed
by site sludges and berms. The incineration strategy as outlined
in the original ROD did not address this additional 188,000 cubic
yards of contaminated soils. Because this volume of soils was to
be landfilled without treatment, the incineration of the sludges
alone would not significantly add to the reduction of the overall
site risk and would not provide any additional benefit to the site.
In addition, information from the pre-design study conducted by the
Corps indicates that the actual amount of material with a risk
equal to site sludges is much ^larger than predicted in the
Feasibility Study report. The current best estimate of material,
both soils and sludges, with a risk greater than 10"*, is
approximately 497,000 cubic yards. Treatment of this volume of
material by incineration is considered impracticable and net cost-
effective. This volume of material would require approximately 5
years just to conduct the actual incineration. Additional time
would be required to construct the incinerator and to conduct the
trial burn. The cost to incinerate 497,000 cubic yards of material
is estimated at $114,000,000. This would bring the estimated total
cost to remediate GU *1, including contingencies, to approximately
$221,000,000.
The pre-design study included a sub-scale incineration
investigation conducted by the U.S. EPA Incineration Research
Facility in Jefferson, Arkansas. The preliminary results indicate
that there are several waste related issues that were unknown
during the preparation of the Feasibility Study. Some of the
sludge from the site has a higher BTU value (energy content) and
water content than previously identified. An increase in either
BTU or water content can decrease the amount of material that can
be incinerated per hour and, therefore, increase the amount of time
and the cost to incinerate the sludge. Alternatively, the BTU and
water content of these sludges may be reduced by mixing with either
other sludges or dirt with lower BTU and water content to produce
a single material with more homogeneous values. Pre-mixing of all
sludges would produce a feed with homogeneous characteristics but
the difficulty of handling, mixing and storage of 108,000 cubic
-------
yards of material prior to the incineration makes this option
impracticable. The space available on site is limited and the
sequencing required to construct the various landfill cells makes
it difficult to identify a suitable area large enough to store this
volume of material. The storage space required for 108,000 cubic
yards is equivalent to two football fields piled 32.5 feet high.
The sludge is thixotropic and becomes more fluid with handling. It
would be difficult to pile the material to any significant height
without measures to stabilize the mass. An additional concern is
the potential air emissions which could be released from the sludge
during handling. Mixing would greatly increase the risk of any
potential releases.
The wide variance in BTU and water contents cause an additional
concern with establishing criteria for the test burn of any
incinerator that would operate at the site. Selection of which
sludge or mixture of sludges used during the test burn would
establish the operation and compliance criteria for the incinerator
for the life of the project. Variability in feed material would
make it very difficult to optimize facility operations and could
mandate several test burns to establish criteria for the various
sludge types.
The pre-design study conducted by the Corps evaluated the placement
of the landfill cells, on-site incineration facility, and the
ground-water treatment facility. The following summarizes the
findings of the Corps' pre-design study. The constricted nature of
the site would increase the difficulty of sequencing construction
of the various facilities, construction of the various landfill
cells, and construction of facilities for temporary storage of
sludge prior to incineration. Factors that would make
implementation of the remedial action very difficult include: 1)
the incinerator can not be constructed on site until an initial
area has been cleaned and compacted to support its foundation; 2)
the incinerator would occupy space that would otherwise be used in
landfill cell construction; 3) it would be necessary to construct
temporary storage facilities to house sludge prior to incineration
(generally a two day supply); and 4) it would be necessary to
construct temporary storage facilities to house ash from the
incinerator prior to landfilling. Delays in incinerator operation
would delay final closure of the landfills since ash from the
incinerated sludges would be placed in one of the on-site landfill
cells.
When the information gathered during the pre-design study indicated
that the use of incineration was no longer an appropriate remedial
action for OU *1, the U.S. EPA re-evaluated the spectrum of
potential alternatives included in the Feasibility Study. This
list of the potentially applicable technologies which could be used
to deal with the contaminants at the site is presented in Section
2.4 and Appendix D of the OU #1 Feasibility Study. The list
includes 11 methods of containment, 15 methods of incineration,
5
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various disposal options, as well as biological remediation, soil
vapor extraction, chemical extraction, soil washing, soil flushing,
dehalogenation, low temperature thermal desorption (LTTD),
solidification/stabilization, microencapsulation, vitrification,
and in^situ vitrification.
Thermal treatment by LTTD was eliminated from further
consideration. The results from the treatability study performed
as part of the Feasibility Study show that LTTD failed to
adequately treat all contaminants of concern at the site and
achieve appropriate clean up standards. In addition, the cost of
implementing LTTD treatment was shown to be similar to
incineration.
Solidification/stabilization technologies were eliminated because
a review of treatability data from the Feasibility Study (Appendix
E) showed that contaminants of concern would leach through the
solidified or stabilized matrix at elevated concentrations. This
rendered the technology ineffective as a stand-alone treatment.
The use of solidification/stabilization technologies or of a
dewatering agent in conjunction with landfilling of the sludges was
also considered. The purpose of a dewatering agent would be to
remove residual moisture from sludges and help prevent the
potential formation of leachate. Discussions with the corps and
experts on this type of technology pointed out that it would be
impracticable to treat the organic chemicals of concern at this
site by solidification/stabilization and the liner/leachate
collection systems of the landfill cells would actually provide the
necessary protection of the ground water from the contaminants
contained within the landfill cells. Potential technical
difficulties were also identified which included clogging of the
leachate collection system, a significant increase in the volume of
material to be placed in the landfill cells, and an increase in air
emissions. Because of the extremely large volume of waste that
would need to be contained in the landfill cells, the contingency
space would be limited. Any nonessential increase in the amount of
material to be contained in the cells would have an adverse impact
on landfill construction and could increase operation and
maintenance (O&M) costs. The interaction between the dewatering
agent and sludge could generate sufficient heat to increase air
emissions during the landfilling process. The benefit gained by
use of a dewatering agent would not provide any significant
reduction in site risks which would not be otherwise provided by
landfilling of the untreated sludges. For these reasons, the use
of a dewatering agent was not considered appropriate for the site.
Soil washing technology was also dismissed as a treatment prior to
landfilling. Treatability studies indicated that this technology
was not technically effective or cost-effective in remediating
soils at the site to risk-based levels.
None of the technologies considered for treating the sludges and
-------
soils prior to landfilling were able to achieve cleanup goals in
treatability studies performed. Further problems were identified in
the re-evaluation of various treatment technologies that resulted
from the pre-design study. The added costs of these treatment
technologies would not provide significant additional risk
reduction at the site over landfilling alone.
In summary, the use of on-site incineration was determined
inappropriate and not cost-effective. This was due to the lack of
significant risk reduction from implementation of this technology,
and the significant engineering and logistical problems associated
with the construction of the remedy. In addition, none of the
other remedial technologies considered were suitable for the site.
Estimate of the cost and time required to implement the ROD
Amendment alternative of landfilling:
This ROD Amendment does not address any issue associated with
ground water or deal with the design of the ground-water treatment
facility. The capital costs associated with the construction of
that facility are currently estimated at approximately $11,000,000.
The cost of ground-water treatment is not reflected in this ROD
Amendment. The total estimated capital cost of ou *1, including
implementation of this amendment and construction of the ground-
water treatment system, will be approximately $56,000,000.
The ROD for OU #l called for incineration of approximately 108,000
cubic yards of contaminated sludges and berms with a risk of
greater than 10"2. The resultant ash would then be contained in on-
site landfill cells. This remedy fails to provide consistent
treatment to approximately 400,000 cubic yards of soils with the
same risk level. For this reason, incineration does not provide
any additional reduction in site risks associated with the
contaminated sludges and soils in the lagoon area.
The U.S. EPA has determined that landf illing of the sludges and
soils without treatment provide the equivalent level of protection
to human health and the environment from site related risks as that
provided by the remedy in the original OU *1 ROD. The untreated
sludges and soils will be contained in on-site RCRA-type secure
landfill cells constructed as part of the original remedial action
at the site. Additional information concerning the design
requirements for these cells is contained in the original ROD. The
landfill cells include two liner and leachate collection systems.
DEscRirriQN or tub re* ftusmTiYB
Capital:
Annual Operation & Maintenance (O&M):
Present Net Worth:
Implementation Time (Total Action):
$44,583,522
$89,030
$45,498,216
3 years
7
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All landfill cells will be upgradient of the ground-water
extraction wells which are used to maintain capture of contaminated
ground water at the site. All ground water passing under the
landfill cells will be captured by this extraction system. Because
contaminants will remain in the aquifer after conclusion of the
remedial action for this operable unit, the extraction system is
scheduled to remain in operation perpetually or until ground-water
cleanup criteria are reached. These cleanup criteria will be
established as part of the ROD for OU *2. However, regardless of
the status of the ground-water treatment system, the landfill and
leachate collection system will be continually monitored. If
leachate is detected and collected it will be treated in the
ground-water treatment system.
Should leachate form despite infiltration protection provided by
the cap, it would be trapped by either the primary or secondary
liner and leachate collection systems of the landfill cells and
then be treated at the on-site ground-water treatment facility.
Should the primary liner and leachate collection system (typically
consisting of a graded filter layer, a geotextile layer, a drainage
layer, an impermeable flexible membrane liner such as 60 millimeter
thick high density polyethylene, and 5 feet of compacted clay with
a permeability of not greater than 10'7 cm/sec) fail, leachate would
be trapped by the secondary liner and leachate collection system
(typically consisting of a drainagfe layer, an impermeable flexible
membrane liner such as 60 millimeter thick high density
polyethylene, and 3 feet of compacted clay with a permeability of
not greater than 10'7 cm/sec). Should the entire multi-layer liner
and collection systems of the RCRA type landfill cell fail, the
leachate would be captured by the ground-water extraction system
and treated along with contaminated ground water in the ground-
water treatment facility.
Since landfilling is a component of the original ROD, capital and
O&M costs for the landfill are accounted for in the original cost
estimate of the Feasibility Study and is a factor for both the
remedy selected in the original ROD and this ROD amendment. The
cost estimate proposed for the Remedial Action in the original ROD
was approximately $72,000,000. During early stages of the design,
errors in the estimate were identified by the Corps and the working
estimate for the design rose to between $100,000,000 and
$120,000,000. The current cost estimate to incinerate 108,000
cubic yards of contaminated sludge (without evaluating the impact
of the engineering design issues identified in the pre-design study
such as higher BTU content and higher water content of some of the
sludges) is expected to be approximately $30,313,000. This cost
includes mobilization, trial burns, demobilization, process area
foundation, and incineration of 116,452 tons of sludge at a cost of
$220/ton. For all construction activities, the Corps estimates
that an additional 43% of the remedial action cost3 should be added
to the total cost. This 43% accounts for cost growth,
contingencies, oversight and administration. This brings the
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projected cost of incineration and handling of the resultant ash to
$43,476,000.
One of the purposes of tha pre-design investigation was to
establish what was the actual extent of contaminated soils around
the lagoons. These volumes were only estimates in the original
ROD, Any additional volumes of contaminated soil identified in the
pre-design investigation would need to be contained in the landfill
cells which would be constructed on-site. The cost associated with
this increased volume of material identified during the pre-design
would be the same for either the remedial action or the amendment
alternative and is therefore not reflected in the cost of this
amendment. This would mean that the total cost savings of
instituting this amended remedy would be approximately $43,476,000.
Because of the uncertainties involving incineration of the lagoon
sludges identified in the pre-design study, it is very likely that
additional costs associated with either incineration or material
handling would be identified prior to the conclusion of the design
or during the start up of the system.
The three hot spots identified in the Feasibility Study for the
proposed OU *2 ROD will be included for disposal along with the
soils and sludges of 0U *1. The volume of soil from the three hot
spots is estimated at approximately 70,000 cubic yards.
O
The volume of soils and sludges required to be landfilled on-site
is approximately double the volume anticipated in the original ROD
for OU *1. Because of this large increase in volume, it will not
be possible to construct a landfill within the confines of the
lagoon area that will be large enough to hold the entire mass. The
unused landfill adjacent to the lagoon area but still within the
boundary of OU *1 will be expanded and upgraded to meet the
requirements of a RCRA type landfill and used to hold the
additional material (see Figure *#5). Only the lesser contaminated
material will be placed in this landfill. In addition, a series of
extraction wells will be installed downgradient of this landfill
and connected to the ground-water treatment facility. These wells
will provide a tertiary containment system should a future problem
occur in the leachate collection system for this landfill cell.
The removal of incineration as a treatment technology has led to a
re-evaluation of two ARARs for the proposed action of landfilling
without treatment of lagoon area soils and sludges. The U.S. EPA
now considers that discrete portions of both RCRA and Ml Act 64 are
relevant and appropriate at the site. Specifically, those
substantive portions of RCRA and MI Act 64 which deal with the
design and construction of the cover, liner and leachate collection
systems for the landfill cells that will be built on-site are
relevant and appropriate for the site. No other portions of the
regulations are considered appropriate for the Bofors site.
Because the design requirements of the MI Act 64 liner and leachate
collection systems are more stringent than those of RCRA, the U.S.
9
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EPA will defer to the State design requirements as specified in the
appropriate sections of MI Act 64.
SVALpatiqn oy ALTFRWTIv?g
The following section outlines the nine criteria that were used to
evaluate the original selected remedy and the amended remedy.
Based on current information, the amended remedy provides the best
balance of benefits measured against the nine evaluation criteria.
This section profiles the performance of the amended remedy against
the nine criteria, noting how it compares to the original ROD
remedy.
Overall Protection of Human Health and the Environment
Both the remedy selected in the original ROD and this amended ROD
provide protection of human health and the environment. The
incineration strategy as outlined in the original ROD does not deal
with site soils posing the same risk as the site sludges nor does
it destroy a major portion of site contaminants. The remedy
selected in the original ROD relies on containment of these
materials to provide overall protection. Eoth remedies rely on
containment and long-term operation and maintenance of both the
landfills and the ground-water treatment system to provide overall
protection of human health and ttu? environment. For this reason,
the reduction of site risks provided by the remedy selected in the
original ROD and this amended ROD is expected to be equivalent.
Compliance with ARARa
Both remedies are expected to comply with all State and Federal
ARARs. The substantive portions of both RCRA and MI Act 64 that
deal with the design and construction of the cover, the liner, and
the leachate collection and monitoring systems for the landfill
cells are both relevant and appropriate for the site.
Long-Term Effectiveness and Permanence
Although incineration of some of the material at the site would
provide a permanent remedy for treated materials, the original ROD
remedy did not call for the incineration of all OU *1 soils with a
risk of greater than lxlO'2, and it addressed only a portion of the
heavily contaminated sludges. A significant volume of material
with a risk level above lxlO"2 was intended to be landfilled in the
original ROD. The significantly greater volume of contaminated
soils with a risk level greater than lxlO*2 found in the pre-design
study significantly lessens the effective overall reduction of risk
at the site that i^ould have been achieved by incineration of the
materials originally selected for treatment in the ROD. in effect,
the long-term effectiveness of both the remedy selected in the
original ROD and the amended ROD are expected to be equivalent.
Long-term effectiveness of both remedies is dependant on
maintaining the integrity of the RCRA-type secure landfill cells
and the continued operation of the ground-water extraction and
10
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treatment system.
Reduction of Toxicity, Mobility, or Volume through Treatment
The original ROD called for incineration of site sludges which
would reduce the toxicity, mobility and volume of those materials.
However, site soils with risks equivalent to site sludges were to
be contained in landfill cells under the original remedy, and
therefore risks associated with the principal threat wastes would
not have been addressed for the overall remedy. This amended ROD
does not require treatment of any of the material at the site
because treatment is not cost-effective. Consequently this
criterion is not satisfied for this ROD Amendment remedy.
Short-Turn Effectiveness
On-site containment is a component of the original ROD and this ROD
Amendment. However, the elimination of incineration as a component
of this ROD Amendment is expected to reduce overall short-term
impacts at the site. Elimination of incineration should also
reduce the time required to implement the remedial action at the
site. It was estimated in the ROD for OU *1 that it would require
5 years to complete the selected remedy. This estimate included
the incineration of the sludges, construction of the landfill
cells, filling and closure of the landfill cells, and construction
of the ground-water treatment facility. It is estimated that the
amended remedy, together with completion of the ground-water
treatment facility, will require 3 years.
Implementability
Implementation of the amended remedy is expected to be easier than
the original selected remedy. Issues associated with the
substantive regulatory requirements for the incinerator would be
eliminated while issues associated with construction sequencing,
material handling, and mixing of the sludges should be simplified.
Cost
The estimated costs for the soil and sludge components of each
alternative are in the following chart:
ALTERNATIVE CAPITAL COST ANNUAL O&M COST PRESENT NET WORTH
Original ROD $88,059,522	$89,030	588,974,216
ROD Amendment $44,583,522	$89,030	$45,498,216
The amended remedy is less expensive and provides the same overall
reduction of risk at the site. Implementatipn of the amended
remedy is estimated to constitute an overall savings of
approximately $43,476,000 in capital costs.
State Acceptance
The State of Michigan concurs on the selected remedy in this
Amendment to the Record of Decision.
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Community Acceptance
There were several comments received from the community during the
public comment period. These comments and the U.S. EPA's responses
are contained in the attached Responsiveness Summary.
STATUTORY DETERMINATIONS
The amended remedy complies with the requirements of CERCLA § 121
by controlling site risks pos«d by ground water, air, or direct
contact with hazardous site materials through the containment of
site soils and sludges. This action will not cause any
unacceptable short-term risk or cross-media impacts. The amended
remedy complies with all State and Federal ARARs. There are no
chemical, action or location-specific ARARs identified for this
action that were not identified and discussed in the original ROD.
The amended remedy is cost-effective. This Amended Remedy reduces
costs associated with construction sequencing, material handling
and temporary storage of the sludge as well as eliminating the
capital and operational costs of the incinerator. It reduces the
overall cost of the remedial action for this operable unit by
approximately $43,476,000 and provides equivalent reduction of site
risks as the original ROD.
The amended remedy provides the Best balance of trade-offs with
respect to the evaluation criteria. Treatment of the principal
threat wastes was found to be not cost-effective and impractical
based on the volume of these materials and the limited number of
applicable technologies that could potentially treat the
contaminants of concern at the site. This action does not satisfy
the preference for treatment as a principal element of the remedy.
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responsiveness summary
The United States Environmental Protection Agency (U.S. EPA) has
recently completed the pre-design study for the remedial design of
Operable Unit *1 (OU *1) at the Bofors-Nobel Superfund site in
Muskegon, Michigan. As part of the pre-design effort, an
investigation was performed to refine the Feasibility Study
estimate of the horizontal and vertical extent of contamination at
the site and to establish design parameters for the incineration
technology.	Information gathered during this pre-design
investigation has provided critical data which has caused the US.
EPA to re-evaluate the use of incineration as a treatment
technology at the site. An Amendment to the 1990 Record of
Decision (ROD) was proposed by U.S. EPA based on the findings of
the pre-design study. U.S. EPA held a public comment period from
April 6 through June 19, 1992, for interested parties to comment on
the U.S. EPA's Proposed ROD Amendment.
The purpose of this Responsiveness Summary is to document the
comments received during the public comment period and U.S. EPA's
responses to the comments. All of the comments summarized in this
document were considered prior to U.S. EPA's final decision.
Following are all the comments received and U.S. EPA's response to
each comment.	^
COMMENT:
EPA should have conducted a more extensive Remedial
Investigation/Feasibility Study (RI/FS) and should not have left
data gaps to be filled in by studies conducted during the pre-
design or remedial design.
P.S. EPA'3 RESPONSE;
The purpose of the RI/FS process is to gather enough information to
make a decision about what will be an appropriate remedial action
for the site. During this process, there is an inherent conflict
between the time required to gather enough information to reach the
decision and the need to respond to an imminent and substantial
endangerment to public health or the environment. Some necessary
information deals with construction decisions and not with the
choice of remedial actions. For this reason, it is appropriate to
the defer those investigations to the design phase when the focus
of the project shifts from choice of remedy to design and
implementation of the chosen action.
U.S. EPA recognizes that new information may become available at
any time during the remediation process, and that this information
could cause U.S. EPA to re-evaluate the selected remedy. For this
reason, U.S. EPA has established a process to amend records of
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decision. That was the case with this project.
COMMENT;
U.S. EPA has no regard for public health daring remedial actions.
The health of the community should not be at risk due to the type
of remediation selected just because U.S. EPA has been mandated to
select long-term or permanent or cost-effective remedies.
P.8. SPA's RESPONSEi
The primary concern of U.S. EPA is protection of human health and
the environment. It is the first criterion by which U.S. EPA
evaluates any potential remedy. Throughout the entire Superfund
process, from the remedial investigation through the conclusion of
the remedial action, U.S. EPA evaluates the impact of site actions
on the local communities. However, U.S. EPA is mandated to seek
the most appropriate remedy for each site and to seek permanent
solutions to site problems. In order to accomplish this, U.S. EPA
evaluates each remedy against the nine criteria specified in the
National contingency Plan. Part of this process is to compare the
current level of risk posed by the site against the potential of
future releases. U.S. IPA evaluates the potential impact from
these releases on both local comauifities arid the environment. Only
then does U.S. EPA determine the appropriate remedy for the
Superfund site. By implementation of this ROD Amendment, U.S. EPA
believes that the short-term risks and impacts on the local
community will be less than the short-term risks posed by the
original ROD remedy.
COMMENT;
U.S. EPA should give preference to local contractors when
conducting the remedial action and should spend as much money
locally as possible during site activities.
0.8. SPA'S RESPONSEi
U.S. EPA has an agreement with the United States Army Corps of
Engineers (Corps) to provide oversight of all remedial design and
remedial action activities at the Bofors/Nobel site. As part of
this agreement, the Corps will be responsible for advertising and
awarding all contracts dealing with site remedial activities. When
advertising and awarding contracts, the Corps must follow the
Federal Acquisition Regulations (FAR). The FAR provides guidance
and places restrictions on how contracting and contracts must be
administered. Both the U.S. IPA and the Corps are prohibited from
showing preference in either advertising or awarding these
contracts. The Corps will advertise the contracts in the Commerce
Business Daily which allows any interested contractor throughout
2
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the nation to bid on the project. If the contract is classified as
an invitation for bid, the contract will be awarded entirely on
cost. If the contract is classified as a request for proposal, the
award will be based on the best proposal to implement the Remedial
Design. Currently, the contracting mechanism for each of the
various phases of the Remedial Action has not been chosen.
Regardless of the contracting method used, due consideration will
be given to all firms, including small businesses and small,
disadvantaged businesses, pursuant to the policies of the FAR.
SQUMSSX:
U.S. EPA should re-evaluate additional alternatives, including SITE
program technologies, instead of landfilling material without
treatment.
E.g. EPA'3 RE8P0NSE:
When the information gathered during the pre-design study indicated
that the use of incineration was no longer an appropriate remedial
action for OU *1, U.S. EPA re-evaluated the spectrum of potential
alternatives included in the Feasibility Study. This list of the
potentially applicable technologies which could be used to deal
with the contaminants at the site^is presented in Section 2.4 and
Appendix D of the OU #1 Feasibility Study. The list includes 11
methods of containment, 15 methods of incineration, various
disposal options, as well as biological, soil vapor extraction,
chemical extraction, soil washing, soil flushing, dehalogenation,
low temperature thermal desorption (LTTD) ,
solidification/stabilization, microencapsulation, vitrification,
and in-situ vitrification. U.S. EPA also evaluated potentially
applicable remediation technology currently under evaluation in the
SITE program. The SITE program was established to evaluate
potentially useful technologies that have not yet been fully
developed. These technologies are generally available for pilot
scale testing at sites but are not applicable to full scale
remediations. As discussed in this ROD Amendment, none of the
available technologies was deemed appropriate for the Bofors site.
COMMENT!
U.S. EPA should allow local fire officials to review the remedial
design for fire safety.
U.S. EPA'S RESPONSE:
U.S. EPA agrees and will instruct the Army Corps of Engineers to
coordinate review of all appropriate sections of the design with
local fire and safety officials.
3
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COMMENT:
U.S. EPA should provide local firefighting agencies with funds and
equipment so that they will be prepared to respond to fire
emergencies onsite.
P.8. EPA*3 RESPONSE;
The activities which U.S. EPA contemplates at this site are to be
taken in accordance with the National Contingency Plan and the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 as amended by the superfund Amendments and
Reauthorization Act of 1986 (SARA).
The fund created in accordance with SARA was established to respond
to the release, or potential release, of hazardous substances into
the environment. It would be inappropriate for U.S. EPA to use
this fund to procure firefighting equipment which would then become
the property of local governmental units.
It is the intention of U.S. EPA to cooperate fully with local
officials on such matters as the nature of the reagents to be
stored on site and potential risks associated with treatment of the
contaminated ground waters at the site. Furthermore, as treatment
manuals and operator training mam&ls are developed, U.S. EPA will
make them available so that local fire fighting personnel have as
complete a picture as possible as to the functioning of the
remedial action.
COMMENT ;
The proposed amendment to the ROD is too stringent and a RCRA-type
landfill is over protective. The waste at the site should simply
be covered in place and the ground-water treatment system operated
to maintain the ground-water plume.
U.S. EPA*a RESPONSE:
The landfill proposed in the Record of Decision and in the
Amendment will provide more long-term protection of human health
and the environment than capping alone. The landfill design will
incorporate a bottom liner and leachate collection system and
thereby further limit infiltration of contamination into the
aquifer below the site.
COMMENT;
Until an appropriate treatment technology can be developed, it
would be more appropriate to place the waste in an above-ground
containment building. This building would be 250 foot on a side
4
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and stand 70 foot tall. The cost for this building would be
approximately $6 million and would be cheaper than construction of
the landfill.
U.S. EPA13 RESPONSE:
Above-ground containment was evaluated by U.S. EPA for this
Amendment and was not found to provide additional protection to
human health and the environment over a RCRA-type landfill system.
In addition, the building proposed by the commenter would have
insufficient space to hold the volume of material from the Bofors
site. Above-ground containment would require 7 such buildings at
a cost for construction of approximately $41 million. The cost of
excavation and material handling to place the sludges and soils
within the buildings would bring the total cost for such above-
ground containment to approximately $98 million.	This
significantly exceeds the current cost estimate for the containment
portion of this project and does not provide additional reduction
of site risks. Additionally, soil at the site will be excavated to
the water table and then replaced with clean fill material. It
would be difficult to insure adequate compaction of the new fill to
provide proper foundational footing for the buildings.
COMMENT:
The proposed amendment fails to address restoration of the Lomac
property.
P.3. SP*«s RESPONSE;
Lomac purchased the facility property with the knowledge and
understanding that the site would be the subject of a remedial
action. The hot spots constitute a small area on the southern edge
of the Lomac property and they are adjacent to OU *1. The impact
on Lomac operations is anticipated to be minor. The Feasibility
Study for OU *2, which deals with the entire Lomac facility
property, has been completed and U.S. EPA is currently evaluating
potential remedial alternatives. The issue of restoration of the
Lomac facility property will be part of the analysis of remedial
alternatives for that operable unit. Construction activities of
the operable units is expected to overlap. Any required
restoration of Lomac property would be most appropriate at the
conclusion all remedial actions.
COMMENT:
The proposed amendment fails to address issues of confidentiality,
security, worker protection and notice to Lomac.
5
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U.S. EPR's RESPONSE;
The purpose of the Amendment to the Record of Decision (ROD) is to
address changes that have become necessary to the ROD as it was
signed in September of 1990. The ROD considered site security and
worker protection during implementation of the remedial action.
The additional risk posed by inclusion of the hot spots does not
add significantly to the previous evaluation of worker risks. Site
security is always a significant issue at Superfund sites.
Appropriate security measures will be evaluated during the remedial
design and implemented as part of the remedial action.
Lomac is a member of the public and will be treated by U.S. EPA
appropriately. Every effort will be made to keep all interested
members of the community, including Lomac, informed about site
activities and any potential impacts to the local area. However,
U.S. EPA does not provide any community member special treatment,
privilege, or information not available to all other members of the
community.
COMMENTi
There is no need to excavate "hot spots" on the Lomac property at
this time.	»
XJ,B. EPA's RESPONSE:
Information from the Feasibility Study for OU *2 indicates that the
hot spots should be removed to provide increased protection to the
environment and potentially reduce the time required for
restoration of the aquifer beneath the site. The hot spots
identified are actually contiguous to portions of the lagoon area
that will be excavated as part of the remedial action for OU *1.
It would require significant, unnecessary and duplicative effort
and expense to postpone removal of the hot spots until OU *2.
6
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2
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9
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2
7
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21
U.S. EPA ADMINISTRATIVE RECORD INDEX
UPDATE #3
BOFORS-NOBEL SITE
MUSKEGON, MICHIGAN
06/23/92
AUTHOR
:uus
RECIPIENT
SS3S
TITLE/DESCRIPTION
cmnstiunn;;
U.S. Any Coroi of
Enoineers
:tirson. 5.. JS Are*
Carps ot Engineers
Reznick. L. jecftert
Price 4 Shoaos
Seznict, l.. Dechert
Prict 4 Rhoads
SZA/'Doochue
Sobelaan. 5., ILLEPfl
7e;n. n.. N5W
USEPA
tiiison. n.. USEPA
Cuffun. l. I
Sustafson. A., UScrA
6usUfson. II., USEPA
2 Figures—Scheeatic ot the JRF Rotary Kiln -
s/staa ana Saapiino flitru
Attacheent A: Scope of fork for the Reeeoial
Design
iiCiarouno info on MedtvtiGOiir.t frirceoures
aoni br hJford Scoers Cuilieore• Concepts
HhMDDk^mM- *31icx Box Configuration*
C#py of Letter Reauestmg Tim Eitensioo tor
CoiMDti of the Si/FS
Objection to Denial of riee Extension for
Coeaents on kI/rS
HOUR ana USEPA	Project Progress Report 6/21/90-10/23/70
Sustafson. If.. USEPA
Priyftysi. R., HDHR
Cover Letter to Intonation Concerning Air
Eiiitiom
"u Covtr *no Proaerty Boundary Action Levels
ana Technical Bethoot ror Evaluation of Air
duality Issues at Kaiarerus luste Cleanup
Sitti
•anil, I., U.S. Arty
Corp* of Engineer*
SZA Oonohuc
Ellison, H,, USEPA
Ellison. K., iiSEPA
SZA/Donohue
Cariact, S., US Any
Corps of Enoineers
U.S. Any Corps of
engineers
HOUR
Jams, L., US Arty
Corps of Engineers'
ADM ino USErA
Ellison, H., USEPA
Superfund Acquisition Strategy Neaorandus for
the Record and Signature Sheet
Baseline Risk Assessment Plan: Plant
Area/6rouno«ater Operatic unit
GU 12 Hot Spot flap (with Fax Cover)
Reaadial Desisn Project Hanageeent Reports
*1-112 iJan.- Gee. I9?i)
Project Progress Report 10/23/90-1/24/91
jSACE Project Reoort for October
Deceaoer. I'm
1
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'HOC
9
J
205
1
7
5
2
2a
?
j
i
I
2
2
13
1
author	RECIPIENT	TJ!LI/J)ISwU?nON
=SXS=3X
The Sunday	Articie--Aiie tne eotors incinerator Safe
Chrgnicii, Nusieoon,
HI
bins, t., WEN	Sustafson. It. I list 91 Csiaumtr Questions rt; incinerator
Ellison, H. U5EFA
*>« Engineering I	Staple Anaiysis--r.M. Aqueous
Science
5A2/Sonfllwt	NOW Alternatives Array Occuaent
Ellison, H.. USEPA	tieiaan, J., (KM Conversation Record sf Visit rei PUceaent
llMM
Ellison. i/ScPA	Jaois, I., US Any Covtr and 2 Reeeoiai Design fleoorts
Cores of EnfiMtri CIJ/i2/fil (sic! and 3/21/11
rjuSson, S.,	Article—"state s ust of Pailuteo Sites Sti-
HustNon Chronicle	11 Sronnw*
Evans, K., WREN I	(IDPH Inferutioo/Cocaenti on Site Health
Cabala. I,, late	AsiMSient
lichiqan Federation	a
Carlack, US Aray	Ellison, H., USc?A USAGE Project Report for January
Corps of Engineers	February 1591
Ellison, H., USEPA	Evans. I., HREN Responses to fluestiom
US Aray Corps of	Engineering Analysis-incineration
Engineers
Carloct, S., .5 Aray	tilison, H., USEPA USACE Frojeci Seoort for Karen 1991
Corps of Engineers
CarJoe*. £., US A re*	Ellison, K.r USEPA Cover tetter ar.s USACE Project Report for
Corps ot Engineers	April, 1991
Ellison, K.. USEPA	Prxyfcysx, R., RDM Aptiogy for Coaaunications Sap
Ellison. K., USEPA	Priybysi, ft., KM Letttr Reiterating Issues and Reaedial
AltefMtim m the feasibility Study
Hercier, H. JJSLArey	Prryfcysz, R., ISM Rarest for 8eter«nation of Mater Quality
Carpi of Engineers	Discharge Lmts
Przybjti, fi., JIWR	Ellison, K.r USEPA Analytical iell Saapiins Results froa 5/6/? 1
Ellison, H., USEPA	Jams, U, US Any Confiraation of Use of Edge for Soils and Ash
Corps of Engianrt During Incineration Phase
2
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tot:
44
i
;a
I
9
29
42
1
4
1
i
1
*
I
4
1
iu'THOfi
:nux
RECIPIENT
sssiscnt
Ti;LE/DESKIrTi3N
::msu8«ms»x
?r:ybysz. R.. NDNR Ellison. H., u'5E?A
Shuitz. S.. Donohue Ellison. K., U3EPA
Jinai, I. U.S. Arty Eiiison. n., USEPA
Cores of Engineers
Fishieck. Thotosnn.—USEPfl
Cirr * Hubtr, Inc.
Caver jr>a iUter Trtittenc Service Agreeeent
»ith Lone »uh lnvoi:es
Caver to CRAFT Fusibility Stuav rieoort tor
6round«ter/Hant Am Gpenolf Unit
Fix Cover ana Sccoe of kori for the Ktteoui
Design	—
6rnnd Htter Discharge levels. (Kith
(unwritten cottents)
Retting Agenda for Project Scheduling
Key issues IHano»ntten notes in targm and
atUchefli
Bmniwittr Sailing korr Plan for Lotac inc.
Acurei Cora.
Janis, L., US Arty
Corps of Engineers
Carroll. o,. LiSEPA
kripps. C. Hoorljno
ToNnshH-ioira
iiSEr A
Ellison, H., USEPA
j«nis. i... US Artv
Corps of Engineers
Sofors Nobel
Test Pi in for Evaiuiung tne incineracility
of Contitinateo Sludges
Cover Heto to Srountiuter Bencn Sole
Tpittbiiity Study iort Plan inot included)
Caver Letter to Evaluating the Incinerablity
cf Contatinated Sludges
Com to Cosy af To»nsbio Drdinance re: Top
Sails ana Sana Retovai
IS Arev Corps of
Engineers
Thurnau. a., USEPA
Ellison, H., USEPA
Petersen, ft., US
Arty Corps of
Engineers
Shuitz, S. i Froh,
D., fionahue
Ellison, H., USEPA
Jams. L.. u: Arty
Corns of Engineers
Olson. C., US Arty
Corpi of Engineers
Ellison, H., USEPA
Jims. I.. U.S. Arty
Corps of Engineers
Janis, L., US Arty
Corps of Engineers
Meeting Attenstr.ee uit-
301 Desion «evie« Conference
Cottents on Test Plan for Evaluating the
incioertoiity of Contaeinatec Sluoges
Decision to Includr Sprinkler Fire Protection
Sr*t»»
Request for Kaiver of EFA 9090 Testing on
6«ottxtiles
Predesign Activities
Counts on Test Plan tor Evaluation the
[nciseraoilitr of Contaainated Sludges
J
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*5e
«S|:
152
i
5o
lb
3
2
1
J
C
I
1
1
2
17
,02
30
MTHOR	RECIPIENT	; IftE/CEsCRfFnOK
sssin	s ssansca	T'lrir*"—		
iiS Any Corps of	301 Desion Ariiiysis-RwtttD COFV
Engineers
Ellison, ri., iiSErA Jans. L., US Any Cooents on Drait Engineering Anilvsis
Corps of Engxnort
^cjrn Corp.	USEPA	Quality Assurance Project Pun for Evaluating
tin IncmeraPility of Contaminated Sludges
ncurti Corp.	iiSEPA	Test Plan lor Evaluating the Incineraoility
of Contaminates Sludges—nevision 1
Us Ariy Corps of	USACE Project Report (Section 11 -1V amino*
Engineers
cllison, H., JSEPA Jinn. L., US Arty	CMMftts on Use of EPA 9090 Testing on
Corai of Enfinttrf	6eot«itiles
:etersen. X.. JS Eiiison, H., USEPA	Cover Letter to 301 Desicn Documents moi
¦iriy Corps of	included)
Engineers
Kiteriina, I..	Carroll, 6., US£PA	Covtr Letter to Revised Test Plan for
Acurei Corp,	Ctfluitinq tne Incinerabihtr or Concasinatea
Slopes
Petersen, n. u3 Arty tliison, H., USEPA	CoaMius on LOtac iort riin ana (he mu#u
Corps of Engineers
Petersen, US Priybysi, ft. HOW	«at«r iuaiity Stanoards for Discharge 01
Ar«y Corps of	8rswno«ater
Engineers
Carrot 1. S.. 'J3EFA Jams. I.. US Any	Covtr Letter to the QA?)?
Corps of EnqinHri
Ellison, n.. iiSErA Kartin. II., USEPA	Staueit i:r Se*ien of 3GZ iesian or
firouid-ifater Treatunt rjciiity
Jims, L., US Arty Ellison, H., USEPA
Corps of Enqmiers
Jams, L.. US Arty Eilison, H., USEPA
Corps of Engineers
US Arey Corps of
Engineers
js Ariy Corps of
Enoineers
Fax Cover md 1 P«oe frot Status Report
Transmittal ar.d DRAFT Floodolain fcelineationj
Hydroiogic Analysis
£noij>ttrir>t} Analysis: Landfill Site
Alternatives
USAGE Project Report
4
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UjCI jA7E AUTHOR
SECIFIEKT

TITLtf DtsCp.IFriOK
s=s*sxs*5=r35S==
rnota
66 iC/C7/?i Jims, l•« Lis Ar«r eiiison. nJSEPA,
Coras of Engineer! et. a).
Cover ana ititcra i Prmtimrr fiecort
tYiluiticn ot BCHT Fr::ess tor aeii
Sehibilitation
47	10/09/91
id	10/09/91
— S9	10/09/51
"C	15/15/91
17/91
"	lc.-ism
73	10/22/91
tliison. H,, ijSEPA Jams, l., jS Are*
Cores o' Engineers
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4
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7
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14:44 f-AI 16187522000
Warner
f\o o
the lagoon area to assist in the installation and/or operation oi
the barrier wall, lagoon area cover, groundwater containment and
extraction and vegetative treatment portions of the TIC remedy.
Details of the scope of this portion of the remedy will be
developed during the Remedial Design-
ZZI.C O.q. <1 Lagoon Arat Cam
As part of this remedy, the O.U. #1 lagoon area will be covered
to eliminate risks associated-with- exposure to O.U. II soils and
sludge, including any risks associated with possible emission of
contaminants from soil and sludge. The O.U. <1 lagoon area cover
will be constructed over the soil and sludge contamination that
constitutes unacceptable risk through relevant exposure routes.
The cover will reduce, but not eliminate, infiltration of
precipitation through the waste mass. The vegetative component
of this remedy requires that the area cover be sufficiently
permeable to allow for plant growth. The vegetation will reduce
erosion, stabilize the cover, and enhance the aesthetics of the
area. Design and construction details for the O.U. #1 lagoon
area cover will be developed during the RD but will be based on
elimination of exposure pathways that may result in unacceptable
risk in accordance with ARARs.
Use of a permeable cover will allow precipitation to percolate
through the waste mass and may provide some flushing of
contaminants from contaminated soils and sludge into groundwater
underneath. Infiltration will be allowed because of the expected
groundwater capture provided by the barrier wall and extraction.
This flushing of contaminants into ground water will occur while
the treatment provided by phytoremedlation is occurring and the
vegetative components of the TIC remedy are maturing.
Contaminants that leach into groundwater would be extracted and
treated before discharge to surface water. Over the oast twenty
years, this type of containment has been successful at this site.
The TIC remedy, including any necessary Contingent Remedial
Actions, is expected to comply with all substantive requirements
of the identified State and Federal ARARs. Wastes that were
deposited in the lagoons are by-products of specialty chemical
production that occurred on site before the enactment of RCRA.
U.S. EPA determined that RCRA and State landfill cap standards
were relevant and appropriate requirements for the Landfill
Remedy. Because the TIC remedy has different objectives,
including movement and capture of groundwater within the source
area, and treatment of waste using phytoremediation, RCRA and
State landfill cap standards are not ARARs for the lagoon area
cover portion of the TIC remedy. In the event a TIC cover
17
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upgrade is later required as a Contingent Remedial Action, RCRA
and Part 111 of NREPA may be ARARs for that upgrade. These
standards would be ARARs for any excavation activity. In the
event that surface cleanup phase of the remedy requires some
excavation and off-site disposal/ the excavated material shall be
characterized, manifested, and disposed of in accordance with
RCRA and parallel State requirements.
IXX.D Vnaatatlon Installation *nd Wetland Knhanc—«nt
As an enhancement to the "groundwater, soil, and sludge
containment provided by the barrier wall, various vegetative
species will be planted within the contained areas of the TIC.
These plant species will immobilize contaminants, serve to
enhance groundwater containment, and provide treatment by
phytoremediation. Available literature indicates that plant
species have the capability to transform organic contaminants to
more benign compounds. The literature further documents that
plant roots provide a medium under which microorganisms can
flourish, and natural destruction of organic contaminants can
occur. As part of the TIC remedy, degradation of the sludge and
contaminated soils will be assessed and studies regarding
phytoremediation will be incorporated as appropriate into the
Remedial Design. Literature suggests that for the nature and
extent of contamination present at the site, treatment mechanisms
provided by the remedy may reduce site contamination to levels
that allow termination of the TIC remedy within an approximate
time of 30 to 70 years, with the most appreciable reduction
occurring in the initial 20 years. In addition, the biological
fouling of existing extraction wells suggests that there is
naturally occurring microbial activity on groundwater
contaminants. These combined mechanisms contribute to the
reduction of contaminants in both groundwater and soils.
Figures 4 and 5 depict the proposed installation layout for TIC
remedy vegetation. Four distinct vegetation areas (noted as
Areas A,B,C,D) have been proposed. Vegetation will be monitored
as needed to assess its success In iromobiliting and fostering
destruction of contamination and to assure that contamination
uptake into the vegetation does not create unacceptable risks.
Ill,*	Groundwater Pontilnwant Rvtraatlan. and Traataant
A network of extraction wells similar to the current system would
have provided containment of contaminated site groundwater for
the Landfill Remedy. Irt the TIC remedy/ groundwater containment
will be provided primarily by the barrier wall, which will re-
direct natural groundwater flow towards a vegetated area
18
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constructed within the barrier wall boundaries- The groundwater
will discharge to the surface in the wetland where it is
anticipated that the contaminants of concern will bind to the
hunvic soils in the wetland, undergo photolysis or biodegrade.
The surface water from this vegetated area will flow to a central
weir and sump collection point. The collected water will be
sampled and analyzed before determining its disposition. If
contaminants in collected water meet appropriate standards, it
may be discharged to the creeJc or the existing wetland outside
the barrier wall. The discharge system may be designed such that
water that meets appropriate standards is recycled back into
vegetated or wetland areas within the barrier wall. Collection,
extraction, treatment, and discharge of any water will comply
with all ARARs.
If groundwater contaminants exceed standards, the collected
groundwater will be directed towards a treatment facility.
Extracted groundwater may be treated, as necessary, at the
existing groundwater treatment plane. The feasibility of
alternate groundwater treatment facilities or further
optimization of the existing GWTP will be investigated during the
Remedial Design.
In the event the vegetation and the barrier wall can not provide
adequate hydrologic control of contaminated groundwater the
extraction system may be enhanced. The enhanced groundwater
extraction system may include the use of existing extraction
wells inside the barrier wall and/or the addition of new
extraction wells inside and/or outside of the barrier wall as
needed to ensure containment.
To control contaminated groundwater that will remain outside the
barrier wall, a groundwater extraction 'system will be installed
prior to or concurrent with construction of the barrier wall.
This extraction sy3tem will be operated as necessary to prevent
discharge of contaminated groundwater exceeding performance
standards to Big Black Creek and adjacent wetlands before,
during, and after TIC remedy construction activities.
IlX.r Monifcagina Ptonama
In order to evaluate and confirm that the performance of the TIC
remedy remains protective of human health and the environment, a
monitoring program for the sampling and analysis of O.U. #1
groundwater will be developed during the Remedial Design.
Groundwater monitoring will need to demonstrate that the remedy
successfully prevents migration of contaminants at concentrations
19
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<00007
UNITED STATES ENVT&OfflOCNTAI* IR0TECTIOH AGENCI
REGION 5
DATE: Friday, July 16, 1999
dfm TpMifi.
SwouZCT«
FROM:
TO:
TRANSMITTAL OF THE BOFORS NOBEL SUPERFUND SITE SECOND
AMENDMENT TO THE RECORD OF DECISION FOR THE FIRST
OPERABLE UNIT
Bill Bolen, Acting Chief
Remedial Response Branch
William E. Muno, Director
Superfund Division
Gail Gins,
Regional
Enclosed for your review and signature is the Bofors-Nobel Site
Second Amendment to the Record of Decision for Operable Unit
10.U.) II. The Amendment includes the Declaration, Decision
Summary, and Responsiveness Summary. The latest update to the
Administrative Record is also included and additional documents
will be added shortly.
We concur with the amended Remedial Action for the second phase
of the first operable unit for the Bofors-Nobel site which
replaces the construction of two on-site RCRA type landfill cells
with a below grade barrier wall, protective cap, and
phytoremediation. This amended O.U. #1 remedy requires
restoration of groundwater as the first phase through
containment, extraction, and treatment. Protection of human
health and the environment is provided through treatment of
contamination by phytoremediation and concurrent maintenance of
containment until treatment effectiveness is determined or
remediation standards are met.
Please feel free to contact us if you have any questions.
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DECLARATION FOR THE SECOND AMENDMENT TO THE RECORD OF DECISION
SITE NAME AND LOCATION
Bofors-Nobel Site
Muskegon, Michigan
PURPOSE
This decision document presents the second amendment to the
Record of Decision (ROD) for Operable Unit (O.U.) #1 at the
Bofors-Nobel Site (the "site") in Muskegon, MI, chosen 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 the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP).
BASIS
The decision to amend the ROD is based upon the Administrative
Record. Indexes attached to this ROD Amendment identify items
that comprise the latest updates to the Administrative Record
upon which this amendment of the O.U. #1 Remedial Action is
based.
DESCRIPTION OF THE AMENDMENT
On September 1"?, 1990 a ROD was signed for the O.U. #1 Remedial
Action choosing thermal treatment of highly contaminated sludge,
disposal of less contaminated soils in an on-site RCRA Subtitle C
landfill, and upgrade of existing groundwater extraction and
treatment systems. On July 22, 1992 a ROD amendment was signed
removing thermal treatment and changing disposal to two on-site
RCRA type landfill cells. U.S. EPA in consultation with the
State of Michigan issued a remedy re-evaluation on July 16, 1996:
affirming this remedy as the best alternative under U.S.
EPA's evaluation criteria, but
determining that a Total In-Situ Containment (TIC) remedy
proposed by certain potentially responsible parties (PRPs)
provided an equivalent approach if implementability and
long-term reliability and effectiveness issues could be
addressed.
In response to the remedy re-evaluation, the PRPs revised the TIC
remedy alternative to address the specific concerns identified,
and expressed a commitment to assure successful implementation of
the revised TIC remedy. This second ROD amendment is being
issued to reflect such new information and:
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replaces excavation and disposal of contaminated source
areas in on-site cells with cover and barrier wail
containment of the source areas,
provides for phytoremediation within the barrier wall to
enhance immobilization of wastes and control of contaminated
groundwater, and promote contaminant treatment and reduction
by biological means,
establishes long term groundwater remediation standards,
soil cleanup goals, and requires deed restrictions for the
site, and
continues to require containment and extraction, and
treatment of groundwater and long term containment and
management of groundwater until groundwater remediation
standards are met.
The goal of this second amended remedy is to eliminate
unacceptable primary human health risks posed by exposure to
contaminated soils and sludge, mitigate environmental threats,
and control and ultimately restore contaminated groundwater.
This amendment to the O.U. #1 remedy is consistent with past
Remedial Actions for this site.
STATUTORY DETERMINATIONS
This second amended remedy is protective of human health and the
environment, complies with Federal and State requirements legally
applicable or relevant and appropriate to the Remedial Action,
and is cost effective. The principal threat wastes will be
reliably controlled in place. In addition, the phytoremediation
component of the remedy provides treatment of these principal
threat wastes consistent with the statutory preference for
treatment as a principal element. Thermal treatment was shown
not practicable in the 1992 ROD amendment because site soil ar.d
sludge consists of mixed waste of widely varying composition and
the large waste volume made thermal treatment technology
impracticable. This remedy will result in hazardous substances
remaining on site, requiring a review every five years after the
start of Remedial Action to ensure the selected remedy remains
protective of human health and the environment.
The State of Michigan concurs with the second amended remedy put
forth in this document.
Wiliiam E. Muno,/C
Superfund Division
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THE SECOND AMENDMENT TO THE RECORD OF DECISION FOR O.U. #1;
BOFORS-NOBEL SUPIRFUND SITE - MUSKEGON, MICHIGAN
TABLE OF CONTENTS
PAGE NUMBER
INTRODUCTION	3
A. Site History	4
3. Summary of Site Contaminants	6
1.	Lagoon Area Soils and Sludge	6
2.	Site Groundwater	6
3.	Other Affected Media	7
4.	Current Status of Site Contaminants	7
C. Summary of Site Risks	8
0.	Remedy Decisions and Implementation of Original Remedy	9
E.	Remedy Goals	10
r. Remedial Action Objectives	12
LL. REASONS FOR ISSUING THE ROD AMENDMENT - Supporting Information
For The Fundamental Change	13
III.	DESCRIPTION OF THE FUNDAMENTAL REMEDY CHANGE -
Total In-Situ Containment (TIC) Remedy	15
A. Barrier Wall	16
3. Surface Area Cleanup, Civil, and Earthwork	16
C.	O.U. #1 Lagoon Area Cover	17
D.	Vegetation Installation and Wetland Enhancement	13
Z. Groundwater Containment, Extraction, and Treatment	18
F.	Monitoring Programs	19
G.	Deed Restrictions	21
ri. Contingent Remedial Actions	22
1.	Operation and Maintenance	23
J. Site Remediation Goals and O.U. #2	24
IV.	NINE CRITERIA ANALYSIS CF THE TIC REMEDY	25
A. The Nine Criteria	25
3. Nine Criteria Analysis of the Second Amended Remedy	26
THRESHOLD CRITERIA
1.	Overall Protection of Human Health & the Environment	26
2.	Compliance With ARARs	27
PRIMARY BALANCING CRITERIA
3.	Long Term Effectiveness and Permanence	28
4.	Reduction of Toxicity, Mobility, or Volume
Through Treatment	33
5.	Short Term Effectiveness	33
6.	Implementability	34
7.	Cost	36
MODIFYING CRITERIA
8.	State Acceptance	38
9.	Community Acceptance	38
JL. STATUTORY DETERMINATIONS	38
1
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LIST OF FIGURES. TABLES. AND APPENDICES
PAGE NUMBER
FIG'JRE 1 - COUNTY LOCATION OF SITE	F-1
FIGURE 2 - SITE LOCATION MA?	F-2
FIGURE 3 - SITE LAYOUT	F-3
FIGURE 3A - SITE LAYOUT AMD APPROXIMATE SAMPLE LOCATIONS	F-3a
FIGURE 4 -	PRELIMINARY LAYOUT OF INSTALLED VEGETATION	F-4
FIGURE 3 - PRELIMINARY CROSS SECTION OF TIC REMEDY	F-5
FIGURE 6 -	PRELIMINARY LOCATION OF BARRIER WALL	F-6
FIGURE 7 -	LOCATION OF EXISTING GROUNDWATER EXTRACTION WELLS	F-7
TABLE 1 - CONTAMINANTS IN SLUDGE AND SOIL 4 SOIL CLEANUP CRITERIA
(PERFORMANCE STANDARDS) - O.'J. »1 LAGOON AREA - BOFORS-NOBEL SITE
T-l.a,b,c,c
TABLE 2 - CONTAMINANTS IN GROUNDWATER AND GROUNDWATER CLEANUP CRITERIA
(PERFORMANCE STANDARDS) - O.U. #1 LAGOON AREA - BOFORS-NOBEL SITE
T-2.a through 2.f
TABLE 3 - COMPARISON OF SAMPLING AND ANALYSIS; BOFORS-NOBEL
O.U. *1 LAGOON AREA	7-3.a through 3.j
TABLE 4 - RISK IDENTIFIED FOR BOFORS-NOBEL O.U. #1 LAGOON AREA	T-4
TABLE 5 - CAPITAL COSTS REQUIRED FOR TIC REMEDY	T-5.a,c
TA3LE 6 - PRESENT WORTH OF O&M AND MONITORING COSTS FOR TIC REMEDY	7-6.a,b
TABLE 5A - PRESENT WORTH FORMULA	T-5A.1
TA3LE 63 - DISCOUNT OF FUTURE COSTS TO PRESENT VALUE FORMULA	T-6B.1
TA3LE 1 - "TIME WEIGHTED" AVERAGE ANNUAL COST OF MONITORING
AND O&M OF TIC REMEDY
APPENDIX A - DISCUSSION OF ARARs
APPENCIX B - RESPONSIVENESS SUMMARY
7.1
A-l through A-9
8-1 through 3-12
2
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I. INTRODUCTION
The purpose of this document is to explain fundamental changes in
the Remedial Action (RA) selected by the U.S. Environmental
Protection Agency (U.S. EPA) in the Record of Decision (ROD)
signed on September 17, 1990, and amended on July 22, 1992
(collectively, "the ROD as amended") for Operable Unit (O.U.) #1
at the Bofors-Nobel Superfund Site {the "site"). The site is
located in the South 1/2 of Section 32, Township 10 North, Range
15 West, at 5307 Evanston Avenue in Egelston Township, Muskegon
County, Michigan (see Figures 1 and 2). The remedy selected in
the ROD as first amended included excavating and placing
contaminated soils and sludge into an on-site RCRA-type landfill
with a leachate collection system (the "Landfill Remedy"), and
extraction and treatment of contaminated groundwater. It is the
excavation and landfilling portion of the remedy that is being
changed by this second ROD amendment. U.S. EPA, in consultation
with the Michigan Department of Environmental Quality (MDEQ),
received new information regarding a viable alternative remedy
that provides equivalent protection of human health and the
environment and potentially improves cost effectiveness.
A specific remedy proposal (known as the "total in-situ
containment" or "TIC" remedy) was obtained after adoption of the
O.U. SI ROD and ROD Amendment and evaluated by U.S. EPA and MDEQ.
U.S. EPA has concluded that both the Landfill Remedy and the TIC
remedy are appropriate approaches to remediate the site. The TIC
remedy proposal, modified as described in this second ROD
amendment, provides equivalent containment, potentially with
greater cost effectiveness. The TIC remedy also provides for
contaminant reduction through phytoremediation within contained
areas (phytoremediation is the ability for vegetation to provide
treatment by transforming contaminants to more benign
substances), groundwater extraction and treatment, attenuation
and bio-degradation.
Under CERCLA § 117 and Section 300.435(c)(2)(ii) of the National
Contingency Plan (NC?), the lead agency is required to propose an
amendment to the ROD ("ROD Amendment") and allow the public the
opportunity to comment on the proposed changes if differences in
the remedial action alter the basic features of the ROD. A
notice of availability of the administrative record and new
proposed plan for this second ROD Amendment was published in the
Muskegon Chronicle on June 17, 1998, commencing a public comment
period from June 15 through July 17, 1998. In addition, a public
meeting to discuss the new proposed plan was held on June 24,
1998 at the Zgelston Township Hall. U.S. EPA responses to
comments received during this period and from the meeting are
3
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contained in a Responsiveness Summary, attached to this ROD
Amendment as Appendix B.
U.S. EPA has provided an update to the Administrative Record for
the site. This information can be found in greater detail in
site-related documents available for review at:
(1)	Egelston Township Hall
5428 East Apple Avenue
Muskegon, MI 49442,
(2)	Hackley Library
316 West Webster Street
Muskegon, MI 49440, and
(3) U.S. EPA Superfund Division Record Center
77 West Jackson Boulevard - 7th Floor
Chicago, Illinois 60604
The Agencies encourage the public to review these and other
documents to gain a better understanding of the site. All
comments received as a result of this comment period and
summarized and responded to in Appendix B will become part of the
Administrative Record for the site.
I .A.	Site History
This 85 acre site is located 6 miles east of downtown Muskegon ir.
Egelston Township, Muskegon County, Michigan, and includes a
currently operating specialty chemical production facility and 10
abandoned sludge lagoons (see Figure 3). The southern portion of
the site is approximately bounded by Big Black Creek.
Lakeway Chemicals, Inc. ("Lakeway") began producing industrial
chemicals at the site in or around 1960. The plant produced
alcohol-based detergents, saccharin, pesticides, herbicides, and
dye intermediates. Unlined lagoons were used for wastewater and
sludge disposal until approximately 1976. Wastes disposed of in
the lagoons included iron sludge, iron scale, 3,3'—
dichlorobenzidir.e ("3,3'-DCB") and other organic wastes, zinc
oxide waste, wastes generated from spills, calcium sulfate
sludge, and detergent wastes. In the 1970s, the State of
Michigan discovered many of these contaminants within site
groundwater. Releases from the lagoons as well as contaminant
concentrations in the groundwater were high enough to severely
decrease the amount of surface water life within Big Black Creek,
which received the groundwater discharge. In 1976, as a result
of enforcement action by the State of Michigan, extraction wells
4
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were installed by Lakeway to capture and contain contaminated
groundwater before it reached Big Black Creek. This system of
extraction wells has been expanded and continues to operate.
In 1977, Bofors Industries, Inc., a wholly-owned subsidiary of
Bofors America, Inc. ("BAI"), acquired title to the site through
its merger with Lakeway and continued the operations of the
chemical plant. The merged company, Bofors Lakeway, Inc.,
remained a wholly-owned subsidiary of BAI. BAI in turn was a
wholly-owned subsidiary of AB Bofors, which later became Nobel
Industries Sweden AB ("Nobel"). In 1981, Bofors Lakeway, Inc.
changed its name to Bofors Nobel, Inc. ("BNI"). In December
1985, BNI filed a Chapter 11 case in Bankruptcy Court. On
December 6, 1986, BAI transferred ownership of BNI to BAI
Holding, Inc., another wholly-owned subsidiary of Nobel. On
March 25, 1987, certain assets of BNI were sold under the
supervision of the Bankruptcy Court. These assets included the
operating plant which was sold to the current owner/operator,
Lomac, Inc.
The Michigan Department of Natural Resources (now the MDEQ) began
the Remedial Investigation (RI) at the site in March, 1987. The
site was placed on the National Priorities List in March, 1989.
Two operable units were defined at the site. MDEQ, with review
by U.S. EPA, completed the RI for both operable units in the
summer of 1989. MDEQ conducted a Feasibility Study (FS) for
O.U. #1 concurrently with the RI. The FS was completed in June,
1990. The first operable unit addresses contaminated sludge and
soils in the abandoned lagoon area and the groundwater extraction
and treatment system. As defined in the ROD, the second operable
unit addressed overall groundwater cleanup standards and
contaminated soils in the plant area. As part of the fundamental
remedy change, this second ROD Amendment for O.U. #1 will
establish site wide groundwater remediation goals and remove them
from the scope of O.U. #2.
To address soils contamination within O.U. #2, Lomac will submit
an Interim Remedial Action Plan to the MDEQ for the plant area
soils during Lomac's continued operations. The Interim Remedial
Action Plan will be reviewed and approved by the MDEQ in
consultation with the U.S. EPA. The U.S. EPA will issue a final
O.U. #2 ROD to address a final cleanup action to be implemented
at the time when manufacturing in the plant area ceases.
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I.B.
Summary of Site Con^f'«""*,«
1.	Lagoon Area Soils and Sludge
Table 1 lists contaminants discovered in soil and sludge in the
lagoon area of O.U. #1 based on the results of sludge and soil
sampling that occurred for the RI and shown in the original 1990
ROD. The compounds aniline, azobenzene, benzene, benzidine,
3,3'-dichlorobenzidine, and methylene chloride have been
identified as contaminants of concern in the baseline risk
assessment for the site. Table 1 includes clean up criteria
under Part 201 (Environmental Remediation) of Michigan Natural
Resources and Environmental Protection Act (NREPA), 1994 PA 451,
as amended ("Part 201") for human direct contact with surface
soil in an industrial exposure scenario. These are the levels
that must be met and maintained by the O.U. #1 lagoon area cover
to ensure that there is no unacceptable human health risk to an
individual working on the site within a controlled work
environment. Part 201 soil cleanup criteria for protection of
groundwater are included in Table 1. These levels must be
reached as one of the conditions necessary to discontinue the
containment component of the TIC remedy. These cleanup criteria
will ensure that groundwater is protected under a reasonable
future land use scenario and for discharges to surface water in
the event that containment and institutional controls are no
longer maintained. If these criteria and the groundwater
criteria described in Section I.B.2 of this ROD Amendment are met
and maintained at all points of compliance, containment and the
associated institutional controls will no longer be necessary.
Threats posed by contamination through human exposure pathways
are discussed in Section I.C and discussion of remedy cleanup
goals and criteria is included in Section I.E of this ROD
Amendment.
2.	Site Groundwater
Table 2 lists the maximum concentration of contaminants found in
groundwater during sampling within the 1990 RI/FS and the
Remedial Design for the Landfill Remedy. Table 2 includes clean
up criteria under Part 201 (Environmental Remediation) of
Michigan Natural Resources and Environmental Protection Act
(NREPA), 1994 PA 451, as amended ("Part 201") for human
consumption of groundwater on-site under future reasonable land
use scenarios. An ultimate goal of the TIC remedy is to achieve
these criteria or Federal maximum contaminant levels (MCLs),
whichever are more stringent. For those listed contaminants that
have Federal MCLs, the Part 201 cleanup criterion is the same as
the MCL for that contaminant. Within the O.U. il area, the clean
6
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up criteria for future industrial land use are applicable unless
appropriate deed restrictions can not be obtained, in which case
criteria for future residential land use would apply. To achieve
successful completion, this second amended remedy must ensure
that these criteria are met and maintained throughout the
affected groundwater area. Unless and until final groundwater
cleanup criteria are met, contaminated groundwater will be
contained by use of the barrier wall and groundwater extraction
to ensure that the remedy protects Big Black Creek. To ensure
that the remedy protects Big Black Creek, Table 2 lists
Groundwater - Surface Water Interface (GSI) criteria that
represent contaminant concentrations in groundwater which, if not
exceeded, are protective of a surface water body that receives
such contaminated groundwater discharge. An ultimate goal of the
TIC remedy is to achieve these criteria to insure that no
unacceptable discharge to surface water occurs in the event that
containment and institutional controls are no longer maintained.
Threats posed by contamination through human exposure pathways
are discussed in Section I.C and discussion of remedy cleanup
goals is included in Section I.E of this ROD Amendment.
3.	Other Potentially Affacted Madia
The 1990 ROD identified that there was a potential for
contaminants to be released from lagoon area sludge and soil by
particulate or volatile emissions. Air sampling both up gradient
and down gradient of the site conducted during the RI and later
during RD of the Landfill Remedy indicated that, although there
were some detections of contaminants in the air, it was not
attributable to lagoon area sludge or soil. Documents containing
both RI and RD results have been included and are available for
review in the Administrative Record for the site.
As noted in the 1990 ROD, the primary route of contaminant
release to Big Black Creek appears to be from discharge of
contaminated groundwater to surface water. Because of the
operation of the groundwater extraction wells, sampling and
analysis conducted during the RI did not identify any concern
with contamination in Big Black Creek surface water or sediment.
In addition, the requirement for and continued operation of a
groundwater containment, extraction, and treatment system ensures
interception of contaminated groundwater before reaching Big
Black Creek.
4.	Current Status of Site Contaminants
To indicate the current status of contaminants in the lagoon
area, Table 3 provides a limited comparison of information in
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Tables 1 and 2 with recent (mid-1997) sampling and analysis of
site groundwater and soil. Table 3 suggests that contamination
in some areas of the O.U. #1 lagoon area (which has not been
disturbed since the mid-1970s) has somewhat diminished through
natural means. There still exists, however, contamination at
high enough concentrations to require immobilization of, and
prevention of contact with, this sludge and soil. Also, control
of contaminated groundwater is necessary by containment,
extraction, and treatment before discharge. When compared with
cleanup criteria listed in Table 1 and 2, contaminant
concentrations for some contaminants continue to exceed State of
Michigan cleanup criteria. Design and construction of the TIC
remedy will be based on the cleanup criteria presented in
Tables 1 and 2 and specific performance standards.
I.C.	Qi^nwma i-y pf Site Rj«k»
Table 4 lists the risk identified in the 1990 ROD associated with
the contaminants found in the O.U. #1 lagoon area. To assess any
possible reduction since 1990 in contaminant concentrations and
risk, U.S. EPA, with consultation by MDEQ and the PRPs,
investigated the risk currently present in the lagoon area using
current site conditions. It has been confirmed that there still
remains significant risk at the site that requires Remedial
Action. Documents summarizing this risk confirmation have been
included in the Administrative Record for the site.
Risk associated with ingestion of and/or contact with surface
water cited in the 1990 ROD ranged from 1 x 1G": to 3.4 x 10"?,
depending upon exposure to contaminated groundwater that
discharged to Big Black Creek. Risk associated with surface
water pathways are being addressed in this ROD Amendment by the
requirement for compliance with State of Michigan GSI cleanup
criteria, as discussed in Section I.B.2 and I.E of this ROD
Amendment.
When the Hazard Index (HI) is greater than 1, there is a
potential for health problems such as damage to vital organs,
birth defects, and anemia and other blood disorders. A lxlO"4
cancer risk value corresponds to a 1 in 1,000,000 chance that an
individual develops cancer as a result of exposure to these
concentrations of contaminants over a period of 70 years.
Similarly, 10"5 corresponds to a 1 in 100,000 chance, 1x10"', 1 in
10,000, and so on.
With implementation of deed restrictions, this ROD Amendment
requires a level of protectiveness for the O.U. #1 lagoon areas
and site groundwater not discharging to Big Black Creek
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consistent with a future industrial land use scenario. Current
zoning of the site, deed restrictions, and site security will
increase the likelihood that future exposure to the site will
only be through a controlled industrial scenario, in accordance
with reasonable future land use fir the site. Fundamental
components of the TIC remedy include a lagoon area cover that
must ensure prevention of contact with contaminated soil and
sludge and associated emissions, a groundwater containment and
extraction system that ensures prevention of contaminated
groundwater from entering the Big Black Creek system, and a long
term commitment to ensure that operation and maintenance of these
mitigative measures continues for a time period adequate to
ensure all Remedial Objectives are met and maintained as long as
necessary.
I.D.	Raaadv Daciainrm i TmpifnUtion of Original Rraedv
The C.U. #1 ROD, as originally amended, selected a remedy which
called for groundwater extraction and treatment and the
excavation and landfilling of contaminated lagoon area soils and
sludge (Landfill Remedy). This remedy provided for:
groundwater containment, through the use of extraction
wells, to prevent discharge of contaminated groundwater to
Big Black Creek;
reduction of contaminants through groundwater treatment; and
secure containment of the contaminated soils and sludge in
an on-site RCRA type landfill.
U.S. EPA intended for the existing extraction system to continue
containing the contaminated groundwater (preventing off-site
migration of the contaminants) and extracting groundwater to
reduce the concentrations of contaminants until acceptable levels
were reached. The O.U. #1 ROD, as amended, also required the
existing extraction system to be upgraded, and required the
construction of a plant to treat the extracted groundwater prior
to discharge into Big Black Creek.
As part of the remedy for O.U. #1, a groundwater treatment plant
(GWTP) was designed by the U.S. Army Corps of Engineers (USACE)
from March 1991 to May 1992. Construction of the GWTP took place
from October 1992 to June 1994 and the GWTP began treating
contaminated groundwater in September 1994. The capacity of the
GWTP was designed to treat the maximum possible flow rate
expected from the Landfill Remedy. The GWTP discharges to Big
Black Creek, and is successful in meeting surface water discharge
standards established by the MDEQ.
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The Remedial Design (RD) for the landfill to contain soils and
sludge of O.U. #1, including hot spots of O.U. #2, was completed
by USACE under agreement with the U.S. EPA. In March 1993, the
Landfill Remedy RD was approved by U.S. EPA. U.S. EPA delayed
landfill construction in order to re-evaluate O.U. #1 remediation
goals and consider the TIC remedy made available after the
landfill design documents were completed.
On July 16, 1996, U.S. EPA (with the concurrence of the State)
issued a remedy re-evaluation document, notice was published in a
major local newspaper of general circulation, and opportunity for
written comments was provided until August 13, 1996. Following
issuance of the remedy re-evaluation document, U.S. EPA, the
State of Michigan, and PRPs identified for the site continued
technical discussions, which then led to refinements of the TIC
remedy as described here and in documents located in the
Administrative Record. Re-evaluation was performed primarily
because: (1) since the time of U.S. EPA's remedy decision, more
information had been developed on barrier wall technology (which
is included as part of the TIC remedy proposal); ana (2) the
timing of U.S. EPA's identification of PRPs had not allowed them
a full opportunity to comment on the prior remedy decisions.
In the re-evaluation document, U.S. EPA established that the TIC
remedy provided an equivalent approach if implementability and
long-term reliability and effectiveness issues could be
addressed. To that end, between July ana September 1997 the PRP
Group researched and investigated the site and refined its TIC
proposal to address these issues. On September 9, 1997, the PR?
Group issued a Technical Memorandum that addresses
implementabi1ity issues and (along with the necessary legal
agreement) provides the required modifications and long term
commitment for a TIC remedy. These documents provide the basis
for this ROD Amendment.
I.E	Remady Goals
Table 1 includes criteria for human direct contact with surface
soil for a future industrial land use scenario. These are the
levels that must be met and maintained to ensure that there are
no unacceptable human health risks to an individual working on
the site within a controlled work environment or otherwise
present on the site. These direct contact criteria will be met
by the O.U. #1 lagoon area cover that will be installed as part
of the TIC remedy and is necessary for the containment of wastes
in place.
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Table 1 lists soil cleanup criteria intended to ensure that
contaminants in soil will not leach to groundwater at
unacceptable levels. These criteria are the level of
contamination in soil that prevents unacceptable levels of
groundwater contamination for a reasonable future land use
scenario. Table 1 lists soil cleanup criteria goals for both
future residential and industrial land use scenarios. Successful
achievement of these criteria and the appropriate Part 201
groundwater cleanup criteria is necessary to eliminate the need
for maintenance of containment- One ultimate goal of groundwater
extraction and the treatment provided by this remedy is the
reduction of the on-site contaminants listed in Table 1 to
cleanup criteria associated with a future industrial land use
scenario, or, if appropriate deed restrictions can not be
obtained, a future residential land use scenario. Another goal
of the groundwater extraction and the treatment provided by this
remedy is the reduction of contamination to those cleanup
criteria protective of surface water.
Table 2 lists GSI criteria that must be met and maintained for
the containment component of the TIC remedy to ensure protection
of Big Black Creek. Table 2 also lists cleanup criteria for
groundwater that are the goals of the combination of the
treatment provided by phytoremediation and the groundwater
extraction and treatment system(s). Table 2 lists groundwater
cleanup criteria for both residential and industrial future land
use scenarios. Specifically, one ultimate cleanup goal is the
reduction of contaminants throughout affected groundwater to
these criteria or Federal maximum contaminant levels (MCLs),
whichever are more stringent. Achievement of GSI standards will
also accomplish another ultimate goal, the reduction of
contaminants to cleanup criteria protective of surface water.
For those listed contaminants that have Federal MCLs, the Part
201 cleanup criterion is the same as the MCL for that
contaminant. These cleanup goals are the levels acceptable for
human consumption within a future industrial land use scenario,
or, if appropriate deed restrictions can not be obtained, to
levels acceptable for human consumption within a future
residential land use scenario. If these soil and groundwater
cleanup goals are met and maintained the containment portion of
the remedy would no longer be necessary.
This TIC remedy provides for containment of sludge, soils, and
groundwater as the base component to immediately address the
threat from contamination in the lagoon area and in site wide
groundwater. In addition to containment, the second amended
remedy provides for reduction of soil and groundwater
contamination levels through treatment provided by
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phytoremediation, groundwater extraction and treatment, and
attenuation and bio-degradation. If treatment and other remedy
components reduce contamination in sludge and soils, and
groundwater to cleanup goals, then the containment provided by
the TIC remedy will no longer be necessary.
I.P.	Remedial Action Obiactivea
The Remedial Action Objectives (RAOs) for this remedy to ensure
containment are as follows:
1.	Containment of lagoon sludge and soils to prevent on-site1
exposure to hazardous substances at concentrations that pose
an unacceptable risk to human receptors under industrial
land use scenarios via the following routes of exposure:
(a) direct contact; (b) inhalation from volatization to
indoor air; (c) inhalation from volatization to ambient air;
(d) drinking water use of aquifer; (e) groundwater contact;
and (f) surface water contact. Containment of lagoon sludge
and soils to prevent on-site exposure to hazardous
substances at concentrations that pose an unacceptable risk
to environmental receptors via the following routes of
exposure and migration pathways: (a) contact with
contaminants present in surface soils, plants, water or air
on-site; (b) groundwater impacts on surface water; and (c)
soil runoff impacts on surface water.
2.	Containment of lagoon sludge and soils to prevent off-site
migration of contaminants to air, soil or groundwater at
concentrations that would pose an unacceptable risk to human
and/or environmental receptors; and
3.	Containment of groundwater to prevent migration of
contaminants at concentrations that would pose an
unacceptable risk to human and/or environmental receptors
off-site including to Big Black Creek and to the on-site
wetlands between Big Black Creek and the barrier wall.
In order to ensure these objectives are met and maintained, the
remedy will include:
1	Tor purposes of this ROD Amendment, 'on-site' means all property within
the former Bofors-Nobel property boundaries except for any property to the
South of the northern shore of Big Black Creek. For purposes of this ROD
Amendment, 'off-site' means any property beyond the former 3ofors-Nobel
property boundaries to the North, East and West, and beyond the northern shore
of Big Black Creek co the South.
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measurement of the effectiveness of containment systems
including measurement of the reduction in contaminant
concentrations; and
operation and maintenance of containment systems until such
time as it is determined that continued operation of
containment is unnecessary.
This TIC remedy will comply with all State and Federal Applicable
or Relevant and Appropriate Requirements (ARARs).
II. R3EASOHS TOR ISSUING THE ROD AMENDMENT - Supporting
Information for th« Fon^ffrTrt'T- Chanq»
The first amended ROD concluded that a thermal treatment remedy
for O.U.il was not cost effective due to the excessive volume of
soil and sludge requiring remediation. That ROD estimated that
the combined present worth of capital and O&M for thermal
treatment of soil and sludge and on-site landfilling was
approximately $ 71,000,000. The first ROD Amendment provided a
more accurate excavation volume and increased this estimate to
approximately $ 221,000,000 (net present wor-h of capital and
O&M). That ROD Amendment further concluded chat containment of
contaminated soil using a landfill would provide a reduction of
risk equivalent to that of treatment at a capital cost of
approximately 3 46,000,000 (not including groundwater extraction
and treatment). The TIC remedy established by this ROD Amendment
will provide containment and reduction of risk equivalent to that
of the Landfill Remedy, but at a reduced net present worth cost
range of approximately $ 10,000,000 to $ 40,000,000 (including a
revised groundwater extraction and treatment system).
The Landfill Remedy intended to address site contamination by
first isolating the contamination source (soils and sludge) from
site groundwater and then physically removing contaminated
groundwater by pumping and treating. By isolating source
material and extracting and treating contaminated groundwater,
the Landfill Remedy could ultimately achieve acceptable
groundwater cleanup limits. In the Feasibility Study, below
grade barrier wall remedies were considered unacceptable because
source material remains in contact with the groundwater resulting
in the potential need for perpetual groundwater extraction. In
addition, landfill technology was selected instead of a barrier
wall due to the uncertainties regarding containment effectiveness
of barrier walls.
In its re-evaluation, U.S. EPA concluded that both the Landfill
Remedy and the TIC remedy (if properly modified) provide
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equivalent degrees of risk reduction if adequate long-term
assurances are in place for the TIC. The TIC remedy, however,
provides the greatest potential for cost effectiveness and
contains treatment components that allow for site remediation by
more natural mechanisms and may allow for potential further
treatment. With the extensive excavation work required, the
Landfill Remedy poses more potential for short term risks than
the TIC remedy (approximately 50,000 cubic yards would be
excavated and/or shifted for the TIC, compared to roughly 800,000
cubic yards for the landfill) .. The TIC remedy presents a
scenario whereby Remedial Action Objectives may be reached
through more natural means at a potentially significant cost
savings. The TIC also offers treatment which may eventually
permit the containment portion of the remedy to be discontinued
if compliance with all cleanup goals at the site is demonstrated.
The presence of the existing groundwater extraction, containment,
and treatment system that has already proven itself through 20
years of operation affords the opportunity for implementation of
this amended remedy. It also allows for the installation and
maturation of vegetative remedy components without increasing
human risk or threatening Big Black Creek. In the event of
failure of the barrier wall portion of the remedy, re-use of
existing wells or installation of new extraction wells can be
easily implemented.
The TIC remedy represents a variation cn, and an expansion of,
the slurry wall containment option that was evaluated in the FS .
Since that time, experience with barrier wall construction has
increased, and, consequently, some uncertainties have decreased.
U.S. EPA agreed to re-evaluate the remedy to consider new
information regarding slurry wall technology not available during
the FS. The TIC remedy is similar in principle to those slurry
wall options presented in the FS, but has been modified to
include other components.
The use of a natural vegetative system as an additional part of
the remedy will also assist in the immobilization of
contaminants, and secondarily may synthesize or trap groundwater
contaminants either through internal processing or natural
uptake. It is anticipated that the vegetative portion of the TIC
remedy will have a root mass below the soil layer containing the
highest contaminant concentrations (see Figure 5). This should
serve as a natural supplement to the containment cell created by
the constructed barrier wall and O.U. #1 lagoon area cover.
Scientific literature suggests that certain vegetative species
are able to survive within contaminated areas. Water will move
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through the vegetation by natural osmotic mechanisms assisting in
hydrologic control of the groundwater and providing an
enhancement to the barrier wall. Vegetation promotes microbial
activity, enhancing contaminant attenuation through biological
mechanisms. The amount of biofouling observed in the on site
extraction wells indicates that biological activity is taking
place at the site.
III. DESCRIPTION OF THE FUNDAMENTAL REMEDY CHANGE
Total In-Situ Containaant (TJ"<7) P^r-tdy
The fundamental change to the O.U. #1 remedy is the method by
which containment of contaminated O.U. #1 lagoon area soils,
sludge, and groundwater is achieved, and the addition of the
treatment component provided by phytoremediation. Current
updates to the Administrative Record include summary documents
presenting the characteristics of the TIC remedy. Figures 4,5
and 6 depict components of this amended remedy. The TIC remedy-
will consist of the following minimum components:
A below grade barrier wall to a depth of approximately 75 to
100 feet around areas of soil contamination, which may be
keyed into a confining layer.
A cover designed to prevent unacceptable exposure to
contaminated soils and sludge and any associated emissions.
Installation of vegetative species to assist in
immobilization of soils and provide enhancement of natural
mechanisms for reduction of contaminant concentrations.
Containment and collection of contaminated groundwater,
using the barrier wall and other acceptable collection
methods, including extraction wells. Construction activity
for the barrier wall, cover, vegetation installation, and
groundwater containment/collection will include restoration
of wetlands that may be disturbed by the construction, and
may create new wetland areas.
Appropriate treatment of collected and extracted groundwater
at the GWTP, or an alternate facility that provides an
equivalent level of effectiveness.
Monitoring programs to assess the containment effectiveness
of the barrier wall and groundwater collection and
extraction system, and to assess the reduction of
contaminant concentrations in soil, sludge and groundwater.
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Establishing appropriate institutional controls (such as
deed restrictions) to preclude unacceptable construction and
use of wells in areas where contamination remains, and tc
ensure that future land use is compatible with the remedy.
Long term operation and maintenance (O&M) to ensure the
effectiveness of containment and groundwater extraction
within areas of known contamination, including newly
vegetated areas.
Contingent Remedial Actions in the event remedy components
fail to meet and maintain performance standards.
III.A	Barrier Wall
To prevent untreated site groundwater from discharging directly
to Big Black Creek or from expanding laterally beyond its present
boundaries, a barrier wall will be installed to a depth that will
ensure retardation of lateral movement of contaminated site
groundwater. The barrier wall may extend to an approximate depth
between 75 and 100 feet, depending on specific depths of the
underlying clay layer. The estimated length of the slurry wall
is approximately 2700 linear feet which is the approximate total
of the southern, eastern, and western perimeters of the iagoon
area. The intent of this barrier wall is mainly to contain the
maximum possible volume of contaminated soils and sludge (the
waste mass would remain in place) and provide lateral retardation
of groundwater flow. The barrier wall will also assist in
capture and/or containment of groundwater contamination located
to the north of the lagoon area, including plant site areas. The
specific composition, location, depth and other details of the
barrier wall will be defined during the Remedial Design. The
wall may be constructed of chemically compatible, low
permeability material, possibly consisting of a mixture of
bentonite clay, native soils, and water, or, for some portions of
the wall, grouted steel sheet piling, or a combination of both.
Alternative materials and/or construction techniques may be
investigated and identified in the Remedial Design.
III.B	Surface Area Cleanup. Civil and Earthwork
Sludge within the O.U. #1 lagoon areas will be excavated, graded,
or relocated in nearby areas and/or stabilized if necessary to
provide a sound foundation for placement of cover material. Any
debris in the O.U. §1 lagoon area will either be consolidated
under the cover, or characterized and disposed of off-site in
accordance with all Federal and State ARARs. If necessary,
earthwork may include targeted limited excavation of portions of
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the lagoon area to assist in the installation and/or operation of
the barrier wall, lagoon area cover, groundwater containment and
extraction and vegetative treatment portions cf the TIC remedy.
Details of the scope of this portion of the remedy will be
developed during the Remedial De5lgn.
III.C	P.P. #1 Lagoon ACow
As part of this remedy, the O.U. #1 lagoon area will be covered
to eliminate risks associated with- exposure to O.U. #1 soils and
sludge, including any risks associated with possible emission of
contaminants from soil and sludge. The O.U. #1 lagoon area cover
will be constructed over the soil and sludge contamination that
constitutes unacceptable risk through relevant exposure routes.
The cover will reduce, but not eliminate, infiltration of
precipitation through the waste mass. The vegetative component
of this remedy requires that the area cover be sufficiently
permeable to allow for plant growth. The vegetation will reduce
erosion, stabilize the cover, and enhance the aesthetics of the
area. Design and construction details for the O.U. #1 lagoon
area cover will be developed during the RD but will be based on
elimination of exposure pathways that may result in unacceptable
risk in accordance with ARARs.
Use of a permeable cover will allow precipitation to percolate
through the waste mass and may provide some flushing of
contaminants from contaminated soils and sludge into groundwater
underneath. Infiltration will be allowed because of the expected
groundwater capture provided by the barrier wall and extraction.
This flushing of contaminants into ground water will occur while
the treatment provided by phytoremediation is occurring and the
vegetative components of the TIC remedy are maturing.
Contaminants that leach into groundwater would be extracted and
treated before discharge to surface water. Over the past twenty
years, this type of containment has been successful at this site.
The TIC remedy, including any necessary Contingent Remedial
Actions, is expected to comply with all substantive requirements
of the identified State and Federal ARARs. Wastes that were
deposited in the lagoons are by-products of specialty chemical
production that occurred on site before the enactment of RCRA.
U.S. EPA determined that RCRA and State landfill cap standards
were relevant and appropriate requirements for the Landfill
Remedy. Because the TIC remedy has different objectives,
including movement and capture of groundwater within the source
area, and treatment of waste using phytoremediation, RCRA and
State landfill cap standards are not ARARs for the lagoon area
cover portion of the TIC remedy. In the event a TIC cover
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upgrade is later required as a Contingent Remedial Action, RCRA
and Part 111 of NREPA may be ARARs for that upgrade. These
standards would be ARARs for any excavation activity. In the
event that surface cleanup phase of the remedy requires some
excavation and off-site disposal, the excavated material shall be
characterized, manifested, and disposed of in accordance with
RCRA and parallel State requirements.
Ill .D	Vegetation Installation and Wetland Enhancement
As an enhancement to the groundwater, soil, and sludge
containment provided by the barrier wall, various vegetative
species will be planted within the contained areas of the TIC.
These plant species will immobilize contaminants, serve to
enhance groundwater containment, and provide treatment by
phytoremediation. Available literature indicates that plan-
species have the capability to transform organic contaminants to
more benign compounds. The literature further documents that
plant roots provide a medium under which microorganisms can
flourish, and natural destruction of organic contaminants can
occur. As part of the TIC remedy, degradation of the sludge and
contaminated soils will be assessed and studies regarding
phytoremediation will be incorporated as appropriate into the
Remedial Design. Literature suggests that for the nature and
extent of contamination present at the site, treatment mechanisms
provided by the remedy may reduce site contamination to levels
that allow termination of the TIC remedy within an approximate
time of 30 to 70 years, with the most appreciable reduction
occurring in the initial 20 years. In addition, the biological
fouling of existing extraction wells suggests that there is
naturally occurring microbial activity on groundwater
contaminants. These combined mechanisms contribute to the
reduction of contaminants in both groundwater and soils.
Figures 4 and 5 depict the proposed installation layout for TIC
remedy vegetation. Four distinct vegetation areas (noted as
Areas A,B,C,D) have been proposed. Vegetation will be monitored
as needed to assess its success in immobilizing and fostering
destruction of contamination and to assure that contamination
uptake into the vegetation does not create unacceptable risks.
III.E Groundwater Containment. Extraction, and Treatment
A network of extraction wells similar to the current system would
have provided containment of contaminated site groundwater for
the Landfill Remedy. In the TIC remedy, groundwater containment
will be provided primarily by the barrier wall, which will re-
direct natural groundwater flow towards a vegetated area
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constructed within the barrier wall boundaries. The groundwater
will discharge to the surface in the wetland where it is
anticipated that the contaminants of concern will bind to the
hurr.ic soils in the wetland, undergo photolysis or biodegrade.
The surface water from this vegetated area will flow to a central
weir and sump collection point. The collected water will be
sampled and analyzed before determining its disposition. If
contaminants in collected water meet appropriate standards, it
may be discharged to the creek or the existing wetland outside
the barrier wall. The discharge system may be designed such that
water that meets appropriate standards is recycled back into
vegetated or wetland areas within the barrier wall. Collection,
extraction, treatment, and discharge of any water will comply
with all ARARs.
If groundwater contaminants exceed standards, the collected
groundwater will be directed towards a treatment facility.
Extracted groundwater may be treated, as necessary, at the
existing groundwater treatment plant. The feasibility of
alternate groundwater treatment facilities or further
optimization of the existing GWTP will be investigated during the
Remedial Design.
In the event the vegetation and the barrier wall can not provide
adequate hydrologic control of contaminated groundwater the
extraction system may be enhanced. The enhanced groundwater
extraction system may include the use of existing extraction
wells inside the barrier wall and/or the addition of new
extraction wells inside and/or outside of the barrier wall as
needed to ensure containment.
To control contaminated groundwater that will remain outside the
barrier wall, a groundwater extraction system will be installed
prior to or concurrent with construction of the barrier wall.
This extraction system will be operated as necessary to prevent
discharge of contaminated groundwater exceeding performance
standards to Big Black Creek and adjacent wetlands before,
during, and after TIC remedy construction activities.
IIZ.F	Monitoring Programs
In order to evaluate and confirm that the performance of the TIC
remedy remains protective of human health and the environment, a
monitoring program for the sampling and analysis of O.U. #1
groundwater will be developed during the Remedial Design.
Groundwater monitoring will need to demonstrate that the remedy
successfully prevents migration of contaminants at concentrations
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that would pose an unacceptable risk to human and/or
environmental receptors off-site or to 3ig Black Creek and to the
wetlands between Big Black Creek and the barrier wall. The
points of compliance will be established at Big Black Creek and
at the property boundary. This will be accomplished through the
use of a combination of new and existing monitoring wells,
located within and outside the barrier wall. Sentinel wells will
be installed between the southern end of the barrier wall and the
Creek, and along the sides of the barrier wall to identify any
contamination at levels above cleanup standards that indicate any
failure or potential failure to satisfy Remedial Action
Objectives including compliance with ARARs. The degree,
frequency, procedures, and scope of the groundwater monitoring
program(s), including location and construction details of any
new wells, and the long term requirements for groundwater
monitoring, will be developed during the TIC Remedial Design.
This groundwater monitoring will be in addition to sampling and
analysis that will be required for development of the TIC
Remedial Design and groundwater monitoring necessary to assess
progress toward achievement of groundwater cleanup goals.
Sampling and analysis of O.U. #1 soils and sludge will be
required to determine if final cleanup goals are achieved or to
determine the presence and degree of the reduction in contaminant
concentrations. The necessity, degree, frequency, procedures,
and scope of any soil and sludge monitoring program(s), and long
term requirements for soils and sludge monitoring, will be
determined during the TIC Remedial Design.
To determine the effect of the vegetative components of the TIC
remedy on the new and existing ecosystem present in O.U. #1
areas, some degree of monitoring of plant and animal life forms
may be required. It is anticipated that there may be a certain
amount of uptake and retention of contaminants by vegetation
which may affect species potentially using the vegetation for
food and inhabitation. Available phytoremediation laboratory and
field information and the recommendations of reviewing ecologists
suggests that, if TIC remedy vegetation absorbs contamination, it
will be stored within the wood and/or transformed by plant
metabolic processes. Vegetative species planted as part of this
remedy may internally synthesize contaminant compounds, which
might necessitate sampling such species to monitor these changes.
Such monitoring may be a requirement for compliance with ARARs
associated with protection of wildlife and ecology that are
identified for the site and summarized in Appendix A to this ROD
Amendment. The necessity, degree, frequency, procedures, and
scope of any ecological and/or biological monitoring program(s),
will be determined during the TIC Remedial Design and will be
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developed in concert with other monitoring programs required for
this remedy.
Air monitoring will be required during construction of the TIC
remedy to ensure compliance with Federal and State ARARs.
Monitoring may entail continuous atmospheric sampling and
analysis to ensure that no particulate or vapor emissions at
unacceptable levels travel beyond the site perimeter. For safety
purposes, local air monitoring at the point of work will be
performed for the safety of both project workers and nearby
passers by, and will serve as a preliminary indicator before
reaching site perimeter sampling points.
In the event it is determined that alternate facilities are
utilized for groundwater treatment, any new groundwater treatment
facility may require regular air monitoring for discharges. The
existing GWTP has already been assessed for such requirements and
currently follows procedures as administered by the State. The
necessity, degree, frequency, procedures, and scope of any air
monitoring program(s), will be determined during the TIC Remedial
Design, and will be developed in concert with other monitoring
programs required for this remedy.
State of Michigan GSI criteria will be used to determine whether
the remedy protects Big Black Creek. Surface water and sediment
were not identified as a concern in the 1990 ROD provided capture
of contaminated site groundwater continues, and/or exposure to
contaminated site groundwater discharging to Big Black Creek is
prevented. In order to ensure compliance with these GSI
criteria, and as part of required State of Michigan surface water
protection procedures, it may be necessary to perform sampling
and analysis of Big Black Creek water and sediment. The
necessity, degree, frequency, procedures, and scope of any
surface water and/or sediment monitoring program(s), will be
determined during the TIC Remedial Design, and will be developed
in concert with other monitoring programs required for this
remedy.
III.6	Daad Restrictions
As part of the Remedial Action, institutional controls and deed
restrictions will be implemented on the O.U. #1 area of the site.
At a minimum, such deed restrictions and institutional controls
shall include a restriction on the use of contaminated groundwater
or soil, prohibition of any activities which may damage any
remedial action component or otherwise impair the effectiveness of
any work to be performed except with prior written approval of the
U.S. EPA. The reasonably anticipated future land use of the site
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is industrial. Current zoning established by Egelston Township
requires that the site can only be used for industrial use.
Implementation of deed restrictions will insure that use of the
site property remains industrial. Land use restrictions or deed
restrictions can only be implemented by a person who controls a
property or a property owner. Water use restrictions will be
implemented with these deed restrictions, so that contact with
site related contamination would be restricted as a supplement to
physical constraints. Provision has been made in the cost
estimate included in this ROD Amendment for the implementation of
deed restrictions.
Ill .H Conting** +•	Actions
It is anticipated that a phased approach for TIC remedy
construction will be implemented. This approach will allow the
different phases of the remedy to be installed, monitored and its
effectiveness measured. As part of the RD, a series of Contingent
Remedial Actions (CRAs) will be refined and will be implemented
subsequent to initial construction activity if any component of
the TIC remedy is ineffective.
In the event performance standards (which are included as Tables 1
ana 2) are not met, the cause(s) of the failure shall be
identified and CRAs shall be implemented. The CRAs that may be
implemented in the event of a performance standard exceedance or
potential exceedance include the following: (1) expedited
monitoring to confirm the characteristics and extent of an
exceedance; (2) upgrade and/or repair of the groundwater
extraction system (including installation of new extraction well
if necessary) within or down-gradient of the barrier wall; (3)
implementing alternate or additional groundwater treatment
technology or using an alternate facility; (4) supplemental
groundwater extraction and treatment until such time that CRAs are
not needed; (5) re-planting of vegetation (including introduction
of additional nutrients and/or provision for replacement of dead
vegetation, or selection of alternate species); (6) repair or
upgrade of the protectiveness and/or impermeability of the O.U. #1
lagoon area cover; (7) repair or replacement of the barrier wall;
and (9) excavation and disposal of targeted contaminated material.
Excavation would only be implemented if it were determined that
this remedy could not securely contain the targeted wastes in
place, or if excavation of limited areas will produce or expedite
final achievement of all performance standards.
In addition, if field visual inspections show adverse ecological
effects on ecological assessment endpoints indicative of
unacceptable acute toxic effects or unacceptable observable
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chronic effects; or if field measurement shows adverse ecological
effects on ecological assessment endpoints indicative of other
unacceptable chronic effects; then contingent ecological
investigations will be implemented which will include an analysis
of the cause. Appropriate CRAs for these adverse ecological
effects (such as upgrade of the O.CJ. #1 lagoon area cover or
enhanced access restrictions and/or engineered controls) could
then be developed and implemented.
Details of identification and implementation of CRAs shall be
developed and included in the Remedial Design.
Ill. I	Operation and Maint«pf"
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5.	Regular inspections of the O.U. #1 lagoon area cover. This
is necessary to assure the protectiveness of the cover and
prevent disturbance and exposure to contaminated soils
remaining underneath the cover and to assess whether adverse
ecological effects are occurring at the site.
6.	Based on vegetative development and the propensity of
contaminant uptake, a potential O&M task may include
harvesting, proper off-site disposal, and re-planting of
vegetation. The necessity of this O&M task is highly
dependent on whether contaminants are synthesized or
accumulated by vegetative species, and the degree and nature
of contaminant fate within the plant species. The necessity
of this O&M task will be determined after the TIC remedy is
installed and allowed to operate for a reasonable time period
and would be based on assessments of the remedy's overall
effectiveness. Serious adverse ecological effects that can
not be remedied through O&M measures will require Contingent
Remedial Actions of the same sort required for failure to
meet standards for soil.
7. Upkeep of any additional extraction system installed to
augment groundwater containment provided by the barrier wall.
This O&M component may require such tasks as repair,
cleaning, and replacement of extraction wells, both existing
and installed as part of the TIC remedy.
9. Upkeep of any new treatment facility, including general
housekeeping, monitoring for process efficiency, repair,
replacement, and preventive maintenance of process equipment
such as pumps, tanks, and contaminant treatment components.
XIX.J	Site Remediation Goals and Operable Onifc J£2
The previous ROD Amendment deferred site-wide groundwater
remediation goals for the ROD that is required for O.U. #2.
Issuance of a ROD for O.U. #2 has been delayed in order to allow
for re-evaluation of the decisions regarding O.U. #1 lagoon area
contamination. O.U. #2 was delineated to segregate soil and
groundwater contamination existing underneath the chemical
production area of the site. The contamination in O.U. #2 soils
is a potential source of groundwater contamination. The barrier
wall, however, will also contain this contaminated groundwater.
In order to achieve site wide remediation goals, the O.U. fr2 soils
may eventually need to be removed or otherwise addressed by other
remediation technology. Complete delineation, evaluation and
remediation of O.U. t2 soils, however, can not occur until the
Lomac production activity is discontinued and buildings are
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removed. U.S. EPA will issue a final ROD for the O.U. #2 area
that will define a final remedy to be implemented after
production activity in the O.U. #2 area ceases.
The final O.U. #2 ROD will addres" the process for evaluating
further data that may be required with respect to:
contamination in and under on-site buildings in O.U. #2
areas;
residual contamination on site in O.U. #2 areas;
the necessity, cost, and feasibility of building demolition;
the need for vegetative or other cover compatible with the
O.U. #1 ROD, as amended; and
disposal options and requirements for remaining contaminated
media.
An interim action will be performed on O.U. #2 to prevent
unacceptable exposure to contaminants. This interim action,
which may include capping and groundwater containment and/or
extraction will be performed under the authority of the State of
Michigan. Through the five-year review process, U.S. EPA will
evaluate the effectiveness of the TIC remedy and consider its
effectiveness and relationship to the O.U. 42 interim action.
IV. NINE CRITERIA EVALUATION OF TBZ TTr BEMgnr
IV.A	THE NINE CRITERIA
THRESHOLD CRITERIA
1.	Overall protection of human health and the environment
determines whether the alternative eliminates, reduces, or
controls threats to public health and the environment
through institutional controls, engineering controls, or
treatment.
2.	Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) evaluates whether the alternative meets
Federal and State environmental statutes, regulations, and
other requirements that pertain to the site.
PRIMARY BALANCING CRITERIA
3.	Long-term effectiveness and permanence considers the ability
of the alternative to protect human health and the
environment over time and the reliability of such
protection, including the degree of certainty that the
alternative will prove successful.
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4.	Reduction of contaminant toxicity, mobility, or volume
through treatment evaluates the alternative's effectiveness
in reduction of the harmful effects of principal
contaminants, reduction of the contaminants' ability to move
in the environment, and the reduction in amount of
contamination present.
5.	Short-term effectiveness considers the length of time needed
to implement the alternative and the risks the alternative
poses to workers, residents, and the environment during
implementation.
6.	Xmplementability considers the technical and administrative
feasibility of implementing the alternative, such as the
practicability and difficulty of construction, and the
availability of goods and services.
7.	Cost considers the estimated capital and operation and
maintenance costs, as well as net present worth costs. Net
present worth is the total cost of the alternative over time
in terms of today's dollars.
MODIFYING CRITERIA
8.	State acceptance considers whether the State agrees with
U.S. EPA's analyses and recommendations of the studies and
evaluations performed.
9.	Community acceptance is determined from the public comments
received as a result of this document.
IV. B	NINE CRITERIA AHALT3IS OF THE SECOND AMENDED REMEDY
THRESHOLD CRITERIA
1. Overall protection of human health and the environment. The
TIC remedy will protect human health and the environment by
immediately preventing unacceptable exposures to soils, sludge
and groundwater through containment, and providing for treatment
of wastes by pnytoremediation offering a more permanent reduction
and elimination of risk. This is accomplished through
containment and extraction of contaminated groundwater, treatment
of extracted groundwater to meet substantive Federal and State
requirements, placing a barrier wall and a cover over and around
the contaminated soiis, and use of phytoremediation to further
reduce contaminant concentrations. The remedy will provide for
long-term operation and maintenance programs. With the remedy
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components and provision and commitments for long term O&M and
monitoring required by this ROD Amendment, the TIC remedy is
equivalent to the Landfill Remedy because it provides equivalent
immediate risk reduction (elimination of the airborne and direct
contact pathways), minimization of contaminant mobility, and
equivalent groundwater extraction and treatment. The TIC remedy
offers a provision for treatment by phytoremediation that the
Landfill Remedy does not have. This treatment component can
reduce contamination to acceptable levels and provide more
permanent long term protection.
2. Compliance with ARARs. The TIC remedy will comply with ail
substantive requirements of the identified State and Federal
ARARs. Part 201 of the Natural Resources ana Environmental
Protection Act, 1994 PA 451, as amended (formerly known as the
Michigan Environmental Response Act) requires that a remedial
action achieve categorical cleanup standards, such as
residential, commercial, or industrial. Cleanup criteria
associated with a future industrial land use will apply to on-
site2 contamination unless appropriate deed restrictions can not
be obtained, in which case criteria for future residential land
use will apply.
For the TIC remedy, it is expected that State groundwater
requirements and Federal MCLs will immediately be met off-site
and outside the TIC remedy area because this remedy would
immediately eliminate mobility of contaminants through
containment, and may ultimately achieve cleanup goals by the
treatment provided by phytoremediation. Extracted groundwater
will be treated to meet all applicable discharge standards, and
will also seek to comply with cleanup goals intended for
protection of Big Black Creek. The soils to be contained within
the barrier wall will include all soils for which the Risk
Assessment in the RI and Part 201 require action.
In the event it is later determined that the permeable O.U. #1
lagoon area cover is not making any significant positive
contribution to site remediation, or the redundant groundwater
containment and extraction systems fail to provide adequate
containment of contaminated site groundwater, or if the
implementation of a Contingent Remedial Action (CRA) regarding
the lagoon area is determined to be appropriate, RCRA and Part
For purposes of this ROD Amendment, 'on-site* means all property within
the former Bofors-Nobei property boundaries except for any property to the
South of the northern shore of Big Black Creek. For purposes of this SOW,
'off-site' means any property beyond the former Bofors-Nobei property
boundaries to the North, East and West, ar.d beyond the northern shore cf Big
Black Creek to the South.
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Ill of NREPA will be considered relevant and appropriate
requirements for any upgrade to the cover.
The TIC remedy construction activities will be implemented to
meet substantive requirements of all Federal, State, and local
regulation dealing with potential releases resulting from
excavation, site preparation, or other site work. The TIC remedy
is expected to comply with all such ARARs identified for O.U. #1
within the 1990 ROD and 1992 ROD Amendment, but is expected to
generate fewer releases than those anticipated for the Landfill
Remedy. A more detailed discussion of all ARARs for this site is
included in Appendix A to this document.
PRIMARY BALANCING CRITERIA
3. Lono Term Effectiveness and Permanence. With the remedy
components and provision and commitments for long-term O&M and
monitoring required by this ROD amendment, the TIC remedy
provides immediate risk reduction equivalent to the Landfill
Remedy. Direct contact risks associated with residual soils for
both remedies, as well as soils and sludge waste within
containment structures would be small, as exposure would be
eliminated. Long term effectiveness was provided by the Landfill
Remedy by preventing exposure to the most highly contaminated
site soils and sludges through containment in a secure landfill.
With the treatment provided by phytoremeaiation, the TIC remedy
potentially may offer a more permanent elimination of risk by
achievement of cleanup goals, affording discontinuation of
containment mechanisms.
Risks resulting from contaminants leaching into Site groundwater
would be minimized because of the containment provided by the
groundwater extraction mechanisms and physical containment. Over
time, the levels of this contamination would be reduced for both
remedies. The Landfill Remedy relied upon flushing and
collecting contamination from material that was not landfilled.
With the TIC remedy, the levels in both soil and groundwater may
ultimately be reduced by treatment and extraction to
concentrations that are no longer unacceptable.
Long term effectiveness of the TIC remedy depends: on maintaining
the integrity of the barrier wall and O.U. #1 lagoon area cover;
on continuing operation of the existing groundwater treatment
plant (or an acceptable equivalent alternative); on the continued
O&M of the extraction system at levels adequate to contain
groundwater that continue to exceed relevant criteria; and on the
effectiveness of the treatment mechanisms provided by
phytoremediation. The O&M will ensure that the barrier wall and
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any supplemental extraction system continues to contain
contaminated groundwater, that discharged groundwater meets
applicable criteria, and that the cover continues to provide an
effective barrier to unacceptable exposure to soils and sludge.
This management is particularly important because, although •
ongoing treatment, infiltration, and extraction of contaminated
groundwater may reduce contaminant concentrations, there is no
certainty that those levels will be immediately reduced
appreciably. As its goal for groundwater, the TIC remedy will
ultimately achieve Part 201 cleanup criteria or Federal maximum
contaminant levels (MCLs), whichever are more stringent,
throughout the affected groundwater area. Achievement of these
criteria insures that groundwater is protected under a reasonable
future land use scenario and for discharges to surface water.
For those listed contaminants that have Federal MCLs, the Part
201 cleanup criterion is the same as the MCL for that
contaminant.
Barrier walls have been constructed at a number of Superfund
sites and have been shown to be an effective limitation against
migration of contaminants when anchored into a bottom confining
layer. This barrier wall component of the TIC remedy would be
constructed using a barrier wall that would have depths according
to site topography and depth of underlying confining layer to
insure retardation of lateral movement of contaminated site
groundwater. The combined effect of the barrier wall and
groundwater extraction will provide an adequate and reliable
long-term containment of contaminated media. It is estimated
that the barrier wall for the TIC remedy may range between 70 and
100 feet deep. Although much of the barrier wall construction
activity takes place underground and cannot be visually
monitored, established quality assurance procedures exist for
barrier wall construction and will be implemented during
construction of this remedy. Although the adequacy and
reliability of the Landfill Remedy was sound, as landfill
construction is a proven remediation technology, the requirements
defined in this ROD Amendment {including recent modifications)
make this amended remedy equivalent.
The adequacy and reliability of the TIC remedy depends on the
ability to detect leaks in the barrier wall, and monitor the
effectiveness of the barrier wall and any supplemental extraction
system. A long-term groundwater monitoring program will be
established in the Remedial Design, implemented during
construction, and continued after the remedy is operational and
functional. If the barrier wall were to fail, escape of
contaminants outside the barrier wall and/or unacceptable
pressure differentials indicating a breach in the barrier wall
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would be detected by sampling and analysis of groundwater
monitoring wells. In the event the barrier wall were to develop
leaks, additional barrier wall construction can be implemented
adjacent to (outside) the first wall in the area where the first
wall fails, and/or groundwater extraction can also be utilized to
contain any contamination leaks. Compared to the Landfill
Remedy, which would have more quickly disclosed failure of the
landfill cap and liner system through a leak detection system,
barrier wall monitoring requires more time. Consideration of the
greater degree of difficulty associated with repair of landfill
cells {such as excavation and repair of damaged portions of the
cap and/or liner), however, makes the adequacy and reliability of
both remedies similar.
Adequacy and reliability is provided by the permeable 0.rJ. #1
lagoon area cover by eliminating airborne contaminant and direct
contact threats. The O.U. #1 lagoon area cover would not be
designed to minimize infiltration of precipitation, so leaching
of contaminants into groundwater may continue. These
contaminants would be extracted and treated, however, through
operation of the groundwater extraction system.
Quality assurance procedures for the barrier wall and O.U. *1
lagoon area cover shall be developed and can be implemented
during installation to assure the integrity of TIC remedy
construction. Continued periodic maintenance of the cover
components will be necessary to assure the integrity of the
remedy and no unacceptable risk exists to nearby ecosystems.
This nay be especially important for the portion of the cap (and
slurry wall) constructed near O.U. #2 areas where there may be
vehicle traffic over TIC remedy components. The Landfill Remedy
would have required equivalent periodic inspection and
maintenance, such as mowing and vegetation control.
As with the Landfill Remedy, the TIC remedy will be designed such
that existing or new groundwater extraction wells, a proven
remedial technology, can be used to complement or provide
containment of groundwater on both sides of the barrier wall and
containment area if needed.
The extraction system will require periodic inspection and
maintenance, including inspection for and prevention of
biofouling currently occurring within extraction and monitoring
wells currently at the site. Extraction wells are regularly
cleaned of biofouling deposits using an acid and flocculent
polymer solution. Because the current extraction well cleaning
procedure may not be the most effective method for the TIC remedy
ultimately implemented, a preventive maintenance program
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specifically suited for the TIC remedy will be developed during
the Remedial Design.
During the Remedial Design, the effectiveness and likelihood for
repair and replacement of groundwater collection and discharge
system(s) will be investigated and appropriate provision will be
made during the Remedial Action for replacement and/or repair as
needed.
Long term effectiveness of the groundwater cleanup is directly
dependent on continued O&M of the groundwater extraction system
and treatment facility. Long term effectiveness is afforded by
the GWTP through a combination of several different treatment
technologies that (individually) have been shown to be effective
for the contaminants involved. In the event any portion of the
treatment process fails, the GWTP has been constructed with
recirculation and/or storage capabilities to halt the discharge
to Big Black Creek until the primary treatment can be repaired or
bypassed and an in-place alternative process can be initiated.
Treatment operations using identical equipment have been
operating for extended amounts of time throughout the country;
the plant is therefore anticipated to remain operative for the
required length of groundwater treatment time.
For both remedies, the magnitude of residual risk from failure of
the groundwater extraction system would be dependent upon the
volume of, and levels of contamination in, the untreated
contaminated soils remaining within or underneath on-site
containment structures and underneath plant areas. It is
currently estimated (by the RD groundwater model) that for any
failure of the extraction system, a time period of 15 days can
elapse before any effect is seen in Big Black Creek. This should
allow enough time for repair of any system component. The
presence of multiple wells permits interim adjustments to the
system to compensate and maintain capture of contaminated
groundwater if some wells fail.
For the Landfill Remedy it was expected that soils underneath the
proposed on-Site landfill would have continued to contaminate
groundwater to an extent that would require constant extraction
and treatment of groundwater, until the groundwater cleanup
levels were reached. The level of contamination in saturated
soils underneath the landfill would have been reduced over time
as contamination would be drawn into groundwater which would be
in turn extracted and treated. Thus, the impact of soil
contamination on groundwater would have been reduced over time.
It is anticipated that contaminant reduction may be improved by
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the TIC remedy through treatment provided by phytoremediation
within contained areas.
Using a computer groundwater flow model, it has been estimated
that the groundwater extraction flow rate with implementation of
the barrier wall (without installed vegetation) would be very
near the natural groundwater flow rate of the aquifer. This
would suggest a more desirable situation when compared against
the higher flow rates needed by groundwater containment with
extraction wells alone. Considering the groundwater uptake
provided by the vegetative portions of the TIC remedy, the
required extraction rate will likely be further reduced. In the
unlikely event the barrier wail and extraction system do not
provide containment and contamination escapes, it has been
estimated that, without retardation provided by the barrier wall,
it would take several days before contaminant particles could
reach the Creek. This allows for implementation of CRAs as
previously discussed.
Deed and water use restrictions will be implemented to supplement
the long term engineering controls which comprise this remedy, so
that contact with site related contamination would be further
restricted. Deed restrictions can only be implemented by a
property owner or a person who controls a property.
Pursuant to Section 300.430(f)(4)(ii) of the NCP, 40 C.F.R.
§3C0 . 825(f) (4) (ii) , U.S. EPA is required to perform a review
every five (5) years ("Five-Year Review") after initiation of a
Remedial Action if hazardous substances, pollutants, or
contaminants remain on-site. Five-Year Reviews determine whether
an implemented Remedial Action continues to provide protection of
human health and the environment. The TIC remedy includes long
term monitoring to provide data on the quality and location of
site groundwater and surface water, and data from other required
monitoring programs. The required long-term monitoring programs
will provide the data necessary for the ongoing review process to
assess whether the remedy continues to protect human health and
the environment. If, through regular Five-Year Reviews, soil and
groundwater cleanup goals are determined to be unachievable, even
after implementation of Contingent Remedial Actions, containment
will continue and the options available to the Agencies wiil be
reviewed, including an assessment of whether other cost effective
treatment options are available. Through the five year review
process, determinations will be made as to the effectiveness of
the TIC remedy, long term requirements for operation and
maintenance of containment systems, including the need to
implement CRAs.
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Lt	 Reduction of toxicity, mobility, or volume through
treatment. With the treatment provided by phytoremediation, this
criterion will be satisfied by the TIC remedy for site soil,
sludge, and groundwater. As described more fully in previous
decision documents, standard treatment processes previously
identified to date were not cost effective for this site. The
TIC remedy will immediately reduce contaminant mobility by
providing containment. It is anticipated that it will ultimately
be demonstrated that the TIC remedy provides contaminant
reduction and reduction of additional contaminant loadings to
groundwater through phytoremediation within contained areas,
groundwater extraction and treatment, and attenuation and bio-
degradation. As with the Landfill Remedy, this criterion will be
satisfied for the groundwater, as reduction of toxicity and
contaminant volume would occur through use of a groundwater
treatment system. Other components of the Landfill Remedy,
however, did not satisfy this criterion.
5. Short term effectiveness. During construction, short-term
risks posed to the community will consist of; airborne
contaminants resulting from earth moving work (necessary grading
and excavation) and slurry wall construction, contaminants
leaving the site through storm water run-off, and risks to on-
site personnel implementing the remedy. Standard engineering,
construction, and personal safety measures to minimize these
risks will be required as part of the construction design. The
Remedial Design for this remedy will require procedures to be
followed for dust control, erosion control, and personal safety.
Installation of a real time air monitoring system will be a
construction requirement and will be installed around the
perimeter of the site. This system will provide updates at
regular intervals throughout construction activity and will
notify on-site personnel when site emissions reach or exceed
regulatory limits. If during construction activity, site dust
and/or emissions reach unacceptable levels, the nature,
locations, and amount of site activity will be reduced,
controlled, or adjusted accordingly. If discharges continue
after such changes are implemented, physical means such as mist
generation or application of foam cover (or other material)
directly at the point of excavation may be utilized. At the end
of each daily construction period, excavation and stockpile areas
will be covered appropriately to prevent releases during off-
hours. A site Health and Safety Plan will be developed to
establish procedures to be followed in specific situations, such
as site emergencies or potential off-site discharges.
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Consideration of short-term effectiveness must also include any
potential ecosystem effects that implementation of a remedy will
have. Specifically, the construction contractor must avoid
disrupting any wetland area, or, if an area is disrupted,
coordinate with the State and the USACE to appropriately restore
and/or replace and/or mitigate the affected area.
The proposed time to implement the TIC remedy is approximately 8
years, including 1 year to complete further site study and
Remedial Design activity, 2 years to install vegetative
components and construct the barrier wall and cover, and 5 years
for maturation and start-up of the entire remedy. With the use
of all preventative and mitigative measures, construction of this
alternative over the proposed time period will not pose a greater
risk to the community than the risk presented by current
conditions at the site. It is anticipated that, when compared
against the Landfill Remedy, the TIC remedy will have greater
short-term effectiveness because of the reduced amount of earth
moving activity.
6. Implementabilitv. Implementation of the TIC remedy will
occur in phases. Initially, lagoon areas will be cleaned of
debris and graded, requiring standard earth moving and disposal
procedures. As surface cleanup and grading occurs, sampling and
analysis of lagoon areas will occur, concur rent with design of
the O.U. #1 lagoon area cover and barrier wall.
following surface cleanup and grading, installation of vegetation
will occur, followed by construction of the O.U. #1 lagoon area
cover and barrier wall. The durable nature of the vegetative
species proposed for the TIC remedy suggests no significant
implementability problems with planting. Treatment provided by
phytoremediation is an innovation whose implementability is
undefined, but the redundancy provided by the lagoon area cover
and containment systems permits its use. Cap and barrier wall
activities utilize proven technology and procedures, and the
existing operational groundwater extraction and treatment system
will continue to run throughout these activities, until the TIC
remedy has been shown to be adequately operating. Contingent
Remedial Actions such as the upgrade of the O.U. #1 lagoon area
cover installation of new extraction wells, and maintenance of
vegetation are not anticipated to present implementability
problems.
Barrier wall construction has occurred at many Superfund sites,
and standard engineering and construction methods would be
implemented. Site topography and loose soil conditions could
make barrier wall construction somewhat difficult at this site.
34
-------
Locse soil conditions may adversely affect slurry wall
construction due to the likely migration of slurry mix into
surrounding soils. Soils comprised of an inordinate quantity of
fines such as those found at Bofors tend to pervade soil-
bentonite-water mixes and jeopardize the non-permeability of
slurry walls. In the event use of slurry proves difficult,
alternative options such a3 sheet piling may be used, alone or in
concert with slurry walls.
Construction quality assurance ("CQA") may be difficult, as there
are no direct means (such as compaction tests) to test
effectiveness of slurry mix at depth during installation. CQA
for slurry walls typically consists of field and lab viscosity
tests of slurry mix before placement, and core samples of the
wall after installation. In the event slurry mix does not meet
specifications after placement, a technique such as in-situ
mixing and placement of additional slurry would have to be
performed.
Although implementabiiity of the Landfill Remedy was good because
of the existence and application of proven techniques, services,
and materials for landfill construction, the remedy requirements
defined in this ROD Amendment (including recent modifications)
and the associated legal agreement have improved the
implementabiiity of the TIC remedy. For the Landfill Remedy,
construction difficulties would have been spatial, in that
maneuvering of earth moving equipment for concurrent liner
construction and waste placement may have been be somewhat
constricted. It is anticipated that these difficulties will be
reduced for the TIC remedy because of the lesser amount of earth
moving activity associated with t'he barrier wall and O.U. #1
lagoon area cover.
Monitoring the effectiveness of the remedy would consist of long
term groundwater monitoring and studying the quality of Big Black
Creek for adverse effects related to the site. Because wastes
will remain in contact with groundwater, the TIC remedy does not
contemplate that groundwater within the slurry wall boundary will
be cleaned to protective levels in the short term. However,
through the treatment provided by phytoremediation, it is
anticipated that over the long term, contaminants within the
barrier wall boundary may be reduced. The effectiveness of the
remedy therefore depends on continuing O&M of the groundwater
extraction system and GWTP until it is proven that cleanup goals
have been achieved and/or containment of wastes is no longer
necessary. The Landfill Remedy would likely have required a
similar degree of long term monitoring.
35
-------
With appropriate maintenance measures, it is expected that the
groundwater collection and extraction system installed for the
TIC remedy will be capable of performing continuous extraction
for extended periods of time. The groundwater extraction system
may require further adjustments depending on the interim actions
in the plant area and the final O.U. #2 remedy ultimately
established by U.S. EPA. Proven techniques, services, and
materials for groundwater extraction well systems exist.
Implementation of the Landfill Remedy would have resulted in
similar improvements to the existing system by installing fewer
but more efficient new extraction wells. With appropriate
maintenance measures, extraction wells installed for either
remedy are capable of performing continuous extraction over their
expected life time, resulting in a significant reduction of
contaminant concentrations in groundwater. If any those
extraction well pumps should need replacement before cleanup
standards are achieved, replacement equipment can be readily
obtained and installed. In addition, well maintenance will
continue to include cleaning out of material caused by biological
fouling as needed.
Implementabi1ity of the groundwater treatment plant is
demonstrated by the fact that the plant has been successfully
constructed and is now operating in compliance with State surface
water discharge limits since 1994.
Consideration of implementability of a remedy must take into
account the difficulty of undertaking any further Remedial
Actions. For the Landfill Remedy, an additional Remedial Action
could have been conducted, but might have been difficult in the
event of excavation of the landfill liner and cap. It was not
anticipated that soil and sludge contained in the landfill would
have been disturbed for some time {the specifications required a
minimum 80 years containment), but in the event some new
remediation technology had become available, or an existing
technology was developed to be technically and fiscally
practicable to the Site, waste contained in the landfill cells
may have been removed and managed in a more definitive manner.
With containment of wastes in place, the TIC remedy affords
easier access for further Remedial Action.
7. Cost. TIC remedy cost depends on whether Contingent
Remedial Actions are implemented. Tables 5 through 7 provide a
detailed break down of capital and O&M costs for all
implementation phases of the TIC remedy, and do not include U.S.
EPA expenditures to date.
36
-------
Costs (including cost estimate contingencies) and implementation
time frames are summarized as follows:
TIC remedy Remedial Design:	$	5,450,000
TIC remedy Minimum Construction Requirements1:	$	10,189,990
Additional Construction capital for CRAs:	$	4.594.540
Total (Maximum Construction Capital Cost):	$	14,784,530
Minimum Project Cost
(RD plus Minimum Construction):	$	15,639,990
Annual
O&M
and
Monitoring4 ¦
- Yrs
1 to 3:
$
830,000
Annual
O&M
and
Monitoring5 ¦
- Yrs
3 to 8 :
$
770,000
Annual
O&M
and
Monitoring5 -
- Yrs
8 to 33:
$
570,000
Annual
O&M
and
Monitoring5 -
• Yrs
33 to 103:
$
353,000
Present Worth of Annual O&M & Monitoring
(including contingency):	$ 14,932,160
Minimum Net Present Worth5 of Project:	$ 25,123,150
Maximum Net Present Worth6 of Project:	$ 29,716,690
Estimated Implementation Time: It is anticipated that 8 years
will be required, including 1 year for RD, 2 years for
installation of vegetative components and construction of the
Barrier Wall, and 5 years for maturation and start-up of the
entire TIC remedy. Literature suggests that for the nature and
extent of contamination present at the site, treatment mechanisms
provided through phytoremediation may reduce site contamination
to acceptable levels within an approximate time of 30 to 70
years, with the most appreciable reduction occurring in the
initial 20 years.
3 "Minimum Construction Requirements" is the construction capital cost for the
basic TIC Remedy. Includes 25% cost estimate contingency (see Table 5).
' O&M and monitoring costs are anticipated to decrease as the project time
period increases. The "time weighted" annual monitoring cost is $ 56,760 ar-.d
the "time weighted" annual O&M cost is S 383,590 (see Table 7).
1 Net present worth of project is the sum of capital costs plus total present
worth of annual costs ;not including RD or U.S. EPA cost to date).
37
-------
MODIFYING CRITERIA
8.	State Acceptance. The State's approval of this remedy was
provided after affirmation of the commitment to:
a.	the installation and implementation of an approved
monitoring system downgradient of the barrier wall; and
b.	the installation of extraction wells along Big Black
Creek to prevent the discharge of contaminated
groundwater to the Creek at concentrations in excess of
State standards, prior to or in conjunction with
barrier wall construction,
as defined in Section III.E of this ROD Amendment and in the
associated legal agreement(s).
9.	Community Acceptance. The Proposed Plan for this ROD
Amendment, provided to collect community input, was issued on
June 15, 1998, and a notice placed in the Muskeaon Chronicle on
June 17, 1998. Comments received from the community appear in
favor of this remedy. All comments received during the comment
period of June 15, 1998 to July 17, 1998 were reviewed and
responded to in a Responsiveness Summary, which is included as
Appendix B to this ROD Amendment and will be made part of the
public record for the site.
V. STATUTORY DETERMINATIONS
The TIC remedy described herein complies with the requirements of
CERCLA §121 by controlling site risks posed by groundwater, air,
or direct contact with hazardous materials through the
containment of site soils. This action will not cause
unacceptable short-term risk or cross-media impacts. This TIC
remedy complies with all State and Federal ARARs. There are no
chemical, action or location-specific ARARs identified for this
action that were not identified and discussed in the remedy re-
evaluation document dated July 16, 1996. The TIC remedy is cost-
effective and reduces costs associated with construction
sequencing, material handling, temporary storage of contaminated
soils, and O&M for groundwater extraction and treatment.
The TIC remedy provides the best balance of trade-offs with
respect to U.S. EPA's remedy evaluation criteria. Other
considerations include the evaluation of reasonably anticipated
future land use for the site as industrial, the revised State of
Michigan statutes applicable to site cleanup, the associated
cleanup criteria, and short term risk and long term requirements
for construction of the remedy alternatives.
38
-------
With the treatment provided by this remedy, this action satisfies
the preference for treatment as a principal element of the
remedy. Given the time requirement for maturation of the
vegetative portions of the TIC remedy, however, treatment
effectiveness can not be immediately measured. Reduction of the
toxicity, mobility, or volume of site wastes will immediately
occur through the baseline remedy provision for containment of
site waste in place, and the significant extraction and treatment
of contaminated groundwater.
Goals of this second amendment to the ROD for the O.U. #1 remedy
at the Bofors-Nobel Site are containment of sludge, soils, and
groundwater as the base component to immediately address the
threat from contamination in the lagoon area and in site wide
groundwater, and reduction of soil and groundwater contamination
levels through treatment provided by phytoremediation,
groundwater extraction and treatment, and attenuation and bio-
degradation. The Remedial Action Objectives (RAOs) for this
remedy to ensure containment are as follows:
1.	Containment of lagoon sludge and soils to prevent on-site6
exposure to hazardous substances at concentrations that pose
an unacceptable risk to human receptors under industrial
land use scenarios via the following routes cf exposure:
(a) direct contact; (b) inhalation from voiatization to
indoor air; (c) inhalation from voiatization to ambient air;
(d) drinking water use of aquifer; (e) groundwater contact;
and (f) surface water contact. Containment of lagoon sludge
and soils to prevent on-site exposure to hazardous
substances at concentrations that pose an unacceptable risk
to environmental receptors via the following routes of
exposure and migration pathways: (a) contact with
contaminants present in surface soils, plants, water or air
on-site; (b) groundwater impacts on surface water; and (c)
soil runoff impacts on surface water.
2.	Containment of lagoon sludge and soils to prevent off-site
migration of contaminants to air, soil or groundwater at
concentrations that would pose an unacceptable risk to human
and/or environmental receptors; and
3.	Containment of groundwater to prevent migration of
contaminants at concentrations that would pose an
4	For purposes of this ROD Amendment, 'on-site' means all property within
the former Bofors-Nobel property boundaries except for any property to the
South of t^e northern shore of Big Black Creek. For purposes of this ROD
Amendment, 'off-site' means any property beyond the former Bofors-Nobel
property boundaries to the North, East and West, and beyond the northern shore
of 3ig Black Creek to the South.
39
-------
unacceptable risk to human and/or environmental receptors
off-site including Big Black Creek and to the on-site
wetlands between Big Black Creek and the barrier wall.
In order to ensure these objectives are met and maintained, the
remedy includes:
measurement of the effectiveness of containment systems
including measurement of the reduction in contaminant
concentrations; and
operation and maintenance of containment systems until such
time as it is determined that continued operation of
containment is unnecessary.
The remote location and current zoning of the site as industrial
supports the assertion that the reasonably anticipated future
land use for the site is industrial in nature. Part 201 of NREPA
requires that zoning of a property where a remedy is implemented
be consistent with the categorical criteria applied at the site.
The current zoning of the former Bofors-Mobel Site is industrial,
as are the cleanup criteria being applied on site (conditional
upon appropriate land use and deed restrictions). U.S. EPA
foresees that appropriate institutional controls, such as deed
restrictions and land use restrictions, combined with standard
security measures will be adequate to prevent or limit the
exposure potential for nearby residents and will guarantee that
components of the remedy will remain intact.
40
-------
\
N
*
NOTE: MAP 8 NOT TO SCALE
MUSKEGON
COUNTY
Muskegon
Lain
LMiCmdtr
Cr—k
MICHIGAN
APPROXIMATE
LOCATION
/ OF SITE
Big BIscA
Cn«k
Mont
Lakt
FIGURE 1 - COUNTY LOCATION
OF BOFORS-NOBEL SITE
F-l
-------
NOTE: MAP B NOT TO 8CALI
MICHIGAN

MUSKEGON
^^^PQUMHNAl C»
•ITl LOCATION
m WKr	w WPw Wm
F1QUPS 2»SITE UQCATION MAP
BOFORS - NOBEL SUPERFUND SITE;
EGELSTON TOWNSHIP, MICHIGAN
F-2
-------
Lomac Area
(OU #2)
LAQOONS
1-10
NOTE: DRAWING IS
NOT TO SCALE
FIGURE 3 • BOFQRS-NOBEL SITE LAYOUT
F-3
-------
MWM04
LEGEND:
PW - PURGE WELL
MW - MONITORING WELL
33 • SOIL SAMPLE
P,WC, IL - MONITORING WELLS
LW - IOMAC WELL
(OUiGn


MM
Big Black
Cmak
NOTE: DRAWING IS NOT TO SCALE
FIGURE 3A.- BQFQRSrNOBEL SITEJAYDUT AND
APPROXIMATE SAMPLING LOCATIONS
F-3A
-------
LomacArea
(OU #2)
m

NV

U.S. EPA


GWTP
m




i

ZONE A - HIGH DENSITY HYBRID POPLAR
ZONE B - HIGH DENSITY EASTERN RED CEDAR
ZONE C - HYBRID POPLAR
ZONE D - GRASS AND RED CEDAR
NV - NATIVE VEGETATION
FIGURE 4 - PRELIMINARY LAYOUT OF IN3TAU.EDVEGETAIIQN
-------
11
I
l/I
O U *1 LAGOON AREA
PROTECTIVE COVER
BARRIER
WAIL
FI+h
mw
M
CONTAMINATED
GROUNDWATER
CLAYAQUrTARO
CONTAMINATED
SOU
FIGURE 5 - PRELIMINARY CROSS-SECTION OF TIC REMEDY
-------
Lomac Area
(OU #2)
u&s*
amp
PRELIMINARY
LOCATION Of
BARRIER WALL
PROPOSED GROUNDWATER COLLECTION POINT
FIGURE « . PRELIMINARY LOCATION OF BARRIER WALL
-------
LomacArea
OU.fS
U.S. 0*A
PW-30
PW-31
PW-28
Pw-M
PW-37
PW-33
PW-41
PW-3#
Big Black Creek
WM5
NOTE: DRAWING IS NOT TO SCALE
FIGURE ? i* LOCATION	QRQUNQlff ATER EXTRACTION IflfELLS
F-7
-------
TABLE I - CONTAMINANTS IN SLUDGE AND SOIL AND SOIL CLEANUP CRITERIA (PERFORMANCE STANDARDS) . O IJ, H\ LACOON
AREA - BOFORS-NOBEI. SITE
CONTAMINANT
PART 201
KPGW'
iw*)
PART 201
IKiW '
PART 201
GSIPCW'
PARI 201 IND
DCV' (ppb)
LAGOON NUMBER (Approximate Location); Contaminant Concentration in ppb
¦ACKOD*
1
1
\
4

fi
7

g
in
Acetone
15000
42000
34000
7 40c* 07
NO4
70







91
II
Mkyl benzene
somers"
N/L'


N/L '
ND4


148000 J


123000 J

147000
148000000 J
4400
Aniline (cc)
3000
12000
IP'
1 50eM)6C"
ND4
860

9200




1700
3900000
3400
Azobenzene (cc)
1400
5900
N/A '
) 40e+06
ND4
93 1

12000000

170000
680000
22000 J
33000)
8200000
230000
\zoxybenzene
N/l.'


N/L'
ND4


690000 J





36000
85000
benzene (cc)
100
100
1000 X"
~00,000 C"
ND 4


980000

23


2800
120000
8J
benzidine (cc)
1000 M"
1000 M"
ID'
1,000 M"
ND4


3400000

2100 J
70000i

13000
1300000
13000 |
{-Butanonc (MbK)
260000
760000
44000
2 70et07 C"
ND4








25 J

2-Chloroaniline
N/l. '


N/L'
N134
260000

270000

540
22000 J;
21000
240
12001*1
2300000
24000 1
tti-Chlorophenyl)
I4-Chlorophcny))
^lethanone
N/L 1


N/L '
Nl)4
300000 J

6100000 J

3300001
1,300,000
5200001
340001
6200000
190000 J
i,3'-Dichlorobenzidinc
and isomers) (cc)
2000 M"
2000 M"
2000
M", X "
55000
ND4
65000 J

2700000

930000;
950000 J
390000,
1000000 J
260000;
1000001
1500000,
17000001
11,000,000
2900000.
3500000 )
Blhylbenzene
1500
1500
360
140,000 C 14
ND4
51




9,200
1



Methylene Chloride
«)
100
100
19000
X"
2.30c+O6
C "
ND4




4 J '**
2200 J
18
1200 J


sulfur - NP "
N/L5


N/L'
ND4
5100 J





8300)

1500

1,1"- Sulfonyl - bis (2-
vlelhyl) Benzene
N/L'


N/L »
ND4









82000 J I
T-l .a
-------
TAPI.E I - CONTAMINANTS IN SL.UPCE AND SOIL AND SOIL CLEANUP CRITERIA (PERFORMANCE STANDARDS) - O.U. »1 LAGOON
		AREA - BOFORS-NOBEL SITE
CONTAMINANT
part 2oi
RPGW 1
PART 201
IPGW'
(PP*(
part ;oi
GS1POW1
(PI*)
'ART 201 INl>
DCV'ipt*)


LAGOON NUMBER (Approximate Location); Contaminant Conccutialion in ppb
BACK Cty

?
1
4
s
6
7
8
9
10
retrachloroethylene
100
100
900 X "
88000 C 14
ND4






82
680


toluene
16000
16000
2800
250000C "
ND*
8,900

1,100,000

17
130,000

80,000
1600000
210
1.2.4-
rrichlorobenzene
4200
4200
1800
l.le+06C 14
ND *


350

150
150

7,100
250000

Jnknowns 10



NP'*
26 J

14001


5700 J
503000 J
19000 J


14400 I
Xylenes (total)
5600
5600
700
150,000 C "
ND*
120



14
58,000




















iMuminum
1000
1000
N/A '
3.00e+08
3770000
250000
IU0000
1740000
781000
7920000
4070000
1900000
6220000
1930000
3830000 |
|\ntimony "
4300
4300
ID'
l60e+06
ND'
25200








1
\rscnic
23000
23000
70000 X"
100000
ND4
43800 E
630 }
6100
600 J
3600
5100
780 J
3700 i
2700 J
3300 J
barium
l.30e+06
l.30c+«6
130000
3.20e+08
12600 1
9800 J
5700 J
40300 J
3400 J
48000 J
43400 J
18300 J
85000
18300)
44700)
beryllium
51000
51000
G "
2.30c+07
ND'


670 J

540 J
2100
320


2400
Cadmium
6000
6000
G.X "
2.30c+06
ND4
424000

21900





15100

-ulcium • NO "


G,X "
4.5 e+06
109000 J
83000 J
242000i
64600000
676000J
194000000
265000000
7350000
253000000
25900000
27IOOOOOO
Chromium
30000
30000
3300
2.20e+07
2200
916000
2400
79500

22100
12100
17000
68000
4J700
21200 |
Cobalt
1000
2000
2000
2.30e+07
2200 J
36700



3500 J
77001



3400) f
Copper
l.60e+08
1.60c+08
G "
I 70e+08
ND *
1640000
41200
226000

19)00
14300
6400
2800
36700
27100
ron - NO"
6000
6000
N/A'
ID'
2650000
5460000
2660000
II000000
1420000
3780000
2550000
3870000
2920000
13000000
(430000
1-
1000 M "
1000 M"
G,X"
M"
900,000 L'
3200
b040000 E
6200
887000
700 J
34700
20800
37400
29700 R
362000
12500 E
T - 1 . b
-------
TABLE I - CONTAMINANTS IN SLUDGE AND SOIL ANt) SOIL CLEANUP CRITERIA (PERFORMANCE STANDARDS! • O.LI. Hi LAGOON
AREA - BOFORS-NOBELSiTE
. ON1AMINAN)
par r mi
KK.W'
HART 201
IPGW 1
HaJU »1
GSIFGW'
(J**)
PART 201 WO
UCV'tW*)
l.AGOON NUMBER (Approximate Location), Contaminant Concentration in ppb
BACKCD*
t
7
1
4

h
7



Vlagnesium - NO
840e+06
240c*07
N/A '
1.0C+09D'
342000 J
95000 J
368000 J
1840000
4590001
2870000
2350000
7210001
3400000
3050000
2470000
Manganese
2000 M"
2000 M"
G,X u
2.IOe+08
17300
2680000
41200
85200
23900
52000
46400
58600
71600
164000
32800 E
vtercury
1700
1700
170
1 40c+06
HI)'
ISO E
100
710





330

Nickel
100000
100000
O"
3,40eH)8
ND*
460000
21001
21000

17500
103001
9300
3600 J
15100
48001
i'oiASSium «NO '*



NO'"
86400

71800 J
189000 J
106000 J
412000 J
245000 J
793001
3940001K
1040001
1320001
Selenium
4000
4000
400
2.30e*07
ND4

6801
1300






24001
pilver
4500
13000
500 M"
2.l0e+07
ND4
15600



4600



18001
1200
[podium '*
3.20e+06
9.00e+06
N/A'
I.Oe+09 D4
ND4

26100 J
5920000
440001
1910001
169000 J
499001
3660001
3500000
3180001
¦Thallium
2300
2300
4200 X"
300000
ND4










[Vanadium
1 00e+06
2.90e+06
240
3.90e+07
4800
28,600
30001
42001
940 i
17700
108001
4600 J
93001
54001
6200 1
feinc
2 40c+06
5 00e+06
G"
1 0e«09 0*
1240000
59,400
15,900
91,200,000
18,500
1,240,000
1.280,000
8,370,000
2.510.000
6 i.800.000
1,270.000
T-l . c
-------
KKJTNOTKS AND LKGfcND FOR TABLE 1
{tcj Baseline risk assessment identified this contaminant as presenting a major Site risk. Baseline risk assessment did not identify any inorganic contaminants as contaminants of concern
1	Daw taken from Kecord of Decision and February 1990 Remedial Investigation (Rl ) Report. Data represents maximum concentrations found in soils or sludge samples taken in lagoon
area at an average depth of 10 feet deep (Soil samples - 2 w 6 ft; Sludge 10 to 12 ft.) No HCBS or pesticides (other than those shown) were detected Blank spaces in Tabic I signify
that compound was not detected in laboratory analysis. See Table J for current site conditions. Values shown in format "I.Oe+09" are scientific notation (i t I 0e+09 - I 000 000 000
I 0e* 06= 1.000,000; l.0e-01=0 001; l.Oc-06-O 000001).
2	IPGW »Industrial Soil Cleanup Criteria Protective of Groundwater as of June I9W. This is the contaminant concentration in soil which, if not exceeded, insures that groundwater is
protective for human consumption under a future industrial land use scenario KPC.W ¦ Residential Soil Cleanup Criteria Protective of Groundwater as of June 1999 This is the
contaminant concentration in soil which, if not exceeded, insures that groundwater is protective for human consumption under a future residential land use scenario GSIPCiW - Soil
Cleanup Criteria Protective of GSI Criteria for Groundwater as of June 1999. This is the contaminant concentration in soil which, if no< exceeded, insures that groundwater is protective
for Big Black Creek. PCV • Direct Contact Value • Part 201 Industrial Direct Contact Value as of June 1999 This is the contaminant concentration in soil which, if exceeded, presents
an unacceptable human risk by contact with the soil within a typical industrial scenario. Any exposure to lagoon area soil would be to an individual working on the Site within a
controlled work environment. The DCV criterion is the basis for the O.U. HI lagoon area cover component of the TIC remedy.
3	BACKGRD - Background concentration taken from sample in relatively "clean" site area
4	ND - Compound Not Delected in laboratory analysis.
5	N/l. • Hot Listed in Michigan Part 201 Generic Industrial and Commercial Cleanup Criteria as of June 1999.
N/A - Not Available or Not Applicable, but contaminant ha been LISTED as of June 1999.
6	D«Concentration constituting cleanup criteria exceeds 100 % in soil hence it is reduced to 100 %.
7	ID - Inadequate Data. There is not enough health risk data to develop criterion for this contaminant.
H	L - Criteria developed using Ute U.S. EPA integrated uptake Biokinetic Model for children. No risk assessment method is currently available to evaluate lead toxicity in adults. Higher
level may be acceptable subject to U.S. EPA and State of Michigan review and approval procedure.
9	IP - Development of generic GSI value in process but not yet complete.
10	NP, NO • Contaminant discovered at the time of the 1990 ROD but subsequently shown (by subsequent sampling and analysis) as Not Present, Naturally Occurring, or well below soil,
air, groundwater, or surface water cleanup criteria. Sec Table 3 for more detail.
11	M - Method Detection Limit is cleanup criterion. The Method Detection Limit is the lowest value accepted by the State of Michigan that laboratory equipment can measure If the Part
201 cleanup criterion is lower than what the laboratory can detect then the MDL becomes the cleanup standard.
12	Alky1bcrt?ene isomers are compounds related to Toluene, Cthylbcnzene, and Isoprupylbentene (all are "Alkyl benzenes").
13	li - Soil criteria for GSI protection is dependent on hardness of water in the area X • I lie USI criterion shown is not protective for surface water that is used as a drinking water source
M C - Soil criteria is based on contaminant«specific generic soil saturation concentration to insure a more protective cleanup goal. Soil criterion may be modified based on an acceptable
site « specific demonstration subject to U S, KPA/MDEQ review and approval
DATA QUALIFIER LEGEND
When chemical analysis data is submitted to US EPA limitations of analytical equipment must be noted with results so an accurate scrutiny can be performed 1 hese limitations are shown as
qualifiers noted as letters next to numerical values fcxplanations of these qualifiers arc as follows:
** Not found in duplicate analysis; •" Less than 10 times the concentration found in lab field or background blanks; "" Compound is unknown in the sense that there were detections
of organic chemicals but specific identification of a certain compound or isomer detected is unknown.
J • Signifies a value that was estimated. This means that the compound was detected by the analytical equipment but the value shown may not be able to be reproduced exactly if the
analysis were repeated.
B - Signifies a compound that was also detected in a blank A blank is a 'clean' sample prepared in the laboratory carried with field samples transported and stored If contamination is
found in a blank there is a possibility that contamination may be from a source other than what was sampled 
-------
TABLE 2 ¦ CONTAMINANTS IN GROUNDWATER' AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS! ¦ O il. *1
LAGOON AREA - BOFORS-NOBEL SITE
CONTAMINANT
FART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA1 focb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA ' (DDb)
PART 201
GENERIC GS1
CLEANUP
CRITERIA4(nob)
PART 201
GROUNDWATER
CONTACT
CRITERIA $roob)
BACKGROUND*
MAX. CONTAMINANT |
CONCENTRATION (ppb) |
IN 1990 ROD OR j
REMEDIAL DESIGN I
(month/vr)1 I
Acenapihene
3,800
1,300
19
4200 S'
ND*
20
Acenapthylcne "
75
26
ID"
3900 S7
ND
21
Acetone
2,100
730
1,700
31,000.000
ND
5,100; 81,000 E
Aniline (cc)
610
150
IP 14
370,000
ND
10,000
Anthracene
43 S'
43 S'
ID 11
43 S'
, ND
14 J
Azobcnzcnc (cc)
32
7.7
NA *
410
ND
420 @ PW-40 (7/93)
Benzene(cc)
5 A *
5 A'
200 X"
9,400
8,000
65,000 |
Benzeneacetic acid "
N/L"
NOT LISTED

ND
140 J |
Benzidine (cc)
0.3 M 10
0.3 M 10
ID "
68
ND
12,000 @ MW-106 (6/92) j
Benzo(»)jmihnicene
S M 10
5 M 10
NA 5
5 M 10
ND
)9J |
Ben2o(a)pyrene "
S M 10
5 M 10
ID11
5M 10
ND
230
1,2,3-Bcnzothisdiazole "
N/L"
NOT LISTED

ND
1,300 J
Benzyl Alcohol
29,000
10,000
NA5
44,000,000 S1
ND
310 @ PW-39 (6/92)
Bis(2-cthyfbcxyl)phthalale
6A«
6 A *
32
47
ND
4,000 J
Carbon Disulfide
2,300
800
ID ,J
1,100,000
ND
1.000
2-Chloroaniline
N/L"
NOT LISTED

ND
63,000
4-ChIoroaniline
N/L"
NOT LISTED

ND
62 @ MW-62 (7/93)
Chlorobenzene
100 A'
100 A1
47
68,000
ND
920
Chloroform
100 A.W"'
100 A,W,lS
170 X,J
96,000
ND
4.8 @ MW-60 (6/94) |
T-2 .a
-------
TAPIE J - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS) -OU«l
			l.ACOON AREA BOFORS-NOBEL $ITF
NTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA' (ppb)
PART 201
RLS1DKN 1'IAL
DRINKING
WATER
CRITERIA 1 (oob)
PART 201
GENERIC GSI
CLEANUP
CRITERIA 4 (DDb)
PART 201
GROUNDWATER
CONTACT
CRITERIA 1 (DDb)
BACKGROUND6
(ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN I9V0 ROD OR
REMEDIAL DESIGN
(month/vr)1
:hlorophenylX4-ch)orophenyl)
ethanone
N/L "
NOT LISTED

ND
700 J
-ysene
5M"
5 M 10
ID "
5 M 10
ND
19 J
lenzofuran "
ID15
ID"
4
ID"
ND
18 J
-Dichlorobcnzidine (and
ners) (cc)
7.7
1.9
0.3 M,X 10 "
270
ND
2,600
•Dichlorobcnzene
600 A*
600 A '
16
160,000 S '
ND
400
¦Dichloroethane
5 A '
5A»
360 X"
11,000
ND
no |
Dichlorocthylcnc (ethene)
7 A*
7 A»
65 X"
9000
ND
34 J@PW-33 (6/94) |
•Dichlorotthylene (ethene)
70 A'
70 A*
ID"
170,000
ND
2,400 @ PW-33 (6/94) Q
J • Dimethylformamide
2,000
700
NA !
130,000,000
ND
450 J
icthyl plithalaie
210,000
73,000
NA 5
4,200,000 S '
ND
120 J
ldhylbenzenanune "
N/L "
NOT LISTED

ND
780 J
icthylnapihalenc "
N/L "
NOT LISTED

ND
52 J
n-Bulylphlhalale
2,500
880
9.7
11,000 S 7
ND
180 (a) PW-40 (11/93)
n-Oclylphllialale
380
130
ID"
250
ND
459 @ PW-40 (6/92)
-Diphenyl- 2,2-Diamine
N/L "
NOT LISTED

ND
3,200 J
-Dihydrodiinelhyl-1 H-lndenc
N/L "
NOT LISTED

ND
42 J
ylbenzene
74 b 14
74 E "
18
170,000 S'
ND
340 (gj PW-41 (9/92)
T-2 . b
-------
TABLE 2 - CONTAMINANTS IN GROUNDWATER' AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS) - OH. #1
LAGOON AREA - BOFORS-NOBEL SITE
CONTAMINANT
PART 201
INDUS IRIAL
DRINKING
WATER
CRITERIA1 fw>b>
PAR r 201
RESIDENTIAL
DRINKING
WATER
CRITERIA J (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA4 (DOb)
PART 201
GROUNDWATER
CONTACT
CRITERIA' (Dob)
BACKGROUND4
(cob)
MAX. CONTAMINANT I
CONCENTRATION (ppb)
IN 1990 ROO OR
REMEDIAL DESIGN J
(month/vr)1 1
Fluoramhene
210 S '
210 S'
1.6
210 S'
ND
16 J j
Fluorine "
2,000 A E'
2,000 A E'
NA 5
13,000,000
ND
16 S
2-Hydroxybcnzonitrile "
N/L "
NOT LISTED

ND
44 J
4-hydroxy-4-methyI-2-penianone"
N/L "
NOT LISTED

ND
190 J
Isophorone
3,700
900
570 X 11
1,100,000
ND
1,400
2-Meihylnapihalane
750
260
ID"
32,000
ND
480
2-Methylphenol
1,000
370
82
710,000
ND
470
4-Methylphenol
100
37
ID"
75,000
ND
170
ll-M«hoxynitfobenzene "
N/L"
NOT LISTED

ND
22,000 J
IMcihylnaphthaiene "
N/L"
NOT LISTED

ND
490 J
Methoxybenaeneamme "
N/L "
NOT LISTED

ND
21,000 J j
Methylene Chloride
SA'
5 A*
940 X"
110,000
ND
5,820 @PW-38 (6/92) j
N-nitroso-Di-n-Propylamine
5 M 19
5M"
NA1
220
ND
30 @PW-34 (12/92) j
(Naphthalene
750
260
13
31,000 S *
ND
650 |
Nitrobenzene
9.6
5M"
180 X "
9,600
ND
6,600 J
Phenanihrene
75
26
5 M
1,000 S'
ND
19 J ]
Phenol
13,000
4,400
210
28,000,000
ND
140; 170 J J
Pyrene
140 S'
140 S'
ID 12
140 S'
ND
27
Sulfur "
N/L"
NOT LISTED

ND
1,800 J
T - 2 . c
-------
TABLE 2 - CONTAMINANTS IN GROUNDWATER' AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS! - O.l) ttl
lagoon arf.a bofors-nqbel site
ICONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (DDb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA ' (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA 4 (Dub)
PART 201
GROUNDWATER
CONTACT
CRITERIA 5 (DDb)
BACKGROUND'
(ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(monlh/vr) 1
ll'etrachlorocthylenc
5 A 1
5 A 1
45 X"
5,100
ND
18.000
¦Toluene
790 E»
790 E'
140
530,000 S '
3,000 J
280,000
Hi ,2,4-Trichlorobenzene
70 A»
70 A*
30
15,000
ND
56 J
IjTrichloro-1 -propene isomer "
N/L "
NOT LISTED

ND
36 J
Trichloroethylene
5 A*
5 A '
200 X"
11,000
ND
1
2,100 @PW-33 (6/94)
3,3,5-Trimethylcyclohexanone
N/L "
NOT LISTED

ND
31,000 J
iTrimp (trimethylphenols)
N/L"
NOT LISTED

ND
2,000 J
|l,2,4-Trithiolane "
N/L"
NOT LISTED

ND
420 i |
|l,3,5-Trithlane "
N/L "
NOT LISTED

ND
100 J
RJnknowns •••*
N/L "
NOT LISTED

ND
100,500
[Vinyl chloride
2 A »
2 A »
15
290
ND
1,000
Xylenes Dotal) . _ _

->an »• •
"h
lQnnrtrt*'
Rftnn
*tfiO ffl) PW-41 CV9IJ
(Aluminum
50
50
NA '
70,000,000
192
23,200
jAntimony "
6 A'
6 A '
ID IJ
75,000
61.3
61
{Arsenic
50 A '
50 A'
150 X "
4,700
4.8 J
74
Barium
2,000 A 1
2,000 A'
190
15,000,000
23.2 J
174 J
Beryllium
4 A »
4 A'
G "
1,100,000
ND
14 @MW-72 (12/92)
Cadmium
5 A »
5 A'
G", X"
210,000
5.3
120,000 @ IL-01 (3/93)
Calcium "
(no threat to human hcalih and the environment)
43,700
345,800 @ PW-41 (10/91)
T-2 . d
-------
TABLE 2 - CONTAMINANTS IN GROUNDWATER' AND GROUNDWATER CLEANUP CRITERIA {PERFORMANCE STANDARDS! - O.U. *1
LAGOON AREA - BOFORS-NOBEL SITE
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA' (opb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA ' (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA 4 (DDb)
PART 201
GROUNDWATER
CONTACT
CRITERIA1 (DDb)
BACKGROUND4
MAX CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yt) 1
Chromium (VI)
100 A'
100 A'
II
1,000,000
28.2
74 @MW-72 (12/92)
flCobalt
100
JO M
100
1,100,000
10
38 @MW-72 (12/92)
Copper
1.000 E'
1,000 E'
G"
8,100,000
64.7
120 @MW-72 (12/92)
|lron "
300 E»
300 E*
NA 4
IDIJ
768
35,400
HLead
4 1, '*
4L"
G,X ""
ID12
7.3
8,800 @MW-I10 (9/92)
Magnesium 17
1,200,000
420,000
NA5
1,000,000,000 D"
13,200
85,000 @MW-106 (9/92) |
Manganese
50 E»
50 E*
G,X '»•"
10,000,000
34
5,390 |
Mercury
2 A1
2 A*
0.2 M "
56 S'
02
1.3 |
Nickel"
100 A »
100 A '
G"
16,000,000
22.9 J
810 @ MW-110 (9/92) |
Potassium 17
(no threat to human health and the environment)
1930 J
16,500 1
Selenium
50 A •
50 A'
5
1,100,000
3 6 J
14,7 S
pilver
98
34
0.2M"
1,000,000
12.9
16,000 @MW-72( 12/92) [
jsodium "
450,000
160,000
NA '
1,000,000,000 D~
1430
1,610,000 |
Thallium
2 A *
2 A »
3.7 X 11
14,000
ND
30 @MW-110 (9/92) |
Vanadium
180
64
12
1,900,000
12.7 J
412 |
idinc
5,000 E *
2,400
G"
70,000,000
88.7
210,000 @ MW-72( 12/92)|
T-2 . e
-------
FOOTNOTES AND LEGEND FOR TABLE 2
(cc) Baseline risk assessment identified this contaminant as presenting a major Silt n>k Baseline risk assessment did not identify any inorganic contaminants as contaminants of
concern.
1	Data taken from Record of Decision and Landfill Remedy Remedial Design Maximums represent either the maximum shown in the ROD, or the maximum concentration
discovered during Rl> quarterly groundwater monitoring from mid-1992 to mid-1994. Maximum concentrations that have been noted with location and tmonth/year) ace KD data
AH other maximums are 1990 ROD and Rl data.
2	Industrial Drinking Water Standard is the cleanup criteria that are applicable to groundwater unless appropriate deed restrictions can not be obtained for future industrial land use, in
which case criteria for future residential land use would apply for groundwater
3	Residential Drinking Water Standard is the cleanup criteria that are applicable to groundwater for future residential land use
4	Groundwater - Surface Water Interface (GSI) Criteria are contaminant concentrations in groundwater which, if not exceeded, are protective of a surface water body that receives
such contaminated groundwater discharge These GSI limns must be maintained to insure protection of Big Black Creek.
5	Groundwater Contact Criteria arc contaminant concentrations in groundwater which, if not exceeded, arc protective of human health in the event of inadvertent human direct contact
with such contaminated groundwater
6	BACKGROUND - Background concentration taken from sample in relatively "clean" Site area as shown in the February 1990 Remedial Investigation (Rl) report For cleanup
standards noted by a 'B\ background concentrations may be used instead of the value shown.
7	S - Criterion is based on the chemical specific water solubility limit.
8	A - State of Michigan Drinking Water Criterion established pursuant to Section S of the Safe Drinking Water Act, Act No 399 of the Public Acts of 1976;
E - Criterion is the aesthetic drinking water value, as required by Sec. 20120(1 R5).
9	ND - Compound Not Detected in laboratory analysis.
10	M - Criterion is below the Method Detection Limit, therefore, the criterion defaults to the MDL, The Method Detection Limit is the lowest value accepted by the State of Michigan
that laboratory equipment can measure. If the Pan 201 cleanup criterion is lower than what the laboratory can delect, then the MDL becomes the cleanup criterion
11	N/L - Not Listed in Michigan Pan 201 Generic Industrial and Commercial Cleanup Criteria.
12	ID * Inadequate Data. The Stale of Michigan does not have enough health risk data to develop criterion for this contaminant.
13	X • The GSI criterion shown is not protective for surface water that is used as a drinking water source.
14	IP - Development of generic OSI value in pioccss but not yet complete.
15	W • Concentrations of trihaiome thanes in groundwater must be added together to determine compliance with (he Drinking Water Standard uf 100ppb.
16	NA - Not Available.
17	Contaminant discovered at the time of the 1990 ROD. but subsequently shown (by subsequent sampling and analysis) as not present, naturally occurring, or well below soil, air.
groundwater or surface water cleanup standard after appiopriatc U S. f.PA and MDfcQ review and approval See Table 3 for more detail
18	II - Standard is dependent on "hardnevi" of groundwater,  dependent upon water hardness in the area
19	L • For Lead, higher concentrations may be acceptable and criteria nwy Ik modified based on an acceptable site-specific demonstration subject to U S KPA/MUtQ review and
approval
20	D - Calculated groundwater criterion exceeds 100% and is reduced to 100 % Site - specific evaluation of contaminant status and adverse impacts subject to U S. EPA/MDfcQ
review and approval may be required.
DATA OUAUHER LEGEND
When chemical analysis data is submitted to U.S. EPA, limitations of analytical equipment must be noted with results so an accurate scrutiny can be performed These limitations arc shown
as qualifiers, noted as letters next to numerical values. Explanations of these qualifiers arc as follows:
• ••• Compound is noted as "unknown" because there were detections of organic chemicals, but specific identification of specific compound or isomer detected is unknown
J - Signifies a value thai was estimated. This means that the compound was detected by the analytical equipment but the value shown may not be able to be reproduced exactly if the
analysis were repeated.
B • Signifies a compound that was also detected in a blank. A blank is a 'clean' sample prepared in the laboratory, carried with field samples, transported, and stored If contamination is
found in a blank, there is a possibility that contamination may be from a source other than what was sampled (such as through faulty sampling, storage, transportation, or laboratory
procedures)
D - Signifies that the sample shown had to be diluted for the lab equipment lo show results that axe reproducible.
E • Estimated value due to deviations discovered in lab quality control (Qt.) procedure
T-2 . f
-------
TABLE 3 • COMPARISON OF SAMPLING AND ANALYSIS: BOFORS-NOBEL O.U. #1 LAGOON AREA
CONTAMINANT
MEDIA
OLD RESULT
(and SAMPLING
LOCATION)1 YEAR 1990'
(ppb or ppm as noted)
NEW RESULT
(and SAMPLING LOCATION)1
LANDFILL RD-Q *7
(June 1994'), or as otherwise noted
NEW RESULT
(and SAMPLING
LOCATION)'
YEAR 1997*
(oab or mm as noted)
Acenapthene

20 ppb (LW-3)'
ND
< 50 U ppb (W-l; MW-43) *

Soil/Studge
ND>
N/A"
< 310 U ppm (L-9)
Accnaptiiylene
Gro—dwtr
21 ppb (LW-3)1
ND'
< 50 U ppb (W-l; MW-43)'
Footnote (12)
Soii/Stadge
MD'
N/A"
<310U ppm (L-10)
Acetone
GraaMhmer
11.000 ppb (WC-2)>
ND'
25,000 ppb (W-l; MW-43)'

Soil/SM*
0.091 ppm (L-9)
N/A"
< 240 U ppm (LS-9) j
Alkyl benzene isoaien'
Groundwater
ND»

N/A"

Soil«M|t
141.000 J ppm (L-9)

N/A"
Aniline (cc)
Graaadwaer
10.000 ppb (WC-27)
7SO D ppb (PW-34)
100 ppb (W-l; MW-43)

Soil/Stodfe
3.900 ppm (L-9)
N/A"
< 310 If ppm (L-9)
Anthracene
Groundwater
14 J ppb (LW-3)
ND'
< SOU ppb (W-l; MW-43)
Footnote (13)
So4/SJ*%e
I.I J ppm (SS-38)
N/A"
< I50Uppm(L-10)
Azobenzene (cc)
Groundwater
20 J ppb(PW-41)
ND'
N/A"

Soil/Sludge
12.000 ppm (L-3)
N/A"
N/A"
Azoxybenzene
Groundwater
ND'



Soil/Sludge
6901 ppm (L-3)
N/A14
N/A"
Benzene
Groundwater
65,000 ppb (WC-27)
9400 ppb (PW-34)
39,000 ppb (W-l; MW-43)

Soil/Sludge
980 ppm (L-3)
N/A"
84 ppm (L-9)
Benzeneaceiic Acid
Groundwater
140 J ppb (WC-2)'
N/A
N/A
Footnote (12)
So«Sludgc
ND'
N/A"
N/A"
Benzidine (cc)
Groundwater
1300 ppb (MW-IOt)
1600 D ppb (MW-60)
110 ppb (P-108 D) J

Sort/Sludge
3.400 ppm (L-3)
N/A"
< 950 U ppm (L-9) |]
Benzo(a)inthracenc
Groundwater
19 J ppb (LW-3)
ND*
< 50 U ppb (MW-43)
Footnote (1 J)
Soil/Sludge
4 3 ppm(SS-3»
N/A"
< 310 U ppm (LS-9)
Benzo(a>pyrene
Groundwater
230 ppb (LW-3)
ND'
< 50 U ppb (W-l. MW-43)
J Footnote (12)
SortS Kid |e
ND'
N/A"
< 150 U ppm (L-10)
1 Benzothiazole isomer
Groundwater
ND'
N/A
N/A"
| Footnote (12)
Soil/Sludge
ND'
N/A"
N/A"
I 1.2.3 - Benzothiadiazole
Groundwater
1300 J ppb (WC-27)
N/A
N/A
| Footnote (12)
Soil/Sludge
ND'
N/A"
N/A
T-3. a
-------
TABLE 3 - COMPARISON OF SAMPLING AND ANALYSIS; BOFORS-NOBEL O.U. LAGOON AREA
CONTAMfNANT
MEDIA
OLD RESULT
(and SAMPLING
LOCATION)* YEAR 1990'
(ppb or ppm as noted)
NEW RESULT
(and SAMPLING LOCATION)'
LANDFILL RD - Q #7
(June 1994'). or as otherwise noted
NEW RESULT
(and sampling
LOCATION)'
YEAR I99r
Iggkornm ti noted)
Benzyl Alcohol
Groundwater
$ J ppb (LW-3)
ND'
N/A
Footnote (1 J)
Soti/Sludpe
WD'
WA"
N/A
II Bii<2-eih)rlhexyl)phthalate
Groundwater
«OOOJppb(MW-7)
10) ppb (MW-102)
21 BJ ppb (P 108)
170 E ppb(PW 36)
110 ppb (PW 37)
<	S U ppb (MW-60)
<	5 U ppb (P 103)
<	5 U ppb (P 108)
<	SUJppb(MW 110)
I
Soil/Sludge
119 J ppra (SS-57)
N/A"
< 310 U ppm (L-9)
Bromodichloromethane
Groundwater
ND'
N/A
N/A
Footnote (12)
Soil/Sludge
ND'
N/A"
N/A
Bromofomi
Groundwater
ND'
ND1
<	5 UJ ppb (MW-44)
<	500 U ppb (MW-43)
Footnote (12)
Soil/Sludge
ND'
N/A*
< 2* ppm (L-9)
Bromomethane
Groundwater
ND1
ND '
< $00 U ppb (MW-13)
Footnote (12)
Soil/Stodge
ND'
N/A"
< 24 (J ppm (L-9)
2-Buunone (MEK.)
Groundwater
ND'
ND'
< 25.000 ppb (MW-43)

Soil/Sludge
0.02S ppm (L-9)
N/A "
< 240 ppra (L-9)
Cvbon DitullKk
Groundwater
1000 ppb (LW-3)
ND*
< 2.500 U ppb (MW-43)

Soil/Sludge
ND'
N/A"
< 240 U ppm (L-9) fl
Carbon Tetrachloride
Groundwater
ND1
NO '
< 500 U ppb (MW-43)
Footnote (12)
Soil/Sludge
ND'
N/A"
< 24 U ppm (L-9)
2-Cfiloro aniline
Groundwater
63.000 ppb (WC-27)
1.600 D ppb (MW-62)
< SOU ppb (MW-43)

4 8 ppb (MW-60)
<	500 U ppb (MW-43)
<	1 U ppb (MW-60)

Soil/Sludge
^D>
N/A"
< 24 L' ppm (L-9)
(3-Chloroph«n)rl) (4-
Chlorophenyl) Meihanone
Groundwater
700 J (WC-27)
N/A
N/A
Footnote (13) | Soil/Sludge
6.200 ppm (L-9)
N/A"
N/A
T-3 . b
-------
TABLE 3 - COMPARISON OF SAMPLING AND ANALYSIS: BOFORS-NQBEL O.U, *1 LAGOON AREA
CONTAMINANT
MEDIA
OLD RESULT
(and SAMPLING
LOCATION)1 YEAR 1990'
(ppb or ppm at noted)
NEW RESULT
(and SAMPLING LOCATION)'
LANORU. RD-Q #7
(Junel994)), or ai otherwise noted
tub or oon at noted)
NEW RESULT
(and SAMPLING
LOCATION)1
YEAR 1997*
Chrywnc
Groundwater
19 J ppb (LW-3)
1J ppb (PW-39)
< 50 U ppb (MW-43)
Footnote (ID)
Soil/Sludge
6. J pptn (SS-38)
N/A"
< 310 U ppm (L-9)
Dibenzofuran
Groundwater
IIJ ppb (LW-3)
ND»
< $0 U ppm (MW-43)
Footnote (12)
Soit/Sludge
HO'
N/A *
< 310 U ppm (L-9)
DtbromocNofometium
Groundwater
ND*
ND'
N/A
Footnote (12)
Soil/Sludge
ND*
N/A"
N/A
DichJorobromomethane
Groundwater
ND'
ND'
< 500 U ppb (MW-43)
Footnote (12)
Soil/Sludge
ND*
N/A"
< 24 U ppm (L-9) d
J J'-OkJilorobenztdtae (and
iwmcn) (oc)
Groundwater
1,900 ppb (WC-27).
2,600 ppb (PW-41)
210 0 ppb (PW-34)
< 200 U ppb MW-4) |
47 ppb (MW-l 10) I
46 ppb (QW-101) 1

Soil/Sludge
11,000 ppni (L-9)
N/A"
4,900 ppm (L-9) J
1 .2-Dichlorobenjxne
Groundwater
400 ppb (L WO)
IQ0ppb(PW*39)
< 500 U ppb (MW-43) |

Soil/Sludge
7.5 J ppm (SS-57)
N/A'*
< 24 U ppm (L-9)
1,1 -DictikMoeduuK
Groundwater
ND'
ND'
< 500 U ppb (MW-43)
Footnote (12)
Soil/Sludge
ND'
N/A"
<24 U ppm (L-9)
1,2-Dichloroethane
Groundwater
110 ppb (PW-33)
ND*
< 500 U ppb (MW-43)
<1 U ppb (MW-l 10)

Soil/Sludge
ND1
N/A"
< 24 U ppm (L-9)
1.1-Dicbloroctltene
Groundwater
ND'
34 J ppb (PW-33)
< 500 U ppb (MW-43)

Soil/Sludge
ND'
N/A"
< 24 U ppm (L-9)
1.2-Dichloroethene
(and isomers)
Groundwater
1,900 ppb (LW-3)
2.400 (PW-33)
<	1,000 U ppb (MW-43)
<	2 UJ ppb (MW-l 10)

Soil/Sludge
ND'
N/AM
N/A
i ,2-Bichloroprapjow
Groundwater
ND*
NO'
< 500 U ppb (MW-43)
Footnote (12)
Soil/Sludge
ND'
N/A"
< 24 U ppm (L-9)
1 J-Dkchloropropcnc 
-------
TABLE 3 - COMPARISON OF SAMPLING AND ANALYSIS: BOFORS-NOBEL O.U. U1 LAGOON AREA
CONTAMINANT
MEDIA
OLD RESULT
(¦*) SAMPLING
LOCATION)1 YEAR 1990'
(ppb or ppm as noted)
NEW RESULT
(and SAMPLING LOCATION)'
LANDFILL RD - Q #7
(June 1994'), or as otherwise noted
(nob or mm n noted)
NEW RESULT
(and SAMPLING
LOCATION)'
YEAR 1997*
(nob or Bum u noted)
Dimethyl phthalate
Groundwater
120 J ppb (LW-4)
ND'
< SO U ppb (MW-43) |

Soil/Sludge
ND'
N/A"
< 310 U ppm(L-9) U
I Dimethylbenzenimine
Groundwater
780 J ppb (LW-4)
N/A
N/A |
Footnote (12)
Soil/Sludge
ND'
N/A"
N/A J
DtmetfiylnapthaJenc
Groundwater
52 J ppb/WC-2)
N/A
N/A
Footno«e(l2)
Soil/Sludge
ND'
N/A"
N/A
Di-n-8ulyiphihalate
Groundwater
S Jppb(MW-51)
1 BJ ppb (MW-41)
1 BJ ppb(MW-63)
1 J ppb (P-108)
1 J ppb (PW-36)
1 J ppb (PW-40)
<	SO UJ ppb (MW-44)
<	50 U ppb (MW-43)

Soil/Sludge
ND'
N/A"
< 310 U ppm (L-9)
Di-n-Octylphthalale
Groundwater
ND '
36ppb(PW-3t);
23 ppb (MW-63);
459 ppb ^ PW-40-01 (Q I (6/92))
<	50 UJ ppb (MW-44)
<	SOU ppb (MW-43)

Soil/Sludge
ND4
N/A"
< 310 L: ppm L-9
2.4-Dimtro phenol
Groundwater
ND 1
ND '
<	200 UJ ppb (MW-44)
<	200 U ppb (MW-43)
Footnote (12)
Soil/Sludge
ND '
N/A"
< 1600 U ppm (L-9) |j
M'-Diphenyl- 2.2-Diamine
Groundwater
3.2001 ppb (MW-106)
12 ppb (MW-62)
N/A |
Footnote (13)
Soil/Sludge

N/A"
N/A
2J-Dihydrndimeif>yl-1H-
Indene
Groundwater
42 J ppb (WC-2)
N/A
N/A
Footnote (12)
Soil/Sludge
ND'
N/A"
N/A
Fthylben/ene
Groundwater
3 J ppb(MW-UO)
120 ppb (PW-41)
< 500 U ppb (MW-43)

Soil/Sludge
9.2 ppm(L-6)
N/A"
< 24 U ppm (1.-9)
Fluoranthene
Groundwater
16 J ppb (LW-3)
ND'
<50 UJ ppb (MW-44).
< 50 U ppb (MW-43)
J Footnote (13)
Soil/Sludge
14 ppm (SS-3S)
N/A"
< 310 U ppm (L-9)
1 Fluorine
Groundwater
16 J ppb(LW-3)
ND *
< 50 U ppb (MW-J3)
| Footnote (12)
Soil/Sludge
ND'
N/A"
< 310 U ppm (L-9)
2-Hydroxybcnzonitrik
Groundwater
44 J ppb (MW-102)
N/A
N/A
Footnote (12)
Soil/Sludge
ND '
N/A"
N/A
T-3 .d
-------
TABLE 3 - COMPARISON OF SAMPLING AND ANALYSIS: BQFORS-NOBEL O.U. »1 LAGOON AREA
CONTAMINANT
MEDIA
OLD RESULT
(and SAMPLING
LOCATTONV YEAR 1990'
(ppb or ppa at noted)
NEW RESULT
(and SAMPLING LOCATION):
LANDFILL RD-Q#7
(Joael9941), or at otherwise noted
(tmb or oom ti noted)
NEW RESULT
(md SAMPLING
LOCATION) :
YEAR 199r
laoh or nun u noted)

I 4-hydroxy-4-methyl-2-
¦ pcntanone
Groundwater
190 J ppb (WC-2)
N/A
N/A
Footnote (12)
Soil/Sludge
ND'
N/Au
N/A j

liophorone
Groundwater
t.400ppb(LW-4)
7.2 ppb (PW-33)
< 5 UJ ppb (MW-110; 55') |

Soil/Sludge
ND'
N/A"
< 310 / ppm (L-9) 1
2-Mettiylnaptfiaiaat
Groundwater
00 ppb (WC-2)
ND'
< 50 U ppb (MW-43) 1
| Footnote (1J)
SoiVSIudfe
35 J ppb (SS-22)
N/A'4
<310 U ppm (L-9) j
| 2-Metfiylpttenol
Groundwater
470 ppb (WC-2)
21 PW-34
<5Uppb(P-IOt;6V)

1
Soil/Sludge
5.71 ppm(SS-57)
N/A"
< 310 U ppm (L-9)
| 4-Methylphenol
Groundwater
170 ppb (WC-2)
II ppbtPW-39)
< ill) ppb (MW-110; 55')
I
Soil/Sludge
ND'
N/A"
< 310 U ppm (L-9)
J 1 -Methoxywitrobumnt
Groundwater
22,000 J ppb (WC-2T)
N/A
N/A
| Footnote (12)
Soil/Sludge
ND'
N/A"
N/A
| 1 -MetfcylrapJtthaJene
Groundwater
490 / ppb (WC-21
N/A
N/A
Footnote (121
Soil/Sludge
SO'
N/A"
N/A
2-Meth> Inaphihalene
Groundwater
480 ppb (WC-2)
ND
< 50 U ppb (MW-43)

Soil/Sludge
35 ) ppb (SS-22)
N/A"
< 310 U ppm (L-9)
Methoxybenzeneainine
Groundwater
21.000 / ppb (LW-I)
N/A
N/A ]

Footnote (12)
Soil/Sludge
ND'
N/A"
N/A 1
Methylene Chloride (cc)
1 (D»chlorotnelh*n«)
Groundwater
1400 J ppb (WC-2)
5 2 J ppb (PW-41)
< 500 U ppb (MW-43) 1

Soil/Sludge
2.2ppm(L-6)
N/A"
< 24 U ppm (L-9)
1 N-nitroso-Di-n-Propylamine
Groundwater
6) ppb(MW-102)
NO'
<	50 U ppb (MW-43)
<	50 U ppb (MW-44)

| Footnote (13)
Soil/Sludge
ND'
N/A"
< 310 U ppm L-9
| Napthalene
Groundwater
550 ppb (WC-2)
1 J ppb (PW-34)
<5 UJ ppb (P-108; 60")
< 50 U ppb(PW-43)
1
Soil/Sludge
6 7 Jppn(SS-57)
N/A"
< 310 U ppm (L-9)

Nitrobenzene
Groundwater
6.500 ppb (WC-27)
ND'
< 50 U ppb (MW-43)

Soil/Sludge
NO'
N/A"
< 310 U ppm (L-9)

Pttenanthrene
Groundwater
19 Jppb(LW-3)
ND1
< 50 U ppb (MW-43) |

Soil/Sludge
7 ppm (SS-3J)
N/A"
< 310 U ppm (L-9) ||
T-3. e
-------
TABLE 3 - COMPARISON OF SAMPLING AND ANALYSIS: BOFORS-NOBEL O.U. *1 LAGOON AREA
CONTAMINANT
MEDIA
OLD RESULT
(and SAMPLING
LOCATION/ YEA* 1990*
(ppb or ppm as aottd)
NEW RESULT
(and SAMPLING LOCATION)!
LANDFILL RD - Q #7
(June 1994'), or as otherwise noted
(oob or oom as noted)
NEW RESULT
(and SAMPLING
LOCATION)'
YEAR 1997'
(sob or mm as noted)
Phenol
Groundwater
170 J ppb (LW-I)
65 DJ ppb (PW-34)
< 5 U ppb (P-108)

Soil/Sludge
3 2Jppm(SS-57)
N/A"
< 310 U ppm (L-9)
Pyrcne
Groundwater
27 ppb (LW-3)
ND'
< 50 U ppb (MW-43)
Footnote (13)
Soil/Sludge
9.9 ppm (SS-31)
N/A"
< 310 U ppm (L-9)
Sulfur
Groundwater
IS001 ppb (LW-I)
N/A
N/A
Footnote (12)
Soil/Sludge
8.3 ppm (1-7)
N/A"
N/A
1,1' - Sulfonyl - bis (2-Methyl)
Benzene
Ground* tier
ND'
12ppb (PW-41)
N/A
Footnote <13)
Soil/Sludge
12 ppm (I-10)
N/A"
N/A
Tetrachloroethylene
Groundwater
18.000 ppb (LW-3)
4,100 ppb (PW-39)
< 500 U ppb (MW-13)

Soil/Sludge
0.68 ppm (L-I)
N/A"
<0.021 U ppm (L-8)
1.1.2 ,2-Tctrachloroethane
GroundwMer
ND*
9 J ppbpene isomer
Groundwater
36 J ppb (MW-I0J)
nva
N/A
Footnote (12)
Soil/Sludge
^D'
N/A"
N/A
I.I.I - Trichloroeth jne
Groundwater
ND'
ND >
< SOO U ppb (MW-43)
c 1 U ppb (ALL OTHER)
| Footnote (12)
Soil/Sludge
ND'
N'A"
< 24 U ppm (L-9)
1.1,2-Trichloroethane
Groundwater
ND'
ND1
< 500 U ppb (MW-43)
c 1 U ppb (ALL OTHER)
Footnote (12)
Soil/Sludge
ND'
N/A"
< 24 U ppm (L-9)
Trichloroethylene
Groundwater
43 ppb (PW-41)
2.100 ppb (PW-33)
<	500 U ppb (MW-13)
4 8 ppb (MW-60)
<	1 UJ ppb (MW-110)

Soil/Sludge
ND J
N/A"
< 24 U ppm (L-9)
3.3,5-Tnmethylcyclohexanone
Groundwater
31 J ppb (MW-106)
600 D ppb (PW-33)
N/A
Footnote (13)
Soil/Sludge
ND'
N/A"
N/A
T-3 . f
-------
TABLE j - COMPARISON OF SAMPLING AND ANAlYSlft BOFOEfrNQBP, OA). »\ LACQQN ARjA
CONTAMINANT
MEDIA
OU) RESULT
(and SAMPLING
LOCATION)1 YEAR 1990'
CpfA or ppm M noted)
NEW RESULT
(and sampling location) '
LANDFILL RD-Q *7
(June 1994'), or m otherwise noted
NEW RESULT
(and SAMPLING
LOCATION)'
YEAR I99r
Trimp (Inmeihylphenoli!
Groundwater
2,000 J ppb (LW-4)
260 D ppb (PW-33)
N/A
Footnote (13)
Soil/Sludge
MO'
N/A14
N/A
1.2.4-Trithiolane
Groundwater
»20 J ppb (WC-27)
N/A
N/A
Footnote (12)
Soil/Sludge
ND>
N/A"
N/A
I J.S-Trittilanc
Groundwater
1001 ppb (WC-27)
N/A
N/A
Footnote (12)
Soil/Sludge
ND'
N/AM
N/A II
Unknowns ****
Groundwater
100.500 ppb (WC-27)
100,500 J ppb (LW-1)
70 ppb (PW-31)
N/A 1

Soil/Sludge
503 J ppm (L-6)


Vinyl Chloride
Groundwater
1,000 ppb (PW-33)
760 ppb (PW-33)
< 1 UJ ppb (MW-110; 55')

Soil/Sludge
ND'
N/A"
< 24 U ppm (L-9)
Xylenes (total)
Groundwater
100 ppb (PW-41)
50 ppb (PW-41)
« 3 U) ppb (P-IOI; 601
< 1500Uppb(MW-«3) j

Soil/Sludge
SI ppm (L-6)
N/A"
< 7| U ppm (L-9)
Aluminum
Groundwater
23.200 ppb (WC-27)
6,100ppb (3/93) 3MW-IM
N/A

Soil/Sludge
7920 ppm SL-5)
3770 ppm BKCD ¦

N/A
Antimony
Ground water
61 ppb (MW-4S)
ND1
N/A
Footnote ( 12)
Soil/Sludge
25 ppm(L-l)
ND'BKGD -

N/A
Arsenic
Groundwater
74 ppb (WC-27)
13 ppb(9/92) @ MW-110
1.2 ppb (P-iOi) "
< 1 U ppb (MW-43)

Soil/Sludge
44 ppm (L-l)
17 ppm BKGD"

N/A
Barium
Groundwater
174 J ppb (PW-33)
64 ppb (12/92) (g MW-72
< 10 UJ ppb (MW-110; 55")
65 ppb (MW-60)

Soil/Sludge
IS ppm (L-l)
12.6 ppm BKGD

N/A
T-3. g
-------
TABLE 3 - COMPARISON OF SAMPLING AND ANALYSIS; BOFORS-NOBEL O.U. #1 LAGOON AREA
CONTAMINANT
MEDfA
OLD RESULT
(and SAMPLING
LOCATION)' YEAR 1990'
(ppb or ppm as noted)
NEW RESULT
(and sampling location) '
LANDFILL RD-Q #7
(June 1994'), or as otherwise noted
(oob or mm is noted)
NEW RESULT
(«* SAMPLING
LOCATION)2
YEAR 1997*
(oob or Dom as noted) 11
Beryllium
Groundwater
ND'
14 ppb (12/92) 
-------
TABLE 3 . COMPARISON OF SAMPLING ANn ANALYSIS: BOFORS-NOBEL O.U. 01 LAGOON AREA
CONTAMINANT
MEDIA
OLD RESULT
(and SAMPLING
LOCATION)1 YEAR 1990'
(ppb or ppm as noted)
NEW RESULT
(and SAMPLING LOCATION)'
LANDFILL RD-Q»7
(June 1994'). or as otherwise noted
look at nnn g nottd)
NEW RESULT fl
(and SAMPLING |
LOCATION)' II
YEAR 1997" 1
(nob or oomaa noted! II
Mercury
Groundwater
1.3 ppb (WC-27)
0 3 ppb (12/92) (g MW-72
<0.2 U ppb (ALL) |

Soil/Sludge
0.71 pprn(LO)
ND> BKGD "

N/A |
Nickel
Groundwater
72.9 ppb (WC-27)
810 ppb (9/92) @MW-I10C
N/A |

Soil/Sludge
IS. I ppra(L-9)
ND *BKGD -

N/A 1
Potassium
Groundwater
16.500 ppb (LW-3)
9,300 ppb (9/92) @ MW-I06C
2.7 ppm MW-44
1 9ppmMW-43
| Footnote (12)
Soil/Sludge
394 ppm L-f
(6.4 ppm BKGD "

N/A
j Selenium
Groundwater
14 7 J ppb (MW-102)
ND'
< 2 U ppb ALL

Soil/Sludge
J.3 ppm (L-3)
IND' BKGD "

N/A
Silver
Groundwater
15.9 ppb (MW-91)
16.000 ppb (IZ/92)@ MW-72-01
< 0.2 U ppb (ALL)

Soil/Sludge
15.6 ppm (L-1)
ND» BKGD "

N/A
Sodium
Groundwater
161.000 ppb (WC-27)
123.000 ppb (6/92) @ PW-34-01
255 ppm (MW-44)
136 ppm (MW-43) J
Footnote (12)
Soil/Sludge
5.920 ppm (L-3)
ND1 BKGD'"

N/A U
Thallium
Groundwater
ND'
30 ppb (9/92) (3 MW-I IOC-01
N/A
Footnote (1 J)
Soil/Sludge
ND'
ND BKGD »

N/A
Vanadium
Groundwater
412 ppb (WC-27)
39 ppb (12/92) @ MW-72-01
N/A

Soil/Sludge
28 6 ppm (L-l)
48 ppm BKGD "

N/A
Zinc
Groundwater
3.010 ppb (WC-27)
210.000 ppb (12/92)@ MW-72-01
1.190 ppb (MW-44)
650 ppb (MW-60)
< 20 U ppb (MW-43)

Soil/Sludge
91.200 ppm (L-3)
lilt m WW"

N/A
T-3. i
-------
FOOTNOTES AND LEGEND FOR TABLE 3
(cc> Baseline risk assessment identified this contaminant as presenting a major Site risk. Baseline risk assessment
did not identify any inorganic contaminants as contaminants of concern,
1	Data taken from Record of Decision and February 1990 Remedial Investigation (RI) Report. To convert ppb
to ppm, divide by 1000 and vice versa (ppm to ppb, multiply by 1000).
2	See Figure 3A - Site Layout and Sampling Locations.
3	Data taken from 7th quarter (June 1994) of quarterly groundwater monitoring performed by USACE for
Remedial Design of Landfill Remedy. Although analysis for inorganic contaminants was discontinued after
Quarter 4 of the RD monitoring program, maximums prior to June 1994 are noted with (month/year).
4	Data taken from document entitled "Technical Memorandum, Total In-Situ Containment Conceptual Design -
Bofors-Nobel Superfund Site", dated September 9, 1997, (the "Tech Memo") available for review in the
Administrative Record.
5	ND - Compound Not Detected in laboratory analysis.
6	Sampling location W-1 is in close proximity to monitoring well that was labeled MW-43 for sampling
performed for the February 1990 Remedial Investigation (Rl) Report.
7	Aikylbenzene isomers are compounds that show laboratory results ("hits") similar to Toluene, Ethylbenzene,
and Isopropylbenzene (all are "Alkyl benzenes"). Sampling and analysis during the new Remedial Design
and Remedial Action will target specific alkyl benzene contaminants.
8	Tentatively Identified Compound. Compound is noted as such because there were detections of organic
chemicals, but specific identification of specific compound or isomer detected is unknown.
9	Benozthiazole isomer was not listed in the RI. This may have been a compound later identified for analysis
in the Landfill Remedial Design, but subsequent sampling events did not include this contaminant, and thus
may no longer be a concern.
10	BKGD - background; sampling and analysts from a "clean" area of the Site performed during the Remedial
Investigation.
11	Portion of inorganic compound or element that is dissolved in groundwater.
12	Contaminant discovered at the time of the 1990 ROD, but subsequently shown (by subsequent sampling and
analysis) as not present, naturally occurring, or well below soil. air. groundwater, or surface water cleanup
standard after appropriate U.S. EPA and MDEQ review and approval. Monitoring for this contaminant may
no longer be necessary.
13	Contaminant will be monitored and, because there is no GSI siandard, must either be below laboratory
detection limits (ND), or. must be demonstrated as not posing any threat to human health and the
environment. This demonstration may include toxicity testing as required.
14	N/A - Not analyzed. There was no chemical analyses performed on lagoon area soil or sludge during the
Landfill Remedy Remedial Design.
DATA QUALIFIER LEGEND
When chemical analysis data is submitted to U.S. EPA, limitations of analytical equipment must be noted with results
so an accurate scrutiny can be performed. These limitations are shown as qualifiers, noted as letters next to numerical
values. Explanations of ihese qualifiers are as follows:
Compound is noted as "unknown* because there were detections of organic chemicals, but specific
identification of specific compound or isomer detected is unknown.
J - Signifies a value (hat was estimated. This means that the compound was detected by the analytical
equipment but the value shown may not be able to be reproduced exactly if the analysis were repeated.
E - Estimated value due to deviations discovered In lab quality control (QC) procedure.
U - Contract Required Quantitation Limit - This signifies that the value shown with a "U" was the lowest
reproducible limit that the laboratory equipment could detect.
D- Diluted sample
T-3. j
-------
TABLE 4 - RISK IDENTIFIED ' FOR BOFORS-NOBEL O-tl. tft LAGOON AREA
EXPOSURE PATHWAY
RESIDENTIAL CARCINOGENIC RISK IDENTIFIED IN 1990 ROD' j
Groundwater
3.4e-05 to 9.9e-0l ' |
Soil Ingestion
1
2e-10 to 2e-03 '
Soil Direct (Dermal) Contact
7.9e-09 to I e-05
Air
7.9e-09 to 1,2e-03 5
Surface Water (Computer Modeled)
3.4e-07 to le-02 *
CUMULATIVE (TOTAL) RISK
3.4 e -05 to 1.0 e-00
FOOTNOTES FOR TABLE 4
1	information from September 1990 Record of Decision and February 1990 Remedial Investigation (Rl)
Report.
2	Risk uses a basis of a 70 year life time. A I 0 e-06 cancer risk value corresponds to a I in 1,000,000
chance that an individual develops cancer as a result of exposure to these concentrations of contaminants
over a period of 70 years. Similarly, 1.0 e-05 corresponds to a I in 100,000 chance, 1.0 e-04,1 in 10,000,
and so on. U.S. CPA may perform a Remedial Action if cancer risks are greater than 1.0 e-04, or a Hazard
Index of 1.0 or greater.
3	Calculated in 1990 by computer models ("SeSOIL" and "AT123D") which simulated contaminant release
as leachate from soil and sludge.
4	Taken from February 1990 Remedial Investigation (RI) Report, Chapter 6. Original risk calculations based
on limited availability of carcinogenic potency information, and computer models noted in Footnote (3). A
fundamental requirement for this remedy is a lagoon area cover that must prevent all unacceptable contact
with contaminated sludge and/or soil.
5	Calculated in 1990 by a computer model ("ISCLT"), that assumed "worst-case" volatilization of organics
from lagoon area sludge.
6	Surface water risks calculated in 1990 by a computer model ("EXAMS-II") that simulated the fate of
contaminants in groundwater discharging to a surface water body. State of Michigan Groundwater-Surface
Water Interface (GSI) Standards will be the performance criteria for this remedy and will insure protection
of Big Black Creek. In addition, the continuation of adequate capture of contaminated groundwater before
discharge to the Creek (which has been in operation since the mid-1970s) is a fundamental requirement for
this remedy, and thus the surface water exposure pathway will continue to be eliminated.
T-4
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TABLE S - CAPITAL COSTS REQUIRED FOR TIC REMEDY '
projf.pt activity
OIJANTITY
I [NIT COST
COST
Lagoon Area surface cleanup and earthwork 2
15 acres *
S 16,118 / acre
S 241,770
Lagoon Area Cap construction (including seeding, mulching, etc.)'
15 acres *
S 33.306 / acre
S 499,590
Planting of vegetation (Areas A,B,C,D, including fertilizer) *
17 acres *
S 68,000 / acre
$ 1,156.000
Monitoring (start-up) of instilled vegetation (1st 5 years)
including replacement (if needed)
20 acres *
S 26,750 / acre
$ 535,000
Barrier Wall installation '
2700 feet
$ 1,175/foot
$3,172,500 J
Groundwater Extraction System 4
Lump Sum

$ 798,480 |
Constructed Wetland '
Lump Sum

S 508,650
Retrofit existing GWTP for TIC Remedy '
Lump Sum

S 395.000
Replacement GWTP (after 5 years) '
Lump Sum

$ 675,000
Installation of Monitoring Wells 10
30 wells
S 5,667 each
S 170.000
SUBTOTAL
v///
y/M
S 8,151,990
Cost Estimate Contingency (25 %)
Y//A
/////
S 2,038,000
MINIMUM CONSTRUCTION CAPITAL FUNDING
////.
/////
SI0.189 990
Contingent Action - Upgrade of cap impermeability "
15 acres
S 94,600 / acre
S 1.419.000
Contingent Action - Maint. and/or Repair of Const Wetland 12
Lump Sum

S 793,770
Contingent Action - Restore/enhance installed vegetation "
Lump Sum

S 621,840
Contingent Action - Additional Barrier Wall (including design)
Lump Sum

S 723,520
Contingent Action - Install 10 New Extraction Wells in addition to
Barrier Wall
10 wells
500 ft. piping
Si0,000 each
£ 35/ft pipe
S 117,500
SUBTOTAL OF CONTINGENT ACTIONS
v///,
'///A
S 3,675,630
Cost Estimate Contingency (25 %)

yXv/
S 918.910
ADDITIONAL CONSTRUCTION CAPITAL FUNDING
RF.OI JIRF.D FOR CONTINGENT ACTIONS

yy/A
$ 4,594.540
TOTAL CONSTRUCTION CAPITAL INCLUDING
CONTINGENT ACTIONS


$ 14,784.530
REMEDIAL DESIGN (RD) COST FOR TIC REMEDY 14


S 5,450,000
MINIMUM CONSTRUCTION CAPITAL


$ 10,189,990
1 TOTAL MINIMUM PROJECT COST


$ 15,639,990
T-5. a
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FOOTNOTES FOR TABLE 5
* Actual lagoon and sludge surficiii ire* totals approximately 15 acres (see Figure 3). A value of 17 acres is
estimated for planted vegetation to include 2 additional acres for integration of vegetation into natural
vegetation existing at the lagoon periphery. An allowance of 20 acres is used for monitoring and includes 5
acres as contingency.
1	All values shown are approximate aad are included for ROD Amendment purposes. Cost estimates have been
provided in the document entitled "Technical Memorandum, Total In-Situ Containment Conceptual Design -
Bofors-Nobel Superfund Site" dated September 9, 1997, (the "Tech Memo") available for review in the
Administrative Record. These cost estimates will be further refined during the RD.
2	Table 8-4 of 9/9/97 Tech Memo - Items I through 9.
3	Table 8-4 of 9/9/97 Tech Memo - Items 10 through 17, including an allowance for field work completion
document.
4	Table 8-5 of 9/9/97 Tech Memo - Items I through 12, including dust control during construction. Areas A, B,
C, and D are designations that represent different vegetative species, with Area A containing the highest
concentrations of contaminants.
5	Table 8-6 of 9/9/97 Tech Memo - Items I through 14.
6	Table 8-8 of 9/9/97 Tech Memo - Items 1-13. This task entails retrofit of existing extraction well system and
construction of collection, extraction, discharge point in concert with barrier wall (such as control weir and/or
valving).
7	Table 8-7 of 9/9/97 Tech Memo - Items 1 through 17.
8	Table 8-9 of 9/9/97 Tech Memo - Items I and 2. This task entails consideration of using a portion of the
already operating U.S. EPA GWTP and/or retrofit, if feasible.
9	Table 8-11 B of 9/9/97 Tech Memo. This is the possible GWTP replacement with a smaller, alternative
GWTP and lower extraction rates created by the barrier wall. Cost shown is discounted value to Year 2002.
10	Table 8-10 - Item 1, and Table 8-11A - Items I through 3 of 9/9/97 Tech Memo. Capital allowance represents
a one-time monitoring well installation capital cost for both measurement of barrier wall effectiveness and
potential natural attenuation. Short- and Long-Term Monitoring costs are included in Table 6, which
summarizes annual costs for operation and maintenance and monitoring.
11	Table 8-4 of 9/9/97 Tech Memo.
12	Table 8-7 of 9/9/97 Tech Memo.
13	Table 8-5 of 9/9/97 Tech Memo. Nutrients, installation of'tube' protection through highest contamination
layer, and supplemental Zone A re-planting included in this contingent task.
14	Tables 8-10 and 8-13 of 9/9/97 Tech Memo. Includes all costs for RD sampling and analysis activity
including all quality assurance and work plans.
T-5. b
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TABLE 6 - PRESENT WORTH OF QAM AND MONITORING COSTS' FOR TIC REMEDY
PROJECT ACTIVITY
ANNUAL
COST1
PROJECT
YEAR
FROM - TO
YEARS
AWAY
FROM
JSSLI
P/F
FACTOR"*
(@ 5%)
ANNUAL
COST
DISCOUNTED
TnVFAB,OOQ
TIME
PERIOD
IN
P/A
FACTOR1
m 5%)
PRESENT
WORTH IN 1999
DOLLARS*
Groundwater Monitoring During RD/RA Activity
(1st 2 years, quarterly)i
$ 80,000
1999-2002
0
1.0
$ 80,000
2.722
$ 217,760
Post-construction Groundwater Monitoring'
$ 70,000
2002 - 2007
0.864
$ 60,480
4 331
$ 261,940
Long Term Groundwater Monitoring
$ 70,000
2007 - 2032
0.677
S 47,390
25
14.096
S 668,010
Long Term Groundwater Monitoring1
$ 50,000
2032- 2102
33
0.200
$ 10,000
70
19.343
$ 193,430
Operation of Existing GWTP *
$ 600,000
1999 - 2002
1.0
$ 600,000
2.722
$ 1,633,200
Operation of Existing Extraction Well Field*
$ 150,000
1999-2002
1.0
$ 150,000
2,722
S 408,300
i. {Operation of Existing GWTP
h.
$400,000
2002 - 2007
0.864
$ 345,600
4.331
$ 1,496,800
Operation of Existing Extraction Well Field1
$ 100,000
2002 - 2007
0 864
$ 86,400
4.331
S 374,200
Initial Lagoon and GWTP Site Management11
$200,000
2002 - 2007
0.864
$ 172,800
4.331
$ 748,400
O&M of New Alternative GWTP 1
Post-construction Lagoon Area Site Management '*
O&M of New Alternative GWTP (includes
sampling and analysis needed for GWTP operation)
S 400,000
2007
14.096
$ 3,817,200
0.677
$ 270,800
$ 100,000
0.677
$ 67,700
14.096
S 954,300
$253,000
0 200
$ 50,600
19.343
$ 978.760
S 50 000
32-2
19? .430
9 34
rea Sue Management
$11,945,730
SUBTOTAL
$ 2,986,450
Cost Estimate Contingency (25 %)

$14,932,160
TOTAL PRESENT WORTH OF ANNUAL
COSTS
T-6. a
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FOOTNOTES FOR TABLE b
1	All values shown are approximate and are included for ROD purposes. Cost estimates have been provided in the document entitled "Technical Memorandum,
Total In-Stiu Containment Conceptual Design - Bufors-Nobcl Superlund Site" dated September 9, 1997, (the "Tech Memo") available for review in the
Administrative Record These cost estimates will be further refined during the Remedial Design.
2	Annual cost value shown is discounted to first year of "From - To" time period (i.e., 'annual cost' value for Item b. is for Year 2002).
3	See Table 6A for explanation of P/A Factor and Present Worth, and Table 6B for P/F Factor.
4	Present Worth value reflects 1999 funding needed to cover annual cost shown.
5	Table 8- 10 of 9/9/97 Tech Memo, Item #3, Costs of Quality Assurance and Work Plans are included in Remedial Design cost shown in previous Tabic 6.
Costs of sampling activity which occurs during Remedial Design are included in Remedial Design costs,
6	Table 8-12 of 9/9/97 Tech Memo, Item called "Annual Monitoring".
7	Table 8-12 of9/9/97 Tech Memo, Item called "Annual Monitoring for Permanent Operation".
8	Table 8-11 B of 9/9/97 Tech Memo, Item#].
9	Table 8-11 B of 9/9/97 Tech Memo, Item tt2.
10	Table 8-11 B of 9/9/97 Tech Memo, Item #4.
11	Table 8-11 B of 9/9/97 Tech Memo, Item #5.
12	Table 8-11 B of 9/9/97 l ech Memo, Item #3. Site Management costs includes general administration, management, inspection of lagoon area (TIC Remedy),
and reporting requirements for the Site.
13	Table 8-12 of 9/9/97 Tech Memo, sum of "New Plant Long Term Maintenance and New Plant Operation". If no GWTP alternative exists or is not available,
then contingency may include continued operation of existing U.S. EPA GWTP, at a level corresponding to the volumetric fraction of extracted TIC
groundwater treated. Annual costs shown reflects technical operation activity, including GWTP repair and preventive maintenance.
14	Table 8-12 of 9/9/97 Tech Memo, Item entitled "Site Management", Years 2007 to 2031. Site Management costs includes general administration,
management, and inspection of lagoon area (TIC Remedy) and repotting requirements for the Site.
15	Table 8-12 of 9/9/97 Tech Memo, Item entitled "Site management", Yean 2032 to 2101.
T-6. b
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TABLE 6A - Present Worth Formula
Because different remedial alternatives have different operating costs and time periods, it is necessary to
provide some equivalent value between alternatives for comparison purposes. The present worth of an
alternative is a measure of how much money will have to be put aside now to provide for one or more
future expenditures. To find the present worth of a series of cash disbursements (such as annual O&M).
it is necessary to discount future amounts to the present by using an interest rate (for the appropriate
number of years) in the following manner:
(1)	Present Worth - F^l + i)# +• F,(l + i)*1 + ...
+ Fk(J + i)* + ... + F,( I +i r
where Fk = future cash flow at end of period k
i = interest rate
k = index for each compounding period (0 < k < n)
n = number of years
A = annual cost (O&M cost)
This series is summarized by the following equations:
(2)	Total P W. = Capital Cost + Present Worth of Annual Cost
(3)	P.W. of Annual Cost = Annual Cost x P/A Factor
P ( I + i)" - 1
(4)
A i( I + if
Thus, for Item b. of Table 6 ($ 70,000, or $ 60,480 in 1999 dollars for 5 yrs. % 5%);
P (i+i)"-l (1 + 0.05)' - 1
- « 	 = 	 = 4.331
A i{ 1 + i)" 0.05 *(1 +0.05)1
and
P. W. of Monitoring = S 60.480 x 4.331 =5 261,940
Source: Engineering Economy. 7th ed.. DeGarmo, Sullivan, Canada, Macmillan Publishing, 1984.
T-6A.1
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TABLE 6B - Discount of Future Costs to Present Value Formula
A present worth analysis was performed to provide a current equivalent value for project tasks over the
entire project life for comparison purposes. Annual cost at some future time must be adjusted to reflect
dollar values at the present moment. The present worth of a future cost is a measure of the equivalent
current value of money used at a later date. To find the present worth of a future cost (such as an O&M
cost 33 years from now), it is necessary to discount future amounts to the present, in a manner very
similar to the Present Worth formula explained in Table 6A.
(1) P.W. of Future Cost = Future Cost x P/F Factor
P I
(2)	. =	
F (l + i)B
Thus, for item b. of Table 6 ($ 70,000 at Project Year 2002 (or n=3) @ 5%):
P 1	1
. = 		 = 	 =0.8638
F (t+i)*	(1+0.05)'
and
P.W of Future Annual Cost of Monitoring = $ 70,000 x 0.864 = $ 60,480
Source: Engineering Economy. 7th ed.. DeGarmo, Sullivan, Canada, Macmillan Publishing, 1984.
T-6B.1
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TABLE 7 - 'TIME WEIGHTED" AVERAGE ANNUAL COST OF MONITORING & QAM OF TIC REMEDY
1
T
E
M
PROJECT ACTIVITY1
ANNUAL
COST'
YEARS
FROM - TO
TIME
PERIOD
(YRS.)
FRACTION OF
PROJECT TIME
"WEIGHTED" 1
ANNUAL COST |
a.
GW Monitoring During
RD/RA
S 80,000
1999 - 2002
3
3-103 = 0.029
S 2,320 |
b.
Post-const. GW Mon
$ 70,000
2002 - 2007
5
5-103 -0.049
5 3,430 g
c.
LTGW Monitoring
$ 70,000
2007 - 2032
25
25-103 = 0.243
$ 17,010 |
d
LTGW Monitoring
S 50,000
2032-2102
70
70-103 = 0.680
S 34,000 |

TOTAL TIME

103
'TIME WEIGHTED-
ANNUAL COST OF
MONITORING'
S 56,760 1
e.
Existing GWTP Oper.
S 600.000
1999 - 2002
3
0.029
S 17,400
f.
Existing Well Oper.
S 150,000
1999 - 2002
3
0.029
S 4,350
g-
Existing GWTP Oper.
S 400,000
2002 - 2007
5
0.049
S 19.600
h.
Existing Well Oper.
S 100,000
2002 - 2007
5
0.049
S 4.900
1
Initial Site Mgmt.
S 200,000
2002 - 2007
5
0.049
S 9,800
}¦
O&M of New Alt.
GWTP
$ 400,000
2007 - 2032
25
0.243
S 97.200
k.
Post-const. Site Mgmt.
S 100,000
2007 - 2032
25
0.243
S 24,300
1
O&M of New Alt.
GWTP (inc.
Samp/Analysis)
S 253,000
2032 - 2102
70
0680
J 172,040
m
Long Term Site Mgmt.
S 50,000
2032-2102
70
0.680
S 34,000
"TIME WEIGHTED" ANNUAL O&M COST'
S 383,590
FOOTNOTES FOR TABLE 7
1,2 As identified in Table 6. All values shown are approximate and are included for ROD purposes. Cost estimates
have been provided in the document entitled "Technical Memorandum, Total In-Situ Containment Conceptual
Design - Bofors-Nobel Superfund Site", dated September 9, 1997, (the "Tech Memo") available for review in the
Administrative Record. These cost estimates will be further refined within the Remedial Design.
3 'Time weighted" annual costs do not represent higher O&M costs during initial remedy operation because of the
variance in annual O&M costs and time periods. A decrease in the total project time period will increase the "time
weighted" values shown.
T-7
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DECLARATION FOB TM SECOND AMENDMENT TO THE RECORD OF DECISION
BOFOR3-NOBEL OPERABLE UNIT #1 - LAfiOON AREA
APPENDIX A - Diacuaaion of Applicable or Relevant and Appropriate
Requirement» (ARAB*)
The 1990 ROD, 1992 ROD Amendment, and July 16, 1996 remedy re-
evaluation established Applicable or Relevant and Appropriate
Requirements (ARARs) for this site. U.S. EPA has reviewed these
ARARs in light of the TIC remedy alternative and has determined
that the substantive provisions of the following continue to be
ARARs or potential ARARs for this operable unit:
I. FEDERAL
I-A. Federal - Action Specific: Action-specific ARARs are
requirements that define acceptable treatment and disposal
procedures for hazardous substances.
I.A.I. Clean Water Act, as amended f33 U.S.C. § 12511:
The National Pollutant Discharge Elimination System (NPDES)
specifies the substantive requirements for discharges into
surface waters, including effluent standards and
limitations. 40 CFR 122, 125 and 136 establish guidelines
and procedures for the National Pollutant Discharge
Elimination System (NPDES). The NPDES program is
administered by MDEQ under Michigan Public Act 245, Part 21.
These substantive requirements are applicable to the TIC
remedy because extraction, treatment, and discharge of
groundwater on-site to Big Black Creek is a remedy
component. Because the Groundwater Treatment Plant (GWTP)
constructed by U.S. EPA has been designed to satisfy (and
has been satisfying) such discharge requirements identified
by MDEQ, continued use of the GWTP complies with this ARAR.
Any groundwater treatment system that is implemented as an
alternative to the GWTP and all other relevant components of
the TIC remedy will also be designed and constructed
according to such MDEQ surface water discharge requirements
to insure compliance with this ARAR. These discharge
standards will first be developed during the Remedial Design
and may be refined as construction and operation of the TIC
remedy proceeds. Use of a natural (vegetative) treatment
cell for containment and treatment of groundwater (which may
not include a specific effluent pipe line or "point source"
discharge) will also be subject to surface water discharge
requirements established by MDEQ. Until new site specific
A-1
-------
surface water standards are developed (if necessary), site
standards already in place will be complied with at all
times, including design, construction, and start-up of the
TIC remedy.
I.A.2. Clean Air Act, as amended f42 U.S.C. § 74011:
The Clean Air Act was enacted to protect and enhance air
quality. 40 CFR 6 provides that all Federal projects,
licenses, permits, plans, and financial assistance
activities conform to any State Air Quality Implementation
Plan (SIP). 40 CFR Part 50 establishes primary and
secondary ambient air quality standards that are applicable
to emissions generated either during construction activities
or during operation of any groundwater treatment facility,
including the GWTP constructed by U.S. EPA. The TIC remedy
will comply with this ARAR during design, construction, and
operation.
I.B. Fedaral - Location. Specific: Location-specific ARARs are
those requirements that relate to the geographical position of a
sice.
1.3.1.	Section 10 of the Federal River and Harbor Act, as
amended:
This Act regulates obstruction or alteration of any
navigable water in the United States, including connected
wetlands. These requirements are implemented through 33 CFR
Parts 320-330. Because construction activities for the TIC
remedy pose a potential impact on Big Black Creek and/or
connected wetlands, this statute is ar. ARAR. The TIC remedy
will comply with this ARAR during design, construction, and
operation, and will provide for any necessary mitigative
measures.
1.3.2.	Clean Water Act (CWA) of 1977. as amended. F33 U.S.C.
1344 1. 33 CFR 322:
Section 404 of the Clean Water Act also specifically
establishes limitations on the discharge of dredged or fill
material into surface waters, including adjacent wetlands.
The TIC remedy will comply with the substantive requirements
of this ARAR by subjecting construction documentation to
review by appropriate authority.
A-2
-------
1.3.3. Executive Orders 11988 40 CFR 6:
executive Orders 11988 40 CFR 6 similarly requires that
construction activities avoid long- and short-term adverse
impacts associated with actions in the wetland or floodplain
areas. The TIC remedy will comply with this ARAR during
construction activities.
I.C. F«d«ral - Ch—ical So»cific: Chemical-specific ARARs
regulate the release to the environment of specific substances
having certain chemical characteristics, and typically determine
the extent of clean-up at a site.
I.C.I. Clean Water Act f33 U.S.C. 12511. Toxic Pollutant Effluent
Standards f40 CFR 1291;
Title 40, Part 129 of the Code of Federal Regulations
establishes toxic pollutant effluent standards and
prohibitions of specific compounds for specified facilities
discharging into navigable waters. 40 CFR 129.104 sets the
ambient water criterion for Benzidine in navigable water as
0.1 ug/1. This standard is an ARAR for discharges from
whatever groundwater treatment facility that will be used
for the TIC remedy. As noted previously, the GWTP has been
designed to satisfy, and has been satisfying, these
requirements, and thus its use complies with this ARAR.
Implementation of any alternative to the GWTP and other
relevant portions of the TIC remedy will be designed,
constructed, and operated to comply with this ARAR.
I.C.2. Resource Conservation and Recovery Act (RCRA). Subtitle C
(42 U.S.C. S 6901) :
Wastes that were deposited in the lagoons are by-products of
specialty chemical production that occurred on. site before
the enactment of RCRA. U.S. EPA determined that RCRA and
State landfill cap standards were relevant and appropriate
requirements for the Landfill Remedy. Because the TIC
remedy has different objectives, including movement and
capture of groundwater within the source area and reduction
of contamination by the treatment components provided by the
remedy, RCRA and State landfill cap standards are not ARARs
for the lagoon area cover portion of the TIC remedy.
Because the O.U. #1 lagoon area cover must be permeable for
sustaining the vegetative components of the TIC remedy, the
O.U. #1 lagoon area cover currently proposed will not meet
RCRA cap requirements. Ir. the event a TIC cover upgrade is
later required as a Contingent Remedial Action, substantive
A-3
-------
portions of RCRA and Part 111 of NREPA which deal with the
design and construction of hazardous waste covers may be
ARARs for that upgrade. RCRA and Part 111 of NREPA
standards would be ARARs for any excavation activity. In
the event that surface cleanup phase of the remedy requires
some excavation and off-site disposal, the excavated
material shall be characterized, manifested, and disposed of
in accordance with these RCRA and parallel State
requirements.
In addition, to the extent groundwater treatment residuals
exhibit hazardous characteristics, on-site activities
relating to disposal of those residuals will comply with the
applicable provisions of 40 CFR Parts 264 and 268. However,
sludge generated within the operating groundwater treatment
system does not exhibit any RCRA characteristics and is
disposed of in a sanitary waste landfill. Further,
technical requirements for long-term monitoring systems may
be relevant and appropriate for groundwater monitoring
programs required for the TIC remedy.
I.C,3. Safe Drinking Water Act (SDWA) of 1974 (42 U.S.C. 300(f)),
as amended:
The Safe Drinking Water Act was enacted to assure high
quality drinking water in public water supplies.
Specifically, 40 CFR 141 specifies maximum chemical
contaminant levels (MCLs! for inorganic and organic
chemicals, maximum contaminant level goals (MCLGs) for
organic chemicals, and establishes national revised primary
drinking water regulations of MCLs for organic chemicals.
Surface water in Big Black Creek and groundwater in the site
vicinity are not currently distributed through the public
water supply systems. Therefore, these regulations are not
applicable to the site. These standards are, however,
relevant and appropriate to establishing final groundwater
cleanup standards that could allow for discontinuing the
groundwater containment portion of the remedy.
As noted above, the groundwater treatment facility currently
satisfies all discharge limitations to Big Black Creek.
-------
II. STATE
XI.A. Staf - Action 8p«Oifi.C
II.A.1. Part 31 of the Natural Resources and Environmental
Protection Act 1994 PA 451, as amended, (formerly Act 245 of the
Public Acts of 1929. as amended:	Water Resources Commission Act:
The National Pollutant Discharge Elimination System (NPDES)
is implemented by the MDEQ, which administers and specifies
the substantive requirements for discharges into surface
waters, including effluent standards and limitations under
Part 21 of the Administrative Rules. Part 4 of the
Administrative Rules, Rule 57 also establishes water quality
standards for all waters of the state. Those requirements
establish limits for discharge of dissolved solids, pH,
taste and odor producing substances, toxic substances,
nutrients and dissolved oxygen.
These substantive requirements are applicable to the TIC
remedy as it includes extraction, treatment, and discharge
of groundwater on-site to Big Black Creek. The groundwater
treatment facility has been designed to satisfy, and has
been satisfying, the surface water discharge requirements
identified by MDEQ. Any groundwater treatment system that
is implemented as an alternative to the GWTP and all other
relevant components of the TIC remedy will also be designed
and constructed according to such MDEQ surface water
discharge requirements to insure compliance with this ARAR.
II.A.2. Part 55 of the Natural Resources and Environmental
Protection Act 1994 PA 451. as amended.(formerly Act 348 of the
Public Acts of 1965. as amended. Air Pollution Act: Part 3):
This law establishes standards for the density of emissions
and emission of particulate matter. The TIC remedy will
require some degree of excavation, resulting in agitation of
site soils and sludges. The TIC remedy will likely require
some degree of emissions control during construction. These
requirements will likely be minimal because the TIC remedy
involves limited excavation and materials handling.
For dust control, the most effective method is wet
suppression using water alone, or a chemical suppressant in
water. This will capture sludge and soil particles, and
will inhibit migration of volatile and semi-volatile vapor.
At the end of each daily construction period, excavation and
stockpile areas will be covered appropriately to prevent
A-5
-------
releases during off-hours. In the event wet suppression
alone does not adequately control site emissions to within
required levels, it will be possible to perform further
controls as discussed above, including erection of wind
screens. It is expected that by using these measures, the
TIC remedy will comply with the substantive requirements of
this ARAR.
II.B. State - Location Specific:
II.B.l. Part 303 of the Natural Resources and Environmental
Protection Act 1994 PA 451, as amended, (formerly Act 203 of the
Public Acts of 1979. The Goemaere-Anderson Wetland Protection
A?t) :
These rules apply to activities that result in discharge to
the wetland area that drains to the Big Black Creek. These
rules include permitting requirements, wetland
determination, and mitigation. It is expected that the TIC
remedy would include all necessary procedures needed to
comply with this statute.
II.B.2. Part 91 of the Natural Resources and Environmental
Protection Act 1994 PA 451, as amended, (formerly Act 347 of the
Public Acts of 1972. Soil Erosion and Sedimentation Control Act):
Part 17 of the Administrative Rules, Soil Erosion and
Sedimentation Control, establishes general soil erosion and
sedimentation control procedures and measures, as well as
earth change requirements and soil conservation district
standards and specifications. The TIC remedy will result in
agitation of one or more acres of iar.d within 500 feet of a
stream. Therefore, these are relevant and appropriate, and
it is expected that the TIC remedy evaluated here will
comply with this statute.
II.C. State - Chemical Specific:
II.C.l. Part 31 of the Natural Resources and Environmental
Protection Act 1994 PA 451. as amended, (formerly Act 245 of the
Public Acts of 1929. as amended. Water Resources Commission
Act). Administrative Rules Part 4. Rule 323.1057 (Rule 57), Water
Quality Standards (Surface Water Quality Standards):
Part 31 of NREPA, Part 4, Rule 57 establishes limits for all
waters of the State. Standards for toxic substances are
established on a site-specific basis. As noted above, the
groundwater treatment facility recently constructed is
A-6
-------
currently required to, and does, satisfy discharge
limitations to Big Black Creek. The TIC remedy will
therefore comply with this ARAR.
II.C.2. Part 55 of the Natural Resources and Environmental
Protection Act 1994 PA 451, as amended, (formerly Act 348 of the
Public Acts of 1965, as amended. Air Pollution Act):
Administrative Rules Parts 7 and 9:
This establishes standards for the emission of regulated
contaminants into the air. The TIC remedy evaluated here
will require some degree of excavation, resulting in
agitation of site soils and sludges, which will result in
emissions. Although the TIC remedy should stir up less
airborne material than the Landfill Remedy originally
selected, some degree of emissions control during
construction may be needed. This is applicable to the
overall site air quality and does not account for air
releases created by nearby industrial facilities.
For dust control, the most effective method is wet
suppression using water alone, or a chemical suppressant in
water. This will capture sludge and soil particles, and
will inhibit migration of volatile and semi-volatile vapor.
At the end of each daily construction period, excavation and
stockpile areas will be covered appropriately to prevent
releases during off-hours. In the event wet suppression
alone does not adequately control site emissions to within
required levels, it will be possible to perform further
controls as discussed above, including erection of wind
screens.
Rule 901 of Part 55 requires that no emissions of an air
contaminant can occur in quantities that cause injurious
effects to human health or safety. Specifically, the
contaminant concentration that corresponds to a 10~s 70 year
lifetime cancer risk can not be exceeded at the site
boundary.
The TIC remedy may require excavation, grading, and/or
stabilization of soft areas of the lagoon area. Also,
soil/slurry mixing processes will be implemented, indicating
that real time perimeter site monitoring and dust control
will be needed. It is expected that the earth work involved
with the TIC remedy will not be as extensive as the Landfill
Remedy originally selected, and should remain within
acceptable Part 55 levels with the use of emissions control.
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II.C.3. Part 201 of the Natural Resources and Environmental
Protection Act. 1994 PA 451. as amended (formerly known as Act
30*7 of the Michigan Environmental Response Act) :
In the 1992 ROD Amendment, the substantive provisions of
Parts 6 and 7 of the rules promulgated under Part 201 were
identified as an ARAR for the Landfill Remedy to be
undertaken at this site. These rules provided, inter alia/
that remedial action be protective of human health, safety
and the environment by a degree of cleanup conforming to
one or more of three cleanup types; Type A, B, and C. The
ROD and the amended ROD determined that the selected soil
remedy would satisfy Act 30~7 soil cleanup standards. The
Act 307 standards have since been replaced by new standards
under Part 201.
The amended Part 201 now defines cleanup standards according
to categorical criteria that define the nature of site for
which Remedial Action is necessary. Specific cleanup
categories are: residential, commercial, recreational,
industrial, limited residential, limited commercial, limited
recreational, limited industrial, and other land use based
on limited categories as established by MDEQ. Part 201
groundwater cleanup criteria are considered ARARs. Under
the TIC remedy, the barrier wall is required to immediately
contain all areas in excess of Part 201 soil cleanup
criteria, and ultimately achieve these criteria with the
treatment provided by the remedy. Further, meeting the
performance standards required of the TIC remedy insures
that groundwater outside the contained area will not exceed
Part 201 cleanup standards, including compliance with
Section 20120a(15) requiring that groundwater venting to
surface water meet the NREPA Part 31 standards. Under Rule
705(5) of Part 201 (Environmental Remediation), groundwater
contamination may not be permitted to migrate laterally
beyond its present boundaries. The ultimate goal of the
remedy is to further achieve compliance with Part 201 soil
and groundwater standards within nhe barrier wall as well.
The containment portions of the remedy will continue unless
and until these standards are met throughout the affected
areas.
It is anticipated that implementation of the TIC remedy will
limit development of site property in order to assure the
continued integrity of the O.U. #1 lagoon area cover. Areas
immediately adjacent to the site are primarily industrial,
and implementation of the TIC remedy precludes or
significantly limits future development for the site. Thus,
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Part 201 cleanup criteria for future industrial land use are
applicable unless appropriate deed restrictions can not be
obtained, in which case criteria for future residential land
use would apply and would be the relevant ARAR.
IZ-C.4, Part 111 of the Natural Resources and Environmental
Protection Act 1994 PA 451, as amended, (formerly Michigan
Hazardous Waste Management Act, PA 64):
U.S. EPA determined that both RCRA and State landfill cap
standards were relevant and appropriate requirements for the
Landfill Remedy. Because the TIC remedy has different
objectives, including movement and capture of groundwater
within the source area and reduction of contamination by
treatment, Part 111 landfill cap standards are not ARARs for
the TIC remedy. Substantive portions of Part ill which deal
with the design and construction of hazardous waste covers
may be ARARs if a specific Contingent Remedial Action
dealing with protective covers is implemented. Part 111
would be ARARs for any excavation activity. In the event
that surface cleanup phase of the remedy requires some
excavation and off-site disposal, the excavated material
shall be characterized, manifested, and disposed of in
accordance with these State requirements.
In addition, to the extent groundwater treatment residuals
exhibit hazardous characteristics, on-site activities
relating to disposal of those residuals will comply with the
applicable provisions of Part 111 regulations implementing
the federal RCRA requirements described above.
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declaration for the SECOND amendment to the record of decision
BOFORS-NOBEL OPERABLE UNIT »1 - LAGOON AREA
APPENDIX S - Responsiveness Summary
This Responsiveness Summary has been prepared to provide answers
to public concerns regarding the cleanup plan for the O.U. #1
lagoon area soil, sludge, and groundwater. This Responsiveness
Summary also meets the requirements of Sections 113 {k) (2) £B) (i'v)
and 117(b) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 (CERCLA),
which requires the United States Environmental Protection Agency
(U.S. EPA) to respond to comments received on a proposed plan for
remedial action. A notice of availability of the administrative
record and proposed plan was published in the Muskegon Chronicle
on June 15, 1998. This Responsiveness Summary addresses concerns
expressed during the subsequent public comment period of June 15
through July 17, 1998. In addition, a public meeting to discuss
the proposed plan was held on June 24, 1998 at the Egelston
Township Hall and comments recorded at the meeting are addressed
in this Responsiveness Summary. Some of the comments appearing
below have been paraphrased for brevity. The Administrative
Record contains copies of written comments and the transcript
from the June 24th public meeting.
COMMENT:
What are the materials of construction for the O.U. #1 lagoon
area cap portion of the Total In-situ Containment (TIC) remedy?
U.S. EFA'S RESPONSE:
Many of the specific construction details for the revised remedy
will be defined during the Remedial Design process. U.S. EPA
expects the O.U. #1 lagoon area cap to consist of soil, clay, and
possibly synthetic liners (such as polyethylene) of a thickness '
and density to insure that there will be no unacceptable exposure
to any contamination underneath.
COMMENT:
Are the trees and other vegetation intended to address soil
contamination or groundwater contamination?
U.S. EPA'S RESPONSE:
The answer is "both". Trees and other vegetation will be
installed inside the containment system provided by the cap,
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barrier wall, groundwater extraction, and will help contain
contaminated groundwater by natural uptake of water. Vegetation
will also help in containing contaminated soils by having roots
in the soil, keeping the soil in place. U.S. EPA expects the
vegetation to provide additional benefits by enhancing the
activity of existing "contaminant consuming" bacteria
underground, or by synthesizing the contaminant compounds through
their own internal processes. Even without those additional
benefits, the TIC remedy fully addresses soil and groundwater
contamination.
COMENT:
How much water will be in the area contained by the TIC remedy
with vegetation present? Will it resemble a swamp? What will
happen to any water that accumulates in this area?
U.S. IPA'g REgpgngs:
U.S. SPA anticipates that, after construction of the TIC remedy
is completed and all vegetative components have matured, there
should not be any excessive accumulation of surface water in the
contained area and this portion of the site will resemble the
ecosystem currently surrounding the lagoons and at Big Black
Creek. The barrier wall will be designed and constructed such
that groundwater will be directed toward a central collection
point, making it possible to control and limit any exposure to
water within the containment area. During design and
construction of the TIC remedy, some or all of the existing
groundwater capture (extraction) system will continue to
function. As an extra safeguard to containment provided by the
TIC remedy, this existing system may be upgraded or replaced as
needed. At the start of construction, there is a possibility
that there may be some accumulation of water on the surface,
before all the vegetation is installed and before it matures.
Access to the contained areas, however, will be controlled with
security measures and the contained area will be monitored to
make sure there is no adverse impact on the Big Black Creek
system.
COMMENT:
Will trees be able to grow in the O.U. #1 lagoon area
environment? Is the TIC remedy somewhat experimental in nature?
U.S. EPA's RESPONSE:
The baseline components of the TIC remedy that will provide
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immediate containment rely on common technology; barrier walls,
soil and/or synthetic covers, and groundwater extraction. There
are several other projects throughout the United States that use
phytoremediation, and laboratory research has shown that it is
possible to grow trees in an environment that contains
contamination. The Administrative Record for this site contains
information summarizing some of these laboratory results. The
phytoremediation part of the TIC remedy is experimental in that
there have not been many Superfund sites that have used
vegetation on the relatively large scale that the TIC remedy will
attempt.
COMMENT:
Although U.S. EPA anticipates using steel sheet piling for the
barrier wall construction, how will is be possible to get clay
down to the 75 to 100 foot depth without the excavation
collapsing?
U.S. SPA's RESPONSE:
U.S. EPA anticipates that the use of sheet piling should
stabilize any excavation wherever clay is used for the barrier
wall component of the TIC remedy. In addition, the density of
the clay slurry mix that is used can be increased to provide a
more stable foundation within excavated areas and prevent any
collapse. Slurry walls have ben constructed to depths up to 100
feet at other sites throughout the United States.
COMMENT:
Will the design of the O.U. #1 lagoon area cover prevent only
humans from coming into physical contact with contamination, or
will it protect animal life? Is the O.U. #1 lagoon area cover
intended to prevent wind erosion or wind induced contaminated
dust clouds?
U.S. SPA'S RESPONSE:
The intent of the O.U. #1 lagoon area cover is to prevent both
human and animal life from coming into contact with
contamination. U.S. EPA anticipates that the O.U. #1 lagoon area
cover design will be very similar to many such covers that have
been installed throughout the United States, and which inherently
prevent any wind disturbance of soil.
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C0I#4EMT:
Is the water treatment plant that U.S. EPA currently uses the
same one that has been in existence since the 1980s? Why didn't
U.S. EPA use that facility instead of constructing the new one?
Does the possibility exist that a third treatment plant, in
addition to the Lomac and U.S. EPA plants, will be constructed?
What will happen if U.S. EPA's new treatment plant is no longer
needed?
U.S. EPA'S RESPONSE:
The treatment plant that has been in operation since the 1980s is
owned and operated by Lomac, who uses it for treatment of their
chemical production process water. Back during the design of the
new groundwater treatment plant, U.S. EPA investigated the
possibility of retrofitting and using the Lomac facility, U.S.
EPA (in consultation with the State of Michigan) decided to
design and construct a new facility that discharges clean water
into Big Black Creek instead of using up the Muskegon County
treatment plant's limited capacity. U.S. EPA did not want to add
to the County plant's burden by using the Lomac facility which
discharges treated water to the County. With the use of a
barrier wall and vegetation, the TIC remedy may be able to reduce
the flow of groundwater that has to be treated, after a number of
years. This means that U.S. EPA's new plant may have extra
capacity and it might be more cost effective to install a
smaller, more economical water treatment system. It may then be
possible to help Muskegon County by having U.S. EPA's plant treat
some of the industrial water users (such as Lomac or Sun
Chemical).
COMMENT:
What is a typical time frame for the vegetation to start being
active? Will it take approximately 20 or 25 years to remove the
necessary amount of groundwater?
U.S. EPA'S RESPONSE:
U.S. EPA anticipates that it will take approximately five years
for installed vegetation to mature. To date, laboratory studies
on the use of vegetation for remedies have been more concerned
with establishing the feasibility of the concept rather than
estimating the time period needed to achieve complete cleanup.
All groundwater and soil containment mechanisms, however, will be
operated for as long as necessary, to protect human health, the
environment, and Big Black Creek. A long term cleanup time
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estimate will be developed either as part of the Remedial Design
or during the Remedial Action, when the vegetation's treatment
effectiveness can be more accurately measured.
COMMENT:
Are there different types of plants that are going to be used
based on different types of contamination? Is there any plan to
fertilize the trees?
U.S. EPA'a RESPONSE:
To date, there are two species of trees that have been identified
in the preliminary TIC remedy proposal, poplar and red cedar.
These species have been selected because of their durability and
fast-growing nature, and not because of any particular
contaminant. Specific analysis regarding the treatment
effectiveness of these {or other) species will be performed in
more detail (including possible lab scale testing) during the
Remedial Design process. Documents that have been included in
the Administrative Record for the site suggest that the current
lack of growth in the sludge lagoons is not due to toxicity from
contamination, but from the lack of nutrients necessary for plant
growth. Investigation of other construction in the local area
(such as roadways and buildings) shows that once native plant
species are disturbed, natural re-growth does not occur easily.
U.S. EPA anticipates that installed vegetation will likely
require introduction of water and fertilizers to insure adequate
growth.
COMMENT:
Are there going to be any extraction wells on the south of the
proposed barrier wall? Is the current system keeping all
contaminants out of the creek?
U.S. EPA RESPONSE:
Although such details will be determined in the Remedial Design,
one of the fundamental components of the TIC remedy is the
assurance of adequate containment of contaminated groundwater.
The current TIC remedy proposal anticipates that the barrier
wall, once constructed, should adequately re-direct groundwater
flow such that extraction wells outside of the barrier wall
perimeter will not be necessary. Regardless of this, extraction
wells south of the barrier wall may need to be installed to
ensure protection of Big Black Creek in the event that the
barrier wall and groundwater containment and extraction portion
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of the TIC remedy is not fully effective. The current
groundwater extraction system consists of twelve extraction wells
installed between the mid-1970s and the mid-1980s. This system
has been operating at an extraction rate high enough to capture
all groundwater before reaching the Creek (therefore also
capturing all contamination).
COMMENT:
In the new remedy, groundwater will be present in a wetland type
area according to environmental standards. Does that mean that
the water currently being treated and discharged into the creek
does not meet such standards? Is the current state of the
lagoons like a swamp or pond, that is, filled with water?
U.S. EPA RESPOUSE;
As previously noted, the existing groundwater extraction system
captures all contaminated groundwater before it can reach the
Creek. U.S. EPA's currently operating groundwater treatment
plant was designed to meet strict State of Michigan environmental
standards for Big Black Creek and is currently meeting and
maintaining those standards. The lagoons still contain sludge
and have the consistency of a sand dune. Due to the sandy nature
of the soil in the area, there is no standing water in any
lagoon.
COMMENT:
Are metals (inorganics) of any concern at the site, and how would
they affect the vegetation?
U.S. EPA RESPONSE:
Although inorganic contaminants were found in site soil, sludge,
and groundwater, they were not at high enough levels to be
identified as a threat to human health and the environment.
U.S. EPA's groundwater treatment plant, however, was designed for
and is capable of extracting any inorganic contaminants from
groundwater, but throughout its 4 years of operation has not
extracted any significant amounts of inorganics. U.S. EPA
anticipates that the vegetation installed for the TIC remedy will
not be adversely affected by any inorganic contaminants, and will
not contain (by natural uptake) inorganic contamination at levels
that pose any risk.
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How will U.S. EPA evaluate the remediation process? How will the
effectiveness of the TIC remedy be measured? How will the
community know it is working?
U.S. EPA'a RESPONSE:
A program of regular sampling and analysis of the site is a
fundamental requirement of the TIC remedy. Although the details
of these monitoring programs will be defined in the Remedial
Design, U.S. EPA anticipates that sampling of groundwater on both
the inside and the outside of the barrier wall will occur
regularly, as well as some soil sampling and possibly ecological
monitoring.
Continual groundwater sampling will be a necessity in order to
insure that the TIC remedy remains protective. This data,
possibly enhanced with soil information, would also be used to
establish the effectiveness of the TIC remedy in reducing the
toxicity of contamination, and ultimately would determine whether
the site is clean. U.S. EPA will make sure that the community is
provided with regular updates, through mailings, the local media,
and the public meeting process.
COMMENT:
The community has not recently been informed as to all that has
transpired at the site. There have not been enough updates and
U.S. EPA should provide 6 month updates as the site remedy
progresses. The community prefers action and is a bit frustrated
at the inaction over the past few years. Why has it taken all
this time to get to this point?
U.S. EPA'S RESPOHSE:
U.S. EPA has not provided regular updates due to the extensive
negotiation process associated with obtaining financial
commitments for the TIC remedy. Because of the confidentiality
required during the development of these legal agreements over
the past year, U.S. EPA could not provide details. Most of the
work that has been happening for this project has been
discussion, re-evaluation, and refinement of the basic
requirements required to make implementation of the TIC remedy
practicable. There has not been much design or construction
field work to present to the community. In addition, much of
U.S. EPA's efforts on this site have been aimed at refining and
optimizing operation and maintenance of the groundwater treatment
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plant. U.S. EPA will be updating the community on a more regular
and re-occurring basis.
COMMENT:
The new plan appears to have significantly more community
acceptance than the previous landfill remedy selected. Some
community members applaud U.S. EPA for attempting something
innovative, considering that the TIC remedy seems the best
possibility for natural treatment as opposed to an incineration
or landfilling option. It is about time to treat the soils which
seem to be continually contributing pollutants to groundwater.
U.S. EFA'S RESPOHSE:
Although Superfund requirements dictate that treatment is always
a preferred option, the first amendment to the O.U. #1 Record of
Decision for this site removed incineration as an option and
replaced it with an on-site landfill containment alternative. At
the time of the first ROD Amendment, it was shown that
conventional treatment technology for the excessive amount of
contaminated site soil was not practicable. In U.S. EPA's re-
evaluation document, the landfilling option was noted as the
preferred method of containment (due to implementability), but
that the TIC remedy could be refined and implemented to provide
an equivalent level of containment. Now that U.S. EPA has the
necessary commitments for such refinements and implementation,
the TIC remedy can be implemented. The remedy also provides an
added benefit of contaminant degradation through more natural
means by the treatment provided by phytoremediation. The nature
of the TIC remedy more readily accommodates further remedial
action on some or all soil contamination if it becomes necessary.
New remedy options will continue to be considered in the event
the treatment provided by phytoremediation as not as effective as
anticipated.
COMMENT:
How large of an area would the proposed deed restrictions cover?
What is the nature of these restrictions?
U.S. EPA'S RESPONSE:
The deed restrictions mentioned in this ROD Amendment are
intended to insure that no one uses contaminated site groundwater
or site soil after remedial action starts. Also, any activity
that might damage or otherwise impair the effectiveness of any
part of the TIC remedy would be prohibited. A deed restriction
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is a simple statement of a property's history, what has been done
on or to the property, and what can or can not be done on or to
the property after a remedy is started. Deed restrictions can
only be implemented by a person who controls a property or a
property owner, and usually comes into play when the property is
bought, sold, or otherwise transferred. The deed restrictions
will extend over the entire site.
COWffiNT:
Has there been any testing done on resident's wells, and how far
away from the site? What about soils at residences? U.S. EFA
must insure that the aquifer underneath the site has not been
reaching resident's homes. Why hasn't U.S. EPA conducted yearly
sampling of well water? New residences along Wolf Lake Road will
use well water as a water source. Are the Bofors site PRPs going
to assist residents of Egelston and Sullivan Townships
financially for Muskegon County water in the distant future?
U.S. EFA'S RESPONSE:
In the late 1980s, at the time of site characterization studies,
wells and soil outside the site boundary to the north and east
was sampled, and no unacceptable levels of site contaminants were
discovered. To the south, wells and soil were sampled (in some
places as far as 500 feet away) on the other side of Big Black
Creek, and no unacceptable concentrations of site contaminants
were found beyond the Creek. To the west of the site, there are
no immediate residents because of the Sun and Lomac facilities.
Between site characterization and the current TIC remedy proposal
of September 1997, there has been extensive site sampling and
analysis, creating a wealth of site data. It has been determined
by both U.S. EPA and MDEQ that the contamination at the Bofors-
Nobel site poses no threat to any water supplies beyond the site
boundary as long as adequate capture of contaminated site
groundwater continues. In addition, there is no evidence of soil
contamination beyond the site boundary. Because of the fact that
there has not been any contamination attributable to this site
documented past the site boundary, U.S. EPA does not anticipate
using Superfund authority in this instance to fund any connection
of residences to the Muskegon County water system.
COMMENT:
What is the financial assurance mechanism that provides for the
funding of this new remedy, since the PRPs are doing the work?
Is the total amount of this financial assurance equal to what the
government has estimated and what is shown in its public record?
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U.S. EPA'S RESPONSE:
The U.S. Government has been negotiating a Consent Decree with
the PRPs for the site, which is an agreement legally recorded in
court. As part of that Consent Decree, there is a provision that
the PRPs must provide a financial assurance using one of several
possible mechanisms in an adequate amount to cover the estimated
costs of the remedy as outlined in this ROD Amendment. For this
site, a bankruptcy settlement by the previous site owners /
operators was obtained by U.S. EPA and now is held in a dedicated
account. This account will also be used to help assure funding
for long-term operation and maintenance of the remedy. The
settlement will also require the PRPs to provide financial
assurance covering all other remedy costs.
CQIMEHT:
During construction of the TIC remedy, will there be any threat
of air emissions, especially when installing the trees? If so,
how will the community be notified?
U.S. EPA'S RESPONSE:
U.S. EPA does not anticipate an excessive amount of dust or other
emissions during any portion of TIC remedy construction. Air
monitoring will occur during construction activities. If it is
discovered that unacceptable levels of dust or other emissions
are occurring, the nature, locations, and amount of site activity
will be reduced or adjusted accordingly. If discharges continue
after such changes are implemented, physical dust control
measures such as mist generation or application of foam cover (or
other material) will be applied directly at the point of
excavation. At the end of each daily construction period,
excavation and stockpile areas will be covered appropriately with
something such as clean soil, a protective tarpaulin, or foam to
prevent releases during off-hours. In the highly unlikely event
that any portion of the community might be at risk, local
emergency personnel and community members will be notified.
CO**
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U.S. SPA'S RESPONSE:
The Bofors-Hobel southern boundary is Big Black Creek. These
unfortunate events are not attributable to this site, nor can
they be mitigated by Superfund personnel assigned to this
project.
C0M4SHT:
How will contaminated soils in O.U. #2 spaces be "covered" when
it is an operating plant and people have to traverse these spaces
daily?
U.S. EFA'S RESPONSE:
Although all details of the O.U. #2 work are not finalized, the
reference to a "protective cover" in this area may refer to
installation of a soil, clay, asphalt, or other synthetic cover.
This construction would consist of earthwork or "laying down" of
asphalt, and can easily occur with appropriate scheduling and
temporary isolation. The areas can then be used within a day or
two of cover installation.
COMMENT:
The rate of the drying up of the Five Lakes area, north and east
of the Bofors site is alarming. The groundwater pumping at and
near the site is drying up Carr Lake and the other four lakes.
Is there any way to divert purified groundwater to re-charge
these wetlands?
U.S. SPA'S RESPONSE:
Because the Five Lakes area is upstream of the Bofors-Nobel site,
it is unlikely that the unfortunate drying of the Five Lakes area
is directly attributable to the pumping being performed
specifically for the remedy along Big Black Creek. U.S. EPA does
not anticipate using Superfund authority in this instance to
alleviate this problem. Diversion of treated groundwater to this
area would not be cost effective. In addition, because the TIC
remedy diverts underground water flow away from Big Black Creek
for treatment, this groundwater must be restored to Big Black
Creek {after treatment) to insure an appropriate water balance to
the Big Black Creek system. With successful implementation of
the TIC remedy, groundwater extraction will occur at a lower
rate, allowing a greater amount of natural groundwater underneath
the site to remain in place.
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After the vegetation is installed, allowed to mature, and the TIC
remedy has been present for some time, will the vegetation absorb
enough contamination where it could be harmful to people,
insects, wildlife, or anything e±se that happens to come in
contact with the site?
U.S. SPA'S RESPONSE:
Available literature indicates that plant species have the
capability to transform organic contaminants to more benign
compounds. The literature further documents that plant roots
provide a medium under which microorganisms can flourish, and
natural destruction of organic contaminants can occur. In
addition, the biological fouling of existing extraction wells
suggests that there is naturally occurring microbial activity on
groundwater contaminants. Based on current research and the
characteristics of the vegetative species that have been
proposed, U.S. EPA anticipates that if the vegetation in the TIC
remedy absorbs enough contamination, it will either be stored
However, if TIC remedy vegetation absorbs contamination, it will
be stored within the wood deep within the interior of the plant
and/or transformed by plant metabolic processes. Contamination
should not be present at unacceptable levels at the plant surface
(such as tree leaves or bark), constituting an unacceptable risk
to insects, birds, or other animals. Site security measures will
prevent access to the site, and, as part of the design of the TIC
remedy, an assessment of the potential of this kind of threat
will be performed. In addition, the site will be monitored for
any adverse effects potentially presented by the TIC remedy.
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U.S. KNVTROKMSHTAXi PROTtCTIOK AGSNCT
RJOOSDIAL ACTION
8SL. DAT!
1 04/30/96
2 05/13/96
3 08/00/96
4 09/00/96
5 02/24/97
6 05/16/97
ADMXVXSTRATTVS RSCORD
POR
BOFORS-HOBIL 3PWUHD SITS
OmtABLI UHXT #1
WrSKKJO*, MCHIOAM
UTOATS #6
JT7KS 11, 1998
ABXHQE	9KIHWT
Fagiolo, J.	Project File
& T. Krueger;
U.S. EPA
TITU/DKSCttXPTIOM	PAQB3
Memorandum re: Sxplana- 34
Cion of Significant
Difference for Operable
Unit #1 Groundwater
Treatment Plant at the
Bofors-Nobel Site
Pagiolo, J.	Project File
4 T. Krueger;
U.S. EPA
Memorandum re: Re-	71
Evaluation of the
Selected Remedy for the
Soils and Sludges Portion
of OU01 at the Bofors-
Nobel Site
U.S. EPA/
OERR
Project File
U.S. EPA/
OSWER
Project File
Engineering Bulletin
Constructed Wetlands
Treatment (EPA/540/
S-96/501)
10
Article from Ground
Water Currents: Chlorin-
ated Solvents Biodegrada-
tion (EPA-542-N-96 - 005)
Hall, B. &	Addressees
K. Wurzel;
NewFields,
Inc.
FAX Transmission re:	2
Minutes of the February
21, 1997 Conference Call
Concerning Various Issues
for the Bofors-Nobel Site
.Bofors-Nobel	Krueger, T.	Letter re: Response to 57
Site Group	& J. Pagiolo,- U.S. EPA's April 30,
U.S. EPA	1997 Letter Concerning
the March 30, 1997 Pre-
ROD Workplan for Total
In-Situ Containment (TIC)
Remedy for the Bofors-
Nobel Site
-------
HSL. DAT!
7 05/29/97
8 05/30/97
9 06/00/97
10 06/04/97
11 06/05/97
12 06/10/97
13 06/12/97
14 06/19/97
Bo£o»-Nob«l AR
tTpdat* #6
Pag* 2
AUTHOR	MCIFHWI
Platz, C..	Fagiolo, J.,
U.S. Army	U.S. 8PA
Corps of
Engineers/
Grand Haven
Area Office
TITLg/DMCaiPTIOM	IASK&
Letter re: Oversight	7
of PRP Sampling o£ the
Bofors Lagoon Area
Mayka, J.,
U.S. EPA
Addressees
NevFields,
Inc.
U.S. EPA
Gilliland, S.,
DuPont
U.S. EPA
Special Notice Letter
re: the Bofors-Nobel
Site w/o Attachments
TriMatrix Lab Reports
From Horizon Environ-
mental (Book 1 and 2)
983
Slides from the May 20,
1997 ARARs Technical
Meeting for the Bofors-
Nobel Site
27
Hall. B. &
K. Wurzel;
NewFields,
Inc.
Addressees
FAX Transmission re:
Minutes of the June 3,
1997 Agency/Technical
Expert Conference Call
Concerning the Ground-
water Flow Model for the
Bofors-Nobel Site
Wurzel, K.,	Addressees
NewFields,
Inc.
FAX Transmission re:	16
Minutes of the June 10,
1997 Conference Call
Concerning Sorption
Tendencies of Benzidine
and DCB
Wurzel, K.,
NewFields,
Inc.
Addressees
Fagiolo, J.,
U.S. EPA &
D. O'Donnell,
MDEQ
Bofors-Nobel
PRP Group/
Project File
FAX Transmission re:
Minutes of the June 10,
1997 Agency/Technical
Expert Conference Call
Concerning Biodegradation/
Attenuation Character-
istics of Benzidine and
Diochlorobenzidine
17
U.S. EPA/MDEQ's Tech-
nical Concerns re: the
TIC Remedy for the Bofors-
Nobel Site
-------
Bofors-Nobal All
Ojpdata 46
Pag® 3
MSLu DAT!
15 07/11/97
17
07/29/97
18 07/29/97
19
08/27/97
20
09/00/97
21
22
09/09/97
09/10/97
23
09/17/97
ASZB2K
Murzel, K.,
HewFields,
Inc.
16 07/18/97 NewFields,
Inc.
Bofors-Nobel
Site Group
Murzel, K.,
NewPields,
Inc.
Croskey, H.
MDEQ
U.S. EPA/
OSWER
Newfields,
Inc.
Graff, C.
MDEQ
Roe, C.,
Dechert,
Price &
Rhoads
aiCIflBTT
Fagiolo, J,
U.S.EPA &
D. Sagle.
MDEQ
U.S. EPA
Krueger, T.
CJ.S. EPA,-
eC al.
Addressees
Eagle, D.,
MDEQ
Project File
U.S. EPA
Eagle, O.,
MDEQ
Fagiolo, J.
ec al,;
U.S. EPA
TiTLB/piscairrioM	1M1S
Memorandum Forwarding 321
Actached Literature re:
Information on Phyto-
remediation
Proposed Ecological	19
Remediation Plan for
the Bofors-Nobel Site
Letter re: Settlement of 2
Coatg for the Bofors-
Mobel Site
FAX Transmission re:	2
Minutes of the June 24,
1997 Agency/Technical
Committee Conference
Call Concerning Agency
Concerns with the Proposed
TIC Remedy for the Bofors-
Nobel Site
Memorandum re: MDEQ's	1
Comments on the Bofors
Groundwater Flow Model
Development and Calibra-
tion
Article from Ground	4
Water Currents: Bio-
degradation of tce
Through Toluene Injec-
tion (SPA 542-N-97-Q04)
Technical Memorandum: 866
Total In-Situ Containment
Conceptual Design for
the lofors-Nobel Site
Memorandum re: MDEQ*g	4
Comments on Three Docu-
ments Concerning the
Remedial Action at the
Bofors-Nobel Site
Letter re: Correction	2
to Bofors-Nobel Super -
fund Site PRP Group
Technical Memorandum
-------
Bofors-Nob*l AR
OJxUt* #6
Pag* 4
IOj. pact	aumuh	Mgnmr
24 11/20/97 Graff, C.,	Bagle, D.,
MDEQ	MDBQ
25 12/00/97 Scientific
American
Project File
26 12/00/97 U.S. BPA/
OSWBR
Project File
27
12/24/97
Fagiolo, J.,
U.S. BPA
Hall, B..
NewFields;
et al.
28
01/19/98
Wurzel, K.,
NewFields
Inc.
Fagiolo, J.
U.S. EPA
29
01/27/98
Graff, C.,
MDEQ
Bagle, D.,
MDEQ
30 04/17/98 Fongers, D.,	Eagle, D.,
MDEQ	MDBQ
Tnu/PiscKimwr eass
Memorandum re: MDBQ'3	15
Comments on the Techr
nical Memorandum Total
In Situ Containment
Conceptual Design for
the Bofors-Nobel Site
Journal Article: Pollu- l
tlon-Purging Poplars
Articles from Ground	4
Water Currents: (1)
Reactive Barriers for
Uranium Removal and (2)
Bnhanced In Situ Ana-
erobic Bioremediation
of Fuel-Contaminated
Ground Mater (BPA-542-
N-97-006)
B-Mail re: U.S. BPA	2
Questions Concerning
the Technical Memorandum
for the Bofors-Nobel
Site
FAX Transmission re:	4
NewFields/HSI Geotrans'
Response to U.S. BPA's
December 24, 1997 B-Mail
Concerning the Technical
Memorandum for the Bofors-
Nobel Site
Memorandum re: MDEQ's	l
Comments on U.S. BPA's
Faxed Letter Concerning
Responses to the December
24, 1997 B-Mail to
NewPields/HSI Geotrans
on the Technical Memo-
randum for the Bofors-
Nobel Site
Memorandum re: MDEQ's	3
Comments on the Bofors
Particle Tracking Analysis
of Advective Transport
-------
S&J. S&XK	apthor	HKIHPrr
31 05/00/98 U.S. SPA/	Project File
OSHBR
32 06/15/98 U.S. EPA	Project File
Bofora-Hob«l AS
OjKl»t« ffS
Vag* 5
Tnu/DKSCRIPTIOM	PAW
Articles from the May	4
1998 Issue of Tech Trends:
!l! Long Term Phyto-
remediation of Organic
Soil Pollutants and (2)
Phytoreroediatlon of
Selenium Laded Soils
(EPA 542-H-98-005)
Proposed Plan for the	11
Second Amendment to the
Record of Decision for
the Soils and Sludge
Portion of Operable Unit
#1 at the Bofors-Nobel
Site
-------
KXPLAMAT1QM OF SICNITirANT ilfFFKRKNOES
BUTTERWOHTU LANDFILL SUPEKFUND SITE
GRAND RAPJUR, MICHIGAN
1. Introduction
The purpose of this document is to provide a brief background of the Butterworth Landfill
Superftind rile (Butterworth) and to explain which remedial activities will differ from Ihc
Remedial Action (RA) selected by the United Slates Environmental Protection Agency (EPA) in
the Record of Decision (ROD) signed on September 29, 1992. The Butterworth site is located in
Grand Rapids, Kent County, Michigan, about one mile southwest of the Grand Rapids downtown
area. The site is approximately 180 acres and its approximate boundaries are the Grand River on
the south. Interstate 196 on the west, Butterworth Street on the north, and a Consumers Power
substation on the east (See Figure 1). A combined storm water outfall crosses the site (See
Figure 2). The site is within the hundred year floodplain of the Grand River.
The urea immediately surrounding the Butterworth situ is predominantly industrial (See Figure
I). To the west of Interstate ]?6 arc gypsum mining and processing facilities. Metal recycling
facilities and the Consumers Power substation arc located to the etui. Across the Grand River is
the Grand Rapids sewage treatment plant, which is permitted by the Stale of Michigan to
discharge to the river just south of the site. Between Butterworth Street and the Butterworth
Landfill ;ire several light industrial facilities. To the north of Butterworth Street is a residential
urea, bail park, and a zoo.
The EPA and the Michigan Department of Environmental Quality (MDliQ) have jointly
overseen remedial design activities tithe Butterworth site under the authority of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980, m amended
(CP.RCLA), 42 U.S.C. Section 9601. etseq. U.S. HP A and ihc Butterworth Landfill Cooperating
Parties (BLCP) entered into a uonsent decree for remedial design of the remedial action,
described in n ROD dated September 29. 1992.
The BLCP has designed the remedy for the site under U.S. RPA and MDRQ oversight. During
negotiations for the conaent decree, new information provided by the BLCP has persuaded IJ.S-
EPA and the MDliQ that certain technical modifications and improvements lo the selected
remedy ure appropriate.
Section 1170 oJ'CHRCLA and Section 300.435(c)(2)(1) of the National Oil and Hazardous
Substances Cuniingcacy Plan establish procedures for explaining, documenting, and informing
the public of significant changes to the remedy thai occur after the ROD is signed. An ESD is
required whea the remedial action to be talcen differs significantly from the remedy selected in
the ROD but docs not fundamentally alter that remedy with respect to scope, performance or
1
-------
10:3128864071
JAN 13199
9 = 54 No.004 P.03
FIGURE 1
PW
i
$

77
§e
•A
/M*S* i
?«*gfcwiev
•ilkk O*
^¦y«- r^—
-------
3128864071
-------
. - - / J , 4 IV . It. Jt I Ji iiTli i I ^
faa jj. :vc o;j
ID 53128864071	JflN 13'99 9 = 56 No . 004 P.05
cost. This Explanation of Significant Differences (F.SD) and suppoitlng documentation shall
become purl of the administrative record file which in available at the Main Branch of the Grand
Kapids Public Library, the West Branch of the Grand Rapkls Public Library and at the U.S. F.PA
regional office in Chicago, Illinois (77 W. Jackson Dlvd, 7th Floor) during normal busines*
hours.
II. Summary of Site History, Contamination Problem*, and Selectod Remedy
A. Site History
llic Bultcrworlh Landfill site (See Figure 1) was operated by the City of Grand Rapids,
Michigan, and was used for both residential and industrial waste. Land filling was performed in
three general areas at the site. The limited information available indicates that, prior to 1967, the
area to the cast of the storm sewer outAUi was used as a municipal landfill. This area is referred
to as the Old Butterworth Dump, or Butter-worth it\. This portion nf the site was operated as an
open landfill where daily cover of rcftise wax not provided. The refbsc was oAcn burned to
reduce its volume.
After the enactment of Michigan Act 87 in 1965, and consistent with (he federal goal of
eliminating open dumping, the Old Butterworth Dump was closed sometime uround 1967 and a
now site, Butterworth Landfill #2, was opened. This new site occupied an area in the southwest
corner of the site.
Later, an additional area, Butterworth Landfill #3, was opened. The combined size 
-------
ID 13128864071	JAN 13'99 9 = 56 No.004 P.06
13. Caann)iu4ni Problems
Surface soil sampling conducted during the Remedial Investigation discovered arsenic
contamination as high as 34 puts per million (ppm), beryllium to 8.5 ppm, chromium to 43,000
ppm. polynuciear aromatic hydrocarbons (PAils) to 12) ppm, polychlorinau»d biphenols (PCBs)
lo 800 ppm and dieidrin to 0.29 ppm. Groundwater sampling discovered antimony to levels of
193 parts per billion (ppb), arsenic to 58 ppb, 1,1 -dichlorocthane to 47 ppb, vinyl chloride to 61
ppb, and bis (2-ethylhcxyl) phthaJate to 310 ppb.
C Selected Keeaady
The ROD for the she (September 1992) required:
Institutional controls;
* Grading arid leveling of the site;
Removal of exposed drums containing hazardous material, substance or waste, and
disposal off-she at a permitted RCRA Subtitle C disposal fuciHty;
Improvement of the site capping to meet the Michigan solid waste cap (Mi Act 641)
requirements with inclusion of a froal protection layer,
Establishment of Alternate Concentration Limits (ACI-s) for groundwater;
Groundwater, surface water and river sediments monitoring;
III. Description uf the Significant Differences »nd tha liuis for those Differences
Determination uf Alternate Concentration Level*
The ROD for the site required the development of A Item ale Concentration Limit* (ACLs) for
shallow groundwater and die implementation of surface water, river sediment, and biological
monitoring programs. These actions were required to monitor for any potential adverse effects of
groundwater venting to the Grand River. Subsequent changes to Michigan regulations allow for
a different approach to the ACL determination for the site.
The regulations identify criteria for measuring the impact of contaminated groundwater on
surface waters, These regulations evaluate the significance of contaminated groundwater venting
to surface water by ooniparing the onsile groundwater contaminant concentration# to the
Ground water/Surface Water Interface (CiSl) criteria that are established by the MDEQ Surface
Water Quality Division (SWQD). As provided under Fart 201 of the Natural Resources and
linvironmcntai Protection Act, 1994 PA 451, the GSI values are developed in accordance with
Rule .123,1057 (Rule 57) of Part 4 of Part 31 of Act 451 (formerly known as Act 245), and the
National Toxics Rule (NTR; Federal Register, 12/22/92).
3
-------
• -••• • '-1 J-'-t am	:aa .i3. o;i	r, UU7
ID :3l288640?l	JfiN 13'99 9:5? No.004 P,07
The generic GSI criteria arc established and updated periodically baaed on available
lexicological and exposure dsia for human health and aquatic life. The generic GSI values are,
with the exception of arsenic, the move restrictive »f tho Rule 57 values and the Nut values,
where bmh values are available,
lite MDEQ Environmental Response Division (liRD) uses GSI criteria to provide protection of
human health and aquatic life in surface waters of the State. The MDHQ published generic OS1
criteria in ERt? Operational Memoranda #8 and #14 (the values are the same in both documents),
whit^t arc periodically updated. The published CIS! values are used for surface water that is not
used 9$ a drinking water source. Thews GSI criteria may cither be "generic" or sito-spccifle,
mixing zona based GSI criteria. The portion of the Grand River located near the site is not used
us a drinking water source. The City of Grand Rapids obtains their drinking water directly from
I-ake Michigan.
The RRD guidance at the time the ROD was signed stated that the GSI criteriu were used to
judge compliance with Rule 299.5713 but did not allow for a mixing zone fur discharges of
venting groundwater.
Ai ihe time the ROD was signed, the relevant groundwater data exceeded a limited number of the
published GSI values; and, because a mixing vmnc was not allowed, a range of alternatives to
protect surface water were considered in the ROD. Despite rhe exceedance of the generic GSI
values, the surface water and sediment simplex that were collected during the R1 did not show a
statistically significant impact on surface water or sediment attributable to the site.
The ROD evaluated this information and eoncludcd that ACLs were appropriate for (he sire due
to the absence of site impact on the Grand River.
The promulgation of the Part 201 amendments and related amendments in June 1995, changed
the GSI methodology for remedial sites in Michigan, by specifically allowing for a mixing rone
for discharges of venting groundwater.
KRD Operational Memorandum #14, Revision 2, dated June 6, J 995, states that the GSI values
define the maximum allowable hazardous substance concentration at the GSI, or at the edge of «
mixing zone, whichever is applicable t» a specific site. This memorandum also slates that a
mixing zone is allowed at those sites where an additional load to the receiving stream of site-
specific contaminants is allowable and where a mixing Zone is appropriate for the receiving
stream.
The mixing zone based GSI criteria, which arc site specific criteria, are the filial ucuie values
(FaVs'J for toxicity Ui aquatic life. Mixing zone based GSI criteria luive been developed for the
Butterworth Landfill. Since mixing zone based GSI criteria are risk based critorla that were
developed to protect human health and aquatic life in surface water, it is acceptable to utilize
these criteria to establish the ACLs for the site.
4
-------
-?v.
^ 75" "gffl ^
ID'.3128864071
:BN 13'99	9:58 NC.00/1 C.M
17» mixing zone based GSI criteria developed under (ho State of Michigan's Part 201 program
will be substituted for the ROD recommended methodology for developing the ACLs for
L'rumitJwater and will become tbe ACLs for tho Butterworth site. Tbe monitoring program used
to measure compliance for the GSI numerical criteria would also replace tbe ROD requirement
for surface water, river sediment, and biological monitoring.
Hie implementation of tho GSI criteria will replace tbe ROD requirements for surface water,
river sediment, and biological monitoring and use of tbe GSI criteria will protect human health
and aquatic lift and will provide a mechanism for measuring the effects of groundwater venting
to the Grand River,
The mixing /one approach lor establishing ACI/S will allow for faster implementation of the
remedy than Lhc schedule outlined in the ROD. The criteria used to establish tbe GSI values
have already been established for this site; the ROD called for a minimum of two yours after the
cap installation is completed for ACLs to be established.
For the reasons mentioned above, U.S. HP A believes that substitution of GSI criteria for the
methodology outlined in the ROD is as protective a* the ROD remedy of human health and the
environment.
Original Kfmptfr
Kstablishinent of Alternate
Concentration Limits (collection
of a minimum of eight quarterly
rounds of groundwater data and
statistical analysis to determine
ACI.s)
Surface waler, river sediments and
biological monitoring program
Alternate Concentration Limits (ACLs)
(Groundwatcr/surfacu wntor interface
numeric criteria developed by the Stale of
Michigan exclusively for the Butterworth
site (See Table 1)
GSI performance monitoring program
Soil Covtr over the Radio Tower and Station Building (RTSB) Area
The ROD i'or the site calls for the upgrade of the existing landfill cap to meet the requirements of
Solid Waste Management Act 641 (1978), as ameudod, Michigan Code of Laws (MCL) Sections
299.401 through 299.436. This upgraded cap would include a vegetative soil layer consisting of
a minimum of six inches of topsoil, an 18 inoh thick rooting zone layer, and a low permeability
clay layer, with » minimum thickness of 24 inches. In the vicinity of the RTS1J area, this cap
upgrade would he modified to incorporate a soil cover, consisting of 6 inches of ropsoil
(permeability of 4 x 10(-7) an/see) and 6 inches of loan clay and silty clay (permeability of 7.2 x
J0(-4) an/sec).
5
-------
ID:3128864071
JAN 13-99 9:58 No.004 P.09
Table 1


S-~-.!&SSu3rs3rSS£
*ni;:rr -i:,-
Acsnaphthena
n
1 /.bichloiabviuxne
160
Antimony*
|,400{A|'
Uicldrm*
0.4K
Arsenic*
MO
Uthylbamnw
320
Uarium*
2,300
Iron*
NL
Benzras*
ijm
l*vt*
2J00
8ott>-BHC*
1.9
Mmgancse*
NA
BIH2-c»l»ylhttxyl)pHh«irt»*
2iS
NlckcJ*
4200 (A]
Biologic*! oxygen demand
10,000*
Nitrogen, anmnnia
2.0001
Cadmium
52 {A}
PCfti*'
MOI.
Chkirobmmne
ISO
Selenium
120
ChlareethMe*
m
SHv«f*
22
Chromium, total*
3,tOO (A)
t'olucnc
1,700
Chrowium, VI
12
I'otnl (iitsolved solids
1.650,000,000'
Cobn)i
740
Tricbloroethenc*
3,300
Copper
100 (At
Vsnadiua*
220
Cywiide, itntciiiible*
44
Vinyl chlarido*
15"
IJ-Wchteroethano*
m
Xylcnci, Mai"
630
1,2-Oichloroclhono*
7JOO*
Zinc*
1.100 (A}
I V AlKxiiutcConeeslratian I.Jmlu «t Sun »ifMtaMtan «Ma$loae-Wirf sromwtarMar-Mfftec **"' Interlace (OS1) c/llcn*. Wllh the
Ol' llOU, iinowwl* (Hmt, pmI TD«, iW« atote are 0«e Wont Asm* Value* dmsbHto* by ik» SWQD, IT* uritula lew HO!l, aiiimoalR, *«!»«¦.
an J TUS aln dilutkM Willi |0P pwoasnt of the *Uva« dcalgft ll»»
Jutk Wttyeheclt (« Hoe> Kunki, d*rd Niwembei-10. J1W7). TW avw**. limit wnld K*470.CKl0,Qua t grt. (hweit en rlvL-,	n>S«- 400 mgfl.
«,*i*e/ - (MU tf,. «nd	- o. 17 eft.)
*	Utnuminiint olCrtmem In UHjwndwaicr, h tbwd III TaMa >4 of the *en*aial ricdgn Wort. Wail
Ml II	MwK.iJ J^cetmi liMtl
NA	N°< o»fiil»l>lc from !¦ MDtiU, !hv SWQD I* o*iifciaUr»| erliirti fin Uiuc eanuiiHaau. I-'imH valaat will be inimud Jnu> thlj (ithlfc and become
mfercanMe wfien available fran> (Im MDDQ.
Nl»	Not (ScteuKd
Nl	No limit TlKMIiKOItMdotcnntncdUniamlaln|ua»^««a
-------
ID:3128864071
JAN 13*99
9=59 No.004 P.10
I liitorical groundwater monitoring results lbm the Rl, the first mixing zone determination
sampling event, and flic first round of remadial design groundwater monitoring, indicate that the
groundwater quality between Ihe RTSB ami and the Grand River meets the mixing nme GS1
criteria outlined above at the present time.
)"he wRStcs present in the RTSB am* have been reported to be older and more highly weathered
than other areas of tho landfill and would be more likely to leach lower amounts of
contamination than the other areas of the landfill. As reported in the Rl report, the waste in this
area lacks significant amounts of pntiexdfaie organic material or decomposing waste odor, and
lacks significant subsurface landfill gas pressure.
Because si portion of the land filled waste 11m below the water table, die reduction in contaminant
flux from the landfill to the river would be minimal, even with placement of an Act 641 clay
cover over the RTSB area.
The ROD requirement entailing the placement of a clay cap over ihc site will be modified to
incorporate the placement of a soil covor over the RTSB area (Soc Figure 3). The soil cover also
addresses the ROD concerns by providing protection from direct contact with landfill content!*.
The groundwater monitoring performed to determine compliance with the mixing *onc OS1
criteria, will be used in assessing the effectiveness of the soil cover during planned five year
reviews at the site. If the live year revicw(j) indicate that the groundwater contamination
exceeds Ihc ACL value? established for the site, a contingency plan ia in place that inquires the
replacement of the soil cover with a day cover over ihe RTSB area. The clay cover would meet
the requirements of Solid Waste Management Act 641 (1978) as amended. Michigan Code of
Laws (MCL) Sections 299.401 through 299.436.
Furthermore, lhcrc are no water supply wells within the portion of the aquifer affected by the
landfill and deed restrictions will prohibit the future installation of water supply well* in affected
portions- of the aquifer, limiting the potential exposure to human health.
A soil cover over the RTSB area is protective of human health and the environment, because it
will prevent direct contact with the landfill content* and will prevent Inhalation of airborne
particles affected by the landfill (exposure pathways of concern identified in the ROD),
Groundwater affected by Icachalo from the RTSB urea will be monitored to ensure compliance
with mixing zone GSl criteria that were developed to address potential human health and aquatic
life exposure at the groundwater/surface water interlace.
Increased groundwater contaminant loading, although a potential problem, will be monitored
closely to ensure no adverse impact to groundwater from the installation of the soil cover
-------

r_i
^ ^ tIPi Wi m:
Or.*ni None A\0MM\29\)«M200I IMS Pfcl 0«U:
apti>t«r x«n*. woo	rM runt	10.1*
ic°>»	I'-UW	MtKtwd */HV	<*> .rtl'i 41 Vacta4
tfrwr'i/t..*
fhuoAoy. Aufv»l I. **»4
l.tM  mwn » awntic
s
1!
o^owm
t'STAJIQN


SEI
LOCATION OF THE RADIQ TOWER &
STATION BUILDING AREA WITHIN THE
BUTTERWORTH LANDFILL
GRAND RAPIDS, MICHIGAN
mmmoi jwc :,
FIGURE 1
-------
ID-3128864071
JPN 13 * 99 10:01 No .004 P.12
Original Rcm«dv
Mndifltd Beipttfy
Improvement of the site capping to
meet the requirements of a solid
waste cap (Solid Waste Management
Act 641 (1978), a, amended, Michigan
Code of Laws (MCL) Section* 299.40)
through 299.436)
Inclusion of a requirement for placement
of a soil cover (minimum 12 inches) over
the RTSB area, while maintaining the
requirement for the solid waste cap
specified in the ROD for the other
areas of the landfill
It i* estimated that approximately 1700,000 in eost saving* can be realized by utilizing the GS1
criteria as the ACLs, eliminating the need to conduct the surface water, river sediment, and
biological sampling and also eliminating die number of monitoring events needed to establish the
ACLs. Because additional evaluation to distinguish silo related impact* to the riv«r from other
potcntiiii sources is unnecessary by using the GSI criteria m (he ACXs, additional cosr savings
may he realized.
It is also estimated that approximately 52,000,000 in cost savings can be realized by
constructing a soil eovor over the KTSB area instead of an Act 641 clay cover, mainly from
reduction in material and transportation costs.
IV.	Support Agency Comment*
MDiiQ concurs with this F.ST).
V.	Affirmation of the Statutory Determination*
Considering the new information that has been developed and the changes that have been made
lo the selected remedy, U.S. EPA and MPEQ believe that the remedy i-emains protective <,f
human health and the environment, complies with federal and state requirements that were
identified in the September 1992 ROD as applicable or relevant and appropriate to this remedial
action at the time of the original ROD, and is cost effective. In addition, the revised remedy
utilizes permanent solutions and alternative treatment technologies to the maximum axiom
practicable for this site.
VI.	Public Participation Actlvitiaa
U.S. lip A will publish a nolicc of this KSD in the Grand Rapids Press and The West Side
Advance newspapers, informing intamsted parties that a copy of the USD, and supporting
documentation is available at the Grand Rapids Public Library - Main Branch, 60 lJbroiy Pluxa.
NF., and Grand Rapids Library - West Side Branch 713 Bridge Smart, NW, and at the IJ.S. liPA
regional offices in Chicago, Illinois, 77 W. Jackson-7th Floor, during normal business hours.
7
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ID:3l288640?l
JflH 13'99 10:01 No.004 p.13
VI1. ConeiifT*BC«
,		(°/l 3 /ft
WjJliatn B, Muno, fljrccf&r	Dale
Supcrfimd Division
8
-------
w
A WASTE MANAGEMENT COMPANY
AUTUMN MILLS RECYCLING & DISPOSAL FACILITY
7C0 jfcth Avenue
Zeehnd, .MI ¦ff-o-
(oIo) 68-3-577"
(61 c"> cSS-iT?'. ?2\
December 13, 2000
Kathy Cavanaugh
David Haywood
Michigan Dept. of Env ironmental Quality
Environmental Response Division
Assistant Attorney General
Natural Resources Division
300 S. Washington Square
Lansing, Ml 48913
Plaimvell District
1342 SR 89 West
RECEIVED
Plainwell, MI 49OS0-1915
Subject: Remedial Action Plan dated November 1998
MDEQ Six Month Review Period
Cereal City Landfill - Battle Creek. Michigan
ERD - KALAMAZOO
DEC 2 6 2000
Dear Ms. Cavanaugh and Mr. Haywood;
Irs November, 1998 Waste Management Inc (W Ml) ^uomitied the above rct .*rcnccd
Remedial Action Plan (RAP) for review -ir-1 appr n;" { y the Micmgan Department ?!
En< ironmenta- Quality ,MDEQ). As the reguLtc y six y6) month tmie frame for MDEQ
review of the RAP was nearing a close, the MDEQ trquested irom U aste Management.
Inc. a series of time extensions for conrnuod review
Wasie Management, Inc. granted the MDEQ requests for time extension on al; occasions
and the MDEQ accepted each of the time extensions Per MDEQ request. Waste
Management. Inc. granted the last extension in April 2000. This extension expired on
September 30, 2000. MDEQ did not request any further time extension for review of the
RAP. Waste Management, Inc considers the RAP approved under P.A. 451 Pan 20!
Section 20114(8), as submitted in November. 1998.
If the MDEQ would like additional copies of the approved RAP for the public record,
please contact me at (616) 688-5777 ext. 17 and I will be forward them as soon as
possible.
Phillip M. Mazor
Remedial Project Manager
cc: Jim Forney (Waste Management, Inc.)
Katie Moertl (Quaries & Brady)
Linda Hicken (RMT)
Sincerely,
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"Sava Heywccd - Cereai C.:y LF - Call" i County
PageTJ
From:
To:
Date;
Subject:
David Heywood
O'Donnell, David
Thu, Sep 7, 2000 11.28 AM
Cereal City LF - Calhoun County
As you know, a RAP was submitted by Waste Management, Inc (WMI) for the Cereal City LF site in
Calhoun County some time ago while Calhoun County was still under Jackson District's jurisdiction- At
the time of the District Boundary change on 10/1/97, Jackson elected to retain oversight of the project
because they felt they were close to bringing the RAP to final approval. The premise was that once the
RAP was through the approval process, they would transfer it over to us for implementation and tracking.
Unfortunately, even though Jackson successfully negotiated agreement on the technical aspects of the
RAP with WMI. final approval has been delayed by an unresolved disagreement between C&E and WMI
on, I believe, a Financial Assurance Mechanism (FAM). The FAM is a necessary element for the final
AOC that would serve as the legal agreement since the RAP proposed a Limited remedy. There have
been several extensions on making the final decision on the AOC. The most recent is set to expire on
9/30/00. Meanwhile, last year Jackson asked that we take the site over m spite of the continuing
disagreement. WMI. to their credit, has implemented the technical portions of the RAP notwithstanding
the fact that an agreement on the AOC is not in place. They have completed final construction and are
performing maintenance activities, conducting ground water and gas monitoring events on schedule and
submitting the appropriate reports. Since we have a PPP that is implementing a RAP in good faith, it
seems to me that it would be prudent for C&E to make a decision on this issue so that we can resolve this
outstanding matter and everyone can go on about their business.
I feel that it is important to lay out a chronology as best I can from reviewing the file. It follows:
1/17/97 - Jackson receives RAP from WMI
1/17/97 - 4/2/97 - Jackson completes district review and solicits review by Tox Unit and others as
appropriate
4/2/97 - Jackson takes RAP to Field Ops QRT.
5/9/97 - Jackson sends correspondence to WMI informing them that RAP is administratively incomplete
due to aosence of Institutional Controls, Restrictive Covenant, etc. and also provides them with list of
technical deficiencies.
5/9/97 - 12/1/98 - Jackson works with WMI to negotiate fma! technical considerations for RAP Jackson,
in conjunction with C&E. works with WMI and Local Units of Government to implement Institutional
Controls, develop Restrictive Covenant and other pertinent aspects of proposed AOC. During this 1 and
V; year period, WMI commences with construction at site and begins monitoring events in accordance
with proposed AOC.
12/1/98 - WMI submits revised RAP
4/22/99 - Case is reassigned from Asst. AG Finkbeiner to Asst. AG Cavanaugh
5/10/99 - Jackson District Supervisor George Jackson sends memo to Plainwell District Supervisor David
O'Donnell indicating that all technical issues have been resolved with the revised RAP submitted on
12/1/98 and that negotiation of the AOC is ongoing because the PPP has not agreed to language that the
state believes to be appropriate.
5/13/99 - Meeting held between Jackson and C&E on status of negotiations. Plainwell DEC Frank Bailo
attends at request of Jackson District to receive update.
5/20/99 - Correspondence from WMI counsel to Cavanaugh referencing letter from 1/21/99 in which WMI
agrees to time extension to 8/1/99 (Extension #1).
5/21/99 - Correspondence from WMI to Jackson District agreeing to time extension to 10/1/99 based on
conversation between Cavanaugh and WMI counsel(Extension #2).
5/24/99 - Email details disagreement between Jackson District and C&E on whether agreement in
principle on administrative elements has occurred and thus, on whether or not "Intent to Approve" letter
can go out,(There is no "Intent to Approve" letter in the correspondence file)
6/28/99 - Meeting of all parties including WMI is held.
8/24/99 - Correspondence from WMI to Jackson District agreeing to time extension to 1/11/2000 based on
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Page 2 |
conversation between Cavanaugh and WMI counsel.(Extension #3)
12/16/99 - Correspondence from Cavanaugh to WMI counsel in which she apologizes for delay in getting
language to WMI counsel regarding WMI's request to modify language in FAM. She indicates that these
issues are still under review by DEQ. She suggests another time extension to 4/12/00
12/17/99 - Correspondence from WMI to Jackson District agreeing to new time extension(Extension #4).
1/14/00 - Correspondence from Plainwell District to WMI confirming extension to 4/12/00 because no one
in Jackson District responded to the 12/17 correspondence.
4/7/00 - Correspondence from WMI to Plainwell District agreeing to time extension to 9/30/00 for final
decision on RAP
4/20/00 - Email from Asst AG Jonathan Pierce to F Ballo and L Elmleaf saying he has no problem
granting new time extension.(K Cavanaugh had lateraled the case to Pierce)
4/20/00 - Correspondence from Plainwell District agreeing to time extension to 9/30/00(Extension #5).
End of Plainwell District File.
To mine and F Ballo's knowledge there has been no recent progress in the resolution of this matter
between C&E and WMI. It was our understanding that C&E was to maintain the lead in solving this
problem As previously mentioned, the new deadline is looming on 9/30/00 I believe this matter needs to
be resolved ASAP and as such I am requesting your assistance in doing so Please advise.
Da>'ia Heywood - Cereai City LF - Caif i County
CC:
Ballo. Frank
-------
STATE OF MICHIGAN
JOHN ENGLER, Governor	REPLY T°
DEPARTMENT OF ENVIRONMENTAL QUALITY	0FFICE
'3etter Service for a Better Environment"
PLAINWE'.l Ml 49C0O-I915
HOLLISTER BUILDING. PO BOX 3CM73 LANSiNG Ml Je909-7973
INTERNET www d«a state m us
RUSSELL J. HARDING, Di'ector
May 25, 2000
RE-MAX PERRETT ASSOCIATES, INC.
Attention: Mr. Neal Vanderwaal
121 Capital Avenue NE
Battle Creek, Michigan 49017
Dear Mr. Vanderwaal:
SUBJECT: Cereal City Landfill, Battle Creek, Michigan, Calhoun County
I am writing pursuant to your telephone inquiry regarding the status of the Cereal City Landfill
located at the intersection of Hubbard and Goodale in Battle Creek, Michigan, Calhoun County.
The Cereal City Landfill is currently owned and managed by S C. Holdings, Inc., a subsidiary of
Waste Management, Inc., (WMI). WMI submitted a Remedial Action Plan (RAP) to the
Department of Environmental Quality (DEQ) in 1997. T^.e RAP was subsequently amended to
its final version in 1998.
The RAP was submitted in order to meet the requirements of Part 201, Environmental
Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as
amended (Act 451). Those requirements provide that the response activity proposed in the RAP
assure the protection of the public health, safety, and welfare, and the environment. Further, the
RAP must attain a degree of cleanup and control of hazardous substances that complies with all
applicable or relevant and appropriate requirements, rules, criteria, limitations, and standards of
state and federal environmental law.
In order to accomplish the above, the response activities proposed by WMI in the RAP included,
but were not necessarily limited to: 1) prohibition of the use of ground water for potable drinking
water in the vicinity of the landfill as stipulated by City of Battle Creek ordinance; 2) long term
monitoring of existing ground water contamination; 3) repair and long term maintenance of the
existing landfill cap; and 4) the collection and long term monitoring of methane gas produced by
the landfill.
The RAP was reviewed by the DEQ and found to be acceptable in meeting the requirements of
Part 201 as discussed above including being protective of the public health, safety and welfare.
WMI has successfully implemented the RAP and is currently completing their monitoring
requirements in compliance with the RAP.
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Mr. Neal Vanderwaal	-2-
If you have any further questions or comments, please contact me.
May 25, 2000
Sincerely,

David J. Heywooa
Environmental Response Division
Plainwell District
616-692-2689
DJH/MS
cc: Mr. David O'Donnell, DEQ
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.CEREAL CITY LANDFILL
13 Calhoun CORRESPONDENCE 1995-1997
-------
STATE CF MICHIGAN	1

CCLf
SS-'-Y "O:
JCHN SNGLE3, Governor	^acxscn -xs^'z~ cp-ch
DEPARTMENT OF ENVIRONMENTAL QUALITY	"
HCLLISTES 3UIL0ING. PO SOX 3C473. 1>NSING Ml 48800-7873	.ACX3CN Ml iSX'.tSjS
iNTESNET: ?irta :a*ww itjt* .m.ui
RUSSELL J. HARDING, Onset ex
May 9, 1997
Mr Philip Mazor
Waste Management of Nonh America
Autumn Hills Recycling and Disposal Facility
700 56th Avenue
Zeeland, Michigan 49464
Dear Mr Mazer:
SUBJECT. Acknowledgment of Receipt of an Administratively Incomplete Remedial Action Plan :cr
the Cereal City Landfill Site (CCLF), Calhoun County, Michigan.
The Michigan Department of Environmental Quality (MDEQ) has received i Remedial Action Plan (RAP)
dated January 1997 for the CCLF facility. This RAP was received by the Jackson District Onfice cn
January 17, 1997
Section 20114(3) of Part 201 of the Natural Resources and Environmental Protection Act ONREP.V!, 1994
PA 4j 1, as amended, states that the MDEQ shall either approve cr deny the ?A? within s:.x months of ±e
submittal of the information necessary or required for the department to makes its decision. The MDEQ
considers a RAP administratively complete when all information necessary or required to approve the RAP
in its entirety has been subtracted.
The above-mentioned RAP has been reviewed, by staff ion the Jackson District and Lansing offices and
has been found to be administratively incomplete. Since the above-mentioned RAP ;s classified as a limited
commercial RAP, the following items are required and will need to be submitted to the Jackson District
Office before the MDEQ can make a decision regarding RAP approval:
TECHNICAL ASPECTS OF RAP:
Groundwater
1.	The concentrations of iron and manganese exceed the genenc residential cleanup criteria (GRCC) for
dnnking water at the furthest downgradient monitoring locations W-13 ana W-17. The estimated race
of removal from groundwater of these constituents is 2 ppb/ft. and 0.7 pp'o/ft., respectively. Based on
the removal rates, ic is estimated that compliance with GRCC occurs 18 fee: downgradient of W-13
and 107 feet downgradienc of W-17. The horizontal downgradient extent of groundwater
contamination should be defined to include the area with groundwater contamination in excess of
GRCC
2.	The groundwater contamination should be indicated to extend vertically through Marshall
Sandstone.
=zp noc-
-------
Mr Philip Mazor
Waste Management of North America

May 9, 1997
3	Sperry Drain is a water of the State. Discharges to waters of the State are regulated by Part 31 and
Part 201 of 1994 PA 451. Tne concentration of ammonia exceeds the groundwater\surfacewater
interface criteria (GSI) at locations W-14, OB-2R and W-L5B (upgradient and downgradient of the
drain). Surfacewater's Rule 57 regulates un-iomzed ammonia discharges. The calculated
concentration of un-ionized ammonia, which is dependent on pH and temperature, exceeds GSI at W-
143 Tne concentrations of banum and chromium exceed the GSI at location 14. Total concentration
cf chrcrruum was measured m the groundwater and compared to the GSI for hexavaient chromium
(GSI for tnvaient chromium was not exceeded). A GSI monitoring well should be installed
downgradient of W-14 and monitored for compliance with GSI for ammonia, banum. and chromium or
another alternate method to demonstrate compliance with GSI.
4	Tr.e points of compliance for groundwater monitoring should include monitoring wells W-l 1C, OB-8R,
and the GSI monitonng point. Addition of these monitoring points to the monitoring program will
increase confidence with the model predictions cf bicremediation processes occurring.
5	The groundwater sample parameter list should be expanded to include iron, manganese, sodium,
chloride, banum (GSI), chromium (GSI), and other parameters indicative of the effectiveness of the
bioremediation (i.e., temperature, pH, DO, etc.).
6	The purge water may be discharged to the ground surface if the contaminant levels in the groundwater
are protective of human health and the environment (i.e., appropriate cleanup criter.a)
Landfill (LF) Gas
1. The continuous air monitors inside the houses need to be aoie to notify homeowners cf elevated gas
levels when unattended. Tne owner's manual for the Dicon models say the unit's sensor should be
vacuumed each month. Tne 0 & M Plan should be modified to provide for this or the Dicon models
should be replaced with a model that will require less frequent maintenance and will notify homeowners
of elevated gas levels when unattended.
2 Tne endpoint of the monitoring in the houses needs to be more specif c than "monitors are expected to
be maintained until LF gas generation and migration potential are negligible". Shut-off should be
based on safety issues and require approval of the MDEQ Please indicate plans for shut-off to occur
after demonstrating to MDEQ's satisfaction that monitors are no longer needed.
3. Tae contingency plan for LF gas should include a response plan to remedy LF gas in the event of
migration past extraction system and impacted residents.
4 It appears that the south and southwest comers of the north waste ceil has waste that will be outside the
radius of influence of the gas extraction wells (see Sheet 4 of 6). The waste extends approximately 400
feet beyond GW-N'14 and GW-N15, approximately 250 feet from property line. Please confirm the
system will effectively control gas migration in this area or modify design as appropriate.
Reporting
1 Attachment II (Figure EI-2) should include other field observations (i.e., ocor, standing water around
casing, etc.).
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Mr Philip Mazor
Waste Management of North America
May 9, J 997
2. The information regarding the observed condition of the monitoring wells should be noted in the Water
Level Measurement Record.
3 The following documents should be included in the annual monitoring report: water level measurement
records, stabilization test records, chain-of-custody forms, gas prc'oe data sheets and gas extraction
well and blower system data sheets.
-V N'on-ccmpiiance events should also be reported to the MDEQ Jackson District OfEce.
5	The Emergency Response and Safety Plan should include a spill response for the condensate tank. Tee
tank will need to comply with applicable requirements if the condensate is hazardous waste.
6	In the Emergency Response Health and Safety Plan, the emergency phene numbers should mciuce the
PEAS phone number 1 -300-292—^706. Lon AicnocT 3 correct phone number :s 5 17-"S0-7339
7. Reportable quantity spiiis, spills that run-off the property, and spills due to containment system failure,
should be reported to PEAS, not EAD.
General
1.	The statement (on page I and page -V of Appendix A of the RAP) that Phil Schrantz's 7/10/55 memo
confirmed that the landfill had been closed in accordance with the 1932 closure agreement is incorrect
and should be revised or deleted.
2.	Throughout the document, the landfill property is referred to as the site. Please recognize that under
Pan 201, site has a specific meaning relating to the extent of contamination attributable to the release
which should be used in this document
3.	Tne proposed activities may require a Permit-by-Rule for Storm Water from Construction Activities,
40 CFR Sec. 122.26(a) from SWQD, and a permit to install the culvert m the regulated wetland from
LWMD These should be added to Table 3 and Table 5 as necessary
4.	SVv'QD staff advise a check dam may be required in the low area that discharges to the wetland (see
sheet I of 6) to control sediments. This dam will require regular maintenance. Please incorporate in
the plan or give evidence that SWQD staff are satisfied with the current design.
5.	Tne Task Specific Hazard Assessment Table 3-1 should indicate diggmg greater than 6" is restricted.
6.	There are errors in some of the tables (e.g., Table 7). Tae MDEQ does not necessaniy agree with the
interpretations of the laws and policy presented in the taoies, but specific comments are not presented.
SITE COVER:
1. The plant species selected for vegetative cover should thrive without supplemental watering or fertilizer
application.
-------
Mr. Philip Mazor
Waste Management of North America	-4-
Mav 9, 1997
2. The existing perimeter fence will not act as an exposure barrier to waste that is buried on the property,
but outside of the fence. The fence should be moved to enclose die waste or the waste brought into the
containment area.
PERMANENT MARKERS:
Tne company name and phone number should be eliminated from the markers and a description of the
containment area (i.e., size and location) should be included.
OPERATION AND MAIN'TENANCE PLAN:
i Tne cover inspection frequency should be increased from once to twice a year for the first two years.
2. Please specify- the time frame for maintenance repairs to the cover and other RAP elements.
RESTRICTIVE COVENANT (RC):
A RC was not included with the submittal. A fin.il draft of the RC is required before the MDEQ issues a
notice of intent to approve the RAP.
INSTITUTIONAL CONTROL (IC):
1.	A statement of intent to implement and a time frame for passing an ordinance to restrict well drilling in
the ccntroLled area of the site from the local unit of government is necessary
2.	Tne IC needs to include the entire plume in excess of the aesthetic and health based GRCC.
3	Tne properties where the IC will be implemented need to be specifically identified in a manner which
allows for independent confirmation of the location at which the IC apply.
4	A time frame for implementation of IC Option £3 needs to be identified.
5	A mechanism to verify* there will be no exposure to contaminated groundwater prior to the IC being
implemented, needs to be proposed.
6	A contingency for failure to implement the proposed IC is necessary (i.e., a commitment from the PLP
that a remedy will be implemented if the proposed ICs fail, and a conceptual description of the
proposed contingency remedy).
7	Tne document attached to the deed	is not a deed restriction. It is an affidavit
advising that the water well is located in an area where groundwater is contaminated. Therefore,
appropriate IC needs to be planned for this location.
FINANCL\L ASSURANCE MECHANISM (EAM):
Before the Department will issue a notice of intent to approve, the financial assurance mechanism needs to
be identified.
-------
Mr. Philip Mazor
Waste Management of North America
-5-
May 9, 1997
Pursuant to Section 20114(8) ofNREPA, the MDEQ will either approve or deny the RAP within six
months of the date that the administratively complete RAP is received in its entirety at the Jackson District
Office. If you have any questions, you may contact me or Lon Aronoff at 517-780-7839. Thank you.
GK.LA:id
cc: Mr. Dan Schultz, MDEQ
Ms. Patricia McKay, MDEQ
Mr R. Dowe Parsons, MDEQ A/ffl)
Ms. Lori Aronoff, MDEQ
Sincerely,
Gary Klepper
District Supervisor
Environmental Response Division
517-780-7852
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MICHIGAN ' ^ARTMENT OF ENVIRONMENTAL r 'XLITY
INTEROFFICE COMMUNICATION
April 3, 1997
TO:
Andy Hogarth, Assistant Division Chief, ERD
Lynelle Marolf, Policy Development Specialist, ERD
FROM: Lon AronofT, Project Manager, Jackson District ERD
SUBJECT: Remedial Action Plan (RAP) for Cereal City Landfill (CCLF), Dated January 1997, Battle
A Lansing Quality Review Team (LQRT) meeting was heia on April 2, i 997 to discuss the proposed RAP
for the CCLF. This memo summarizes the District's understanding of the LQRT's recommendations for
the RAP. The LQRT is in agreement with the Jackson District QRT's (JDQRT) recommendations with
the following exclusions or additions:
1.	The District will find out what kind of deed restriction was placed on the residence at 4^^^^^^
by the Calhoun Co Health Dept.
2.	The District will ask SWQD if Sperrv Drain is a "water of the State" and subject to Part 31 of PA
451.
3.	The District wiil determine if COD/TOC is a problem in W-I4B for GSI.
4.	The institutional controls (IC) proposed need the following additional items:
•	A statement of intent and a time frame for passing an ordinance to restrict well drilling in the
controlled area.
•	Specifically identify the properties where the ICs will be implemented.
•	A contingency for failure to implement the proposed IC (i.e., a commitment from the PLP that a
remedy will be implemented if the proposed ICs fail).
•	A mechanism to verify there will be no exposure to contaminated groundwater prior to the IC
being implemented.
5.	Eliminate the company name and phone number from the markers and include the size of the restricted
area.
6.	Specify the tune frame for maintenance repairs to the cover and other RAP elements.
7.	The District has re-evaluated the monitoring program and included W-UC and OB-8R in the
monitoring program to increase confidence that what the model predicted will happen with the
bioremediation continues to work.
8.	Before the Department will issue a notice of intent to approve, we need the financial assurance
mechanism identified and the final language for the ICs (i.e., restrictive covenant).
Please let me know if the District's understanding is correct. We will await receipt of the completed LQRT
Meeting Approval Form before a response is prepared for the PPP.
Creek, Calhoun County, Michigan
cc: Gary Kiepper, MDEQ
R. Dowe Parsons, MDEQ
Leonard Lipinski, MDEQ
.4
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CH&CMlHe$sage
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FACSIMILE COVER SHEET
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-------
ATTACHMENT C

iP Jt T/2£
MICHIGAN
DEPARTMENT of
environmental quality
/TRONMENTAL RESPONSE DIV. ON
LAND USE BASED CLOSURE
APPROVAL AND TRACKING FORM
revision date
^LCLLf' 2/11/97
site name: Cereal City Landfill (CCLF)
county: Calhoun
SITE ID: 130054
PROJECT MANACER: LOfi AfOnOff
FUNDING: PLP
raptitle: Cereal City Landfill Battle Creek, Michigan, Remedial Action Plan
rap prepared BY: RMT, Inc., Madison, Wisconsin
date: January 1997 daterecd: January 17, 1997
description of proposed remedy: Soil cover (min. 18") over waste, active landfill gas extraction system, restrict land
use, restrict exposure to waste and groundwater on landfill property, restrict access to groundwater in affected aquifer off-
property, long term monitoring, and long term O&M.
DATE ERD'S REVIEW MUST BE COMPLETED: 7/17/97
SUMMARY OF SITE INFORMATION:
See Attachment C, Appendix A.
CLOSURE CATEGORY:
Note: All LIMITED category closures
require that either a restrictive
covenant (RC) be filed with the
Register of Deeds in the county
wnere the facility :s located or
other acceptable institutional
control (IC) be in effect at the
Ficslity.
SITE LISTED? YeS SITE SCORE: 36
LIMITED COMMERCIAL
LIMITED RESIDENTIAL
D RC received from	of D«c4j:
(Out)
Q IC Med:
(D«i)
site summary prepared by-. Lori Arorioff date: March 31, 1997
1
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DISTRICT QRT MEETING RECOMMENDATION/APPROVAL FORM
district qrt date: March 27, 1997
X

¦ -	SPECIFIC CLOSURE CATEGORY REQUIREMENTS:
\ ~ 20a(l)(f)-{j) and 20a(2) - Category Closures (Limited Residential, Commercial, Recreational, Industrial,
\	other limited category or site specific category):
technical aspects OF RAP: Denied
comments: See Attachment C, Appendix B
SITE COVER: Approved	REQUIRED? YES
NATURE OF SITE COVER: EXPOSURE BARRIER
description .and location of site cover: A minimum of 12" of fill and 6" of topsoil will be placed
over the waste cells with grading of 2 to 25 percent. Vegetative species that will thrive under site
conditions will be planted over topsoil cover. The existing perimeter fence is proposed as an
additional waste exposure barrier.
District recommends: 1. Plant species selected for vegetative cover should thrive without
supplemental watering or fertilizer application. 2. The existing perimeter fence will not act as an
exposure barrier to waste that is buried on the property but outside of the fence. The fence should
be moved to enclose the waste or the waste brought into the containment area.
• PERMANENT MaRKXRS: Approved	NECESSARY? YES
number and general location of markers: A total of four markers will be placed at the locations
along each perimeter where people would be most likely to see them. The markers will be granite or
similar weather-robust material. The markers will be approximately 2 feet wide by 2 feet tall by 6
inches thick (similar to a standard cemetery grave marker), and will be set on a concrete base. The
markers will be inscribed with this message: "This site is the Closed Cereal City Landfill.
Unauthorized access to any portion of the site is prohibited. Contact Waste Management, Inc., at
313-462-6900 with questions. Monument placed 1997.* The markers will also include the liber and
page number of the restrictive covenant.
operation and maintenance plan: Denied necessary? yes
description of ACTrviTiES: Long term operation and maintenance is proposed for the cover, gas
extraction system and the groundwater monitoring system. The cover will be visually inspected
annually and repaired an necessary. Vegetative cover will be maintained. The landfill gas probes
and extraction wells will be inspected for physical damage during each monitoring event and
repaired as needed. The continuous air monitors in the residences will be calibrated once each year.
Groundwater monitoring wells will be visually inspected twice each year during sampling events and
repaired as necessary. The existing perimeter fence will be maintained.
District recommends: 1. cover inspection be increased from once to twice a year for the first two
years
• LONG TERM MONITORING: Denied	NECESSARY? YES
description of activities: Long term monitoring is proposed for the perimeter landfill gas extraction
system, the continuous monitors in the residences, and the off-property groundwater contaminant
plume. The effectiveness of the gas extraction system will be monitored through quarterly
measurement of methane and oxygen concentrations and pressure in the gas probes, the extraction
wells, at the blower, and in the extraction system header pipe at the well heads. If after 2 years of
operation, the monitoring results indicate stable conditions, less frequent monitoring, or fewer
2
-------
monitoring points will tie proposed to the MDEQ. Otherwise monitoring	~:.e zr a quarviy
basis until the 5-* r remedy review. The groundwater mor/ :ng program will begin after the soil
cover is installed roundwater samples will be collected an iter ievels will be measured during
two monitoring events each year from nine wells. Groundwater samples will be analyzed for VOCs
arsenic, nitrogen (as ammonia and as nitrate-nitrite), specific conductance, and total organic carbon
district comments: See technical comments in Attachment C, Appendix 8 for groundwater and
landfill monitoring.
GROUNDWATER W'aJVER:	REQUIRED? NO
comments: Natural biological and chemical degradation processes are reported to be occurring at
the site. This conclusion is based on the decreasing contaminant concentrations and increasing
dissolved oxygen concentrations with increased distance from the landfill. Cue to these processes,
the proposed remedial action will comply with Rule 705(5) and Rule 7C5(5).
• R£STRJCTr\"E CO\"ENA.VT: Denied	(Can be replaced by Institutional con(rol)
A RC will be placed on the landfill property deed. No details regarding the content of the RC are
available at this time. The RC will be negotiated with the State's Attorney General's Office.
district's comments MODIFICATIONS or ADDITIONAL RESTRICTIONS: The RAP Approval and Tracking
Procedure st3tes tfte RC needs to be included In tfte submits! for 3n/^
i
INSTITUTIONAL CONTROL: Denied	NECESSARY? YES
The RAP does not identify a specific IC to be implemented. It proposed 3 options: 1. local ordinance, 2.
voluntary deed restriction by the property owner, and 3. purchase property cr water rights. The RAP
state one or more of the proposed options "may be employed". Option 1 would be pursued first. After 1
year without success, option 2 would be pursued for an additional year. As necessary, option 3 would be
pursued for those properties for which deed restrictions could not be negotiated.
district's comments: 1. The RAP includes letters from the township planning commissions
documenting the landfill is a legal nonconforming land use. However, no mso shewing the nearest
residential property is included as required in O.M. #14. 2. The description of the area where !Cs will be
implemented to prevent exposure to off-property groundwater needs to be more specific >n regards to
"the other areas in which the Part 201 generic residential health-based drinking water values are likely
exceeded (i.e., sidegradient to the west of the fill areas)". The IC area needs to be revised to include the
entire groundwater plume in excess of esthetic and health-based GRCC. 3. There is no time frame
given for option 3. 4. No contingency plan is offered if implementation of the 3 IC options proposed is
unsuccessful. 5. The RAP does not demonstrate that imposition of land use or resource use restrictions
through restrictive covenants is impractical as required in Sec. 20b(5) prior to attempting to impose an
ordinance that serves as an exposure control off-property. 6. The RAP Approval and Tracking
Procedure states the ICs need to be included in the submittal for and administratively complete RAP.
FINANCIAL ASSURANCE MECHANISM: Denied NECESSARY? ~ Y"ES ~ NO
CHECK TYPE: ~ ESCROW ACCOUNT ~ LETTER OF CREDIT ~ TRUST
~ CO RPO RATE TEST/FINANCIAL C UARAMTEE ~	
(Other)
ESTIMATED AjVNUAL OAM AMOUNT: J	
comments: The financial assurance mechanism is not included in the RAP. It will be included in the
RC to be negotiated.
DISTRICT QRT SIGNATURES:







3
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Lansing qrt meeting approval form
Lansing qrt date;,
SPECIFIC CLOSURE CATEGORY REQUIREMENTS:
~ 20a(l)(f)-(j) and 20a(2) - Category Closures (Limited Residential, Commercial, Recreational, Industrial,
other limited category or site specific category):
technical aspects of raP: ~ Approved Denied
comments:	nrtUck+t*. .	y a C^. OxAgfrw
SITE CAP.'COV-ER:	B^pproved . ~ Denied required? yes 0 no
NATURE OF SITE CAP/CO VXR : EflxpOSURE BARRIER O INFILTRATION BARRIER ~ BOTH
DESCRIPTION AND LOCATION OF SITE CAP/COVER:	
permanent markxrs:	~ Approved Q^Denied NECESSARY? B^YES ~ NO
HUMPCR Afq) OCXCRaL LOCATION OF M^grFBS:
iiAwr^ l Mo*.
<4.
OPERATION AND MAINTENANCE PLAN: ~ Approved	CK^Denied	NECESSARY? B^YES ~ NO
flE3C!Uff l^M^^»CTrV'TTtES: /YUj^+-
(^Df^ts 
-------
LONG term MONtTORiNG: ~ Approved ttf Denied NECESSARY? 1sf"\ ES ~ NO
DESCRIPTION Of IVTTtES:
ydtj.
ftOj a /*»o—
SCHEDULE:
groundwater waiver:	~ Approved O Denied REQUIRED? ~ yes H^o
comments:
date approved:
mixing zone-.	~ Approved O Denied required? ~ yes B^no
comments:
	dh	6r>^r» (j/1			
TbtL/fOQ /r.ks 
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financial assurance mechanism: ~ Approved ~ Denied necessary?	~ no
CHECK TYP1 ~ ESCROW ACCOUNT ~ LETTER OF CRE ~ TRUST
~ CORPORATE TEST/FINANCIAL GL'ARANTEt ~	
(Other)
ESTIMATED ANNUAL O&M AMOUNT: J	
comments: /V>^ (ft\A CtsJitou J

.ADDITIONAL COMMENTS OR RESTRICTIONS:
Note: If any component of the RAP is denied, explain condition or requirement which would make the RAP approvable:
	*y\irt*a	1^1 *y*> (fo^i	.	
Lansing qrt approval/denial signatures-.
CHAIRPERSON OF LANSING QRT: ^ /K. A	r		 DATE:	f
FIELD OPERATIONS SUPERVISOR:			DATE:
7
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ATTACHMENT C
Michigan ENVIRONMENTAL RESPONSE DIVISION revision date
department of LAND USE BASED CLOSURE -1/11/97
ENVIRONMENTAL QUALITY	APPROVAL AND TRACKING FORM	
4/r
,K'
site name: Cereal City Landfill (CCLF)	county: Calhoun	site id: 130054	*/f
PROJECT MANAGER: LOli Aronoff	FUNDING: PLP
rap title: Cereal City Landfill Battle Creek, Michigan, Remedial Action Plan
rap prepared by: RMT, Inc., Madison, Wisconsin date: January 1997 daterecd: January 17,1997
description of proposed remedy: Soil cover (min. 18") over waste, active landfill gas extraction system, restrict land
use, restrict exposure to waste and groundwater on landfill property, restrict access to groundwater in affected aquifer off-
property, long term monitoring, and long term O&M.
DATE ERD'S REVIEW must BE COMPLETED: 7/17/97
SUMMARY OF SITE INFORMATION:	SITE LISTED? YeS SITE SCORE: 36
See Attachment C, Appendix A.
CLOSURE CATEGORY:
Note: All LIMITED category closures
require that either a restrictive
covenant (RC) be filed with the
Register of Deeds in the county
where the Facility is located or
other acceptable institutional
control (IC) be in effect at the
racility
LIMITED COMMERCLA.L
LIMITED RESIDENTIAL
C] RC received from Register of Deeds:
(D.te)
~ IC filed:	
(Date)
SITE SUMMARY PREPARED BY: Lot! Aronoff
date: March 31,1997
1
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DISTRICT QE 1EETING RECOMMENDATION. PROVAL FORM
district qrt date: March 27, 1997
SPECIFIC CLOSURE CATEGORY REQUIREMENTS:
~ 20a(l)(f)-(j) and 20a(2) - Category Closures (Limited Residential, Commercial, Recreational, Industrial,
other limited category or site specific category):
•	TECHNICAL ASPECTS OF RAP: Denied
comments: See Attachment C, Appendix B
site cover: Denied	required? yes
NATURE OF SITE COVER: EXPOSURE BARRIER
description and location of site cover: A minimum of 12" of fill and 6" of topsoil will be placed
over the waste cells with grading of 2 to 25 percent. Vegetative species that will thrive under site
conditions will be plantsd ever topsoi! cover. The existing perimeter fence is proposed as an
additional waste exposure barrier.
District recommends: 1. Plant species selected for vegetative cover should thrive without
supplemental watering or fertilizer application. 2. The existing perimeter fence will not act as an
exposure barrier to waste that is buried on the property but outside of the fence. The fence should
be moved to enclose the waste or the waste brought into the containment area.
•	permanent markers: Approved	necessary? yes
number and general location of markers: A total of four markers will be placed at the locations
along each perimeter where people would be most likely to see them. The markers will be granite or
similar weather-robust material. The markers will be approximately 2 feet wide by 2 feet tall by 5
inches thick (similar to a standard cemetery grave marker), and will be set on a concrete base. The
markers will be inscribed with this message: "This site is the Closed Cereal City Landfill.
Unauthorized access to any portion of the site is prohibited. Contact Waste Management, Inc., at
313-462-6900 with questions. Monument placed 1997." The markers will also include the liber and
page number of the restrictive covenant.
. operation and maintenance plan: Denied necessary? yes
description of activities: long term operation and maintenance is proposed for the cover, gas
extraction system and the groundwater monitoring system. The cover will be visually inspected
annually and repaired an necessary. Vegetative cover will be maintained. The landfill gas probes
and extraction wells will be inspected for physical damage during each monitoring event and
repaired as needed. The continuous air monitors in the residences will be calibrated once each year.
Groundwater monitoring wells will be visually inspected twice each year during sampling events and
repaired as necessary. The existing perimeter fence will be maintained.
District recommends: 1. cover inspection be increased from once to twice a year for the first two
years
long term monitoring: Denied	necessary? yes
description of activities: Long term monitoring is proposed for the perimeter landfill gas extraction
system, the continuous monitors in the residences, and the off-property groundwater contaminant
plume. The effectiveness of the gas extraction system will be monitored through quarterly
measurement of methane and oxygen concentrations and pressure in the gas probes, the extraction
wells, at the blower, and in the extraction system header pipe at the well heads. If after 2 years of
operation, the monitoring results indicate stable conditions, less frequent monitoring, or fewer
2
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monitoring poii 'ill be proposed to the MDEQ. Otherwist nitoring will continue on a quarterly
basis until the b-, ear remedy review. The groundwater mor.... ing program will begin after the soil
cover is installed. Groundwater samples will be collected and water levels will be measured during
two monitoring events each year from nine wells. Groundwater samples will be analyzed for VOCs,
arsenic, nitrogen (as ammonia and as nitrate-nitrite), specific conductance, and total organic carbon.
district comments: See technical comments in Attachment C, Appendix B for groundwater and
landfill monitoring.
GROUNDWATER WAIVER:	REQUIRED? NO
comments: Natural biological and chemical degradation processes are reported to be occurring at
the site. This conclusion is based on the decreasing contaminant concentrations and increasing
dissolved oxygen concentrations with increased distance from the landfill. Due to these processes,
the proposed remedial action will comply with Rule 705(5) and Rule 705(6).
• RESTRICTIVE COVENANT: Denied	(Can br rrpbcrd by Institutional control)
A RC will be placed on the landfill property deed. No details regarding the content of the RC are
available at this time. The RC will be negotiated with the State's Attorney General's Office.
district's comments modifications or ADDITIONAL, restrictions: The RAP Approval and Tracking
Procedure states the RC needs to be included in the submittal for and administratively complete RAP.
institutional control: Denied	NECESSARY? yes
The RAP does not identify a specific IC to be implemented. It proposed 3 options: 1. local ordinance, 2.
voluntary deed restriction by the property owner, and 3. purchase property or water rights. The RAP
state one or more of the proposed options "may be employed". Option 1 would be pursued first. After 1
year without success, option 2 would be pursued for an additional year. As necessary, option 3 would be
pursued for those properties for which deed restrictions could not be negotiated.
district's comments: 1. The RAP includes letters from the township planning commissions
documenting the landfill is a legal nonconforming land use. However, no map showing the nearest
residential property is included as required in O.M. #14. 2. The description of the area where ICs will be
implemented to prevent exposure to off-property groundwater needs to be more specific in regards to
"the other areas in which the Part 201 generic residential health-based drinking water values are likely
exceeded (i.e., sidegradient to the west of the fill areas)". The IC area needs to be revised to include the
entire groundwater plume in excess of esthetic and health-based GRCC. 3. There is no time frame
given for option 3. 4. No contingency plan is offered if implementation of the 3 IC options proposed is
unsuccessful. 5. The RAP does not demonstrate that imposition of land use or resource use restrictions
through restrictive covenants is impractical as required in Sec. 20b(5) prior to attempting to impose an
ordinance that serves as an exposure control off-property. 6. The RAP Approval and Tracking
Procedure states the ICs need to be included in the submittal for and administratively complete RAP.
financial assurance mechanism: Denied necessary? D YES D NO
ESTIMATED ANNUAL OAM AMOUNT: J	
comments: The financial assurance mechanism is not included in the RAP. It will be included in the
RC to be negotiated.
CHECK TYPE: ~ ESCROW ACCOUNT ~ LETTER OF CREDIT ~ TRUST
~ CORPORATE TEST/FINANCIAL GUARANTEE ~	
(Other)
DISTRICT QRT SIGNATURES:
PROJECT MANAGER:
SENIOR DISTRICT GEOLOGIST:
BOND SUPERVISOR (i/applii
DISTRICT SUPERVISOR:
DATE
DATE
DATE
DATE
3
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ATTACHMENT C, APPENDIX A
SUMMARY OF CEREAL CITY LANDFILL INFORMATION
Listed Site #130054, Site Score 36
SITE HISTORY
The Cereal City Landfill (CCLF) is located on a 151-acre parcel and consists of two unlined waste cells,
with a combined fill area of approximately 73 acres. The landfill (LF) was licensed under both the
Garbage and Refuse Act, 1965 PA 87 and the Solid Waste Management Act, 1978 PA 641. It reportedly
received municipal, commercial, and industrial waste during its operation from 1951 through 1982. The
landfill was closed in 1983. The parcel is reported to be a legal non-conforming commercial use in the
City of Battle Creek (area zoned residential) and the Township of Bedford (area zoned agricultural) in
Calhoun County. The CCLF is surrounded by residential properties and undeveloped land. The highest
density residential land use occurs to the south and east of the property, with a lesser density of residences
to the west of the property. Undeveloped forested land bounds the property to the north. Sperrv Drain is
located approximately 1300 feet west of the north waste cell. The site is approximately 1 mile north-
northeast of the Kalamazoo River which flows into Lake Michigan approximately 60 miles downstream
(west).
During operation, the CCLF had a history of off-site migration of methane gas through the soil and
leachate seeps. The gas migration problem was temporarily addressed through the use of passive gas
vents and an active gas extraction system along the southwest perimeter of the property. Upon closure of
the CCLF. the final cover was augmented with bentonite. Since closure has been complete, Department of
Natural Resource (DNR) staff visited the site and found erosion of the cap with exposure of the underlying
refuse and numerous leachate seeps from the base of the fill.
In 1981, both on-property monitoring wells and nearby domestic wells were found to be contaminated
with typical landfill contaminants. Bottled water was pro\idcd to residents with a contaminated potable
water well in 1989 One hundred fifty thousand dollars (S 150.000) was requested from FY90 Bond funds
for a water main extension and well abandonments. Five hundred thousand dollars ($500,000) was
requested to conduct a remedial investigation and feasibility study. Once the funding was appropriated, a
potentially liable party fPLP) Waste Management of North America. Inc. (WMNA), and its subsidiary
S.C. Holdings, Inc. (SCHI) voluntarily extended the water main to six residences in 1992, completed the
remedial investigation fRJ) in 1993, conducted a feasibility study (FS) in 1995, provided a public
comment period for the FS in 1996, and submitted a remedial action plan (RAP) on January 17, 1997.
SITE HYDROGOLOGY
The site hydrogeologic conditions were investigated during the RI. The uppermost geologic stratum
beneath the site consists of 40 to 172 feet of sandy outwash with a discontinuous layer of clay present in
some areas. The thick outwash sands overlie up to 107 feet of silly sandstone and siltstone. The silty
sandstone in turn overlies more than 80 feet of shale with occasional sandstone interbeds. No laterally
continuous low-permeability strata separate the outwash from the bedrock in the southern two-thirds of
the site.
The water table at the site is approximately 12 feet below grade at the southern end of the site and 67 feet
below grade 2.100 feet south of the LF. Groundwater flow in the outwash and sandstone under the eastern
and central portions of the site is generally to the southwest, toward the Kalamazoo River. Groundwater
along the western edge of the site in the outwash is deflected to the west, toward Speny Drain.
Groundwater velocities in the sandy outwash and the sandstone range from approximately 60 to 10 feet
per year, respectively. There is a downward component of flow across most of the study area, such that
flow migrates down through the sandy outwash into the sandstone, as it flows to the south-southwest.
Upward gradients exist within the outwash near Speny Drain. Two wetlands were identified on the LF in
an unfilled area on the east side of the property. The 5 acre wetland is regulated under authority of Part
303. The smaller wetland which is less than 1 acre has the potential to also be regulated.
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LF WASTE
The nature and extent of the waste in the LF was defined through geophysical methods, soil borings,
historical aerial photograph examination and measurements of leachate head and chemistry. The waste is
between 4 feet and 45 feet thick with a approximate volume of 1.400,000 cubic yards in the northern cell
and 920,000 cubic yards in the southern cell. It is variably degraded and consists of sand and gravel
interbedded with common municipal solid waste materials (packaging and paper, wood chips, plastic
sheeting, glass and metal). The waste is covered by a sand and gravel layer that varies in thickness from 0
to 10 feet. On the basis of the leachate head measurements, soil boring logs, and the water table
configuration, the waste in the southern portions of the north and south waste cells is in contact with the
water table. Up to ten feet of waste is below the water table in the southern portion of the south waste
cells.
There is leachate head buildup within the LF due to the higher permeability of the cover compared to the
lower permeability of the waste, topographic relief, and sparse vegetation on the surface. Dissipation of
the leachate is hindered by the low bulk hydraulic conductivity of the waste compared to the underlying
outwas'n. The ieac'nate contained elevated concentrations of organic and inorganic constituents. Tne
constituents with concentrations in excess of Generic Residential Cleanup Criteria (GRCC) measured in
the leachate in 1992 were tetrahydrofuran, xylenes, methylene chloride, ethyl benzene, trichloroethene,
tetrachloroethene, benzene, chloride, nitrate, arsenic, manganese, zinc, iron, lead, sodium, chromium,
magnesium, nickel, and mercury.
GROUNDWATER CONTAMINATION
The nature and extent of groundwater contamination has been investigated using data collected from a
network of 38 monitoring wells at 15 locations. Groundwater has been sampled and analyzed on a
quarterly schedule subsequent to the completion of the Phase HI Hydrogeologic Study in accordance with
the Interim Groundwater Monitoring Plan. The groundwater contains elevated concentrations of organic
and inorganic constituents. The constituents with concentrations in excess of GRCC measured in the
groundwater since 1992 are benzene, chlorobenzene, chloride, nitrate, arsenic, iron, manganese, sodium,
and barium. Contaminants extend vertically into the Marshall Sandstone. The constituents detected in
the groundwater from the Coldwater Shale are likely a result of the dissolution of the Shale materials and
not a LF contaminant.
The horizontal extent of groundwater contamination is defined by the off-property wells at locations 4, 9,
11, 13, 15, and 17. Contaminant concentrations at these locations are below the drinking water GRCC
\nth the exception of locations 13 and 17 where concentrations of iron and manganese exceed the GRCC.
Concentrations of iron measured in groundwater from wells upgradient of these locations (1,12 and 8)
demonstrate a trend of decreasing iron concentrations. The rate at w hich iron is removed from the
groundwater has been estimated based on removal rates in upgradient wells. Iron is removed from
groundwater at a rate that ranges from 11 ppb/ft to 2 ppb/ft Using the conservative removal rate of 2
ppb/ft, it is estimated that iron concentrations will comply with the GRCC 107 feet downgradient of well
location 17. Manganese concentrations increase at a rate of 0.1 ppb/ft to 0.41 ppb/ft from the property
line to 1200 feet downgradient. From 1,200 feet to 2,100 downgradient of the property line, manganese
concentrations decrease at a rate of 0.7 ppb/ft. If manganese continues to be removed at the rate of 0.7
ppb/ft, it is estimated that manganese concentrations will comply with the GRCC 18 feet downgradient of
well location 13
GSI
The upper portion of the aquifer on the northwest part of the LF discharges to the Sperry Drain. The
portion of the aquifer that underflows the drain is monitored by the wells at location 15. The
Groundwater/Surface Water Criteria (GSI) for ammonia is exceeded at W-15B. No contaminant
concentrations exceeding the drinking water GRCC have been detected at location 15 in the past two
sampling events. Monitoring wells at locations 2 and 14 are 600 feet and 750 feet, respectively,
hydraulically upgradient of the drain. Concentrations of ammonia in excess of GSI were detected in OB-
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2R, W-14A, and W-14B. Concentrations of barium and chromium in excess of GSI were detected in W-
14C. Total dissolved chromium was measured in the groundwater and compared to the GSI for
hexavalent chromium (GSI for trivalent chromium was not exceeded).
BIODEGRADATION
Natural biological and chemical degradation processes are reported to be occurring at the site. This
conclusion is based on the decreasing contaminant concenirations and increasing dissolved oxygen
concenirations with increased distance from the LF. Concentric redox zones around LF waste and its
associated contaminant plume have been documented to exist. Concentrations of organic contaminants
are regulated mainly by the rate of microbial degradation, which in turn varies with redox conditions and
the availability of oxygen. Concentrations of inorganic contaminants are also strongly affected by redox
conditions; for example, iron and manganese are highly soluble under reduced conditions and precipitate
from solution when conditions become oxidizing. Arsenic concenirations begin to decrease at the same
lime as iron and manganese due to co-precipitation wiih the iron and manganese oxyhydroxides.
Fate and transport modeling was conducted using the BIOPLUME™ code, to simulate contaminant
concentrations in the aquifer under two landfill cover opticus! the high permeability soil cover, and a
conventional low-permeability cover. Surrogate contaminants including many organics and some
inorganic compounds were used to represent contaminants in the groundwater whose concentrations are
controlled to a large degree by dissolved oxygen concenirations. The model was calibrated to the
historical trend in concenirations in the groundwater and then used in prediction mode to simulate future
conditions.
The model predicted with the soil cover, contaminant concentrations in the groundwater would continue
to decrease steadily and the extent of the contaminant plume would shrink, resulting in a greatly reduced
size plume in 30 years, and a small remnant plume in as little as 50 years. Alternately, a conventional
low-permeability landfill cover would prolong the decay of the waste so that concenirations of
contaminants in the groundwater would persist over a substantially longer period, and the contaminant
plume might actually increase in extent. Groundwater containment using extraction wells was also
simulated, in conjunction with both cover designs. The model results reportedly indicate that a two-well
system pumping at a combined rate of 200 gpm would speed up the recovery of groundwater contaminants
somewhat, allhough the time needed to achieve GRCC for groundwater at the site might not be decreased
substantially. The study document did not report the estimated times.
RAP COMPONENTS
The Remedial Action Plan (RAP) proposes a Limited Commercial Subcategory II closure on the property
and a Limited Residential closure off-property at the site. The proposed remedy is intended to abate the
unacceptable risks identified in the Baseline Risk Assessment: prevent direct contact and ingestion of
waste and contaminated groundwater, and prevent off-property migration and accumulation of subsurface
landfill gas. The remedial actions include constructing a soil cover over the waste cells, upgrading the
perimeter landfill gas control system, institutional controls, long term landfill gas and groundwater
monitoring, and long term operation and maintenance of the cover, gas extraction sy stem and the
groundwater monitoring system.
COVER
The soil cover will prevent direct contact with the LF contents while providing the oxygen necessary to
sustain the natural biochemical degradation processes that have been reducing the concentrations of
landfill constituents in groundwater downgradient of the LF. General fill will be added to achieve a
minimum 12 inches of cover materials over the waste areas. Six inches of topsoil will be placed over the
cover materials in the waste cells to support vegetation. Vegetative species that will thrive under site
conditions will be planted. Grading for the site typically ranges from 2 to 25 percent and has been
designed to meet the original 1982 closure agreement for the CCLF, maintain the existing surface water
drainage patterns, and promote positive drainage away from the waste cells.
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The final cover will be inspected annually for evidence of erosional damage, subsidence that could lead to
surface water ponding, burrowing by animals, and the presence of adequate and thriving vegetation.
Erosional washouts 6 inches or deeper will be repaired as soon as practicable after identification and the
vegetative cover restored. Localized subsidence that results in ponding of surface water will be filled with
general fill and/or topsoil and the vegetative cover restored. The inlets and outlets of on-property culverts
will be visually inspected for the presence of debris and sediment. Debris and sediment build-up will be
removed as necessary to maintain unobstructed drainage of surface water. The maintenance of the
vegetative cover will include mowing, reseeding and fertilizing as appropriate for the vegetative species
selected from the design plant palette study. The existing trees on the property will be kept to improve
site aesthetics. When observed and located, burrowing animals will be exterminated or removed from the
property.
LAiNDFILL GAS MANAGEMENT
Migration of LF gas generated in the south cell is currently being controlled by an active LF gas
extraction system operating along the western and southwestern property boundary. The RAP proposes
expansion of this system to prevent off-property migration of gas from the north cell. The existing system
»wll be upgraded to handle the increased capacity . In audition, there are continuous ambient air monitors
in the basements of seven buildings on Hubbard Street adjacent to the LF. The passive gas vents installed
in the interior of both waste cells in 1981 will be properly abandoned.
The effectiveness of the gas extraction system will be monitored through the use of soil gas probes.
Concentrations of methane and oxygen (on a percent volume-to-volume basis), and the pressure in the gas
probes, the extraction wells, at the blower, and in the extraction system header pipe at the well heads will
be measured using portable combustible gas meters and pressure gauges quarterly for 2 years after the
start up of the north cell perimeter gas extraction system. If after 2 years of operation, the monitoring
results indicate stable conditions, less frequent monitoring, or fewer monitoring points will be proposed to
the MDEQ Otherwise monitoring will continue on a quarterly basis until the 5-year remedy review An
annual monitoring report will be submitted to the MDEQ
The gas probes and extraction wells will be inspected for physical damage during each monitoring event.
N'eeded repairs will be recorded and repairs made on a timely basis. The continuous ambient air monitors
in the basements of the six residences will be checked once each year. These ambient air monitors are
"'expected to be maintained until the landfill gas generation and migration potential are negligible". A
contingency action plan has been prepared describing actions to be taken if the soil pore gas levels
measured in the perimeter gas probes exceed 50 percent of the lower explosive limit for methane.
INSTITUTIONAL CONTROLS
Institutional controls will be used to prevent direct contact with the landfill contents and ingestion and/or
dermal adsorption of groundwater affected by the landfill. Institutional controls on the property will
consist of maintenance of the existing perimeter fence and secured gate, installation and maintenance of a
permanent marker on each side of the landfill warning against unauthorized access, and a restrictive
covenant on the landfill property deed. The restrictive covenant is not included in the RAP, but identifies
uses and activities to be restricted by the covenant. The RAP states the restrictive covenant will be
included in a negotiated Administrative Order by Consent (AOC) between the MDEQ and SCHI for
implementing the remedial action. The AOC will be contained in Appendix D of the RAP.
"Institutional controls will be developed to prohibit construction of off-property water supply wells in the
portion of the aquifer affected by the LF. The area in which water supply wells would be prohibited is the
area downgradient of the site (to the southeast) to well nest W-17, as well as other areas in which the Part
201 generic residential health-based drinking water values are likely exceeded (i.e.. sidegradient to the
west of the fill areas). Water supply wells will also be prohibited for a short distance around the rest of
the site to prevent potential pumping that could induce groundwater gradients in directions that are not
currently of concern. Except for the house at 459 Hubbard Avenue, there are no other known drinking
water supply wells in these areas. Because the owner of the property at	could not be
-------
located, the CaJhoun County Public Health Department placed a deed restriction on this property in
September 1992. The house is still vacant."
The RAP does not identify a specific institutionai control to be implemented. It proposes 3 options: 1.
local ordinance, 2. voluntary deed restriction by the property owner, and 3. purchase property or water
rights. The RAP states one or more of the proposed options "may be employed". Option 1 would be
pursued first. After 1 year without success, option 2 would be pursued for an additional year. As
necessary, option 3 would be pursued for those properties for which deed restrictions could not be
negotiated. No time limit is set for pursuit or option 3, nor is a contingency plan proposed if all 3 options
fail.
GROUNDWATER MONITORING
The objectives of the groundwater monitoring program are to: 1. monitor long-term trends in
groundwater quality, 2. detect changes in the direction of groundwater flow, and 3. detect significant
changes in the concentrations of site related contaminants. The groundwater monitoring program will
begin after the soil cover is installed over the waste cells. Groundwater samples will be collected and
water levels will 'oe measured during two monitoring events each year from nine wells. Water level will
be measured in two upgradient wells annually. The remaining 27 monitoring wells will be properly-
abandoned. The points of compliance for groundwater monitoring are downgradient wells W-13C, W-
17B, and W-17C.
The groundwater samples will be analyzed for VOCs, arsenic, nitrogen (as ammonia and as nitrate-
nitrite), specific conductance (field), and total organic carton (as NPOC). SCH1 believes these parameters
are indicative of groundwater affected by the LF and will enable SCH1 to assess compliance with
regulatory standards, to track the migration of LF related constituents, and to monitor ongoing natural
attenuation and biodegradation processes.
Because there are no downgradient users of the aquifer affected by the landfill, the results of the
groundwater monitoring events are not expected to trigger the need for a time-critical response action.
Trends in the groundwater quality data will continue to be evaluated on a yearly basis. If an increasing
trend in the concentrations of groundwater constituents is observed, this finding will be reported to the
\IDEQ and a response plan will be developed and submitted to the MDEQ for review prior to initiating
contingency response actions.
SCHEDULE AND REPORTING
The RAP includes a schedule for implementing the remedial action. Construction is scheduled to begin in
May 1997. The expansion of the gas extraction system will be completed before construction of the waste
cell cover. The vegetative cover will be seeded no later than the end of September 1997. Adjustments to
the schedule may be necessary and the MDEQ will be advised of any significant schedule changes. Soil
gas monitoring will continue throughout construction of the cover and gas extraction system.
Groundwater monitoring will be suspended until after the installation of the final cover is complete to
avoid monitoring transient conditions during the major earthmoving activities.
A construction documentation report for the expansion of the perimeter gas control system to the north
waste cell and the placement of the soil cover will be submitted to the MDEQ. Annual reports of the
finding from the environmental monitoring program will be submitted to the MDEQ in March following
each year of monitoring. The effectiveness of the long-term environmental monitoring program will be
reviewed after five years and changes may be recommended to the MDEQ and appropriate.
RESTRICTIVE COVENANT AND FINANCIAL ASSURANCE
Because the RAP is based on criteria provided for in Section 20l20a(l)(g), the land and resource use
restrictions, the monitoring program, the operation and maintenance program, the permanent markers,
and the financial assurance mechanism must be stipulated in a legally enforceable document with the
MDEQ. The financial assurance mechanism to secure the performance of operation and maintenance,
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oversight, monitoring, and other costs necessary to ensure the effectiveness and integrity of the
containment measure set forth in the RAP will be described in a negotiated AOC. All aspects of financial
assurance , except for the performance bond will be included in a to-be-negotiated AOC. An example of
the performance bond is provided in the RAP.
RULE 705
Due to the natural biological and chemical degradation processes reported to be occurring at the site, the
proposed remedial action will comply with Rule 705(5) and Rule 705(6).
PREPARED BY: ^GAS Si ¦			DATE: _ 3/m/<> /
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ATTACHMENT C, APPENDIX B
TECHiNICAL ASPECTS OF RAP
Groundwater
1.	The concentrations of iron and manganese exceed the generic residential cleanup criteria (GRCC) for
drinking water at the furthest downgradient monitoring locations W-13 and W-17. The estimated rate of
removal of these constituents (2 ppb/ft and 0.7 ppb/ft, respectively) is reflective of the redox conditions
documented to exist at the site. As the dissolved constituents migrate with the groundwater from reducing
conditions to oxidizing conditions, the iron and manganese precipitate out of solution. It is estimated,
based on the removal rates, compliance with GRCC will be attained 18 feet downgradient of W-13 and 107
feet downgradient of W-17. The JDQRT recommends the horizontal downgradient extent of groundwater
contamination be defined at these points. The JDQRT believes the sodium and chloride detected in the
shale at W-17C are a result of the dissolution of the shale materials and other natural occurrences. (Pages,
14, 12)
2.	The groundwater contamination extends vertically through the Marshall Sandstone.
3.	The concentration of ammonia exceeds the groundwaterVsurfacewater interface criteria (GST) at
locations W-14, OB-2R and W-15B Surfacewater's Rule 57 regulates un-ionized ammonia discharges.
The calculated concentration of un-ionized ammonia, which is dependent on pH and temperature, exceeds
GSI at W-14B only. The concentrations of barium and chromium exceed the GSI at location 14. Total
concentration of chromium was measured in the groundwater and compared to the GSI for hexavalent
chromium (GSI for trivalent chromium was not exceeded). The JDQRT recommends a GSI monitoring
well be installed downgradient of W-14 and monitored for compliance with GSI or another alternate
method to demonstrate compliance with GSI.
4 The points of compliance for groundwater monitoring should include a well from location 11, OB-8R,
and the GSI monitoring point.
5.	The groundwater sample parameter list should be expanded to include iron, manganese, sodium,
chloride, barium (GSI), chromium (GSI), and other parameters indicative of the effectiveness of the
bioremediation (i.e., temperature, pH, DO, etc.).
6.	The purge water may be discharged to the ground surface if the contaminant levels in the groundwater
are protective of human health and the environment (i.e., appropriate cleanup criteria).
Landfill Gas
7.	Is the stated LF gas shut off point adequate? (P 31)
8.	The continuous air monitors inside the houses will be calibrated once a year. The owner's manual says
the unit's sensor should be vacuumed each month. The newer models (Dicon) have an alarm that will not
stop once activated until unplugged. This would allow homeowners to know if levels have exceeded safe
levels even while away from home. The older models should be replaced. (App A p22)
9.	The endpoint of the monitoring in the houses needs to be more specific than "monitors are expected to
be maintained until LF gas generation and migration potential are negligible". Shut off should be based on
safety issues. (App A p23)
10.	The contingency plan for LF gas should include a response plan to remedy LF gas which has migrated
past extraction system and impacted residents. (App A p24)
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11. It appears that the S & . corner of the N waste cell has waste that be outside the radius of
influence of the gas extraction wells (see Sheet 4 of 6). The waste extends approx. 400' beyond GW-N14
and GW-N15 approx. 250' from property line. (App B P7)
REPORTING
12.	Attachment II (Figure II-2) should include other field observations (i.e., odor, standing water around
casing, etc.).
13.	The information regarding the observed condition of the monitoring wells should be noted in the Water
Level Measurement Record.
14.	The following documents should be included in the annual monitoring report: water level measurement
records, stabilization test records, chain-of-custody forms, gas probe data sheets and gas extraction well
and blower system data sheets.
15.	Non-compliance events should also be reported to the MDEQ, Jackson District Office (page 27, App.
A).
16 The Emergency Response and Safety Plan should include a spill response for the condensate tank. The
tank will need to complv with applicable requirements if the condensate is hazardous waste (page 28 App.
B).
17.	In the Emergency Response Health and Safety Plan, the emergency phone numbers should include the
PEAS phone number (800) 292-4706. Lori AronofFs correct phone number is (5 17) 780-7839 (page 2-7
App B)
18.	Reportable quantity spills, spills that run-off the property, and spills due to containment system failure
should be reported to PEAS, not EAD (page 3-32 App B).
GENERAL
19 The statement (on page 1 and page 4 of Appendix A of the RAP) that Phil Schrantz's 7/10/95 memo
confirmed that the landfill had been closed in accordance with the 1982 closure agreement is incorrect. The
memo states that the closure agreement was signed by Director Tanner.
20.	Throughout the document the landfill property is referred to as the site. Under Part 201, site has a
specific meaning which should be used in this document.
21.	The proposed activities may require a Permit-by-Rule for Storm Water from Construction Activities,
40 CFR Sec. 122.26(a) from SWQD and a permit to install the culvert in the regulated wetland from
LWMD. These should be added to Table 3 and Table 5 as necessary.
22 SWQD staff advise a check dam may be required in the low area that discharges to the wetland (see
sheet 1 of 6) to control sediments. This dam will require regular maintenance.
23.	The task specific hazard assessment Table 3-1 should indicate digging greater than 6" is restricted,
(page 101 App B).
24.	There are errors in some of the tables (e.g., Table 7). The MDEQ does not necessarily agree with the
interpretations of the laws and policy presented in the tables but specific comments have not be presented.
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STATE OF MICHIGAN
JOHN ENGLER, Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOLLISTER BUILDING. PO BOX 20473. LANSING Ml *8808-7873
RUSSELL J. HARDING. Director


REPLY TO:
JACKSON OiSTWCf HEADQOARTHRS
J01 E LOUIS OUCXtftW
>cxson ui tf2oi-isea
November 1, 1995
Mr. Phillip Mazor
Waste Management of North America, Inc.
Autumn Hills Recycling and Disposal Facility
700 56th Avenue
Zeeland, Michigan 49464
Dear Mr. Mazor:
Subject: Cereal City Landfill, Battle Creek, Calhoun County, Michigan
Staff of the Michigan Department of Environmental Quality (MDEQ) has reviewed
the Focused Feasibility Study Report, dated April, 1995, for the subject
facility. The remedial alternatives considered and the remedial action
recommended in the feasibility study appear to be appropriate for this
facility based on the data generated during the remedial investigation. The
MDEQ, therefore, approves the Focused Feasibility Study Report, as modified
according to RMT's correspondence dated September 27, 1995.
If a remedial action plan (RAP) is developed pursuant to R 299.5515 of Part
201 of the Natural Resources and Environmental Protection Act, please submit
it to this office for MDEQ approval. The RAP should include a contingency
plan which describes the corrective actions to be implemented in the event of
an increase in risk to the environment, natural resources, or public health
from the facility. If you have any questions please feel free to contact me
at 517-780-7839.
Sincerely,
A- .AAfr'l
Lori A. Aronof f' *
Environmental Quality Analyst
Environmental Response Division
LA: kl
cc: Ms. Linda Hicken, RMT
Mr. R. Dowe Parsons, MDEQ

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MICHIGAN STATE UNIVERSITY
CENTER FOR MICROBIAL ECOLOGY
PLANT AND SOIL SCIENCES BUILDING
EAST L\NSING. MI
A NSr SCIENCE AND TECHNOLOGY CENTER
PHONE
FAX V;-
October 31, 1995
Ms. Lori Aronoff
Division of Environmental Quality
Department of Natural Resources
Lansing, Michigan
Re: Cereal City Landfill
Dear Lori,
As you requested, 1 have reviewed the documentation submitted to the
Michigan Department of Natural Resources by RMT, Inc. regarding the assessment of
remedial alternatives for the Cereal City Landfill in Battle Creek, MI. Specifically you
asked if 1 would comment on (a) whether the available data supported that assertion
that intrinsic biological processes could account for the loss of contaminants in
leached from the landfill to the aquifer, and (b) whether fate and transport models
could be used to predict future contaminant concentrations at various locations in the
aquifer.
In my opinion, the data provided strongly suggest that microbial processes
within the aquifer may be reposnsible for the observed attenuation of volatile organic
hydrocarbons (VOC's) in the groundwater. Consequently, 1 think it is reasonable to
consider the use of intrinsic bioremediation as a means to remediate the site provided
that receptors, such as drinking water wells, are not imminently at risk of
contamination.
Fate and transport models are certainly useful for obtaining some notion of the
likelv fate of contaminants in the subsurface. However, the models are only as valid
as the boundary conditions (i.e., data) that are available. In this case, it seems as
though the information at the site is largely derived from monitoring wells and not
from empirical (experimental) measures of contaminant degradation rates, or from
intensive vertical sampling of the aquifer at key points within the plume. These facts,
plus the heterogeneity so often encountered in the subsurface, leave open the
possibility that the fate and transport models could lead to faulty predictions. It is
important to relaize that the rates and extent of contamination will undoubtedly varv
(increase or decrease) depending on the availability of electron acceptors, the
concentration of contaminants, the availability of other dissolved organic matter, as
well as many other factors. Because of this, I think it is important to carefully develop
MSL ii an	Action/Equal Of>f>ortun\tx fnsntufio*
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Ms. Lori Aronoff
October 31,1995
Page Two
a scheme for monitoring migration of the plume so that significant changes in the
behavior of the dynamic biological processes can be followed, and so additional
measures can be implemented if needed because of increased risk.
Finally, 1 would caution you to carefully evaluate any steps that might be
proposed as ways to "enahance" the rates of biodegradation in the subsurface through
manipulation of environmental conditions (e.g., addition of electron acceptors). I
view the situation as one that has reached a dynamic equilibruim and efforts to
manipulate the environment could lead to undesired outcomes.
1 hope these comments are useful to you. Please do not hesitate to call if you
or RMT. Inc. have any questions or would like to discuss this further.
fiinrprplv \mnrc
Larry Forney, Ph.D
Associate Director
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Section 6
DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
The objective of this section is to assemble the institutional controls and the landfill contents
source control and groundwater containment technologies that were described in Section 5
into remedial alternatives for the site. For each alternative, a description of the major
components is presented, followed by an assessment of the effectiveness and
implementability of the alternative. The estimated construction and annual operation and
maintenance costs are also presented. The alternatives are compared amongst each other in
Section 7.
The following remedial alternatives are developed and evaluated in this section and in
Section 7:
Alternative	Description
1	No action
2	Soil cover
3	Soil cover with groundwater containment
4	Conventional cover
5	Conventional cover with groundwater containment
Each of these alternatives includes as a minimum, the following four components:
Institutional controls (maintenance of the existing perimeter fence only)
Control of perimeter landfill gas migration in the South Waste Cell
• Long-term groundwater monitoring
Long-term soil gas monitoring
Alternatives #2 through #5 also propose additional institutional controls such as deed
restrictions limiting land use and a local ordinance prohibiting construction of potable water
supply wells on the site and at certain nearby properties. Alternatives #2 through #5 also
include an active gas migration control system along portions of the perimeter of the North
Waste Cell. Alternatives #4 and #5 (the alternatives with the conventional cover) include
three additional perimeter extraction wells and interior gas collection systems to prevent off-
site gas migration that would be induced with a low-permeability cover. Alternatives #2
through #5 represent the four combinations of two different final covers—with and without
groundwater containment.
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The components common among the alternatives are described below.
Institutional Controls
The following institutional controls may be used to control exposure to landfill constituents and
groundwater affected by the landfill via ingestion and/or dermal adsorption:
•	[Maintenance of the existing perimeter fence.
•	Deed restrictions limiting use of the property.
•	Use of the appropriate regulatory authorities to prohibit construction of potable
water supply wells on the site and at nearby properties (Calhoun County
requires a permit to construct all types of water supply wells). The area in
which potable water supply wells would be prohibited is primarily the area
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An interim groundwater monitoring plan (RMT, 1993cf) has been developed for the CCL. The
interim groundwater monitoring program has been implemented since October 1993, and is
expected to be continued until the Remedial Action Plan (RAP) is approved. The interim
monitoring plan includes collecting samples on a quarterly basis and analyzing them for the
constituents of concern and for other inorganic indicators (e.g., ammonia, conductivity, pH) of
landfill effects on groundwater quality. For reporting purposes, the groundwater monitoring
year starts in October, which includes an expanded number of wells that are sampled, and is
followed by three quarterly sampling events in January, April, and July. The quarterly
monitoring events focus on the wells that are downgradient of the landfill. The October,
January, and April resutts are reported quarterly to the MDNR in summary data table format.
A comprehensive annual report is prepared following the July sampling event. On the basis of
comments received from the MDNR on the interim groundwater monitoring plan (MDNR,
1994a), modifications have been made to the plan for the 1995 monitoring plan (RMT, I994d),
which began in October 1994.
The long-term groundwater monitoring plan will be developed as part of the RAP for this site.
For the purpose of estimating annual monitoring costs, it was assumed that the long-term
monitoring plan will be similar to the interim monitoring plan described above.
Long-Term Soil Gas Monitoring
Combustible gas (as methane) and oxygen concentrations and soil gas pressure are
measured in each of the soil gas monitoring probes along the landfill perimeters (Figure 2-6)
once a quarter. In addition, the concentrations of combustible gas (as methane) and oxygen
and the negative pressure (vacuum) in each of the gas extraction wells and the header pipe
at the wellhead along the South Waste Cell perimeters are measured once each quarter.
On the basis of these readings, the valve settings on the gas extraction wells are adjusted to
maintain a negative pressure and a gas quality below the lower explosive limit (LEL).
The RAP will also include a long-term soil gas monitoring plan. For the purpose of estimating
annual monitoring costs, it was assumed that the long-term soil gas monitoring program will
be similar to the current monitoring program—with the addition of the gas extraction wells in
parts of the North Waste Cell.
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Control of Perimeter Landfill Gas Migration in the North Waste Cell
In addition to the South Waste Cell active gas extraction system, an active gas extraction
system along portions of the perimeter of the North Waste Cell is also included as part of
Alternatives #2 through #5. The design of the North Waste Cell perimeter gas migration
control system was discussed previously in Subsection 5.4 and shown schematically on
Figure 5-3 for the conventional cover design (Alternatives #4 and #5), and on Figure 5-6 for
the soil cover design (Alternatives #2 and #3).
6.1 Alternative 1: No Action
6.1.1 Description
Evaluation of a 'no-action* alternative is required under Rule R299.5513(2)(a)(iii) to
provide a baseline against which other alternatives can be compared. The "no action'
alternative for the CCL would leave the existing cover, which was approved by the
MDNR at the time of closure, in place. This would allow the natural attenuation and
biogeochemical degradation of wastes in the fill and groundwater to continue. This
alternative also includes fencing as an institutional control and long-term groundwater
and soil gas monitoring as described above. It does not include deed restrictions or a
local ordinance prohibiting construction of water supply wells in certain areas. It
includes continued operation of the perimeter gas control system in the South Waste
Cell, but not the addition of a perimeter gas control system in the North Waste Cell.
6.1.2 Effectiveness
The effectiveness of the existing cover in remediating groundwater impacts at and
downgradient of this site has been evaluated extensively. This evaluation, which is
documented in a technical memorandum that is included in Appendix B, included a
review of relevant case histories and research related to degradation of groundwater
contaminants under various environmental conditions; an analyses of the trends in
chemical concentrations in the groundwater, over time, at the CCL; and computer
modeling of existing and future extent of contamination under different cover options,
both with and without groundwater containment.
The major conclusions of this study were as follows;
• The chemical trends in the groundwater, over space and time, demonstrate
that there is substantial attenuation of VOCs under current landfill conditions
(with the existing covers) at the CCL Readily degradable compounds, such
as the BTEX species, are major contaminants in groundwater immediately
adjacent to the landfill, but are below detection limits at downgradient
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i
monitoring well locations. The extent of impacts downgradient of the landfill is
much more limited than expected based on groundwater velocities in the
permeable sand aquifer. (The less reactive compounds, such as
tetrahydrofuran and chloroethane, remain in the groundwater at concentrations
below the Part 201 generic residential health-based drinking water criteria at
the downgradient edge of the plume.)
Evidence from similar sites indicates that biodegradation of amenable
compounds is effective at removing many VOCs, such as the BTEX species,
from the groundwater under aerobic conditions, and that the supply of oxygen
is the limiting factor governing the rate of degradation. Even chlorinated
solvents have been shown to be effectively biodegraded under aerobic
groundwater conditions such as those existing downgradient of the landfill.
Many inorganic constituents such as arsenic, are attenuated under oxidizing
conditions downgradient of the landfill, through co-precipitation with iron.
The concentrations of key indicators, such as BTEX, TOC, and chloride,
indicate that groundwater contaminant concentrations at the CCL have
decreased by 50 to 90 percent over the last 12 years. The downward trend in
contaminant concentrations would be expected to continue and the
contaminant plume to shrink under the existing cover conditions, which
enhance the supply of oxygen to the fill and groundwater.
The long-term effect of the landfill cover on contaminant concentrations in
groundwater was simulated using the BIOPLUME™ contaminant transport and
biodegradation model. The results are described in detail in the Appendix B report.
Assuming the permeability of the cover remains the same, the model results indicated
that the total dissolved contaminant mass in the groundwater would be reduced by 31
percent within 12 years, and by 91 percent within 48 years.
In summary, this study documents that the landfill, in its current state, is an effective
bioreactor that is reducing the toxicity, mobility, and volume of groundwater
contaminants over time. Furthermore, alteration of the landfill cover to a less
permeable condition will slow the natural degradation processes because it will reduce
the supply of oxygen to waste constituents. The resulting concentrations in
groundwater would decrease at a slower rate, and the extent of the plume might
actually increase.
It is important to note that natural biodegradation is an acceptable remedial action
under Sections 20118(5) and (6) of Part 201 of P.A. 451 as amended, and meets the
requirements of Rule 299.5705(6), which requires that "all remedial actions which
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address the remediation of an aquifer shall provide for removal of the hazardous
substance or substances from the aquifer, either through active remediation or as a
result of naturally occurring biological or chemical processes which can be
documented to occur at the site." The results of the study conducted for the CCL (as
documented in Appendix B) provide the technical justification for selecting a remedial
alternative for this site which employs natural biodegradation processes as a method
for on-site treatment of hazardous substances.
Maintaining the existing perimeter fence will continue to restrict access to the site, thus
limiting potential direct contact with wastes. This alternative, however, will not reduce
potential risk or hazard from the off-site migration of subsurface gases along the
northern perimeter and southeastern comer of the North Waste Cell, The potential
risk or hazard associated with these areas would increase if structures were built
adjacent to the fill. In addition, potable water supply wells could be constructed in the
future in areas affected by the landfill if institutional controls are not in place to prohibit
this.
6.1.3	Implementabillty
The implementabillty of this alternative is straightforward.
6.1.4	Cost
The only capital cost associated with this alternative is for preparing the long-term
groundwater and soil gas monitoring plans. The estimated cost for this is $25,000.
The estimated annual operating, maintenance and monitoring (OM&M) costs are
$200,000. The net present value (NPV) of the OM&M costs is $3,700,000. The total
capital and NPV of the OM&M costs is $3,725,000. Details regarding these estimates
are provided in Appendix E.
8*2 Alternative 2: Soil Cover
6.2.1 Description
This alternative would involve upgrading the existing cover to promote surface water
runoff and to support vegetation. Additional vegetation would also improve the
aesthetic appearance of the site. The components of this alternative are as follows:
* Regrading the site to obtain final grades ranging from 2 percent to 20 percent
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•	Adding an average of 6 inches of general fill on top of an average of 6-inches
of existing cover materials (minimum thickness of general fill will be 12 inches)
•	Placing 6 inches of topsoil, and seeding with appropriate vegetation
•	Installing a perimeter gas control system along the northern boundary and
southeastern corner of the North Waste Cell
Upgrading the existing gas migration control system blower
•	Maintaining the existing perimeter fence
•	Deed restrictions limiting site access and future land use
•	A local ordinance prohibiting construction of potable water supply wells in
certain areas
•	Continuing to operate and maintain the perimeter gas migration control system
in the South Waste Cell
Implementing long-term groundwater and landfill gas monitoring
The soil cover will allow the biodegradation of waste constituents to continue at its
current rate. The evidence supporting this was summarized in Subsection 6.1.2, and
is documented in Appendix B.
6.2.2 Effectiveness
Implementation of deed restrictions and a local ordinance prohibiting construction of
potable water supply wells in the area will protect the public from potential future
exposure to landfill contents and to groundwater affected by the landfill.
The effectiveness of the soil cover in treating groundwater affected by the landfill
would be the same as that described for the existing cover that was part of the no
action alternative described in Subsection 6.1. The addition of an average of 6 inches
of general fill and 6 inches of topsoil plus vegetation would not significantly reduce the
supply of oxygen reaching the groundwater from that under the existing cover
conditions. The soil cover would therefore allow natural biodegradation processes to
continue at their current rate. Therefore, this alternative would remove hazardous
substances from the aquifer in accordance with Rule 299.5705(6), MAC.
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This alternative would not actively remove contaminants in the groundwater that have
already moved beyond the site boundaries. This is not believed to be an
unacceptable situation, because there are currently no known users of the aquifer
between the landfill and the Kalamazoo River (into which the affected groundwater
discharges); the levels of landfill constituents beyond the site boundaries are relatively
low; and institutional controls prohibiting future construction of potable water supply
wells in areas affected by the landfill would address potential concerns regarding
future health risks via ingestion of groundwater.
This alternative will also reduce potential future health risk and hazard associated with
the off-site migration of landfill gas from portions of the North Waste Cell.
Exposure via dermal contact would be controlled by a minimum 12 inches of general
fill and 6 inches of topsoil, continued maintenance of the perimeter fence, as well as
deed restrictions on future land use.
6.2.3	Implementability
Regrading of the site, placing general fill and topsoil, planting vegetation, and
installing landfill gas extraction systems are all common landfill construction activities,
making implementation of this alternative reasonably achievable. For ease of site
access and working conditions, these activities should be conducted during the
spring-to-fall construction season. It should be recognized that waste that is exposed
during grading activities could contain asbestos. In addition, exposing waste could
also create airborne exposures to landfill contents or chemical constituents, potentially
resulting in adverse health effects or nuisance odors. This may require exposing only
small areas of waste at any one time to avoid creating a potential health problem or
nuisance to nearby residences. This alternative would also entail working with the
appropriate local authorities to pass an ordinance prohibiting the construction of
potable water supply wells in certain areas.
6.2.4	Cost
The estimated total capital cost to implement this alternative is $1,900,000. The
estimated annual OM&M costs are $240,000. The net present value (NPV) of the
OM&M costs is $4,500,000. The total capital and NPV of the OM&M costs is
$6,400,000. Details regarding these estimates are provided in Appendix E.
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6.3 Alternative 3; Soil Cover with Groundwater Containment
6.3.1	Description
This alternative contains the same components, including the soil cover, as
Alternative #2, with the addition of groundwater containment.
As described in Subsection 5.6, groundwater containment could be achieved at this
site by pumping a combined rate of approximately 200 gallons per minute from two
extraction wells. One extraction well would be located on the western side of the site
near well nest OB-8, and the other would be located in the southwestern corner of the
site near well nest OB-1.
The quality of the extracted groundwater should be dischargeable to the Kalamazoo
River under the City's NPDES stormwater permit without treatment. Preliminary
discussions with the City indicate that the pumped groundwater could be discharged
to the City's storm sewer system at the southwestern corner of the site. However,
approximately 2,200 feet of the storm sewer system, from the southwestern corner of
the site to the intersection of Hubbard and Laramie Streets, consists of open ditches
and culverts. In order to avoid potential problems associated with freezing
temperatures, this alternative would need to include installing a 4-inch-diameter
underground pipeline from the extraction wells to Hubbard and Laramie Streets. This
would involve obtaining a right-of-way or easement to construct on the off-site sections
of the route.
6.3.2	Effectiveness
The effect of groundwater containment on contaminant concentrations in groundwater
was simulated using the Quickflow~ and BIOPLUME™ models. These analyses are
described in detail and the results are illustrated on figures in the Appendix B report.
The model results indicated that the groundwater containment system, operating at
200 gpm in conjunction with the soil cover would reduce the total dissolved
contaminant mass in the groundwater from 2,600 kg to 1,400 kg within 12 years (this
would be 54 years after the start of filling), as compared to 1,800 kg within 12 years
without groundwater containment. This represents the difference between a 46
percent reduction in mass with groundwater containment versus a 31 percent
reduction in mass without it
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CEREAL CITY LANDFILL	FINAL
Looking further into the future, the contaminant mass would be reduced to 135 kg
after 48 years of pumping, compared to 240 kg after 48 years without containment.
This represents the difference between a 95 percent reduction in mass after 48 years
with groundwater containment versus a 91 percent reduction in mass without it.
Other than the faster removal of contaminant mass from the aquifer, and therefore
meeting Rule R299.5705(6), MAC, the effectiveness of Alternative #3 would be the
same as for Alternative #2. The groundwater containment system described in
Subsection 5.6 would not reverse the natural groundwater flow direction at locations
downgradient of the extraction wells. The groundwater containment system was
conceptually designed to prevent ongoing migration of landfill constituents in the
groundwater beyond the site boundaries. Capture of landfill constituents that have
already moved off-site would require additional extraction wells in off-site locations.
Because the levels of contaminants are low and because there are no known current
users of the aquifer for drinking water, institutional controls prohibiting the installation
of potable water supply wells in areas where the groundwater has been affected by
the landfill should be adequate to protect against potential future health risks
associated with ingestion of groundwater.
6.3.3 Implementabillty
This alternative is generally implementable, although the inclusion of groundwater
containment introduces some new issues that were not factors in Alternative #2.
These additional issues include the following:
•	Estimates of the quality of groundwater pumped from the locations described
above, at a combined rate of approximately 200 gpm, indicate that it would
meet the discharge limits in the City's NPDES stormwater permit for discharge
to the Kalamazoo River without treatment. It was estimated that up to 350
gpm of groundwater could be pumped and stilt meet the Kalamazoo River
water quality criteria. There are, however, uncertainties in these estimates,
and the actual pumped groundwater quality could be different and may
change over time.
•	Approval from the City to discharge into the storm sewer and to install buried
force main along the section of the storm sewer system that consists of open
ditches and culverts would be needed.
•	Long-term groundwater pumping would require regular operation and
maintenance attention.
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6.3.4 Cost
The estimated total capital cost to implement this alternative is $2,300,000. The
estimated OM&M cost is $300,000. The net present value (NPV) of the OM&M costs is
$5,600,000. The total capital and NPV of the OM&M costs is $7,900,000. Details
regarding these cost estimates are provided in Appendix E.
6.4 Alternative 4: Conventional Cover
6.4.1 Description
This alternative would involve placing a conventional low-permeability cover over the fill
areas to reduce infiltration of rainfall and snowmelt into the waste and generation of
leachate. Six low-permeability cover options were evaluated (refer to the report in
Appendix A) with the one consisting of (from top to bottom) 6 inches of topsoil,
18 inches of general fill, a geosynthetic clay liner (GCL), and 18 more inches of
general fill for frost protection, being selected as the most cost-effective option that
meets the Part 115 performance criteria. The design of this GCL cover option was
discussed previously in Subsection 5.5.1. A conventional cover also requires interior
landfill gas controls—in addition to the perimeter system previously described for both
the North and South Waste Cells—and surface water runoff controls. These are both
included as part of the conventional cover design.
The surface water that accumulates in the two sedimentation basins would be
conveyed to the City storm sewer system via a new lift station and underground
piping. This water would eventually be discharged to the Kalamazoo River under the
City's NPDES stormwater permit. Even though only a portion of the surface water
runoff would be routed to the sedimentation basins, a 10-inch-diameter pipe would be
necessary to handle the peak flow of 1,200 gpm during a 10-year, 24-hour storm
event. By contrast, only a 4-inch-diameter pipe would be needed to handle the
200 gpm pumping rate needed for groundwater containment, as described in
Alternative #3.
Alternative #4 also includes the institutional controls and long-term groundwater and
soil gas monitoring programs that were included with the three previous alternatives.
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6.4.2	Effectiveness
The effectiveness of a conventional cover in remediating groundwater quality at the
CCL was also evaluated as part of the study documented in Appendix B. The effect of
a low-permeability cover on the subsurface conditions would be to decrease the
recharge rate to the groundwater from 12 to 0.75 inches per year (as compared to a
soil cover), to decrease the rate of source decay from 50 to 7 percent per 12-year
period, and to decrease the re-aeration coefficient from 2 x 102 to 2 x 103 percent per
day. The changes in the model input parameters showed that the mass of
groundwater contaminants would decrease at a much slower rate under a
conventional, low-permeability cover as compared to a soil cover that allows more
oxygen to reach the groundwater. For example, 90 years after the start of filling, the
total dissolved contaminant mass would have decreased from 2,600 kg to 980 kg, a
reduction of 62 percent (compared to a 91 percent decrease with the soil cover
option).
These results are considered to be best case in that the effect of continued leaching
of the waste by groundwater throughflow is not considered. For the approximately
25 percent of the area where waste is in direct contact with groundwater, the rate of
leachate generation would likely be higher than simulated, which would result in
somewhat higher groundwater concentrations. In fact, the model results indicate that
the extent of the contaminant plume might actually increase under a low-permeability
cover. Increasing the horizontal extent of the plume as a result of a remedial action is
not allowed under Rule R299.5705(5), MAC.
The effectiveness of the institutional controls and perimeter gas extraction along
portions of the North Waste Cell boundaries in reducing health risks and hazards
would be the same as for Alternatives #2 and #3 (the soil cover alternatives) with the
notation that the area in which institutional controls would be needed to prohibit
installation of potable water supply wells would likely need to be extended further
south.
6.4.3	Implementabillty
Alternative #4 would be more difficult to implement than the previous three alternatives
because it involves more extensive grading, placement of cover layers, interior gas
control systems, and surface water runoff collection and discharge systems. These
are all common components of municipal solid waste landfills and can be designed
75
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CEREAL CITY LANDFILL	FINAL
and implemented in a relatively straightforward manner. Potential health or odor
problems associated with exposing large areas of waste may limit the rate of
construction.
Collection and disposal of surface water will require careful planning because the
design rate (preliminarily estimated to be about 1,200 gpm) is high as a result of the
large surface area being drained. It will be important to better determine the
applicable limits on flow rates and water quality and routing of pipelines with the City.
The implementability issues related to institutional controls that were previously
described would also apply to this alternative.
6.4.4 Cost
The estimated total capital cost to implement this alternative is $7,400,000. The
estimated annual OM&M cost is $330,000. The net present value (NPV) of the OM&M
costs is $6,100,000. The total capital and NPV of the OM&M costs is $13,500,000.
Details regarding these estimates are provided in Appendix E.
6.5 Alternative 5: Conventional Cover wtth Groundwater Containment
6.5.1 Description
This alternative contains the same components, including a conventional cover, as
Alternative #4—with the addition of groundwater containment. The groundwater
containment system would be the same as that described in Alternative #3, where
groundwater containment was combined with the soil cover (i.e., two extraction wells,
one on the western side of the site near well nest OB-8, and one in the southeastern
corner of the site near well nest OB-1, would pump at a combined rate of
approximately 200 gallons per minute, with discharge to the Kalamazoo River under
the City's NPDES stormwater permit without treatment). The pumped groundwater
would be combined with surface water collected in the sedimentation basins and
pumped to the City's storm sewer system. The 10-inch-diameter pipe described in
Alternative #4 to control surface water runoff would also be adequate to handle an
additional 200 gpm of flow from groundwater extraction wells.
76
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6.5.2	Effectiveness
The effect of groundwater containment combined with a conventional, low-permeability
cover on contaminant concentrations in groundwater was simulated using the
Quickflow™ and BIOPLUME"* models. These analyses are described in detail and the
results are illustrated on figures in the Appendix B report. The model results indicated
that the groundwater containment system, operating at 200 gpm in combination with a
conventional cover, would reduce the dissolved contaminant mass in the groundwater
from 2,600 kg to 1,500 kg within 12 years (this would be 54 years after the start of
filling), as compared to 2,100 kg within 12 years for a conventional cover without
groundwater containment. This represents the difference between a 41 percent
reduction in mass for a conventional cover with groundwater containment versus a
19 percent reduction in mass without it.
Looking further out, the contaminant mass would be reduced to 480 kg after 48 years
of pumping (and a conventional cover), compared to 980 kg after 48 years with a
conventional cover alone. This represents the difference between a 82 percent
reduction in mass after 48 years for a conventional cover with groundwater
containment versus a 62 percent reduction in mass without it.
Other than the quicker removal of contaminant mass from the aquifer, which meet the
requirement of Rule 299.5705(6), MAC, the effectiveness of Alternative #5 would be
the same as for Alternative #4. The effectiveness of groundwater containment in
removing landfill constituents that have already migrated beyond the site boundaries
would be the same as for groundwater containment under Alternative #3 (soil cover
with groundwater containment).
6.5.3	Implementability
This alternative would be the most difficult of the five alternatives to implement,
although it would still be generally straightforward. The following issues regarding
implementability would need to be addressed (these were all described in at least one
of the previous alternatives):
•	Working with the appropriate regulatory authorities to implement the
institutional controls.
•	Controlling odors and potential health risks created by exposed waste during
grading activities.
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CEREAL CITY LANDFILL	FINAL
Receiving approval from the City to discharge combined flows from the
pumped groundwater (estimated to be 200 gpm) and peak stormwater runoff
flow (estimated to be 1,200 gpm during a 10-year, 24-hour rain event) via their
stormwater sewer system to the Kalamazoo River under the City's NPDES
stormwater permit.
•	Obtaining a right-of-way or easement to construct an approximately 2,200-foot
section of the off-site discharge piping in areas where the storm sewer system
currently consists of open ditches and culverts.
•	Operation and maintenance of a long-term groundwater pumping system.
•	Grading and placing cover layers during favorable construction conditions (i.e.,
spring to fall).
6.5.4 Cost
The estimated total capital cost to implement this alternative is 57,600,000. The
estimated annual OM&M cost is $350,000. The net present value (NPV) of the OM&M
costs is $6,500,000. The total capital and NPV of the OM&M costs is $14,100,000.
Details regarding these estimates are provided in Appendix E.
73	2048 « 0000 RTE c«f»0627
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CEREAL CITY LANDFILL	FINAL
Section 7
COMPARATIVE ANALYSIS OF ALTERNATIVES
This section presents a detailed analysis of the five remedial alternatives described in
Section 6. The basis for this comparison are the nine criteria that are outlined in
Rule R299.5513 MAC, and that are listed below:
1.	The effectiveness in protecting the public health, safety, or welfare, or the
environment
2.	Details about the alternatives
3.	Costs to implement the final remedy, including operation and maintenance
4.	Engineering implementability, reliability, and constructability
5.	Technical feasibility
6.	Whether recycling, reuse, waste minimization, waste biodegradation, waste
destruction, or other advanced, innovative, or alternative technologies are
appropriate
7.	Adverse environmental impacts, methods of mitigation, and costs of mitigation
8.	Risks remaining after implementation of the remedy
9.	The extent to which the alternative attains or exceeds ARARs
The purpose of this comparative analysis is to identify the advantages and disadvantages of
each alternative relative to one another. This will determine the key areas of difference among
the alternatives that need to be weighed and balanced in the selection of a remedy for this
site. The alternatives are evaluated against each of the nine criteria in the following
subsections. A summary of this comparison is shown in Table 7-1.
7.1 Effectiveness In Protecting the Public Health. Safety, or Welfare or the
Environment
This criteria addresses the adequacy with which the alternatives can provide protection of
human health and the environment by controlling exposures to contaminants.
79
2044 43 0000 FTTE c*r*OeZ7
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TABLE 7-1

Page 1 ol 5 I





Revised Final September 1995


SUMMARY OF COMPARISON OF THE REMEDIAL ALTERNATIVES



FOR THE CEREAL CITY LANDFILL


I Act 307 Rufc
¦i.V |

, r.
Sol Com trthQroundwatar
'a
6
Conventional Cover w(th
[ R299.S513 Criteria
No Action
Soil Cover
Containment
Convention* Cover
Groundwater Containment
1. Effectiveness
• Treatment of landfill constituents
• Same as (or Alternatrve #1. and
• Modeled reduction in total
• Natural degradation
• Modeled reduction in total

via natural biodegradation
controls potential future risk and
dissolved contaminant mass
processes would be slowed
dissolved contaminant

processes win continue at
hazard from oft sue migration of
in groundwater is 46% m 12
down because less oxygen
mass in groundwater is

current rate Modeled reduction
landfill gas from portions of the
years and 95% m 46 years.
would be available The
41% in 12 years and 62%

in total dissolved contaminant
Norlh Waste Cell, as well as
• Eliminates potential future
extent of the contaminant
in 48 years

mass in groundwater is 31* in
eliminates potential future risk ot
exposure to affected
plume might actually
• Institutional controls would

12 years and 91% in 48 years.
ingesting groundwater affected
groundwater
increase Modeled reduction
need to be extended


by the landfill.
• Eliminates potential future
in total dissolved
further south



direct contact with the landfiH
contaminant mass in
• Eliminates potential future
|


contents.
groundwater is 19% in 12
exposure to attected
|


• Controls potential future risk
years and S3% in 48 years
groundwater.
I


and hazards from off site
• Institutional controls would
• Eliminates potential future
I


migration of landfill gas from
need to be extended further
direct contact with the
¦


portions of the North Waste
south.
landfill contents
|


Cell
• Eliminates potential future
• Controls potential future
I



exposure to affected
risk and hazards from off-
| NOTE:



groundwater.
site migration of landfill gas
I



• Eliminates potential future
from portions of the Nonh
1 For all alternatives.



direct contact with the landfill
Waste Cell
1 the modeled



contents.

I contaminant



• Controls potential future risk

| reduction Is



and hazards from off-site

1 expressed in years



migration of landfill gas from

| following remedy



portions of the North Waste

j implementation.



Cell

TOM 4 ouoocti c*«*oe?r t
-------
| TABLE 7-1 (CONTINUED) Page 2 ol 5
B Revised Final September 1995
1 SUMMARY OF COMPARISON OF THE REMEDIAL ALTERNATIVES
I FOR THE CEREAL CITY LANDFILL
1 Act 307 Rute
| R290.SS13 Criteria
1
No Action
2
SoilCover
3
So# Cover wtti Groundwater
Comafcwmnf
4
CofWtoUooal Cover
5
Conventional Cover with
Groundwater Containment
| 2. Detailed
A descriptions
•	Eliminates potential future direct
contact with I he landfill contents
•	Existing cover.
Maintenance ot the existing
perimeter lence.
•	Long-term groundwater and soil
gas monitoring.
•	Continued operation erf the
perimeter gas control system in
the South Wasta Coll.
•	Regrading existing cover to
control surface water, (ban
adding an average ol 6 inches ot
general fill on top of an average
of 6 inches ot existing cover
materials (minimum thickness ot
general fill will be 12 inches), and
6 inches of topsoil.
•	Vegetating the surface
•	Installing a perimeter gas control
system along itie nartliem
perimeter and southeastern
corner of the North Waste Cell
•	Upgrading the existing South
Waste Cal gas migration control
system blower,
•	Deed restrictions limiting site
access and future land use.
•	A local ordinance prohibiting the
installation of water supply weHs
in certain areas.
•	Maintenance of the existing
perimeter fence.
•	Long term groundwater and soil
gas monitoring.
•	Continued operation of the
perimeter gas control system in
the South Waste Cell.
•	Same as for Alternative #2,
with the addition of
groundwater containment
•	Groundwater pumping rate of
200 gpm (total) from two
wells
•	Effluent discharge to the
Kalamazoo River via City
storm sewer.
•	Regrading site, then placing
(from bottom to top) 18
inches general fill, a
geosynthetic clay liner, 18
inches general fill, and 6
inches topsoil
•	Vegetating the surface.
•	Installing interior landlill gas
control.
•	Perimeter gas control lor the
North and South Waste
Celts
•	Two sedimentation basins
with piping and a Wt station
to discharge surface water to
the Kalamazoo River via the
City storm sewer system.
•	Institutional controls (fencing,
sewers, deed restrictions,
and prohibiting water supply
wells in certain areas).
•	Long term groundwater and
soil gas monitoring
•	Replacing the gas control
system Mower, Name
arrester and condensate
tar* with higher capacity
equipment
•	Same as for Alternative #4,
with the addition of
groundwater containment
•	Groundwater pumping rate
of 200 gpm (total) from two
wells.
•	Effluent discharge (with
surface water) to
Kalamazoo River via the
City storm sewer system.
904* *2 ouuu frit	t
-------
N
I


TABLE 7-1 (CONTINUED)
SUMMARY OF COMPARISON OF THE REMEDIAL ALTERNATIVES
FOR THE CEREAL CITY LANDFILL
Page 3 of 5
Revised Final September 1995
| Act 307 Rule
| R289SS13 Criteria
1
No Action
2
SoH Cover
3
Sod Cover wkh Groundwater
Containment
4
Conventional Cover
5
Conventional Cover with
Groundwater Containment
I 3 Costs:





J ¦ CaprtaJ
- Annual OMSM
NPV of OMSM
1 costs
1 ¦ Capital plus
I NPV of OMSM
I costs
$25,000
$200,000
$3,700,000
$3,725,000
$1,900,000
$240,000
$4,500,000
$6,400,000
$2,300,000
$300,000
$5,600,000
$7,900,000
$7,400,000
$330,000
$6,100,000
$13,500,000
$7,600,000
$350,000
$6,500,000
$14,100,000
] 4 Implementability,
I reliability, and
9 constructability
Straightforward
• Should be reasonably achievable;
however, site grading may
expose wastes, which may slow
construction Will need local
approvals to implement additional
institutional controls.
• Generally implement able
Issues requiring attention
include: exposure of waste
during grading; confirmation
of effluent water quaMy;
construction of approximately
2,200 feet of underground
storm sewer piping in city
streets, requires approval
from the City to discharge Into
the storm sewer. Requires
long term O&M of
groundwater pumping system
• More difficult than
Akematrves #1#3 because
of more extensive surface
construction Collection and
disposal of surface water will
require careful planning and
long term O&M of pumping
system.
• Most difficult. Combines
issues associated with
extensive surface
construction, surface water
collection arid discharge,
groundwater pumping and
discharge, and institutional
controls.
5. Teclinical
feasibility
Not applicable
Technically feasible
Technically feasible.
Technically feasible.
Technically feasible
0000 WTl (N««^ I
-------
Page 4 ol f>
Revised Final September 19'JS
Act 307 Rule
| R209.5S13 Criteria
1
No Action
2
Soil Cover
3
8«ll Coyer with Groundwater
Containment
4
Conventional Cover
5
Conventional Cover with
Groundwater Containment
6 Approprialoness
ol recycling,
etc , and/or
I innovative
I technologies
Incorporates waste biodegradation
in an alternative treatment
technology.
Incorporates waste biodogradation
in an alternative treatment
technology.
Incorporates waste
biodegradation in an alternative
treatment leclinotoyy
Does not incorporate any of
these preferred technologies
Docs not incorporate any ol
these preferred technologies
7. Adverse
environmental
impacts
Off-site vegetation directly north of
the North Waste Cell would
continue to be stressed.
None expected.
None expected.
Extent of off-site plume could
move further down gradient
Runoff to on-site wetlands will
increase.
Runoff to on site wetlands will
increase.
8 Remaining risks
Potential luture risk or hazard from
off site migration of subsurface
gases along the northern perimeter
and southeastern corner of the
North Waste CeB remain. Potential
luture risk ot ingesting groundwater
contaminated by the landlilt.
Controls potential luture risks and
hazards.
Controls potential luture risks
and hazards.
Controls potential luture risks
and hazards,
Controls potential future risks
and hazards
TABLE 7-1 (CONTINUED)
SUMMARY OF COMPARISON OF THE REMEDIAL ALTERNATIVES
FOR THE CEREAL CITY LANDFILL
K44 «? OOOO Hfl	1
I
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TABLE 7-1 (CONTINUEO)
SUMMARY OF COMPARISON OF THE REMEDIAL ALTERNATIVES
FOR THE CEREAL CITY LANDFILL
Pago S of 5
Revised Final September 1995
Art 30? Rule
R299.5513 Criteria
9 Compliance with
ARARs
1
No Action
Arsenic could exceed groundwater
quality criteria in otf srte locations.
Meets the requirement for removal
of hazardous substances Irom the
aquifer in Rule R299 5705(6), MAC.
Meets Rule 299 5705(5). MAC
Meets the applicable final cover
requirement.
2
Soil Cover
Meets the groundwater cleanup
criteria in Section 20120a(t)(f)
(limited residential land use) of
Part 201 of Act 451 Meets the
soil cleanup criteria in
Section 20120a(1)(i) (limited
industrial land use) of Part 201 of
Act 451. Meets the requirement
for removal of hazardous
substances from tfie aquifer in
Rule R299 5705(6), MAC. Meets
Rule 299.5705(5), MAC Meets
applicable final cover requirements.
Sol Cover wttt Groundwater
ConfafewMrt
Meets the groundwater cleanup
criteria in Section 20120a(t)(f)
(limited residential land use)
of Part 201 of Act 451. Meets
the soil cleanup criteria in
Seel ion 20t20a(1)(i) (limited
industrial land use) of Part 201
of Act 451. Meets the
requirement lot removal ol
hazardous substances Irom the
aquifer in Rule R299 5705(6),
MAC Meets Rule 299 5705(5),
MAC. Meets applicable final
cover requirements
Conventional Cover
Meets the groundwater cleanup
criteria m Section 20120a(1 HO
(limited residential land use)
of Pari 201 of Act 451. Meets
the soil cleanup criteria in
Section 20120a(t)(i) (limited
industrial land use) of Part 201
of Act 451 Does not meet
Rule R229 5705(6), MAC. Does
not meet Rule R299 5705(5),
MAC, which prohibits
increasing the extent of the
plume as a result of a remedial
action. Meets hydraulic
conductivity requirements for
impermeable liners in Part 115
of Act 451.
Conventional Cover with
Groundwater Containment
Meets the groundwater
cleanup criteria in
Section 20120a(1)(f) (limited
residential land use) of
Part 201 of Act 451 Meets
the soil cleanup criteria
in Section 20120a(1)(i)
(limited industrial land use) of
Part 201 ol Act 451 Meets
the requirement fur removal ol
hazardous substances from
tlie aquifer in Rule
R299,5705(6), MAC Meets
hydraulic conductivity
requirements tor impermeable
liners in Part 115 of Ad 451
I04t *3 oaoa «r|	i
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RMT FEASIBILITY STUDY REPORT
SEPTEMBER 1995
CEREAL CITY LANDFILL
FINAL
Alternative #1 does not provide protection from potential future exposures to the landfill
contents or to groundwater affected by the landfill because it does not include deed
restrictions to limit land use or a local ordinance prohibiting construction of potable water
supply wells in certain areas. Alternatives #2 through #5 provide the same degree of
effectiveness in preventing these exposures because they include additional institutional
controls to address them. Alternative #1 provides current protection from exposure via direct
contact with the landfill contents because there is a perimeter fence (with a locked gate)
already in place.
All five alternatives would be equally effective in preventing exposure to and controlling a
potential safety hazard as a result of off-site landfill gas migration from the South Waste Cell
because each alternative includes the continued operation of the existing active gas extraction
system along the western border and southwestern corner of the South Waste Cell. The
expanded system in this area has been in operation since August 1993 and ongoing
monitoring (initially monthly, now quarterly) has demonstrated its effectiveness in controlling
off-site migration of landfill gas.
Alternatives #2 through #5 would be equally effective in also preventing potential future
exposure and controlling a potential safety hazard associated with the off-site migration of
landfill gas that is occurring along the northern boundary and southeastern corner of the
North Waste Cell because these four alternatives include an active perimeter gas extraction
system in these areas. Alternative #1 (the no action alternative) does not include a perimeter
gas control system in the North Waste Cell.
The effectiveness of Alternatives #2 through #5 in remediating impacts to groundwater quality
was studied extensively for this site, and the results are documented in a report in
Appendix B. The effectiveness of Alternative #1 (no action) and Alternative #2 (soil cover) in
remediating impacts to groundwater quality would be about the same because both would
allow approximately the same rate of oxygen and moisture to reach the waste constituents in
the fill and groundwater.
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The differences in the effectiveness of Alternatives #2 through #5 are a result of the
combination of two different rates of removal of waste constituents in groundwater via natural
biodegradation and the rate of removal of waste constituents in groundwater by pumping
groundwater from wells. The effectiveness of Alternatives #1 through #5 in remediating
groundwater quality impacts is summarized in Table 7-2. This table shows that the greatest
reductions in contaminant mass within 12 years would be achieved by the alternatives that
include groundwater containment (Alternatives #3 and #5) but that after 48 years, the
alternatives that enhance the natural biodegradation of waste constituents by allowing more
oxygen to reach the groundwater (Alternatives #1, #2, and #3) would achieve 9 to 33 percent
better results than with a conventional landfill cover.
To varying degrees, Alternatives #2 through #5 will meet the remedial action objective of
reducing the off-site migration of groundwater affected by the landfill. The effectiveness of
natural biodegradation of landfill constituents has been demonstrated by the chemical trends
seen in the results obtained during 12 years of groundwater monitoring at this site. The case
histories and research conducted at other sites support the conclusions reached for the CCL
regarding the effectiveness of natural degradation processes in reducing the concentrations of
certain landfill constituents in groundwater. In addition, computer modeling predicts that the
off-site extent of groundwater impacts will be greater with a low-permeability cover because
longer travel distances will be necessary to achieve similar natural degradation effects.
Although Alternative #3 (soil cover) and Alternative #5 (conventional cover) will most
effectively reduce off-site migration of groundwater affected by the landfill because they
include groundwater containment, the added benefit of not allowing groundwater affected by
the landfill to migrate beyond the site boundaries needs to weighed against the following: the
incremental cost to install recovery wells and piping; the issues associated with discharging
the pumped water; the nature and concentration of the landfill constituents migrating off-site;
and the level of risk reduction that can be achieved via institutional controls alone.
7.2 Details About the Alternatives
Detailed descriptions of each of the components of the alternatives, including the cover
designs, the grading plans, the surface water controls, the interior and perimeter landfill gas
management systems, the groundwater containment system, the institutional controls, and
cost estimates, were presented previously in Section 5 and in Appendices A, B, and E.
86
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TABLE 7-2




SUMMARY OF THE EFFECTIVENESS OF ALTERNATIVES #1 THROUGH #5
IN REMEDIATING IMPACTS TO GROUNDWATER QUALITY AT THE CEREAL CITY LANDFILL



Technologies Used to Remove
Hazardous Substances from the Aquifer
Percent Reduction in Contaminant
Mass 12 and 48 Years After
Implementation of Remedy
Alternative
Description
Natural
Biodegradation
Groundwater
Extraction1
After 12 Years
After 48
Years
1
No action
S

31
91
2
Soil cover
~

31
91
3
Soil cover with groundwater
containment
S
S
46
95
4
Conventional cover3


19
62
5
Conventional cover3 with groundwater
containment

~
41
82
NOTES:





' Groundwater extraction would be achieved by pumping at a combined flow rate of 200 gpm from two recovery wells.
2	Calculations were made on the basis of 2,600 kg of dissolved contaminants at the beginning of the period evaluated (see report
in Appendix B of the FS for additional background and details).
3	The conventional cover was modeled to represent the performance characteristics of a cover layer that includes (from top to
bottom): 6 inches of topsoil, 18 inches of general fill, a geosynthetic clay liner, and 18 inches of general fill.
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Section 6 described which of these components were included in each remedial alternative.
In order to avoid repeating the same information here, the reviewer is asked to refer back to
the above-referenced sections and appendices.
7.3	Estimated Costs
The estimated capital and operating, maintenance, and monitoring (OM&M) costs for each
alternative were presented in Section 6 and are summarized in Table 7-1.
The net present values (NPV) of the estimated OM&M costs were calculated on the following
basis:
•	Costs increase at a rate of 3 percent per year beginning in April 1995
Costs are incurred monthly beginning in July 1997
•	Costs are incurred for a period of 30 years
•	The cost of money is 6 percent per year
7.4	Engineering Implementabllltv. Reliability, and Constructabllttv
Implementabilitv
Each of the alternatives incorporates standard engineering design and construction elements
that can be implemented without encountering more than the usual amount of problems. The
foreseeable areas at potential difficulty in implementing the alternatives are described as
follows:
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Alternatives Affected
Potential Difficulty
2, 3, 4, and 5
Passage of a local ordinance restricting the use of private property
in areas affected by the landfill by not allowing future construction
of potable water supply wells
2, 3, 4, and 5
Exposing and moving wastes to obtain final grades that are
needed to provide surface water runoff control may create
nuisance odors, or less likely, emissions of hazardous constituents
above allowable health-based concentrations
3 and 5
Receiving approval from the City to allow the untreated continuous
discharge of approximately 200 gpm of pumped groundwater to
the Kalamazoo River via their storm sewer system under their
NPDES permit
3, 4, and 5
Installing approximately 2,200 feet of buried pipe between the
southwestern corner of the landfill and the intersection of Hubbard
and Laramie Streets to replace the open culverts and drainage
ditches along this portion of the City's storm sewer system
4 and 5
Increasing the volume of surface water runoff to the on-site
wetland areas to the east of the waste cells
4 and 5
Receiving approval from the City to allow up to 1,200 gpm of
surface water runoff to the storm sewer system as a result of a
peak rainfall event under their NPDES permit
In general, those alternatives involving the existing cover or a soil cover (Alternatives #1, #2,
and #3) would be easier to implement than those involving the conventional, low-permeability
cover (Alternatives #4 and #5) simply because they involve less construction activity.
Similarly, those alternatives that do not involve groundwater containment (Alternatives #1, #2,
and #4) would be easier to implement than those that include this component (Alternatives #3
and #4). Overall, the degree of implementability of the five alternatives, with the easiest being
listed first, is as follows:
•
Alternative
#1
•
Alternative
#2
•
Alternative
#3
•
Alternative
#4
•
Alternative
#5
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Reliability
The reliability of the remedial alternatives is related to the type and complexity of the
components included in the alternative. The reliability of a conventional cover (Alternatives #4
and #5) is more sensitive to the quality control of the construction process than is a soil cover
(Alternatives #2 and #3). The long-term care and maintenance of a conventional cover is also
important in maintaining the integrity of the low-permeability layer. The pumps required to
achieve groundwater containment (Alternatives #3 and #5) are subject to mechanical failure
and will require regular maintenance and periodic replacement. In addition, the more
extensive the landfill gas system needed, the greater the operational and maintenance effort
needed to keep it running. Overall, the degree of reliability of the five alternatives, with the
most reliable being listed first, are as follows:
Alternative #1
Alternative #2
Alternative #4
Alternative #3
Alternative #5
Const ructabilitv
Construction of a conventional cover (Alternatives #4 and #5) would be much more difficult
than construction of a soil cover (Alternatives #2 and #3) because of the number of layers
involved (four versus one) and because of the extra quality control needed to ensure the
proper placement of each layer in order to achieve the specified performance standard. Even
the soil cover would require extensive grading to achieve positive drainage. The replacement
of off-site sections of City storm sewer drainage ditches and open culverts with buried pipe
(Alternatives #3, #4, and #5) will present another set of construction concerns. Construction
of the groundwater recovery wells and landfill gas extraction system (perimeter or interior) are
not expected to present any unusual construction issues. Overall, the degree of
constructability of the five alternatives, with the easiest to construct being listed first, is as
follows:
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Alternative #1
Alternative #2
Alternative #3
Alternative #4
Alternative #5
7.5	Technical Feasibility
Each of the alternatives evaluated are technically feasible. The USEPA's presumptive
remedy guidance for CERCLA municipal landfills (Appendix D) was previously referenced
(Subsection 5.2) as the basis for screening out technologies that are not technically feasible
for this type of site. The technologies included in the alternatives being considered for the
CCL have all been demonstrated at many other sites. The criteria of technical feasibility
therefore does not provide a basis for differentiation among the alternatives considered for this
oite.
7.6	Assessment of the Apypr'aKness of Recycling. Reuse. Waste Minimization,
Waste biodeuroJotlon. Waste Oest-uctlon, or Alternative Technologies
Recycling, reuse, waste minimization, and/or w=»sre destruction are not applicable technologies
for remediation of environmental impacts at a municitol solid waste landfill as concluded by
the USEPA in their presumptive remedy guidance for this type of site (Appendix D).
Waste biodegradation is, however, an applicable technology for this site because of its
hydrogeologic setting, the types and levels of landfill constituents detected both on- and off-
site, and the results of a site-specific baseline risk assessment. A detailed evaluation of the
effectiveness of the natural biodegradation processes at this site under the four combinations
of cover and groundwater pumping, is presented in Appendix B. The results of this study
were summarized throughout Section 6. The effectiveness of this technology, when used in
conjunction of the other remedial technologies to form the five remedial alternatives for this
site, is summarized in Table 7-2. In order to avoid repeating the same information here, the
reviewer is asked to refer back to the above-referenced sections and appendices.
7.7	Adverse Environmental Impacts
No major impacts are expected to occur as a result of implementing any of the remedial
alternatives evaluated in this FS. Less significant adverse environmental impacts that could
occur include the following:
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Under Alternative #1, the off-site vegetation (trees and grass) directly north of
the North Waste Cell would continue to be stressed as a result of methane
migration in this area.
Under Alternatives #4 and #5, stormwater from all of the North Waste Cell and
the northern and eastern portions of the South Waste Cell would run off to the
on-site wetland areas to the east of the waste cells where it would infiltrate into
the ground.
Under Alternative #4, the extent of the off-site plume could move further
downgradient of the landfill as a result of the decreased volatilization and
decreased rate of oxygen supply to waste constituents in the groundwater.
7.8 Risks Remaining After Implementation of the Remedy
The baseline risk assessment (RMT, 1993a) found that there were no unacceptable risks or
hazards under current land use. Under a hypothetical future residential land use, the following
unacceptable health risks were identified:
Inhalation of VOCs in subsurface gas that could migrate into the basements of
structures near the northern boundary arid southeastern corner of the North
Waste Cell at concentrations above acceptable ambient levels and/or above
the LEL
Ingestion of VOCs and nonvolatile chemicals in groundwater affected by the
landfill if new potable water supply wells were constructed downgradient of the
landfill
Dermal absorption of nonvolatile chemicals in groundwater
The risks and hazards associated with subsurface landfill gas from the North Waste Cell would
be mitigated in Alternatives #2 through #5 because each of these includes an active gas
extraction system in these areas. The risk and hazard would remain if the no action
alternative is selected.
The potential future risk of ingesting groundwater affected by the landfill would be controlled in
Alternatives #2 through #5 by implementing a local ordinance prohibiting the installation of
new potable water supply wells at the site and in certain areas (primarily downgradient)
surrounding the site. Alternatives #2 through #5 also eliminate future potential for direct
contact or ingestion of landfill contents by deed-restricting the site.
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Installing a low-permeability cover and/or hydraulicalfy containing groundwater at the site will
not provide additional risk protection beyond that provided through institutional controls. The
same institutional controls would still be needed even with a low-permeability and groundwater
containment. In fact, they may be needed for a longer period of time.
7.9 The Extent to Which the Alternatives Attain or Exceed ARARs
7.9.1 Chemical-Specific ARARs
Groundwater
There are no exceedances of the Part 201 generic residential groundwater cleanup
criteria (Table 3-7) at off-site locations under current land uses. The only exceedances
of the Part 201 generic industrial groundwater cleanup criteria is for arsenic and
benzene in on-site monitoring wells. Potential future exposure to landfill constituents
in groundwater would be controlled in Alternatives #2 through #5 through the
implementation of institutional controls that would include a local ordinance that would
prohibit construction of potable water supply wells in the areas affected by the landfill
and deed restrictions prohibiting construction of potable water supply wells on-site.
Because Alternative #1 does not include deed restrictions or an ordinance that would
prohibit construction of future water supply wells on the site and in certain off-site
areas, it would not control potential future exposure to affected groundwater.
Alternative #1 does not meet the Rule R299.4433 limit for methane concentration at
the property line (i.e., < LEL) because this alternative does not include a perimeter
gas control system for the North Waste Cell. Alternatives #2 through #5 include the
same plans to control off-site landfill gas migration from the North Waste Cell, and
would therefore provide the same level of compliance with ARARs for soil gas.
Soil
There are no on-site exceedances of the Part 201 generic industrial soil cleanup
criteria In addition, potential residential exposure to on-site soil is currently controlled
by the limited site access allowed by the perimeter fence and locked gate. Potential
future residential exposure to on-site soil will be controlled by maintenance of the
perimeter fence, locked gate, and deed restrictions limiting future land use.
Soil Gas
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Alternatives #2 through #5 provide the same level of protectiveness and compliance
with soil criteria. Alternative #1 is less protective because it does not include future
deed restrictions.
7.9.2	Action-Specific ARARs
Each of the alternatives evaluated would meet the applicable final cover requirements
for a Type II municipal solid waste landfill. As noted in Section 1, a closure agreement
for the site was approved by the MDNR in June 1982, and completion of closure
activities was verified by the MDNR in April 1983. It should be noted that the soil
cover included in Alternatives #2 and #3 would exceed the performance standard
contained in the SWMA rules applicable at the time of closure.
Alternatives #1, #2, #3, and #5 meet the requirement for removal of hazardous
substances from the aquifer contained in Rule R299.5705(6), MAC, by either
promoting natural biodegradation (Alternatives #1 and #2), pumping groundwater
from recovery wells (Alternative #5), or using a combination of these (Alternative #3).
Alternative #4 is not designed to remove the hazardous substances from the aquifer.
Alternatives #1, #2, #3, and #5 meet the requirement to not increase the extent of
contaminants in the aquifer contained in Rule R299.5705(5), MAC. Alternative #4 may
not meet this requirement based on the results of the modeling described in
Appendix B.
7.9.3	Location-Specific ARARs
The only location-specific ARARs applicable to the CCL site are those pertaining to
wetland protection. The state of Michigan Wetlands Protection Act, 1979 P.A. 203, as
amended, requires actions to minimize the destruction, loss, or degradation of
wetlands.
Remedial Alternatives #1 and #2 would have little or no impact on the on-site
wetlands that are located on the eastern portion of the site because neither of these
alternatives involve actions that could impact them. To a very limited extent,
Alternative #3 could affect these wetlands because groundwater would be pumped
from the western side and southwestern corner of the landfill, which could have
localized effects in lowering the groundwater table. Alternatives #4 and #5 would
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have the greatest potential impact to on-site wetlands because these two alternatives
involve the installation of a low-permeability liner over the North and South Waste
Cells, which would alter the stormwater drainage pattern throughout the site and
would increase the amount of stormwater runoff to the on-site wetlands.
95
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Section 8
RECOMMENDED REMEDIAL ACTION
The recommended remedial alternative for the Cereal City Landfill is Alternative #2. This
alternative includes the following components:
•	Implementing institutional controls, including:
Maintenance of the perimeter fence to restrict site access
Deed restrictions limiting future land use
A local ordinance prohibiting construction of new potable water supply
wells on the landfill, and in certain areas around it (primarily in the
downgradient direction as far south as well nest W-12) to prevent
potential future exposure to landfill constituents via ingestion or dermal
absorption of groundwater affected by the landfill
•	Constructing a soil cover over the two waste disposal areas to further prevent
potential direct contact with the landfill contents. This cover would involve the
following:
Regrading the existing cover to control surface water
Placing an average of 6 inches of additional general fill on top of an
average of 6-inches of existing cover materials (the minimum thickness
of the general fill will be 12 inches)
Placing 6 inches of topsoil on top of the general fill
Vegetating the surface
Long-term care of the landfill cover.
Installing a perimeter gas control system along the northern perimeter and the
southeastern corner of the North Waste Cell to control off-site gas migration in
these areas.
•	Continuing the operation and maintenance of the perimeter gas control system
in the South Waste Cell.
•	Long-term soil gas monitoring.
•	Long-term groundwater monitoring.
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This alternative represents the most cost-effective approach for controlling potential future
health risks and the current hazards identified in the baseline risk assessment, which was
approved by the MDNR. It also meets the applicable closure requirements for this site that
were also approved by the MDNR.
The proposed chemical-specific cleanup criteria for groundwater are the Part 201 generic
residential cleanup criteria. Potential future exposure to landfill constituents in groundwater
would be controlled through the use of a local ordinance that would prohibit construction of
potable water supply wells in the areas affected by the landfill. There are no current off-site
exceedances of arty of the Part 201 groundwater cleanup criteria. The proposed chemical-
specific cleanup criteria for on-site soil are the Part 201 generic industrial cleanup criteria.
Potential future residential exposure to on-site soil will be controlled by the restricted access to
the site.
An important advantage of the soil cover as compared to a low-permeability cover is that the
soil cover will allow the natural biodegradation processes that are breaking down the landfill
constituents to continue at their present rate. Covering the landfill with a less permeable
material will slow the natural degradation processes because it will reduce the supply of
oxygen to waste constituents. The resulting concentrations in groundwater would decrease at
a slower rate, and the extent of the plume might actually increase. Inorganic constituents
such as arsenic are also attenuated under oxidizing conditions through coprecipitation with
iron.
Natural biodegradation is an acceptable remedial action under Part 201 because there is
documented evidence that it is an effective method of on-site treatment of hazardous
substances in the aquifer at this site.
Hydraulic control of groundwater migrating from the site is not recommended because it does
not provide additional risk reduction benefits and because institutional controls would still be
needed.
97
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FOCUSED FEASIBILITY STUDY REPORT
CEREAL CITY LANDFILL
BATTLE CREEK, MICHIGAN
PREPARED FOR
SC HOLDINGS, INC,
ZEELAND, MICHIGAN
PREPARED BY
RMT, INC.
MADISON, WISCONSIN
SEPTEMBER 1995
G	, .
Consulting Hydrogeologist

Linda E. Hicken, P.E.
Senior Project Manager
RMT, Inc. - Madison, Wl
INC.
744 Heaituno Trail • 53717-1934
P.O. Bo* 8923 • 53708-8923
608/831-4444 « 608/831-3334 FAX
m
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SEPTEMBER 1995
CEREAL CITY LANDFILL
FINAL
TABLE OF CONTENTS
Section
Page
4.
5.
INTRODUCTION	
1.1	Background	
1.2	Purpose and Scope
2. EXISTING CONDITIONS	
2.1	Site Setting and Land Use	
2.2	Hydrogeologic Conditions 	
2.3	Source Characterization	
2.4	Nature and Extent of Contamination
2.5	Contaminant Fate and Transport . .
2.6	Baseline Risk Assessment 	
2.7	Landfill Gas Management Systems .
IDENTIFICATION OF ARARs
1
1
3
6
6
7
a
9
12
14
16
23
23
24
3.1	Introduction	
3.2	Part 201 of Act 451
3.3	Chemical-Specific ARARs and TBC Criteria		25
3.4	Action-Specific ARARs and TBC Criteria		29
3.5	Location-Specific ARARs and TBC Criteria 		38
3.6	Identification of Site-Specific ARARs for Remedy Selection 		38
REMEDIAL ACTION OBJECTIVES 	 44
TECHNOLOGY SCREENING	 45
5.1
5.2
5.3
5.4
5.5
5.6
Introduction		45
Presumptive Remedies		45
Institutional Controls		47
Containment and/or Treatment of Landfill Contents		47
Landfill Cover Systems			48
5.5.1	Conventional Cover		51
5.5.2	Soil Cover		54
Groundwater Containment		55
6. DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES		64
6.1	Alternative 1: No Action		67
6.1.1	Description 		67
6.1.2	Effectiveness 		67
6.1.3	Implementability		69
6.1.4	Cost 		69
6.2	Alternative 2: Soil Cover 		69
6.2.1	Description 		69
6.2.2	Effectiveness		70
6.2.3	Implementability		71
6.2.4	Cost 		71
Printed On
Racycted Papar
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TABLE OF CONTENTS
(CONTINUED)
Section	Page
6.3	Alternative 3: Soil Cover with Groundwater Containment 		72
6.3.1	Description 		72
6.3.2	Effectiveness		72
6.3.3	Implementability		73
6.3.4	Cost 		74
6.4	Alternative 4: Conventional Cover 		74
6.4.1	Description 		74
6.4.2	Effectiveness		75
6.4.3	Implementability		75
6.4.4	Cost 		76
6.5	Alternative 5: Conventional Cover with Groundwater Containment 		76
6.5.1	Description 		76
6.5.2	Effectiveness		77
6.5.3	Implementability		77
6.5.4	Cost 		78
7.	COMPARATIVE ANALYSIS OF ALTERNATIVES 		79
7.1	Effectiveness in Protecting the Public Health, Safety, or Welfare or the
Environment		79
7.2	Details About the Alternatives		86
7.3	Estimated Costs		88
7.4	Engineering Implementability, Reliability, and Constructability		88
7.5	Technical Feasibility		91
7.6	Assessment of the Appropriateness of Recycling, Reuse, Waste
Minimization, Waste Biodegradation, Waste Destruction, or Alternative
Technologies		91
7.7	Adverse Environmental Impacts 		91
7.8	Risks Remaining After Implementation of the Remedy		92
7.9	The Extent to Which the Alternatives Attain or Exceed ARARs		93
7.9.1	Chemical-Specific ARARs		93
7.9.2	Action-Specific ARARs	 94
7.9.3	Location-Specific ARARs 	 94
8.	RECOMMENDED REMEDIAL ACTION 		96
9.	REFERENCES	 98
Ust of Table*
Table 3-1	Potential Michigan Chemical-Specific ARARs 		26
Table 3-2	Potential Federal Chemical-Specific ARARs 		28
Table 3-3	Potential Michigan Action-Specific ARARs		30
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TABLE OF CONTENTS
(CONTINUED)
Section	Page
Table 3-4 Potential Federal Action-Specific ARARs		33
Table 3-5 Potential Michigan Location-Specific AFlARs		39
Table 3-6 Potential Federal Location-Specific AFlARs		40
Table 3-7 Proposed Part 201 Groundwater Cleanup Criteria		41
Table 3-8 Proposed Part 201 Soil Clean-Up Criteria for the Cereal City Landfill		43
Table 5-1 Remedial Technologies Suitable for Landfill Contents		49
Table 5-2 Summary of Low-Permeability Cover Options		52
Table 7-1 Summary of Comparison of Remedial Alternatives 		80
Table 7-2 Summary of the Effectiveness of Alternatives #1-#5 in Remediating
Impacts to Groundwater Quality at the Cereal City Landfill 		87
List of Figures
Figure 1-1 Site Locator Map		5
Figure 2-1 Existing Conditions Map: Groundwater Monitoring Wells and Leachate
Head Wells 		17
Figure 2-2 Chemical Concentrations in Groundwater and Leachate Along
Geologic Cross Section A-A', August 1992 		18
Figure 2-3 Water Table Map		19
Figure 2-4 Chemical Concentrations in Groundwater and Leachate, August 1992 ...	20
Figure 2-5 Chemical Concentrations in Groundwater and Leachate Along
Geologic Cross Sections B-B' and C-C\ August 1992 		21
Figure 2-6 Existing Conditions Map: Gas Management Systems		22
Figure 5-1 Configurations of Conventional Cover Options 		58
Figure 5-2 Conventional Final Cover		59
Figure 5-3 North Waste Cell Gas Extraction System for a Conventional Final
Cover		60
Figure 5-4 South Waste Cell Gas Extraction System for a Conventional Final
Cover		61
Figure 5-5 Soil Final Cover		62
Figure 5-6 North Waste Cell Soil Final Cover and Perimeter Gas Migration Control
System 		63
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TABLE OF CONTENTS
(CONTINUED)
Section
List of Appendices
Appendix A Final Cover Options Analysis Technical Memorandum
Appendix B Report of an Evaluation of the Effectiveness of Landfill Covers and
Groundwater Containment in Remediating Groundwater at the Cereal City
Closed Landfill
Appendix C Environmental Response Division Operational Memoranda: #6, Revision 3
(February 4, 1994); #8, Revision 4 (June 5, 1995); #14 (September 23, 1993);
#14 Revision 2 (June 6, 1995); and #15 (September 30, 1993)
Appendix D USEPA Guidance on the Use of Presumptive Remedies: Presumptive
Remedies: Policy and Procedures (OSWER Directive 9355.0-47FS), and
Presumptive Remedy for CERCLA Municipal Landfill Sites (OSWER Directive
9355.0-49FS)
Appendix E Opinions of Probable Cost for Remedial Alternatives #1 through #5
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Section 1
INTRODUCTION
1.1 Background
SC Holdings, Inc. (SCHI), a subsidiary of Waste Management, Inc., is voluntarily undertaking
corrective action at its Cereal City Landfill (CCL) in Battle Creek, Michigan. The landfill is
situated on a 150-acre parcel of property and consists of two unlined waste cells with a
combined fill area of approximately 68 acres (Figure 1-1). The landfill received municipal,
commercial, and industrial solid waste during active operation from 1951 through July 1982. A
closure agreement was approved by the Michigan Department of Natural Resources (MDNR)
in June 1982, and completion of the closure requirements was verified by the MDNR in
April 1983. In August 1995, the Waste Management Division of the MDNR reviewed the
regulatory status of the landfill with regard to the Michigan solid waste rules and confirmed
that the landfill had been closed in accordance with the closure agreement (MDNR, 1995). A
detailed description of the site history was presented in the Phase II Hydrogeologic Study
Workplan (RMT, 1991).
A Phase I Hydrogeologic Study of the site was completed in August 1990. This was an office
study to compile and preliminarily evaluate conditions at the site as of the time of the study.
The findings of the Phase I study (RMT, 1991) formed the basis for scoping the Phase II
investigation, which was completed in March 1992. The purpose of that study, which included
field and laboratory investigative activities, was to investigate the geology and hydrogeology at
and near the site, and to evaluate the nature and extent of potential impacts of volatile organic
compounds (VOCs), metals, and other landfill constituents to soil and groundwater as a result
of past activities at the site. The results of the study were presented in the Phase II
Hydrogeologic Study Report (RMT, 1992), which was approved by the MDNR in a letter dated
July 14, 1992.
Concurrently, at the request of the USEPA Region V, the Preremedial Unit of the MDNR
conducted a Site Screening Inspection (SSI) in August 1990 to evaluate the site for possible
inclusion on the National Priorities List (NPL). The SSI report was released in January 1992
(MDNR, 1992). Because SCHI had agreed to, and was actively undertaking, corrective action
at the site, the MDNR recommended that the site be given a low priority. No further action
had been taken by the USEPA.
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While the Phase II hydrogeologic study generally succeeded in meeting its planned objectives
and significantly improved the understanding of site conditions, some remaining data gaps
were identified that needed to be addressed in order to adequately assess potential risks to
human health and the environment, and to evaluate remedial alternatives. The Phase III
Hydrogeologic Study was subsequently performed to fill these gaps and to allow for the
assessment of risk to human health and the environment. The Phase III Hydrogeologic Study
Report (RMT, 1993a) presented a more complete characterization of on-site source areas and
the nature and extent of associated contamination. It also included a baseline risk
assessment for the Cereal City Landfill that has served as the basis for the preparation of this
feasibility study.
Several issues that have required further evaluation were identified by the MDNR in their
review of the Phase III Hydrogeologic Study Report. These issues included the following:
characterization and assessment of landfill gas emissions; monitoring and control of
subsurface landfill gas at the landfill perimeters; establishment of naturally-occurring
concentrations of arsenic in groundwater at and near the site; and development and
implementation of an interim groundwater monitoring program. The following reports and
documents related to these issues have been prepared by RMT and reviewed by the MDNR;
Landfill Gas Emission Characterization and Assessment Report (RMT, 1993b)
Documentation Report for the Installation, Abandonment, and Reconditioning
of Soil Gas Probes (RMT, 1993c)
Interim Groundwater Monitoring Plan (RMT, 1993d)
•	Background Concentrations of Arsenic in Groundwater Technical
Memorandum (RMT, 1993e)
•	Documentation Report for the Expansion of the Active Landfill Gas Extraction
System (RMT, I993f)
•	Background Concentrations of Selected Metals in Soils (RMT, 1994a)
Follow-up letter, dated May 31, 1994, regarding background concentrations of
arsenic in groundwater (RMT, 1994b)
Quarterly Results of the Interim Groundwater Monitoring Program
(RMT, 1994c)
2
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RMT FEASIBILITY STUDY REPORT
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CEREAL CITY LANDFILL
FINAL
The MDNR's comments on these reports and documents have been addressed and all of the
reports have been approved (RMT, 1994 d and e, and MDNR, 1994 a and b) by the MDNR in
a letter dated July 29, 1994.
The feasibility study (FS) for the site was initially prepared in general accordance with
Rule R299.5513 of the Michigan Administrative Code (MAC) and the Michigan Environmental
Response Act (MERA) (1982, PA 307, as amended), and was submitted to the MDNR in April
1995. With the enactment of the new environmental response law, Part 201 of Act No. 451 of
the Public Acts of 1994, as amended (the Natural Resources and Environmental Protection Act
[NREPA]), the applicable or relevant and appropriate state requirements (AFtARs) have
changed substantially. The most significant changes that affect the remedy selection for this
site are the new soil and groundwater cleanup criteria that are now based on land use, and
the acceptance of institutional controls and natural biodegradation of contaminants in an
aquifer as part of the final remedy. At the request of the agency, RMT sent a letter dated
July 21, 1995, to the MDNR on behalf of SCHI asking them to set aside the April 1995 FS
report and to review this modified report that reflects changes compelled by the new Part 201
rules instead.
1.2 Purpose and Scope
The purpose of this document is to present the results of a focused feasibility study (FS) for
the CCL site. This FS was conducted in general accordance with Rule R299.5513, MAC,
which describes the FS process including the screening of remedial technologies, the
development and screening of remedial alternatives, and a detailed analysis of remedial
alternatives, and Part 201 of Act 451, as amended. The FS evaluated a range of remedial
alternatives for addressing actual or potential releases of site-related constituents to the
environment. The range of remedial alternatives includes a conventional low-permeability
cover, a soil cover, hydraulic containment, and "no action.*
The following reports that have not previously been submitted to the MDNR are included as
appendices to this Feasibility Study:
Final Cover Options Analysis for the Cereal City Landfill (Appendix A)
3
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Report of an Evaluation of the Effectiveness of Landfill Covers and
Groundwater Containment in Remediating Groundwater at the Cereal City
Closed Landfill (Appendix B).
The major tasks that were performed for this FS included the following:
•	Reviewed regulations and other published documents to identify potential
applicable or relevant and appropriate requirements (Section 3)
•	Identified remedial action objectives for exposure pathways of concern
(Section 4)
•	Referenced the presumptive remedy guidance developed by the United States
Environmental Protection Agency (USEPA) for Comprehensive, Environmental,
Response, Compensation, and Liability Act (CERCLA) municipal landfills to
identify potential remedial technologies (Section 5)
Developed and screened practical remedial alternatives (Section 6)
•	Estimated the cost of each remedial alternative (Section 6)
•	Compared the remedial alternatives against each other (Section 7)
•	Evaluated the effect of cover design and groundwater containment on
groundwater quality within and downgradient of the CCL (Appendix B)
Because the number of applicable remedial alternatives for this site is relatively limited, as is
typical for municipal solid waste landfills, this Feasibility Study moves quickly from an initial
screening of remedial technologies to a more focused development and comparative analysis
of a smaller group of practical remedial alternatives using the eight criteria specified under the
administrative rules.
To improve the readability of this report, all subsequent figures, many of which are 24-inch-by-
36-inch drawings, have been placed at the end of the report section in which they are first
referenced.
4
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
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Figure 1-1 Site Locator Map
5
2046.43 0000:CTE:cot0627
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LAKEVIEW WELL
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2046.43
SC HOLDINGS, INC.
SITE LOCATOR MAP
CEREAL CITY CLOSED LANDFILL
CALHOUN CO.. MICHIGAN
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Section 2
EXISTING CONDITIONS
This section describes the existing site conditions with respect to site setting and land use
(Subsection 2.1), hydrogeologic conditions (Subsection 2.2), source characterization
(Subsection 2.3), nature and extent of contamination (Subsection 2.4), contaminant fate and
transport (Subsection 2.5), and the baseline risk assessment (Subsection 2.6), and gives a
description of the landfill gas collection and monitoring systems (Subsection 2.7). A more
detailed description of the first five topics can be found in the Phase III Hydrogeologic Study
Report (RMT, 1993a); a description of the existing gas collection systems can be found in the
Report of the Expansion of the Active Landfill Gas Extraction System (RMT, 1993f).
The locations of the groundwater monitoring wells and leachate head wells are shown on
Figure 2-1.
2.1 Site Setting and Land Use
The CCL is located within the northern city limits of Battle Creek, Michigan, in a residential and
undeveloped area (Figure 2-1). It is approximately 1 mile north-northeast of the Kalamazoo
River which flows into Lake Michigan, approximately 60 miles to the west of the site. The
elevation at the site ranges from approximately 910 feet mean sea level (M.S.L) at the
northern site boundary to approximately 860 feet M.S.L at the southern site boundary.
The terrain in the area adjacent to the site is gently rolling, with riparian wetlands associated
with the Sperry Drain, a Kalamazoo River tributary, located to the west and northwest of the
site.
The 150-acre site contains two refuse fill cells (north and south) totalling approximately
68 acres. The North Waste Cell is gently crowned on top blending into the adjacent land (no
sideslope) on the western half of its north side. Sideslopes approximately 40 to 50 feet high
occur along the eastern half of the north side. Adjacent to the northeast portion of the cell is
a wooded wetland area The eastern and southern portions of the North Waste Cell contain
slopes approximately 15 to 25 feet high. The western slope gently grades to a depressional
borrow area There is also a wooded wetland area located south of the North Waste Cell.
6
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
The South Waste Cell is bounded on its north and east sides by prominent slopes ranging
from approximately 15 to 25 feet in height. The southwest portion of this cell has no
sideslopes and is lower than the adjacent land. Slopes along the western side of the South
Waste Cell range from 0 to 15 feet in height, leveling near the south end. A grassed swale,
which may flow intermittently, runs adjacent to the southeast and east side of the South Waste
Cell and drains toward a wooded wetland northeast of the South Waste Cell.
Annual rainfall averages approximately 34 inches. Eight to 12 inches of groundwater recharge
is estimated for the site (RMT, 1993a).
A detailed discussion of the adjacent land use was presented in the Workplan for a Phase II
Hydrogeologic Study (RMT, 1991), and is summarized briefly here. The CCL is located in an
area of variable land use. The area is dominated by residential and undeveloped lands. The
highest density residential land use occurs to the south and east of the site, with a lesser
density of residences to the west of the site. Undeveloped forested land bounds the site to
the north. The area around the site is serviced by municipal water from Battle Creek and
Bedford and Pennfield Township water supply systems. Private wells within a 0.5-mile radius
of the site in downgradient or sidegradient locations were assessed during a Phase I
hydrogeologic study (RMT, 1991). All of these wells except for one have been connected to
the Battle Creek municipal water supply, and the private wells have been abandoned in
accordance with the Michigan Administrative Rules. The owner of the remaining well could
not be located (the house was abandoned at the time of the study). The Calhoun County
Health Department placed a deed restriction on the property's title.
2.2 Hydrogeologic Conditions
The uppermost geologic stratum beneath the site consists of 40 to 172 feet of sandy outwash
with a discontinuous layer of clay present in some areas (see Figure 2-2). The thick outwash
sands overlie up to 107 feet of silty sandstone and siltstone. The silty sandstone, in turn,
overlies more than 80 feet of shale with occasional sandstone interbeds.
The outwash is composed of fine- to medium-grained sand and silty sand, with an apparently
continuous clay lens in the northern third of the study area. The hydraulic conductivity of the
outwash ranges from 1 x 10"4 to 2 x 10"2 cm/s, with a geometric mean of 3 x 103 cm/s; the
7
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hydraulic conductivity of the underlying sandstone is slightly lower, with a geometric mean of
4 x 10"* cm/s. No laterally continuous low-permeability strata separate the outwash from the
bedrock in the southern two-thirds of the study area.
The water table in the study area is approximately 12 feet below grade at the southern end of
the site, and 67 feet below grade 1,800 feet south of the landfill. Groundwater flow in the
outwash and sandstone over the eastern and central portions of the site is generally to the
southwest, toward the Kalamazoo River (see Figure 2-3). Groundwater along the western
edge of the site in the outwash is deflected to the west, toward Sperry Drain. Groundwater
velocities in the sandy outwash and the sandstone range from approximately 60 to 10 feet per
year, respectively. There is a downward component of flow across most of the study area,
such that flow migrates down through the sandy outwash into the sandstone, as it flows to the
south-southwest. Upward gradients exist within the outwash near Sperry Drain.
2.3 Source Characterization
The extent of waste and the nature and extent of leachate at the site have been investigated
through geophysical methods, soil borings, historical aerial photograph examination, and
measurements of leachate head and chemistry.
Details of historical waste disposal practices at the site are not well documented. The landfill
reportedly accepted municipal, industrial, and commercial solid waste. Based on the results of
the recent investigations, the waste is concentrated in two cells of approximately equal area in
the northern and southern portions of the property. The two waste cells are separated by a
narrow strip of land in which waste was not deposited. The outline of the extent of waste is
shown on Figure 2-1.
The waste covers an area of approximately 68 acres total, between the North and South
Waste Cells. The waste is covered by a sand and gravel layer that varies in thickness from 0
to 10 feet. The waste is between 4 feet thick and 45 feet thick at the edges of the cells, with
an average thickness of 32 feet. The maximum thickness in the northern cell is 45 feet, and
the maximum thickness in the southern cell is 25 feet. The approximate volume of waste in
the northern cell is 1,350,000 cubic yards and in the southern cell is 830,000 cubic yards.
8
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RMT FEASIBILITY STUDY REPORT
SEPTEMBER 1995
CEREAL CITY LANDFILL
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The waste is variably degraded, and consists of sand and gravel, interbedded with common
municipal solid waste materials (packaging and paper, wood chips, plastic sheeting, and glass
and metal).
Leachate heads have been measured in 10 leachate head wells—six in the northern ceil and
four in the southern cell (see Figure 2-1). On the basis of the leachate head measurements,
the logs from soil borings that fully penetrated the landfill, and the water table configuration,
the water table is in contact with landfill waste in the southern portion of the North Waste Cell,
and up to 10 feet of waste is below the water table in the southern portion of the South Waste
Cell.
There is no liner beneath the waste, and no active leachate collection system. There is
leachate head buildup within the landfill, caused by the higher permeability of the landfill cover
(typical measured hydraulic conductivity of 3 x 103 cm/s) as compared to the lower
permeability of the waste (typical measured hydraulic conductivity of 2 x 10"8 cm/s), the
topographic relief, and the sparse vegetation on the landfill surface. Dissipation of the
leachate head within the landfill is hindered by the low bulk hydraulic conductivity of the
waste, compared to the underlying outwash.
Leachate at the site has been found to contain a combination of 17 VOCs, elevated ammonia
and specific conductance, and above background concentrations of metals. VOCs of concern
in the leachate include maximum measured concentrations of vinyl chloride (1 ^g/L), benzene
(6 ^g/L), methylene chloride (170 m9/L). tetrachloroethene (6 ng/L), trichloroethane (13 m9/l).
and tetrahydrofuran (1,600 m9/L). Inorganic constituents of concern in the leachate include
total lead (2,400 ng/L) and total arsenic (470 mS/L). A full characterization of the leachate is
provided in the Phase III Hydrogeologic Study (RMT, 1993a).
2.4 Nature and Extent of Contamination
Groundwater affected by the landfill typically contains elevated concentrations of VOCs,
arsenic, and ammonia The affected area extends up to 1,200 feet downgradient from the
landfill. The area of affected groundwater starts at the water table near the landfill, and
extends into the upper portion of the sandstone downgradient of the site. Landfill constituents
were not detected in the lower portions of the sandstone or in wells in the underlying shale.
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RMT FEASIBILITY STUDY REPORT
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Groundwater from the on-site monitoring wells contained 12 VOCs at quantifiable levels
(concentrations greater than 1 ^g/L). Samples from 9 of 13 on-site downgradient wells and 5
of 14 off-site downgradient wells contained quantifiable levels of VOCs. The areal distribution
of chemicals in groundwater and leachate is shown on Figure 2-4 and in cross section on
Figures 2-2 and 2-5.
The highest concentrations of VOCs detected in 1992 sampling of on-site groundwater were
for chloroethane (up to 92 ptg/L), tetrahydrofuran (up to 120 m9/L), xylenes (up to 87 ^g/L),
and diethyl ether (up to 50 ^g/L). Five of 14 downgradient off-site monitoring wells yielded
samples containing quantifiable concentrations of VOCs. Most of the VOCs detected were
present at concentrations of less than 5 hq/L The highest concentrations were recorded for
tetrahydrofuran (up to 27 ^g/L) and diethyl ether (up to 12 nQ/l).
Vinyl chloride was detected in groundwater from 8 downgradient wells, including two off-site
wells (W-12B and W-12C). The reported concentrations range from 2 ^g/L (at W-14C) to
0.3 hq/L (at OB-1AR). The only detectable off-site concentrations are below the practical
quantitation limits, and are 0.7 /ig/L at W-12C and 0.6 pQ/L at W-12BC. Vinyl chloride has not
been detected in groundwater from any of the off-site water table wells.
Well nests OB-1, W-12, and W-17 lie along a groundwater flow line that intersects the landfill,
and groundwater samples from the well nests exhibit progressively lower VOC concentrations
moving downgradient from the landfill. The maximum downgradient extent of groundwater
that contains VOCs above the Part 201 generic residential cleanup criteria is between well
nests OB-1 and W-12, which are located at the southwestern corner of the site and
approximately 1,200 feet south-southwest of the southwestern corner of the site.
The vertical extent of the aquifer affected by the landfill ranges from the water table beneath
and near the landfill (elevation 850 feet M.S.L) to within underlying sandstone at an elevation
of 730 feet M.S.L Tested parameters other than VOCs that would indicate groundwater
contamination attributable to the landfill have not been detected in the wells screened
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RMT FEASIBILITY STUDY REPORT
SEPTEMBER 1995
CEREAL CITY LANDFILL
FINAL
at the base of the sandstone or at the top of the shale at any of the drilling locations.
In the northern section of the site, which is underlain by the lean clay layer in the sandy outwash,
the clay layer appears to impede the downward migration of contaminants.
Dissolved arsenic concentrations in groundwater samples from the monitoring wells at the landfill
vary from less than 1 Mg/L to 98 j*g/L Samples from 10 of 17 on-site monitoring wells contained
detectable concentrations of arsenic. Arsenic was detected in the off-site wells at a maximum
concentration of 9.8 y.q!L (W-12C). The background concentration of arsenic upgradient of the
site is estimated to be 4.2 fig/L (RMT, 1994b). The significance of the background concentration
of arsenic at this site was greatly diminished by the change in the state groundwater cleanup
criteria from 0.2 ^g/L for a Type C generic industrial cleanup under Act 307 (Environmental
Response Division Operational Memorandum #14, Revision 1), to 50 /ig/L for a generic residential
or industrial cleanup under Part 201 of Act 451 (Environmental Response Division Operational
Memorandum #14, Revision 2).
Groundwater affected by the landfill exhibits elevated ammonia concentrations (up to 280 mg/L).
Groundwater not affected by the landfill shows ammonia of concentrations from less than 0.1 to 3
mg/L Typical ammonia concentrations in groundwater at the site not affected by landfill leachate
are less than 1 mg/L Elevated ammonia concentrations in groundwater coincide with a zone of
chemically reducing conditions typically found around municipal landfills. At the CCL ammonia
concentrations greater than 3 mg/L are a good indicator parameter for identifying areas where the
groundwater is impacted by the landfill. Elevated ammonia concentrations in the wells screened
in the sandstone extend out to well nest W-12, which is 1,200 feet downgradient from the landfill.
In summary, groundwater containing dissolved leachate constituents typically contains elevated
concentrations of arsenic and ammonia, as well as VOCs. In a horizontal direction, groundwater
affected by the landfill extends up to 1,200 feet from the landfill waste boundary. In a vertical
direction, the area of impacted groundwater starts at the water table near the landfill, and extends
into the upper portion of the sandstone downgradient of the site. Landfill constituents were not
detected in the lower portion of the sandstone or in wells in the underlying shale.
Groundwater has been sampled and analyzed on a quarterly schedule subsequent to the
completion of the Phase III Hydrogeologic Study in accordance with the Interim Groundwater
Monitoring Plan (RMT, 1993d). The results of the monitoring activities, which are submitted to the
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
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MDNR on a regular basis, generally indicate a continued trend of decreasing concentrations of
VOCs, in both the on-site and off-site monitoring wells. This trend is evident from an examination
of sampling data from 1981 to 1994, and is discussed in more detail in Appendix B.
2.S Contaminant Fate and Transport
Leachate generated within the landfill has affected groundwater quality beneath the landfill and, to
a lesser degree, groundwater downgradient of the site. On-site concentrations of arsenic and
benzene are in excess of the generic residential and industrial cleanup criteria Surface water
runoff and associated sediment from the site contains no VOCs or metals at concentrations in
excess of the Part 201 generic residential cleanup criteria. Furthermore, direct surface water and
sediment migration from the site would not be expected to be of concern because precipitation
infiltrates the sandy soil readily, and there is no significant potential pathway for contaminant
migration from the site for these media. The maximum on-site concentrations of metals and
volatile organic compounds in soil are well below the Part 201 generic industrial cleanup criteria.
The potential for the migration of landfill leachate into groundwater exists at the site. In
August 1992, up to 10 feet of leachate head were observed in leachate head wells. Because the
waste cells were not constructed with impermeable liners, leachate is migrating from the base of
the landfill to the water table and entering the groundwater flow system. In addition, a portion of
the waste in both cells is currently below the water table. However, the relatively low permeability
of the waste impedes the flow of leachate into the aquifer.
Groundwater beneath the western side of the North Waste Cell flows to the west due to
groundwater discharging to the Sperry Drain. Groundwater flowing toward the drain contains
dissolved landfill leachate constituents, based on groundwater samples from well nest W-14.
Groundwater flow beneath the eastern side of the North Waste Cell and beneath the South Waste
Cell is to the southwest, toward the Kalamazoo River. Dissolved parameters indicating landfill
impacts to groundwater have been detected in well nest OB-1. Groundwater at well nest W-12
has not been affected by the landfill.
Concentrations of landfill indicator constituents, including VOCs, metals, and other inorganic
parameters, decrease as groundwater flows downgradient from the landfill, both to the west
toward Sperry Drain, and to the southwest toward well nest W-12.
Groundwater above the lean clay layer flowing beneath the western edge of the North Waste Cell
discharges to Sperry Drain. Stream sediment samples and surface water samples from the Sperry
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Drain collected and analyzed by RMT (RMT, 1992) and the MDNR (MDNR, 1992) did not contain
detectable levels of landfill leachate constituents. Based on observed hydraulic gradients and
hydraulic conductivities, it was estimated that a total of approximately 4 gallons/minute of
groundwater would enter the entire reach of Sperry Drain from the landfill site (RMT, 1993a).
Groundwater flowing in outwash and sandstone beneath the landfill is moving at an average linear
velocity of approximately 60 and 10 ft/yr, respectively. Variations in the hydraulic conductivity in
the aquifer cause mixing, or dispersion, of contaminated and unaffected groundwater in the
aquifer, and lower contaminant concentrations.
Chemical and biological processes are effectively reducing the concentrations of many of the
landfill contaminants. This effect is evident by the differential removal of readily degraded
constituents such as xylenes and ethylbenzene at downgradient locations, while more
conservative landfill indicators such as ammonia, tetrahydrofuran, and chloroethane persist much
further downgradient. Further evidence of attenuation of solutes in the leading edge of the plume
is that no indicator constituents were detected in well nest W-12, even though the leading edge of
the plume likely could have reached 1,200 feet downgradient from the landfill in the time since the
landfill began operation, based on the calculated average linear velocity for groundwater at the
site.
The basic processes of attenuation and biogeochemical degradation are discussed in the Report
of an Evaluation of the Effectiveness of Landfill Covers and Groundwater Containment in
Remediating Groundwater of the Cereal City Landfill (Appendix B). This report describes the
biogeochemical processes that are reducing the concentrations and the mass of leachate
constituents in groundwater, and supports the hypothesis that the arsenic in groundwater is being
removed from solution by coprecipitation with iron. The study also concludes that the VOCs are
being adsorbed onto free organic carbon in the aquifer and are being degraded abiotically and
biologically, and that ammonia is undergoing nitrification as chemically reduced groundwater from
near the landfill is mixed with oxygenated water farther from the landfill.
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The groundwater pathway for potential human exposure has been eliminated since municipal
potable water supply piping was extended to homes in the immediate area of the site.
Residences within 1/2 mile downgradient from the landfill have also been connected to city water
supplies. However, downgradient landowners are not presently precluded from drilling new water
supply wells in the affected area in the future. The implementation of the institutional controls
would be necessary to eliminate a future off-site pathway for human exposure to affected
groundwater.
2.6 Baseline Risk Assessment
A baseline risk assessment (RMT, 1993a) was performed to characterize the nature and estimate
the magnitude of potential environmental and public health effects associated with the
constituents of concern identified at the CCL The baseline risk assessment was based on the
information contained in the Phase II and Phase III Hydrogeologic Studies (RMT, 1992 and 1993a)
and the Site Investigation Study (MDNR, 1992), and considered potential adverse health effects
that could result under current and future land use. The baseline risk assessment was conducted
in 1993 when the MDNR's acceptable risk level for evaluating estimated site-related risks was one
in one million (1 x 10"9) excess upperbound lifetime cancer risk. Even though the MDNR's
acceptable risk level under Section 20120a(4) of Part 201 of Act 451 was increased to one in one
hundred thousand (1 x 10 s), the baseline risk assessment was not revised because the new
acceptable risk level is less conservative and because the overall conclusion of the baseline risk
assessment is unchanged. Without institutional controls prohibiting water supply wells directly
downgradient of the landfill, a resident adjacent to the southwestern corner of the landfill could
install a water supply well within the area of groundwater affected by the landfill. This resident
could potentially ingest landfill constituents at concentrations above the current MDNR acceptable
risk level.
For purposes of the baseline risk assessment, the landfill was assumed to be at a steady-state
condition, even though the concentrations of constituents are expected to decrease over time due
to the gradual reduction of source material via biodegradation and venting through the landfill
cover.
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Under current land use, the only completed exposure pathway is for site workers who may be
exposed to constituents of concern in affected surface soil during routine site maintenance which
occurs approximately once per month. Because the site is fenced, potential receptors are limited
to site workers. Although the groundwater pathway is affected, it is not complete, because private
water supply wells are no longer in use in the area of affected groundwater.
Under current land use conditions, the total estimated risk for a site worker under Reasonable
Maximum Exposure (RME) assumptions was 3 x 107, or three in ten million additional cancer
occurrences in a 70-year lifetime, which is an order of magnitude less than the then-current
1x10"" MDNR acceptable risk level. The estimated site hazard index under RME assumptions is
0.02, which is 50 times less than 1.0, which is considered to be the level of regulatory concern.
Under future land use, the site worker exposure was expected to be the same as under current
land use. In addition, the future land use scenario included a hypothetical resident who owns a
home directfy adjacent and downgradient to the landfill boundary, and whose water supply well is
screened in the outwash or sandstone aquifers in the absence of regulatory controls on
groundwater use. This hypothetical future nearby resident serves as the RME receptor.
The total estimated risk for the hypothetical resident under future land use conditions under RME
assumptions is 3 x 10 3, which is above the then-current 1x10"® MDNR acceptable risk level. This
risk is primarily associated with the ingestion and dermal absorption of dissolved constituents in
groundwater over a 70-year lifetime, specifically arsenic, and to a lesser extent, vinyl chloride and
benzene. The estimated total site hazard index for the RME receptor is due to the ingestion of
arsenic (hazard index=10) and ammonia (hazard index=8) in groundwater. The total hazard
index is 19 times higher than 1.0, the USEPA's and the MDNR's level of concern.
The estimated excess upperbound lifetime cancer risks and hazard indices for current and future
land use were summarized as follows:
Current Land Use
Estimated
Risk
Estimated
Hazard
Site Worker -	inhalation of soil
-	dermal absorption from soil
-	incidental ingestion of soil
Total
2	x 107
3	x 10*
6 x 1041
3 x 10"'
0.00005
0.006
0.01
0.02
15
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PMT FEASIBILITY STUDY REPORT
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Future Land Use
Site Worker - inhalation of soil
- dermal absorption from soil
incidental ingestion of soil
Total
2	x 107
3	x 10'8
0.00005
0.006
0.01
6 x 10
3 x 10-7
!-«
0.02
Resident
ingestion of VOCs and
nonvolatile chemicals, with
3 x 103
19
inhalation and dermal
absorption of VOCs in
groundwater
dermal absorption of
nonvolatile chemicals in
groundwater
6 x 10"6
0.05
Site Total
3 x 103
19
The results of the risk assessment indicate remediation should be focused on the groundwater
pathway.
The risk and hazard estimates summarized above are likely overestimated due to the conservative
assumptions required for RME in Superfund baseline risk assessments.
2.7 Landfill Gas Management Systems
Passive gas vents were installed in both waste cells in 1981. The locations of the gas extraction
wells, gas monitoring probes, and passive gas vents are shown on Figure 2-6. An active gas
extraction system was installed along the southwestern perimeter of the South Waste Cell in 1981,
and was upgraded in 1993 by adding more extraction wells and monitoring probes near the
residences along the southern and western borders of the South Waste Cell. The active gas
extraction system consists of extraction wells, interconnecting piping, a condensate collection
tank, a blower, a flame arrester, and a utility flare. The flare is not lit because the quality of the
collected gas is not suitable for safely sustaining combustion. Instead, the gas is vented to the
atmosphere from an elevated stack next to the blower building. There are gas probes along the
perimeters of both cells that are monitored once each quarter.
Off-site landfill gas migration is occurring along the northern boundary and southeastern corner of
the North Waste Cell, but is not present in areas that are close to residences. This is a potential
concern that is addressed in each of the remedial alternatives considered.
16
2046.43 0000:ffrE.c*re0627
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Figure 2-1 Existing Conditions Map: Groundwater Monitoring Wells and Leachate Head Wells
17
2046 *3 0000.FmE:cm0627
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Figure 2-2 Chemical Concentrations in Groundwater and Leachate Along Geologic Cross
Section A-A\ August 1992
18
20*6 43 0000:ffTE.c«r»0627
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Figure 2-3 Water Table Map
19
2046.49 0000:CTE:c«*0«27
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CFTY LANDFILL	FINAL
Figure 2-4 Chemical Concentrations in Groundwater and Leachate, August 1992
20
JOW.43 0000;RTF-C*f *0827
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Figure 2-5 Chemical Concentrations in Groundwater and Leachate Along Geologic Cross
Sections B-B' and C-C", August 1992
21
204S 43 0000 ATE c»rtOej7
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Section 3
IDENTIFICATION OF ARARs
3.1 Introduction
In accordance with the Michigan Natural Resources and Environmental Protection Act (NREPA)
(Act No. 451 of the Public Acts of 1994, as amended), Part 201, "Environmental Response," and
the National Oil and Hazardous Substances Pollution Control Plan (NCP), the remedial action
selected for the CCL site must comply with federal and state environmental laws that are either
applicable or relevant and appropriate requirements (ARARs). The state requirements for
selecting and implementing environmental response activities are set forth in Sections 20118
through 20120d of Part 201 of Act 451. Guidance for assessing federal ARARs is contained in the
USEPA's manuals entitled 'CERCL^ Compliance with Other Laws' (USEPA, 1988), and "CERCUV
Compliance with Other Laws Manual Part II: Clean Air Act and Other Environmental Statutes and
State Requirements" (USEPA, 1989b).
In order to be considered as an ARAR, a requirement must be applicable or relevant and
appropriate. As defined in the NCP, 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 CERCIA site" (40 CFR § 300.5)(1991). 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 CERCLA site, address problems or situations sufficiently
similar to those encountered at the CERCLA site that their use is well suited to the particular site'
(40 CFR § 3O0.5)(1991).
Another category of criteria that may affect the selection of a remedy for a site is the To Be
Considered* (TBC) criteria. TBC criteria are guidelines or advisories that are issued by the federal
or state government, but which have not been promulgated and are not legally binding. These
guidelines, however, may be used to ensure protection of public health and the environment if
they are not superseded by ARARs. If there is not an ARAR that addresses a specific condition at
a site, the TBC criteria can be used to establish remedial guidelines or targets. Even when TBC
criteria are used, the requirements imposed on remedy selection, including cost-effectiveness, still
apply (55 Fed. Reg. 8745, March 8, 1990).
23	204« 43 0000:OTE.C*r«0627
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RMT FEASIBILITY STUDY REPORT
SEPTEMBER 1995
CEREAL CITY LANDFILL
FINAL
Evaluation of remedial alternatives needs to consider the following three categories of ARARs and
TBC criteria: chemical-specific, action-specific, and location-specific. These categories are not
always mutually exclusive and often overlap to some degree. The chemical-specific ARARs/TBC
criteria are numeric requirements that are typically health-based criteria using a standard set of
exposure and toxicity assumptions. The action-specific ARARs/TBC criteria are technology- or
activity-based requirements or limitations. The location-specific ARARs/TBC criteria are
requirements or limitations given the physical setting of the site. The tables referenced in
Subsections 3.3, 3.4, and 3.5 that list the potential ARARs and TBC criteria for the CCL were
presented to the MDNR in preliminary form prior to the promulgation of Act 451 (RMT, I993g).
3.2 Part 201 of Act 4S1
Sections 20118 through 20120d of Part 201 of Act 451 contain the state requirements for selection
and implementation of response activities. The MDNR Environmental Response Division (ERD)
operational memoranda, along with portions of the administrative rules promulgated for the former
Act 307, provide additional guidance.
Section 20118 of Part 201 describes the criteria that the MDNR may consider in evaluating
whether a proposed remedial action is protective of public health, safety, or welfare, or the
environment. Specifically, Section 20118(2)(b) requires that the remedial action 'attain a degree of
cleanup and control of hazardous substances that complies with all applicable or relevant and
appropriate requirements, rules, criteria, limitations, and standards of state and federal
environmental law." This requirement is expanded upon in Section 20118(5), which references
rules R299.5705(5) and R229.5705(6), Michigan Administrative Code (MAC), as criteria for
assessing whether a remedial action attains the necessary degree of cleanup and control of
hazardous substances. Rule R299.5705(5) requires that the horizontal and vertical extent of
hazardous substance concentrations in an aquifer above the higher of either the concentration
allowed by R299.5707 or the concentration allowed by R299.5709 shall not increase after the
initiation of remedial actions to address an aquifer. ..." Rule R299.5705(6) states that 'all remedial
actions which address the remediation of an aquifer shall provide for removal of the hazardous
substance or substances from the aquifer, either through active remediation or as a result of
naturally occurring biological or chemical processes which can be documented to occur at the
site'.
R299.5705(6) is particularly relevant at the CCL site because the groundwater quality data support
the occurrence of a significant degree of natural biodegradation. More discussion of the site-
specific conditions and of remedial alternatives that incorporate natural biodegradation are
24
2046 43 0000:RrE c««06Z7
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TABLE 3-1
POTENTIAL MICHIGAN CHEMICAL-SPECIFIC ARARs
CEREAL CITY LANDFILL
page 1 of 2
Pathway
Requirement
Prerequisite(s)
Citation
Comments
Ambient air
Hazardous substance concentrations
must not produce any emissions
which result in a violation of the
provisions of the parts of Act 451 that
were formerly Act 348.
Type C degree of
cleanup is appropriate
for site.
R299.5715, Michigan
Administrative Code
(MAC)
Relevant and
appropriate.
Requires site to meet
emission standards
listed in Part 55 of Act
451.

Air permit required.
New or modified
process which emits
Toxic Air Contaminant
(TAC).
R336.1201, MAC
Applicable

TAC must not exceed standards set
in Part 2 of Act 451, formerly Act 348,
Rule 230, MAC.

R336.1230, MAC
Applicable if an air
permit is required.

VOCs must stay below emission rates
set in Part 7 of Act 451, formerly
Act 348, Rule 702, MAC.
New source of VOCs
R336.1702, MAC
Applicable if an air
permit is required.
Groundwater
Hazardous substance concentrations
in the aquifer at the downgradient site
boundary cannot exceed the generic
residential groundwater cleanup
criteria.
Potential receptors are
residents who may
ingest groundwater
affected by the landfill.
ERD Operational
Memorandum #8,
Revision 4, June 5, 1995.
Health-based drinking
water values for
groundwater.
Applicable to existing
and potential future
potable water supply
wells downgradient of
the landfill.
2046 42 OOOO.flTE.c«r«062? t2
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TABLE 3-1 (CONTINUED) page 2 of 2
POTENTIAL MICHIGAN CHEMICAL-SPECIFIC ARARs
CEREAL CITY LANDFILL
Pathway
Requirement
Prerequisite^)
Citation
Comments
Groundwater
(continued)
Hazardous substance concentrations
in the aquifer at the site cannot
exceed the generic industrial
groundwater cleanup criteria.
Protective of workers
drinking water from an
on-site groundwater
source.
ERD Operational
Memorandum #14,
Revision 2, June 6, 1995.
Health-based drinking
water values for
groundwater.
Not applicable because
groundwater is not used
as an on-site source of
drinking water.
On-Site soil
Hazardous substance concentrations
in on-site soil cannot exceed the
generic industrial cleanup criteria.
Current and future site
land use is industrial.
ERD Operational
Memorandum #14,
Revision 2, June 6, 1995.
Direct contact values for
industrial land use.
Applicable for on-site
soil.
Off-Site soil
Hazardous substance concentrations
in soil on residential property cannot
exceed the generic residential
cleanup criteria.
Off-site residential
properties must be
affected by site-related
constituents.
ERD Operational
Memorandum #8,
Revision 4, June 5, 1995.
Direct contact values for
residential land use.
Not applicable because
off-site soil has not
been affected by landfill
constituents.
204a 42 0000 RTE c«r«0627 (2
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TABLE 3-2
POTENTIAL FEDERAL CHEMICAL-SPECIFIC ARARs
CEREAL CITY LANDFILL
p 1 ot t
| Pathway
noqiriramem
Prereqii*he(a)
Citation
Comments
I Groundwater
Sale Drinking Water Act (SDWA) Maximum
Contaminant Levels (MCLsj for 75
compounds, radioactivity, rmcrobacteria,
and turbidity, which are enforceable for
public drinking water systems.
Puttie water systems defined as
piped water serving at least 25
persons.
40 CFR 141.11 through 141.16
Relevant and appropriate under
current land use conditions (i e ,
the groundwater is not used lor
drinking purposes), and under
future land use lor groundwater
used for drinking purposes.

SDWA MCL Goals lor 75 compounds,
radioactivity, mtaotoactana, and turbidity,

40 CFR 141.50 through 141.51
To be considered. MCL goals are
nonenforceable lor public drinking
water systems

Ammonia in groundwater must not exceed
30 mg/L

•Drinking Water Regulations and Health
Advisories," USEPA, May 1994
To be considered. There are no
applicable drinking water criteria.
904S 49 QOQQflTf mmN>' O
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Michigan's generic residential soil and groundwater cleanup criteria are contained in the ERD
Operational Memorandum #8, Revision 4, dated June 5, 1995. The state's generic industrial
soil and groundwater cleanup criteria are contained in ERD Operational Memorandum #14,
Revision 2, dated June 6, 1995. These documents are included in Appendix C. In general,
the federal groundwater criteria are the maximum contaminant levels (MCLs) in the Safe
Drinking Water Act, 40 CFR 141.11 through 141.16.
There is no Michigan cleanup criterion for ammonia in groundwater nor are there primary or
secondary federal drinking water standards for ammonia. The only published criteria for
ammonia in groundwater is from the USEPA Office of Water 'Drinking Water Regulations and
Health Advisories' (USEPA, May 1994) which lists a draft health advisory of 30 mg/L as N (or
31.6 mg/L as NHJ. The draft health advisory is based on the USEPA report 'Drinking Water
Health Advisory for Ammonia,' which concludes that "...ammonia at low concentration, per se,
is not very toxic" (USEPA, 1991), and goes on to recommend that the taste and odor level of
34 mg/L as N be used as a guide for the lifetime health advisory. The highest measured
concentration of ammonia in groundwater at the CCL was 280 mg/L as N (at well OB-1AR in
October 1991). Table 3-2 lists a chemical-specific TBC for ammonia in groundwater based on
the USEPA health advisory.
3.4 Actlon-Spectfic ARARs and TBC Criteria
The action-specific AFlARs and TBC criteria are determined by the specific activities included
in the remedial alternatives being considered. Tables 3-3 and 3-4 list the potential action-
specific ARARs and TBC criteria for the CCL, with Table 3-3 listing the Michigan requirements
and Table 3-4 listing the federal requirements. The most significant of these criteria as
pertaining to the remedy selection for CCL are the state requirements for the collection of
landfill gas and the federal requirements for discharge of groundwater extracted from the
aquifer. The MDNR has determined that Part 115 of Act 451, formerly Act 641 is not an ARAR
for this site because the CCL was closed in 1983 in accordance with the closure agreement
for the site (MDNR, 1995). The MDNR has stated that Part 115 is a TBC for the CCL
29
2040.43 OOOO FTE c*raOB27
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—1	¦ ¦¦ 1
TABLE 3-3
POTENTIAL MICHIGAN ACTION-SPECIFIC ARARa
CEREAL CITY LANDFILL
p. 1 of 3
Action
Requirement
Prerequisite(s)
Citation
Comments
Final cover
Final cover shall be a minimum of
2 feet of soil compacted to not less
than 90 percent of maximum dry
density. Soil classification of ML,
SC, Cl_ or CH is required.
Applies to
existing Type II
Landfills
Solid Waste Management Act,
Pan 115 of Act 451 (formerly
Act 641), R299.4305, MAC
To be considered.

Final cover should consist of:
6 inches of topsoil
2 feet of clay (10' cm/s)
Applies to
existing Type II
landfills closed
after October 9,
1993.
Part 115 of Act 451,
R299.4425, MAC
To be considered.

• The slope of the final cover
should be 4 percent
minimum and 25 percent
maximum




Final cover should consist of:
•	6 inches of topsoil
•	Erosion protection, including a
drainage layer
Applies to new
Type II landfills
closed after
October 9,
1993.
Part 115 of Act 451,
R299.4425, MAC
To be considered.

• Geomembrane composite, the
lower soil component
consisting of:




- Soil (10 s cm/s) or
bentonite geocomposite
liner (GCL) underlain by soil



2046 42 0000 RTE c«r«062/ U
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TABLE 3-3 (CONTINUED)
POTENTIAL MICHIGAN ACTION-SPECIFIC ARARs
CEREAL CITY LANDFILL
p. 2 of 3
Action ^ •
Requirement
Prerequisite(s)
Citation
Comments
Closure and
post-closure
care
Final cover should be inspected
and maintained to prevent erosion
and ensure vegetative growth.

Part 115 of Act 451,
R299.4316, MAC
To be considered.

Final cover should be maintained
throughout post-closure period (30
years). Final cover depths should
be maintained. Monitor the
groundwater and gas systems
following closure.

Part 115 of Act 451,
R299.4449, MAC
To be considered.
Groundwater
Groundwater monitoring required
after closure of the landfill.

Part 115 of Act 451,
R299.4315, MAC
To be considered.
monitoring
Groundwater quality must not
exceed standards described in 40
CFR 257 (Appendix 1) at the solid
waste boundary.

Part 115 of Act 451,
R299.4306, MAC
To be considered.

Groundwater monitoring required
throughout post-closure period;
standards include 40 CFR 258
(Appendix 1) constituents.

Part 115 of Act 451,
R299.4440, MAC
To be considered.
Direct
discharge of
treatment
system
effluent to the
surface
Entities proposing discharge of
wastewater to the surface of the
state must apply for a NPDES
wastewater discharge permit.
Surface
discharge of
treated effluent
within state
Michigan Water Resources
Commission Act, Part 31 of
Act 451 (formerly Act 245),
General Rules Part 21 and
323.6b
Relevant and appropriate if
the groundwater is treated
and the effluent is discharged
to the surface of the landfill as
part of the selected remedy.
2046 42 0000 RTE c#f«0627 t2
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o
TABLE 3-3 (CONTINUED) p. 3 of 3
POTENTIAL MICHIGAN ACTION-SPECIFIC ARARs
CEREAL CITY LANDFILL
Action
Requirement
Prerequisite(s)
Citation
Comments
Gas
collection
Methane concentration < 25% of
LEL in facility structures.
Methane concentration < LEL at
property boundary.
Implement monitoring.
In event of exceedance, implement
remediation plan. Install active gas
collection system if necessary.
Type II Landfill
Part 115 of Act 451,
R299.4433, MAC
Applicable
Surface water
control
Landfills must prevent discharge of
pollutants that violate the Clean
Water Act, NPDES area or
statewide water quality plans, or
Part 31 of Act 451 (formerly
Act 245).
Contaminants
released from a
landfill
Part 115 of Act 451,
R299.4436, MAC
Relevant and appropriate if
discharges of contaminants
occurred during remediation
and reached surface water
bodies.
2046 42 OOOO.RTE.c«r*Oe?r C2
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TABLE 1-4

p t of 5

POTENTIAL FEDERAL ACTIONSPtCIFtC ARARa
CEREAL CITY LANOfILL


A0O009
R#qutrafr*n(
Pca>*qu*sft* (i)
CAadon
Coftwnant*
R CotuolKialton ot
Davatop tugibva and odor amission control plan lor (hit action V asialmg
sita plan is inadaquala

CAA Saction 101 * and
40 CFR 52*
Ralavant and appropriata rt waatas af« conaolidatad as pari
of tia aalactad ramady Odor ragulahona ara intandad to
limit nuisanca condttona from air pollution amissions
FugArva amission controls ara a faatura ot tha atata
implamantabon plan usad to achiava/maintain tha ambiant
air quality standards for particulate mattar.

Air •mission raqulramants

40 Cf R 521 and
40 CFR 611
Rslavant and appropriate Saa discuaalon undar Oaa
Coftaction J
Surtic* wain
control
Pravant run-on. and control and collact runoff from landfills (24-hour, 25-
yaar storm)
Land basad ftoraga or disposal
40 CFR 264 2S(c)(d)
40 CFR 264 273(c)(d)
40 CFR 2*4 301(c)(4
Ralavant and appropriata if waatas ara consolidatad as part |
of V>a aalactad ramady and mcluda on-slta land basad II
ftoraga or diaposal 1
Gu coNact»on
Proposed standards tor control ot amtsalons ol volatila organic*. Claan
Ah Act amandmant

*2 FR 3746 (draft
Fabruary 5, 1967)
To ba conaldatad This is a proposad rula ¦ tha j
raqulramant la finaluad in rta propoaad form, it may ba |
ralavant and appropriata to soma of tha ramadial action* at !
municipal landfill sitaa Tha propoaad atandard would 1
knpoaa raat/ictiona on RCRA traatmant. ftoraga. and 1
diaposal lacilitias that would limit tha aMowabla amissions f
of volatila organic* ftom thaaa faclWta* |

Dasign systam lo provlda odor-fraa oparation.

CAA Saction 101* and
40 CFH 52*
Ralavant and appropriata If gas coMaclion is pari of tha |
aalactad ramatfy |

Fita an Air Pollution Emlaaion Noflca (APE^ **h stata to incJuda
astimation of amiaslon rata* tor aach pollutant axpactad

40 CFR 52*
Ralavant and appropriata 1

Includa with tha klad APEN tha following
•	Modalad impact analysis ot tourca amissions
•	A Baft AvaMabla Control Tachnology (BACT) raviaw for tha
aourca oparation
This addttonal work and Informal Ion U
normally appHcabla to sourcas maating tha
'mato** crUarla and/or to sourcf* proposad
foi nonattaii- -it araas
40 Cf ft 52*
Ralavant and appropriata

Pradtct total anvttiont of volaltla organic compounds (VOCi) to
damonstrala *>al amission* do not axcaad 490 Ib/hr. 3.000 lb/day.
10 gal/day. or aMowabla amission lavaia from similar aourca* using
Raaaonably Availabla Control Tachnology (RACT)
Sourca oparation mutt ba in an ozona
nonattainmant araa
40 CFR 521
Ralavant and appropriata
704« 42 0000 KTE «.ot0*2' U
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o
TABLE 3-4 (CONTINUEO)
p 2 ol 5
POTENTIAL FEOERAL ACTION-SPECIFIC ARAB*
CEREAL CITY LANOf ILL
Action*
Requirement
PreroquMM*)
rHartnn
Com/TMMK*
Gas coHecttcn
(continued)
Verity through emission astimates and dispersion modeling that
hydrogen aulhda emissions do ool craata an ambient concentration
greater than oi aqual to 0 10 ppm.

40 CFR 61*
Relevant and appiopriata

Verity that amissions ol marcury, vinyl chloride, and benzene do not
aaceed leval* ax pad ad from tourcet In compliance with huardoua air
pollution ragulations

40 CFR 61*
Relevant and appiopnata
I Duect discharge
oi treatment
systam effluant
Applicabla ladaiai water quality criteria lor tha protaction of aquatic life
mutt be compliad with
Suiiaca discharge of traatad effluant to
walars ot tha United States
SO FR 30764
(July 29. 1965)
Applicabla if groundwater i* traatad and lha effluant it
dttchargad to surface watar* a* part of tha salecled
remedy

Fadaral wator quality stand aid* mutt ba mat undar tha Claan Water Act
(CWA)

40 CFR 122 44 »nd
Stat* regulation*
approvad unda* 40 CRF
131
Relevant and appropriate. V ftata rtguMiont ara mor#
stringent than federal watar quality standard*, the stata 1
standarda wW be applicable to direct discharge lha Stata [
ha* authority undar 40 CFR 131 to implemant diract 1
discharge lequkamentt within tha state, and should ba [
contacted on a caae-bycase bast* when direct dischargat 1
are contamplated [

Tha discharge muat ba constatent with tha requirement of a Water
Quality Managamant Plan approved by EPA under Section 206(b) ol tha
CWA.

CWA Section 206(b)
Relevant and appropriala Discharge must comply with I
subetantiva. but not administrative. raquiramanis of lha I
M#ntgam*m Pi#n. [

Baat available technology (BAT): Use ot BAT economfcafty achievable la
itqukad to contool toxic and nonconvanOonal poMutanta Use ot baat
conventionel poNufent control technology (BCT) la required to control
conventional poftutant* Taohnology-bMad HmlUttona may ba
determined on a caaa by-caae beat*

40 CFR 122 44(a)
Applicable Permitting and reporting requirements will ba [
applicable only 1 the effluent Is discharged at an oft site I
location. The permitting authority should be contacted on 1
• c ate-by-caae baais to determine effluent standards I

Discharge limitation* muat ba aatahWahart lor aH toxic poNuUnte tiat era
of may ba dtacharged at levels greater than thosa that can ba achieved
by technoJoffy-bastd standards

40 CFR 122.44(c)
Rslsvnl and appropriate. Exact limitations ara bated on 1
review of the proposed treatment system and racaKring |
water characteristics, and are usually determined on a J
case-by-case be*i*. The permitting authority *houid ba 1
contacted to d at ermine effluent limitation* |
304*42 0000 *11 t>iiOM> O
I
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TABLE 14 (CONTINUED)	p 3 ol 5
POTtNUAL fCOCHAL ACTION SPCCIfIC A HA Ha
CEREAL CITY LANDFILL
Aetton*
OtyifMiw<
Preraqu*s*e(s)
CMon
Comments fl
Oiitct diich«ig«
ol trsatment
system effluent
(continue^
Monitoring requirements Discharger mutt be monitored to ensure
compliance Oischarger will monitor
« Tha mm ol itch pollutant discharged
•	Th# volume of sffluenl discharged
•	The frequency ol discharge and other meesursmsnts as
appropriate

40 CFR 122 44(0
Applicable These requirement* aie generally incorporated
Into perm**, which are not required for on site discharges
The substantive requirements are applicable, however, in
ft at vsrtfiabJe avtdsncs must bs oftarad thai the discharge
standards are being met The permitting authority should
be contacted to determine monitoring and operational |
requirements fl
Approved test methods tor waste constituents to be monitored muil be
followed Detailed requirements tor analytical procedure* end quality
control* ere provided.
Permit application Information mutt be submitted, including e description
ol activities, a listing ol environmental permits, etc
Monitor end report results as required by permit (at laast annually)

40 CFR 122 21
40 CFR 122 44(i)
Relevant and appropriate H
Comply with addition el permR condWone such as:
Duty to mitigate any adverse effects o1 any discharge
• Proper operation and maintenance 01 treatment systems

40 CFR 122 4t(f)
Relevant and appropriate |
Develop and Implement a Bast Management Practices (BMP) program
and Incorporate in the NPOES per ml to prevent tie release ol tonic
constituent* to surface waters.
The BMP program must:
•	Establish specific procedures loi the control ol toxic and
hazardous pottutant spills
•	Include a prediction of direction, rate of flow, and total quantity
of toxic pollutants where experience Indicates s reasonable
potential tor equipment failure
•	Ensure proper management ol solid and haiardoue waste In
accordance wfth regulations promulgated under RCRA

40 CFR 123 100
40 CFR 125 104
Applicable. Theee Issues ere determined on a case-by- I
case baels by the NPOES permitting authority for any D
proposed surface discharge ol treated wastewater |
Although e CERCLA site remediation Is not required to 1
obtain an NPDES permit for orvslte discharges to surface I
waters, the substantive requirements ol the NPDES permit h
program must be met by the remediation action if possible I
The permitting authority should be consulted on a case-by- |
cut bull Is dtUrmlnt BMP ttqulrtminU H
70«« 42 0000 CTE	O
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o
TABIC *-4 (COHT1NUCO)	p 4 of 5
POTENTIAL FEDERAL ACTtOM-SPCCIftC ARARa
CEREAL CITY LAMOf H L |
Aettotw

PntaquiaMal
amon
Comma*** [
0«r*ct diichtrgt
ol traatmant
•filtm fWutni
(continued)
S*mp4« p*»««rvaUon procaduras. conlatri*; ma!«rt«l*. and maktmufft
¦JJowabi# holding lim«» a/a p4
AppHcabla THaaa raqukamartfa ara ganaralty incorporatad |
Into p«rmfta. which ara not raquiiad for on tita ditchargat |
Tha aubatant»*a raqukamarrt* ara applkabla. howavar. in 1
tfial vartftabla avfcMrnca must ba offarad that alandardft aia 1
Nlng mat. Tha patmituog authority ahootd ba (oniuNad ]
on a caa*by-caa« baala to datormina analylical 1
fiqutf#marrt«. (
0*«charga (0
POTW4
Pollutant* that p«aa tuough tha POTW without traatma**. intartafa with
POTW oparallon. or that corriaminata POTW aludgo ara prohibited
Diacharga ot hquid to • POTW
40 CFR 403 5
AppHcabta M grown cfc* alar la traatad and (ha affluant ia 1
diacha*g*d to a POTW aa part of lha aaiactad ramady In 1
accordance w*h guidance, a diac barge permit *Mt be a
requ«ed ay an lor an onafte drecharge. «inc« permitting it !
*e only aubaianttva control mechaniam available lo a 1
POTW. |

Sp*cMkC prohibition# pf«cU*3a tr>a dt achat ga ol polhAanU to POTW* thai,
•	Qatfa «fit* or txplaftlen hizard In fw POTW
•	Am canoaWa (pHdk>g on tha charadariatict 1
ol th« waate etream and tha receiving POTW Soma
mu^cipaWM hart pwb4i«h*d atandifda tor norv
categorical. ftondomeatic diacha*gee Change* m tha
tompoiiofl of tha waata ¦traajn due to pfatrttimaM
procaaa ehangee or tha addition of new waste atreama «i
ia<|UN« lanogotttftktn of t«t pacrnK condWona

lntra«aa tta tamparatura of wMtowalar antaring t» baelmeol
piaM tw« wouM imuI In Inurfaraoca. but in no cim ralta t*a
POTW tafluam tampwalufs abova t
-------
TABLE 3 4 (CONTINUEO) p 5 ot 5 I
POTENTIAL FEDERAL ACTION-SPECIFIC ARARa
CEREAL CITY LANDFILL
Agfecw
Rf^UlfNMN^
PmaquWM*)
CMon
Cwwtwli
Diacharga lo
POTW1
j (conltnuad)
Diacharga musl comply with local POTW pratraatmant program,
including POTW-tpacitic pollutant*. tpJU pravantion program
raqulramant*. and raporting and monitoring raqulramant*
RCHA parmM by-ruls ra^uiramant* mutt ba compMad with lor diacharga*
of RCRA haxardou* waata* to POTW* by buck, rail, or dadicalad pipa

40 CFR 403 5 and k>cal
POTW ragulaUon*
40 CFR 264 71 and
40 CFR 264 72

NOTES.
A portion of tha Caraal Cfty Landfill ixlMdi bayood Im SCHT* proparty Hrm( I tha *ha ii c«pp«d. coniolld«|ioA of wiiIm within tha cuntnt wm ot waata diil may ba conducted
AH of tha Claan Air Act ARARi that hava bwn iiUWMwd by tta Fadar al Qovarnmant may ba covarad by matching data raguialton* Tha StcU may hava tf»a authof% lo managa thaaa program* through tha Approval o4 iu
Implamanlabon plan* (40 CFR 52 Subpart Q|.
Thaaa ragdaliona apply tagardlaaa of whaftar t» ramadlal action dlacKarga* Into tha aawrar or truck* t» wmM lo an Wat lo tha aawaga corwayanc* ay slam loctfad upatraam of fea POTW
»44 4i 0000 RTE C*>«ua27 O
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O

TABLE 3-5
POTENTIAL MICHIGAN LOCATION-SPECIFIC ARARs
CEREAL CITY LANDFILL
p. 1 of 1
Area
Requirement
Prerequisite^)
Citation
Comments
Wetlands
Action to minimize the
destruction, loss, or
degradation of wetlands.
Wetlands continuous with
a water body or 5 acres
(or larger) in size and the
county population is less
than 100,000.
Michigan Wetlands
Protection Act, 1979
P.A. 203, as amended
(Act 203)
Applicable if wetlands as
defined by Act 203 are
present adjacent to the
site'.
1 1 The MDNR will interpret whether wetlands exist, as defined by Act 203.
2046 42 0000 RTE .c#f«0«27 t2
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O

TABLE 3-6
POTENTIAL FEDERAL LOCATION-SPECIFIC ARARe
CEREAL CITY LANDFILL
p. 1 of t J
Area
Requirement
PrenpqtWtafs)
(Station
Comments |
Wetlands
Action to minimue the destruction,
loss, or degradation of wetlands
Wetland as defined by Executive
Order 11990 Section 7.
Executive Order 11990,
Protection of Wetlands, 40
CFR 6, Appendix A
Applicable. Jurisdictional wetlands' 1
are present adjacent to the site. |
Within area affecting
national wild, scenic, or
recreational river
Avoid taking or assisting in action thai
win have direct adverse effect on wrid.
scenic, or recreational river.
Activities that art act or may affect
any of the rivers specified in
Section 1276(a).
Scenic Rivers Act (16 USC
1271 et sea. Section 7fa):
40 CFR 6.302(e)
Relevant and appropriate if national
wild, scenic, or recreational rivers are
located near the site and will be
affected by site remediation
' Jurisdictional wetlands are defined by the U.S. Army Corps of Engineers Delineation Manual (1987).
Km* 42 OOOO nri cweMGtf e
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RMT FEASIBILITY STUDY REPORT
SEPTEMBER 1995
CEREAL CITY LANDFILL
FINAL
3.5	Locatlon-Speclflc ARARs and TBC Criteria
The location-specific ARARs and TBC criteria are restrictions on the activities that can be
undertaken at a site based solely on the site's location. Site activities may be limited in order
to protect floodplains, critical habitats, and/or wetlands. Tables 3-5 and 3-6 list the potential
location-specific AFlARs and TBC criteria for the CCL, with Table 3-5 listing the Michigan
requirements and Table 3-6 listing the federal requirements. These criteria are not expected
to be major factors in the selection of a remedy for the CCL
3.6	Identification of Slte-Speclflc ARARs for Remedy Selection
Certain of the ARARs and TBC criteria have the most direct impact on remedy evaluation and
eventual selection. Both federal and state requirements apply; however, the primary
requirements for the CCL are identified in Part 201 of Act 451.
Groundwater Clean-Up Criteria
The proposed groundwater cleanup criteria for the CCL are the Part 201 of Act 451
health-based drinking water values for generic residential land use that are contained
in the ERD Operational Memorandum #8, Revision 4, with the exceptions of ammonia
and diethoxymethane, for which there are no state or federal groundwater criteria.
The only published criteria to use as a basis for establishing a cleanup criteria for
ammonia is a USEPA draft health advisory (USEPA, 1994). This TBC criteria (30 mg/L)
is the proposed cleanup level for ammonia. There is no proposed cleanup level for
diethoxymethane because there are no published criteria on which to base one.
The proposed groundwater cleanup criteria for landfill-related constituents detected at,
and near the site are shown in Table 3-7. This table also shows the maximum
concentrations of the landfill-related constituents in the on-site and the off-site
monitoring wells during the four 1994 groundwater monitoring program sampling
events that were conducted from October 1993 through July 1994 (RMT, 1994e).
Soil Clean-Up Criteria
The results of the Rl (RMT, 1993a) indicated that trichloroethene (TCE) and
tetrachloroethene (PCE) were the only VOCs detected in surface sediment samples,
and that no VOCs were detected in deeper soil samples. TCE and PCE were
,/
detected at estimated concentrations less than 1 ^g/kg, which is less than the target
method detection limit of 10 jig/kg for these compounds (ERD Operational
38
20*6 43 0000 ATE c«t®0627
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TABLE 3-7

Page 1 of 1
PROPOSED PART 201 GROUNDWATER CLEANUP CRITERIA
FOR THE CEREAL CITY LANDFILL

Constituent
Maximum OrtSft*
Concentration'
(*g&, except «*
noted}
Muxtmum Off-Site
Concentration'
(ftfl/L,except m
• noted)
Proposed Cteanup
Criteria
(WL *xcept»
noted)
BasJ»for PropoMd
Ctoanup Crteri*
Arsenic
130
10
50
Generic Residential2
Benzene
7.8
0.1
5
Generic Residential2
Chlorobenzene
92
0.5
100
Generic Residential2
Chloroethane
10
0.3
220
Generic Residential2
Chloromethane
1
1
66
Generic Residential2
1,1-Dichloroethane
2.6
0.5
880
Generic Residential2
ci»-1,2-Oichloroethene
0.6
0.7
70
Generic Residential2
1,2-Oichloropropane
02
02
5
Generic Residential2
Diethoxymethane
S
2
NS
No published criteria
available
Diethyl ether
47
10
3,700
Generic Residential2
Ethylbenzene
0.07
0.1
700
Generic Residential2
Nitrogen, as ammonia
240 mg/L
18 mg/L
30 mg/L
USEPA draft health
advisory3 (USEPA,
1994)
T etrachloroethene
0.2
0.1
5
Generic Residential2
Tetratydroluran
100
23
240
Generic Residential2
1.1.1 -T nchloroethane
0.05
0.1
200
Generic Residential2
Trichloroethene
2*
0.3
5
Generic Residential2
Vinyl chloride
0.8
0.9
2
Generic Residential2
NOTES:




1	Maximum concentrations reported during the 1994 groundwater monitoring year from October 1993 through Juty
1994 (four rounds of data).
2	ERD Operational Memorandum #8, Revision 4, Generic Residential Cleanup Criteria, June 5, 199S. The critena
shown are the health-based drinking water values.
3	There are no state or federal drinking water quality standards for ammonia.
4	Trichloroethene was not detected in any of the on-site wells between October 1993 and July 1994. The detection
shown in this table is from September 1992.
20*a.42 OOdO RTH »r«06371
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RMT FEASIBILITY STUDY REPORT
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CEREAL CITY LANDFILL
FINAL
Memorandum #6, Revision 3). The locations of the four soil samples in which TCE
and/or PCE were detected did not correspond well with the detections of these
constituents in groundwater or leachate samples. In addition, arsenic was detected in
surface soil at concentrations ranging from 1.6 to 12.4 mg/kg. The concentrations of
TCE, PCE, and arsenic are all well below the direct contact values for generic
industrial land use contained in the ERD Operational Memorandum #14, Revision 2,
dated June 6, 1995, and which are the proposed soil cleanup criteria for these
constituents at the CCL
On the basis of the site-specific baseline risk assessment (RMT, 1993a), there are no
unacceptable current or future risks or hazards to site workers as a result of exposure
to arsenic in soil. Potential future exposure to residents is controlled by the restricted
access to the site. Future potential residential use of the site would be prohibited by
deed restrictions.
The naturally occurring concentrations of barium, manganese, mercury, and zinc in
soil in the vicinity of the CCL were calculated on the basis of additional soil samples
that were collected in areas unaffected by the landfill (RMT, 1994a). The maximum on-
site concentration of each of these metals is less than the corresponding site-specific
background concentration as well as the direct contact value for generic industrial
land use (ERD Operational Memorandum #14, Revision 2). The direct contact values
for industrial land use are the proposed soil cleanup criteria for these metals at the
CCL The specific Part 201 soil clean-up criteria proposed for this landfill are shown in
Table 3-8.
42
2046 43 0000 RT?.c«c0627
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TABLE 3-8

PROPOSED PART 201 SOIL CLEAN-UP CRITERIA FOR THE CEREAL CITY LANDFILL
Constituent*
Maximum On-Site
Concentration
Proposed Clean-Up Criteria*
Trichloroethane
0.7 jig/kg Q2
1,600,000 hg/kg
T etrachloroethene
1 pQlkg Q
490,000 ^g/kg
Arsenic
12.4 mg/kg
83 mg/kg
Barium
94 mg/kg
320,000 mg/kg
Manganese
538 mg/kg
22,000 mg/kg
Mercury
0.16 mg/kg
1,400 mg/kg
Zinc
53 mg/kg
1,000,000 mg/kg
NOTES:


1 Methylene chloride, toluene, and xylenes were also detected in on-site soil samples at
concentrations up to 2 ^g/kg; however, these constituents, which are also common
laboratory contaminants, were detected at similar concentrations in more than half of the
laboratory method blanks and are not believed to be landfill-related.
' Q denotes an estimated concentration. The actual concentration is above the method
detection limit, but is less than the practical quantitation limit.
3 ERD Operational Memorandum #14, Revision 2, direct contact values for generic industrial
land use, June 6, 1995.
2046 42 0000:HT£ car«OG27.t
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Section 4
REMEDIAL ACTION OBJECTIVES
On the basis of the site characterization studies and the baseline risk assessment for the CCL,
the following remedial action objectives were developed to eliminate unacceptable risks to
human health and the environment, and to meet ARARs:
•	To reduce off-site migration of landfill constituents in groundwater
•	To prevent off-site migration of subsurface landfill gas
To prevent future exposure to landfill contents via direct contact or ingestion
Remedial action objectives were not developed for on-site soils, surface water, sediments, and
air because there were no adverse effects identified for these media in the Phase III Study and
Baseline Risk Assessment (RMT, 1993a) or the Characterization and Evaluation of Landfill Gas
Emissions (RMT, 1993b). Specifically:
•	On-site surface soil at the landfill does not contain constituents of concern at
concentrations greater than the Part 201 generic industrial soil cleanup criteria
for direct contact.
Surface water and sediments in areas likely to be affected by the landfill
(i.e., the Sperry Drain) do not contain constituents at concentrations greater
than the Part 201 generic residential cleanup criteria.
•	Air quality sampling, analysis, and dispersion modeling resulted in predicted
ambient air concentrations that were well below the levels specified in Part 55
of Act 451, formerly Act 348.
44
2048.43 OOOOffTH ftmOSZT
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RMT FEASIBILITY STUDY REPORT	SEPTEMBER 1995
CEREAL CITY LANDFILL	FINAL
Section 5
TECHNOLOGY SCREENING
5.1 Introduction
The initial step in the evaluation of alternatives is to identify technologies that may apply to the
CCL site (40 CFR Part 300.430[e]) and meet the clean-up criteria applicable under Part 201.
This section will identify specific technologies that may be appropriate to meet the remedial
action objectives (Section 4). Technologies have been identified to address the landfill
contents, groundwater, and soil gas issues. Technologies that may be applicable for the
treatment, disposal, waste minimization, recycling or destruction at an off-site facility, as
prescribed in R299.5513(2)(a)(i), Michigan Administrative Code (MAC), were not considered
because excavation and transport of landfill contents have been determined to not be feasible
or to be cost prohibitive by the USEPA (a more detailed discussion of the application of
presumptive remedies at this site is provided in the next subsection). After identification of
various specific technologies, the technologies are screened to eliminate those that are
inappropriate for inclusion in specific alternatives and to establish those that are carried
forward into Section 6.
5.2 Presumptive Remedies
The USEPA has issued a procedural guidance for selection of remedies for certain categories
of sites that have similar characteristics and for which the same limited range of technologies
is consistently selected. The USEPA's guidance for using the presumptive remedy approach
to accelerate selection of cleanup actions is contained in the OSWER Directive 9355.0-47 FS,
•Presumptive Remedies: Policies and Procedures," and is reproduced in Appendix D. The
USEPA has issued a directive specific to the selection of presumptive remedies for CERCLA
municipal landfill sites (OSWER Directive 9355.0-49 FS, also contained in Appendix D).
In developing the presumptive remedy guidance for municipal landfills, the USEPA conducted
an analysis of potentially available technologies for these sites and found that certain
technologies are routinely and appropriately screened out on the basis of effectiveness,
feasibility, or cost, and that the universe of alternatives that should be analyzed in detail may
be limited to the components of the presumptive remedy, unless site-specific conditions
indicate otherwise, or alternatives are considered that were not addressed in the USEPA's
"Feasibility Study Analysis for CERCLA Municipal Landfills," September 1993. Thus, the initial
45
204fl. 0000:flTE:c#f«0«Z7
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RMT FEASIBILITY STUDY REPORT
CEREAL CITY LANDFILL
SEPTEMBER 1995
FINAL
identification and screening of alternatives during the FS can be streamlined. While the CCL
is not a Federal CERCLA site, the presumptive remedy approach is relevant to the screening
of remedial technologies for use at the CCL because it has taken into consideration the criteria
outlined in Rule R299.5513, MAC.
The presumptive remedy guidance for CERCLA municipal landfills identifies containment of the
landfill mass as the preferred remedy for these types of sites. The presumptive remedy for
municipal landfills also includes the following other potential components:
Source area groundwater control;
•	Leachate collection and treatment;
•	Landfill gas collection and treatment; and/or
•	Institutional controls to supplement engineering controls.
The presumptive remedy guidance for landfills notes that groundwater contamination that has
migrated away from the source will generally require a comprehensive risk assessment to
determine whether action is warranted beyond the source area and, if so, the type of action
that is appropriate. A baseline risk assessment that evaluated current and potential future
residential exposure to groundwater affected by the landfill was performed for the CCL (RMT,
1993a).
It is important to note that although the US EPA has identified containment as the presumptive
remedy for municipal landfills, innovative technologies can still be evaluated and
recommended. Specifically, the Presumptive Remedy: Policies and Procedures guidance
(OSWER Directive 9355.0-47 FS) provides the following interpretation of how presumptive
remedies affect the potential selection of innovative technologies:
The NCP in Section 300.430(a)(1) (iii)(E) states that "EPA expects to consider
using innovative technology when such technology offers the potential for
comparable or superior treatment performance and implementability, fewer or
lesser adverse impacts than other available approaches, or lower costs for
similar levels of performance than demonstrated technologies." The use of the
presumptive remedies may tend to reduce the frequency of the full evaluation
of innovative technologies. However, as indicated previously, the presumptive
remedies provide a tool for streamlining the remedy selection process.
46
2040.43 0000 RTE C4X0827
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RMT FEASIBILITY STUDY REPORT
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CEREAL CITY LANDFILL
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They do not preclude the consideration of innovative technologies should the
technologies be demonstrated to be as effective or superior to the presumptive
remedies. Innovative technologies may be evaluated and recommended in addition to
the presumptive remedies where these criteria are met."
The preceding discussion regarding presumptive remedies and innovative technologies is
particularly applicable to the CCL because the recommended remedy is a combination of
conventional methods and innovative technologies.
5.3	Institutional Controls
Fencing and deed restrictions are potentially applicable institutional controls for the CCL for
eliminating potential exposure to the landfill contents via direct contact or ingestion. The
perimeter fencing that is already in place at the site, should be maintained. Deed restrictions
limiting land use and passage of a local ordinance prohibiting the construction of potable
•vater supply wells on and around the CCL particularly in the downgradient direction, would
be appropriate for eliminating potential future exposure to landfill constituents via ingestion of
groundwater. Construction of new potable water supply wells can be effectively prohibited by
a local ordinance because a permit to install any new well in Calhoun County is required. The
use of institutional controls to limit exposure pathways is allowable under Sections 20120a(16)
and 20120b(3) of Part 201.
5.4	Containment and/or Treatment of Landfill Contents
The objectives of containment are to isolate the landfill contents and to mitigate potential off-
site surface water impacts. Containment technologies that may be applicable to the CCL
include actions ranging from surface water controls to cover placement. Because of the
volume and heterogeneity of the contents of a municipal solid waste landfill, the objective for
treatment of the landfill contents is mostly limited to hot spots, if they can be identified. Hot
spots have not been found at the CCL Treatment of landfill contents may also include soil
vapor extraction to reduce the concentrations of landfill gas constituents.
The landfill contents may be contained and/or treated using a combination of the following
general response actions:
Containment
Removal of waste constituents
47
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CEREAL CITY LANDFILL	FINAL
Treatment of hot spots
Control of landfill gas
The potential effectiveness of these technologies is site-dependent and costs may vary
substantially. Table 5-1 identifies a range of process options for each of these general
response actions, and identifies those that are included in the remedial alternatives.
5.5 Landfill Cover Systems
The FS for the CCL concentrates on two landfill cover designs for containing the waste. The
designs of these two options are summarized as follows:
A conventional landfill cover, that uses a geosynthetic clay liner (GCL), which
is a low-permeability geosynthetic product, would provide source control by
limiting infiltration of precipitation. A low-permeability cover requires runoff
controls for precipitation falling on the cover to direct the runoff away from the
landfill, and run-on controls to prevent precipitation from areas adjacent to the
landfill from running onto the cover. Surface water runon and runoff would
have to be managed as a discharge under a NPDES permit from the MDNR.
In addition, the placement of a low-permeability cover would result in the build-
up of landfill gases in the two waste cells, thus making it necessary to install
an active perimeter and interior landfill gas extraction system to replace the
existing passive gas venting system.
A soil cover would minimize surface water erosion by promoting the growth of
vegetation on the final cover, yet also provide the oxygen necessary to sustain
the natural biodegradation processes that have been reducing the
concentrations of landfill constituents in groundwater downgradient of the site
for many years. This cover design would generally maintain the existing site
drainage patterns which result in minimal direct surface water runoff from the
CCL property. This cover design would not require modification of the existing
interior gas management system, but would incorporate a perimeter gas
extraction system along the northern boundary and the southeastern corner of
the North Waste Cell.
Both types of covers would prevent direct contact with fill material and would reduce exposure
to landfill gas. The designs of these covers are described more fully in the following
subsections.
48
2046 *3 OOOO WTE CM0627
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J
TABLE 5-1 Page 1 of 2
POTENTIAL REMEDIAL TECHNOLOGIES FOR LANDFILL CONTENTS
General Response
Action Type
process Option
Brief Description
Suitability for the CCL
Appropriate for Further
Consideration?
Containment
Surface water
controls
Collection of run-off and
possibly pumping for discharge
to storm water
Applicable depending on cover
configuration
Yes
Grading
Modification of topography to
promote drainage and yo cover
waste
May be needed for erosion
control and to isolate waste
mass
Yes
Reseeding
Placement of seed to promote
revegetation
Will be utilized to improve
surface stability
Yes
Soil cover
Additional fill and topsoil to
provide additional exposure
protection
Would improve aesthetics and
smooth out the existing cover
topography
Yes
Conventional landfill
cover
Single barrier cover to reduce
infiltration, prevent direct
contact, limit gas emissions, and
control erosion
Can be applied, but will require
significant regrading
Yes
Composite barrier
Additional barrier layer to more
completely control infiltration
Not needed at site due to
predominance of municipal
waste
No
Removal
Excavation
Excavation of hot spots of highly
impacted fills
No specific areas identified for
excavation in Rl
No
Treatment of fill (hot
spots)
Stabilization
Addition of reagents to fill
materials to minimize leaching of
constituents
No specific hot spots were
identified in the Rl
No

Vapor extraction
Removal of VOCs from fill by
drawing air through slotted
screens
No specific hot spots were
identified in the Rl
No
2046 42 0000 RTE.c«r*0627 (
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| TABLE 5-1 (CONTINUED) Page 2 of 2
POTENTIAL REMEDIAL TECHNOLOGIES FOR LANDFILL CONTENTS
General Response
Action Type
Process Option
Brief Description
Suitability tor the CCL
Appropriate for Further
Consideration?
Control of landfill
gas
Passive gas systems
Installation of additional pipe
vents or trenches for
intercepting gas
Passive collection systems
currently in place have been
ineffective in controlling off-site
migration
No
Active gas systems
Mechanical systems to control
migration of landfill gas
Existing system enhancements
would be protective of
neighboring properties
Yes
Treatment of landfill
| gas
Enclosed ground
flares
Enclosed burner with stack
exhaust for combustion of
landfill gas
Insufficient methane to support
combustion. Gas constituents
not above regulated levels
No
2046 42 0000 ATE c»i»0627 I
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RMT FEASIBILITY STUDY REPORT
SEPTEMBER 1995
CEREAL CITY LANDFILL
FINAL
5.5.1 Conventional Cover
A range of design options for a conventional low-permeability cover was studied, with
the GCL design being selected for further evaluation in the feasibility study. The
detailed evaluation of cover design options is presented in a technical memorandum
entitled 'Final Cover Options Analysis,' which is included in Appendix A. Figure 5-1
and Table 5-1 summarize the configurations of the covers that were analyzed in this
study. Each of the cover options was evaluated on the basis of expected performance
and cost. All of the cover options meet the hydraulic conductivity requirements for
impermeable liners as defined by Part 115 of Act 451 (formerly Act 641). The best
performing option at the lowest cost was the geosynthetic clay liner (GCL) as the low-
permeability component of the liner (see Option 1 on Figure 5-1 and Table 5-1).
The GCL was selected from the range of conventional cover design options presented
on Figure 5-1 and in Table 5-1, even though it does not meet the material specification
and thickness requirements (i.e., 2 feet of clay) for a new landfill as described in the
1994 SWMA amendments. The GCL cover (without a geomembrane and/or clay) is
recommended on the basis of the following factors:
1.	The MDNR Waste Management Division verified that the CCL met the
applicable requirements when it was closed in 1983 (MDNR, 1995).
2.	The 1994 SWMA allows for alternative cover configurations.
3.	The GCL cover meets the Part 115 requirements for an existing landfill.
4.	The GCL cover has a reported hydraulic conductivity of 3 x 109 cm/s or less
(based on manufacturer's information), which exceeds the performance
characteristic of a 2-foot-thick clay cover which would have a hydraulic
conductivity of 1 x 10'7 cm/s.
5.	The GCL cover would not be affected by frost penetration or desiccation.
A plan view of the GCL cover design is shown on Figure 5-2. The GCL cover, as well
as all of the other conventional cover design options, requires collecting the
precipitation that falls onto the cover and discharging it in an acceptable manner. The
surface runoff from the southern and western portions of the South Waste Cell would
be directed to two new sedimentation basins. The discharge from the sedimentation
basins would flow by gravity to a lift station in the southwestern corner of the site.
51
2046.43 OOOO BTE c«r«0627
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TABLE 5-2
SUMMARY OF LOW-PERMEABILITY FINAL COVER OPTIONS
Option
Thlckne$$of
TOpSOl
Thickness of General FBI layer
Above Low-Permeability Liner
Type and Thickn©89
of Low Permeability Layer
Soil Type and Thickness
Between Low Permeability
Layer and Waste
1
6 inches
18 inches
Geosynthetic clay liner (GCL)
18-inch general fill
2
6 inches
18 inches
24 inches of clay
None
3
6 inches
18 inches
40-mil very low density polyethylene
(VLDPE) geomembrane with GCL
18-inch general fill
4
6 inches
24 inches with geocomposite
drainage layer
40-mil VLDPE geomembrane with
GCL
18-inch general fill
5
6 inches
12 inches with geotextile layer
and 12-inch select granular fill
40-mil VLDPE geomembrane with
GCL
18-inch general fill
6
6 inches
24 inches with geocomposite
drainage layer
40-mil VLDPE geomembrane and 18
inches of clay
None
7
6 inches
12 inches with geotextile layer
and 12-inch select granular fill
40-mil VLDPE geomembrane and
18 inches of clay
None
2046 43 0000 PTE cei«0627 t
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RMT FEASIBILITY STUDY REPORT
CEREAL CITY LANDFILL
SEPTEMBER 1995
FINAL
Assuming that surface water runoff from the southern and western portions of the
South Waste Cell is the only source of water to the lift station, the lift station pumping
system would be designed for a maximum flow rate of 1,200 gpm, using three
400-gpm pumps operating in parallel. The 1,200-gpm flow rate was selected on the
basis of the peak discharge from the sedimentation basins resulting from a 10-year,
24-hour storm event.
Discharge of surface water from the lift station would be routed to the Kalamazoo River
via the City of Battle Creek storm sewer system. A section of the City's storm sewer
system, from the southwestern corner of the site to the corner of Hubbard and
Laramie Streets, consists of open ditches and culverts. This section of the discharge
route from the CCL would be modified to consist of a buried 10-inch-diameter force
main to prevent potential problems during the winter. A request has been made of the
Battle Creek Public Works Director to evaluate the placement of the force main along
this section of the storm sewer system, either by SCHI purchasing a right-of-way or the
City granting an easement. The City has an NPDES permit for the discharge of
stormwater into the Kalamazoo River. Discharge of surface water runoff from the CCL
would need to meet the requirements of the City's permit and would require the City's
approval to discharge to the storm sewer. On the basis of preliminary discussions
with the Battle Creek Public Works Department, this appears to be feasible.
The surface water runoff from all of the North Waste Cell and the northern and eastern
portions of the South Waste Cell will be routed to the on-site wetland areas to the east
of the South Waste Cell, where it would infiltrate into the ground. This discharge is not
expected to require a permit.
Because a conventional cover will prevent the upward migration of landfill gas through
the surface of the landfill, an interior gas extraction system for both the North and
South Waste Cells is also needed with this option. The interior gas extraction systems
for the North and South Waste Cells would consist of perforated pipes placed below
the GCL that would be spaced approximately 200 feet apart. In addition to the interior
gas extraction system, approximately 13 perimeter gas extraction wells would be
installed along the northern and southern boundaries of the North Waste Cell to
control off-site migration in these areas. Figure 5-3 shows the preliminary design for a
gas extraction system for the North Waste Cell, and Figure 5-4 shows the preliminary
design for a gas extraction system for the South Waste Cell.
53
2044 43 0000 ATE Cf06Z7
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RMT FEASIBILITY STUDY REPORT
CEREAL CITY LANDFILL
SEPTEMBER 1995
FINAL
Both gas extraction systems would be connected to the existing South Waste Cell
perimeter gas extraction system (refer to Subsection 2.7 for a description of this
system and to Figure 2-6 for a layout). The additional vacuum necessary to run the
new gas extraction systems in conjunction with the existing system would require
replacement of the existing blower, flame arrester, and condensate tank with higher
capacity equipment. This expanded gas extraction network would likely produce a
gas mixture that could support combustion and therefore enable burning of the
existing utility flare that is not currently operating. The existing passive gas vents in
both the South and North Waste Cells would be abandoned if a conventional cover is
selected.
The estimated direct capital cost for installing the conventional cover and the gas
collection systems is $4,900,000 (Appendix E). It should be noted that the cost
estimates presented in the technical memorandum regarding final cover design
options (Appendix A) were prepared in early 1993. The cost estimate for the GCL
cover option (Option 1) has since been revised to reflect more current material and
installation costs and to include the additional components required for
implementation of the conventional cover.
5.5.2 Soil Cover
The soil cover option is designed to prevent erosion and dermal contact with waste
materials while allowing natural processes to biodegrade waste constituents in the
groundwater. This option includes regrading the site and placing additional general fill
and topsoil to achieve final grades to minimize on-site ponding of surface water and
promote vegetation. An additional 6 inches of general fill on top of an average of
6 inches of existing cover materials, plus an additional 6 inches of topsoil (total of 18
inches, minimum) is estimated to be adequate to promote and support vegetation over
the existing waste disposal areas. The final grades for the soil cover range from
approximately 2 percent to 20 percent as shown on Figure 5-5.
A perimeter gas control system would be needed along the northern boundary and
southeastern corner of the North Waste Cell, as shown on Figure 5-6, to control off-
site migration of landfill gas in these areas. The perimeter gas control systems would
consist of approximately ten additional gas extraction wells and interconnecting piping
that will allow this system to be connected to the existing South Waste Cell perimeter
gas migration control system. The installation of these new wells would require
54
204S 43 0000 flTE c«»0eZ7
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RMT FEASIBILITY STUDY REPORT
SEPTEMBER 1995
CEREAL CITY LANDFILL
FINAL
upgrading the existing blower serving the South Waste Cell perimeter gas control
system; however, the existing condensate tank and flame arrester are large enough to
handle the North Waste Cell perimeter gas control system. It is not expected that the
combustible content of the gas collected from the North Waste Cell, when combined
with the gas from the South Waste Cell, will support a continuous flame. Therefore,
the gas will continue to be vented to the atmosphere. Interior gas collection systems
would not be needed in either cell because the gas will be able to migrate vertically
through the cover.
The estimated direct capital cost for installing the soil cover and the perimeter gas
extraction system in the North Waste Cell is $1,200,000 (Appendix E).
5.6 Groundwater Containment
Hydraulic containment of groundwater affected by landfill constituents could be achieved with
two new extraction wells pumping at a combined rate of approximately 200 gallons per minute
(see Appendix B for details). The extraction wells would be located in downgradient positions
on the west side and in the southwest corner of the site—in the vicinity of existing monitoring
wells OB-1 and OB-8, respectively. This pumping scenario would result in a capture zone that
would encompass all of the area under the landfill plus several hundred feet east and west of
the waste boundaries.
The groundwater containment plan for the CCL outlined above would be applicable under
either final cover alternative. This plan was developed by conducting a capture zone analysis
using the analytic element code Quickflow ~ (Rumbaugh, 1991), and then testing the results
from the Quickflow1" analysis in the groundwater contaminant transport model BIOPLUME™
(Rifai et a)., 1987). Testing the results of the Quickflow"* analysis in the BIOPLUMEn' model
provided confirmation of the optimum extraction well locations and pumping rates, and
provided a quantitative assessment of the effectiveness of the groundwater containment
system in reducing the concentration of contaminants in groundwater—under both a soil cover
and a conventional cover. The basis and results of the Quickflowm and BIOPLUME™ analyses
are described in detail in the 'Evaluation of the Effectiveness of Landfill Covers and
Groundwater Containment in Remediating Groundwater at the Cereal City Closed Landfill,'
which is presented in Appendix B.
55
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RMT FEASIBILITY STUDY REPORT
SEPTEMBER 1995
CEREAL CITY LANDFILL
FINAL
Higher pumping rates and additional extraction wells were also evaluated, but were found to
be of little additional benefit to the overall remediation of groundwater, on the basis of the
results of the model simulations and the preliminary cost estimates to implement.
Alternative groundwater containment technologies, such as slurry walls, sheet piles, injected
screens, and grout curtains, were briefly considered for the CCL but were quickly eliminated
because their effectiveness relies on keying the base of these systems into an underlying low-
permeability geologic unit. In the downgradient part (southern) of the site, the top of the
uppermost low permeability unit, the Coldwater Shale, is on the order of 160 feet below
ground surface, making these technologies impractical for this site.
Similarly, alternative groundwater removal technologies, such as subsurface drains and
collection trenches, were ruled out because the depth to the groundwater in the southern
portion of the site is approximately 25 feet below ground surface.
Groundwater pumped from the aquifer would have to be disposed via a surface water
discharge and would require a NPDES permit. The most cost-effective means of routing the
pumped groundwater to a surface water discharge point would be through the existing storm
sewer that runs from the southwestern comer of the site to the Kalamazoo River parallel to
Hubbard, Parkway, and Jordan Streets.
Under the Clean Water Act. two types of standards must be met for discharges of this type of
wastewater. The first are the industry-wide standards, also called categorical standards
(40 CFR Subpart N), which have currently been written for approximately 40 industries.
Landfills, however, are not among the 40 industries covered. The second type are the water
quality standards which are specific to identified bodies of water and the water use for that
portion of the water body. The water quality standards apply to all discharges, irrespective of
the industry-wide standards that must be met. It should be noted that not all bodies of water
have water quality standards.
Because there are no categorical standards that are applicable to the discharge of wastewater
from landfills, the primary issue relative to obtaining an NPDES permit for groundwater
discharged from the CCL to the Kalamazoo River, which is the closest, practical surface water
discharge point for the site, would be to evaluate the requirements for meeting water quality
criteria established for the Kalamazoo River. Critical to this determination is establishing the
design flow of the river at the approximate point of discharge according to the provisions of
56
2046 43 0000 RTE:cara08Z7
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"44 Hcarriand Trail 53"I*-193-1
P.O. Box S923 5JTOS S923
Madison, W!
Telephone: 608-831 -4444
Fax; 608-831-3334
REMEDIAL ACTION PLAN
FOR THE
CEREAL CITY LANDFILL
BATTLE CREEK, MICHIGAN
PREPARED FOR S.C. HOLDINGS, INC.
PREPARED BY RMT, INC.
REVISED FINAL
NOVEMBER 1998
Z.iVtrcmni-iW.
Zoiu'io**
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¦¦
Table of Contents
1.	Introduction	1-1
1.1	Background	1-1
1.2	Purpose and Scope	1-3
2.	Pre-Construction Site Conditions	2-1
2.1	Site Setting and Land Use	2-1
2.2	Hydrogeologic Conditions	2-3
2.3	Source Characterization	2-4
2.4	Nature and Extent of Contamination	2-5
2.5	Contaminant Fate and Transport	2-7
2.6	Landfill Gas Migration and Control	2-9
2.7	Baseline Risk Assessment	2-10
3.	Identification of ARARS	3-1
3.1	Introduction	3-1
3.2	Part 201 of Act 451	3-2
3.3	Chemical-Specific ARARs and TBC Criteria	3-3
3.4	Action-Specific ARARs and TBC Criteria	3-3
3.5	Location-Specific ARARs and TBC Criteria	3-4
3.6	Identification of Site-Specific ARARs	3-4
4.	Selected Remedial Action	4-1
4.1	Remedial Action Objectives	4-1
4.2	Selected Remedial Action	4-2
4.3	Landfill Final Cover	4-4
4.4	Perimeter Landfill Gas Control Systems	4-5
4.5	Institutional Controls	4-6
4.5.1	On-Site Institutional Controls	4-6
4.5.2	Off-Site Institutional Controls	4-8
4.6	Estimated Costs	4-9
5.	Abandonment of Wells and Gas Vents	5-1
5.1	Abandonment of Monitoring Wells, Leachate Head Wells, and a Residential Well5-1
5.2	Abandonment of Passive Gas Vents	5-2
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Cereal City Landfill
Revised Final November 1998
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6.	Fugitive Dust and Ambient VOC Monitoring and Control Plan	6-1
6.1	Fugitive Dust Control Plan	6-1
6.2	Fugitive Dust Monitoring Plan	6-1
6.3	Ambient Volatile Organic Compound Monitoring	6-2
7.	Implementation Schedule	7-1
8.	Reporting	8-1
9.	Financial Assurance	9-1
10.	References	10-1
List of Tables

Table 1
Potential Michigan Chemical-Specific ARARs
Table 2
Potential Federal Chemical-Specific ARARs
Table 3
Potential Michigan Action-Specific ARARs
Table 4
Potential Federal Action-Specific ARARs
Table 5
Potential Michigan Location-Specific ARARs
Table 6
Potential Federal Location-Specific ARARs
Table 7
Target Groundwater Cleanup Criteria for the Cereal City Landfill
Table 8
Soil Clean-Up Criteria for the Cereal City Landfill
Table 9
Schedule for Implementing the Remedial Action
List of Figures

Figure 1
Site Locator Map
Figure 2
Chemical Concentrations in Groundwater and Leachate Along Geologic

Cross Section A-A', August 1992
Figure 3
Water Table Map, October 1995
Figure 4
Marshall Formation Potentiometric Surface Map, October 1995
Figure 5
Chemical Concentrations in Groundwater and Leachate, August 1992
Figure 6
Chemical Concentrations in Groundwater and Leachate Along Geologic

Cross Sections B-B' and C-C', August 1992
Figure 7
South Waste Cell Soil Gas Probes and Perimeter Gas Migration Control

System
Figure 8
Gas Probe Locations in the North and South Waste Cells
Figure 9
Soil Final Cover
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Cereal City Landfill
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Figure 10
North Waste Cell Soil Gas Probes and Preliminary Perimeter Gas Migration
Control System
List of Appendices
Appendix A Environmental Monitoring Plan
Appendix B Operation and Maintenance Plan
Appendix C Evidence of Current Property Use as a Legal Nonconforming Land Use
Appendix D Water Supply Well Survey
Appendix E On-Site Institutional Controls: Restrictive Covenants for the Landfill
Property
Appendix F Off-Site Institutional Controls - City of Battle Creek
F-l	Notice to City of Battle Creek Residents near the Landfill of the Proposed
Groundwater Ordinance
F-2	List of Parcel Numbers for City of Battle Creek Properties within the Area of
the Groundwater Ordinance
F-3	City of Battle Creek Groundwater Ordinance
Appendix G Off-Site Institutional Controls - Bedford Township
G-l	List of Parcel Numbers for Bedford Township Properties within the Area of
the Groundwater Ordinance
G-2	Bedford Township Groundwater Ordinance
Appendix H Opinion of Probable Cost for the Selected Remedial Action
Appendix I	Administrative Order on Consent
Appendix J	Summary of Responses to the MDEQ's Comments on Drafts of the RAP
J-l	Responses to the MDEQ's October 30,1997, Comments on WMI's
September 23,1997, Draft Revisions to the RAP
J-2	Responses to the MDEQ's July 18, 1997, Comments on January 1997 Draft
RAP
J-3	Draft Responses to the MDEQ's May 9,1997 Comments on the January 1997
Draft RAP
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Section 1
Introduction
1.1 Background
In response to a March 29,1991, letter from the Michigan Department of Natural Resources
(MDNR) to Waste Management of North America, Inc., S.C. Holdings, Inc. (SCHI), a subsidiary
of Waste Management, Inc., has been undertaking corrective actions at the Cereal City Landfill
(CCL) in Battle Creek, Michigan, to remedy environmental concerns. The landfill is situated on
a 151-acre parcel of property and consists of two unlined waste cells that together, cover
approximately 73 acres (Figure 1). The landfill received municipal, commercial, and industrial
solid waste during active operation from 1951 through July 1982.
A closure agreement for the landfill was approved by the MDNR in June 1982 (the MDNR was
reorganized in October 1995 and the Environmental Response Division [ERD], which has been
overseeing the remedial activities at the CCL, became part of the MDEQ) and in
November 1982, the MDNR requested that the USEPA withdraw the landfill from the
Superfund candidate list (MDNR, 1982). A detailed description of the site history is contained
in the Phase II Hydrogeologic Study Workplan (RMT, 1991).
A Phase I hydrogeologic study of the site was completed in August 1990. This was an office
study that compiled and made a preliminary evaluation of site conditions. The findings of the
Phase I study (RMT, 1991) formed the basis for scoping the Phase II investigation, which was
completed in March 1992. The purpose of that study, which included a field investigation and
laboratory analyses, was to investigate the geology and hydrogeology at and near the site, and
to evaluate the nature and extent of potential impacts of volatile organic compounds (VOCs),
metals, and other landfill constituents to soil and groundwater as a result of past activities at
the landfill. The results of the study were presented in the Phase II hydrogeologic study report
(RMT, 1992), which was approved by the MDNR in a letter dated July 14,1992.
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Concurrently, at the request of the USEPA Region V, the Preremedial Unit of the MDNR
conducted a Site Screening Inspection (SSI) in August 1990 to evaluate the site for possible
inclusion on the National Priorities List (NPL). The SSI report was released in January 1992
(MDNR, 1992). Because Michigan Landfill Holdings, Inc. (which is now SCHI), committed as
the landfill owner, to undertake corrective actions at the site (letter from Waste Management of
North America, Inc., to the MDNR, dated April 12,1991), the MDNR recommended that the site
be given a low priority. No further enforcement action has been taken by the USEPA.
A Phase III hydrogeologic study was performed to collect additional data to assess potential
risks to human health and the environment, and to evaluate remedial alternatives. The
Phase III report (RMT, 1993a) presented a detailed characterization of on-site source areas and
an evaluation of the nature and extent of landfill-related contamination. It also included a
baseline risk assessment that has served as the basis for the feasibility study (FS) and this
remedial action plan (RAP).
The following reports and documents that addressed issues identified by the MDNR in their
review of the Phase III hydrogeologic study report were also submitted to the MDNR:
¦	Landfill gas emission characterization and assessment report (RMT, 1993b)
¦	Documentation of the installation, abandonment, and reconditioning of soil gas probes
(RMT, 1993c)
¦	Interim groundwater monitoring plan (RMT, 1993d)
¦	Background concentrations of arsenic in groundwater (RMT, 1993e)
¦	Documentation report for the expansion of the active landfill gas extraction system (RMT,
1993f)
¦	Background concentrations of selected metals in soils (RMT, 1994a)
¦	Follow-up letter regarding background concentrations of arsenic in groundwater (RMT,
1994b)
¦	Quarterly results of the interim groundwater monitoring program (RMT, 1994c)
The MDNR's comments on these reports and documents have been addressed (RMT, 1994d and
1994e; and MDNR, 1994a and 1994b) and all of the reports were approved by the MDNR in a
letter dated July 29,1994.
The FS for the site was initially prepared in accordance with the Michigan Environmental
Response Act (MERA) (1982, PA 307, as amended), and was submitted to the MDNR in
April 1995. However, with the enactment of Part 201 of Act 451 of the Public Acts of 1994, as
amended (the Natural Resources and Environmental Protection Act [NREPA]), the applicable
or relevant and appropriate state requirements (ARARs) changed substantially. The most
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significant changes that affected the remedy selection for this site were the new soil and
groundwater cleanup criteria that are based on land use, and the acceptance of institutional
controls and natural biodegradation of contaminants in an aquifer as part of a final remedy. In
July 1995, the Waste Management Division of the MDNR reviewed the regulatory status of the
landfill with respect to the Michigan solid waste rules and concluded that Part 115 of the
Natural Resources and Environmental Protection Act, 1994 P. A. 451 (formerly the Solid Waste
Management Act, 1978 P.A. 641) is not an ARAR for this site (MDNR, 1995). At the request of
the MDNR, a modified FS, which reflected the regulatory changes compelled by Part 201, was
submitted in September 1995 (RMT, 1995a). The modified FS contained a final cover options
analysis (RMT, 1995b), and an evaluation of the effectiveness of different landfill covers and
groundwater containment options (RMT, 1995c), as appendices. The MDEQ approved the FS
on November 1,1995 (MDEQ, 1995a).
Additionally, groundwater monitoring reports have been submitted to the MDEQ for
October 1993 through July 1994 (RMT, 1994e), for October 1994 through July 1995 (RMT, 1996a),
for October 1995 through July 1996 (RMT, 1996b), and for April 1998 (RMT, 1998).
1.2 Purpose and Scope
The purpose of this RAP is to present SCHI's selected remedial action for the Cereal City
Landfill to the MDEQ for approval. This RAP is intended to remediate the "site", as defined in
Section 20101(l)(hh) of Part 201. It should be noted however, that both "site" and "landfill
property" are used in the body of this document when referring to the landfill property. When
used in this context, "site" is not intended to define the location of environmental
contamination. The term "site" is used in the strict regulatory context in the Administrative
Order on Consent for the remedial action, which is an appendix of the RAP.
The selected remedial action is Alternative #2 from the FS report, which was approved by the
MDEQ in November 1995. The selected remedial action includes the following components:
¦	Constructing a soil cover over the two waste disposal areas to prevent potential direct
contact with the landfill contents
¦	Implementing the appropriate institutional controls to restrict site access, to limit future
use of the landfill property, and to prohibit installation of water supply wells on the
landfill and on certain properties around it
¦	Long-term care of the landfill cover
¦	Installing a perimeter gas control system in the North Waste Cell to control off-site gas
migration
¦	Continuing the operation and maintenance of the perimeter gas control system in the
South Waste Cell
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¦	Replacing the gas blower for the existing South Waste Cell perimeter gas control system
with a higher capacity blower that can be used for both waste cells.
¦	Long-term soil gas monitoring
¦	Long-term groundwater monitoring
The RAP was prepared in accordance with Sections 20118 through 20120d of Part 201 of
Act 451; Rules 515, 517, and 519 of Part 5 (Response Activities) of the Administrative Rules for
former Act 307 (1982 PA 307, as amended); Part 6 (Selection of Remedial Action) of the
Administrative Rules for former Act 307; and Rule 719 of Part 7 (Cleanup Criteria) of the
Administrative Rules for former Act 307. To the extent that Part 201 differs from the
Administrative Rules for former Act 307, Part 201 was given precedence. The RAP was also
developed to be consistent with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP).
The scope of the RAP includes a review of the site's operating and regulatory history, a
summary of existing site conditions based on the investigative activities conducted to date,
identification of ARARs and site-specific cleanup criteria, a detailed description of the selected
remedial action, an ambient air emissions monitoring and control plan, a schedule for
implementing the remedial action, a plan for reporting site progress, and information required
for financial assurance. An environmental monitoring plan and an operation and maintenance
plan are included in Appendices A and B, respectively, to the RAP.
Consistent with Rule 517(2)(d), MAC, for the operation and maintenance plan, the RAP also
includes the design and construction plans for the soil cover in both waste cells and the
expansion of the perimeter gas control system to the North Waste Cell. The remedial design
plans are being submitted with the RAP in order to streamline the MDEQ's review.
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Cereal City Landfill
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!¦
Section 2
Pre-Constructi on Site Conditions
This section describes the pre-construction site conditions with respect to site setting and land
use (Subsection 2.1), hydrogeologic conditions (Subsection 2.2), source characterization
(Subsection 2.3), nature and extent of contamination (Subsection 2.4), contaminant fate and
transport (Subsection 2.5), the landfill gas collection and monitoring systems (Subsection 2.6),
and the baseline risk assessment (Subsection 2.7). A more detailed description of the first five
topics can be found in the Phase III Hydrogeologic Stmdy Report (RMT, 1993a); a description of
the pre-construction gas collection system can be foun
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this cell has no sideslopes and is lower than the adjacent land. Slopes along the western edge of
the South Waste Cell range from 0 to 15 feet in height, leveling near the southern edge.
Two wetlands were identified in the Wetland Delineation Report (Appendix B of the Phase III
Report [RMT, 1993a]). A 5-acre wetland is located in the east-central portion of the landfill, in
the area between the waste cells. This wetland is surrounded by dense woods and extends off-
site to the east. A smaller wetland, less than one acre, is present on the east side of the South
Waste Cell, in an unfilled area of the landfill.
Annual rainfall averages approximately 24 inches. Groundwater recharge of 8 to 12 inches was
estimated for the site (RMT, 1993a).
A detailed discussion of the adjacent land use was presented in the workplan for the Phase II
study (RMT, 1991), and is summarized briefly here. The landfill is surrounded by residential
properties and undeveloped land. The highest density residential land use occurs to the south
and east of the landfill, with a lesser density of residences to the west of the landfill.
Undeveloped forested land bounds the landfill to the north.
The Battle Creek/Bedford Township line bisects the landfill from east to west as shown on the
plan view figures in the RAP. The portion of the landfill within the limits of the City of Battle
Creek is currently zoned for residential use, while the portion within Bedford Township is
zoned for agricultural use. Letters from the Battle Creek and Bedford Township planning
commissions documenting that the landfill is a legal nonconforming land use are included in
Appendix C. These letters satisfy the requirements of Section 20120a(6) of Part 201. The Real
Estate Property Tax identification numbers for the five properties to which the restrictive
covenants apply are City of Battle Creek properties)
and^^^^^^^J, and Bedford Township property |
The area around the landfill is serviced by municipal water from the City of Battle Creek,
Bedford Township, and Pennfield Township water supply systems. Private wells within a
0.5-mile radius of the landfill in downgradient or sidegradient locations were identified during
the Phase I hydrogeologic study (RMT, 1991). All of these wells except for one (at^^^^^^J
^^^) were abandoned in accordance with state requirements. Because the owner of the house
could not be located (the house is reportedly still abandoned [personal
communication with	who lives	the Calhoun County
Health Department attached an affidavit to the deed for the property
advising that the water well is located in an area where the groundwater is contaminated. All
other properties within 0.5 mile of the landfill that had private wells have been connected to the
Battle Creek municipal water supply.
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In March and April 1998, another survey of water supply wells around the landfill was
conducted to confirm that no new wells had been installed in the area of the proposed off-site
institutional controls since the 1991 wellhead survey. The areal limits of the 1998 search were
Morgan Road to the north, Washington Avenue to the east, Parkway Drive to the south, and
Limit Stieet/Waubascon Road to the west (note that this area extends further north than the
proposed area of off-site institutional controls). The following sources of information were
used in conjunction with two site reconnaissance visits to complete the 1998 survey:
¦	The City of Battle Creek Water Department records
¦	The Calhoun County Department of Environmental Health private well records
¦	The City of Battle Creek Department of Engineering records
¦	The Bedford Township Department of Engineering records
¦	A database search by Environmental Data Resources, Inc.
Eight private water supply wells were identified within the area of the survey, however, only
the well at	was within the proposed area of institutional control. The seven
other wells were located at least 1,500 feet northwest of the North Waste Cell. Additional
information about the 1998 water supply well survey, including a map showing the area of the
survey, the preliminary area of proposed off-site institutional controls, and the private wells
identified, is provided in Appendix D.
2.2 Hydrogeologic Conditions
The uppermost geologic stratum beneath the site consists of 40 to 172 feet of sandy outwash
with a discontinuous layer of clay present in some areas (Figure 2). The thick outwash sands
overlie up to 107 feet of silty sandstone and siltstone. The silty sandstone, in turn, overlies
more than 80 feet of shale with occasional sandstone interbeds.
The outwash is composed of fine- to medium-grained sand and silty sand, with an apparently
continuous clay lens in the northern third of the study area. The hydraulic conductivity of the
outwash ranges from 1 x 10-4 to 2 x 10-2 cm/s, with a geometric mean of 3 x 10° cm/s; the
hydraulic conductivity of the underlying sandstone is slightly lower, with a geometric mean of
4 x 10-1 cm/s. No laterally continuous low-permeability strata separate the outwash from the
bedrock in the southern two-thirds of the study area.
The water table in the study area is approximately 12 feet below grade at the southern end of
the site, and 67 feet below grade 1,800 feet south of the landfill. Groundwater flow in the
outwash and sandstone under the eastern and central portions of the site is generally to the
southwest, toward the Kalamazoo River. A water table map and potentiometric surface map
for October 1995 are shown on Figures 3 and 4, respectively (water level measurements
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collected in 1996 [RMT, 1996b] and 1998 [RMT, 1998] gave rise to similar interpretations).
Groundwater along the western edge of the site in the outwash is deflected to the west, toward
Sperrv Drain. Groundwater velocities in the sandy outwash and the sandstone range from
approximately 60 to 10 feet per year, respectively. There is a downward component of flow
across most of the study area, such that flow migrates down through the sandy outwash into
the sandstone, as it flows to the south-southwest. Upward gradients exist within the outwash
near Sperry Drain.
2.3 Source Characterization
The extent of waste and the nature and extent of leachate at the landfill have been investigated
through geophysical methods, soil borings, historical aerial photograph examination, and
measurements of leachate head and chemistry.
In November 1995, thirty-one test pits were excavated along certain segments of the landfill
boundary to further evaluate the lateral extent of waste and the thickness of the cover
(RMT, 1995d). In general, the findings were consistent with the geophysical surveys and soil
borings that had been performed as part of the RI. In certain areas, however, the waste
boundaries needed to be adjusted. For instance, along the western half of the northern
boundary of the North Waste Cell, the waste was found to extend further north than previously
estimated. Additionally, on the south side of the North Waste Cell, the limits of waste were
found to extend further south. Along the southwest side of the South Waste Cell, the waste
was found to extend further west than previously estimated; and on the northeast side of the
South Waste Cell, the limits of waste extend further north and east. The pre-constraction areal
extent of waste is shown on the plan view figures contained in this RAP.
The waste is covered by a sand and gravel layer that varies in thickness from 0 to 10 feet. The
thickness of the existing cover materials was evaluated with greater accuracy in November 1995
(RMT, 1995d). The cover thickness was tested on a 100-foot grid in both waste cells to identify
areas where additional general fill will be needed to meet the final cover design criteria of
12 inches of general fill and 6 inches of topsoil, as described in the FS. The thickness of the
cover was tested through a combination of Geoprobe® borings driven at least 12 inches into the
cover materials and test pits excavated at least 12 inches deep. In general, much of the waste
areas were found to already contain at least 12 inches of cover material on top of the waste.
The waste is between 4 feet thick and 45 feet thick at the edges of the cells. The maximum
measured thickness of waste in the North Waste Cell is 45 feet with an estimated average
thickness of 25 feet. The maximum measured thickness in the South Waste Cell is 25 feet with
an estimated average thickness of 15 feet. The approximate volume of waste in the North
Waste Cell is 1,400,000 cubic yards and in the South Waste Cell is 920,000 cubic yards.
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The waste is variablv degraded, and consists of sand and gravel, interbedded with common
municipal solid waste materials (packaging and paper, wood chips, plastic sheeting, and glass
and metal).
Leachate heads have been measured in 12 leachate head wells —seven in the North Waste Cell
and five in the South Waste Cell (Figure 3). On the basis of the leachate head measurements,
the logs from soil borings that fully penetrated the landfill, and the water table configuration,
the water table is likely in contact with landfill waste in the southern portion of the North
Waste Cell, and up to 10 feet of waste is below the water table in the southern portion of the
South Waste Cell.
As was common practice approximately 40 years ago when this landfill was built, there is no
liner beneath the waste, and no active leachate collection system. Leachate is present within the
landfill as a result of the higher permeability of the existing landfill cover (typical measured
hydraulic conductivity of 3 x lO3 cm/s) as compared to the lower permeability of the waste
(typical measured hydraulic conductivity of 2 x 10"6 cm/s), the topographic relief, and the
sparse vegetation on the landfill surface. Dissipation of the leachate head within the landfill is
hindered by the low bulk hydraulic conductivity of the waste, compared to the underlying
outwash.
The leachate was found to contain up to 16 VOCs, elevated ammonia and specific conductance,
and above background levels of metals. The highest concentrations of VOCs in the leachate
were tetrahydrofuran (up to 1,600 ng/L), toluene (up to 330 ng/L), xylenes (up to 290 ng/L),
methylene chloride (up to 170 ng/L), and ethyl benzene (up to 120 ng/L). Other VOCs
detected in the leachate at levels above 10 jag/L include chlorobenzene (up to 87 ng/L),
diethylether (up to 61 |ig/L), diethoxymethane (up to 57 ng/L), 1,1-dichloroethane (up to
22 Hg/L), and trichloroethene (up to 13 ng/L). Vinyl chloride was detected at 1 ng/L.
Inorganic constituents of interest in the leachate include lead (2,400 ng/L) and arsenic
(470 ug/L). A full characterization of the leachate is provided in the Phase III report
(RMT, 1993a).
2.4 Nature and Extent of Contamination
The RI found that groundwater affected by the Cereal City Landfill contains low levels of VOCs
and/ or elevated levels of arsenic, ammonia, iron, and manganese. As many as 12 VOCs have
been detected at quantifiable levels in groundwater samples from the on-site monitoring wells.
The highest concentrations of VOCs in on-site monitoring wells during the August 1992
sampling event were for chloroethane (up to 92 ng/L), tetrahydrofuran (up to 120 ng/L),
xylenes (up to 87 ug/L), and diethyl ether (up to 50 ug/L). (Because the August 1992 sampling
event was part of the RI and included the most sampling points and analytical parameters of
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any of the sampling events at the site, the data from this sampling event are used as a common
point of reference for describing groundwater conditions. This is a conservative basis because
the concentrations of landfill constituents have generally decreased since 1992.) The highest
concentrations of constituents detected in off-site monitoring wells were for tetrahydrofuran
(up to 27 ng/L) and diethyl ether (up to 12 ng/L). The other VOCs detected in off-site
monitoring wells were present at concentrations less than 5 ng/L. The areal distribution of
chemicals in groundwater and leachate for the August 1992 sampling event is shown on
Figure 5 and in cross section on Figures 2 and 6.
The downgradient areal extent of groundwater affected bv the landfill that exceeds
concentrations of regulatory concern was determined by comparing the concentrations of
landfill-related constituents in monitoring wells to the Part 201 Generic Residential Cleanup
Criteria (GRCC; MDEQ, 1998) and, for metals, to naturally-occurring background levels.
Vinyl chloride was detected in groundwater in eight downgradient monitoring wells, two of
which are off-site (W-12BC and W-12C). On-site concentrations of vinyl chloride were 2 ug/L
(at W-4C) or less. Vinyl chloride was detected in two off-site piezometers (0.6 ng/L at VV-12BC
and 0.7 pg/L at W-12C) at levels that are below both the practical quantitation limits and the
GRCC (2 jig/L).
Groundwater at 10 of the 17 on-site monitoring wells contained dissolved arsenic at
concentrations that ranged from less than 1 ng/L to 98 pg/L (at OB-8R). Arsenic was detected
off-site at a maximum concentration of 9.8 ng/L (at W-12C), which is slightly above the
background concentration of arsenic of 4.2 |ig/L (RMT, 1994b), but well below the GRCC for
arsenic of 50 jig/L.
Groundwater affected by the landfill also has elevated levels of ammonia (up to 280 mg/L).
Groundwater in the vicinity of this site that has not been affected by the landfill contains
ammonia at concentrations from less than 0.1 mg/L to 3 mg/L, usually at less than 1 mg/L.
The elevated ammonia coincides with a zone of chemically reducing conditions that are
typically found around municipal landfills. At this particular site, ammonia concentrations
over 3 mg/L were found to be a good indicator of the extent of groundwater affected by the
landfill. Although there is not a GRCC for ammonia, ammonia is a potential source of nitrate
for which there is a GRCC (10 mg/L). When the measured concentration of ammonia is
converted to a nitrate equivalent and then added to the measured concentration of
nitrate+nitrite, the hypothetical total concentration of nitrate exceeds the nitrate GRCC at well
nest W-12, but not at well nest W-17. It should be noted however, that the measured levels of
nitrate+nitrite are orders-of-magnitude less than the calculated nitrate equivalent value.
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The concentration of iron exceeds the GRCC which is the aesthetic drinking water value, at
W-13C, VV-17B, and W-17C. The State of Michigan has not established a health-based criteria
for iron. The concentrations of manganese also exceed the GRCC aesthetic drinking water
value, but not the health-based criteria, at W-13C and W-17B.
In summary, the downgradient extent of the plume of groundwater affected by the landfill is
estimated to be 20 feet southwest of well nest W-13 and 110 feet southwest of well nest W-17.
These downgradient limits were defined by the iron and manganese concentrations in
piezometers at well nest W-13 and W-17, which exceeded the GRCC aesthetic drinking water
values.
The vertical extent of the aquifer affected by the landfill ranges from the water table beneath
and near the landfill (at elevation of about 850 M.S.L.) through the outwash and much of the
underlying sandstone (the Marshall Formation) downgradient of the landfill. Analvtes other
than VOCs that are indicative of groundwater contamination attributable to the landfill have
not been detected in the wells screened at the base of the sandstone or at the top of the shale at
any of the locations investigated. In the northern portion of the site, which is underlain by the
lean clay layer in the sandy outwash, the clay layer appears to impede the downward
migration of groundwater contaminants.
Groundwater was sampled and analyzed on a quarterly schedule from October 1993 to
July 1996, in accordance with the interim groundwater monitoring plan (RMT, 1993d). The
results of these monitoring activities, which were submitted to the MDNR/MDEQ, indicate a
continued trend of decreasing concentrations of VOCs, in both the on-site and off-site
monitoring wells. This trend is evident from an examination of sampling data from 1981
through 1996, and is discussed in detail in the "Report of an evaluation of the effectiveness of
landfill covers and groundwater containment in remediating groundwater at the Cereal City
Landfill" (RMT, 1995c).
In April 1998, groundwater samples were collected from three piezometers that are located
progressively farther downgradient along a flow line of the plume of groundwater affected by
the landfill. These samples were collected to assess potential changes in groundwater
chemistry downgradient of the landfill since July 1996. The results were consistent with
historical observations at the site (RMT, 1998).
2.5 Contaminant Fate and Transport
Leachate generated within the landfill has affected groundwater quality beneath the landfill
and, to a lesser degree, groundwater downgradient of the site. On-site concentrations of
arsenic and benzene are greater than the generic residential and industrial cleanup criteria.
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However, surface water runoff and associated sediment from the site do not contain VOCs or
metals at concentrations above the GRCC. Surface water and sediment transport from the site
would not be expected to be of concern because precipitation infiltrates the sandy soil readily,
and there is no significant potential pathway for contaminant migration from the site for these
media. The maximum on-site concentrations of metals and VOCs in soil are well below the
Part 201 generic industrial cleanup criteria.
In August 1992, up to 10 feet of leachate were observed in leachate head wells. Because the
waste cells were not constructed with low-permeabilitv liners, leachate is migrating from the
base of the landfill to the water table and entering the groundwater flow system. In addition, a
portion of the waste in both cells is below the water table. The relatively low permeability of
the waste itself, however, impedes the flow of leachate into the aquifer.
Groundwater above the lean clay layer beneath the western side of the North Waste Cell flows
to the west, discharging to Sperry Drain. Stream sediment samples and surface water samples
from Sperry Drain collected and analyzed by RMT (RMT, 1992) and the MDNR (MDNR, 1992)
did not contain detectable levels of landfill leachate constituents. Based on observed hydraulic
gradients and hydraulic conductivities, it was estimated that a total of approximately
4 gallons/minute of groundwater would enter the entire reach of Sperry Drain from the landfill
(RMT, 1993a). Groundwater beneath the eastern side of the North Waste Cell and beneath the
South Waste Cell flows to the southwest, toward the Kalamazoo River.
Dissolved parameters indicating landfill impacts to groundwater have been detected at well
nests OB-1, W-12, and, to a lesser degree, at W-17. Concentrations of landfill indicator
constituents, including VOCs, metals, and other inorganic parameters, decrease as groundwater
flows downgradient from the landfill, both to the west toward Sperry Drain, and to the
southwest toward well nests W-12 and W-17.
Groundwater flowing in outwash and sandstone beneath the landfill is moving at an average
linear velocity of approximately 60 and 10 ft/yr, respectively. Variations in the hydraulic
conductivity in the aquifer cause mixing, or dispersion, of contaminated and unaffected
groundwater in the aquifer, and thereby reduce contaminant concentrations.
Chemical and biological processes are reducing the concentrations of many of the landfill
contaminants. The result of these natural processes is evident by the differential removal of
readily degraded constituents such as xylenes and ethylbenzene at downgradient locations,
while more conservative landfill indicators such as ammonia, tetrahydrofuran, and
chloroethane persist much further downgradient. Further evidence of attenuation of solutes in
the leading edge of the plume is that indicator constituents (VOCs, ammonia, nitrate, or metals)
were not detected or calculated (for nitrate) above the GRCC (except for low levels of iron and
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manganese) at well nest W-17, even though the leading edge of the plume likely could have
reached 1,800 feet downgradient from the landfill in the time since the landfill began operation,
based on the calculated average linear velocity for groundwater at the site.
The basic processes of attenuation and biogeochemical degradation are discussed in the report
of an evaluation of the effectiveness of landfill covers and groundwater containment in
remediating groundwater at the Cereal City Landfill (RMT, 1995c). This report describes the
biogeochemical processes that are reducing the concentrations and the mass of leachate
constituents in groundwater, and supports the hypothesis that the arsenic in groundwater is
being removed from solution by coprecipitation with iron. The study also concludes that the
VOCs are being adsorbed onto free organic carbon in the aquifer and are being degraded
abiotically and biologically, and that ammonia is undergoing nitrification as chemically
reduced groundwater from near the landfill is mixed with oxygenated water farther from the
landfill.
Potential exposure to groundwater affected by the landfill is controlled by a deed restriction for
the landfill and by local ordinances that prohibit the installation of water supply wells within
certain areas around and downgradient of the landfill. Current residences within the restricted
areas (except	which is now owned by the City of Battle Creek as a result
of delinquent taxes) were previously connected to municipal water. Future property
improvements (new houses or businesses) within the restricted area will also need to use
municipal water. The institutional controls to prevent groundwater use on the landfill and in
certain off-site areas are described in detail in Subsection 4.5.
2.6 Landfill Gas Migration and Control
Passive gas vents were installed in the interior of both waste cells in 1981. An active gas
extraction system was installed along the southwestern perimeter of the South Waste Cell in
1981, and was upgraded in 1993 by adding more extraction wells and monitoring probes near
the residences along the southern and western borders of the South Waste Cell (Figure 7). The
active gas extraction system consists of extraction wells, interconnecting piping, a condensate
collection tank, a blower, a flame arrestor, and a utility flare. The flare is not lit because the
quality of the collected gas is not suitable for safely sustaining combustion. Instead, the gas is
vented to the atmosphere from an elevated stack next to the blower building. There are gas
probes along much of the perimeters of both cells (Figure 8) that are monitored once each
quarter.
Prior to the RA construction activities, off-site migration of landfill gas above the LEL was
occurring along the northern property boundary and the southeastern corner of the North
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Waste Cell, but was not present in areas that are close to residences. This was a potential
concern that was addressed in each of the remedial alternatives considered in the F5.
The concentrations of methane and oxygen (on a volume-to-volume basis), and the pressure in
the gas probes, the extraction wells, at the blower, and in the extraction system header pipe at
the well heads, have been measured quarterly. The valves on the gas extraction wells are
adjusted to maintain methane levels below detectable concentrations in the gas probes along
the site perimeter and the concentration of methane in the header pipe below the LEL. Because
of the low methane production of the waste in the area of the older extraction wells, and the
placement of the new extraction wells along the waste perimeter, the extracted methane content
from the South Waste Cell is low.
In addition, there are continuous ambient air monitors (similar to a smoke alarm) in the
basements of seven buildings on Hubbard Street (at^^^^^^^^^^^^^^^^^Uand^J
adjacent to the landfill. These monitors emit an audible alarm if the
concentration of combustible gas (methane) in the air around them exceeds 25 percent of the
LEL. The presence and operabiiity of these alarms are checked once each year.
2.7 Baseline Risk Assessment
A baseline risk assessment (RMT, 1993a) was performed to characterize the nature and estimate
the magnitude of potential environmental and public health effects associated with the
constituents of concern identified at the CCL. The baseline risk assessment was based on the
information contained in the Phase 11 and Phase III hydrogeologic studies (RMT, 1992 and
1993a) and the Site Screening Inspection (MDNR, 1992), and considered potential adverse
health effects that could result under current and future land use. The risk assessment was
conducted in accordance with the USEPA's guidance for Superfund baseline risk assessments
(USEPA, 1989a).
The baseline risk assessment was conducted in 1993 when the MDNR's acceptable risk level for
evaluating site-related risks was one in one million (1 x 10-6) excess upperbound lifetime cancer
risk. Although the MDEQ's acceptable risk level under Section 20120a(4) of Part 201 of was
increased to one in one hundred thousand (1 x lO*5), the baseline risk assessment was not
revised because the new acceptable risk level is less conservative and because the overall
conclusion of the baseline risk assessment is unchanged. The baseline risk assessment
concluded that, without institutional controls prohibiting construction of water supply wells
directly downgradient of the landfill, a resident adjacent to the southwestern corner of the
landfill could potentially be exposed to groundwater concentrations above the GRCC.
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For purposes of the baseline risk assessment, the landfill was assumed to be at a steady-state
condition, even though the concentrations of constituents are expected to decrease over time
due to the gradual reduction of source material via biodegradation and venting through the
landfill cover.
Under pre-RA land use, the only completed exposure pathway is for site workers who may be
exposed to constituents of concern in affected surface soil during routine site maintenance
which occurs approximately once per month. Because the site is fenced, potential receptors are
limited to site workers. The groundwater pathway is not completed because water supply
wells are no longer in use in the area of affected groundwater.
Under pre-RA land use, the total estimated risk for a site worker under Reasonable Maximum
Exposure (RME) assumptions was 3 x 107, or three in ten million additional cancer occurrences
in a 70-year lifetime, which is an order of magnitude less than the former Act 307 1 x 10-6
acceptable risk level. (The total estimated risk is two orders of magnitude less than the current
Part 201 1 x 10"5 acceptable risk level.) The estimated site hazard index under RME assumptions
is 0.02, which is 50 times less than limit of 1.0.
Under future land use, which was assumed to still be a closed landfill, the site worker exposure
was expected to be the same as under current land use. In addition, the future land use
scenario included a hypothetical resident who owns a home directly adjacent and
downgradient to the landfill boundary, and whose water supply well is screened in the
outwash or sandstone aquifers in the absence of institutional controls on groundwater use.
This hypothetical future nearby resident served as the RME receptor.
The total estimated risk for the hypothetical resident under future land use under RME
assumptions was 3 x 10°, which is above the then-current 1 x 10-6 MDNR acceptable risk level,
as well as the current 1 x 10-5 MDEQ acceptable risk level. This risk was primarily associated
with the ingestion and dermal absorption of dissolved constituents in groundwater over a 70-
year lifetime, specifically arsenic, and to a lesser extent, vinyl chloride and benzene. The
estimated total site hazard index for the RME receptor was due to the ingestion of arsenic
(hazard index=10) and ammonia (hazard index=8) in groundwater. The total hazard index was
19 times higher than 1.0, which is both the USEPA's and the MDNR's level of concern.
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The estimated excess upperbound lifetime cancer risks and hazard indices for pre-RA and
future land use were summarized as follows:
Estimated	Estimated
Pre-RA Land Use (closed landfill)	Risk	Hazard
Site Worker -	inhalation of soil	2xl0'7	0.00005
-	dermal absorption from soil	3 x 10"8	0.006
-	incidental ingestion of soil	6 x 1Q-6 0.01
Total	3 x 10*7 0.02
Future Land Use (closed landfill)
Site Worker - inhalation of soil	2 x 10-7	0.00005
-	dermal absorption from soil	3 x 10"8	0.006
-	incidental ingestion of soil	6 x 1Q-6	0.01
Total	3xlOr	0.02
Resident - ingestion of VOCs and	3xl0'3	19
nonvolatile chemicals, with
inhalation and dermal
absorption of VOCs in
groundwater
- dermal absorption of	6 x 10-6	0.05
nonvolatile chemicals in
groundwater
Site Total
3 x 10-3
19
The risk and hazard estimates summarized above are likely overestimated due to the
conservative assumptions required for RME in Superfund baseline risk assessments.
Potential adverse health effects of landfill gas emissions on ambient air quality were assessed
by: 1) collecting and analyzing gas samples from points within the waste; 2) estimating the
overall rate of gas emissions from the landfill based on estimates of the filling history and types
of waste materials accepted; 3) calculating a mass flux rate of landfill constituents into the air
based on the results of the first two tasks; 4) using an air dispersion model to estimate the
concentrations of landfill gas constituents at the property lines; and 5) comparing the maximum
modeled property line concentrations to the Michigan Acceptable Ambient Concentrations
(AACs) that were established by the MDNR. The result of this assessment (RMT, 1993b) was
that the landfill gas emissions do not exceed the AACs.
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Qualitative Assessment of Risks and Hazards Associated With Landfill Gas Migration
The baseline risk assessment did not include a quantitative assessment of potential health risks
and hazards associated with off-site landfill gas migration. Under pre-RA land use, landfill gas
appeared to be migrating off-site only along the northern property boundary and the
southeastern corner of the North Waste Cell. Currently, there are no occupied structures near
these landfill boundaries. If buildings are constructed close to these boundaries of the landfill
in the future, landfill gas could potentially enter a building(s) through cracks or utility line cuts
in the foundation and accumulate in a building to concentrations above the lower explosive
limit (LEL). Landfill gas that accumulates in a building could also present a potential
inhalation exposure risk to the building occupants. Therefore, the qualitative assessment of
potential health risks and hazards associated with landfill gas migration along the northern
property boundary and the southeastern corner of the North Waste Cell indicates that under a
hypothetical future land use scenario, this contaminant migration pathway could be completed
and could pose unacceptable health risks and/or hazards.
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¦I.
!¦
Section 3
Identification of ARARS
3.1 Introduction
In accordance with the Michigan Natural Resources and Environmental Protection Act
(NREPA) (Act 451 of the Public Acts of 1994, as amended), Part 201, "Environmental Response,"
and the National Oil and Hazardous Substances Pollution Control Plan (NCP), the remedial
action selected for the CCL site must comply with federal and state environmental laws that are
either applicable or relevant and appropriate requirements (ARARs). The state requirements
for selecting and implementing environmental response activities are set forth in Sections 20118
through 20120d of Part 201. Guidance for assessing federal ARARs is contained in the USEPA's
manuals entitled "CERCLA Compliance with Other Laws" (USEPA, 1988), and "CERCLA
Compliance with Other Laws Manual Part II: Clean Air Act and Other Environmental Statutes
and State Requirements" (USEPA, 1989b).
In order to be considered as an ARAR, a requirement must be either applicable or relevant and
appropriate. As defined in the NCP, 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 CERCLA site" (40 CFR § 300.5,1991). 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 CERCLA site,
address problems or situations sufficiently similar to those encountered at the CERCLA site
that their use is well suited to the particular site" (40 CFR § 300.5,1991).
Another category of criteria that may affect the selection of a remedy for a site is the "To Be
Considered" (TBC) criteria. TBC criteria are guidelines or advisories that are issued by the
federal or state government, but which have not been promulgated and are not legally binding.
These guidelines, however, may be used to ensure protection of public health and the
environment if they are not superseded by ARARs. If there is not an ARAR that addresses a
specific condition at a site, the TBC criteria can be used to establish remedial guidelines or
targets. Even when TBC criteria are used, the requirements imposed on remedy selection,
including cost-effectiveness, still apply (55 Fed. Reg. 8745, March 8,1990).
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Evaluation of remedial alternatives considered the following three categories of ARARs and
TBC criteria: chemical-specific, action-specific, and location-specific. These categories are not
always mutually exclusive and often overlap to some degree. The chemical-specific
ARARs/TBC criteria are numeric requirements that are typically health-based criteria using a
standard set of exposure and toxicity assumptions. The action-specific ARARs/TBC criteria are
technology- or activity-based requirements or limitations. The location-specific ARARs/TBC
criteria are requirements or limitations given the physical setting of the site. The tables
referenced in Subsections 3.3, 3.4, and 3.5 that list the potential ARARs and TBC criteria for the
CCL were presented to the MDNR in preliminary form prior to the promulgation of Act 451
(RMT, 1993g).
3.2 Part 201 of Act 451
The state requirements for selection and implementation of environmental response activities
are contained in Sections 20118 through 20120d of Part 201 of Act 451. The MDEQ
Environmental Response Division (ERD) operational memoranda, along with portions of the
administrative rules promulgated for the former Act 307, provide additional guidance.
Section 20118 of Part 201 describes the criteria that the MDEQ may consider in evaluating
whether a selected remedial action is protective of public health, safety, or welfare, or the
environment. Specifically, Section 20118(2)(b) requires that the remedial action "attain a degree
of cleanup and control of hazardous substances that complies with all applicable or relevant
and appropriate requirements, rules, criteria, limitations, and standards of state and federal
environmental law." This requirement is expanded upon in Section 20118(5), which references
rules R299.5705(5) and R229.5705(6), Michigan Administrative Code (MAC), as criteria for
assessing whether a remedial action attains the necessary degree of cleanup and control of
hazardous substances. Rule R299.5705(5) requires that "the horizontal and vertical extent of
hazardous substance concentrations in an aquifer above the higher of either the concentration
allowed by R299.5707 or the concentration allowed by R299.5709 shall not increase after the
initiation of remedial actions to address an aquifer...." Rule R299.5705(6) states that "all
remedial actions which address the remediation of an aquifer shall provide for removal of the hazardous
substance or substances from the aquifer, either through active remediation or as a result of naturally
occurring biological or chemical processes which can be documented to occur at the site" (emphasis
added).
R299.5705(6) is particularly relevant at the CCL site because the groundwater quality data
support the occurrence of a significant degree of natural biodegradation. More discussion of
the site-specific conditions and of remedial alternatives that incorporate natural biodegTadation
are included in a report entitled "Report of an Evaluation of the Effectiveness of Landfill Covers
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and Groundwater Containment in Remediating Groundwater at the Cereal City Closed
Landfill" (RMT, 1995c).
3.3	Chemical-Specific ARARs and TBC Criteria
Tables 1 and 2 list the chemical-specific ARARs and TBC criteria for the CCL, with Table 1
listing the State of Michigan requirements and Table 2 listing the federal requirements.
Michigan's generic cleanup criteria are contained in the ERD's Integrated Table of Part 201
Cleanup Criteria and Screening Levels (MDEQ, 1998). In general, the federal groundwater
criteria are the maximum contaminant levels (MCLs) in the Safe Drinking Water Act,
40 CFR 141.11 through 141.16.
There is no Michigan cleanup criterion for ammonia in groundwater nor are there primarv or
secondary federal drinking water standards for ammonia. The only published criteria for
ammonia in groundwater is from the USEPA Office of Water ''Drinking Water Regulations and
Health Advisories' (USEPA, 1994) which lists a draft health advisory of 30 mg/L as nitrogen (or
31.6 mg/L as ammonia). The draft health advisory is based on the USEPA report "Drinking
Water Health Advisory for Ammonia," which concludes that "...ammonia at low concentration, per
se, is not very toxic" (USEPA, 1991), and goes on to recommend that the taste and odor level of
34 mg/L as nitrogen be used as a guide for the lifetime health advisory. The highest measured
concentration of ammonia in groundwater at the CCL was 280 mg/L as nitrogen (at well OB-
1AR in October 1991). Table 2 lists a chemical-specific TBC for ammonia in groundwater based
on the USEPA health advisory.
ERD guidance (MDEQ, 1998) requires that all potential sources of nitrogen-nitrate be combined
and compared to the nitrate criteria. Therefore, the reported concentration of ammonia must be
converted to a hypothetical nitrate equivalent and then added to the reported laboratory result
for nitrate+nitrite, this sum is compared to the GRCC for nitrate (10 mg/L).
3.4	Action-Specific ARARs and TBC Criteria
The action-specific ARARs and TBC criteria are determined by the specific activities included in
the remedial alternatives being considered. Tables 3 and 4 list the potential action-specific
ARARs and TBC criteria for the CCL, with Table 3 listing the Michigan requirements and
Table 4 listing the federal requirements. The most significant of these criteria as pertaining to
the remedy selection for CCL are the state requirements for the collection of landfill gas and
the federal requirements for discharge of groundwater extracted from the aquifer. The
MDNR had determined that Part 115 of Act 451, formerly Act 641, is not an ARAR for this
site (MDNR, 1995). Rather, the MDNR stated that Part 115 is a TBC for the CCL.
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3.5	Location-Specific ARARs and TBC Criteria
The location-specific ARARs and TBC criteria are restrictions on the activities that can be
undertaken at a site based solely on the site's location. Site activities may be limited in order to
protect floodplains, critical habitats, and/or wetlands. Tables 5 and 6 list the potential location-
specific ARARs and TBC criteria for the CCL, with Table 5 listing the Michigan requirements
and Table 6 listing the federal requirements. These criteria were not major factors in the
evaluation of remedial alternatives for the CCL.
3.6	Identification of Site-Specific ARARs
Certain of the ARARs and TBC criteria have the most direct impact on remedy selection.
Although both federal and state requirements apply, the primary requirements for the CCL are
contained in Part 201.
Target Groundwater Clean-Up Criteria
The RAP for the Cereal City Landfill is based on Limited Residential land use off-site
and on site-specific criteria on-site. Deed restrictions and institutional controls will be
used to prevent exposure to those portions of the aquifer affected by the site. While
current off-site groundwater quality in the portion of the aquifer affected by the site
does not meet all of the generic residential cleanup criteria (GRCC), these criteria may
be met in the future as a result of natural attenuation and degradation of landfill
constituents. Therefore, the target groundwater cleanup criteria for off-site portions of
the aquifer affected by the landfill are the Part 201 GRCC (MDEQ, 1998), and the target
groundwater cleanup criteria for on-site portions of the aquifer are the Part 201 generic
industrial and commercial II, III, and IV drinking water criteria (MDEQ, 1998).
The site-specific target groundwater cleanup criteria for landfill-related constituents
detected at, and near the site are shown in Table 7. The list of constituents for which
site-specific target groundwater cleanup criteria are shown includes those VOCs that
have been detected in groundwater from October 1993 through July 1996, as well as the
inorganic constituents detected above the GRCC. These parameters were selected on
the basis of 14 years of monitoring data, which has shown them to be representative of
the nature of constituents being released from this landfill. Table 7 also lists the
maximum concentrations of the landfill-related constituents detected in the on-site and
the off-site monitoring wells during the five most recent monitoring events that were
conducted from October 1995 through April 1998 (RMT, 1996 and 1998).
As shown in Table 7, the only on-site exceedences of the Part 201 generic industrial
cleanup criteria during the 1996 monitoring year were for arsenic and total nitrate (a
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hypothetical value). The only off-site exceedence of the Part 201 generic residential
cleanup criteria during the 1996 monitoring year was for total nitrate (a hypothetical
value). However, because well OB-8R is on the western border of the landfill, and the
concentration of arsenic in well OB-8R was as high as 110 jig/L during the 1996
monitoring year, it is likely that arsenic is also present off-site at concentrations above
50 |ig/L (the GRCC).
Soil Clean-Up Criteria
The results of the RI (RMT, 1993a) indicated that trichloroethene (TCE) and
tetrachloroethene (PCE) were the only VOCs detected in surface sediment samples, and
that no VOCs were detected in deeper soil samples. TCE and PCE were detected at
estimated concentrations less than 1 ng/kg, which is less than the target method
detection limit of 10 ng/kg for these compounds (ERD Operational Memorandum #6,
Revision 3). The locations of the four soil samples in which TCE and/or PCE were
detected did not correspond well with the detections of these constituents in
groundwater or leachate samples. In addition, arsenic was detected in surface soil at
concentrations ranging from 1.6 to 12.4 mg/kg. The concentrations of TCE, PCE, and
arsenic are all well below the direct contact values for generic industrial land use
(MDEQ, 1998) and which are the site-specific soil cleanup criteria for these constituents
at the CCL.
On the basis of the baseline risk assessment (RMT, 1993a), there are no unacceptable
current or future risks or hazards to site workers as a result of exposure to arsenic in
soil. Potential future exposure to residents will be controlled by the restricted access to
the site. Future potential residential use of the site is prohibited by deed restrictions.
The naturally occurring concentrations of barium, manganese, mercury, and zinc In soil in the
vicinity of the CCL were calculated on the basis of additional soil samples that were collected in
areas unaffected by the landfill (RMT, 1994a). The maximum on-site concentration of each of
these metals is less than the corresponding site-specific background concentration as well as the
direct contact value for generic Industrial land use (MDEQ, 1998). The direct contact values for
industrial land use are the proposed soil cleanup criteria for these metals at the CCL. The
specific Part 201 soil clean-up criteria proposed for this landfill are shown in Table 8.
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¦¦
Section 4
	Selected Remedial Action
4.1 Remedial Action Objectives
On the basis of the site characterization studies and the baseline risk assessment, the following
remedial action objectives were developed:
¦	To ensure that the extent of groundwater affected by the landfill above the applicable
criteria does not increase in dimension or concentration (R 299.5705[5] and [6])
¦	To prevent potential exposure to constituents of concern at levels above the applicable
criteria (Section 20118[2][b])
¦	To prevent possible direct contact with the waste in the future by either site workers or site
trespassers
¦	To prevent possible ingestion of groundwater affected bv the landfill in the future bv either
site workers or nearby residents
¦	To prevent potential accumulation of subsurface landfill gas in buildings on or near the
landfill
¦	To monitor the progress of the natural processes that are biodegrading landfill constituents
in the groundwater
¦	To monitor changes in the concentrations of landfill constituents in groundwater and the
areal and vertical extent of groundwater affected by the landfill.
¦	To develop and implement contingency response plans for groundwater and landfill gas
that will be used to respond to unanticipated or changing site conditions.
Remedial action objectives are not needed for on-site soil, surface water, sediment, and air
because there were no adverse effects identified for these media in the Phase III Study and
Baseline Risk Assessment (RMT, 1993a) or the Characterization and Evaluation of Landfill Gas
Emissions (RMT, 1993b). Specifically:
¦	On-site surface soil at the landfill does not contain constituents of concern at
concentrations greater than the Part 201 generic industrial soil cleanup criteria for direct
contact, nor does it result in an unacceptable risk to site workers via inhalation, dermal
absorption, or incidental ingestion.
¦	No VOCs were detected in surface water and sediment in areas likely to be affected by the
landfill (i.e., the Sperry Drain). Inorganic constituents detected in surface water were at
levels below the state generic groundwater-surface water interface (GSI) criteria
(MDEQ, 1998). The generic GSI criteria are, with the exception of arsenic, the more
restrictive of the State of Michigan's Rule 57 value (Rule 323.1057 of Part 4 of Part 31 of Act
451), and the Federal National Toxics Rule (FR, December 22,1992), where both values are
available. Inorganic constituents in sediment were detected at levels that were either less
than 20 times the generic GSI criteria or comparable to background levels.
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¦	Air quality sampling, analysis, and dispersion modeling resulted in predicted ambient air
concentrations that were well below the Acceptable Ambient Concentrations established
by the MDEQ.
4.2 Selected Remedial Action
The selected remedial action for the Cereal City Landfill includes the following components:
¦	Implementing institutional controls, including:
Maintenance of the existing perimeter fence and secured gate to restrict site access
An Agreement for a Site-Specific Cleanup, which includes a restrictive covenant on
the landfill property deed. The restrictive covenant will meet the requirements of
Part 201, Section 20120b(4) and Rule 719(3), MAC.
Local ordinances that prohibit construction of off-site water supply wells in certain
areas around the landfill (primarily in the downgradient direction to approximately
110 feet southwest of well nest W-17) have been passed by the City of Battle Creek
and Bedford Township to prevent potential future exposure to landfill constituents
via ingestion or dermal absorption of groundwater affected by the landfill. These
institutional controls meet the requirements of Part 201, Section 20120b(5).
The proposed Agreement for a Site-Specific Cleanup, the restrictive covenant for the
landfill property, and the local well ordinances are described in more detail in
Subsection 4.5.
¦	Constructing a soil cover over the waste disposal areas to prevent potential direct contact
with the waste. This cover would involve the following:
Regrading the cover to control surface water
Placing additional general fill over the waste cells to achieve a minimum thickness
of 12 inches of general fill over all waste disposal areas
Placing 6 inches of topsoil on top of the general fill
Vegetating the surface
For those areas where the waste is outside of the pre-construction perimeter fence,
either the waste will be excavated and reconsolidated within an area to be covered
by the soil cover, or the perimeter fence will be moved out to include the area
within the fenced-in portion of the landfill.
¦	Long-term care of the landfill cover
¦	Installing a perimeter gas control system in the North Waste Cell to control off-site gas
migration
¦	Continuing the operation of the perimeter gas control system in the South Waste Cell
¦	Replacing the gas blower for the South Waste Cell perimeter gas control system with a
higher capacity blower that can be used for both waste cells.
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¦	Long-term soil gas monitoring
¦	Installing a new water table well (W-18A) downgradient of well nest VV-14 and upgradient
of Sperry Drain
¦	Long-term groundwater monitoring
For the most part, the selected remedial action was Alternative #2 in the feasibility' study
(RMT, 1995a) that was approved by the MDEQ (MDEQ, 1995). Subsequent to the FS, the
MDEQ requested the addition of a water table well between W-14 and Sperry Drain (W-18A) as
part of the remedial action. The selected remedial action is protective of human health and the
environment. It is the most cost-effective approach for controlling potential future health risks
and the hazards identified in the baseline risk assessment, which was approved by the MDNR.
It also meets the applicable closure requirements for this site that were approved by the MDNR.
The target on-site groundwater cleanup criteria for this site are the Part 201 generic industrial
and commercial cleanup criteria (MDEQ, 1998). The target off-site groundwater cleanup
criteria are the Part 201 generic residential cleanup criteria (MDEQ, 1998). Additionally, the
generic GSI criteria for barium and chromium VI (MDEQ, 1998) are the cleanup criteria for
W-18A, which will be located just upgradient of Sperry Drain.
Potential future exposure to landfill constituents in on-site groundwater will be controlled
through a restrictive covenant for the landfill property in accordance with Section 20120b(4) of
Part 201 and Rule 719(3), MAC. Institutional controls will be used to prohibit construction of
off-site water supply wells in the portion of the aquifer affected by the landfill, in accordance
with Section 20120b(5) of Part 201. Potential future exposure to the waste will be controlled by
placement of the soil cover and by the restrictive covenant.
An important advantage of the soil cover as compared to a low-permeabilitv cover is that the
soil cover will allow the natural biodegradation processes that are breaking down the landfill
constituents to continue at their present rate. The biodegradation processes achieve the
requirement for removal of hazardous substances from the aquifer contained in Rule
R299.5705(6), MAC. Covering the landfill with a less permeable material will slow the natural
degradation processes because it will reduce the supply of oxygen to waste constituents. The
resulting concentrations in groundwater would decrease at a slower rate, and the extent of the
plume might actually increase. Therefore, the selected remedial action will meet the
requirement stated in Rule R299.5705(5), MAC, to not increase the extent of contaminants in the
aquifer. Inorganic constituents such as arsenic, will also be attenuated in the aquifer under
oxidizing conditions through coprecipitation with iron.
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Natural biodegradation is an acceptable remedial action in accordance with Section 20118(6)(d)
of Part 201 because there is documented evidence that it is an effective method of on-site
treatment of hazardous substances in the aquifer at this site.
Hydraulic control of groundwater migrating from the site is not recommended because it does
not provide additional risk reduction benefits and because institutional controls would still be
needed.
Descriptions of the soil cover, the perimeter gas control system in the North Waste Cell, and the
institutional controls are presented Ln the following subsections. The long-term soil gas, and
groundwater monitoring programs are described in Appendix A. Operation and maintenance
activities are outlined in Appendix B.
4.3 Landfill Final Cover
The soil cover will prevent direct contact with the landfill contents while providing the oxygen
necessary to sustain the natural biodegradation processes that have been reducing the
concentrations of landfill constituents in groundwater downgradient of the site for many years.
As stated in Subsection 2.3, much of the waste areas were found to already contain at least
12 inches of cover material (sand and gravel) on top of the waste (RMT, 1995d). General fill
will be added in areas where the current sand and gravel layer is less than 12 inches thick to
achieve a minimum 12 inches of cover materials over the waste areas. Six inches of topsoil will
be placed over the cover materials in the waste cells to support vegetation. Vegetative species
that will thrive under site conditions will be planted.
The grading plan for the site (Figure 9) has been designed to meet the applicable state
requirements for a final cover for a Type II municipal solid waste landfill (as noted in Section 1,
a closure agreement for the site was approved by the MDNR in June 1982, and completion of
closure activities was verified by the MDNR in April 1983). This plan shows that, at a
minimum, the waste in both cells will be covered by 18 inches of materials —up to 12 inches of
new general fill, depending on how much sand and gravel are already in place, and 6 inches of
topsoil. On-site borrow areas will only be within areas that are outside the limits of waste. On-
site fill areas will be outside of any delineated wetlands. Filling will not involve use of any off-
site waste materials and will only involve use of on-site waste to the extent that waste along
certain property boundaries extends beyond the property line. This waste will be brought back
on-site and placed in an area to be covered.
The grading plan for the soil cover was designed to maintain the existing surface water
drainage patterns. The area of the landfill from which run-off will reach the adjacent wetlands
will be about the same as under current conditions. The grading was designed to promote
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positive drainage away from the waste cells and to prevent ponding of water over the waste
cells. The surface grades are typically in the range of 2 to 25 percent. The Solid Waste
Management Act that was in effect when the landfill closed in 1982 (Act 87, P.A. 1965) does not
specify minimum or maximum slope requirements. While the permeability of the topsoil layer
will be somewhat lower than the existing cover soils, the increase in vegetative cover should
off-set the potential for increased run-off from the site. Run-off from the waste cells will
discharge to on-site areas.
On-site soil (non-waste) will be excavated from the area between the north and south waste
cells to achieve the top of general fill grades shown on Figure 9. Under pre-RA conditions,
surface water from the waste cells did not drain to the area between the waste cells. The
surface water run-off patterns in this portion of the site will not be significantly altered by
excavating soil in this area.
Six inches of topsoil will be placed over the waste cells and over areas outside of the waste that
will be affected by cutting or filling activities. The areas receiving topsoil will be seeded with
grasses that will thrive on natural amounts of precipitation and without fertilizer. Fertilizer
may be applied after seeding and during the first couple of years to establish the cover
vegetation.
In accordance with Rule 517(2)(d), the remedial design for this site is contained in the
Operation and Maintenance Plan (Appendix B).
4.4 Perimeter Landfill Gas Control Systems
As described in Subsection 2.6 and shown on Figure 7, there is an active landfill gas extraction
system currently in operation along the western border and southwestern corner of the South
Waste Cell. This system has proven effective in controlling off-site migration of landfill gas in
this part of the site, which is adjacent to residential properties. Operation of this system,
including the proposed expansion of the perimeter gas control system to the North Waste Cell,
will continue until the MDEQ approves a proposal to cease operation. A proposal to reduce or
end active gas extraction will include an evaluation of the gas pressures within the waste cells,
the age of the waste, the quality of the gas in the extraction wells, and the likelihood that the
concentrations of methane in gas probes at the property boundaries will be less than the lower
explosive limit (LEL) without the operation of the perimeter gas extraction system.
Some of the perimeter gas extraction wells may be turned off before others. For example, wells
along a certain border of a waste cell may be turned off sooner than along other borders of the
same gas cell, or all of the wells around one waste cell may be turned off while the gas
extraction system continues to be run in the other waste cell.
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When gas extraction wells are initially turned off, the gas probes along the property boundary
near these wells will be monitored at an increased frequency to ensure that, without active gas
extraction, the concentration of methane along the property line is less than the LEL, in
accordance with Rule R299.4433, MAC. If the concentration of methane in the perimeter probes
is above the LEL without the gas extraction system running, the gas extraction wells in that area
will be turned back on. When the gas extraction wells are initially turned off, the gas probes
along the property boundary near these wells will be monitored (for pressure, methane, and
oxygen) once a week for a month, and then once a month for 6 months. Monthly monitoring
will be extended beyond 6 months, if necessary, to include monitoring through March, because
the potential for gas migration is greatest during the winter months due to frozen
cover/ground conditions.
The perimeter gas control system will be expanded to the North Waste Cell, as shown on
Figure 10, to control off-site migration of landfill gas. The perimeter gas control system in the
North Waste Cell will consist of 14 additional gas extraction wells and piping to connect the gas
extraction wells in the North Waste Cell to the perimeter gas migration control system for the
South Waste Cell. The blower for the existing South W:aste Cell perimeter gas control system
will be replaced with a higher capacity blower that can be used for both waste cells. It is
uncertain whether the combustible content of the gas collected from the North Waste Cell,
when combined with the gas from the South Waste Cell, will support continuous operation of a
flare. As warranted, the existing flare and flame arrestor for the South Waste Cell gas
extraction system may be replaced with higher capacity equipment also. Alternately, the gas
will be vented to the atmosphere as is currently done.
Interior gas collection systems will not be needed in either cell because the gas will still be able
to migrate vertically through the proposed soil cover.
4.5 Institutional Controls
4.5.1 On-Site Institutional Controls
The following on-site institutional controls will be used to prevent direct contact with
the landfill contents and ingestion and/or dermal adsorption of groundwater affected
by the landfill:
Maintenance of the existing perimeter fence and secured gate. In certain
areas where on-site waste extends beyond the perimeter fence, the fence
will be moved outward to include those areas within the fenced-in portion
of the landfill. (In other places where the landfilled area extends beyond
the perimeter fence, the waste will be excavated and reconsolidated on-site
within an area to be covered by the soil cover.)
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In accordance with Section 21020b(3)(d) of Part 201 and Rule 719(3)(f),
MAC, install and maintain a permanent marker on each side of the landfill
(total of six markers) warning against unauthorized access. The markers
will be placed at the locations along each perimeter where people would
be likely to see them. The markers will be granite or similar weather-
robust material. The markers will be approximately 2 feet wide by 2 feet
tall by 18 inches thick (similar to a standard cemetery grave marker), and
will be set on a concrete base. The markers will be inscribed with a
schematic diagram of the landfill property and will include the following
message: "The area within this fence is known as the Cereal City Landfill.
Unauthorized access is prohibited. The restrictive covenant on this
property can be found at Liber 2049, page 974 and Liber 2072, page 930 of
the Calhoun County Register of Deeds. Monument placed in 1998."
A restrictive covenant on the landfill property deed. The restrictive
covenant will meet the requirements of Section 21020b(4) of Part 201, and
Rule 719(3), MAC. The restrictive covenant, which is included in
Appendix E, contains the following:
1.	Restrictions of uses of the property to those identified in the baseline
risk assessment (RMT, 1993a) or other uses which are consistent with
the exposure assumptions modeled in the baseline risk assessment.
2.	Restriction of activities at the property that mav interfere with a
remedial action, operation and maintenance, monitoring, or other
measures necessary to assure the effectiveness and integrity of the
remedial action.
3.	Restriction of activities at the property that may result in exposures
above levels established in the MDEQ-approved RAP. The restricted
activities include:
Prohibition of groundwater well installation and groundwater use
within the property boundary for all domestic, commercial, and
industrial uses.
The groundwater restriction applies to all waterbearing aquifers
within the property boundary.
Prohibition of construction of ground water-fed impoundments
within the property boundary.
Prohibition of excavation of soils beyond the top eighteen (18)
inches within the Limit of Waste identified in the MDEQ-approved
RAP, unless personnel are properly trained according to CFR 29
1910.120. Any excavated areas within the Limit of Waste must
have the cap restored to its original specifications within a
reasonable time frame. Any soils removed from excavation must
comply with Part 201 of the NREPA. Excavation within the
property boundary and outside the Limit of Waste is limited to the
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unsaturated zone. Excavation outside the Limit of Waste and
within the saturated zone is prohibited unless personnel are
properly trained according to CFR 29 1910.120.
Construction of any structure within the property boundary must
be reviewed and approved bv the MDEQ regarding compliance
with Part 201 of the NREPA prior to construction.
4.	The Owner shall provide to the MDEQ of the Owner's intent to
convey any interest in the Property 14 days prior to consummating the
conveyance. A conveyance of title, an easement, or other interest in the
Property shall not be consummated by the Property owner without
adequate and complete provision for compliance with the terms and
conditions of the Covenant.
5.	The Owner shall grant notice to the MDEQ and its designated
representatives the right to enter the Property at reasonable times for
the purpose of determining and monitoring compliance with the RAP,
including the right to take samples, inspect the operation of the
remedial action measures, and inspect records.
6.	The Owner shall install six (6) permanent markers that have been
approved by the MDEQ, which describe the restricted area and
include the liber and page number of the Restrictive Covenant as
recorded in the Calhoun County Register of Deeds.
The Owner also acknowledges that surface and subsurface soils found
within the limit of waste on the property must be managed in accordance
with the requirements of Section 20120c of NREPA and other applicable
state and federal laws.
4.5.2 Off-Site Institutional Controls
Institutional controls will also be used off-site to prevent ingestion and/or dermal
adsorption of constituents in the groundwater that has been affected by the landfill.
These institutional controls meet the requirements of Section 21020b(5) of Part 201 and
Rule 719(3), MAC.
Ordinances have been enacted by the City of Battle Creek (Appendix F) and Bedford
Township (Appendix G) that prohibit construction of water supply wells on certain
properties in the vicinity of the landfill. The areas covered by the groundwater
ordinances were delineated with consideration to the following criteria:
Inclusion of the areal extent of groundwater affected by the landfill in
exceedence of the GRCC (MDEQ, 1998). This includes the area
downgradient of the landfill (to the southwest) to at least 110 feet
southwest of well nest W-17, and sidegradient of the landfill to at least 20
feet west of well nest W-13.
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Inclusion of a "buffer zone" around the upgradient and sidegradient
perimeters of the landfill to prevent the installation of a residential water
supply well in an area that could induce groundwater gradients in
directions that are not currently of concern. The buffer zone also provides
an additional factor of safety for uncertainty in the areal delineation of
affected groundwater.
Within the City of Battle Creek, the area of the ordinance was delineated
along streets.
Within Bedford Township, the area of the ordinance was delineated along
property parcels.
The water supply well	which is within the area of the City of
Battle Creek groundwater ordinance, will be abandoned by the Owner of the landfill.
Once the well at this property is abandoned, as described in Subsection 5.1, the affidavit
on the deed for this property will not be needed.
4.6 Estimated Costs
The estimated total capital cost to implement the selected remedial action is 52,070,000. The
estimated annual operating, maintenance, and monitoring (OM&M) costs are S206,000. The net
present value (NPV) of the OM&M costs is roughly S3,900,000. The basis for these estimates are
shown in Appendix H.
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Section 5
Abandonment of Wells and Gas Vents
5.1 Abandonment of Monitoring Wells, Leachate Head Wells, and a
Residential Well
Groundwater quality and flow directions have been monitored at and around this landfill for
14 years. Subsurface conditions have been adequately characterized to assess potential risks to
human health and the environment, and to evaluate remedial alternatives. A long-term
groundwater monitoring program has been developed to monitor the effectiveness of the
remedy (Appendix A). Before the RA, there were 38 monitoring wells in 15 locations at, and
around the landfill; however, many of these are not needed to monitor long-term trends in
groundwater quality or to detect changes in the direction of groundwater flow downgradient of
the landfill. Therefore, the following 27 monitoring wells will be abandoned:
The monitoring wells will be abandoned by overdrilling the casing through the base of the
screen, then pressure-grouting the hole with a cement-bentonite slurry as the drill rod is pulled
from the ground.
Leachate head elevations are also unnecessary for assessing the long-term effectiveness of the
remedy. Therefore, the 12 leachate head wells (7 in the North Waste Cell and 5 in the South
Waste Cell) will be abandoned. The leachate head wells will be abandoned in the same manner
as the groundwater monitoring wells.
The property	Street has been abandoned since at least 1991. The City of Battle
Creek has taken ownership of the property as a result of tax delinquency. The water supply
well at this former residence will be abandoned in the same manner as the groundwater
monitoring wells.
OB-1BR
OB-4B
W-9C
W-12BC
W-14A
W-15C
W-1D
OB-6R
W-10A
W-12D
W-14C
W-17A
W-1E
OB-7R
W-11A
W-13A
W-14D
OB-2R
W-9A
W-11C
W-13B
W-15A
OB-4R
OB-9R
W-12A
W-13D
W-15B
RMT, Inc.
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5.2 Abandonment of Passive Gas Vents
The passive gas vents serve no useful purpose because they do not provide a preferential
pathway for landfill gas to reach the atmosphere. It is unknown to what depth or in what type
of soil/waste the vents were completed, because the construction of the vents was not
documented when they were installed in 1981. Additionally, many of the older vents in the
South Waste Cell are in poor condition. The gas vents will not be needed with the soil cover
because the gas will still be able to migrate vertically through the soil cover to the atmosphere.
The active gas extraction system will continue to control potential off-site migration and the
probes along much of the perimeter of the landfill will continue to be monitored routinely for
indications of increased lateral migration. Therefore, all of the passive gas vents (72 in the
North Waste Cell and 13 in the South Waste Cell) will be abandoned by either plugging or
overdrilling, depending on field conditions.
RMT, Inc.
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Section 6
Fugitive Dust and Ambient VOC
Monitoring and Control Plan
This section describes the fugitive dust control plan and the ambient VOC monitoring plan that
will be implemented during the construction activities. Up to three types of air monitoring will
be performed during the construction activities:
¦	Measurement of fugitive dust levels at downwind property lines
¦	Measurement of VOCs present in the ambient air in the workers' breathing zone during
construction activities at the site in which waste will be exposed
¦	As necessary, measurement of VOCs present in the ambient air at downwind property
lines
6.1	Fugitive Dust Control Plan
Fugitive dust may be generated during the remedial action by construction equipment
traveling over unpaved surfaces, by unloading soil, or as a result of grading activities and cover
placement. The objective of the fugitive dust control plan is to prevent transport of nuisance
levels of dust across the landfill property lines. Fugitive dust will be controlled primarily by
watering frequently-traveled unpaved roads and soil working surfaces on an as-needed basis.
In addition, the wheels on construction vehicles will be washed before leaving the site and the
soil haul truck beds will be covered as they enter and leave the site.
The effectiveness of the fugitive dust control efforts will be evaluated through a combination of
visual observation and regular measurement of dust levels at downwind property line
locations. Additional measures will be taken as necessary to eliminate persistent dust
problems.
6.2	Fugitive Dust Monitoring Plan
The objective of the fugitive dust monitoring plan is to assess the effectiveness of the fugitive
dust control efforts.
Concentrations of particulates in the air will be measured with a real-time instrument three
times each day when activities that could generate significant amounts of fugitive dust are
taking place at the site. The measurements will be taken at three to four locations on the
property line that are downwind of the dust-generating activities. The measurements will be
lla
!¦
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taken at different downwind locations unless elevated readings are measured at a particular
location. In this case, readings may be repeated at this location during the dav. If applicable,
locations where visible dust is evident will be preferentially selected for monitoring.
Airborne particles will be measured using a MIE, Inc., Miniram monitor or an approved
equivalent. This is a hand-held field instrument that senses and measures dust concentrations
in the range of 0.01 to 100 mg/m3. The Miniram displays the 10-second averaged concentration
on a direct-read liquid crystal display. Three measurements will be made each time a location
is monitored. The average of the three readings will be recorded and used as the basis to
decide whether more aggressive dust control measures are needed. The level at which
additional actions will be taken will be determined in the field based on best professional
judgment as to what might be considered a nuisance to nearby residents and site workers.
Conservative judgment will be used in order to minimize potential concern by nearby
residents. As a screening-level assessment, the measured levels will be compared to the
National Ambient Air Quality Standard (NAAQS) for particulate matter of 150 fig/ m3 (0.15
mg/m3). It should be noted, however, that because the NAAQS is a 24-hour exposure criteria,
it is not directly applicable to the real-time dust measurements that will be made at this site.
Additional actions will be taken as necessary to control fugitive dust (e.g., increasing the water
application frequency or reducing the areas in which dust is being generated).
A record of fugitive dust monitoring activities will be maintained, including the dates, times,
and locations of dust measurements and visual observations, problems and corrective actions
taken, maintenance, and the monitoring results. Any concerns or complaints from the general
public will also be recorded in the log book.
6.3 Ambient Volatile Organic Compound Monitoring
VOCs could present a potential health risk to site workers or nearby residents as a result of
inhalation of airborne VOCs during construction activities in which the landfill contents are
exposed to the ambient air. The people who are most likely to be affected by VOCs emitted
from the landfill are the drillers installing the gas extraction wells and the construction workers
who will be digging the trenches for the perimeter gas control system piping and
reconsolidating small areas of waste. In general, the landfill contents will be minimally
disturbed during the cover grading that will be performed. In certain segments of the landfill
perimeter (on the western side of the South Waste Cell and on the northern and southern end of
the North Waste Cell), waste that extends just beyond the landfill property boundary will be
pulled back on-site and consolidated with the adjacent on-site fill. The landfill contents at any
location will be exposed for periods on the order of several hours to no more than 3 days,
depending on the types of activities being performed.
RMT, Inc.
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Ambient VOC Monitoring Plan
The personal protective air monitoring for workers that will be performed in accordance with
Table 3-2 of the Site Emergency Response Health and Safety Plan (Attachment II to the
Operation and Maintenance Plan) will also be used for screening level monitoring for off-site
ambient air. It will be assumed that as long as the VOC concentrations in the workers'
breathing zone are acceptable, that the off-site ambient air is also protected.
During work at the site in which waste will be exposed, measurements will be taken with a
photoionization detector (PID) in the workers' breathing zone.
The following monitoring activities, action levels, and response activities will be followed:
1. WORKERS' BREATHING ZONE MONITORING
A.	If the reading in the workers' breathing zone is less than 5 ppm, no additional action is
necessary.
B.	If the reading in the workers' breathing zone is greater than 5 ppm. but less than
10 ppm, workers will upgrade to Level C respiratory protection equipment in
accordance with the Site Emergency Response Health and Safety Plan prior to
continuing with any additional activity in the working area. The monitoring
technician will proceed to the nearest downwind property line to take and record a
reading with the PID. The downwind property line will be determined using
directional information from a windsock. The reading taken at that location will
dictate what, if any, further action is needed. As necessary, the area of exposed waste
may be reduced or eliminated by placing clean soil over the waste.
C.	If the reading in the workers' breathing zone is greater than 10 ppm, work will be
halted and mitigation measures will be taken immediately at the excavation location to
reduce the ambient concentration of VC)Cs. All non-essential personnel will be
evacuated from the work area. Workers will evacuate to an area that is not downwind
of the intrusive work. The monitoring technician will proceed to the nearest
downwind property line to take and record a reading with the PID. The reading taken
at that location will dictate what, if any, further action is needed. The downwind
property line will be determined using directional information from a windsock.
Finally, workers will complete the activities in the affected area using the appropriate
level of respiratory protection (as specified in the Site Emergency Response Health and
Safety Plan) based on continued PID measurements.
RMT, Inc.
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2. PROPERTY LINE MONITORING
(Property line monitoring will be initiated only if the VOC levels in the workers' breathing zone
exceed 5 ppm).
A.	If the reading at the property line is less than 1 ppm, no additional action is necessary.
Record the location and reading at the property line in the field log book and continue
with monitoring in the workers' breathing zone as scheduled. Readings will be taken
and recorded at the property line every 15 minutes for at least 1 hour after the initial
reading to ensure that an increase in levels is not occurring. If an increase is observed,
continue monitoring until the concentration has stabilized, or immediate evacuation of
workers, in the area where waste is exposed, is indicated.
B.	If the reading at the property line is greater than 1 ppm but less than 5 ppm, record the
location and reading at the property line in the field log book and continue monitoring
at the workers' breathing zone as scheduled. In addition, readings will be taken and
recorded at the property line every 15 minutes for at least 1 hour to ensure that an
increase in levels is not occurring. After at least 1 hour of stabilized readings, continue
with property line monitoring at the rate of at least one reading per hour while intrusive
work is continuing. Property line monitoring may be discontinued if the property line
concentration is consistently less than 1 ppm.
C.	If the reading at the property line is greater than 5 ppm. construction activities will be
halted and mitigation measures will be taken immediately at the excavation location to
reduce the ambient concentration of VOCs. All non-essential personnel will be
evacuated from the work zone. Workers will evacuate to an area that is not downwind
of the intrusive work. Record the location and reading of the property line every 15
minutes for at least 1 hour to ensure that the mitigation measures taken are adequate
and an increase in levels is not occurring. Property line sampling should continue until
work has completed for the day, or the property line concentration is consistently less
than 1 ppm.
RMT, Inc.
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m\m
IB
Section 7
Implementation Schedule
As required by Rule R299.5515(l)(e), a schedule for implementing the remedial action is shown
on Table 9. Construction began in June 1997, and will be completed in 1998.
The effectiveness of the long-term environmental monitoring program (Appendix A) will be
reviewed after five years. As appropriate, changes may be recommended to the MDEQ.
RMT, Inc.
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Section 8
Reporting
The following reports will be prepared and submitted to the MDEQ:
¦	A construction documentation report for the expansion of the perimeter gas control system
to the North Waste Cell and the placement and seeding of the soil cover. This report will
also include the results of the fugitive dust monitoring, and documentation of installation,
abandonment, and repairs of monitoring wells, leachate head wells, and passive gas vents.
¦	An annual environmental monitoring report will be submitted to the MDEQ by March I,
following each complete year of groundwater and soil gas monitoring. The report will
include the following information for the previous calendar year.
Landfill Gas-Related
A summary of the operating conditions associated with the gas extraction system
(i.e., data collected from the gas probes, the perimeter extraction wells, the blower,
and the exhaust system).
An assessment of the effectiveness of the gas extraction system in preventing
accumulation of subsurface landfill gas in buildings on or near the landfill.
An assessment of the effectiveness of the gas extraction system in preventing
migration of landfill gas beyond the property lines.
Groundwater-Related
The groundwater monitoring results, including water level measurements,
stabilization test data, sample logs, chain-of-custody records, and laboratory
reports.
A comparison of the laboratory results to the site-specific cleanup criteria.
A water table map.
An assessment of spatial and temporal trends in the chemistry of the groundwater
affected by the landfill.
An assessment of the effectiveness of the natural degradation processes in reducing
the concentration and areal and vertical extent of landfill-related affects on the
aquifer.
RMT, Inc.
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General
An assessment of the effectiveness of the institutional controls in preventing
unauthorized access to the landfill and potential exposure to groundwater affected
bv the landfill.
j
A summary of the maintenance inspections and repairs that were completed.
The annual monitoring reports will also describe any contingency response actions taken as a
result of unanticipated or changing conditions related to either groundwater or landfill gas.
Minor non-compliance events that were corrected during the reporting year will also be
documented in the annual reports. Conditions that may pose an immediate threat to health,
safety, or the environment will be reported to the MDEQ Pollution Emergency Alerting System
(PEAS) and the Plainwell District Office, the Battle Creek Fire Department and/or the Calhoun
County Health Department within 24 hours from the time that the threat is identified. Bedford
Township officials will also be notified.
RMT, Inc.
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Section 9
Financial Assurance
Because the RAP for the Cereal City Landfill is based on criteria provided for in Section
20120a(2), the land and resource use restrictions, the monitoring program, the operation and
maintenance program, the permanent markers, and the financial assurance mechanism are
stipulated in a legally enforceable document with the MDEQ. The financial assurance
mechanism to secure the performance of operation and maintenance, oversight, monitoring,
and other costs necessary to ensure the effectiveness and integrity of the containment measure
set forth in this RAP are described in an Administrative Order on Consent between the MDEQ
and SCHI (Appendix 1).
Cost estimates for long-term care and monitoring at the Cereal Citv Landfill following
implementation of the selected remedial action are presented in Appendix H. These costs were
developed using unit costs reflective of third parties conducting the work. The estimated total
annual operating, maintenance, and monitoring (OM&M) costs are 5206,000. Based on a long-
term care period of 30 years, with an assumed rate of inflation of 3.8 percent, and an assumed
7-percent cost of money, the approximate net present value of the annual OM&M costs are
53,900,000.
RMT, Inc.
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¦¦
Section 10
References
MDEQ. 1995a. Letter dated November 1,1995, from Lori Aronoff to Phillip Mazor, Waste
Management Inc.
MDEQ. 1998. ERD integrated table of Part 201 cleanup criteria and screening levels.
September 1998.
MDNR. 1982. Letter dated November 10, 1982, from Howard Tanner, Director MDNR, to
Valdas Adamkus, Regional Administrator, U.S. EPA-Region V.
MDNR. 1992. Superfund Section. Site Screening Inspection Report for the Waste
Management, Inc., Cereal City Landfill, Battle Creek, Michigan. January 22,1992.
MDNR. 1994a. Letter dated June 16,1994, from Lori Aronoff to Phillip Mazor, Waste
Management, Inc.
MDNR. 1994b. Letter dated July 29,1994, from Lori Aronoff to Phillip Mazor, Waste
Management, Inc.
MDNR. 1995. Interoffice memorandum dated July 10,1995, from Phil Schrantz, Waste
Management Division, to Lori Aronoff, Environmental Response Division.
RMT, Inc. 1991. Phase II hydrogeologic study workplan.
RMT, Inc. 1992. Phase II hydrogeologic study report.
RMT, Inc. 1993a. Phase III hydrogeologic study report (includes the baseline risk
assessment).
RMT, Inc. 1993b. Characterization and evaluation of landfill gas emissions.
RMT, Inc. 1993c. Documentation report for the installation, abandonment, and
reconditioning of soil gas probes.
RMT, Inc. 1993d. Interim groundwater monitoring plan.
RMT, Inc. 1993e. Background concentrations of arsenic in groundwater.
RMT, Inc. 1993f. Documentation report for the expansion of the active landfill gas
extraction system. October 1993.
RMT, Inc. 1993g. Letter from RMT to the MDNR regarding potential federal and state
ARARs.
RMT, Inc.
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RMT, Inc. 1994a. Background concentrations of selected metals in soils.
RMT, Inc. 1994b. Followup letter, dated May 31,1994, responding to the MDNR's
comments on the technical memorandum on the background concentrations of arsenic
in groundwater.
RMT, Inc. 1994c. Quarterly results of the interim groundwater monitoring program.
RMT, Inc. 1994d. Letter dated July 26,1994, to Lori Aronoff, MDNR, documenting the
resolution of the MDNR's comments submittals during the period from September
1993 to February 1994.
RMT, Inc. 1994e. Annual groundwater monitoring report. October 1993 through July
1994.
RMT, Inc. 1995a. Focused feasibility study report.
RMT, Inc. 1995b. Final cover options analysis (Appendix A of the focused feasibility study
report [1995a]).
RMT, Inc. 1995c. Report of an evaluation of the effectiveness of landfill covers and
groundwater containment in remediating groundwater at the Cereal City Landfill
(Appendix B of the focused feasibility study report [1995a]).
RMT, Inc. 1995d. Letter report to Phillip Mazor, dated December 15,1995, summarizing
the findings of the field verification of the lateral extent of waste and the cover
thickness.
RMT, Inc. 1996a. Annual groundwater monitoring report. October 1994 through July
1995.
RMT, Inc. 1996b. Annual groundwater monitoring report. October 1995 through July
1996.
RMT, Inc. 1998. Groundwater monitoring results for the April 1998 Sampling Event.
Letter to Phill Mazor, dated June 12,1998.
USEPA. 1988. CERCLA compliance with other laws manual. Draft guidance —interim
final. EPA 540/G-89/006. August 1988.
USEPA. 1989a. Risk assessment guidance for Superfund: Vol. I: Human health
evaluation manual: Part A, baseline risk assessment. EPA/540/1-89/002.
USEPA. 1989b. CERCLA compliance with other laws manual. Part II. Clean air act and
other environmental statutes and state requirements —interim final. EPA 540/G-
89/009. August 1989.
RMT, Inc.
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USEPA. 1991. Drinking water health advisory for ammonia.
USEPA. 1994. Office of Water, "Drinking water regulations and health advisories."
RMT, Inc.
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AUJ5. U.M
Superfund Reforms: Updating Remedy Decisions	Page I of 7
EXHIBIT 1
SEPAgP-*— Suoerftind
MEMORANDUM
OSWER Directive #9200.0-22
SUBJECT: Superfund Reforms: Updating Remedy Decisions
FROM: Stephen D. Luftig, Director - Office of Emergency and Remedial Response
Barry N. Breen, Director • Office of Site Remediation Enforcement
TO:	Director, Office of Site Remediation and Restoration - Region I
Director. Emergency and Remedial Response Division - Region II
Director. Hazardous Waste Management Division - Regions III. DC
Director, Waste Management Division - Region IV
Director. Superfund Division - Regions V, VI, VII
Assistant Regional Administrator. Office of Ecosystems Protection and
Remediation - Region VIII
Director, Environmental Cleanup Office • Region X
Regional Counsel. Office of Regional Counsel. Regions I - X
1.
Purpose
2.
Background
3.
Objective
4.
Implementation
5.
Conclusion
Purpose
[Go Bacli)
The purpose of this Superfund Reform is to encourage appropriate changes to remedies
selected in existing Superfund Records of Decision (RODs). These updates are intended to
bring past decisions into line with the current slate of knowledge with respect to remediation
science and technology, and by doing so. improve the cost effectiveness of site remediation
while ensuring reliable short and long term protection of human health and the environment.
Remedy changes will be completed in accordance with existing regulations and guidance,
which call for a memorandum to (he file, an Explanation of Significant Differences, or a ROD -
amendment, as appropriate for the significance of the change. Cleanup levels are not expected
to change absent a showing that remediation levels are unattainable.
Background
[Oo Back)
At the inception of the Superfund program in 1980, few technologies existed for the
characterization and cleanup of hazardous waste sites, and relatively little was known
regarding the nature of subsurface contamination. Since that time, numerous technical
advances have been made which greatly improve our ability to characterize and remediate
hazardous waste sites. In addition, analysts of EPA and State program experience has led to a
greater understanding of the difficulties involved in remediating certain types of
contamination problems.
The Agency recognizes that some remedy decisions made at Superfund sites in the past
should be modified to bring those decisions up to date with the current slate of the science.
The best example of how knowledge and expectations have evolved in the Superfund
program is the case of contaminated ground water. At the outset of the program, it was
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-iupcfiuuu Kcxuuuv upuatihg Kemeay uectsions	Page 2 of 7
anticipated that ground water contamination would migrate in a relatively simple and
predictable manner, and (hat remediation using pumping wells coupled with above-ground
treatment would be straightforward and rapid. Today, we realize that many of the
contaminants present in ground water at Superfund sites were derived from "dense,
nonaqueous phase liquids" (DNAPLs) such as trichloroethylene (TCE). Such contaminants	T
behave in a manner that was not widely understood by the technical community until die late
1980s. The migration, fate, and cleanup of DNAPL contamination in ground water is still the
subject of considerable research.
The Superfund program has evolved in response to scientific advancement and remediation
experience. For example, the 1993 "Guidance for the Evaluation of the Technical
Impracticability of Ground water Restoration" followed the completion of an EPA study of
the efficacy of "pump and treat" cleanups at Superfund and other contamination sites. This
guidance recognizes (hat numerous challenges may be faced cleaning up contaminated
ground water, and provides advice on how to demonstrate that required cleanup levels should
be waived in favor of a protective, but less-stringent cleanup approach. The need for
flexibility in the implementation of ground water remedies will be discussed in detail in (he
forthcoming EPA guidance "Presumptive Response Strategy and Ex-Situ Treatment
Technologies for Contaminated Ground Water at CERCLA Sites," which should be available
in late 19%.
Modification of a ROD is not a new concept in the Superfund. However, the need to modify
RODs to keep up to date with new technologies has grown as the complexity of Superfund
cleanups has become more apparent and national concern regarding the costs of such
cleanups has increased.
Objective
[Go Back]
This reform effort encourages the Regions to take a close look at. and modify as appropriate,
past remedy decisions where those decisions are substantially out of date with the current	'<
state of knowledge in remediation science and technology, and thus are not as effective from	. i
a technical or cost perspective as they could be.
This initiative does not signal any changes in Agency policies regarding site cleanup,
including policies based on the Superfund statute regarding remedy selection, treatment of
principal threats, preference for permanence, establishment of cleanup levels, waivers of such
cleanup levels, or the degree to which remedies must protect human health and the
environment It is instead an effort to promote the use of the best science and most
appropriate technologies at Superfund sites.
Implementation
[Go Back)
EPA is prepared to review and update existing RODswhere appropriate. Eligibility for this
reform effort is open to Fund, other federal agency-lead, and potentially responsible party
(PRP)-lead sites. Candidate sites for remedy updates may be identified by EPA or other
interested parties.
Modification of RODs generally is appropriate where significant new information has
become available (i.e.. (he information was not available at the time the ROD was signed)
that subs(an(ially supports (he need to alter the remedy. This approach is in keeping wi(h (he
general expectation that updates will be based on program experience and new scientific
information.
Types of Remedy Updates Anticipated
We expect that the primary focus of these updates will be ground water sites, as the science of
ground water remediation has changed dramatically since the inception of the Superfund
program. Nonetheless, remedy updates may be appropriate at other types of sites as well We
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expect thai remedy updates will consist of three principal types:
•	Changes in the remediation technology employed, where a different technology would
result in a more cost effective cleanup;
•	Modification of the remediation objectives due to physical limitations posed by site
conditions or the nature of the contamination; and
•	Modification of the monitoring program to reduce sampling, analysis, and reporting
requirements, where appropriate.
These types of updates are discussed below in greater detail, particularly as they relate to
ground water remedies;
•	Changes in the Remediation Technology: Sites where new information indicates
thai another remediation technology would perform significantly better than the
selected remedy for equivalent cost, or perform as well as the selected remedy for
significantly lower cost, would be good candidates for a remedy update. Note that
there should be sufficient information available to determine that such a technology or
approach will perform as expected, given the conditions at the site. Given the
potential risks of technology failure and its consequent cost, only proven technologies,
or innovative technologies with well-understood performance capabilities, should be
considered for remedy updates.
•	Remediation Objectives Reconsidered: This category includes sites where
information gathered during remedial design or remedial action indicates that
achieving the selected cleanup levels (e.g.. Maximum Contaminant Levels) is not
technically practicable from an engineering perspective. An example of such a site
would be one where DNAPLs have been directly identified or reliably inferred from
newly-acquired evidence, and where presence of the DNAPL will critically limit the
ability to achieve cleanup levels. This scenario also might include cases where the
physical attributes of the site (e.g., very complex hydrology) will prevent the selected
remedy from attaining the required cleanup levels in a reasonable time frame.
Another type of site that might be considered for an update under (his general
category is a site where an existing ground water remediation system has reduced
contaminant levels, but contaminant recovery efficiency is so low that a concentration
"plateau" has effectively been reached. EPA expects that reasonable efforts will have
been made to refine any existing remediation systems, so that the loss of contaminant
recovery efficiency can be attributed with relative confidence to physical limitations
of the site, and not to inadequacy of remediation system design or its operation. A
determination regarding contaminant recovery efficiency may be made over portions
of sites, targeting for review and update only those areas of the site where remediation
has become demonstrably inefficient For farther information on defining
concentration "plateaus," see "Statistical Methods for Evaluating Cleanup Standards:
Volume II, Ground Water'' (EPA Publication 23O-R-92-0I4, 1992).
Where such a determination is made (i.e., thai further active remediation with a given
technology is no longer practicable), alternative remedy options include: 1) use of a
different remediation technology or approach to enhance recovery rates; 2) use of
natural attenuation to complete the cleanup, but over a somewhat longer time frame;
and 3) recognition that complete cleanup is not technically practicable using either of
the first two options, and that modification of the cleanup levels may be required (e.g.,
ARAR waiver or alternate concentration limits). For further information on waivers of
cleanup levels, see "Guidance for Evaluating (he Technical Impracticability of
Ground Water Restoration," OSWER Publication No. 9234.2-23 (September 1993).
Use of natural attenuation to complete ground water cleanup may be appropriate
where site characterization and remedy performance dau indicate that required
cleanup levels will be attained within a reasonable time frame through biodegradaiion.
dispersion, dilution, adsorption, or other natural processes. The "reasonableness" of
the time frame to achieve cleanup must be determined on a site-specific basis.
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considering such factors as use and value of the resource: the urgency of (he need for
the resource; the availability of other water supplies in the area: and the ability to
prevent human exposures and impacts to environmental receptors. State and local
input on these decisions therefore will be critical.
• Reduced Monitoring Data Needs: Sites where the ground water monitoring
program could be streamlined without compromising the effectiveness or
protectiveness of the remedy also may be considered for review. For example, sites
undergoing long-term remedial actions such as pump and treat may, after a period of
time, require less intensive monitoring than originally called for in the ROD or other
work plan document. Such a determination may be made after the remediation system
has been operational and functional for a period of time sufficient to determine
whether 1) the remediation system is achieving the degree of contaminant plume
control sought; and 2) there have been no short-term fluctuations in contaminant
concentrations or other phenomena that would justify the continuation of frequent
sampling.
Where these conditions are met, it may be appropriate to consider streamlining the
ground water monitoring program. Such streamlining might, for example, reduce
sampling frequency from quarterly to semiannually or annually with no significant
change in data quality or monitoring effectiveness. Similarly, the number of
parameters tested for in each sample also may be reduced in certain cases. In other
cases, specific monitoring wells may be eliminated from the program entirely. For
example, wells formerly located in the contaminated plume which now comply with
cleanup levels, or wells that are sufficiently close to other monitoring points that their
omission from the sampling program would not adversely impact overall data quality
may be eliminated from the monitoring program.
Factors to consider when contemplating changes to the monitoring program include
proximity to downgradient receptors (e.g., supply wells), the relative speed with
which ground water Hows in the affected aquifer, and whether large seasonal changes
occur in the hydrologic system. And, as virtually alt ground water sites have some
type of monitoring program, regional review and modification of monitoring
programs should focus on those sites where such changes will produce significant cost
savings. Changes to a ground water monitoring program often will not constitute a
significant change to the implementation of the remedy. Where this is the case, such
changes may be documented through a memorandum to the post decision document
file or through modification of the specific document(s) governing the monitoring
plan, as appropriate.
These examples of updates, while not exhaustive, are meant to be representative of the
types of sites where it may be appropriate to modify the remedy. In cases where a
change in remedial technology or approach is proposed, remedy updates should be
based on site-specific information gathered or developed after the ROD was signed. -
Remedy Updates Process
Each Region should set up a process for reviewing requests for remedy updates submitted by
EPA staff or other parties. The process may consist of three phases:
1.	Identification and prioritization of RODs for review;
2.	Technical review (to detetmine whether changes to the remedy are warranted); and
3.	Implementation of the remedy update (changes documented in the post-ROD Hie, an
Explanation of Significant Differences, or a ROD Amendment; or where the remedy
selected ROD is not altered, by revision of a work plan or other relevant document).
Prioritization. EPA will consider and evaluate potential remedy updates for Fund, other
federal agency, and responsible party-lead sites. Requests for review of candidate RODs may
be sent to the Waste Management Division Director or the Remedial Project Manager
http://ww w .epa.gov/superfund/programs/re forms/ remedy/index, htm
-------
Superfund Reforms: Updating Remedy Decisions
assigned to the site. To ensure that the Region's rationale for prioritizing remedy reviews is
clear and equitable, all such requests should be carefully tracked. During the prioritization
phase, the Region shall assess the type of modification that may be called for. the resources
needed to conduct the review and update, and the potential cost savings. Review and
consideration of potential remedy updates should not. however, result in any delays in ihe
completion of work products or other remediation activities required by the existing ROD and
enforcement instruments (UAOs/CDs). Work stoppage is not permitted except as authorized
in the enforcement instrument for PRP-lead sites.
Review and modification of RODs can be resource intensive. We therefore encourage the
Regions to establish priorities for ROD reviews and updates that balance the demands of this
reform effort with available Regional resources and the need to meet other program targets. It
is recommended that in setting priorities among updates, the Regions should evaluate the
potential cost savings of the update. Furthermore, when factoring cost savings into priority-
setting for reviews, Regions should consider both the gross cost savings estimated for the
update (favoring large sites with potentially large cost savings), as well as the proportion of
total remedy cost which the savings would represent (fostering update opportunities for
smaller sites with large proportionate reductions in cost).
Estimation of the amount of cost savings expected for the proposed remedy change should
include consideration of the resources required to review and update the remedy decision, as
well as the resources required to implement the change in the remedy itself. As Superfund
decisions have evolved with program experience, we anticipate that older RODs may be the
more likely candidates for updating than more recent RODs. However, another factor that can
affect remedy update cost savings is the stage of a remedy's construction. The costs of
implementing a change in remedial technology may be much lower, for example, if the
change is made during design as opposed to during or after construction. When estimating
cost savings associated with a potential remedy update, (he Region therefore should consider
whether a given remedy is still in (he design phase, or whether construction is underway or
already completed, In addition, the impact of any delays to the cleanup schedule should be
considered. Additionally, the Regions should consider the administrative costs of modifying a
remedy, which may include preparation of an ESD or ROD amendment, responding to the
concerns of parties affected by the remedy change, and modifying or renegotiating UAOs or
consent decrees.
Technical Review. During the review phase, Regions will review the technical information
supporting the need to alter the response action. This should include detailed site-specific
information related to how the selected remedy has performed or can be expected to perform.
This information may be augmented by non-site-specific information such as published
reports regarding the efficacy of a particular remediation method under conditions similar to
those found at the site, or other widely-accepted technical information that was not available
at the lime the ROD was signed. The Agency expects that PRPs and federal agencies
requesting remedy reviews will take responsibility for collecting and assembling relevant
information in a manner that supports an efficient review process. EPA will assume this
responsibility for Fund-lead sites.
Implementation. Sites that are selected for update would then pass on to the third phase,
implementation. Note that this reform initiative does not in any way change the manner in
which remedies are modified, as specified in the March 8. 1990 National Contingency Plan
(NCP). Where modifications to a ROD would represent a significant, but not fundamental,
change from the selected remedy, EPA (or the lead agency) is required to publish an
Explanation of Significant Difference (ESD), as outlined in NCP §300.435(cX2)(i). Where a
ROD modification would result in a fundamental difference from the selected remedy, a ROD
Amendment should be proposed, as discussed in NCP §300.435{c)(2)(ii). Minor, or non-
significant. changes to a remedy must be recorded and explained in the post decision
document file. Remedy changes that do not alter the remedy selected in the ROD (e.g., some
ground water monitoring program changes) may be documented by revision of the work plan
or other relevant document
Community preferences are particularly important regarding any proposed changes to the
remedy. Regions must ensure that communities are involved in the remedy update process
and should provide an opportunity for public comment whenever the change will result in a
r,«„/cnr^rfnnrt/nrnoram
-------
owpcuuuu (\ciuuu5. i^puauii^ Kciueay uecisions
ROD amendment Public notice of modification of a ROD will be carried out in accordance
with the NCP and existing guidance. Where an ESD is used, EPA (or the lead agency)
generally provides a summary of the ESD in a local newspaper, and makes the ESD and
supporting information available to the public in the Administrative Record and in the site's
information repository (NCP §300.825(aX2)l, We also encourage ihe RejjpM m the lead
agency to solicit public comment on ESDs where appropriate. Public involvement for ROD
amendments is carried out in the same manner as for a ROD. including requirements for
public comment, response jo comments, and update of the Administrative Record (refer to
OSWER Directive 9355.3-02). For minor, or non-significant changes, the public may access
documentation of the changes in the post decision document file in the Administrative
Record. If the lead agency chooses, it also may publish an optional Fact Sheet describing the
minor changes to the ROD.
Further guidance on what may constitute a minor, significant, or fundamental change to a
ROD can be found in the Preamble to the above sections of the NCP. and in OSWER
guidance documents "Interim Final Guidance on Preparing Superfund Decision Documents"
(Directive 9355.3-02, October 1989) and "Guide to Addressing Pre-ROD and Post-ROD
Changes," (Publication No. 9355.3-02FS-4. April 1991).
Slate, Native American Tribe, or Supporting Agency Role
States play a role in the modification of remedy decisions. Both CERCLA §121(0 and the
Model CERCLA Consent Decree (which forms the basis for most consent decrees) provide
that the States be given the opportunity to review and comment on specified steps in remedy
selection. Further, (he Model Consent Decree requires that (he State be given a reasonable
opportunity to review and comment on any proposed modifications. Agreements between
EPA and a State, including contracts, may require modification following a change to a
remedy. Further information regarding the role of Stales and supporting agencies in the
remedy modification process can be found in the "Interim Final Guidance on Preparing
Superfund Decision Documents," OSWER Directive 9335.3-02 (October 1989).
Native American Tribes are afforded substantially the same treatment as States with respect
to certain provisions of CERCLA (see CERCLA § 126; NCP §300J). A tribe that is
federally-recognized, has a governing body that is currently performing governmental
functions regarding environmental protection, and has jurisdiction over a Superfund site can
be treated substantially the same as states under CERCLA § 104 (see NCP §300.515). For
more information, please contact Dave Evans ( Director, State, Tribal, and Site Identification
Center), at (703)-603-8885.
Modifications of RD/RA Consent Decrees
When a modified remedy is to be (or is being) implemented by PRPs pursuant to a Remedial
Design/Remedial Action (RD/RA) consent decree, modification of the consent decree may be
necessary. Most remedy updates will require modification of the Statement of Work (SOW)'
which provides detail regarding implementation of the ROD. Most consent decrees follow the
Model Consent Decree which provides (hat any material modification to the Statement of
Work for the remedy requires the written approval of the United States, the settling PRPs. and
the court which entered the decree. Where remedy updates adopted pursuant to this
administrative reform proposal result in cost savings to the settling defendants, it is not
anticipated that the Regions will have difficulty obtaining the cooperation (and assistance) of
PRPs in preparing the documents required to obtain court approval of the modified consent
decree.
Where the modified remedy requires a nonmaterial change in the SOW, the Model Consent
Decree language provides that the modification can be made upon written agreement between
EPA (after providing the State a reasonable opportunity to review and comment on the
modification) and the settling defendants. If the remedy update does not require a change to
the SOW, the Model Consent Decree modification provision does not require approval of the
settling parties. The Department of Justice should be consulted as soon as Che Region believes
that modification of the consent decree would be required to accommodate a remedy change.
023/024
ClOt /
http://www.epa.gov/superfund/programs/reforms/rcmedy/indcx.htm
9/8/00
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09/17/03 11:29 FAI 16167522000	WARNER
Superfund Reforms: Updating Remedy Decisions
Headquarters Consultation
Current policies regarding consultation with Headquarters on certain remedy selection issues
apply to this initiative. Current consultation policies are found in the memorandum entitled,
"Twenty Fifth Remedy Delegation Report - FY 1994," signed by Richard J. Guimond,
October 8. 1993. However, in the future the Regions should refer to any relevant
Headquarters memoranda updating these consultation guidelines.
Conclusion
{Go Back]
III closing, let me state that the success of this Superfund Reform will be contingent in part on
how well the results of these reviews and updates are communicated among Regional and
Headquarters offices. Progress reports, including the number and type of remedies reviewed,
and the number and nature of the remedies updated, will be prepared periodically by my staff
with your involvement. Copies of these reports will be provided to you so that you may be
aware of national trends in this reform effort. We expect to hold periodic conference calls to
coordinate the national implementation of this Superfund reform and to obtain results on the
progress in reviewing and updating RODs.
ff you have any questions or wish to discuss these matters further, please contact Peter
Feidman ((703) 603-8768) or Bruce Means {(703) 603-8815) of the Office of Emergency and
Remedial Response, Karen Harrison of the Office of Enforcement and Compliance Assurance
((202) 564-5121), or Brian Grant of the Office of General Counsel ((202) 260-6512).
cc Elliott Laws, OSWER
Tim Fields. OSWER
Jim Woolford, FFRRO
Earl Salo, OGC
Craig Hooks, FFEO
Liz Cotsworth, OSW
Bruce Gelber, DO!
Superfund Managers
[ EPA Home I OSWER Horn* I Sutxrfund Home ]
[Search EPA 1 Search Suowfund I What's New 1 Contact U» 1
URL: http://www.epa.gov/superfund/programs/rvforms/remedy/indevhtm
This page last updated on October 2.1998
Web Page maintained by Office of Emergency and Remedial Response
Comments: superfutut.info9epa.iiov.
— —•^•nH/nmaram«/ri"fnrms/remedv/index.htm
-------
"t
OFFICE Of
SOLO WASTE AND EMERGENCY
RESPONSE
OSWER #9355.0-94
MEMORANDUM
Release of Summary Report for FY 2000 and FY 2001 for the Superfund
Administrative Reform "Updating Remedy Decisions"
Michael B. Cook, Director 0' ^
Office of Superfund Remediation and Technology Innovation
Superfund National Policy Managers, Regions 1-10
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
AUG 29 2003
SUBJECT:
FROM:
TO:
We are distributing electronically the third in a series of two-year reports, which
summarize the progress made through implementation of the Superfund Administrative
Reform entitled Updating Remedy Decisions during FY 2000 and FY 2001. This
document can be accessed at the following Superfund Reforms web site:
http://www.epa.gov/oerrpage/superfund/Dro grams/reforms/docs/
Since this reform was announced on October 5,1995, the Superfund program
continuously tracked national progress updating remedies. The following statistics
concerning the progress of this reform are included in this summary report:
o Cumulatively, from FY 1996 through FY 2001, EPA has updated over 415
remedies, reducing estimated future cleanup costs by more than $1.7 billion, while
at the same time increasing estimated future cleanup costs by only about S225
million.
o Specifically, for FY 2000 and FY 2001, EPA updated 111 remedies, reducing
estimated future cleanup costs by more than $265 million, while at the same time
increasing estimated future cleanup costs by about $100 million.
o For FY 2000 and FY 2001, half of ten EPA Regions have accumulated estimated
savings in excess of $50 million.
Internet Address (URL) • http j7www apa.gov
Recycled/HecycUble • Pmted «th VtQttobkt CM Based Into on Recycled Paper (Mmmum 25% Poslconsumer}
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-2-
o For FY 2000 and FY 2001, about two-thirds of the remedy updates were initiated
by parties outside of EPA . About two-thirds of the remedy updates were
documented with Explanations of Significant Differences, not Record of Decision
(ROD) Amendments.
These results clearly show that measurable progress continues to be made by
implementing this reform. The results also show a maturation of this reform over time.
Originally, Regions and outside parties identified numerous remedy updates which
generated high estimated savings. Today, we see more remedy updates which generate
lower estimated cost savings and, in some cases, an increase in the frequency of updates
which result in higher estimated costs than the original remedy.
The data contained in this report was accumulated by contacts in each region and
then forwarded to headquarters for national tracking. The bulk of this report consists of
two large Appendices, which give site-specific details on each remedy update completed
during this two-year period. Much of the data we track was part of a congressional
inquiry received during the initial stages of the reform. This data is used for tracking
purposes only. This document is not a substitute for EPA's statutes, regulations or
guidance, and does not impose requirements or policy changes with regards to remedy
selection.
For further information on this reform, please contact Matt Chars Icy of my staff at
Charskv.matthew@eDa.gov or (703) 603-8777.
cc: Nancy Riveland, Superfund Lead Region Coordinator, Region DC
Jeff Josephson
NARPM Co-Chairs
OSRTI Regional Center Directors
Steve Caldwell, OSRTI State/Site Identification Center Director
Joanna Gibson, OSRTI Document Coordinator
James Woolford, FFRRO
Charles Openchowski, OGC
Debbie Dietrich, OEPPR
Robert Springer, OSW
Walter Kovalick, TIO
Cliff Rothenstein, OUST
Linda Garczynski, OBCR
Elliott Gilberg, FFEO
Susan Bromm, OSRE
-------
SEPA
United States
Environmental Protection
Agency
Updating Remedy Decisions
at Select Superfund Sites
Biannual Summary Report
FY 2000 and FY 2001
February 2003
-------
Summary Report FYOO and FY01
Cumulative Summary (FY96-FY01)
Since its inception, Updating Remedy Decisions has continued to significantly impact Superfund sites
across the country. From FY96 - FY99, there were 307 remedy updates reducing future cleanup costs by
more than $1.4 billion while at the same time increasing estimated future cleanup costs by about S128
million. In FYOO and FY01, EPA updated more than 110 remedies, reducing estimated future cleanup
costs by more than S265 million while at the same increasing estimated future cleanup costs by about
5100 million. By including the FYOO and FY01 data, the cumulative totals for FY96-FY01 are 418 remedy
updates reducing future cleanup costs by more than $1.7 billion while at the same time increasing
estimated future cleanup costs by about S228 million.
Executive Summary (FYOO—FY01)
During FYOO and FY01, Updating Remedy Decisions continued to be one of EPA's most successful
Superfund reforms. The key successes and findings include the following:
•	Most remedy updates completed during FYOO and FY01 were the result of additional technical
information gathered as part of the remedy design process A small number of remedy updates were
the result of non-technical changes in the applicable or relevant and appropriate requirements
(ARARs), land use, or required cleanup levels. Another small number of remedy updates were the
result of State input or community preference which focused on either technical or non-technical
modifications to the remedy.
•	EPA tracked all remedy updates during FYOO and FY01, most of which were reform-related. In FYOO,
the total estimated cost savings for remedy updates were in excess of $185 million, all of which was
based on scientific and technological advancements. For remedy updates completed in FY01, the total
estimated cost savings were in excess of $84 million, all of which was based on scientific and
technological advancements. There were 10 remedy updates in FYOO that resulted in cost increases
totaling an estimated 587.7 million, and there were 6 remedy updates in FY01 that resulted in cost
increases totaling an estimated $12.5 million.
•	Estimated cost savings for 111 individual remedy updates during FYOO and FY01 ranged from a
negligible amount to over $75 million, with most remedy updates generating savings under $10 million.
There were also 16 remedy updates that resulted in estimated cost increases of over $100 million, with
a majority under $2 million.
•	Remedy updates generally occurred in the remedial design phase of the cleanup process and were
more likely to be documented with Explanations of Significant Differences (ESDs) than Record of
Decision (ROD) Amendments. Over the two-year period, there were 70 ESDs and 41 ROD
Amendments representing remedy updates with both cost savings and increases.
•	Most remedy updates during FYOO and FY01 were initiated by parties outside of EPA (e.g., potentially
responsible parties (PRPs), States, communities, Federal facilities). Over the two-year period, parties
outside of EPA initiated 66 updates and EPA initiated 55 updates (these numbers do not include 38
updates initiated by more than one party).
•	Over the two-year period, the most commonly addressed medium was ground water (68 updates)
followed by soil (59 updates). Nine other media types were addressed by remedy updates during FYOO
and FY01.
1
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Table of Contents
Cumulative Summary	1
Executive Summary	1
1.0 Introduction 	3
2.0 FY00 and FY01 Results 	4
Exhibit 2.1: Estimated Remedy Update Savings by Region in FYOO and FY01 	4
Exhibit 2.2: Estimated Savings Per Remedy Update in FYOO and FY01 	5
Tab/e 2A: Remedy Updates by Medium in FYOO and FY01 	5
Table 2B: Number and Type of Remedy Updates in FYOO and FY01 	6
3.0 Remedy Update Initiators 	6
Exhibit 2.3: Remedy Update Initiators in FYOO and FY01	7
3.1	Remedy Update Type 	8
Table 2C: Types and Percentages of Remedy Updates in FYOO and FY01 	8
3.2	State/Tribal and Community Roles 	8
3.3	Remedy Update Duration	8
Exhibit 2.4: Approximate Review Time for Remedy Updates in FYOO and FY01 	9
4.0 Lessons Learned 	9
4.1	Benefits 	10
4.2	Site Examples 	10
5.0 Conclusion 	12
Acknowledgments
Appendix A: Summary of Updated Remedy Decisions for FYOO and FY01
Appendix A. 1: Summary of Remedy Update Information for FYOO
Appendix A.2: Summary of Remedy Update Information for FY01
2
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Summary Report FYOO and FY01
1.0 Introduction
Updating Remedy Decisions, announced in the third
round of Superfund Reforms in October 1995, is one of
a broad range of administrative reforms undertaken to
improve the efficiency, speed, and fairness of the
Superfund program. Specifically, the Reform
encourages the Regions to revisit selected remedy
decisions at sites where significant new scientific
information, technological advancements, or other
considerations will protect human health and the
environment while enhancing overall remedy cost
effectiveness.
This report contains an evaluation of remedy updates
completed during FYOO and FY01 and is the third
biannual Summary Report since the reform was
announced. Previous remedy update reports may be
found as indicated below.
For remedy updates completed in FY96 and FY97, see
the document,"Updating Remedy Decisions at Select
Superfund Sites, Summary Report, FY 1996 and FY
1997: July 1998, OSWER Directive 540-R-98-017 on
EPA's website listed below. The Summary Report for
FY96 and FY97 contains the background information of
the Reform, a description of the Reform, the process
for implementing the Reform, and Regional
implementation plans from each of the ten EPA
Regions.
For remedy updates completed in FY98 and FY99, see
the document"Updating Remedy Decisions at Select
Superfund Sites, Summary Report, FY 1998 and FY
1999." March 2001, OSWER Directive 540-R-01-00 on
EPA's web site listed below.
Finally, to find a cumulative summary of this reform as
well as trends during fiscal years 1996 through 1999,
see the document, "Updating Remedy Decisions at
Select Superfund Sites Cumulative Summary Report
FY 1996 Through FY 1999," March 2001, OSWER
Directive 9355.0-77 on EPA's web site listed below.
•	Highlights estimated future cost reductions (cost
savings) or cost increases expected to result from
updated remedies; and
•	Presents stakeholders with information on the role of
remedy updates in improving Superfund
implementation.
Since this reform was announced, EPA sought to
encourage remedy updates that would incorporate
such new information into existing site cleanups. As a
whole, reforms were implemented to make Superfund
faster, fairer, and more efficient.
It is important to emphasize that this initiative does not
signal any variations in the Agency's current policies
regarding site cleanup, including policies regarding
remedy selection, treatment of principal threats,
preference of permanent remedies, establishment of
cleanup levels, or the degree to which remedies must
protect human health and the environment. EPA
remains committed to the protection of public health,
welfare, and the environment as provided in CERCLA
and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP).
For Previous Remedy Update Reports,
visit these Web sites:	
For remedy updates completed in FY96 and
FY97 see:
http://www.epa.gov/oerrpage/superfund/
programs/reforms/docs/urd96-97.pdf
For remedy updates completed in FY98 and
FY99 see:
http://wwwZepa.gov/oerrpage/su perfund/
programs/reforms/docs/biannual.pdf
For remedy updates FY96 through FY99 see:
http://www.epa.gov/superfund/programs/
reforms/docs/cumulat.pdf
The FYOO and FY01 report:
• Provides a summary of Superfund sites where
remedies have been updated;
3
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
2.0 FY00 and FY01 Results
EPA completed approximately 111 remedy updates
in FY00 and FY01, saving over S265 million in
estimated site cleanup costs, while at the same
time creating increases in estimated site cleanup
costs of only about $100 million.
Updates during FY00 resulted in a total estimated cost
savings of over $185.0 million, all of which resulted
from updates of the kind identified in the Reform
Guidance. Updates during FY01 resulted in a total
estimated cost savings of over $84.0 million, all of
which resulted from updates of the kind identified in the
Reform Guidance.'
The estimated cost savings per update ranged from a
negligible amount to $75.0 million, with all EPA Regions
reporting savings in each year reviewed. Exhibit 2.1
shows the amount of savings, by fiscal year, among the
EPA Regions. Exhibit 2.2 shows the amount of
estimated savings for both fiscal years. (Note. Exhibit
2.2 may not include all remedy updates from FY00 and
FY01 because of limitations on EPA Regional
accessibility to non-EPA remedy update information.)
Most of the remedy updates generated savings of less
than $10.0 million per update, as shown in Exhibit 2.2.
(Note: Cost estimates for several remedy updates are
either unavailable to EPA or incomplete at the time of
this writing. These are labeled NA/TBD (Not available/
To be determined) in Appendices A, A.1 and A.2.)
90
80
70
60
I 50

40
30
20
10
0
Exhibit 2.1:
Estimated Remedy Update Savings by Region in FYOO and FY01
J	i
i
I



I
12.1
!5.<
)

23
n
18.2
21


¦
1 »
1
| o-s ^
i.J i ft.*-.
83.4
5.2
5	6
Region
~ FYOO
¦ FY01
8	9	10
Based on 111 updates
'(See the Reform Guidance. "Supertund Reforms: Updating Remedy Decisions.* OSWER Directive 9200.2-22, dated September 27. 1996. at
EPA's website: http://www.epa.gov/oerrpage/superfund/prograiTis/raforiTi8/remedy/index.htm.)
4
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Summary Report FYOO and FY01
Exhibit 2.2:
Estimated Savings Per Remedy Update in FYOO and FY01
Increases
22%
NA/TBD
19%
¦ No Savings
¦ <$1M
~ >S1 M-S10M
~ >S10M-S20M
¦ >S20M
~ NA/TBD
¦ Increases

No Savings
33%
S10M-S20M
4%
>S1M-S10M
10%
Based on 111 updates
EPA Regions also reported on updated remedies that
generated cost increases during FYOO and FY01. The
FYOO cost increases for 10 remedy updates totaled
$87.7 million. The FY01 cost increases for 6 remedy
updates totaled $12.5 million. Most of these remedy
updates generating estimated cost increases during
FYOO and FY01 were less than $2.0 million per update.
The remedy update cost increase for FYOO and FY01
occur in eight EPA Regions and no EPA Region has
more than four increases over the two-year period.
Recent advances in the area of soil and ground water
science and remediation made remedies involving
these media good candidates for remedy updates.
Table 2A shows that during FYOO and FY01, updates of
ground water remedies were the most common (68
updates), followed by soil remedies (59 updates). The
remaining updates pertained to nine other media, as
Table 2A:
Remedy Updates by Medium in FYOO and FY01
Medium
FYOO
FY01
Total
Ground Water
43
25
68
Soil
32
27
59
Sediment
2
5
7
Debris
4
0
4
Surface Water
3
1
4
Sludge
3
0
3
Leachate
2
1
3
Solid Waste
3
0
3
Wetlands
2
0
2
Air
1
0
1
Other (Slag)
1
0
1
5
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Table 2B:
Number and Type of Remedy Updates
in FYOO and FY01


FYOO
FY01
Total
Total # of Remedy Updates
64
47
111
# Updates With
Estimated Savings
37
20
57
# Updates With
No Savings
14
10
24
# Updates With
Estimated Increases
10
6
16
# Updates NA or TBD
3
11
14
depicted in Table 2A. These media are consistent with
media typically found at contaminated Superfund sites.
More detailed information regarding remedy updates
completed in FYOO and FY01 can also be found in
Appendices A, A. 1 and A.2. Specific remedy updates
are listed by Region and site, and include the following
information:
•	Type and date of remedy update;
•	Update initiator;
•	Media involved;
•	State and community involvement;
•	Estimated resource demands;
•	Estimated cost savings or cost increases; and
•	Summary of remedy change and factual basis.
Table 2B depicts the number and kind of remedy
updates that were completed in FYOO and FY01. It
shows that not all remedy updates generated cost
savings or cost increases. In some cases, the remedy
updates generated neither cost savings nor cost
increases; in other cases, the numbers are yet to be
determined or were unavailable at the time of this
report. Because all values are not included in this
report, the summary totals are conservative values for
estimated cost savings and increases. The daia do not
differ significantly from FYOO to FY01.
3.0 Remedy Update Initiators
After a remedy decision has been completed at a site
(i.e., a ROD is signed), new information may be
received or generated that could affect how the remedy
selected in the ROD should be implemented. This
information may be supplied by a PRR a Federal
agency conducting the cleanup, the support agency
(e.g.. another Federal agency or State/Tribe), or the
public or other interested parties. Data for FYOO and
FY01 indicate that 63 remedy updates were initiated by
parties oulside of EPA (e.g., PRPs, States,
communities. Federal facilities) compared to 34
updates initiated by EPA (see Exhibit 2.3). In addition.
14 remedy updates have joint initiators because
information arrived simultaneously from several
different parties. Exhibit 2.3 shows that the relative
percentages of remedy update initiators were not
significantly different from FYOO to FY01.
6
-------
Summary Report FYOO and FY01
Exhibit 2.3:
Remedy Update Initiators in FYOO and FY01
Remedy Update Initiators in FYOO
Stale (4)		PRP(Il)
FedFac(lO)
¦ Slate (4)
Bused on 6-1 iipiiiiles
Remedy Update Initiators in FY01
State(l)	PRP (18)
EPA (16)
Based on J 7 updates
~	PRP (18)
¦	EPA (16)
~	Joint (3)
~	Fed Fac (9)
¦	State (I)
7
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
3.1 Remedy Update Type
Generally, the type and scope of change will
determine which of the following documents EPA uses
to update the remedy: memorandum or note to the
Administrative Record for a non-significant or minor
change; an ESD for a significant change; or a
ROD-Amendment for a fundamental change.
For background information on remedy update type,
see "A Guide to Proposing Superfund Proposed Plans,
Records of Decision, and Other Remedy Selection
Decision Documents,"OSWER Directive No. 9200.1-
23P (July 1999). Enforcement decision documents
may also need to be modified, depending on the type
of remedy update and the language in the order or
consent decree, if there is an order or consent decree.
As shown in Table 2C, there were 70 ESDs and 41
ROD Amendments completed during FY00 and FY01.
There were no minor changes completed during FY00
and FY01.
In general, more remedy updates occur during remedy
design and represent a significant but not fundamental
change to the remedy. More remedy updates also
correspond to at least one of the following situations:
the scope of the remedy has changed (e.g., volume
increase or decrease); the performance of the remedy
can be modified or optimized (e.g., change in disposal
or discharge point); or there is a more cost effective
way to implement the remedy.
3.2 State/Tribal and
Community Roles
Most remedy updates in FY00 and FY01 involved State
participation and/or community involvement. Although
the initiation of a formal public comment period is
required only in the case of a fundamental update [i.e.,
ROD Amendment), most remedy updates, regardless
of their significance, have a substantial community
involvement component (see NCP Section
300.435(c)(2)(i) and (ii)). For example, documents
pertaining to the site, including any information on
remedy updates, are placed in the Administrative
Record or at the site repository located near the site
(e.g.. local library). Other activities, including a public
availability session, public meetings, issuance of fact
sheets about the site, and the release of an amended
proposed plan, may allow the surrounding community
and other interested parties an opportunity to learn
more about the site and present their opinions on
remedial activities.
Refer to the individual site summaries in Appendices
A.1 and A.2 for specific activities related to State
participation and community involvement that were part
of the remedy update process for each update
completed during FY00 and FY01. States initiated five
remedy updates during FY00 and FY01. There were
no Tribal-initiated updates and no community-initiated
updates either. There were three public-joint updates
and eleven State-joint updates.
Table 2C:
Types and Percentages of Remedy Updates
in FY00 and FY01
ESDs
ROD Amendments
FY00
39 (56%)
25 (61%)
FY01 Total
31 (44%) 70
16(39%) 41
3.3 Remedy Update Duration
Reviewing site-specific material and completing the
ESD or ROD Amendment took less than a year for a
majority of the remedy updates completed during FY00
and FY01 (see Exhibit2.4). Of note, there is a slight
increase in the number of remedy updates with
extended review periods. An examination of sites with
longer review periods suggests that the review
durations were influenced by:
•	A lengthy, but important public involvement phase;
•	An extensive verification/pilot test period following
the discovery of new performance, technical, or
toxicological data;
-------
Summary Report FYOO and FY01
Exhibit 2.4:
Approximate Review Time for Remedy Updates in FYOO and FY01
Review Time for Remedy Updates in FYOO
-3—3-
~ ROD-A
¦ ESD
1-2
years
>2-3 >3-4 >4 years
years years
Based on 64 updates
Review Time for Remedy Updates in FY01
25
20
15
10
5
0
—I 4
"TlTJ
o
~ ROD-A
¦ ESD
<1 year >1-2 >2-3 >3-4 >4 years
years years years
Based on 47 updates
4.0 Lessons Learned
•	The discovery of unexpected contamination late in
the remedy design phase; or
•	A redefinition of land use.
Section 4.2 provides specific examples of remedy
changes whose reviews lasted more than one year.
During the last two years of reform implementation,
EPA has gained insight into ways of successfully
updating site remedies. The following sections detail
information collected regarding reform benefits, site
examples, and comments from stakeholders.
9
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES	||||||||a||H||HBHH||||||
4.1	Benefits
This Reform has been very successful in bringing past
decisions in line with current science and technology.
By doing so, these updates improve the cost
effectiveness of site remediation while ensuring reliable
short- and long-term protection of human health and
the environment. The quantifiable results of this
Reform have been announced in EPA's testimony
before Congress, described in private industry
evaluations of Superfund reforms, and included in a
report by the U.S. General Accounting Office. Of
additional note is EPA's overwhelmingly positive record
of responding to remedy update requests made by
outside parties.
4.2	Site Examples
In many cases, remedies were updated as a result of a
decrease or increase in contaminant volume or an
inability to achieve desired results in a test of the ROD-
selected treatment or contaminant technology during
the remedial design phase of the cleanup Although all
updates described in Appendix A represent site-
specific situations, it is possible to use some as
examples of typical remedy update situations that
occurred during FYOO and FY01.
Updates Based on New Technology
Some updates were the result of new technology that
was not considered at the time of the original remedy.
For instance, the results of a pilot test to characterize
the extent of contamination lead to a change in the
remedy at the Keystone Sanitation Landfill in
Pennsylvania. The original remedy, which included
excavation and capping of the contaminated area and
site access restrictions, was replaced with a new gas
extraction method used in conjunction with upgrades to
the existing soil cover, monitoring, and institutional
controls. Consequently, the contaminated soil and
landfill waste cleanup has proceeded with estimated
savings of $3.6 million.
Similarly, the results of a treatability study conducted
during the Remedial Design supported a remedy
update at the New Hanover County Airport Burn Pit
in North Carolina. A traditional ground water pump
and treatment system was replaced with air sparging
as an innovative technology, with resultant estimated
savings of S2.000.
New technology paved the way for a change tn the
remedy at the Odessa Chromium site in Texas.
Nearly $1 million in estimated savings were achieved
with remedy updates on two operable units where a
ground water pump and treat system was replaced by
an innovative technology known as in-situ ferrous
sulfate treatment.
Updates Based on New Performance Data
New performance data can also provide the needed
basis for updating remedies. At the Vineland
Chemical Co., Inc. in New Jersey, the changes
documented in the ESD were based on new
information received subsequent to the issuance of the
ROD. Performance studies indicated that, by following
the remedy outlined in the proposed plan, cleanup level
for arsenic would not be attained in the contaminated
soils. The original remedy of in-place soil flushing was
replaced by excavation and soil washing in a soil
washing treatment plant with clean soil re-deposited
on-site. Over $14 million in estimated savings resulted
from this remedy.
Coordinating the Update
Some remedy updates involve coordination among
EPA, other Federal agencies, and State and local
government agencies. For example, at the Idaho
National Engineering Lab (INEEL) U.S. Department
of Energy (DOE) facility, EPA coordinated the remedy
update with the State and DOE as a Federal facility.
The original remedy involved a ground water pump and
treat system for all zones of a contaminated plume.
However, post-ROD treatability studies demonstrated
that the cleanup could be conducted in less time and at
a lower cost. The remedy update consisted of cleanup
of a "hot spot" area at INEEL in conjunction with a
pump and treatment system for part of the
contaminated plume and monitored natural attenuation,
with resultant estimated savings of $1 million.
to
-------
Summary Report FYOO and FY01
State Input in the Update
States can be either the lead or support agency for a
remedy update. The remedy update was State-lead at
the Duell and Gardner Landfill in Michigan. The
results from a post-remedy Investigation demonstrated
that the extent of contamination in the soil and ground
water was less than expected, and the size of ground
water plumes either stabilized or decreased since the
Remedial Investigation. Moreover, the State revised its
cleanup standards which reduced the amount of soil
that required excavation and disposal. By replacing the
low temperature thermal desorption required in the
original remedy with long-term monitoring, use
restrictions or institutional controls, and landfill capping,
in accordance with new State standards, estimated
savings of S3.4 million resulted.
Community Preference
Community preference can have a significant impact in
addressing site contamination. For example, EPA
participated in numerous community meetings at the
Rowe Industries site in New York in an attempt to
implement the original remedy. Strong and sustained
community opposition to discharging all treated water
directly into the surface water lead to a remedy update
whereby the discharge was split between the surface
water and recharge basin. This change in the remedy
meant that the discharged surface water would only
replace the ground water that would normally seep into
the surface water if the plume was not being pumped,
and resulted in undisclosed cost savings.
Another example of the effect of community
involvement on remedy updates, occurred at the
Monroe Auto Equipment Co. in Arkansas. The
public was supportive of a remedy update which
changed on-site containment of soils and sludges to
treatment and off-site disposal because it provided
greater reuse possibilities for the site. The revised
remedy was as protective as the original remedy, and
also resulted in undetermined cost savings.
Cost Increases
While the Reform Guidance is aimed at controlling all
site costs, there are remedy updates that result in cost
increases. At the Denver Radium Shattuck Chemical
site in Colorado, the original remedy was replaced
after a Five-Year Review yielded additional data on
contaminated soils. Although this remedy update
resulted in an estimated cost increase of $35 million,
the process incorporated facilitated meetings with State
and local officials as well as community members. As
a result, remedy alternatives were selected to allow for
restricted use of the site following cleanup.
Similarly, at the San Gabriel Valley site in California.
a remedy update became necessary when data
revealed that concentrations of contaminants in ground
water increased to unacceptable levels. The original
passive remedy of monitoring only was replaced by a
more active remedy for ground water containment
using a pump and treat system. An estimated cost
increase of S24 million resulted, with the State sharing
the cost.
Timeframe for Completing
Remedy Updates
The time needed to complete an update varies with
each site. In some instances, exploring other remedies
takes years of review and completion. For example, at
the McKin Co. site in Maine, a technical evaluation
documented that cleanup under the original remedy
within a reasonable time frame was not possible. The
remedy update to achieve ground water restoration
involved the use of institutional controls, long-term
monitoring, and contingencies in the event that certain
monitoring criteria are exceeded. Undetermined cost
savings resulted from the change in remedy.
In contrast, a review for the remedy update at
Coiesville Municipal Landfill site in New York took
roughly six months to complete. The results of field
tests, sampling, and a treatability study lead to an
enhanced remedy with resultant estimated savings of
$10 million. Moreover, the potentially responsible party
at the site considered remedy alternatives with
complete State involvement.
11
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES	¦¦¦¦¦¦¦¦¦¦¦¦¦¦¦
5.0 Conclusion
EPA and outside parties continued to consider
Updating Remedy Decisions a successful Reform in
both FYOQ and FY01, The number of remedies
updated by each Region during FYOO and FY01 clearly
shows that all ten EPA Regions are implementing this
Reform, with half of the Regions reporting estimated
cost savings above $50 million for the two fiscal years
combined, AH ten EPA Regions continue to evaluate
requests to review early Fund-lead remedies, as well as
consider updates to more recent remedies that may not
be up-to-date with current science or technology.
Regions also continue to encourage outside parties to
submit remedy update requests to EPA when new
technical information exists to support them. Typically,
EPA and outside parties share the benefits of both cost
and time savings as a consequence of implementing
the updated remedy.
Interested parties should review the existing Reform
Guidance (OSWER Directive 9200.2-22) for basic
information concerning the Reform. Additional
guidance on remedy updates is included in the updated
Record of Decision Guidance (see "A Guide to
Preparing Superfund Proposed Plans, Records of
Decision, and Other Remedy Selection Decision
Documents," OSWER Directive 9200.1-23P, July 1999).
Specific questions on implementation of the Reform
may be directed to Matt Charsky of the Office of
Emergency and Remedial Response by telephone at
(703) 603-8777, e-mail at
charsky.matthew@epamail.epa.gov. or FAX at (703)
603-9133. Each Region also has a remedy update
contact who can be reached by contacting the
Superfund Program office in any of EPA's ten Regional
offices.
Acknowledgments
This report was made possible by the dedicated efforts
of numerous EPA Superfund staff. Regional remedial
project managers (RPMs) responsible for considering
and implementing remedy updates at Superfund sites
are to be commended for making these changes to
select the best technologies available at Superfund
sites nationwide.
This report was prepared for EPA under contract #68-
W7-0051.
12
-------
Summary Report FYOO and FY01
Appendix A:
Summary of Update Remedy Decisions for FYOO and FY01
Note: The information and data presented in Appendix A have been supplied to EPA headquarters by Regional
offices. The data is subject to occasional updates as new information is received, thus Appendex A data
should be used for informational purposes only.
-------
Summary ok Di'da i i:i> Uk.mm>y Dkcisions r>r FYOO
Region
0 With No
Sav.
0 of TBI)
0 With Ett.
Sav.
0 With Est.
Incr.
Estimated
Saviors
Estimated
Increases
Change initiator
Type of Change
PRP
KPA
Stale
Fed.
Kac.
Public
Joint
ESD
ROD-A
1
3
0
(1
1
(1
in SM
1
.1
0
0
0
0
4
0
2
'
0
2
ll
$23 DM
0
3
0
0
0
0
0
2
1
3
2
()
7
1
132.IM
ill 9M
X
1
'
0
0
0
5
5
4
3
0
7
1
SO SM
Ml IM
4
s
0
1
0
1
5
6
5
1
1
7
ll
>35.')M
II
T
7
0
2
(i
3
A
5
6
0
0
3
0
J2.SM
II
1
0
2
0
0
0
2
1
7
2
0
1
i
J0.6M
til 6M
1
2
1
0
0
0
3
1
8
0
0
3
i
J4.7M
>35.(IM
0
0
0
2
0
2
2
2
V
1
1
3
i
$2 3M
>24 (IM
0
1
0
3
0
0
A
2
III
1
1
4
4
! 4M
>_'(. <>M
1
">
0
•t
0
5
H
¦>
1 utul
14
3
37
10
SI85.IIM
>87.7M
21
IK
A
Ml
0
11
39
25
14 3 37 10	21 PRP IX HI*A 11 JOINT	39 F.SD
64 sites	lOFFDFAC 4 STATE		25 ROD-A
64 sites	64 sites
Appendix A
1
-------
Summary ok Ui*i>atk.i> Ukmkdv Decisions kor FY01
Region
# With
No Sav.
not
TBD
# With Est.
Sav.
tf With Fit.
Incr.
Estimated
Savings
Estimated
Increases
Change Initiator
Type of Change
PRP
EPA
State
Fed.
Fac.
Public
Joint
ESf)
KOD-A
1
3
!
1
2
SI OM
SO MM
2
•»
0
s
0
0
X
1
2
0
3
()
0
$N 2K\
O
0
•>
0
0
0
1
3
0
3
1
1
(>
0
SIX 2M
O
f>
1
0
1
0
0
S
3
-1
1
0
1
t
il.-JM
VI SM
0
2
0
1
0
0
1
2
5
3
3
5
1
S9.2M
SI) 1M
7
4
1
0
0
0
X
4
6
'
0
1
0
S2I.0M
0
1
1
0
0
0
0
0
2
7
0
0
1
1
$ 11 OM
S4.0M
0
1
0
1
0
0
0
2
H
0
0
1
0
$2 6M
1)
0
0
0
1
0
0
I
0
y
0
0
1
1
W 3K1
S 4 OM
1
0
0
0
0
I
1
0
10
1
1
3
0
SS 2 M
0
1
.1
0
0
0
1
3
7
Tulal
10
II
20
6
>H4.1 M
SI2.5M
18
16
1
9
0
3
31
16
10 II 20 6	18 I'RP l(> HPA 9 FFID FAC	31 F.SD
47 silcs	3 JOINT I STATF		16 ROD-A
47 sites	47 silcs
Appendix A
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Appendix A.1:
Summary of Remedy Update Information for FYOO and FY01
for Sites Without Cost Increases
Note: The information and data presented in Appendix A.1 represent only a portion of the information available in
the decision document. If more information is needed, please refer to the site's ESD. ROD-Amendment,
memo-to-file, or letter.
-------
Summary of Remedy Update Information tor l«'Y00 and KY01 for Sites Without Cost Inereases
Region
Site Name, State
Date of
Original ROD Dale
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Ki'|;ion 1 - KY 00
Region 1
Iron Horse Park.
OU 2 - Shaffer 1 andfill,
MA
6/27/91
9/8/00 (LSD)
7/00
9/X/OO
I'RI'
(iround water
(leacliate)
State concurrence letter,
public meeting
Fed - Unknown
Contr - Unknown
list'd Savings = $0
Type of Change: From - Collecting leacliate via perimeter toe drains; To - Collecting leachate via dual band collection (leachate and
gas) wells in landfill.
Factual Basis: Collection of leacliate from the Icachatc mound should result in collection, treatment and disposal of much greater
volume of leachate than would be realized from the perimeter toe drains.
Region 1
U S Naval Construction
Battalion Center
Davisvillc, Rl
9/30/99
1/5/00 (PSD)
1 2/29/99
1/5/00
II'A
Soil. (irouiui
water
IT'A, Slate concurred;
community notified;
public notice in
newspaper
l ed - J2K
P.PA - $200
lis I'd Savings - SO
Type of Change: There is a need for a time extension ol two months
Factual Basis: The Navy's contractor was unable to provide a ( lass 1 survey for the area of institutional controls, in the tunc period
required by the ROD
Appendix A.l
I
-------
Summary of Remedy Update Information for KYOO and KYOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Orieinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 1
Sullivans Ledge Site OU 1,
MA
6/28/89
9/27/00 (USD)
9/27/98
9/27/00
LI'A
W etlands,
(irouml water
Series of informal public
meetings
Fed = None
Conlr = None
list'd Savings - SO
Type of Change: From - Concrete lining of unnamed stream adjacent to the cap over the disposal area and shallow ground water
collection trench; To - Stream placed in culvert and wetlands replicated (irouml water captured with slurry wall and shallow wells
Factual Basis: New site conditions during construction lead to new data and required construction changes in the field. Wetlands lost to
a stream ctilverting were replicated downstream. The shallow collection trench at the down gradient side of the cap was
supplemented with a slurry wall and 2 shallow wells
Region 1 - FY 01
Region 1
Fletcher's Paint Works and
Storage Facility, OU 1, Nil
9/30/98
3/14/01 (LSD)
1/01
3/14/01
I'K 1'
Soil
State concurrence letter,
community notified
Fed - 160 hrs.
Conlr. - None
Lst'd Savings - SO
Type of Change: From • Lxcavation and use of thermal desorption treatment; To - Addition of language to the the cleanup criteria
allowing consideration for the cleanup of arsenic to the background concentration, if the background concentration, is higher than the
cleanup level set in the KOI), and the consideration for the practical quant nation limit for bcno/.o(a)pyrene over the ROD cleanup level
Factual Basis: I'K P identified the "missing" ROD language allowing lor con side rat ion of background concentrations and practical
quantitation limits in establishing final cleanup cnlciia fm the silc
Appendix A.I
-------
Summary of Remedy Update Information for FYOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 1
l.oring Air Force Hase,
OU4, ML
(U.S. Air Force)
9/30/9(1 OlM
1/26/01 (ESI))
Unknown
1/26/01
U.S. An F'oice
Landfill ground
water
State concurred on LSI)
Restoration Advisory
lioard Consulted on
dralt I-;SI)
Fed Insignificant costs
incurred (lil'A)
C'onlr = Insignificant
costs incurred (US Air
I'orcc)
Rst'd Savings = $0
Type of Change: From - Minimal actum (monitoring) in conjunction with source control remedy (RCRA C covers), To - Revised
ground water compliance and ground water restriction boundaries to expand the oil-base parcel for which the U.S. Air Force obtained an
casement/institutional control (e g , no ground water extraction)
Factual Basis: Detection ol ground water contaminants associated with the land I'll Is oil the oil base boundary resulted in the remedy
update
Region 1
l.oring Air Force Base,
Oil 12, mi;
(U.S. Air Force)
9/19/99 OIJ12
1/26/01 (FSD)
Unknow n
1/26/01
US Air Force
(irounil water
Stale concurred on LSI)
Restoration Advisory
Hoard Consulted on
it raft FSI)
Fed - Insignificant costs
incurred (lil'A)
("ontr Insignificant
costs incurred (US Air
Force)
Lst'd Savings - $0
Type of Change: From - Limited action ground water management /one alternative, institutional controls, provisional water supply and
long term monitoring; To - Fxtcml the ground walei management /one for w Inch the U S Air Force obtained an easement associated
with an institutional control lor the oil base parcel west ol'lhe Quany
Factual Basis: Contamination associated with the Quarry was detected off-base and beyond the originally defined ground water
management zone-
Appendix A.l
3
-------
Summary of Remedy Update Information for KYOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
F.st'd Cost Increase
Region 1
Materials Technology
l aboratory (U.S. Army),
OU 1, MA
9/26/96
6/7/01 (ESI))
Unknown
6/01
At my
Soils
State concurred on ESI)
Restoration Advisory
Hoard given opportunity
to review and comment
on lira ft F.SI).
Fed - $500* (HI*A)
I'onlr. - N/A
Est'd Savings - $ 1 0-
$1 5M
Type of Change: From - Soil excavation ami oft -site disposal; To - Natural Attenuation
Factual Basis: Natural Attenuation
'Note: This was the second ESD for the site, although the issue in this ESD was the same as the earlier (1998) ESI) Therefore, the
resources from EPA for document review, etc were low
Region 1
McKin Co., ME
7/22/85
3/30/01 (KOD-A)
5/97
3/30/01
1.1'A
(1 round water
Mediated discussions
included EPA, State,
I'RI's, the town, the
local water district and
community members
Fed - Unknown
C'ontr. - Unknown
Est'd Savings -
Unknown
Type of Change: From - (iround water restoration to technical iinpiacticaliilily waiver for federal and state drinking water AKAKs;
To - Institutional controls, long term monitoring, contingencies lor future action should certain monitoring criteria be exceeded
Factual Basis: EPA's technical impracticability evaluation documented lh.il aquifer restoration within a reasonable time frame was not
technically feasible.
Appendix A.l
4
-------
Summary of Remedy Update Information for KYOO and KY01 tor Sites Without Cost Increases
Region
Site Name, State
Date of
Orisinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 1
New Bedford Harbor
OU 1,
MA
9/25/98
9/27/01 (LSD)
9/()/(> 1
9/27/01
1.1* A
Sediments
Slate concurred
Fed - 3 wks.
Contr. - None
iist'd Savings - $0
Type of Change: From - Design and construction of Confined D isposal Facilitation (CDFs) and associated water treatment facilities,
dredging sediments and place in CDF, interim capping; To - Added live elements to the 200 acre sediment cleanup, mechanical
dcwalcring; additional shoreline stabilization, use of the pilot study CDF; change in the CDF D wall design; and use of a rail line at
CDF.
Kactuul Basis: Additional site information (e g , field suivcys. sediment sampling and state-of-the art dredging field lest) and refined the
cleanup approach for llic upper and lower harbor area
Region 1
Union Chemical Co., Inc.,
ME
12/27/90
9/28/01 (CSD)
10/97
9/28/01
I'KI's
(iiound watci
Monthly meetings with
the local citi/.cns group,
the stale and the PRl's
Fed - Unknown
Contr. = Unknown
list * d Savings ;-
Unknown
Type of Change: From - Extracted ground water being treated using ultraviolet/oxidation and treated ground water being discharged to
surface water, To - In-situ use of chemical reductanls ami rcinjcction into 1 lie ground water
Factual Basis: The results of a pilot test indicated that ground water could be treated without first requiring extraction and disposal in
surface water.
Appendix A.I
5
-------
Summary of Remedy Update Information for l-'YOO and l-'YOl for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Mcginn 2 - KY 0(1
Region 2
Hyron Drum and Uarrcl,
NY
9/29/89
8/2/00 (LSD)
3/99
7/00
PRC
(iround water,
Soil
Lull State involvement;
community expressed
some interest and
expressed support for
the changes at an
8/24/00 public meeting.
Fed = 100 hrs
Contr. ^ None
Lst'd Savings ~ $0
Type of Change: From - The K( >1) called tor extraction and treatment of the contaminated ground water in (wo areas of the site,
recharge oi'thc treated ground water to the soil to enhance the Hushing of the contamination in the soil into the ground water (i.e., in-silu
soil (lushing), and further evaluation ol the concentrations of inorganic constituents in the surface soil in a third area of the site to
determine if levels of concern aic present. To - tt.iscd on prc-rcmcdial design (KM) sampling, it was concluded that further action in
these two areas is not warranted The contamination in the remaining area of the site, however, still requires remediation. To enhance
the remediation of the contaminated soil in this area, instead ol'Uncharging the Healed water to a recharge basin, as was originally
planned An infiltration gallery consisting of peiloralcd pipe and giavcl, will be installed alter the excavation of several feet of
contaminated soil The excavated soil will be transported off-site lor trcatnicnl'd isposal
Factual Basis: Data collected during prc-KD sampling revealed that the contaminant concentrations in the ground water in one of the
two areas of the site noted above are only marginally above the cleanup levels specified in the ROD and that the levels of inorganic
contain inanls in the mii face .soil in the third aie.i ol the silc noted above is eonsistent with bac k ground concentrations
Region 2
l olcsville Municipal
l.andlill, NY
3/29/91
9/7/00 (CSD)
2/00
8/00
I'M'
(iround water
Lull Stale involvement;
community expressed no
opinion
Led - 100 hrs
Conlr - None
Lst'd Savings - S> 10M
Type <>f Change: From - Pump and treatment; To - I'uitip and liealment Willi enhanced reductive dechlorination
Factual llasis: f ield tests, post capping, giound walci sampling, and a pilot si_.de licatability study
Appendix A.I
6
-------
Summary of Remedy Update Information for l<'Y00 and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Kegion 2
Myers Properly, NJ
9/28/99
7/6/00 (ROn-A)
1996
7/6/00
I'KI"
Soil
State worked with I:PA
as support/advisory
agency, local
neighborhood group has
been involved for
several years.
Fed -1000 hrs *
(ontr - None
list"d Savings - 1> 1
Type of Change: From - On-site treatment using soil washing and backfill and replacement with new soil; To - Off-site disposal in
secure landfill and replace with new soil.
Factual Basis: Treatability studies in the mid-1990's showed that original remedy using soil washing would not work.
•Note: lil'A used extensive resources to oversee multiple PKP treatability studies and several rounds of work plans and revisions There
were also regular meetings with the I'KI'. community and sl.uc to diMiiss llic planned icincdy update
Appendix A.I
7
-------
Summary of Remedy Update Information for FYOO and l<"YOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
F.st'd Cost Increase
Region 2 - !• V 01
Region 2
Kinbuc Landfill, NJ
9/28/92
8/16/01 (LSD)
6/3/97
5/2/01
F.I'A
Land fill
refuse/drums
Stale concurred with the
LSI) L:I'A held a
number of meetings
with the Town Council
about this work, and
found general
acceptance of IIPA's
planned remedy change
A local environmental
group has expressed
strong reservations
about ihe actions taken
not being "enough "
Fed 1 Unknown
("ontr - Unknown
Lsl'd Savings -
Unknown*
Type of Change: From - The original KOI) identified Ihe contents oflbe "Moiiml M" portion of the site as household refuse ami
industrial debris, and required maintenance of a clay cap A limited number ot drums were subsequently discovered; To • The LSI)
concluded that the Mound U remedy was still adequate, hut added icimnal of drums to the extent practicable The drum removal work
look place earlier in 200 1.
Factual Basis: RPA performed several investigations to determine the extent of the drums in Mound B. and collected samples of the
drums, the other refuse, and the ground water
•Note: The PRI* has not shared its response costs with F.I'A.
Appendix A.I
X
-------
Summary of Remedy Update Information for KYOO and l-'YOl for Sites Without Cost Increases
Region
Site Name, State
Date of
Oricinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 2
Rowc Industrie* Ground
Water Contamination, NY
9/30/92
7/97 (l-:SD)
5/5/01 (liSI))
3/01
5/01
l l'A. I'uhlie
(iround water
FI'A attended numerous
community meetings
trying to implement
construction of the
original remedy, but the
community was
adamantly opposed to a
treated water discharge
to surface water.
Fed 1 0 public mtgs
(n P A)
Contr - 10 public mtgs
Fst'd Savings "
Unknown*
Type of Change: From - Treated water being discharged to the surface water; To - Splitting the discharge between the surface water and
the recharge basin. That way. the discharged surface water only replaces the ground water that normally would seep into the surface
water if the plume was not being pumped as an attempt to balance the water discharge
Factual Basis: In response to public concern about potential impacts resulting from discharging ground water, the remedy was updated.
•Note: The I'RI' will implement the remedy update so I: PA docs not have the cost details
Region 2
Vine land Chemical, Co.,
Inc.. NJ
9/28/89
9/10/01 (LSD)
1 999
9/0 1
lil'A
Soil
State concurred with the
liS 1 > No significant
public opposition to the
i;si>
Fed - 40 hrs
Contr. = None
Lst'd Savings - $14 2M
l ypc of Change: l-rom - In-place soil Hushing (llusli into the shallow aquifer where contamination was to be collected by a pump and
treat plant); To: F.xcavation and soil washing in soil washing treatment plant and redeposition of clean soil on-site
Factual Basis: The pump and treat studies indicated that the uiisatuiated /ouc soils would not all reach the cleanup level lor arsenic and
icsiillcd in the remedy update
Appendix A.I
9
-------
Summary of Remedy Update Information tor I VOO and l«'Y(ll for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
KiKioii .3 - KV 00
Region 3
Aladdin Plating Site Oll2,
I'A
1 2/30/93
1/21/01) (ESI))
12/99
1/21/01
II' A
(iround water
The slate concurred with
icmcdy change
Kequired changes to
Administrative Record
made in accordance with
40 CFR.
l ed - 50 hrs
Contr - None
Lst'd Savings - $0
Type of Change: The original remedy, which provided for sampling, will be done by removal instead of the remedial process
factual Basis: Sampling should have been a removal action untier CLRC1 A section 101(23)
Region 3
Avco Lycoming
Williamsport Division, PA
6/30/9 1
4/9/92 (LSD)
12/30/96 (ROD-A)
4/6/00 (ROD-A)
5/9X
4/6/00
l'l< 1'
(iround waler
State provided support
throughout the
evaluation and
cone lined on
amendment. Public
meeting and comment
period Comments
addiessed ill
Responsiveness
Summary
Fed - 150 hrs
Contr. = None
list'd Savings -- $1 9M
Type of Change: From - Lxtraction with air sparging/soil vapor extraction (SVL) and metal precipitation systems to address organic;
installation of a molasses injection system to address licxavalenl chromium. To - (iround water recovery system to capture volatile
organic compounds; source reduction through either air sparging'SVL, ground water extraction and/or m-silu oxidation; and recogni/e
existing down gradient extraction system C ontinue iiimIu metals precipitation and monitoring
(-'actual It tikis: Supplemenl.il data gallic red a tier hi si a ll.it ion of .in spai gmg and S V1: «;u found to he I lie lice live, due to subsurface
geologic conditions.
Appendix A.I
10
-------
Summary of Remedy Update Information lor l-YOO and l-'YOl for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 3
Brown's Battery Breaking,
HA
OlJtfl - 9/2X/90
(HJ#2 - 7/2/92
5/31/00 (ROD-A)
1/95
5/00
I'R 1'
Soil
State approval: 5/2 3/00
Public meeting and
comment period
April/May 2000
l ed 1 50 hrs
C ontr - None
lis I'd Savings - $2 6M

Type of Change: From - Additional soil excavation in Appendix (i areas to a cleanup level of 200 ppm; planned excavation sei|iience,
prior to tlie issuance of Appendix (i; solidificaiioii/slahili/ation ol all materials excavated from the site prior to oil-site disposal,
separation of incidental lead posts and plates from casings prior to treatment; permanent relocation of on-site residents and business and
implementation of deed restrictions to limit future use; To - l.imil excavation in Appendix (i areas where sampling confirms removal of
lead up to 200 ppm; reevaluate llic sequence of excavating Appendix (i soils and other soils exceeding 1000 ppm cleanup standard
Allow testing of marginally contaminated soils to determine if treatment is needed; change potential future use of property

Factual Basis: federal iruslccs identified additional soil excavation aieas Test pitting in pre design outlined the extent of
contamination
Region 3
Keystone Sanitation
Landfill OUI.I'A
9/30/90
9/14/00 (ROD-A)
1 1/98
9/14/00
I'R P
Soil, l andfill
wastes
State consulted an
alternate source control
remedy and concurred
with amendment Public
meeting and comment
period with no
objections.
Fed - 1 50 hrs.
I'ontr = 0
Fst'd Savings = $3 6M

Type of Change: From - Lxcavation and consolidation into landfill; impermeable cap and gas collection system over landfill and
subsequent revegetation; and implementing site access restrictions; To • l'niploy Fnhanced Landfill (ias lixtraction (LLGE) system to
remove and destroy volatile organic compounds (VOl's) and methane from landfill waste; upgrades to existing soil cover; monitoring,
and institutional controls

Factual Basis: Pilot test conducted foi lit
concentration
1 system New mclliod> now available to eharacteri/e landfill pel meal)ility and gas
Appendix A.I
-------
Summary of Remedy Update Information for KYOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 3
Metal Bank Silt, PA
12/31/97
9/2 7/00 (KSI>)
3/6/00
9/00
I'KP
(iround water.
Soil
State concuiicd with
LSD
Fed 75 hrs
Contr - None
Lst'd Savings = JO
Type of Change: From - Install oil collection system; install temporaly cofferdams; soil monitoring. To - Lxcavale l.NAPI. in lieu of
oil collection system; eliminate cofferdams, elimination of soil mointoiing program and use of geotextile layer
Factual Basis: Preliminary design sampling ami investigation results lead to the remedy update
Region 3
Moycr Landfill Silo, PA
9/20/85
1/3/00 (LSD)
4/26/99
12/23/99
State
(iround water.
Surface water
Public Notice
requirements of 40 CFR
and sub parts have been
met
Fed = 75 hrs
C'ontr = None
Est'd Savings = $2M
Type of Change: From • On-site treatment of leachate; To • I cucliate collection with treatment at an existing Publicly Owned
Treatment Works, contingent on the construction of interceptor sewers
Factual Basis; Results of recent flow data lead to I lie remedy update.
Region 3
MW Manufacturing Site,
PA
Oil#3 6/30/93
9/2 7/00 (LSD)
1 1/95
7/00
I'KP
(iround water
Stale concurred with
LSD
Fed - 60 hrs
Contr = None
Lst'd Savings $20M
Type of Change: From (itouml water extraction system lor DNAI'I collection, lo Construct an interceptor ticncli and intermittent
liediock wells for DNAI'I collection Note: Cleanup standards changed liom liackgiouinl to M( l..s, which was anotlicr molivc toi the
icinedy change.
Factual Uasis: Prc-dcsign investigation results including .1 geopmlic investigation, grouiul watei sampling to I VOCs, overhiirilen
ac|uilcr test, natural attenuation evaluation, and additional giound water modeling
Appendix A.I
12
-------
Summary of Heniedy Update information for I'VOO and FY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Ked/Contr.
Est'd Cost Increase
Region 3
Old City of York Landfill
Site, PA
9/30/91
3/31/00 (ROI)-A)
9/I/9X
3/00
I'R 1'
(n ound water
Slate approval received
in February 2000
Public informed on
9/21/99.
Fed 250 hrs
Conlr - None
list'd Savings = $0 5M
Type of Change: From - Operate a ground water reeovery/trealinent system in both refuse Areas 1 and 3 and install additional
extraetion wells in these areas, if needed; To - Monitored natural attenuation with institutional eontrols in both refuse Areas 1 and 3.
factual Basis: Results of a ground water extraction and Irealment system lead to the remedy update
Region 3
Whitmoycr Laboratories
Site (OIJ3), l'A
12/31/90
9/30/99 (ROD-A)
8/24/00 (ROI)-A)
.3/X/00
6/22/00
PHP
Soil
Slale concuiicd with
Amendment U2 lor OIJ
S3 on 7/21/00
I'llirty-day public
comment period
(6/22/00-7/22/00), in
addition to a public
meeting held on 6/26/00
Fed- 175 hrs.
(,'ontr. - None
Fsl'd Savings - $ 1 5M
Type of Change: From - Excavate moderately contaminated unsaturated oil-site soil, cover on-site soil witli impermeable cover; off-
site disposal of nonhazardous concrete and building debris; and excavate and dispose of underground piping and building foundations
To - Leave moderately contaminated unsaturated soils in place, olT-sile. and cover with two feel of clean soil; eliminate soil excavation
activities in the southeastern oil-site area along the sleep embankment adjacent to rail tracks; allow for non-ha/ardous concrete and
building debris to be used as fill on site, undcrncalli >oil cover, and allow nonha/ardous building foundations and nonha/ardous piping
to be left on-site, provided that they are located below the two fool cover of clean soil. Deed restrictions necessary for oil-site areas
where contaminated unsaturated soil icmaius m place
Factual Basis: f inal soil/sedimenls delineation piogiam icmiIis icpoit icsiilled in tlic iciiicdy update
Appendix A.l
13
-------
Summary of Remedy Update Information for FYOO and KYOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Kcginn 3 - KY 01
Region 3
Arrowhead Associates/
Scovill Corporation, VA
9/29/91 (ROD)
9/9X (USD)
9/2X/OI (ROD-A)
10/00
9/28/01
I'RP
Ground water
Stale approved on
9/2K/OI
Fed - 150 hrs
Contr = 0 hrs
F.st'd Savings = J>2 OM
Type of Change: From - Ground water pump and treat system The LSD in 1998 changed the remedy to a Permeable Rcaetive
Subsurface Harrier (PR SB), To - The ROD Amendment provides lor eon tinning with the P RSI) and allows lor the installation of an
impermeable Surface Cap which is estimated to produce a more efficient and more cost- effective remedy than either the pump and treat
technology or the I'RSB operating alone
Factual Basis: Continuing evaluations of the I'KSU system hy the I'RPs indicated that an impermeable surface cap would improve
peilormancc of the PRSH unit
Region 3
Uciks Sand I'll, I'A
9/29/8X
2/2/94 (USD)
9/14/01 (ESI))
3/01
7/13/01
1 PA
Ground water
State l etter of Approval
on 7/13/01
Fed - 50 hrs.
Contr. - 0 hrs
Lst'd Savings - $0
Type of Change: From - Local restrictions to prevent any further drinking water wells in the contaminated areas of the aquifer; To -
Remove local restrictions from preventing any turther dunking watei wells in the contaminated area Operating ground water pump and
treat system has lowered the contamination of the ground walci to allow lifting the prohibition against new drinking water wells
Monitoring and public outreach to continue.
Factual Basis: The remedy was working well enough to icscind ihe institutional control
Appendix A.l
14
-------
Summary of Remedy Update Information for l- VOI) and KYOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original KOI) Date
of Change
(ESD/ROD-A)
Date Review
C ommcnccd
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 3
Centre County Kepone
Site (OU 1), HA
-4/2 1/95
3/8/01 (ROD-A)
•1/16/97
3/2/01
I'KP
Sub-surface
soil
Slate approved on
3/2/01
I'ed - 150 hrs
Contr - 0 hrs
Lst'd Savings = $2 4M
Type of Change: From - Excavation of sub-surface VOC, mirex and kepone contaminated soils and oil-site disposal; To - Soil Vapor
Extraction (SVE) of VOCs in soil. Excavation will still occur where mirex and kepone exceed clean-up criteria and where bedrock is
near the ground surface (less than b feet) Other components of the ROD remain the same
factual Basis: Soil vapor extraction technology will achieve cleanup goals and is less expensive than the excavation of VOC
contaminated sub-surface soils
Region 3
1: 1 Dul'unt Newport Site
(South La ml III! only), DE
8/26/93
8/16/95 (LSD)
5/18/01 (ESD)
1 i m
5/16/01
I'RI'
Soil, (iround
w alcr
State approved on
5' 1 6/0 1
Fed - 250 hrs
Contr - 0 hrs
Est'tl Savings - $9 3M
Type of Change: From - In-silu chemical precipitation with sodium .sulfide and sodium sulfate; upgrade containment system from a soil
cover to a low-permeability synthetic cap, install circumscribing ground water barrier wall and a ground water pump and treat system;
To - Installation of a Permeable Ke active Han ici System (l'l< US) to remove metals from ground watei, const met ion of a low-
permcabilily synthetic cap, and elimination of ground water pump ami treat system
Factual Basis: The PKUS is designed to remove the contamination from the ground water while it is still in the ground Treatment takes
place in the permeable /one, eliminating the need for a pump and treat system liotli LPA and the State ol Delaware concurred with the
change in treatment technology
Appendix A.I
15
-------
Summary of Remedy Update Information lor I'YOO and I VOI lor Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Cliange
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 5
Hunterstown Road Site,
PA
8/2/93
8/:5/98 (I1SD)
3/22/01 (HSD)
8/2 3/00
3/8/01
' l< I*
I agoon
SedllllClllb and
drum removal
State I oiler of Approval
on 3/8/01
Fed 75 hrs
I'ontr. = 0 hrs
Fst'd Savings - $75K
Type of Change: From - Oil-silt: stabilization treatment ol lagoon sediments, stressed vegetation and corridor areas and disposal; To -
On-site stabilization treatment of lagoon sediments, stressed vegetation and corridor areas Figlity drums were discovered during on-site
(ic.iImeill Drums were removed and contents treated and destioycd Original cost savings from on-site treatment were estimated to he
$100,000 Costs of drum removal and disposal lowcied estimated cost savings
Factual Basis: The PR I* wanted a cheaper remedy
Region 3
Jack's Creek Superfund
Site, PA
9/30/97
4/19/01 (LSD)
4/00
3/29/01
PR P
Soil, Debris
State approval on
3/29/01
l-ed - 75 hrs.
Contr. - 0 hrs
Fst'd Savings - S2.2M
Type of Change: From - F.xcavalion ol on-site I hi oat (metal contaminated) materials, transport off-site, off-site stabilization and off-site
disposal, To - Fxcavation ol on site lineal (metal-containmated) uiateiials. oil site stabilization and placement ul stabilized materials
beneath the on-site multi-layer cap Doth the PRP liroup (for reasons ol decreased costs) and community members (for reasons of least
disturbance) prefer on-site treatment Oil site treatment would require the need to truck some 750 loads of contaminated soil through
the community to the disposal site
Factual Basis: On-site stabilization and placement of stabilized materials beneath the cap satisfies the needs of both the PRP and the
community. With certain conditions, the Stale concurred with the remedy
Appendix A.I
16
-------
Summary of Remedy Update Information for l-'YOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Ked/Contr.
Est'd Cost Increase
kegion
Metal Banks Site, PA
12/21 m
9/27/00 (OSD)
12/15/00 (USD)
J/00
1 l/oo
I'K 1'
Soil. Cirouml
water
State approved in 1 1/00
l ed 75 hrs
Conlr. - None
F.st'd Savings - $0*
Type of Change: From - Soil hot spots of PCH contamination exceeding 25 ppm will be excavated and confirmation sampling done at
the conclusion of the excavation; Oil Collection and Monitoring System installed along site perimeter to collect oil floating on shallow
ground water and off-site disposal; install sheet pile wall around southern and western perimeter of property to prevent erosion of fill
material into DE River; To - Sampling I'CH hot spots cither prior to or after excavation of soils to allow for a more focused remedy; and
installment of Oil Monitoring and Collection System only in area SA 4/5 (which leaves out SA 1, 2, and 3). Installment of Oil
Monitoring System only in the other ,ii c.ts Collecting of ml floating mi shallow ground water for oil site disposal Sheet Wall reduced
in size to cover surface water area only and addition.il ciosioji conliol incaMiiCN were required such as icvcgcl.ition, geotcxtile covers
and supplemental rip rap along llic 1)1- river where signs of hank ciosion aic delected.
factual Basis;: The new, more focused remedy should result in a cheaper cleanup with the same results
•Note: The remedy changes will clearly result in cost savings Due to the on-going litigation between the site owners and the I'KI's
iclated to remedy issues, obtaining icalislic estimates ol Inline costs liom any ol the paitics would he impractical now When the court
resolves the issues, obtaining cost estimates should be feasible
Appendix A.I
17
-------
Summary of Remedy Update Information tor I' YOO and FYOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M cdia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 3
Patuxenl River Naval Air
Station, MI)
1 2/22/98
6/25/01 (ROD-A)
2/2/99
4/00
Navy
Soil
U S lil'A Region 3
approval: 6/25/0 1
1 ed 150 hrs
I'ontr. = 0 hrs
list'd Savings - S2.2M
Type of Change: From - lixcavalion of contaminated soil, off-sile incineiation and disposal in oll'-sile RC'RA approved Landfill; To •
L'xc aval ion of smaller portion of soil liot spots, addition o 1 soil cover and app Ileal ion of clean fill, and off-site disposal o f soils. No off-
sile incineration will be employed
Factual Basis: The Navy believes that more foeused, less expensive remedy will achieve the cleanup goals. The Maryland Department
of the Lnvironnienl concurred that the ROD Amendment is protective of human health and the environment.
Region 4 - IV 00
Region 4
Camp L.cJcunc Military
Res (US Navy), NC
5/15/9 7
6/20/00 (ROD-A)
3/1/98
6/20/00
Navy
Subsurface
soils
Slate concurred on
amendment Public
notice of Proposed Plan,
during public comment
period from 9/1/98 to
10/1/98.
l ed - Unknown
I'ontr -¦ Unknown
list'd Savings = S200K
Type of Change: Krom - On-site biological treatment of soil contain mated with PA 11 compounds. To On-site landfill
tactual Basis: Results of a treatability study found that hiologic.il treatment would not treat all ol'tlie I'All compounds
Appendix A.I
18
-------
Summary of Remedy Update Information for KYOO and KY01 lor Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region -4
Davis Park Road TCL, NC
9/29/98
9/27/00 (LSD)
9/1 5/00
9/27/00
l.l'A
Ground water
The State concurred
with the LSI) The LSD
was publicized by a
notice in the local
newspaper.
Fed - Unknown
( ontr - None
Lst'd Savings ; $0
Type of Change: From - Providing waler service to 70 families and conducting long term monitoring of nalural allemiation with
traditional ground water pump and treatment as a eomingent remedy; To - Providing waler service to 70 families and eondueting long
term ground water monitoring of nalural attenuation with no contingent remedy
Factual Basis: Ground water monitoring results showed that natural attenuation was occurring ill the ground waler at the site.
Region 4
General Llectric Co./
Shepherd Farm, NC
9/2')/') 5
7/27/00 (ESD)
1 211 /99
7/27/00
l.l'A
(iround water
The State concurred
with the LSI) The LSD
was publicized by a
notice in the local paper
Fed Unknown
( ontr - None
Lst'd Savings - Small
cost reduction
Type of Change: From - Ground walei pump and treatment with id - si tu biological remediation To - Ground water pump and treatment
with no biological treatment
factual Basis: The results of a treatability study, conducted during llic Remedial Design, determined that in situ biological treatment
would not be effective in remediating the site
Appendix A.I
19
-------
Summary of Remedy Update Information for KYOO and KYOI for Sites Without Cost Increases
Region
Site Name, Slate
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Ked/Contr.
Est'd Cost Increase
Region 4
JFl) Lleclronics/ChanncI
Master, NC
9/10/92
7/19/00 (ESI))
6/1 0/00
7/19/00
1,1'A. I'RI'
Soil, Sludge
flic Slate concurred on
the LSD The ESD was
publicized by a notice in
the local newspaper and
there was a public
meeting on 6/1 2/00
Fed ; Unknown
C'ontr = None
Est'd Savings - $ 1 50K
Type of Change: From - The remedy called tor excavation and mix of on-site and olf-site disposal options based on waste type; inetal
contaminated wastes were to be solidified and disposed on-site; and other wastes were to be transported off-site for disposal; To - All
wastes will be excavated and transported off-silc for disposal
Factual Basis: Oil sampling for hexavalent chionimni, conducted after the ROD was issued, determined that the area and extent of soil
contamination at the site was significantly less llian previously dclcrmincd during the Kcincili.il Investigation The community
supported off site disposal of all wastes
Region A
New Hanover County
Airport Hurn Pit, NC
9/29/92
4/1 1/00 (ROI)-A)
1 0/1 /99
4/1 1/00
I'R 1'
(iround water
l lic State concurred on
the amended ROD The
Proposed Plan public
comment period was
1 1/16/99 to 1/1 5/00
led Unknown
Contr - None
Est'd Savings -¦ $2K
Type of Change: From - Traditional giound water pump and treatment; To - Air sparging as an innovative treatment technology.
Factual liasis: The results of a treatability study conducted during llic Remedial Design supported the remedy update
Appendix A.I
20
-------
Summary of Remedy Update Information fur KYOO and KYI) I Tor Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 4
North Belmont PCL, NC
9/24/97
8/24/00 (ESD)
1/5/00
8/24/00
I; PA
(irouiul water
I he State concurred on
the hSI) The LSI) was
publicized by a notice in
Ihe local newspaper and
a fact sheet was sent out
to ihe site mailing list
Fed - Unknown
C'ontr. = None
F.sl'd Savings: $ 100K
l ypc of Change: From - In well vapor stripping technology ami in-silu biological remedialum. To - Deleting the in-situ biological
remediation and using only the in well vapor stripping technology
Factual Basis: Results of a treatability study conducted during the Remedial Design lead to the remedy update.
Region 4
Para - Client Southern,
Inc., SC
9/27/93
1 2/23/99 (ROU-A)
10/1/99
12/23/99
PR 1'
Soil
The Stale concurred on
the amended ROW The
Proposed Plan public
comment period was
8/26/99 to 9/25/99.
Fed - Unknown
ConU - None
list'd Savings = $8 1 K
Type of Change: From - Soil excavation and ofl-Mtc disposal ol all contaminated soils on site; To - Changed remedy to require soil
vapor extraction in one area of site in lieu of soil excavation and off-site disposal
Factual Basis: The Remedial Action was 75 percent complete when the I'KP identified an area of the site that could be successfully
remediated using soil vapor extraction at a significant cost reduction
Appendix A.I
21
-------
Summary of Remedy Update Information tor t' YOO and KYOI for Sites Without Cost Increases
Region
Site Name, Stale
Date of
Orioinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 4
Potters Septic Tank
Service Pits, NC
8/5/92
9/27/00 (ROD-A)
6/1 '00
9/27/00
1 PA
Ground water
The State concurred on
the amended ROD The
Proposed Plan public
comment period was
8/10/00 to 9/9/00
list'd Savings - $0
Contr - None
Ust'd Savings - S6K
Type of Change: From - Ground water contamination source removal and ground water pump and treatment; To - Source removal and
ground water natural attenuation with institutional controls.
Factual Basis: During the source removal phase of the Remedial Action, it was observed that there was a significant improvement in
ground water quality at the site
Region 4
Red wing Carriers, Inc.,
(Saraland), AL
12/15/92
6/14/00 (ROD-A)
1/15/99
6/14/00
ni'A
Soil, Ground
water
Received Slate
concinrencc. Public
notice of Proposed Plan,
public comment period
4/19/99 to 6/25/99
Fed - Unknown
Contr - None
Est'd Savings: $0
Type of Change: From - Source removal with oIImic disposal and ground water pump and treatment; To - More extensive source
removal with off-site disposal Ground water pump and treatment is now a contingent remedy
Factual Basis: Changes were deemed necessary based on new site information discovered during an IT'A I99(i/|997 Removal Action
The area and extent ol source material al the site was lound lo lie greater than picviously determined
Appendix A.I
22
-------
Summary of Remedy Update Information for KYOO and I'YOl for Sites Without Cost Increases
Region
Site Naine, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
C omnienced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Ked/Contr.
F.st'd Cost Increase
Region 4
Sapp Ballery Salvage, FJ.
9/26/86
6/29/00 (ESl>)
6/1/00
6/29/00
I'R P
Soil. Debris
State concurred on F.SI),
Fact Sheet sent out to
mailing list
Fed 20hrs
Contr - 5hrs.
Lst'd Savings - SO
Type of Change: From - On-site stabilization anil solidification ol soil containing battery casings and on-site disposal; To - On-site
separation of soil and battery easing; then stabilization, solidification and on-site disposal of contaminated soil, and on-site treatment and
offsite disposal of battery casings
Factual Basis: During a Removal Action, it was determined that stabilization and solidification of the soil and battery casings together
was not technically feasible
Region 4 - KY 01
Keg Kin -4
Cape Fear Wood
Piescrving, NO
6M0/H9
3/23/01 (ROD-A)
10/1/00
3/23/01
11'A
(iround water
Slate concurred on
Proposed Plan, public
comment period, public
meeting 1 1 /14/00
Fed - 120 hrs
Contr - 6 hrs
f:st'd Savings - SO
Type uf Change: From - On-site ground water pump and tieal milil cleanup goals aie met; To - On-site pump and treat with natural
attenuation to meet cleanup goals
Factual Basis: Information about the area and cMcnt of'soil contamination was discovered during the soil Removal Action.
Appendix A.I
23
-------
Summary of Remedy Update Information for l< Y00 and FY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 4
Cecil Field Naval Air
Station, FL
6/2-4/96
1/25/01 (KOD-A)
6/1 /99
1/25/01
Navy
(¦round water.
Soil
State concurred on
Proposed Plan, public
comment period
Fed - 40 hrs
C'ontr - 0 hrs
list'd Savings - $1 4M
Type ol Change: Fiom ln-situ ground water ticatincnl and on-site hiotrealmenl of contaminated soils; To - Monitored natural
attenuation of ground water and off-site disposal of contain mated soils
Factual Basis: After the contaminated soils were excavated and placed in the biolreatnient area, ground water monitoring indicated that
natural attenuation was occurring. During hiotrcatment O&M, it was determined that treatment costs were going to be significantly
higher than planned Oll-silc disposal was found to he nunc cost cU'ective
Region 5 - FY (Ml
Region 5
Conrail Kail Yard (OU2),
(Llkhart) IN
6/28/91 interim
9/9/94 final
9/27/2000 (KOD-A)
2/00
9/00
I'KI's
(iround water.
Soil
Stale concurred with
amended remedy
Public comments were
addressed in
Responsiveness
Summary
Fed - None
C ontr = None
Lst'd Savings = $6 IM
Type of Change: From - F.xtract and treat ground water to MO.s, monitoring, and institutional controls, and in-situ treatment of soil;
To - Technical impracticability waiver for Dense Non-Ai|iicous Phase Liquids (DN A PI.) on rail yaril properly, hydraulic con la mm en 1 of
DN AIM. source areas, natural gradient flushing of dissolved portion of ground water plume, drag strip source remediation, monitoring of
ground water and contingent remedy.
Factual Basis: New information was collected dining Remedial Design
Appendix A.I
2
-------
Summary of Remedy Update Information for FYOO and KYUI for Sites Without Cost Increases
Region
Site Name, Stale
Date of
Original ROD Date
of Change
(KSD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Kst'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 5
Fcmald OU4 (Silos Project
1 & 2), Oil
1 2/7/^4
7/31/01) (ROD-A)
3/97
7/00
i:i'a, noi:
(iroiuul water.
Soil. Sludge
State concurred with
amended remedy Slate
submitted extensive
comments during formal
public comment period
Fed - 120 hrs
Contr 40 hrs.
Lst'd Savings - S2.5M
Type of Change: From - Soil removal, decanting of sludge, vitrification, and off-site disposal; excavation of soils and replacement with
clean backfill; and pump and treatment of ground water; To - Removal of the contents of silos 1 and 2 and treatment using chemical
stabilization; disposal of soil and debris ol'fsitc
Factual Basis: A problem Willi the inili.il sign and performance of v iti ilicalion icmcdy icsultcd in the remedy update.
Region 5
Industrial Fxcess Landfill,
Oil
7/17/84
3/1/00 (KOI)-A)
1990
3/00
[•.I'A
(iround water,
Soil, 1 anil fill
gas and w,isles
Slate provided
comments during public
comment penod Slate
wanted long term
monitoring program thai
includes limited
radiation testing
Fed - None
Contr - $ 1 0-20K
Fst'd Savings - $ 1 2.3M
Type of change: Froin - Install multi-layer RC'KA Subtitle C cap over landfill, expansion of existing methane venting system; extract
and treat ground water by air stripping, carbon adsorption, and flocculalion/scdiincnialion/liltration Remedy includes monitoring and
institutional controls . ; To -Institutional controls, redesigned landfill cover, monitored natural attenuation for ground water, and
expansion of existing methane venting system
Fiirtuai Basis: Post-ROl) sampling icmiIis showed that 1 I'A could eliminate the pump and treat system because there was no evidence
thai the plume of contamination exists outside ol silc boundaries
Appendix A.I
25
-------
Summary of Remedy Update Information for KYOO and KY01 for Sites Without Cost Increases
Region
Site Name, Stale
Date of
Orieinai ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
F.st'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 5
Johns-Manville Corp ,
OU 1, 1L
6/30/8 7
2/9/93 (F.SO)
9/22/00 (LSD)
2000
9/00
PR P
Air, (iround
water, Soil,
Surface water
State did not concur
with liSI). Stale wants
current land till
regulations to apply to
closure of ponds.
Fed - None
Contr - None
list'd Savings - None
Type of Change: From - Cover soil, monitor ground water, surface water, and air; pave two parking lot areas, resurface roadways; and
apply rip rap along treatment ponds, To - Closuie o 1 leinaining treatment ponds ami on-site landfill areas
Kactual Basis: Closure of manufacturing facility in 1998 and pond closure is more cost-effective and has more long term effectiveness
lliun continually pumping storm water run-off into the former waste water treatment system
Region 5
Lemon l.anc l andfill
OU 1, IN
8/1 3/84
5/12/00 (ROO-A)
9/95
5/00
ll'A
Soil, Solid
waste
Slate concurred with
amended remedy. City
and county support the
remedy.
l ed - None
Contr = SftOOK*
Cst'd Savings: N/A
part of Weslinghouse/
liloominglon
Type of Change: From - Incinerate l'CU contaminated materials, cap site with synthetic liner, and solid waste removal; To - Hot spot
removal and off-site disposal and capping with RCRA Subtitle I cap, and consolidate landfill
factual Basis: Federal court decision slating that landfill must he icmcdialed liy 1 2/3 1/0(1. Also, the original remedy could not be
implemented as selected and recent data fioui ncaihy iCMilciih.il wells necessitated a icinedy change
•Note; The initial incineration was never implemented due to public opposition and the state passing laws picventing the review of the
permits Therefore, the site needed complete investigation with multiple sampling events
Appendix A.I
26
-------
Summary of Remedy Update Information tor KYOO and KYOI tor Sites Without Cost Inereases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
F.st'd Cost Increase
Region 5
New l.ymc Landfill, Oil
9/27/85
1 1 /16/99 (ROD-A)
9/98
1 1 /99
1 I'A, Stale
(ii ound wa tcr.
Soil, I.cachale
Slate concuired with
amendment
Fed - N one
t'ontr - None
Lsfd Savings - S9 4M
Type of Change: From - On-site treatment ol ground water using biologieal dise, sodium hydroxide preeipilation and granular activated
carbon, and on-site consolidation of sediment Remedy includes ground water monitoring; To - Close down ground water treatment
facility and amend long term ground water monitoring program including a contingency plan
Factual Basis: The favorable results ol a focused feasibility study preceded the remedy update
Region 5
Nl. industries Taraeorp
l ead Smeller, Oil 1,11.
3/30/90
1995 (LSI))
9/19/00 (LSD)
8/00
9/00
federal
ciiloiccmeiil
Soils, Debus,
(ii ouiul wa lei
Some Slate input
Fed - Unknown
( iinlr Unknown
Lst'd Savings - $2 5
Type of Change: From - Lxcavate more than 9-4,000 cubic yards of Icad-coiUanimalcd soil ami debris, consolidate ami cover with a
RCR A multi-media cap, remove all on-site drums to an off-site facility lor recovety and install ground water collection/containment
system; To - Monitored Natural Attenuation
Factual Basis: Favorable ground water monitoring data preceded the remedy update
Region 5
Onalaska Municipal
Landfill,OIJ 1, II.
8/90
9/29/00 (LSD)
9/1 3/00
9/29/00
I.I' A, State
(¦round water
Stale involved with LSD
and agreed with
modification
Fed = 80 hrs
Contr. - None
Lst'd Savings ~ S600K
Type of Change: From - Install landfill cap, extract and treat ground water, and inslall air injection system to enhance btoremedialion;
To New Stale standards lor scveial site iclalcd chemicals
Factual Change: Information obtained during long Iciui Remedial Action 1 'lie new Wisconsin ground water I'icvcntivc Action 1.units
(I'A I s) allow the use of sland.nd lalmialoiy dcicclion limits
Appendix A.I
27
-------
Summary of Remedy Update Information tor l-'YOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Orieinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Ked/Contr.
Est'd Cost Increase
Region 5
Sangamo Electric
Dump/Crab Orchard,
OU 1, II.
8/1.'90
6/23/00 (LSD)
1 I/23/9X
(>/()()
federal
facility
(/round water,
soil
Slate concurred,
community reviewed the
ISD
Fed - 1 30 lirs
Contr. - None
Fst'd Savings $2 5M
Type of Change: From - iixcavate ami treat soil and sediment using incineration or In-Situ Vitrification (ISV), slabili/alion/fixalion of
residues and metal contaminated soil and sediment, on site disposal of treated material; monitoring of ground water, surface water, and
Icachalc; and institutional controls, To - Multi-phase extraction with limited pliytorcmcdiation and monitored natural attenuation to
address ground water.
Factual Basis: Higher concentrations of T( '1: were discovei ed in ground water during post-R( )l> A Iso, there was an increased volume
of I'l'H-contaminated material to be thermally treated Iron) the upper sand and clay layers of the subsurface soil, which will mitigate
further degradation of ground water
Region 5 - KY 01
Region 5
Ducll and Ciardncr I.and fill
Site. Ml
9/7/93
X/10/01 (ROD-A)
i im
8/10/01
Stale
Soil, (iround
water
State announced the
proposed plan, public
meeting
Fed = None
Contr - None
Hst'd Savings - S3.4M
Type of Change: From - Low-temperature treatment of contaminated soil, carbon adsorption treatment of ground water and capping of
the landfill; To - Revised soil and ground water cleanup standards; reduced volume of soil to be remediated by excavation and disposal;
eliminated l.TTD from the remedy; required long-term monitoring; use restrictions or institutional controls lor ground water; and
construction of landfill cap
(''actual Basis: Data from predesigned investigation dclcinuncd that extent oi'contamination in the soil and ground water is less and
si/e'in.iss of ground water plumes appear to ha\c stabilized oi dccicascd since the remedial investigation Additionally, the Stale revised
its cleanup levels, which resulted in a icduction in the volume of soil requiring i cmcdiation at the site
Appendix A.l
28
-------
Summary of Remedy Update Information for KYOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Oricinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Ked/Conlr.
Est'd Cost Increase
Region 5
fields Urook
Sediment Operable Unil,
OH
9/30/86
8/15/97 (USD #1)
9/30/97
4/8/99 (CSD #2)
8/17/01 (HSU Hi)
1 0/00
8/01
I'RI's (LSI)
Hi)
Sediments
(LSU Hi also
at lectcd I he
Hoodplain/W et
land Operable
Unit)
Slate was nculral on
LSU Hi (State was
consulted, but did not
actively participate in
the LSD review
process).
Led - None*
Contr - None*
Lst'd Savings = SO*
T>pe of Change: From - Lxcavatc and solidify sediments and place in an on-site landfill, To - LSD #3 - modified sediment and
floodplain/wclland KO Us to allow on-site thermal treatment of DN A PL-impacted soil anil sediment. Musically, the HSU allowed for a
change of treatment location without a change in the type of treatment.
Kuctual Bash: LSI) Hi - Discovery of a layer of DNAI'I under the sediment and lloodplain resulted in a larger volume of material that
required thermal treatment
•Note: F.SD Hi allowed a change in the location of the thermal treatment of highly contaminated sediments The LSD was initiated
when an area of DNAI'I. saturated sediment and soils was identified. The early 1986 ROD allowed on-site thermal treatment However,
as part of LSD H 1, thermal treatment ot scJiiiiciiIn was iiio\ cd off-Mte since the volume of material requiring treatment were expected
not to make on-site treatment cost-elfeclivc The cost change is assumed to he neutral because the LSI) returns to the original on-site
thermal treatment determination
Appendix A.I
29
-------
Summary of Remedy Update Information for I'YOO and FY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Orieinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
initiator
Media
State/Conim unity
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Kegion 5
Fields Brook
Flood Plains/Wetlands
Operable Unit, OH
9/30/8&
8/15/97 (LSD #1)
9/30/97
4/8/99 (CSn #2)
8/17/01 (ESI) ft3)
10/00
8/01
I'KI's
Soil
Slate was neulral on
LSI) W3 (Stale was
consulted, but did not
actively participate in
the LSD review
process)
Fed Unknown'
C'ontr. - Unknown*
Est'd Savings -
Unknown*
Type of Change: From - Lxcavate soils, backfill wiih clean soil, on-sile eoniainineni with a cover, and disposal cither on-sile or off-site;
To - LSI) tti - modified sediment and lloodplam/wetl;ind KODs to allow on-site thermal treatment of DNAPl.-impacted soil and
sediment For soils, the LSI) extended llie technical dclcnnin.itions Irom Ihc sediment operable unit that reclined thennal treatment of
highly contaminated material
Factual Basis: LSI) tt 3 - Discovery ola layer of DNAPl. under the sediment and floodplain resulted in a need to thermally treat highly-
contaminatcd soils The LSI) extended the approach used in the adjacent impacted sediments
•Note: LSI) tti allowed a change in the location of the thermal treatment of highly contaminated sediments Since highly-contaminated
soils had not previously been identified in the floodpl.iiii/welland area, lliis LSI) required additional work (and thus additional costs)
within this Oil. l lie LSI) extended the lccliiuc.il dclci mutations hum llie -.cdiiiicnl opciahle unit to addicss soil* that had been impacted
by DNAPl. and had moved from under llie brook channel to the lloodplain
Appendix A.I
30
-------
Summary of Uemedy Update Information for KYOO and KYOt for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 5
(ialesburg/Koppers Co., 11.
6/30/89
8/29/01 (1£SD)
7M0/00
8/1/01
1' K1'
(iioiind w ater
Dual signature, no
public meeting
Fed - Unknown
Contr. - Unknown
Fsl'd Savings =
Unknown*
Type of Change: From - Shallow interception trenches aiid deeper pumping wells lo contain and extract contaminated ground water; To
- (i round water pumped from lower pari of aquifer and treated I n the well head and then recirculated into the top of the aquifer instead of
being extracted, treated and then discharged.
Factual Basis: The HKHs performed pump tests and found loo much water would be generated to dispose of effectively 1'ilot tests of
the in-situ treatment technology worked effectively lo reduce concentrations below target levels
•Note: The estimated cost savings are likely significant hecause the PRP is no longer responsible for paying for the disposal of treated
water
Region 5
Metamora Landfill, OIJ2,
Ml
9/28/90
9/27/01 (ROD-A)
3/00
6/1 1/01
I'KI'
(iround water
State concurred/ no
letter »eill
Fed - None
Contr - None
Est'd Savings - S3.6M
Type of Change: From - Cap landfill and ground water pump and licat; To • Monitored natural attenuation.
Factual Basis: The results of ground water studies demonstrated stability of the V()( s in the ground water plume.
Appendix A.I
31
-------
Summar y of Remedy l'|>(l;itc liiform.-ition for I' YIM) and I VDI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(F.SD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M cdia
State/Comni unity
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 3
Motor Wheel Inc.. M 1
9/10/91
7/12/01 (FSD)
1/0 1
f./ol
i: p a
(¦round water
ROD- State concurred
ESD- State did not
concur
Fed ~ None
C'ontr - None
F.st'il Savings ~ $0
Type of Change: Fxpaniletl the original extent of contamination from the perched anil glacial aquifer to include the underlying Saginaw
aquifer and expanded the scope of the remedial action to include the remediation ol the Saginaw aquifer
factual Basis: Concerns about the migration of the contamination through unconfined intersections of the glacial aquifer and Saginaw
aquifer resulted in the remedy update At lime of oi iginal KOI), a full contamination study of the Saginaw aquifer was not complete.
Region 5
Peerless Plating Co.. Ml
9/21/92
4/5/01 (l:.SD)
1 1/99
4/5/tll
1: P A
Soil
The State concurred on
the I'Sl). Public notice
on 3/15/01.
Fed _ Unknown.
Contr. ~ None
Est'd Savings - % 1 0M
Type of Change: from - Saturated contaminated soil will he excavated to approximately .1 to 4 feet helow the water table, but no
further; To - Contaminated soils will be excavated only to the water table Institutional controls are part of the remedial action for the
site
Factual Basis: Changes were deemed necessary based on a new site information discovered during the construction of the ground water
treatment building. Previously unidentified soil contamination was discovered and found to be widespread in the subsurface over a large
portion of the site.
Appendix A.l
32
-------
Summary of Remedy Update Information for KYOO and h'YtM for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edla
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 5
Kasmusscn's Dump. Ml
.V2K/9I
7/20/01 (l(OI)-A)
6/99
WOO
PRI's
(¦round water
State announced the
proposed plan, public
meeting
Fed = None
Contr. = None
Cst'd Savings - $200K

Type of Change: from - Remedy changed from on-site pump ami treat (with soil (lushing); To - In-situ ozone oxidation of the
remaining contaminated ground water /ones. Hasicallv the remedy revised ground water cleanup standards, but discontinued SVOC
monitoring and soil Hushing No other ROD requirements were modified

Factual Basis: Data from monitoring events indicated a /one of contamination that may have by passed the ROD extraction capture
system Changing the ROD remedy from pump and treat to in-situ o/onc oxidation to treat all remaining zones of ground water with
contamination above clean-up standards will allow the clean-up to proceed more rapidly at reduced expense.
Appendix A.I
33
-------
Summary of Remedy Update Information Tor FYOO and TYO! for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M cdia
State/Community
Involvement
F.st'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 5
Republic Steel Corp.
Ouarry, OH
9/30/XX
9/2X/OI
5/30/01
<)/2X'0'
1.1'A
Cironnd water,
soil, quarry
surface water,
sediment
State concurrence letter.
City of Flyria ( R P)
involvement in
concurrence
Fed ~ N one
Contr - None
Fst'd Savings - SO

Type of Change: From - Fxcavate and remove sediment and soils from drainage ditch and hot spots around edge of quarry, ground
water monitoring, and 1 i 1 W. the remedy was updated lo allow for something other than conveyance to the I'O'I'W.
Appendix A.l
34
-------
Summary of Remedy Update Information for FY00 and FY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROI) Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 5
TriCounty LL ("<>./ Llgin
Landfills Supcrfund Site;
oin, II
9/10/92
6/25/96 ((iW LSD);
4/23/98 (CAP LSI));
7/14/99 (CAP LSD)
7/3/01 (CAP LSD)
4/15/01
7/V'OI
l*l< 1'
Soil
State concurred
verbally: remedy still
complied with State
ARARs
Fed ~ Approximately
S2K
Contr. - Minimal review
Est'd Savings ~ SI 0M
Type of Change: From • About 60 of landfill surface in low permeability. high strength asphalt coverage of landfill surface; About
40 % landfill surface coveiage with geosynthetic composite cap. To - 100 % coverage by gcosynthctic composite cap.
Factual Basis: Under the 7/14/1999 LSD. about 60 % of the Llgin Landfill was going to be covered with low permeability, high
strength asphalt cap. and approximately 4(1 of the Llgin l andfill was going to be covered in the geosynlhctic cap at a total cost of
approximately S3.456.63X (landfill cap costs only) Hy covering the entire landfill with gcosynthctic composite, the cost would be
reduced to approximately S2.446.S20.
Region 6 - FN' 00
Region 6
Odessa Chromium #1
(Ol 12), TX
3/18/88
1 0/25/99 (LSD)
4/99
10/25/99
Stale
(iround water
State has lead
responsibility for the site
and proposed change;
minimal community
interest in change
Fed - None
Contr. - $I0K
Lst'd Savings ~~ S500K
1 ype of Change: From - I'limp and treat system; To - Addition of in-sitit ferrous sulfate treatment
Factual Basis: New technology paved the way for the remedy update.
Appendix A.I
35
-------
Summary of Remedy Update Information for FY 00 and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Orieinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Ucgion (i
Odessa Chromium #2
North and South Plumes,
TX
VIX/9X
10/25/99 (PSD)
4 m
1 (1/25/99
State on South
Plume. PRP
on North
Plume
(iround water
State proposed change;
minimal community
interest in change
Fed ~ None
Contr - SI OK
Hst'd Savings =
North Plume: S350K
(SHQUA Cooperation.
PRP Lead)
South Plume: $ 100K
(TNRCC. State Lead)
Type of Change: I'rom - Pump and treat system; To • Addition of in-situ ferrous sulfate treatment.
Factual Basis: New technology paved the way for the remedy update
Appendix A.I
36
-------
Summary of Remedy Update Information for l;Y00 and FY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Com ntenccd
Date Review
Completed
Change
Initiator
M edla
State/Community
Involvement
Esfd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 6
Tex I in Corporation
Supcrfund Site, TX
5/1 im
9/28/00 (ROI)-A)
.1/7/00
4/5/00
PRP
< iround water.
Slag. Soil.
Wastes
High interest by
community and state
Comments submitted by
the community during
public comment period
and state review and
comments on site
documents. High city
interest to start the
cleanup process.
Fed - Unknown
Contr. - Unknown
Estimated Savings:
Approximately $1 5M

Type of Change: Prom - Stabilization treatment standard"; for leachatc to meet ground water Maximum Contaminant Levels (MCI.s);
To • Stabilization treatment standards for Icachate to meet RC'RA Toxicity Characteristic I.caching Procedure (TCI.P) levels since
shallow ground is not a potential drinking water source.

From - (iround water monitoring. To - Contiolling horizontal flow direction with installation of a w estern slurry wall barrier; managing
vertical gradients; reducing discharge to Ponds 24. 2s. and 26; identifying and treating soils that could leach contaminants to the shallow
ground water; and ground water monitoring

Factual Basis: PRP presented new information that was not available to IvI'A prior to the signing of the original ROD New information
resulted in the PRPs conducting a supplemental Feasibility Study
Appendix A.I
37
-------
Summary of Remedy Update Information for l-'YOO and TVOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Orieinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
Statc/Comm unity
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 6 - F'Y 01
Region 6
Monroe Auto Equipment
Co., (I'aragould Pit). AR
9/26/96
1 1/9/00 (ROI)-A)
9/98
1 1 /9/00
I'RP
Soil
State had lead role in
overseeing PRP's work,
and State drafted the
ROD amendment
Community was
supportive, as revised
remedy provided greater
reuse possibilities.
Fed ~ N/A
Contr. = N/A
F.st'd Savings = SO
Type of Change: From - On-site containment of contaminated soils and sludges; To • Treatment and ofT-site disposal of same
Factual Hasis: Revised remedy was equally piotective. piovided for reuse of the property, and was favored by the community.
Region 6
Popilc, Inc.. AR
2/1/91
9/28/01 (ROD-A)
1 9>)7/9S
9/28/01
1 PA
Soil. Ground
water
State supported change;
minimal public interest
in site.
Fed - N/A
C ontr. '"N/A
Est'd Savings = S2 1 0M
Type of Change: From - Excavation and onsite biological treatment of contaminated soils and sludges; in-situ bioremediation of deep
subsurface soils; To Containment through maintenance of on-site vault created during Removal Action and some additional capping,
plus institutional controls
From - Extraction anil treatment of contaminated ground water; To - Technical Impracticability waiver, monitoring, and institutional
controls
Factual Rasis: Hiotrealnienl pilots failed to aeliiev c cleanup goals, ami new data showed that the ground water plume was stable
Appendix A.l
38
-------
Summary of Remedy Update Information for KYOO and FYOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Com nteneed
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 7 - FY 00
Region 7
Hastings OW 13 (Well 3).
Nl
6/30/93
1 1/19/99 (ROI)-A)
6/1/99
1 1/19/99
I-PA
Ground water
State concurrence,
public comment period
and opportunity to meet
Fed ~ 1 20 hrs.
Contr ~ None
F.st'd Savings - JO
Type of ( linnnc: ( ontinuc l<> use llie existing ground water tieatment system Id reduce contaminant concentrations and reduce clean up
performance goal from (lie interim target of 31 mieiograms per liter (ug/I) to tin. SOW A Mt'L of 5 ug.'l. Time period and costs expected
to be within initial estimates
Factual Rasis: Better than expected performance of the ground water pump and treat system resulted in the remedy update
Region 7
People's Nnlnr.il Cias, IA
9/16/91
3/1/00 (r.SD)
3/29/94
3/1 1/00
PR P
('¦round water
State concurrence and
public notice
Fed ^ None
Contr = None
Est'd Savings - S553K
Type of Change: Implement continued ground water monitoring and delete ground water extraction and treatment.
Factual Rasis: Residual contamination is below ROD clean-up levels and pumping the alluvial aquifer may accelerate migration of
contaminants from the shallow silly sand aquifer and exacerbate the problem
Appendix A.I
-------
Summary of Remedy Update Information for KMX) and KYOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Chance
(F.SD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
F.st'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 7
Pester Mum Pond, KS
9/30/92
3/1/00 (PSD)
ft/1 1 /99
3/1/00
State
Sludge
State-lead concurrence
and community input
Fed - TIU)
Contr. ~ TUD
Fsl'd Savings - SO
Type of Chance: Revised risk assessment ami cleanup goal to relied reasonable land use and modern risk assessment methods
resulting in less restrictive land use
Factual Basis: l ite results of an updated risk assessment lead to the remedy update
Region 7 - FY 01
Region 7
( nrnliusker Anny
Ammunition Plant. OW 1.
ni;
9/29/94
9/20/01 (ROI)-A)
3/01
9/01
federal
facility
Ground water
State concurrence,
public meeting
Fed = 80 hrs.
Conlr. = None
Fsl'd Savings - $ 1 1 (IM
Type of Change: From • An oil-site pump and treat system; To - Monitored Natural Attenuation (MNA). On-site puinp and treat well
added. On and off-site institutional controls also added
Factual Basis: Long-term monitoring of ground water and rccvaluation of MNA resulted in the remedy update
Appendix A.l
40
-------
Summary of Remedy Update Information for FYOO and h'YOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region N - FY 00
Region 8
C'hcmiral Sales Site (OIJ1 )
CO
6/27/91
.1/27/00 (FSD)
9/30/9S
6/30/99
F.PA. State
(¦round water
No significant
comments from Stale
and Community.
Fed - 80 hrs
Contr. - S15K
F.st'd Savings = S200K
Type of Change: From • High volume extraction from (wo wells in plume area of site. Ilicn treatment via air stripping plus sourec
remediation To - Natural attenuation of plume plus source remediation
Factual Basis: New information from hydrogeologic investigations indicated that the two wells would be ineffective. The design
Hydraulic conductivity valve (K valve), derived from the Plume Area geology and aquifer lest analyses and conditionally agreed upon by
F.PA. was 1/3 for the valve reported in the Rl/FS and used in the ROD. The change in the K valve resulted in a proportional reduction in
predicted capture zone for each of the wells
Region 8
Defense Depot Ogden
1 It all (DDOU). IJT
6/26/92
9/1 3/00 (HSD)
7/1/00
9/1 3/00
DOI)
Soil
No significant
comments HSD signed
by the State
Fed - 100 hrs
Contr. - S200K
F.st'd Savings - SI.5M
Type of Change: From - Cleanup levels for soils to icsiilonli.il standards; To - Cleanup levels for soils to industrial standards, increase
in amounts of soil excavated, and additional costs
Factual Basis: New area of contain ination at the Plain City Canal Site initiated this FSD DDOIJ is now closed, and undergoing reuse
by private parties The reuse plan, approved by the City 7 DOD, docs not have any residential reuse planned
Appendix A.I
41
-------
Summary of Remedy Update Information for FYHO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(F.SD/ROD-A)
Date Review
Com mcnccd
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Key ion X
Defense Depot Ogdcn
Utah (DDOU). UT
X/3/92
X/9/00 (KOI)-A)
ft/9/00
X/9/00
l)OI)
Soil, ground
water
No significant
comments ROD
Amendment signed by
the State
Ted = 200 hrs
Contr = S.TOOK
F.st'd Savings - J.VOM

Type of Change: I'roni - Tlu* 1992 ROD provided for excavation and off-site disposal of all contaminated soils Shallow ground water
was to lie treated using ;tir stripping and granular activated carbon : To - Hxcavation of additional soil amounts to allow some
contaminated soil and debris underneath a warehouse on-site to be loft in place; and treatment of ground water using a new ozonation
process. The amended remedy also adds additional institutional controls for the affected area

Factual Basis: During implementation of the ROD remedy, a new "hot spot" was discovered (OIJ4 hot spot). The hot spot consists of a
localised source area and the associated ground water plume. Some of the source was located between two warehouses and some was
beneath the warehouse The buildings are to be sold to private parties The source, outside the buildings, has been excavated and
shipped off-site The buildings will provide a covci for the remaining waste l ite contaminated ground water is being extracted and
treated. Institutional controls will be placed in the deed
Appendix A.I
42
-------
Summary of Remedy Update Information for KYOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date or
Original KOI) Date
oT Change
(ESD/ROU-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 8 - I'Y 01
Region 8
Rocky Mountain Arsenal,
OIJ 3. CO
ISD for Chemical Sewer
6/1 1/96
1 1 /10/00 (USD)
8/00
1 0/00
A r m y
Soil
The State reviewed the
draft version of the LSD
and provided comments.
No comments from the
public were received
Fed = Approximately 60
hrs.
Contr. = 100 hrs (S7K)
F.sl'd Savings = S2.5M
Remediation (Section 35
and 26)
Type of Change: From Overburden from the excavation area to be removed and stockpiled; excavation of the remaining sewer line
and disposal in the on-site hazardous waste landfill; and excavation of human health cxcecdance soil surrounding removed sewer lines lo
a depth of 1 0 feet or 2 feet below the sewer line, whichever is deeper; To - No additional soil surrounding the former chemical sewer
will be excavated The remaining sewer line segments will be excavated under other site projects

Factual Basis: Most of the sewer line was removed as part of a separate response action in 1982. The ROD estimated that contaminated
soil (not based on sampling) associated with the former sewer pipe location would extend 10 feet on each side of the sewer line and 10
feet below ground surface or 2 feet below the sewer line, w hichever was deeper. Design review of the 1982 response action indicated
that a large portion of the associated soil had also been removed. Additional soil sampling was conducted in April 2000 to determine the
extent of any remaining cxcecdance soils. Analytical results were below human health cxcecdance criteria for soil.
Appendix A.I
43
-------
Nummary of Remedy Update Information for l-'YOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M cdla
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 9 - KY 0(1
Region 9
Apache Powder Supcrfund
Site. AZ
9/30/94
9/29/00 (ESI) #2 )
1997-98
7/00
IP A
Soil
State concurred
Fed = 400 hrs.
Contr. - S35K
Est'd Savings = $1 5M
Type of Change: From - 1 stablished cleanup standards for Contaminants of Concern (('()('*) (cither recently detected or without ROD
cleanup standards) identified in on-site soils, sediments or diuins (soils media components); To - Modified soils cleanup remedies and
"no further action" for selected soils media components, where hazardous substances were not detected or did not exceed EPA's selected
soils cleanup standards
Factual Basis: Investigative activities, including additional soil sampling and characterization, on site areas of waste disposal indicated
that wastes in several areas of the site were non-hazardous or did not exceed EPA's cleanup standards
Region 9
Del Norte Pesticide
Storage, C'A
9MO/85
8/29/00 (ROI)-A)
1 2/99
8/29/00
I PA
(¦round water
Accepted by State and
community
Fed = 200 hrs.
Contr = None
Est'd Savings = S540K
Type of Change: From - Pump and treat system; To Containment
Factual Basis: The plume has been stable for five ycats. no significant difference in concentration or area of plume whether actively
pumping and treating or led alone-
Appendix A.I
44
-------
Summary of Remedy Update Information for KYOO and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Oricinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 9
Lawrence Livcrmore
National Laboratory,
Main Site. OA
8/5/92
2/21/00 (LSD)
1 1 /1 /99
2/24/00
DOL
Ground water
Stale Dept. of Toxic
Substance Control and
the Ray Regional Water
Quality Control Board
were involved
Fed - 120 hrs.
Contr. = None
Est'd Savings = S263K
Type of Change: From In-Silu treatment using Palladium catalyst; I n - Closed loop above ground treatment with Palladium.
Factual llask: VOCs will be reduced more quickly wiili the remedy update.
Region 9
March AFB Sites 10 and
15 (OUl).CA
6/20/96
8/24/00 (LSD)
4/1 /00
8/24/00
Federal
Facility
Soil, ground
water
State Department of
Toxic Substance Control
and Regional Water
Quality Central Board
reviewed the document
and had no changes
Fed = 80 hrs.
Contr. - $2K
Est'd Savings = Similar
in cost
Type of Change: Froin - L.xcavation and low temperature thermal desorption for soils and extraction and treatment of ground water
using liquid phase granular activated carbon absorption; To • Lxcavatc and treat soils by bio-remediation
Factual Basis: Cost re-analysis performed during Remedial Design showed that biorcmediation of contaminated soil would provide
equal protection at lower cost than thermal desorption. which had been selected in the original ROD based on an estimated lower cost.
Appendix A.I
45
-------
Summary of Remedy Update Information for FYOO and h'YOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M cdia
St ate/Comm unity
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 9
Treasure Island Naval
Station, Hunters Point
Annex. Parcel B. ( A
10/7/97
5/5/00 (1 SI"))
WOO
5/5/00
Navy
Soil
Thirty-day public
comment period
Fed = Unknown
Contr = Unknown
Fst'd Savings =
Unknown
Type of Change: l;rom - Soil cleanup goals based on 1995 Preliminary Remediation Goals (PRCs): To - Soil cleanup goals revised
based on October 1999 I'RCis.
Factual Basis: The Navy revised soil cleanup goals to take into account revisions to the toxicity and other factors included in the
calculations of the Region 9 PRCis issued in October 1999.
Region 9 - FV 01
Region 9
J II Baxter & Co.. OU 1.
(A
9/25/90
3/27/98 (ROD-A)
9/1 .1/01 (HSD)
9/1/00
9/13/0 1
PR P
Soil
State involved froin
start, minimal
community involvement
Fed - 200 hrs.
Contr ~ N/A
Fst'd Savings = $0.3M
Type of Change: From - Additional treatment of contaminated soil; To - Containment on-site in RCRA cell, without additional
treatment
Factual Basis: Non-carcinogenic PA lis were found to have contaminated 800 cubic yards of soil. On-site treatment had not met ROD
standard, and soil would have had to be transported off-site for treatment. Since the 1998 ROD amendment enabled the use of a RCRA
cell or Corrective Action Management Unit (CAMU). the original ROD standard was not appropriate and was relaxed on site disposal of
the soil w ithout additional treatment
Appendix A.I
46
-------
Summary of Remedy Update Information for l-'VOO and FY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESI)/ROI)-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M cdia
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 10 - !•"V 00
Region 1 0
Bangor Ordnance
Disposal, W A
1 2/1 0/9 1
7/18/00 (F.SD)
4/9r>
7/18/00
Navy
Surface water
The State is lead
regulatory agency at this
site The change was
presented to the Bangor
Restoration Advisory
Board and a notice was
published in a local
newspaper
Fed = 10 Ins (F.PA)
Contr " None
Fst'd Savings = S250K
Typo of Chnngr: From - Treatment of Site A soil treatment basin leachatc prior to discharge. To - Discharge of Site A soil treatment
basin leachatc without treatment. The I'St) also documents the increased costs for the overall cleanup, as compared to the ROD
estimate
Factual Basis: The untreated leachatc concentrations had leveled off at concentrations slightly above the surface water cleanup level
established in the ROD A literature search and whole effluent toxicity testing demonstrated that discharge of the untreated leachatc
would be protective of aquatic life
Region 1 0
Harbor Island (Lead), WA
Shipyard Sediments OU
(Todd Shipyards portion)
1 1 /96
12/27/99 (FSD)
2/99
12/27/99
1 PA
Sediments
Fact sheet was sent to
250 individuals
Fed = 100 hrs.
Contr. = None
Fst'd Savings -
Unknown
Type nf Change: From • One shipyard sediment Oil; To Two separate shipyard sediments OUs. with an expanded area that requires
remediation for the Todd Shipyard Oil
Factual Untis: Additional information gathered during iemcdi.il design investigations disclosed that the OH boundary did not
encompass all of the potentially contaminated sediments requiring remediation.
Appcndit A.I
47
-------
Summary of Remedy Update Information for b'YOO and l' YOl for Sites Without Cost Increases
Region
Site Name, State
Date of
Oricinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edla
State/Comm unity
Involvement
Est'd Resource
Demands -
Fed/Contr.
Ejt'd Cost Increase
Region 10
Kerr • McCiec Chemical
Corp (Soda Springs
Plant). ID
9/28/95
7/I.V00 (ROD-A)
2/(10
7/1.1/00
PRP
Industrial solid
waste
The State concurred in
the remedy change. A
proposed plan was
mailed to the
community, and a public
meeting was held during
the 60-day comment
period.
Fed = 410 hrs.
C ontr. = None
Est'd Savings = $75 M*

Type of Change: From - Recycling calcine (ailing'; anil roaster reject materials through an on-site fertilizer plant; To - Cap remaining
calcine tailings and roaster reject materials ill place Remainder of remedy was unchanged

Factual Basis: Fertilizer plan was constructed and operated, hut was never able to meet the ROD's volume commitment due to technical
difficulties with the waste material

•Note The savings listed are only those from not continuing to operate the fertilizer plant using these wastes as raw materials, minus the
cost of capping FPA did not include fertilizer plant operating costs in the original costs in the original ROD remedy because Kerr-
McCiee was at the lime an operating facility However. Ken-McCice indicated that losses of *>5M/year were expected with continued
fertilizer plant operation Mased on the historical operation of an average 150 tons/day. the fertilizer plant w as expected to operate for 16
years resulting in a total operating loss of approximately SXOM The cost of the landfill cap was approximately S5M. resulting in a cost
savings of approximately S75M It is noted that the $75M saving could be considered saved operating costs, instead of as remedy cost
savings
Appendix A.I
48
-------
Summary or Remedy Update Information for FYOO and FYOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(F.SD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
•State/Community
Involvement
Kst'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 1 0
(IS DOII Man ford 100
A rca. W A
1 00-HR-3 Of
4/96
10/24/99 (KOI)-A)
6/9')
10/24/99
l)OI:. State
Ciround water
State concurred with
change Thirty-day
public comment period
on the proposcil plan,
with five comment
letters received.
Fed = 30 hrs. (F.PA)
Contr. ~ None
F.st'd Savings $ 8M *
Type of Change: From - Implement the previously selected pump and treat remedy for a newly characterized ground water plume; To -
Implement an innovative in-silti remedy (permeable reactive barrier) for the newly characterized plume.
Factual Basis: An additional plume of chromium contamination was discovered beyond the existing pump and treat systems. A 1 999
treatability study of the innovative in-situ treatment within the plume showed positive results
'Note Cost savings are reflected as the estimated difference in the net present value between an additional pump and treat system, and
the innovative in-situ technology over a twenty-year period. The selected remedial action is an additional estimated $4 6M over the
ROD estimates
Appendix A.I
49
-------
Summary of Remedy Update Information for h'YOO and I'YOl for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands •
Fcd/Contr.
Est'd Cost Increase
Region 10
US POF Han ford 300
Arcn, W A
300-FF-l OIJ
7/17/96
1/1 1/00 (USD)
6/99
l/l I'OO
IP A. POL.
and State
Soil. Debris
The state supported the
LSP. with comments
about additional work
needed beyond the
scope of this FSP. The
LSP was discussed with
the site-specific advisory
board. A fact sheet was
mailed out
Fed = 80 hrs (F.I'A)
Contr = None
Est'd Savings = S200K
Type of Change: From - Removal and on site disposal of contaminated soil and debris from many sites, willi treatment to meet hand
Disposal R estrictions (hi) R) if necessary; To - Removal and on-site disposal of contaminated soil and debris from ma ny sites, with
treatment to meet hand Disposal Restrictions (I.PRs) if necessary, and a RCR A site-specific treatability variance for one site
Factual Basis: During remediation, one site was unexpectedly round to be contaminated with lead as well as radioactive contamination.
Some samples were designated as a lead characteristic hazardous waste
Region 1 0
US DOh IN hi-L, 11)
Test Reactor Area
(OU 2 13)
12/97
6/23/00 (LSD)
3/00
6/23/00
DOI-. F P A.
and State
Soil, Ground
water
The State supported the
changes to the selected
remedy. Notice of the
F.SP was published in
seven Idaho newspapers.
Fed = Minimal
Contr. = None
F.st'd Savings - $0
Type of Change: From (icttcr.il institutional contiol requirements: To - More specific iiistitiition.il control requirements.
Factual Basis: Review of the ROD showed that it did not contain adequate details on the institutional controls and how they would be
implemented, maintained, and monitored Additional details on the institutional controls were added to the selected remedy to be
consistent with regional guidance issued subsequent to the original ROD
Appendix A.I
50
-------
Summary of Remedy Update Information for l-'YOO and l-'YOl for Sites Without Cost Increases
Region
Site Name, Slate
Date of
Orlcinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/C omm unity
Involvement
Est'd Resource
Demands -
Fed/Con tr.
Est'd Cost Increase
Region 10 - FY 01
Region 1 0
Uoniu'villc I'owcr
Administration Ross
Complex (IJS DOT:). OUI
& OU 2, WA
5/6/93 and 9/24/93
1 /1 S /() 1 (LSD)
h'l/00
1 /1 X/OI
1 1* A
Soil
T he State supported the
change. A notice of the
F.SI) was published in a
local newspaper
Fed = 8 hrs
Contr. = None
F.st'd Savings - None
Type of Change: From - Vague institutional control requirements; To - Site-specific and facility-wide institutional control requirements
Factual Basis: The CERCLA Five-Year Review recommended that BPA develop a strategy to belter provide for long term
administration, implementation and maintenance of institutional controls.
Appendix A.t
51
-------
Summary of Remedy Update Information for l-'VOO and FY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 1 0
Frontier Hard Chrome.
Inc.. OUI & OU2. WA
12/30/8 7 and 7/5/88
8/30/0 1 (ROD-A)
hi') 7
8/30/01
i:pa
Soil, (iround
water
State was actively
involved in identifying
alternative technologies
and concurred with the
selected remedy. A
proposed plan for the
amended remedy was
released and one
generally supportive
comment letter was
received
Fed = 100 hrs
Contr = S70K
Est'd Savings = Either
$2 2M or S 10.4M *
Type of Change: From • Soil excavation, stabilization and replacement, and extraction and treatment of ground water; To - In-situ
treatment of source area ground water and soils using the in-situ redox manipulation
Tactual Basis: I'ost KOI) studies revealed that the originally selected remedies would he ineffective Further studies identified newly
available and cost-eflcctive technologies.
•Note: Combined cost estimates, in original soil and ground water RODs, were estimated to be $5 8 million. Based on new site
information, the updated costs were estimated to be approximated SI 4 million Combined cost of the amended remedy is estimated to
be approximate (t million Thus, the estimated savings would be approximately $2.2 million if you compare the 1 987 and 1 988
RODs with the amended remedy, or would be S 1 0 4 million if you compared the updated cost estimate for the original remedy and the
amended icmcdy The ROD amendment uses the updated cost estimates for its comparison
Appendix A.I
52
-------
Summary of Remedy Update Information for KYOO and I'YOI for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Chance
Initiator
M edia
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 1 0
Harbor Island (Lcail). WA
Soil and Ground water
Opcrahlc Unit
9/30/9,1
9/26/0 1 )
X' 16/01
9/25/01
PR P
Soil
The State concurred
with the change. An
announcement of the
FSI) was made in the
Fact Sheet sent to
interested parties, as
well as published in a
local newspaper.
Fed - 80 hrs.
C'ontr. - $0
F.st'd Savings - S2.0M

Type of Change: From - A hoi spol action level for excavation of highly contaminated soil; To - A less stringent hot spot action level
for certain well characterized soils that extend under permanent structures

Kaftii.il Basis: Addilion.il hot spots have been discovered during the cleanup, and some of the hot spots extended beneath permanent
.structures that make the costs for cleanup substantially gieatcr Also, additional information was developed on the risk associated with
the weathered materials that demonstrate that this higher action level is protective This hot spot concentration change is also consistent
with recent State cleanup decisions
Appendix A.l
53
-------
Summary of Remedy Update Information for KYOO and I Y0I for Sites Without Cost Increases
Region
Site Name, Stale
Date of
Original KOI) Date
of Change
(ESU/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 1 0
INF.n. -Idaho National
Engineering Lah (US
DOT.). II)
Test Area North (Oil 1 -
07H)
8/4/95
9/19/01 (ROI)-A)
.1/30/00
9/19/01
noi:. i:pa.
State
(iround water
The State participated
and concurred in the
selection of the remedy
and concurred in the
remedy change A
proposed plan was
released and public
meetings were held. In
addition, presentations
were made to the
Citizens Advisory
Hoard.
Fed - 200 hrs.
Contr - S5K
list'd Savings - SI.0M

Type of Change: From • I'ump and treat in all /ones of the contaminated plume; To - In-situ hioremediation in the hot spot; pump and
treat in the medial zone of the plume (unchanged from the original remedy); and monitored natural attenuation in the distal /one of the
plume, institutional eonlrol requirements arc unchanged

Factual Basis: I'ost-ROI) treatability studies showed that the use of monitored natural attenuation and an innovative technology, in-situ
hioremediation. in combination with the originally selected pump and treat technology, could cleanup the contaminant plume in less
time and at a lower cost than the originally selected remedy
Appendix A.I
54
-------
Summary of Remedy Update Information for FYOU and KY01 for Sites Without Cost Increases
Region
Site Name, State
Date of
Orieinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 10
Teledyne Wall Chang. WA
9/27/95
9/28/01 (P.SD)
2/01
9/28/01
IIP A
Soil
State supported change.
Notice of F.SD published
in local newspaper
Fed - $I0K
Contr -*¦ None
l:st'd Savings ~
Unknown

Type of Change: From - l-xcavation and nlT-site disposal of all gamma emitting soil, institutional controls, and site closure
requirements; To - In-plnce management of contamination including some excavation and institutional controls during life of Ilic facility,
and modified site closure requirements to capitalize on facility's existing closure requirements under state permit and radiation program
administrative rules

Factual Basis: The extent of buried radioactive contaminated soil was significantly less than initially estimated in the RI/FS
characterization of the site.
Appendix A.I
55
-------
Summary Report FYOO and FY01
Appendix A.2:
Summary of Remedy Update Information for FYOO and FY01
for Sites With Cost increases
Note: The information and data presented in Appendix A.2 represent only a portion of the information available in
the decision document If more information is needed, please refer to the site's ESD, ROD-Amendment,
memo-to-file, or letter.
-------
Summary of Remedy Update Information for KYOO and FYOI for Sites With Cost Increases
Region
Site Name, State
Date of
Oricinal ROD Date
of Change
(F.SD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
F.st'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 1 - I V 00
Region 1
Stamina Mills Supcrfiind
Site, OUl, Rl
9/2X/90
6/2 7/nn (RSD)
I0/9X
8/00
r.PA
Sediments,
(iround water
State concurrence
received
Fed ~ I Inknown*
Contr ~ Unknown*
F.st'd Increase - S500K*
Type of ChnnEc: From • Fxcavation of sediments, placement on existing landfill and capping of existing landfill; To - Fxcavation of
sediments and landfill materials, and oil-site disposal at an approved facility; using UV/oxidation to treat contaminated ground water, as
well as using air stripping and activated carbon
Factual Basis: Concerns over the structural integrity of the landlill and operational problems with the UV/oxidation technology
necessitated modification of site cleanup decisions
*Notc: Unable to provide cost increases or cost savings on an OU or L;SD basis because the OUs were combined in the remedy action
and work was completed by a responsible party
Apprndii A.2
-------
Summary of Remedy Update Information for h'YUO and FY01 for Sites With Cost Increases
Region
Site Name, State
Dale of
Original KOI) Date
of Change
(ESD/KOD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
M cdin
State/Community
Involvement
Eit'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 1 - I'Y 01
Region 1
Brunswick Naval Air
Station. OU5. MI;
2/12/98
1 2/27/00 (USD)
N/A
1 2/00
Navy
(¦round water
State concurred; public
meeting held
Fed = S2 5K (EPA)
Fed - S5K* (Navy)
Contr. - S20K* (Navy)
F.st'd Increase = S1 M *
for capital costs to
implement ESD
Est'd Decrease - J200K
annually for plant ()& M
savings once ESI)
implemented
Type of Change: From - (iround water treatment technology from UV oxidation; To • Air dripper and system effluent discharge from
publicly owned treatment work* to infiltration gallery Also added Institutional Controls (It') that were not specified in the original
KOI) to prevent use ot ground water until cleanup goals are attained These arc enforced by a Navy Hase Operating Instruction which
documents ICs and specifies a process bv which they are considered in hase construction.
Factual Basis: Due to chemical properties of the preliminary contaminate of concern. 1.1,1 -TC'A. U V oxidation could only reduce
concentrations by 50% Air stripping achieves greater thati 99% concentration reduction, thus allowing treatment effluent to be
discharged to a ground water infiltration gallery Both the air stripper and infiltration gallery will have lower operating costs than the
original UV treatment with discharge to the public owned treatment works Institutional Controls were initially enforced in effect by the
Navy, but are now formally documented and enforced
*Note: Costs are estimates, but unable to provide precise cost increases and savings as the work was completed by the responsible party.
Appendix A.2
2
-------
Summary of Remedy Update Information for KYOO and KYOI for Sites With Cost Increases
Region
Site Name, State
Date of
Oricinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Co mmenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 1
Otis Air National Guard
liase/Camp Fdwards,
OIJ5. MA
9/30/98
10/11/00 (FSD)
woo
10/00
Federal
Facility
Soil
State concurred on
10/24/00; informal public
comment period - 8/28/00
to 9/26/00
Fed - 100 hrs.
Contr.- Included below
Fst'd Increase ~ $84K
Type of Change: From • No further action; lo - Include additional, similarly contaminated area into excavation planned lor adjacent
storm drainage area originally proposed in 1998 KOI)
Factual Basis: Drainage swale at the Chemical Spill 2 (CS-2) Study Area determined to contain elevated levels of soil contaminants
such that a No Further Action Decision Document lor CS-2 could not go forward F.PA directed AFC'l-1£ to prepare an USD to document
the inclusion of the CS-2 drainage swale into the 1 948 ROD. and then proceed with No Further Action for remainder of CS-2 Study
Area
Region .1 - FY 00
Region 3
Tybouts Corner 1.ami fill.
nr.
3/6/86
5/17/92 (FSD)
7/26/00 (FSD)
1 0/96
5'3 1/00
PR P
Soil
State concurred on
5/3 1/00; notice of FSD in
local newspaper:
Administrative Record
updated
Fed = 125 hrs
F.PA Contr - None
Fst'd Increase - S900K
Type of Change: From Install temporary gas vending system along northern boundary of the site (Red I.ion Road) to prevent off-site
migration of landfill gas and monitor basements in residential dwellings near the landfill; To - Improve and expand active and passive
gas venting systems hy installing permanent above-ground system along the Red l ion Road corridor that will operate with other system
components now in place
Factual Basis: Additional investigation in 1 997 and I 998 resulted in the remedy update
Appendix A.2
-------
Summary of Remedy Update Information for KYOO and FY01 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
N1cdia
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 4 - FY 00
Region 4
Mar/one Inc /('hcveron
Chemical Co.. CiA
9/30/94
5/2/00 (ROD-A)
10/1/99
5/2/00
PR P
(iroiind water
The State concurred on
the amended ROD The
proposed plan public
comment period was
1 2/1 5/99 to l/l 5/00.
Fed - Unknown
Contr - Unknown
Est'd Increase = S100K
Type of Change: f rom - 1 r.iditiori.il ground water pump and treatment technology; 10 - Passive Funnel and (iate Innovative Treatment
Teehnology utilizing iron filings and in-situ treatment of ground water
Factual Basis: A treatability study was conducted during the Remedial Design and resulted in the remedy update
Region 4 - FY 01
Region 4
Whitchousc Oil Pits. (:l.
5/30/85
7/16/01 (FSD)
10/1/98
7/16/01
F. PA
(¦round water.
Soil. Sediment
Slate concurred on ESD;
Fact Sheet sent out to
mailing list
Fed = 40 hrs.
Contr = 1 0 hrs.
Est'd Increase = S4.5M
Type of Change: From - On-site construction of a lime cutlairi. slurry wall and capping of contaminated soils; To • Off-site cleanup of
contaminated sediments and on site construction of slurry wall and larger cap lime cuitain was deleted from design
Factual Basis: During Remedial Design, it was determined that olT-site sediments needed to be remediated, the lime curtain was not
needed, and area of the slurry wall and cap needed to be increased in si/e.
Appendix A.2
4
-------
Summary of Remedy Update Information for FYOO and KY01 for Sites With Cost Increases
Region
Site Name, State
Date of
Oricinal ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 5 - FY 01
Region 5
l.owcr l:.corsc Creek
Dump, M I
7/1 7/96
7/13/01 (ROI)-A)
.vi/no
V29/OI
i:pa
Soil
Both the State and City of
Wyandotte were in full
support of the change
No comments were
received from the general
public.
Fed = 1 00 hrs
Contr. - None
F.st'd Increase: $35K
Type of Change: From - Excavation and disposal of shallow and deep soil: resampling, if necessary, and restoration of residential areas
affected by excavation: To - Soil cover
Factual Basis: Test pitting results indicated that the affected soil could safely be kepi in place.
Region 7 - FY 00
Region 7
Mruno Co-op
Assoc i;i lion/Associated
I'ropcrt ics. Oil 1, N 1
9/10/9X
X/2 5/00 (LSD)
1/2 5/00
X/25/00
fpa
('¦round water
State support, community
availability sessions, and
comment period
Fed- 100 hrs.
Contr " SI 25K
F.st'd Increase: S590K
Type of Change: Irom - Active pump and treat remedy to restore aquifer. To • Update provides greater detail in the assessment of
operation and maintenance costs as well as increased costs lor capital expcndituics and contingencies
f actual Basis: Kc-cvahialion of the ex-situ conventional pump and treat system, as compared with in-situ ground water circulation well
technology that generated a better cost estimate, resulted in the remedy update.
Appendix A.2
5
-------
Summary of Kemedy Update Information for l-'YOO and KYOI for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROn-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
F.st'd Cost Increase
Region 7 - I V HI
Region 7
ACF Services. KS
5/5/99
9/1.VOI (ROI)-A)
."!/()()
9/1 VOI
II' A
Ground water.
Soil
State concurred, public
meeting
Fed - 60 hrs
Contr. - S 1 OK
F.st'd Increase " $<1M
Type of Change: From - F:xtract and treat ground water and discharge treated water into creek tributary. Publicly Owned Ticatnicnt
Works IPOTW), or to beneficial reuse: To • Increase the si7e of treatment plant, number of extraction wells, method of treatment,
demolition of old site buildings, and provision of city drinking water supply to several residents
Kaetual Basis: Additional ground water monitoring during Remedial Design indicated that the plume was much larger than previously
thought. Based on increased extraction volumes, the type of treatment was changed to be more cost effective. The plume had also
spread to neighboring wells requiring the provision of another water supply. An increase in plume size required increase in plant size,
thus requiring a change in location back to the original site that required demolition of site buildings.
Appendix A.2
6
-------
Summary of Remedy Update Information for h'YOO and KY01 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 8 - FY 00
Region 8
Denver Radium
Sliattuek Chemical Site,
OUR. CO
I/2K/92
6/16/00 (ROD- A)
VI 4/99
1 2/20/99
Five-Year
Review with
State. City &
County
elected
officials.
Public
(iround wa ter.
Soil
Slate. City & County of
Denver, and local
community requested that
FPA consider other
alternatives to the onsite
remedy to allow for
restricted use of the site.
Fed - 500(1 hrs*
Contr = S300K
F.st'd Increase - SJSM
Type of Change: From - Under lite original remedy, all buildings were demolished and disposed of off-site. A monolith was placed on-
site. consolidating the excavated Shattuck facility soils along with soils from vicinity properties and from the adjoining railroad right-of-
way The monolith was capped with low-infiltration harrier materials and rip-rap surface; To - Removal of the monolith from the site
along with any additionally identified contaminants in excess of the cleanup levels specified in the amended ROD. The monolith and
any additional identified contaminated soils would he excavated and disposed of offsitc at a licensed/permitted disposal facility or would
he iccyclcd at a licensed facility Complete removal ol the monolith ami additional identified contaminants would leave no residual
eo nt am in at ion. pursuant to the origina 1 i cmcdv < iround watei moil itoi ing will cont inue as spcci fied in the original R OD
Factual Basis: Additional data on contaminated soils was provided.
*Note: A community activist group sued F.l'A for an inadequate five-year review of the on-site solidification/stabilization of low-level
radioactive soil A focused remedy review process included an unprecedented public dialogue with stakeholders including OSWFR.
Region 8. PUP, Stale. City, and community groups I'll is process involved long facilitated meetings and an FPA HQ contractor
conducted the independent Five-Year Review I'uhlic comment on this proposed plan was extensive and much effort was needed to be
as responsive as possible
Appcndit A.2
7
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Summary of Remedy Update Information for h'YOO and l-'YOI for Sites Willi Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fcd/Contr.
Est'd Cost Increase
Region 9 - KY 00
Region 9
San (iabricl Valley, Area 1
Whitticr Narrows Operable
Unit. t'A
3/31/93
1 1/10/99 (ROD- A)
1 996
1 1 /99
r.r a
Ciround water
State shared cost;
community notified with
proposed plan; extensive
coordination with basin
and down gradient water
purveyors.
Fed - 5000 hrs *
Contr = $2M
list'd Increase - S24M
Type of Change: From - Monitoring only; To - (iround water containment by pump and treat system (1 1.000 gpm).
Factual Basis: Concentrations of contaminants in ground water increased to unacceptable levels, necessitating an active remedy.
•Note: The work for the ROD amendment included installing several additional multiport wells in the area to determine the extent of the
newly detected contamination in both the shallow and deep ground water The extent that the plume had traveled into the Whitticr
Narrows OU from an up gradient source needed to be determined Additional detected compounds, ground water modeling, data
analysis and outreach to surrounding stakeholders was also needed
Appendix A.2
X
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Summar y of Remedy Update Information for I' YOO and KY01 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(ESD/KOD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
Statc/Comm unity
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 9 - FY 01
Region 9
Purity Oil Sales Inc.. OU2.
(A
9/30/92
6/30/96 (USD)
.1/30/01 (ISD)
•4/9X
3'01
('omm unity.
TP A
Soil
Substantial community
involvement throughout
process and ongoing
Fed -- 800 hrs *
Contr - S200K
f'st'd Increase " $3M
Type of Change: From - No relocation of lesidents. To - Temporary relocation of 32 families and pennanent relocation of 16 families
Factual Basis: Unacceptable short-term impacts to all residents of an adjacent trailer park resulted in the remedy update. Contaminated
soil discovered beneath fence line residents necessitated pennanent relocations
*Note: Thc remedy update resulted from numerous meetings with the community and other stakeholders from April 1998 until March
30, 2001 when the USD was written There were many negotiated meetings with the County of Fresno and the community as well as
oversight of construction activities that started in October 2000 The HSD requires the relocation of residents and many hours were
spent preparing the residents for relocation and determining the actual relocation offer Also during January 2001. F.PA conducted field
investigation work along the site perimeters that icsulted in the generation of a technical memorandum that documented the discovery of
contaminated soils beneath thc trailers and beneath the (ioldcn State Market
Appendix A.2
9
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Summary of Remedy Update Information for h'YOO and KY01 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD Date
of Change
(F.SD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Eit'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 10 - I'V 00
Region 1 0
Commencement Bay
Ncarshorc/Tideflats, WA
Thca Toss, Wheclcr-
Osgood and llylcbos
Waterways
9/30/98
8/30/00 (HSD)
f./99
8/30/0(1
IPA
Scd iments
Lxtensive coordination
and concurrence from
State and Puyallup Tribe.
One public comment
period prior to issuance
of the draft HSD A 65-
day public comment
period on the F.SD, plus a
public meeting 1 80
comment letters received.
Fed = Approximately
2.500 hrs.*
Contr. = Approximately
S25K
Fst'd Increase -
Approximately $25M
Type of Change: From - Site me restrictions. source control, nntiir.il recovery, sediment remedial action (i c.. confinement and hahilal
restoration), anil monitoring; To - Mote specific remedial actions consistent with the ROD. and identification of disposal sites for
containment of dredged contaminated sediments
("actual Basis: I're-rcmediatton design studies at the individual waterways better defined (lie area and volume exceeding the cleanup
levels that lead to the identification of specific areas where natural recovery would he appropriate, and specific areas to be dredged or
capped The estimated volume of material that needs to he dredged increased approximately 80% to 100% from the ROD estimates In
addition, the post-ROl) studies helped lil'A identify w hich disposal sites would be most appropriate to safely contain the dredged
sediments
'Note: The remedy update required extensive 1 PA resources to do the following activities:
1)	significant detailed review of design studies on the two major waterways;
2)	complicated negotiations with numerous PRPs and various regulatory agencies;
3)	complex source control issues involving major storm watei control and a NAl'I. source area from a historic coal gasification plant;
and 4) habitat migration needs
Appcndi* A.2
10
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Summary of Remedy Update Information lor I' YOU and FYOI for Sites With Cost Inereases
Region
Site Name, State
Date of
Original KOI) Date
of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 10
US DOl, 11 an lord
100 Area, WA
100 1U-6 Ot/
7/yy
6/1 5/00 (LSD)
2/00
6/1 5/00
II' A. 1)1)1.,
Stale
Wastes, Soil,
1 Jehus
The Slate supported and
concurred on the 1:S1)
I'lie Hanford Advisory
Hoard was briefed on the
LSD and a notice of
availability was published
in the local newspaper
fed - X0 hrs (I; P A )
I'onlr None
Lst'd Increase - JI.3M

Type of ( hungc: l-'ioiii - Remediation of Ki soil contamination ,u cas through lemoval of con I am in a ted soil. si rue lures and associated
debris; Irealinent as icqiiHed to meet the disposal tacility icquiremcnl.t; and disposal at an on site facility; Id - Keinediation ol 4K soil
contamination areas through removal ol contaminated soil, structures and associated debris; treatment as required to meet the disposal
facility requirements; and disposal at an on-site facility

Factual Change: The KOI) allowed the selected remedy in the KOI) to be applied to similar, but separate sites that met specific criteria,
if the public was informed about the additional sites through an LSD Based on (he posl-KOI) investigations, two additional sites were
determined to require remediation and to met the criteria established in the ROD
Region 10
US DOL Hanford
300 Area, WA
300 IT-5-OIJ
7/1 7/9(i
6/1 5/00 (LSD)
2/00
6/15/00
1:1'A, I)01;.
State
(iroiind water
I'he Slate supported and
concurred on the LSD
file Hanford Advisory
Hoard was briefed on the
LSI) and a notice of
availability was published
in Ihc local newspaper
Ked = 80 hrs (F.I'A)
t'ontr. - None
Lst'd Increase - SI80K

Type of Change: From • Interim remedy lor ground uater beneath the 300 area complex and the immediate vicinity, To • Interim
remedy lor ground water beneath all of the 300 area waste sites

Factual Change: Additional ground water plumes have been found beyond the original boundaries of the ground water OIJ. The
original selected interim remedy was dctcimined lo be inappiopriatc for these additional plumes
Appcndii A.2
-------
Summary of Remedy Update Information for h'YOU and KYOI for Sites With Cost Increases
Region
Site Name, State
Date of
Original KOI) Date
of Change
(ESD/ROD-A)
Date Review
Coin nicnced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Ked/Contr.
Est'd Cost Increase
Region 1 0
US HOC INLLl., II)
Argonnc National
Laboratory - West (OU9-
04)
9m
2/14/00 (LSD)
1 1 /99
2/14/00
noi.
Soil
Notice ol LSI) published
in six newspapers State
fully involved in
decision
Fed 10 hrs (LI'A)
Contr - None
Lst'd Increase S65K
Type of Change: Kroni - In-situ phyloreinedialion lor all site*. 1 o - In-situ phytoiemediation at some sites, cx-situ pliytoremediation at
one site, and excavation and on-INLLl. disposal lor lite rest ol" the sites
factual Basis: Hench-scalc tests showed that remediation goals could not he met in a reasonable time frame at some of the sites In- situ
pliytoremediation changed to cx-situ phytoremediation due to security upgrade needs
Appendix A.2
12
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Office of Solid Waste and Emergency Response
Washington, D.C. 20460
OSWER 9355.7-08FS
EPA 540-F-02-004
-------
Roy F. Weston. Inc.
Sane 500
"50 E. Bunker Court
Vernon Hills, 1L 60061
2 November 2000
Mr. Timothy J. Prendiville, SR-6J
U.S. Environmental Protection Agency
Region V
~/~ West Jackson Boulevard
Chicago, IL 60604
U.S. EPA Contract No.: 68-W7-0026
Work Assignment No.: 034-ROBE-Q537
Document Control No.: Rf W03--3A-AGUC
Subject: West KL Avenue Landfill Site
Kalamazoo County. MI
Dear Mr. Prendiville:
In accordance with your request, please find enclosed comments on the Request for Modification
by the West KL Avenue Landfill Group to the Record of Decision, dated S September 2000.
Please contact me at (847) 913-1042 if you have any comments regarding this submittal of the
subject project.
Very truly yours,
ROY F. WESTON, INC.

William F. Karlovitz, P.E.
Site Manager
WFK:kms
Enclosure
c: P. Vogtman
l •.V01RaCQ3^:9309-LTR WPD
*f\vo}4-:-a-aguc
This document *as prepared by Roy F. Weston. Inc.. expressly for I'.S. EPA. It shall not be released or disclosed m whole or in part
Hithout the express, written permission oft S. EPA.
-------
Review of Draft Request for Modification of ROD
West KL Site
Kalamazoo Michigan
1 November 2000
Roy F. Weston. Inc. (WESTON*) has reviewed the draft request for modification of the Record
of Decision (ROD) at the West KJ_ Landfill (hereinafter "the draft request") by the PRP group,
dated 8 September 1000.
1.0	Conclusions
1.1	Groundwater
Overall, WESTON concurs with the groundwater portion of the draft request. The groundwater
plume does indeed apDear to satisfv Agency guidance for using monitored natural attenuation
(MNA).! Extensive studies document that the plume is stable or shrinking, and no groundwater
receptors are at nsk while the natural processes take place. The only major reservation we
express about the draft request's groundwater remedy is the cost estimate.
The cost estimate for the pump-and-treat remedy appears high, and the cost estimate for the
natural attenuation remedy appears low. The cost for r.he pump-and-treat system appears nigh
because the estimated present worth of groundwater pump-and-treat has expanded from
approximately S2.3 million :n the ROD to S30 million in the draft request— a 13-foid increase.
MNA's cost appears low because MNA typically requires more water monitoring costs than
active remedies require. "In general, the levei of site characterization necessary ;o support a
comprehensive evaluation of NINA is more detailed than that needed to suppor. active
remediation."2 Yet m the draft request, the opposite is true. The draft request tells us :o budget
S"2.S25 per year for water monitoring under pump-and-treat. yet only S31.966 for water
monitoring under natural attenuation.
1.2	Landfill Cap
WESTON also concurs to some extent with the draft request's assessment of the landfill
remedy. We concur that a RCRA cap maybe excessive and, indeed, detrimental. We agree that a
RCRA cap regulations are not applicable. We agree that RCRA cap regulations are not
appropriate. We agree that infiltration of rainwater helps to keep the subsurface moist and
oxygenated, thereby speeding the decomposition of the chemicals of concern.
With regard to the revised cost of the RCRA cap. we are inclined to agree with the estimate in
the draft request. In the ROD, a RCRA cap was priced at about S14 million and in the draft
request, a RCRA cap is expected to cost about S21 million—a 50 percent increase, but not an
inordinate increase considering that feasibility studies typically do not aspire to precision in their
cost estimates.
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STANDARD RAC FOOTER
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In addition, to provide an independent rule-of-thumb comparison, the Federal Remediation
Technology Roundtable suggests that RCRA Subtitle C caps usually cost around S225.000 per
acre.-' For an 80-acre landfill, we would expect a cost of approximately SIS million, which is
easily w ithin 20 percent of the request's estimate.
We disagree, however, with the notion that because a RCRA cap would be detrimental to MNA
in groundwater, one may directly conclude that essentially no further action is appropriate. First,
the draft request misstated direct contact and inhalation risks to people. Second, the draft request
overlooked the ROD's documented concerns about ecological risks. Third, while doing a fine
job of explaining recent advances in remedy selection guidance, the draft request does not
identify recent guidance on ecological risk assessment. Fourth, the draft request fails to
acknowledge the possible detrimental effects of the existing cap on natural attenuation in
groundwater. Fifth, the risk of building a cap has been grossly overstated. [These points are
developed iater in WESTON's review.)
2.0	Recommendations
2.1	Groundwater
We recommend accepting the draft request for forgoing groundwater pump-and-treat. We
support the notion of proceeding with VINA for groundwater. We Jo. however, recommend
refining the cost estimates for the groundwater remedies.
2.2	Landfill Cap
We recommend taking a fresh look at determining the optimal cap for the landfill. The optimal
cap might be the existing cap, a gravel cap. a phyto cap. or some other variation on the theme.
The optimal cap will need to be compatible with MNA of groundwater and also be protective of
human health and the environment. We recommend evaluating ecological risk in accordance with
current guidance.
3.0 Record of Decision in 1990
The existing ROD was approved in 1990 and called for a groundwater component and a landfill
component.
The ROD's groundwater component consisted of Alternative GW-2 and a pump-and-treat
scheme. GW-2 was titled "limited action" and included groundwater monitoring, deed
restrictions, and residential well closures. The pump-and-treat scheme involved extraction of all
contaminated groundwater emanating from the site's western side, treatment of the extracted
water by fixed-film bioreactors, and discharge by reinjection. According to the ROD. the
pump-and-treat scheme was to restore groundwater within 18 years.
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STANDARD RAC FOOTER
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The ROD'S landfill component consisted of Alternatives LF-2 and LF-3b. LF-2 was titled
"limited action" and consisted of a perimeter fence and deed restrictions. LF-3b was titled
"containment utilizing a RCRA cap" and consisted of a 2-foot-thick clay cap and a polyethylene
liner over 83 acres. The main purposes of the cap were to prevent direct contact and to reduce
leachate generation. The reductions were judged relative to the existing cap. a patchwork of
bentonite in some places and nothing in other places. The RCRA cap appears to have been
considered "relevant and appropriate" rather than "applicable" because the last waste was placed
in May 1979, one year before promulgation of hazardous waste regulations under RCRA The
RCRA cap was selected instead of a Michigan Act 64 cap because the RCRA cap provided much
better control of infiltration while only modestly increasing cost.
At the time of the ROD, costs were estimated for the selected remedy as follows:
!
| Alternative
Capital Cost
PW of 30-vr O&M
Total PW
! GW-2
S4.200
S141.400
Si45.600 ;
I P&T with bioreactors
| (enhanced
| bioremediation)
St.533.300
5656.000
S2.195.000 •
| LF-2
SI 62.400
S 1.151,"00
S314.000 !
LF-3b
SI 3.601.600
SI 50.300
s: 3."52,400 :
i Total
1
S15.30~.000
SI.099.900
SI6.40". 100 j
The ROD was consistent with AR.ARs and Agency guidance at the time it was signed.
4.0	Draft Reauest=s Assessment of Site in 2000
The draft request acknowledges that the active elements in the ROD were not implemented. In
other words, neither the pump-and-treat system nor the RCRA cap was installed.
4.1	Groundwater
The request does a fine job of establishing that natural attenuation takes place in the aquifer. It
establishes the mechanisms of natural attenuation. It also establishes the protectiveness of natural
attenuatton for groundwater, showing that the groundwater plume is stable or shrinking while
never reaching a groundwater receptor.
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STANDARD RAC FOOTER
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4.2 Landfill Cap
The draft request establishes that infiltration of rainwater contributes to natural attenuation in the
groundwater. The request does not, however, devote attention to whether the existing cap allows
an optimal or near-optima) amount of infiltration. As the ROD explained, "a cap consisting of a
2-foot layer of mixed soil and granular bentonite was placed over areas of the landfill with less
than 10 percent slope and in areas where the slope was greater than 10 percent, no bentonite was
applied."'1 Considering that the request views infiltration as a desirable feature, we might have
expected the request to consider the possibility that the existing cap's impermeability might be
an impediment to infiltration and, therefore, might be an impediment to natural attenuation.
Instead, the request consistently calls the existing cap a semi-permeable cap. ignoring the point
that the landfill's flat areas are capped with a low-permeability mixture of soil-'oentonite.
The draft request misquotes the ROD in an attempt to downplay the risk of direct contact and
inhalation. According to the request. "The ROD implicitly recognized the effectiveness of this
cover in addressing direct contact inhalation risks when :t found that health risks associated with
those pathways 'are within acceptable nsk levels."' r Actually, the ROD expressed concern,
elaborating directly after the quoted portion to warn 'hat "The values for the exposure via
inhalation of volatiles by residents and dirt bikers are near unacceptable levels, but :hese issues
will be indirectly addressed through the containment (capping) of the iandtlil and the land use
restrictions of the selected remedy.'"' The ROD's current land use scenario showed significant
excess cancer risks (2E-05) to residents and dirt bikers ilE-O-t). We expec: that such risks
continue in 2000. even though the draft request does not r.ention them.
The draft request fails to acknowledge :he nsk to ecological receptors. In the 1990 ROD. the
Agency found that "The estimated PCBs intake by robins and shrews exceeds the toxicity values
derived for these species, therefore reproductive effects :n some members of the population may
be occurring."" As with the human health risks; we expect that the ecological risks continue in
2000. even though ihe draft request does not mention them.
We note that the draft request includes a claim that the nsk of traffic accidents necessarily makes
any cap counterproductive. The draft request actually claims that building a RCRA cap would
create a one-in-three chance of killing somebody in a traffic accident/ This claim appears
exaggerated, [f the Agency accepted it, no landfill would ever merit capping.
5.0	Evaluation of Changes
5.1	Science
The draft request does a good job of explaining the advances in the science of MNA in
groundwater, a field that has advanced considerably since the ROD was signed in 1990. We
consider the presentation of MNA in groundwater to conform to the orthodox understanding of
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STANDARD RAC FOOTER
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natural attenuation. We further note and appreciate that the PRP group has relied upon advice
from the leading experts in the field of natural attenuation.
5.2 Reeulation and Guidance
The ROD of 1990 only contained brief mention of ecological receptors, but any major review of
a ten-year-old ROD should consider the advances in Agency guidance since 1990. An eight-step
technical process for ecological risk assessment was established in 199".'' Guidance for site
managers was established in 1999.10 Given that even the rudimentary efforts in 1990 disclosed
ecological risk for two species, we think that ecological risk should have been considered more
fully using the current guidance in the draft request. Ecological nsk at the landfill surface could
exert a strong influence on the type of cap needed at West fCL, so the question of ecological risk
has considerable practical significance.
ENDNOTES
:. See. e.g.. Technical Protocol for Evaluating Natural Attenuation of Chionnated Solvents :n
Ground Water. EPA600."R-'")3 128. September 199S. See also L'se of Monitored Natural
Attenuation at Superfund. RCRA Corrective action, and Underground Storage Tank Sites.
OSWER Directive 9200.4-1 "P. 21 April 1999.
vOSW'ER Directive 9200.4-1 "P. p. 13.
J. Remediation Technology Screening Matrix and Reference Guide. Version 3.0. Federal
Remediation Technologies Roundtable. October 199". Section 4.30.
4. ROD for West K.L Landfill. September 1990. p. 1
-.Draft Request, p. 11, quoting ROD, p. 6.
6.	ROD, p. 6.
7.	ROD, p. 7
\ Draft Request, p. 11.
9. Ecological Risk Assessment Guidance for Superfund: Process for Designing and Conducting
Ecological Risk Assessments (ERAGS). OSWER Directive 9285.7-25. June 1997.
!0. Ecological Risk Assessment and Risk Management Principles for Superfund Sites. OSWER
Directive 9285.7-28P. October 1999.
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UJ ua:^9 KAI 616 459 3107
*ARNER NORCROSS
3 002
From:
To:
Data:
Subjact:
-------
S~A"E OF MICHIGAN
re?'.v
ENVIRONMENTAL RESPONSE 3MS»ON
JOHN ENGlcR, Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY ™£?£SSTE
'Bettor Service for 9 Better Environment*	i>nsing wi -Mseoo-:9»
-CLL STES BUILDING 30 9CX 30473 -ANSiNG Ml 48909-7973
;NTrnNET	a*q state mi us
RUSSELL X HARDING, director
November 4, 1998
Mr. Tim Prendiville
United States Environmental Protection Agency
Superfund Division SR-6J
77 West Jackson Boulevard
Chicago, Illinois 60604
Dear Mr Prendiville:
There has been a lot of discussion over the past several months about the West KL Landfill
located in Kalamazoo, Michigan. Much of the discussion has centered around the possibility of
allowing the Potentially Responsible Parties (PRP's) to repair and maintain a semi-permeable
cap over the landfill contents. There have been several university and United States
Environmental Protection Agency (EPA) studies performed that indicate a high degree of
potential biodegradability for both the landfill contents and the contaminant plume that has
developed.
Initially there were several chemicals of concern emanating from the landfill that migrated
through the vadose zone to the ground water. The resulting plume has been intensively
studied through vertical aquifer sampling and monitoring well sampling for more than a
decade For the past few years there has been a steadily declining trend in both the number
and mass of volatile organic chemicals (VOCs) in the groundwater piume near the source
area. This pattern may or may not continue.
The Michigan Department of Environmental Quality (MDEQ) has had open discussions at the
section and division level regarding the permeable cap issue. The scientific evidence points to
the landfill and the vadose zone beneath it as comprising a large bioreactor which seems to be
effectively destroying much of the hazardous content of the leachate. Additional source
control at the landfill boundary should complement these biological processes and eliminate
additional volatile organic compounds from entering the contaminated groundwater plume.
We feel comfortable that a semi-permeable cap, properly maintained, could be acceptable at
this site providing that adequate source control and ground water control measures are
implemented. Monitored Natural Attenuation may be an acceptable groundwater control
measure for the existing groundwater plume provided that adequate justification is provided,
adequate controls are put in place, and that the current ground water plume does not expand.
Under these conditions, such a cap could be protective of human health and the environment
cCP V00»
-------
From:	
To:	?.5»ST . R5WASTE (PRENDIVILLE-TIMOTHY)
Date:	10/22/98 10:49am
Subject:	Re: West XL and MNA
The purpose of the cap is to prevent contamination from moving away from
the fill as ground water flows under the landfill. A biotreatment system
at the down gradient boundary of the landfill will also prevent
contamination from moving away from the fill as ground water flows under
the landfill, and meets the definition of source control. As a practical
matter, in terms of reducing contamination in the rural residental
neighborhoods down grandient of the landfill, the biotreatment would
probably be a more effective means of source control than would a cap.
-------
Prom:
To:
Date:
Subj ect:
Mark Henry 
R5WST . R5WASTE ( PRENDIVILLE-TIMOTKY)
7/30/98 10:32am
KL issues -Reply -Reply
Tim, thanks for gectir.g back to me so soon. I did ask Andy if the DEQ would
allow for a permeable cap even though it had not been done before in Michigan
He said that yes they would support such a decision if it seems reasonable in
light of the forthcoming GW direction data, the LF studies that have already
beer, dor.e, etc. I personally beleive that the MNA and permeable cap are the
right thing to do at this site...and that's what I'm working towards. Later,
MK
-------
From:
To :
Date:
Subject:
TI MOTH"/ PRENDIVILLE
R5 CHG.IN("HENRYMASsta t e.mi.us"}
7, 30/98 10 : Ham
XL issues -Reply
Hi Mark,
Thanks for the message. Here are my quick thoughts on what ycu said. Let me
knew if I'm way off on this.
I guess I overstated what we thought the DEQ's position had been. My
management was ]ust concerned that your management was now backing away from
MNA and/or a permeable cover as even being a possibility here. Like ycu we
have not applied the seal of approval to MNA. We just want to make sure that
DEQ is not now becoming adverse to MNA/permeable cover as a concept. I think
that you should continue to seek an answer from your management in terms of
the permeable cover since less uncertainty surrounds that technology. They
shculd be able to give answer to whether they would ever approve of that
option. We all agree that additional work is needed cn the groundwater to
shew that MNA will work at this site. However, if your management is dead se
against a permeable cover, that may make the whole MNA issue meet, i.e. that
could adversely affect the MNA viability and 'JpJchn may not want to go any
I'm going to try to talk with Upjohn today and if I do I'll let you knew of
possible dates for a meeting. We'll of course talk before any meeting is hel
to clarify what we'll ask of them.
ner.
-------
Mr. Tim Prendiville
-2-
November4, 1998
In the event that this experimental remedy proves ineffective, the revised Focused Feasibility
Study (FFS) should probably contain viable contingency plans that would include a Resource
Conservation and Recovery Act Subtitle C impermeable cap (or the equivalent) over the landfill
contents and active ground water remediation. If the revised FFS is acceptable to the EPA
and the MDEQ it would constitute a fundamental change to the existing Record of Decision
(ROD). The revised FFS should be referenced within an amended ROD for the site after
presentation to the public.
I will continue to work with you towards a remedial action at the site that will satisfy all of the
regulatory and most of the PRP concerns. Please let me know if I can be of additional
assistance.
Sincerely,
Mapk Henry
Sdperfund Section
Environmental Response Division
517-335-3390
lapk
idpe
cc: Mr. David Kline, MDEQ
KL Site File
-------
03/16/04 14:46 FAJ 269 833 6811
PFIZER EHS
Pharmacia
?hannaaa Corporation
7000 Portage Road
Kalamazoo. Michigan *9001
February 7,2003
re/616.S33.4000
fat616.SU.4077
wytw.phamaaa.com
Mr. Timothy J. Prendiville
Remedial Project Manager
U.S. Environmental Protection Agency - Region V
Waste Management Division
77 West Jackson Boulevard HSRW-6J
Chicago, IL 60604
RE: STATUS UPDATE ON
PILOT STUDIES FOR ALTERNATE REMEDIAL TECHNOLOGIES
WEST KL AVENUE LANDFILL SITE,
KALAMAZOO COUNTY, MICHIGAN
Dear Mr. Prendiville:
This letter provides a status update on Pilot Studies for alternate remedial technologies
proposed by the KL Ave. Landfill (KLA) Group as outlined during our January 22, 2002
telephone call. As you know, the two pilot studies we have discussed are: 1) sulfate-addition
(bioenhancement) for groundwater near the landfill margin, as recommended by EPA research
to accelerate groundwater restoration and provide additional groundwater source control; and 2)
enhanced landfill gas extraction (ELGE) to remove/treat remaining sources in landfill waste. If
successful, these technologies could be implemented on a full scale in lieu of an impermeable
cap that would entomb such sources.
During the meeting with MDEQ and EPA management on December 12,2002, the KLA Group
noted that the cost to conduct the field-scale pilot studies is significant (about one million
dollars). Therefore, before the Group incurred such costs, we requested acknowledgement from
MDEQ that if the pilot studies were successful toward meeting performance goals previously
developed in cooperation with the State, it would support a ROD amendment to include such
technologies, in lieu of an impermeable cap. While this is a federal lead site, EPA asked that
the KLA Group seek the concurrence of the state in our proposed approach. It was hoped that
the DEQ Director would be able to respond to our request before Christmas as he indicated he
would, but that did not occur. Since that time, a new Director has been named and is awaiting
confirmation. The KLA Group has asked to meet with the newly appointed Director in an
attempt to resolve this issue.
We have worked diligently with EPA and MDEQ to prepare work plans for the pilot studies,
with EPA and MDEQ acknowledging that the latest version of the sulfate-addition Pilot Study
Work Plan was acceptable. During that time, we have continued to move forward with cap
design so that time-lines in the RD Work Plan are maintained. EPA has indicated to us that
such time-lines should not be delayed as we work to demonstrate the effectiveness of these
-------
03/16/04 14:47 FAl 269 833 6811
PFIZER EHS
Iffl UU3
To: Tim PrendiviUe. USEPA-Reirmn V 2	February 7. 2003
alternative technologies. Considering the time constraints, we initiated some preliminary pilot
work in early-to-mid December 2002 at the Sulfate-Addition Pilot test area.
With the delay in receiving word from the State, there is now insufficient time to effectively
perform the pilot programs and establish the superiority of the alternate remedy over the
impermeable cap approach before the RD schedule requires cap construction to begin. Given
the significant expense of conducting the pilot studies, we simply cannot justify moving
forward with the pilot projects when, even if successful, we have no assurance they will be
incorporated into the site remedy. Even early cap construction activities would cause major
damage and risks to the area that the alternative remedy is intended to avoid.
We request that EPA agree to allow us sufficient time to appropriately conduct the pilot
activities before a final cap construction must begin, to give us sufficient time to demonstrate
that the proposed alternative is more, protective of the environment, poses less risk to the
residents, and is an all around superior remedy to that specified in the ROD based on criteria
established in the NCP. It is unfortunate that we are placed in this position because of delays
associated with the state's inability to respond. We have worked diligently to avoid reaching
this point, but we are concerned that sufficient time may no longer be available to reach
technically sound conclusions unless EPA grants a schedule extension.
Please don't hesitate to call if you have any questions regarding this letter or other site-related
issues.
Sincerely,
William G. Gierke
Pharmacia & Upjohn - Environmental Quality Division
KLA Group - Technical Member
cc: Mark Henry, Michigan Department of Environmental Quality (MDEQ)
KLA. Group
Golder Associates Inc.
m, EPA2-C7-03 let
-------
U3/16/U4
14:4/ bAA ^by 844 bSll
rn^tK ttii

Pharmacia
Ptiarmao (orvontion
7000 Porta# Hooc
Kabmoioo, Mkhiqon 41001
February 5,2003
fe#6T6.JJ3.4000
falil6J}i.4077
www.plurmtas.cem
Mr. Mark Henry
Remedial Project Manager
MDEQ-ERD Superfund Division
525 W. Allegan, 4,h Floor, Constitution Hall
Lansing, Michigan 48913
RE: FORMAL MEETING REQUEST
ALTERNATE REMEDIAL TECHNOLOGIES
WEST KL AVENUE LANDFILL SITE
KALAMAZOO COUNTY, MICHIGAN
Dear Mr. Henry:
To follow up a previous verbal request to meet with the newly appointed Director, this letter
provides a formal request to meet with Mr. Chester to discuss the KL Ave. (KLA) Landfill
Group's position on proposed alternate technologies at the KL Ave. Landfill Site. This request
is made in light of the new Director not being party to December 12, 2002 and May 22, 2002
meeting discussions between former Director Harding and representatives of the KLA Group,
that included respective municipalities (i.e. Oshtemo Twp., Kalamazoo County and the City of
Kalamazoo) and Pharmacia. If you would prefer that we communicate directly with the
Director's office, we will be glad to do so.
We look forward to meeting with the new Director and to continue working with MDEQ in
developing the best approach to protecting human health and environment at this site
Sincerely,
William G. Gierke, P.G.
Pharmacia Corporation
KLA Group - Technical Member
w/Attachments
cc: Tim Prendiville, USEPA-RPM
KLA Group
Golder Associates Inc.
-------
03/16/04 14:46 FAX 269 833 B811
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7000 Portage Road
Kakmazoo. Michigtn 49001
tei 616.833 3000
ta6l6.833.68H
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-------
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Hies, Robert
From:	Gierke, William G [SUP/02G0J fwilIiarTi.g.gierke@pharmacia.com]
Sent;	Friday, December 20, 2002 9:23 AM
To:	'Mark Henry'; prendivilie.timothy@epa.gov
Cc:	Robenjiies@Goi6er.com (E-mail); Todd_Hees@Golder.com (E-mail)
Subject:	RE. comments to S04 WF
Mark,
The four additional consents 3re appropriate and helpful ar.d we will incorporate tiie.ti ir.tc
the Pilot Tsst Work Flan. I wculc like to revise specific pagea/ca'clea to the Work Plan
to incorporate your corjr.er.ts and attach the revised pages/table of parameters to a lett-sr
addendum if that is fine with you - considering the revisions will ba mir.ir.ai.
.K!cte, the wire-wrapped screens will be specific to the extraction ar.d injecticr. wells ;to
increase ef ficier.cy/effective open area] as monitoring wells are slotted, considering t.N.ay
wi 11 be 53-T.clec with low-flow .'bladder
pcir.ps! ar.d efficiency is not a problem.
Best regarcs ar.d enJCY the holidays.
cxll
	Original Message	
From; Mark Her.ry 'r.aiitc: HENRYMA3michigan.gov]
Sent: Thursday, Decerrxer 19, 2002 2:15 PM
To: prendivill*.ti~othy9e?a.gov
Cc: Gier
-------
HfiR-18-2304 THU 10:30 m GOLDER ASSOCIATES
FAX NC. 12
P. 2!
Hies, Robert
Sent:
To:
Cc:
Subject:
From:
Gierlce, William G [SUP/0200J [william.g.gierke@ph8rmacia.com]
Thursday, December 19, 2002 2:42 PM
RobertJIIes@Golder.Com (E-mail)
Todd_Rees@GoldBr.com (E-mail)
FW: comments to S04 WP
Prsndiville
2-19-02.doc (24 K,,
FY I
	-Original Message	
from; Mark Henry [raailto: HSNRVMASir.iehigan. gov]
Sent; Thursday, Decanbe: 13, 2002 2:19 5K
To; prenaiviile . t-tt.ozhySsoa. gov
Cc: Gierke, Xiliiarr. S ;S'JP ,'0200]
Subject: czz-er.zs to SC4 wp
Tlx, at tacr.ad are my ccrnjr.er.cs to the final draft oi ths sulfate sciaitior. W?. Pli-as-r let xe
know if vcu have any concerns, later,MH
>!ark A. Henry
. Engineer/ Pro] . Kanacer
icec-sr:-
Super fund Becticr.
PO Box 30425
Lansing, MI 4 3 909
31? 335 2353
F.fcr.ryy^.Ss-aze .mi. us
1
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MR-18-2004 TKl' ! 0: 3C AM COLDER ASSOCIATES
FAX MO. 1
12/19/02
Tim Prendiville
USEPA - Superfund Div.
77 W. Jackson Blvd.
Chicago, IL 60604
Dear Mr. Prendiville;
I completed my review of the document Final Draft, Sulfate Addition Pilot Work Plan,
Additional Pre-RD Hydrologic Investigations, West KL Avenue Landfill, Kalamazoo,
Michigan. I have compared this draft to the previous version that was submitted in July
2002. After review I offer the following comments:
•	Section 4,1.2; p 12, pp 3; This paragraph discusses the use of Sch 80 slotted PVC
screens. For long term reliability I would recommend using wire-wrapped
screens; either stainless steel or PVC. I have discussed this matter with Bill
Gierke and he is in agreement.
•	Section 4.2, p 12, pp 2; This paragraph mentions using ion-specific electrodes for
the analysis of the bromide tracer, i would recommend that at least 10% of these
samples also be analyzed in a fixed-based laboratory for verification.
•	Section 5.1, p 17, pp 4; Field analysis of the water samples should include ORP
and specific conductivity since both of these parameters should change over time
due to the modifications planned for the geochemistry at the site.
t Table I; Please have ORP included in the table of stabilization parameters. If it is
demonstrated by the PRPs that ORP cannot stabilize in a reasonable time during
purging, we can discuss removing it from the list.
If you have questions about any of these points or you would like to discuss these further,
please call me at your convenience.
Sincerely,
Mark Henry
Remediation and Redevelopment Division
. 517 335 3390
-------
:i?5l CrC Career Rccd, 3C:
Charry -i ii, N, Q8C3J
reiec-ore ;'££o} c i0-3 ~£i>
-ct (850)
©older Associates lnc.
II" Golder
Associates
November 22, 2002
Project No.: 943-3200
Wilham G. Gierke, P.G.
Pharmacia Corporation
Mail Stop 0047-88-009
7000 Portage Road
Kalamazoo, MI 49001
RE: SUMMARY OF NOVEMBER 13, 2002 MEETING
WEST KL LANDFILL, KALAMAZOO, MICHIGAN
Dear Mr. Gierke:
fa accordance with your request, Golder Associates Inc. (Golder) provides the following summary of
the meeting held on November 13, 2002 in Kalamazoo, Michigan between representatives of the
United States Environmental Protection Agency (EPA), Michigan Department of Environmental
Quality (MDEQ), Roy F. Weston, Inc., the West KL Landfill Group, and Golder.
Attendees at the meeting included.
Tim Prendivillc, USEPA
Mark Henry, MDEQ
Bill Karlovitz, Weston
Bill Gierke, Pharmacia
Kevin Walsh, Pharmacia
Bob Illes, Golder Associates
Steve f inn, Golder Associates (via telephone)
The main topics of discusston included an update of recent activities and review of Agency comments
on the Enhanced Landfill Gas Extraction (ELGE) Pilot Test Work Plan dated October 10, 2002. A
summary of the discussion and conclusions reached related to each of these topics is provided below.
Update on Recent Activities
Bill Gierke summarized recent activities that have included the following submittals: Enhanced
Landfill Gas Pilot Test Work Plan (October 10, 2002), a revised letter on remedy performance
standards (October 11, 2002), Data Summary Report for July through September rre-RD
Hydrogcologic Investigations (November 8,2002), Data Report for the 2002 Annual Residential Well
Sampling Event (November 5, 2002) and a Final Draft of the Sulfate Addition Pilot Test Work Plan
(November 8, 2002). In addition, a meeting was held on October 15, 2002 with EPA management
and MDEQ in Chicago to discuss the Group's proposals for an alternative to the ROD remedy and the
associated pilot studies. It was also stated that the quarterly sampling event was recently completed at
the end of October and included all wells recently installed along the down gradient margin of the
landfill and the monitoring well in the Oshtemo Trace subdivision.
Of==-C£S ACROSS ASIA. AUSTRALASIA. EUQC?E. NCWM AMERICA. SOUTH AMERICA
-------
KAR-18-2004 TK'i 10:23 M COLDER ASSOCIATES

i-.
Pharmacia Corporation
Mr. William G. Gierke
November 22. 2002
943-8200
EPA and MDEQ indicated that they had no objections to proceeding with the sulfate-addition pilot
test to consider this technology as an alternative to the ROD pump and treat remedy. MDEQ
indicated that they were still having internal discussions related to regulatory and performance
measurement issues for the ELGE system and whether it could serve as an equivalent - with respect
to environmental protection - to an impermeable cap. A meeting was tentatively scheduled with
MDEQ management for December 12 to further discuss these issues.
ELGE Pilot Test Comments
EPA and MDEQ comments on the ELGE Pilot Test Work Plan were received from EPA ir. an e-mail
dated November 6,2002. The majority of the discussion focused on the various comments related to
addressing the vadose zone with the ELGE system, approaches for measuring performance,
quantifying the mass of contaminants currently within the landfill and vadose zone, and the use of
inlet wells.
Vadose Zone
The KL Group agreed to investigate the vadose zone as pan of the ELGE pilot test to assess whether
there is substantial mass of benzene and THF within this zone that may be amenable to vapor
;xrraction. There was consensus that this investigation could consist of collecting soil gas samples
from discrete elevations from select borings in the pilot test area. The ELGE pilot test would be
expanded, if appropriate, into the vadose zone if substantial contaminant mass is available for vapor
extraction. The pilot test may therefore include additional probes within the vadose zone, although
the number would be less than in the waste mass due to the relative homogeneity of the vadose zone.
If warranted based on vadose-zone sampling results, an additional extraction well may also be
installed, screened through the vadose zone and the waste, m addition to the one currently planned
within the waste only. EPA indicated that a modified SAP/QAPP may be required to be consistent
with most recent EPA QAPP guidelines. The EPA RPM would discuss this issue internally with the
EPA QA representative.
Mass of Contaminants
Several comments were made related to sampling the soil and waste prior to the pilot test
(establishing a baseline) and sampling following the pilot test to evaluate effectiveness of the ELGE.
It was agreed that there was no practical method to sample the waste so as to establish a reliable
baseline mass of contaminants in the waste, due to its heterogeneity. It was noted that baseline vapor
conditions will be established in the pilot test zone prior to initiating the pilot test and on a lar.diill-
wide basis prior to initiating full-scale ELGE. The Group noted that the key performance criteria is
that the rate of source mass removal exceeds that ot" the current flux to groundwater for benzene and
EPA indicated that they would further discuss this issue internally.
Met wells
Dr. Mort Barlaz of North Carolina State University was brought into the meeting via telephone,
Inlet wells were proposed as a means to experiment with introducing oxygen into the deeper portions
of the landfill. Inlet wells could enhance removal of VOCs at depth and potentially provide some
THF,
Goldftr Associates
-------
' MAR-18-2004 THU 10:23 A,M GC.DER ASSOCIATES
FAX NC, 12
P, i8
Pharmacia Corporation
Mr. William G. Gierke
November 22, 2002
943-4200
aerobic oxidation particularly for THF. .However, it is not the intention to mm the .system hilly
aerobic as other constituents that are being treated aerobically may begin to leach. Concern was
expressed with the potential for starting art underground (landfill) fire. It was acknowledged that this
approach is relatively ne-.v and that, prior to including it in a full-scale system, additional evaluation
would need to be conducted on the results at other landfills where air has been introduced. It was
noted that the pilot test will be small scale and will monitor oxygen and temperature during the test.
Remaining Comments
All of the remaining Agency comments on the ELGE Pilot Test Work Plan were reviewed during the
meeting. The following clarification and adjustments to the Work Plan were agreed as response to
the Agency Comments:
1.	The pH within the waste will not be measured.
2.	Dilution air is necessary at the blower to avoid "starving" the blower during operation. The
system will be equipped with a flame arrestor, intrinsically safe equipment and include
monitoring to mi!igate the potential for explosion as described in the draft Work Plan.
3.	Condensate collection is not planned following the blower as it is not planned to reduce
temperatures prior to treatment below the dew point.
4.	Carbon steel will be used during the pilot test for the transmission lir.es as it is a relatively
short duration test. More resistant materials (e.g., HDPE) would be used for a full-scale
system.
5.	A P1D is planned :o be used to assess baseline conditions as described in Tabic 3-1 of the
Work Plan. Moisture content of the vapor stream will be measured using a field
instrument.
6.	Oxygen and carbon dioxide will be monitored to evaluate effectiveness of inlet wells and a
separate tracer gas will not be introduced.
7.	Pressure will be monitored during the recovery test at more frequent intervals (e.g., every
10 minutes).
8.	Pulsed testing is not planned as part of the pilot test and the text will be modified to clarify
this issue.
9.	Manometers will be used to measure vacuum.
10.	A 10.6 eV lamp will be used on the PID. If available, a methane rich gas will be used as
the reference standard to check meter response to methane.
11 - Equipment will be intrinsically safe, where possible.
12.	A range of values for the dynamic viscosity of the landfill gas and the refase porosity will
be considered when evaluating the results of the pilot test.
13.	The radius of influence will be calculated based on a vacuum of 0.1 inches of water, per
EPA guidance.
14.	A reference will be added to indicate the equation on P. 21 of the draft Work Plan is from
the USACOE (1995).
15.	A clarification will be added to the Work Plan explaining the potential of temperature rise
during the introduction of ambient air.
!6. The tedlar bags will be purged three rimes with sample gas prior to collection of the
sample.
17.	A clarification will by added to the SAP referencing the internal quality control checks.
18.	The MDEQ address will be corrected in the SAP.
19.	Extraction well screens depths and monitoring probe screen intervals will be determined
based on field conditions encountered. Monitoring probe screens will be 5 feet unless field
Golder Associates
-------
!1frH8-2004 THu 10:2S m GOLDER ASSOCIATES
FAX NO. 12
Pharmacia Corporation
November22. 2002
943-S2CO
Mr. William G. Gierke
conditions dictate a longer screen. The extraction well screen will extend to the bottom ox"
the waste if a separate well encompassing the vadose zone is not included as pan of the
Pilot Test.
The USEPA requested that the QAPP for the proposed laboratory be provided. In addition, :hey wiil
check to determine that the SAP. QAPP format provided in the Work Plan is suitable in Region V
MDEQ requested that the Group conduct sampling for pharmaceuticals from select wells along the
downgradient margin of the landfill. Pharmacia indicated that they would evaluate MDEQ's request.
A site visit was conducted following the meeting to review the location of the sulfate pilot test.
Very truly yours,
WL'PSF'bjb
S:\prcj«is\04J.82QO\J :-22-Q21tr,d(x
cc: Tim Prendiville, USEPA
Mark Henry, MDEQ
Kevin Walsh, Pharmacia
Other
GOLDER ASSOCIATES INC.
PP /I////
/ y Robert J. Illes, P.G.
Associate
P. Stephen Finn, C.Eng.
Principal
Gofder Associates
-------
&R-: = -2:C4 Tr.: 10:25 ^ COER associates
llles, Robert
From:	GIERKE, WILLIAM G [SUP/02CQ] [william.g gierke@pharmacia.com]
Sent:	Wednesday, November 06,2002 12:45 PM
To:	Robert_li;es@Golder Com (E-mail)
Cc:	WALSH, KEVIN M [SUP/0200]
Subject:	FW: ELGE Comments
ELGEpiiCtStudyWP. :r«nc.ville 10-25-02
wpd (19 KB) ELGE.doe ...
3cb,
Here they ar;. We need to talk today regarding a number of tnir.gs, please call.
Bill
	Cr.cinal Message	
From: ?r ;r.o: vi I1 e . I ir.othyjepamail. epa .gov
; mailt:;: ?rer.di*-ill9. Tir.cthy*3ep«r5sii . epa. gov)
Sent : A5cr.= scay, November 06, 2002 12:18 ?*•:
Tc: William. 3 .Gi§r*s3ar..pnu.com
Cc: ner.rvma 33t it e . ~i . js; karlovibSmail. rfwe.sr or:. com
S-Cject: ZLGZ rommi-r.ts
Fcr purposes of -discussion at the planned November 13rh meeting I am attaching, 1:-. .vr.c.s,
>iDZQ'3 and Wester; 's comments or. the draft Pilot Stuoy Work ?lsr.. Th^r* are tv;c
cvsrir:.-.:-: zcr.oerns of tne agencies which were also presentee! ir. our meeting if irttc^r
15th whicr. 1 war.t to
here. First the pilot study must m some way address vadese cone
contamination. If the EI.GZ system merely addresses the source materials within the
lancfiilec waste, it may potentially be ignoring a mere substantial mass cf centammsr.-.5,
result.n; _n no real net gam in the time to remediate the croundv;ater even if it .s
effective 1.- tr,e was-e material. Secondly, and related Co the first concern, some effort
niscs to be mace to define tne mass in the waste anc vadose tone prior tc the pilot test
(establishing a baseline), anc then develop the pilot tc evaluate the effectiveness ir. th*
removal of that mass. There are obvious inherent difficulties in measuring tr.e
effectiveness over such a abort time period, but we believe some demonstration must oe
made before «; are willing tc commit more time to this technology.
Wc look forward to discussing these comments, and any ether issues with you cn tr.e 13th.
I: you sn:u.; have any questions prior to then feel free to give me a cali.
(Sea attacnec file: ELGEpilctstudyrtP.wee)(See attached file: Prer.diville 10-25-C2
——Gi.occ1
1
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Draft PILOT STUDY WORK PLAN
Enhanced Landfill Gas Extraction System
West KL Avenue Landfill Site
Kalamazoo, Michigan
Weston Solutions, Inc. has completed a review of the draft Pilot Study Work Plan,
Enhanced Landfill Gas Extraction System for the West KL Landfill Site, dated October
2002, and offers the following comments.
General comments include the following:
The proposed pilot test would allow evaluation of contaminant mass in the land fill but not in
the Vadose 2one. An additional S VE well along with several monitoring probes to evaluate
the contaminant mass could be placed in the middle of the vadose zone and a similar pilot
test could be run. The proposed monitoringprobes in the rillmaterial could also be used to
monitor vacuum influence for an SVE well placed in the vadose zone. This would allow
evaluation of contaminant mass and vacuum influence within the vadose zone.
Specific comments include the following:
2.4 Well Construction
The work plan proposes to install the SVE weil screens from 15 feet bgs to 5 feet above the
base of the fill. Depth of the fill is reported to be 20 to 30 feet. The SVE well screen should
be screened in the bottom one-third to one-half of the landfill and extend to the bottom of the
fill to maximize the radius of influence. Placing the screen above the bottom of the fill will
minimize vapors extracted from the last five feet of the fill.
Probes are proposed to be 10 feet in length. This is too long a slotted interval (SI) given the
depth of the fill and the function of the probe. An adequate amount of separation is required
to distinguish the difference in vacuum between the shallow and deep monitoring points.
Five feet is more than sufficient for a vapor probe. It is important that all probes of the same
t>pe (deep or shallow) should be installed the same depth below the surface of the fill.
2.5.1 System Components
The extraction blower should be equipped with explosion-proof motor and
controls. All instrumentation and equipment in contact with the landfill vapors
should be intrinsically safe or explosion-proof.
-------
fAR-13-2C04 THU 10:26 COLDER ASSOCIATES
FP.X NC. 12
p. ::
2.6.3 Step Test
A flow rate of 10 cfm will be difficult to control with a blower rated at 250 cfm even
with changing shives and belts.
The rationale for testing of the passive inlet wells is unclear. It would seem
counterproductive to draw excessive amounts of air into the fill. This could effect
the anaerobic methanogens and thus reduce methane production. The limited
amount of passive wells is unlikely to promote additional movement of air within
the landfill.
3.1 Operational Data
The pitot tube flow meter is very sensitive to moisture build-up. A different type of
flow meter should be considered.
3.4 Additional Testing
Some testing should be performed on discharge side of carbon cannisrers to
determine if breakthrough has occurred.
4.1 Data Analysis and Interpretation
The one-dimensional radial flow model may be appropriate but may overestimate
the radius of influence. A two-dimensional model, such as that developed by
Shan, et.al., Water Resources Research, April 1972, provides a more robust
solution for the radius of influence. This model allows comparison of vertical
versus horizontal intrinsic permeability. This may provide an analysis of the effect
of the existing bentonite enhanced cover.
-------
HAR-18-2004 THU 13:27 AM GCLQER ASSOCIATES
10/25/02
Tim Prendiville
US Environmental Protection Agency
Superfund Division - SR6J
77 W. Jackson Blvd.
Chicago, 0L 60604
Dear Mr. Prenciviile:
1 have reviewed the Golder & Associates document Draft Pilot Study Work Plan,
Enhanced Landfill Gas Extraction, Kalamazoo County, Michigan prepared for the
potentially responsible parties (PRPs) for the KL Landfill Superfund site. After
consideration of this plan I offer the following comments.
•	Section 2.1, page 5, bulleted items; The PRPs should characterize the vertical
distribution of contamination in the vadose zone beneath the waste. It is very likely
that the majority of the contaminant mass currently exists in this vadose zone. Bu
neglecting this source area, the effects of an Enhanced Landfill Gas Extraction
(EGLE) system may not be evidenced in the groundwater at the edge of the landfill
for several years, if at all.
•	Section 2.1, page 5, bullet 3; The PRPs suggest that they will measure the pH of the
waste. I would like to know how this will be performed.
•	Section 2.2, page 7, pp 1; The PRPs state that they will investigate the flow regime
within the waste. It ;s also important to measure the flow regime in the vadose zor.e
beneath the waste.
•	Section 2.2, page 7, pp I; The PRPs state that the performance of the EGLE system
will be evaluated by assessing the VOC mass removal rates. This approach is flawed
because we do not have a baseline against which to compare the mass removed, i.e.
we do not know the total mass in the landfill. A better gauge would be to measure the
amount of mass in the soil or waste and sample agam after the pilot to show a
decreased mass in the source material. We should use this same approach to gauge the
effectiveness :n removing mass from the vadose zone.
•	Section 2.3, p S, pp 1; The monitoring probes that the PRPs proposed should also
include a set of proves in the vadose zone because the vadose zone should also be
remediated using the EGLE and, of course, should be monitored.
•	Section 2.4, p S, pp 1, the EGLE extraction well should be installed to the water table
and outfitted with a packer of some other device to isolate testing in the waste from
testing in the vadose zone.
•	Section 2.4, p 8, pp 2; I do not think that it is necessary to bentonite the bottom of the
EGLE extraction well hole since it is not necessary to isolate this well screen from the
underlying soils. The remediation of the underlying soils beneath the waste should
also be tested for treatment as mentioned previously.
•	Section 2.4, p 3, pp 3; In the full implementation of the ELGE technology, 1
recommend using the combusted vapors from the extraction treatment system as
-------
8-2004 THU 10:27 AM GOLDER ASSOCIATES
Frv! NO.
influent gasses to the passive inlet vents. These exhaust gasses should be iow in
oxygen and high in moisture, both of which would be desirable for reinjection into the
landfill.
•	Section 2.4, p 8, pp 4; There is a typographic mistake. The word "construction"
should probably be "constructed". In this same paragraph, the description of the
probes should also include a description of probes into the vadose zone.
•	Section 2.5.2, p 10, pp 2; The PRPs state that they will use dilution air to reduce
either the flow rate or vacuum potential at the wellhead. I suggest that it is unwise to
mix air with a methane-rich landfill gas within transmission lines because of the
potential explosion hazard.
•	Section 2.5.2, p 11, pp 1; The PRPs indicate that additional condensate removal will
be accomplished post-blower. The diagram that thev provide (Figure 2-3) does not
indicate this process. Also, the condensate is likely to be acidic due to organic acids,
sulfides, etc., carbon steel may not be the best choice of materials for the transmission
lines.
•	Section 2.6.2, p 11; Included in the baseline sampling should be measurements
utilizing PID detector to determine the PID response to the landfill gas. PED's do
respond to methane, so a response to the landfill gas is not necessarily a response to
aromatic/alkene molecules. In addition, the moisture content of the extracted baseline
landfill gas should be measured to establish a baseline.
•	Section 2.6.3, p 12, pp 2; The PRPs propose to open the two passive gas inlet vents
during a portion of the pilot test. I would recommend that the PRPs introduce a tracer
gas such as helium, argon, or perhaps even propane to serv e as a tracer compound to
more accurately determine the residence time of the introduced air that comes
specifically from the air inlets.
•	Section 2.6.5, p 13; The PRPs propose to measure the recovery of the landfill
pressures as a function of lime after the extraction has been discontinued on hourly
intervals. I suggest that for the first hour or two that measurements be performed at 10
minute intervals due to the greater pressure changes that will likely occur early in the
recovery. Later in this paragraph there is a typographic mistake. The word
"intermitted" should probably be replaced by "intermittent". Mention is made that the
ELGE system operated in a pulsed mode will be "evaluated". How will this
evaluation be performed if not actually tested in the pilot iest?
•	Section 3.1. p 15, first bullet; I recommend that water manometers be used rather than
gauges for measuring vacuum. Manometers are more accurate and much less
expensive.
•	Section 3.2.1.1, p 16, pp 1; The PRPs intend to use a PID detector with an 11.7 eV
bulb. This powerful a buib will excite methane which will be detected with a response
that could be interpreted as a response to VOCs. 1 fully expect that methane will pass
through the GAC system and be detected by the PID. It may be better to use a 10.6 eV
bulb which will have a greatly reduced sensitivity to methane, and hence a greatly
reduced detector response. In this manner the PID response is almost exclusively due
to VOCs which is what we wish to monitor with the PID. An LEL meter is probably a
better measure of methane concentrations that is less sensitive to VOCs and will
provide a better indication of methane concentrations for the purposes of safety. If
methane concentrations are to be measured, I would recommend a meter that is
-------
16-2C04 THU 10:26 AM GOLCtR ASSOCIATES
FAX NO. 12
specifically designed to measure methane (eg. Lantec Gem 500 Landfill Gas meter).
•	Section 3.2.1.1, p 16, pp 2; In this paragraph the work plan calls for the calibration of
the PID detector with a "known reference standard". I suggest that this reference
standard contain a substantial amount of methane (-45%) so that the detector
response during calibration is more heavily weighted to the detection of VOCs and
less so for methane
•	Section 3.2.1.2, p 17, pp 2; Since the workers will be working in an area with
potentially high methane levels, the PRPs should consider using intrinsically safe
equipment.
•	Section 3.2.2; It may be instructive to measure the VOC concentration in the exhaust
gas from each of the GAC units near the end of the pilot test to find out if VOCs have
broken through the GAC units. This may be valuable information to be used later in
this process and would take almost no time to measure.
•	Section 4.1, first equation; In this equation the dynamic viscosity of air is used. If a
value for the dynamic viscosity of a methane/nitrogen mixture is known, it may be a
more appropriate value to use in this equation.
•	Section 4.1, p 20, pp 1; This paragraph states that the "Refuse porosity will be based
on the permeability, bulk density, and moisture content." Since the permeability, bulk
density and moisture content are all estimated values, thai means that the refuse
porosity estimate will be based on estimates. Since this value has a large amount of
uncertainty associated with it, if a calculated porosity value is used, that a range of
values will be considered - sort of a sensitivity analysis.
•	Section 4.1, p 20, pp 3; The text states that a theoretical radius of influence (ROr) will
be calculated from a graph of the data where the data converges on the horizontal
axis. The current thinking about actual ROI for vapor extraction wells is that the ROl
should be calculated, not froin a point of zero vacuum influence, but from a point of
approximately 0.1 inches of water vacuum.
•	Section 4.1, p 21, ppl; Is this equation also from the USACOE (1995) reference?
•	Section 4.1, p 21, pp 4; Please have he PRPs explain what is meant by there statement
that introduction of ambient air will "result in excess temperature rise".
•	SAP Section 2.2.1, p 1 of 11, pp 1; This paragraph states that the Tedlar bags will be
purges with air three times before each use. I suggest that it would be best to purge the
bags with sample gas three times before a sample is collected.
•	SAP Section 2.2.1, p I of 11, pp 2; I recommend using a peristaltic pump if the
sample tubing is to be purged. The PRPs did not specify the type of pump to be used.
•	SAP Section 2.4.3, p 6 of 11, pp 2; As mentioned above, it would be better if the
sample gas were used to purge the Tedlar bags prior to sample collection, rather than
air.
•	SAP Section 2.7, p 7 of 11, pp 1; Please have the PRPs specify what procedures are
their "Internal QC checks".
•	SAP Table B-l; Please correct the MDEQ address; it should be: iMark Henry,
Constitution Hall, 3rd Floor South, PO Box 30426, 525 West Allegan, Lansing, MI
48909. Also, please have the PRPs include a phone and fax number for Bill Gierke.
I hope that you find these comments helpful in the evaluation of this ELGE work plan.
If you have questions about any of these points, please call me at your convenience
-------
THU 10:28 AN GOLDER ASSOCIATES	FAX NO. 12	?. '.5
Sincerely,
Mark Henry
Remediation and Redevelopment Division
517 335 3390
-------
03/11-04 15:53 FAJ 16107522000	WARNER	__ ^005
1
JOHN ENQLER
Swrs or Michigan
DEPARTMENT OF ENVIRONMENTAL QUALITY
Lansing
DI&
HU83ELL J. HARDING
OIBSCTOA
October 29,2002
Mr. Tim Prendivilte
United States Environmental Protection Agency
Superfund Division - SR8J
77 W. Jackson Boulevard
Chicago, Illinois 60604
Dear Mr. Prendiville:
I have reviewed the Goider & Associates document Draft Pilot Study Work Plan,
Enhanced Landfill Gas Extraction, Kalamazoo County, Michigan prepared for the
potentially responsible parties (PftPs) for the KL Landfill Superfund site After
consideration of this plan I offer the following comments.
•	Section 2.1, page 5, bulleted items; The PRPs should characterize the vertical
distribution of contamination in the vadose zone beneath the waste. It is very
likely that the majority of the contaminant mass currently exists in this vadose
zone. By neglecting this source area, the effects of an Enhanced Landfill Gas
Extraction (EGLE) system may not be evidenced in the groundwater at the edge
of the landfill for several years, If at all.
•	Section 2.1, page 5, bullet 3; The PRPs suggest that they will measure the pH of
the waste. I would like to know how this will be performed,
« Section 2.2, page 7, pp 1; The PRPs state that they will investigate the gas flow
regime within the waste. It is also important to measure the flow regime in the
vadose zone beneath the waste.
•	Section 2.2, page 7, pp 1; The PRPs state that the performance of the EGLE
system will be evaluated by assessing the volatile organic compound (VOC)
mass removal rates. This approach is flawed because we do not have a
baseline against which to compare the mass removed, i.e. we do not know the
total mass in the landfill. A better gauge would be to measure the amount of
mass in the soil or waste and sample again after the pilot to show a decreased
mass In the source material. We should use this same approach to gauge the
effectiveness In removing mass from the vadose zone.
•	Section 2.3, p 8, pp 1; The monitoring probes that the PRPs proposed should
also Include a set of probes in the vadose zone because the vadose zone should
also be remediated using the EGLE and, of course, should be monitored.
CONSTTTUTION MALL • 535 WEST AUEGAN *m«rr - P>,a BOX 30*30 « LAN3MNCL MfGHKJAM 4M0#-79a8
* (317) 3T5-9W?
-------
03/11/04 15:53 FAX 16167522000	WARNER			2)006
Mr. Tim Prendtville	-2-	October 29, 2002
•	Section 2.4, p 8, pp 1; the EGLE extraction well should be installed to the water
table and outfitted with a packer or some other device to isolate testing in the
waste from testing In the vadose zone.
•	Section 2.4, p 8, pp 2; I do not think that it is necessary to bentonite the bottom of
the EGLE extraction well hole since it Is not necessary to isolate this well screen
from the underlying soils. The remediation of the underlying soils beneath the
waste should also be tested for treatment as mentioned previously.
•	Section 2,4, p 8, pp 3; In the full implementation of the ELGE technology, I
recommend using the combusted vapors from the extraction treatment system as
influent gasses to the passive inlet vents. These exhaust gasses should be low
in oxygen and high in moisture, both of which would be desirable for reinjection
Into the landfill.
•	Section 2.4, p 8, pp 4; There is a typographic mistake. The word "construction"
should probably be "constructed". In this same paragraph, the description of the
probes should also include a description of probes into the vadose zone.
•	Section 2.5.2, p 10, pp 2; The PRPs state that they will use dilution air to reduce
either the flow rate or vacuum potential at the wellhead. I suggest that it is
unwise to mix air with a methane-rich landfill gas within transmission lines
because of the potential explosion hazard
•	Section 2.5.2, p 11, pp 1; The PRPs indicate that additional condensate removal
will be accomplished post-blower. The diagram that they provide (Figure 2-3)
does not indicate this process. Also, the condensate is likely to be acidic due to
organic acids, sulfides, etc.; carbon steel may not be the best choice of materials
for the transmission lines.
•	Section 2.6.2, p 11; Included In the baseline sampling should be measurements
utilizing photo ionization detector (PID) detector to determine the P1D response to
the landfill gas. PID's do respond to methane, so a response to the landfill gas is
not necessarily a response to aromatic/alkene molecules. In addition, the
moisture content of the extracted baseline landfill gas should be measured to
establish a baseline.
•	Section 2.6.3, p 12, pp 2; The PRPs propose to open the two passive gas inlet
vents during a portion of the pilot test. I would recommend that the PRPs
introduce a tracer gas such as helium, argon, or perhaps even propane to serve
as a tracer compound to more accurately determine the residence time of the
introduced air that comes specifically from the air inlets.
•	Section 2.0.5, p 13; The PRPs propose to measure the recovery of the landfill
pressures as a function of time after the extraction has been discontinued, on
hourly intervals. I suggest that for the first hour or two, that measurements be
performed at 10 minute intervals due to the greater pressure changes that will
likely occur early in the recovery. Later in this paragraph there Is a typographic
-------
04 15:53 FAI 16167322000	WaRNER			g|007
Mr. Tim Prendiville	-3-	October 29,2002
mistake. The word "intermitted" should probably be replaced by "intermittent".
Mention is made that the ELGE system operated in a pulsed mode will be
"evaluated". How will this evaluation be performed if not actually tested in the
pilot test?
•	Section 3.1. p 15, first bullet' I recommend that water manometers be used rather
than gauges for measuring vacuum. Manometers are more accurate and much
less expensive.
•	Section 3.2.1.1, p 16, pp 1; The PRPs intend to use a PID detector with an 11.7
eV bulb. This powerful a bulb will excite methane which will be detected with a
response that could be interpreted as a response to VOCs. I fully expect that
methane will pass through the GAC system and be detected by the PID. It may
be better to use a 10.6 eV bulb which will have a greatly reduced sensitivity to
methane, and hence a greatly reduced detector response. In this manner the
PID response is almost exclusively due to VOCs which is what we wish to
monitor with the PID. An LEL meter is probably a better measure of methane
concentrations that is less sensitive to VOCs and will provide a better indication
of methane concentrations for the purposes of safety. If methane concentrations
are to be measured, I would recommend a meter that is specifically designed to
measure methane (eg. Lantec Gem 500 Landfill Gas meter).
•	Section 3.2.1.1, p 16, pp 2; In this paragraph the work plan calls for the
calibration of the PID detector with a "known reference standard". I suggest that
this reference standard contain a substantial amount of methane (~45 percent)
so that the detector response during calibration is more heavily weighted to the
detection of VOCs and less so for methane.
•	Section 3.2.1.2, p 17, pp 2; Since the workers will be working in an area with
potentially high methane levels, the PRPs should consider using intrinsically safe
equipment
•	Section 3.2.2; It may be instructive to measure the VOC concentration in the
exhaust gas from each of the GAC units near the end of the pilot test to find out if
VOCs have broken through the GAC units. This may be valuable information to
be used later in this process and would take almost no time to measure.
•	Section 4.1, first equation; In this equation the dynamic viscosity of air is used. If
a value for the dynamic viscosity of a methane/nitrogen mixture is known, it may
be a more appropriate value to use in thfs equation.
•	Section 4.1, p 20, pp 1; This paragraph states that the "Refuse porosity will be
based on the permeability, bulk density, and moisture content." Since the
permeability, bulk density and moisture content are all estimated values, that
means that the refuse porosity estimate will be based on estimates. Since this
value has a large amount of uncertainty associated with it, if a calculated porosity
value is used, that a range of values will be considered - sort of a sensitivity
analysis.
-------
03-1104 15:53 FAX 16167522000
WARNER
2oos
Mr. Tim Prendiville
October 29, 2002
•	Section 4.1, p 20. pp 3; The text states that a theoretical radius of influence (RQI)
will be calculated from a graph of the data where the data converges on the
horizontal axis. The current thinking about actual ROI for vapor extraction welts
is that the ROI should be calculated, not from a point of zero vacuum influence,
but from a point of approximately 0.1 inches of water vacuum.
•	Section 4.1, p 21, pp1; Is this equation also from the USACOE (1995) reference?
•	Section 4.1, p 21, pp 4; Please have he PRPs explain what is meant by there
statement that introduction of ambient air will "result In excess temperature rise"
•	SAP Section 2.2.1, p 1 of 11, pp 1; This paragraph states that the Tedlar bags
will be purged with air three times before each use. I suggest that it would be
best to purge the bags with sample gas three times before a sample is collected.
•	SAP Section 2.2.1, p 1 of 11, pp 2; I recommend using a peristaltic pump if the
sample tubing is to be purged. The PRPs did not specify the type of pump to be
used.
•	SAP Section 2.4.3, p 6 of 11, pp 2; As mentioned above, It would be better if the
sample gas were used to purge the Tedlar bags prior to sample collection, rather
than air.
•	SAP Section 2.7, p 7 of 11, pp 1; Please have the PRPs specify what procedures
are their "Internal QC checks".
•	SAP Table B-1; Please correct the MDEQ address; it should be: Mark Henry,
Constitution Hall, 3rt Floor South, PO Box 30426, 525 West Allegan, Lansing, Ml
48909. Also, please have the PRPs include a phone and fax number for Bill
Gierke.
I hope that you find these comments helpful in the evaluation of this ELGE work plan.
If you have questions about any of these points, please feel free to contact me at your
convenience.
Sincerely,
M
Superfund Section
Remediation and Redevelopment Division
517-335-3390

-------
P. 02
Goider Associates Inc.
i95: ~>c Cj'rcerr 7cca. iure 301
Chdfiy tU. N'J G8C24
T9l0C.-!Ore tS5o) C! S-R166
Fox (3ccj 416-1874
October 11. 2002
Pharmacia Corporation
Mail Stop 004--SS-009
7000 Portage Read
Kalamazoo, MI 4900!
Attn: William G. Gierke
RE: REVISED PILOT TEST PERFORMANCE OBJECTIVES
WEST KL LANDFILL. KALAMAZOO, MI
Dear Mr. Gierke.
As requested, this letter is submitted pursuant to discussions at the September 6, 2002 meeting
bep.veen representatives of MDEQ, the KL Avenue Landfill Group and Goider Associates (v.a
telephone). This letter describes performance objectives tor conducting pilot tests to evaluate
alternate technologies to the ROD Remedy currently contemplated at the Wesc KL Aver.ue
Landfill (Site). Alternate technologies considered involve groundwater source treatment through
enhanced biodegradation (e.g.. sulfate-addition) ar.c enhanced landfill gas extraction (ELGE) :o
actively remove and treat remaining contaminant sources.
This letter follows our letter dated September 18, 2002 and addresses MDEQ comments received
on October 7, 2002.
REMEDIAL OBJECTIVES
The remedy performance objective is to achieve equivalent performance to the remedy selected in
the Record of Decision (ROD) with respect to overall protection of human health and the
environment. Specific performance objectives for the remedy include the attainment of Michigan
Part 201 groundwater cleanup standards. MDEQ has identified the western (downgradier.t) edg:
of the Balkema Property as the point of compliance for groundwater standards.
The ROD does not specify a timeframe for achievement of remedy performance objectives. Site-
specific calculations based on vadose zone retention times (FFS; Goider 2001) indicate that
installation of an impermeable cap would not begin to significantly improve groundwater quality
for at least six years, with 20 or more years possible. Site-specific calculations (FFS; Goider.
2001) also indicate that it would take 10 years or more for a groundwater pump/treat system -
installed at the downgradient margin of the landfill - to achieve cleanup objectives at the
downgradient margin of the Balkema property. The timeframe required to meet performance
standards was further discussed at the September 16, 2002 meeting with EPA and MDEQ. EPA
indicated they would accept performance equivalent to the cap, subsequently, EPA indicated that
4 to 6 years would be an acceptable timeframe to meet remedial objectives based on pilot study
performance. MDEQ indicated on September 16, 2002 that they would prefer a timeframe on the
order of 4 to 5 years to achieve performance standards.
The KL Group therefore proposes that the pilot rests for alternate technologies to the ROD
demonstrate, with a reasonable level of confidence, a rate of performance that will achieve
Goider
Vc/Associates
Project No.: 943-8200
Arp^v-	a• m >a- J. r«t>xc •-pifrrv,	r \ 'Virry
-------
Pharmacia Corporation
William G Gierke
-1 .
October ! I, 2002
	O-O-^oo
groundwater cleanup standards within 5 years at the downgradient edge of the Balkema property.
Per discussions on September 16. 2002 with \DDEQ and EPA, some flexibility in the timeframe
would be appropnare si the Pilot Tes; data demonstrates to the L'SEPA and MDEQ that a short
additional time-period is warranted to achieve remedial goals.
SULFATE ADDITION (ENHANCED BIODEGRADaTION) PILOT TEST
fn following USEPa-ORD's technical recommendation, a pilot test is planned to evaluate ±e
effectiveness of adding sulfate as an electron acceptor to groundwater along the downgradient
margin of the sue in order to accelerate aquifer restoration through the biodegradation of the
remaining organic sources of concern (benzene and tetrahydrafuran). The pilot test proposal
envisions limited groundwater extraction at the downgradient end of a 200-foot wide mixing
zone, and injection of sulfate-enriched groundwater at the upgradient end of the mixing zone.
Two extraction wells and two injection wells approximately 200 feet apart are anticipated with a
network of monitoring wells located within the mixing zone. Based on modeling, the pilot test
will begin with a 12 gallon per minute pumping rate for each well, and a 200 mg/1 sulfate feed
"rate. The sulfate feed rate will be confirmed prior to implementation of the pilot test based on
analytical testing for biological sulfate demand of groundwater and aquifer material samples.
Other feed rates and/or amendments may also be used during the pilot test, based on the early
monitoring results, to further enhance biodegradation processes. VIDEQ has also suggested use
of bioaugmentation to accelerate the process and the KL Group plans to investigate this
possibility further
The overall objective of the pilot test is ;o stimulate the existing microbial population tha: is
capable of degrading benzene and THF, thereby accelerating the degradation rates of benzene and
THF, and to provide site-specific design data for a full-scale system. The overall concept is :o
produce a treatment zone of accelerated degradation of benzene and THF (i.e. reduced half-lives)
so that the concentrations will achieve standards at the point of compliance. Currently, the half-
iife for benzene in anaerobic groundwater downgradient of the site is over 500 davs as
determined by Ravi et al (1998). Published data suggests that this could be reduced by more than
an order of magnitude within the suifate-addition treatment zone, which will also ultimately
accelerate shrinkage of the downgradient plume, causing it to collapse on itself as previously seen
with other compounds.
Data collected from the pilot test will enable half-lives within the treatment zone to be calculated.
As the test proceeds and microbial populations increase, half-lives are expected to decline,
initially close to the injection wells and then over an expanding area downgradient. Eventually a
new steady-state half-life will be established throughout the treatment zone, although it is
currently unknown how quickly the half-lives will decline and how quickJy the accelerated
treatment zone will expand downgradient; establishing these timings is an imponant result of the
pilot test.
As described in the Draft Sulfate Addition Pilot Test Work Plan and subsequent amendments
(July. 2001, December 2001, June 2002), performance will be assessed through monitoring (via a
network of wells) the groundwater chemistry and geochemical indicators throughout the
treatment zone within the water table aquifer. A perched zone was identified in four of the ten
profile borings recently completed along the downgradient margin of the landfill. If this zone is
encountered at the pilot test location, it will be monitored to provide information for design of a
full-scale system.
Golder Associates
-------
Pharmacia Corporation
William G. Gierke
-3-
October 11, 2002
943-8200
Dispersion of a stable tracer (bromide) will be monitored ir. order to facilitate the assessment of
contaminant concentrations and degradation rates within '.he treatment zone. The reduction in
contaminant levels over time will be analyzed for the various monitoring points to estimate the
half-life of contaminants in the treatment zone. It ;s anticipated that, after a period of
acclimation, half-lives will decline over time and the size of the effective treatment zone will also
expand over time. The performance goal will be to demonstrate half-lives tha: will enable current
groundwater source concentrations to be reduced to the cleanup standards at the point of
compliance downgradient of the treatment zone. For example, a half-life of 50 days wouid
enable three orders of magnitude concentration reduction over the 432 ft width of the Baikema
property. During the period of time available for the pilot test (through April 2004), clearly
established trends will be achieved in order to determine degradation rates (half-lives). Decay
rates will be established using statistical methods that will be submitted to and approved by the
Agencies. Projected cleanup times will then be determined from decay rates to assess if
performance is acceptable - in comparison to the ROD remedy.
The attached Figure provides concentration-distance trends for benzene withjr. the Pilot test zone
and downgradient to the proposed compliance point at the western boundary of the Baikema
property. Initial concentrations are based upon average conditions in the "core" of the plume and
assume a constant source term (i.e. it is assumed that there is no source depletion and additional
source controls are not in place). Concentrations at various times after initiation of the Pilot test
are indicated for several different haif-iives (decay rates). As noted above, it is expected tha:
half-lives will decline over a period of months as microbial populations become established
throughout the pilot test zone. The effect of treatment will also become evident downgradient of
the treatment zone over time. Based on groundwater flow velocities, the effect of treatment is
likely to become evident at the downgradient boundary of the Baikema property after about 2
years and Part 201 standards would be reached in approximately 5 years. The predicted
concentrations should be regarded as conceptual in nature and are derived from one-dirr.snsionai
solute transport modeling with advection, dispersion and reaction (degradation) terms. While the
•concentration curves represent reasonable expectations based on the results of published studies
(Lovely, et al., 2000 and Ravi, et al. 1998), it is important to recognize that the goal of the Pilot
Test is to establish this data on a site-specific basis.
enhanced landfill gas extraction
In following the MDEQ Director's suggestion to "think outside the box", the concept of an
Enhanced Landfill Gas Extraction System (ELGE) was presented in a letter dated July 1, 2002
from Goldcr Associates and discussed in the July 11, 2002 meeting with MDEQ, when the State
recommended we strongly pursue this alternative technology.
An ELGE system is similar to a SVE system for treatment of VOCs in contaminated soil, i.e.,
EPA "Presumptive Remedy" for treating VOCs in soils. An ELGE system extracts VOCs and
methane from the waste, and the combination of reduced vapor pressure and increased advection
by the system blower induces further volatilization of VOCs from the waste. Therefore, an
ELGE system is an active source removal and treatment remedy that increases mass removal rates
of VOCs over other containment or control technologies, thus reducing cleanup times. The thick
vadose zone beneath the waste at the K.L Landfill also provides additional anaerobic treatment.
Conceptual schematics of an ELGE pilot test were presented in the July 1, 2002 Golder letter and
consisted of an extraction well and a series of monitoring probes at various depths and radial
locations. The purpose of an ELGE Pilot Test is twofold First, to demonstrate the feasibility of
enhanced gas extraction for VOC source (mass) removal at the Site. Specifically, a pilot test will
Golder Associates
-------
Pharmacia Corporation
William G. Gierke
October i 1, 2002
943-3200
demonstrate whether ELGE is an effective method to induce volatilization and remove VOCs
from the landfill waste. Simultaneously, the pilot test will provide data on flow rates* radii of
influence and mass removal rates to enable design of the full-scale extraction and treatment
system. The primary indicator for the success of an ELGE pilot test is the extent to which VOCs
can be removed
It ;s anticipated that ELGE pilot test field data will be collected to support developmen: of the
full-scale ELGE system design, including estimates of the following:
•	Vapor phase chemical composition;
•	A;r permeability of the unsaturated subsurface within the landfill;
•	VOC mass removal rates;
•	Condensate generation rates; and,
•	Effective radius of influence of gas extraction wells based on vacuum response and pore
gas velocity considerations.
Design details of the ELGE pilot test have been provided in a Work Plan for Agency review and
comment.
Sampling for VOCs, oxygen, carbon dioxide and methane, and monitoring of pressure and
temperature will be conducted prior to starting the system blower to establish baseline conditions
that will assist in evaluating the performance of the pilot test. Field monitoring data obtained
during the pilot test will include measurements of pressures within the waste in the area
surrounding the gas extraction well during the landfill gas extraction process and recovery period.
VOC and respirable gas (i.e., oxygen, carbon dioxide, methane) concentrations in the collected
gas and at various monitoring points, analysis of collected condensate for VOC content and
measurement of gas flow rates generated as a result of various applied vacuums during the test.
Both step tests and constant rate tests will be undertaken. Any initial spikes in VOC or methane
concentrations, plus other trends in composition during the period of gas extraction, will be
evaluated in order to establish appropriate baseline vapor-phase compositions that will be used as
a basis for the full-scale treatment system design.
One of the most important design parameters that would be determined from a pilot test is the
radius of influence of an extraction well and any associated amsotropy. During the pilot test,
vacuum/pressure data from the monitoring points will be used as the primary means to determine
the radius of influence and calculations will be made using the methodologies described by the
U S. Army Corps of Engineers (USACOE, 1995). Also, oxygen, methane, and carbon dioxide
data from the extracted gas would also be monitored throughout the pilot test in order to evaluate
the effects of the vacuum extraction on the infiltration of ambient air through the landfill cover
Based on gas data collected in 1996 at ICL Landfill, preliminary scoping calculations indicate :hat
more than 1000 pounds per year of benzene (possibly up to 5000 Ibs/yr) could be removed by
ELGE. This rate of removal would be equivalent to pumping and treating over 2000 gpm of
groundwater. In addition, an ELGE system may also be able :o remove hundreds of pounds of
THF per year. Although THF is highly soluble, it also has a high vapor pressure and can <
therefore be removed in vapor phase. A key advantage of an ELGE system over a cap is that it
removes and treats the source material. As discussed at the July 11, 2002 meeting with MDEQ, a
key concern related to the operation of an ELGE system is the potential for excessive drying of
the waste leading to reduced mass removal efficiency by the ELGE system. As with an
impermeable cap. further drying of the waste would inhibit the natural biodegradation thar has
Golder Associates
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J

r. UK
Pharmacia Corporation
William G Gierke
- 3 -
October 11.2002
943-3200
been shown to be effectively treating contaminant sources under existing cover conditions
(Focused feasibility Study, Golder 2001).
Estimates of the mass flux of contaminants from the landfill source to the groundwater are or. the
order of 1200 Ibs/yr, as provided in the Feasibility Study (Golder, 2001). Mass removal rates via
ELGE, that are commensurate with the estimated flux to groundwater, would constitute
acceptable performance.
SUMMARY
The KL Avenue Landfill Group has proposed to conduct pilot tests to evaluate alternate
technologies to the ROD remedy involving m-situ groundwater source treatment through
enhanced biodegradation (e.g. sulfate addition) and enhanced landfill gas extraction to remove
and treat remaining contaminant sources. The pilot tests will be used to evaluate the potential
capability of a full scale system to achieve the remedial objectives described herein and provide
data for the design of full scale systems. One or both of the technologies may be implemented as
part of a site-wide alternative remedy based on the results of the pilot tests and Agency
concurrence. It is anticipated that the ELGE system wtl! provide enhanced long tern
performance over a cap as this technology provides active source removal and treatment. The
sulfate addition system would provide treatment of those contaminants that have already ienched
from the landfill and are in groundwater.
As stated in the Focused Feasibility Study (Golder 2001), should sulfate addition fail to achieve,
or not be predicted to achieve, remedial objectives in a reasonable time frame, contingency
remedies that include other groundwater source control technologies (e.g., ozone addition as
suggested by MDEQ) may be used, if feasible, in conjunction with monitored natural attenuation.
Other contingent technologies are also described in the FFS.
SCHEDULE
Pursuant to EPA's letter dated April 17, 2002, the pre-RD studies for groundwater and any
evaluation of alternate technologies shall be completed by April 2004. The Agencies have
requested that sufficient information be made available from the Pilot Tests at the end of this
period to facilitate remedy decisions.
A work plan and Agency approval for conducting an ELGE pilot test will be required. A Work
Plan for conducting an ELGE Pilot test will be submitted during the first half of October 2002. It
is anticipated that the pilot test could be initiated approximately 60 days following Agency
concurrence with the Work Plan. The fieldwork to construct and conduct the pilot test is
estimated to take approximately one month. Design and construction of a full-scale ELGE
system would also include Agency review and approval, to help ensure efficient operation and
performance.
It is anticipated that the pilot test for sulfate addition could be initiated approximately 60 days
following Agency concurrence with the Work Plan and obtaining access to the required
properties. Field work to construct the system is anticipated to take approximately 60 days
depending on weather conditions. It is therefore anticipated that a minimum of 15 months
operation of the sulfate addition pilot test can be accommodated.
Golder Associates
-------
Pharmacia Corporation
Willtam G. Gierke
-6-
October 11,2002
	943-8200
We trust that this letter adequately summarizes our discussions and can be used as a basis for
moving forward with the pilot test work.
Very truly yours.
COLDER ASSOCIATES INC.
Robert J. Hies, P.G.
Associate
;1 /
P. Stephen Finn, C.Eng.
Principal
RJIf'PSF: Irl
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Goldor Awoclotes
-------
October 2002
943-8200
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Page 1 of 1
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Pharmacia
Pharmacia Corporation
7000 Pottage itaad
Mamccae, Mahmn 4900!
Ui6>6MM00
September 18, 2002	foxmsn w?
r	wmtpbarmava.com
Mr. Mark Henry
Remedial Project Manager
MDEQ-ERD Superfund Division
525 W. Allegan. 4sh Floor, Constitution Hall
Lansing, Michigan 48913
RE: PERFORMANCE OBJECTIVES FOR PILOT STUDIES
TO EVALUATE ALTERNATE REMEDIAL TECHNOLOGIES
WEST KL AVENUE LANDFILL SITE
Dear Mr. Henry:
In response to your request during our meeting on September 6. 2002, please I'ind attached a
letter prepared by Golder Associates Inc. regarding proposed performance objecmes for Pilot
Studies to evaluate alternate remedial technologies to the ROD remed\ for the West KL
Landfill Site, Wc hope the attached letter provides all the information you requested and meets
your with management's approval.
We would be happy to discuss any comments on the letter with MDEQ and EPA ,->o that
performance goals can be agreed-upon pnorto implementation of Pilot Studies.
Please don't hesitate to call if you have any questions or anv comments regarding the attached
letter.
Sincerely.,
William G. Gierke. P.G,
Pharmacia Corporation
KLA Group - Technical Member
w/Attachments
cc: Tim Prendiville. USEPA-RPM
Kevin M. Walsh
Golder Associates Inc.
-------
1951 Old Cumber? Read. Suite 301
Cherry Hill. NJ 08034
Teieohc.°,e (856) 616-31 56
Fox (856) 616-1874
Golder Associates Inc.
}' Golder
'Associates
September 18. 2002
Project No.: 943-8200
Pharmacia Corporation
Mail Stop 0047-88-009
"000 Portage Road
Kalamazoo. MI 49001
Attn: William G. Gierke
RE: PILOT TEST PERFORMANCE OBJECTIVES
WEST KL LANDFILL. KALAMAZOO, MI
Dear Mr. Gierke:
As requested, this letter is submitted pursuant to discussions at the September 6. 2002 meeting
between representatives of MDEQ. the KL Avenue Landfill Group and Golder Associates (via
telephone). This letter describes performance objectives for conducting pilot tests to evaluate
alternate technologies to the ROD Remedy currently contemplated at the West KL Avenue
Landfill (Site). Alternate technologies considered involve groundwater source treatment through
enhanced biodegradation (e.g.. sulfate-addition) and enhanced landfill gas extraction (ELGEi to
activelv renune and treat remaining contaminant sources.
REMEDIAL OB.JEC TIYES
The remedy performance objective is to achieve equivalent performance to the remedy selected in
the Record of Decision (ROD) with respect to overall protection of human health and the
environment. Specific performance objectives for the remedy include the attainment of Michigan
Part 201 'groundwater cleanup standards. MDEQ has identified the western (downgradient) edge
of the Balkema Property as the point of compliance for groundwater standards.
The ROD does not specify a timeframe for achievement of remedy performance objectives. Site-
specific calculations based on vadose zone retention times (FFS; Golder 2001) indicate that
installation of an impermeable cap would not begin to significantly improve groundwater quality
for at least six years, with 20 or more years possible. Sue-specific calculations (FES. Golder.
2001) also indicate that it would take 10 years or more for a groundwater pump/treat system -
installed at the downgradient margin of the landfill - to achieve cleanup objectives at the
downgradient margin of the Balkema property. The timeframe required to meet performance
standards was further discussed at the September 16, 2002 meeting with EPA and MDEQ. EP \
indicated they would accept performance equivalent to the cap; subsequently, EPA indicated that
4 to 6 years would be an acceptable timeframe to meet remedial objectives based on pilot study
performance. MDEQ indicated on September 16, 2002 that they would prefer a timeframe on the
order of 4 to 5 years to achieve performance standards.
The KL Group therefore proposes that the pilot tests for alternate technologies to the ROD
demonstrate, with a reasonable level of confidence, a rate of performance that will achieve
groundwater cleanup standards within 5 years at the downgradient edge of the Balkema property.
Per discussions on September 16, 2002 with MDEQ and EPA, some flexibility in the timeframe
OccICES ACROSS ASIA. AUSTRALASIA. EUROPE. NORTH AMERICA. SOUTH AMERICA
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Pharmacia Corporation
William G. Gierke
September 18, 2002
	943-8200
enable three orders of magnitude concentration reduction over the 435 ft width of the Balkema
property. During the period of time available for the pilot test (through April 2004). clearly
established trends will be achieved in order to determine degradation rates (half-lues). Decay
rates will be established using statistical methods that will be submitted to and approved by the
Agencies. Projected cleanup times will then be determined from decay rates to assess if
performance is acceptable - in comparison to the ROD remedy.
ENHANCED LANDFILL GAS EXTRACTION
In following the MDEQ Director's suggestion to "think outside the box", the concept of an
Enhanced Landfill Gas Extraction System (ELGE) was presented in a letter dated July 1. 2002
from Golder Associates and discussed in the July 11. 2002 meeting with MDEQ. when the State
recommended we strongly pursue this alternative technology.
An ELGE system is similar to a SVE system for treatment of V'OCs in contaminated soil. i.e..
EPA "Presumptive Remedy" for treating VOCs in soils. An ELGE system extracts VOCs and
methane from the waste, and the combination of reduced vapor pressure and increased advection
by the system blower induces further volatilization of VOCs from the waste. Therefore, an
ELGE system is an active source removal and treatment remedy that increases mass removal rates
of VOCs over other containment or control technologies, thus reducing cleanup times. The thick
vadose zone beneath the waste at the KL Landfill also provides additional anaerobic treatment.
Conceptual schematics of an ELGE piiot test were presented m the July 1. 2002 Golder letter and
consisted of an extraction well and a senes of monitoring probes at various depths and radial
locations. The purpose of an ELGE Pilot Test is twofold. First, to demonstrate the feasibility of
enhanced gas extraction for VOC source (mass) removal at the Site. Specifically, a pilot test will
demonstrate whether ELGE is an effective method to induce volatilization and remove VOCs
from the landfill waste. Simultaneously, the pilot test will provide data on flow rates, radii of
influence and mass removal rates to enable design of the full scale extraction and treatment
system. The primary indicator for the success of an ELGE pilot test is the extent to which YOC's
can be removed.
It is anticipated that ELGE pilot test field data will be collected to support development of the
full-scale ELGE system design, including estimates of the following:
•	Vapor phase chemical composition;
•	Air permeability of the unsaturated subsurface within the landfill;
•	VOC mass removal rates;
•	Condensate generation rates; and,
•	Effective radius of influence of gas extraction wells based on vacuum response and pore
gas velocity considerations.
Field monitoring data obtained during the pilot test will include measurements of pressures within
the waste in the area surrounding the gas extraction well during the landfill gas extraction process
and recovery period. VOC and respirable gas (i.e.. oxygen, carbon dioxide, methane)
concentrations in the collected gas and at various monitoring points, analysis of collected
condensate for VOC content and measurement of gas flow rates generated as a result of various
applied vacuums during the test. Both step tests and constant rate tests will be undertaken. Any
initial spikes in VOC or methane concentrations, plus other trends in composition during the
period of gas extraction, will be evaluated in order to establish appropriate baseline vapor-phase
compositions that will be used as a basts for the full-scale treatment system design.
Golder Associates
-------
Pharmacia Corporation September 18,2002
William G. Gierke	- 5 -	943-8200
We trust that this letter adequately summarizes our discussions and can be used as a basis for
moving forward with the pilot test work.
Very truly yours.
GOl.DER ASSOCIATES INC.
obert J. Illes, P.G.
Associate
f) r
Kl w_
P. Stephen Finn. C.Eng.
Principal
RJL PSF:lrl
) I frPHRFSTDS DOC
Golder Associates
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UJ/11/04 13:52 F.-VI 18167522000	*\RNER	r*nn„
	l£] 002
JOHN ENGLER
OCV1HNO*
Statu or Michigan
DEPARTMENT OF ENVIRONMENTAL QUALITY
Lansing
HUSSEU. J. HARDING
Ort*CTO*
August 9, 2002
Mr. William Gierke
Pharmacia
7000 Portage Road
Kalamazoo, Michigan 49001-0189
Dear Mr. Gierke:
On July 11, 2002, the Department of Environmental Quality (DEO) met with
representatives of the Potentially Responsible Party (PRP) Group for the West KL
Avenue Landfill Superfund site to discuss performance objectives for technologies that
might be used to show equivalent performance to the Record of Decision (ROD)
specified impermeable cap and the pumping and treatment of groundwater. This
meeting was a logical follow-up to the May 22, 2002 meeting that the PRPs and
Environmental Response Division had with DEQ Director Russell J. Harding where we
were encouraged by Director Harding to "think outside the box" when deciding which
technology to employ at the site to mitigate the groundwater contamination emanating
from the landfill.
During the July meeting with the PRP Group, Michigan Part 201 criteria (Part 201,
Environmental Remediation, of the Natural Resources and Environmental Protection
Act, 1994 PA 451, as amended) were recognized as the cleanup standards for the
groundwater. Currently the landfill leachate contains Benzene, Tetrahydrafuran (THF),
methane (dissolved and vapor phases), ammonia, total dissolves solids, and dissolved
iron (Fe-H-) at levels greater than the Part 201 criteria. A properly designed landfill cap
such as the one specified in the ROD would reduce the leachate generation of the
landfill, thus greatly reducing the flux of dissolved volatile organic chemicals (VOCs),
and other dissolved organic and inorganic chemicals that have contributed to the
aforementioned Part 201 exceedances. If the ROD specified pump and treating of
groundwater were employed at the edge of the landfill, the leachate that was generated
by the landfill would be captured before it further affected the groundwater. The ROD
specified landfill treatment system would isolate the landfill from the groundwater
system whose leachate assimilative capacity has been exceeded.
The volume of groundwater that has been affected by the continuing releases from the
landfill is enormous. This contamination has affected groundwater quality as far
downgradlent as Dustin Lake, nearly one mile from the source. It remains to be seen if
CONSTITUTION HALL • 623 WEST ALLCOaN STREET • PO. BOX 30«2« • LANSING. MICHIGAN 40909-7900
w»«r.mltn
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03/11/04 15:52 FAX 16187522000
0000
Mr. William Gierke	-2-	August 9,2002
natural attenuation mechanisms are effective In restoring the aquifer to a usable
condition. If this is to happen in a reasonable timeframe however, it is clear that the
continued flux of contamination must be cut off at the source.
Our discussions on July 11, 2002, centered around the necessary performance
objectives for the pilot test and for the final remedy. Normally the objective of landfill
control technologies would be to prevent contamination escape from the property. The
DEQ recognizes that the distribution of the solid waste, and the nature of the PRP
Group's proposed in-situ remedial technology may justify the utilization of the
neighboring property (Bulkema property) Immediately west of, and along the entire
landfill boundary as an in-situ biologic "reaction zone". The DEQ could consider an
alternate point of compliance for the landfill contaminants to be at the western edge of
the Bulkema property. The width of the additional property would allow migrating
groundwater an additional year of residence time downgradient of the PRP Group's
proposed in-situ treatment system before it exits the biologic reaction zone. At this
point, the western edge of the Bulkema property, the concentrations of landfill related
chemicals in the groundwater and soil gas must not exceed Part 201 generic residential
cleanup criteria.
During the July 11, 2002, meeting the PRP Group proposed using an in-situ
groundwater treatment technology such as enhanced bioremediation using sulfate
reducing microorganisms (sulfate-injection) which would be pilot tested within the
reaction zone. In addition, the PRP Group presented information on an enhanced
landfill gas extraction (ELGE) system that would be used to extract vapor phase VOCs
from the landfill contents and the contaminated vadose zone and capillary fringe
beneath them. The PRPs also propose to pilot test this technology in tandem with the
sulfate-injection pilot testing. The ELGE technology seems to hold some promise in
addressing some of the landfill problems and if successful may provide an adequate
basis to justify equivalency with the landfill cap requirements. The DEQ pointed out that
the ELGE system may also have the ability to effect remediation of the capillary fringe
but pointed out that the system, if used too aggressively, may desiccate the waste to the
point of reduced biologic activity or draw undesirable amounts of oxygen into the landfill
system. The DEQ would like to encourage the PRP Group to test these innovative
technologies with the hope that they can achieve the objective of controlling the landfill
as a source of contaminant release.
In Summary, the remedial objectives of the remedy should be to achieve control of the
groundwater plume exceeding generic residential cleanup criteria at the landfill property
boundary, or alternately, at the Bulkema property boundary in a timeframe consistent
with the ROD remedy, i.e., within one and one half years. If in-situ treatment is used in
lieu of the ROD specified pump and treat, then "control" of the plume should be defined
as achieving the cleanup standards at the downgradient edge of the reaction zone
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WARNER
a
Mr. William Gierke
August 9,2002
(I.e., Bulkema property). If the ELGE is used to control the further release of
contaminants from the landfill in lieu of the ROD specified cap, achievement of such
control would be evidenced by meeting Part 201 criteria at the landfill boundary within
two years.
We look forward to seeing the results of your technology pilot testing and look forward
to working with you to clean up this site. We hope that you understand the expectations
of the DEQ with regards to the criteria to be achieved within the defined reaction zone
and the timeframe that would be acceptable. Please contact me at your convenience if
you have questions about these points or would like to further discuss the details of tills
remedial strategy.
cc: Mr. Tim Prendlvilie, U.S. EPA
Mr. Russell J. Harding, DEQ
Mr. Arthur R. Nash Jr., DEQ
Mr. Andrew Hogarth, DEQ
Mr. David Kline, DEQ
Mr. Mark Henry, DEQ
KL Landfill Site Files
Sincerely,
Claudia Kerbawy, Chief
Superfund Section
Environmental Response Division
517 335 3397
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