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FEASIBILITY STUDY

PRELIMINARY SCREENING

SPIEGELBERG AND RASMUSSEN DUMP SITES

Prepared for the

Michigan Department of Natural ResourcesState of Michigan Contract No. 1611

NUS Project Number 8330

June, 1989

NUSCORPORATION

*

SPEIGELBERG AND RASMUSSEN DUMP SITES

FEASIBILITY STUDY

PRELIMINARY SCREENING

Prepared For:

MICHIGAN DEPARTMENT OF NATURAL RESOURCES

CONTRACT NO. 1611

Prepared By:

George D. GardnerNUS CORPORATION

Bryan j. HughesWarzyn Engineers, Inc

MAY 1989

TABLE OF CONTENTS

SECTION PAGE

EXECUTIVE SUMMARY ES- 1

1.0 INTRODUCTION!

1.1 SITE DESCRIPTIONS 3

1.1.1 Spiegelberg Site Description 3

1.1.2 Rasmussen Dump Site Description 3

1.2 REFERENCE DOCUMENTS 5

1.3 IDENTIFICATION OF AREAS OF CONCERN, CHEMICALS OFCONCERN, AND ROUTES OF EXPOSURE 5

1.4 PHYSICAL DESCRIPTIONS OF THE AREAS OF CONCERN 15

1.4.1 Rasmussen Dump Site - Probable DrumStorage/Leakage/Disposal Area 15

1.4.2 Rasmussen Dump Site - Industrial Waste Area 16

1.4.3 Rasmussen Dump Site - Northeast Buried DrumArea 17

1.4.4 Rasmussen Dump Site - Top of the MunicipalLandfill 18

1.4.5 Spiegelberg and Rasmussen Dump Sites -Groundwater Contaminant Plumes 18

2.0 REMEDIAL ACTION OBJECTIVES 20

2.1 RASMUSSEN SITE REMEDIAL OBJECTIVES 21

2.1.1 Northeast Buried Drum Area 21

2.1.2 Top of the Municipal Landfill 21

2.1.3 Industrial Waste Area 24

2.1.4 Probable Drum Storage/Leakage/DisposalArea 24

2.1.5 Groundwater Plume (Rasmussen) 24

TABLE OF CONTENTS (continued)

SECTION PAGE

2.2 SPISGELBERG SITE REMEDIAL OBJECTIVES 25

2.2.1 Groundwater Plume (Spiegelberg) 25

3.0 APPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTS (ARARs) . 27

4.0 DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES 35

4.1 GENERAL RESPONSE ACTIONS 35

4.2 REMEDIAL TECHNOLOGIES AND PROCESS OPTIONS 36

4.2.1 No Action 37

4.2.2 Institutional Actions 37

Fencing- 37

Monitoring and Analysis- 37

Deed Restrictions (Well Construction)- 65

4.2.3 Alternative Drinking Water Supply 65

Municipal Water System- 66

Bottled Water, Above-ground Tanks,Individual Treatment Systems- 66

Deeper or Up-gradient Water SupplyWells- 67

4.2.4 Containment 67

Surface Capping- 67

Clay andMulti-media Caps 67

Vertical Barriers 69

Block Displacement Grouting 70

11


SECTION PAGE

4.2.5 Removal 71

Excavation 71

Groundwater Pumping 72

4.2.6 Onsite Treatment 73

Thermal Treatment 73

Incineration 73

Infrared Incineration 74

Immobilization 74

Solidification 74

Vitrification 75

Physical Treatment 76

Soil Flushing 76

Soil Washing 77

Soil Aeration 77

Air Stripping (Groundwater) 78

Chemical Treatment 79

Dechlorination 79

Activated Carbon Adsorption 80

Biological Treatment 80

Aerobic Biodegradation 81

Anaerobic Biodegradation 82

In-situ Treatment 83

Vacuum Extraction 83

In-situ Biodegradation 83

iii


SECTION PAGE

4.2.7 Offsite Treatment 84

Thermal Treatment 84

Incineration 844.2.8 Onsite Disposal 85

4.2.9 Offsite Disposal 86

Removal to a POTW 87

Removal to a Treatment Facility 874.3 ASSEMBLE OF ALTERNATIVES 884.4 ————~PROCESS-OPTION (ACTION) SPECIFIC ARARs

APPENDIX A - VOLUME CALCULATIONS FOR AREAS OF CONCERN

93

IV

LIST OF TABLES

TABLE 1-1 p. 8

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS, AND CONTRIBUTIONTO RISK NORTHEAST BURIED DRUM AREA, RASMUSSEN DUMP SITE

TABLE 1-2 p. 9

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS, AND CONTRIBUTIONTO RISK TOP OF MUNICIPAL LANDFILL, RASMUSSEN DUMP SITE

TABLE 1-3 p. 10

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS, AND CONTRIBUTIONTO RISK INDUSTRIAL WASTE AREA, RASMUSSEN DUMP SITE

TABLE 1-4 p. 11

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS, AND CONTRIBUTIONTO RISK PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREA, RASMUSSEN DUMPSITE

TABLE 1-5 p. 13

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISK, RASMUSSEN GROUNDWATER PLUME

TABLE 1-6 p. 14

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISK, SPIEGELBERG GROUNDWATER PLUME

TABLE 2-1 p. 22

TARGET CONCENTRATIONS FOR SOIL REMEDIATION, RASMUSSEN DUMP SITEAREAS OF CONCERN

TABLE 2-2 p. 23

TARGET CONCENTRATIONS FOR GROUNDWATER CLEANUP, SPIEGELBERG ANDRASMUSSEN DUMP SITES

LIST OF TABLES (CONTINUED)

TABLE 2-3 p. 26

SUMMARY OP COMPOUNDS REQUIRING CONSIDERATION FOR NPDESAND CONCENTRATIONS TO COMPLY WITH MICHIGAN RULE 57 FOR SURFACEWATER DISCHARGE, SPIEGELBERG AND RASMUSSEN DUMP SITES

TABLE 3-1 p. 29

CHEMICAL SPECIFIC ARARs, SPIEGELBERG AND RASMUSSEN DUMP SITES

TABLE 3-2 p. 31

LOCATION SPECIFIC ARARs

TABLE 4-1 p. 38

SUMMARY OF REMEDIAL ACTION OBJECTIVES AND ASSOCIATED REMEDIALTECHNOLOGIES AND PROCESS OPTIONS BY ENVIRONMENTAL MEDIA

TABLE 4-2 p. 50

SUMMARY OF EFFECTIVENESS, IMPLEMENTABILITY, AND GENERAL COST FORREMEDIAL TECHNOLOGIES AND ASSOCIATED PROCESS OPTIONS

TABLE 4-3 p. 89

PROCESS OPTIONS THAT PASSED SCREENING FOR ASSEMBLY INTO REMEDIALACTION ALTERNATIVES (SOIL AND WASTE AREAS OF CONCERN)

TABLE 4-4 p. 90

PROCESS OPTIONS THAT PASSED SCREENING FOR ASSEMBLY INTO REMEDIALACTION ALTERNATIVES (GROUNDWATER PLUME AREAS OF CONCERN)

TABLE 4-5 p. 91

ASSEMBLY OF REMEDIAL ACTION ALTERNATIVES {SOIL AND WASTE AREAS OFCONCERN)

VI

LIST OF TABLES (CONTINUED)

TABLE 4-6 p. 92

ASSEMBLY OF REMEDIAL ACTION ALTERNATIVES (GROUNDWATER PLUME AREASOF CONCERN)

TABLE 4-7 - p. 94

PROCESS-OPTION (ACTION) SPECIFIC ARARs

vn

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EXECUTIVE SUMMARY

1.0 INTRODUCTION

The preliminary screening of the remedial action alternatives isa portion of the feasibility study that describes the processfor the development of remedial action alternatives for theSpiegelberg and Rasmussen Dump sites located in LivingstonCounty, Michigan.

Each of these sites are separate federal National Priority List(NPL) sites as assessed under the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA) and theSuperfund Amendments and Reauthorization Act (SARA) collectivelyreferred to as Superfund.

Sections 1.0 throygh 4.0 of this report constitute thePreliminary Screening of remedial alternatives. Altenativesthat pass the screening are then evaluated in greater detail insubsequent sections of the report. Sections 1.0 through 4.0include a general description of both the Spiegelberg andRasmussen sites, a summary of the areas of concern, chemicals ofconcern, and routes of exposure as identified in the remedialinvestigation and risk assessment, an identification of theAppropriate, Relevant, and Applicable Requirements (ARARs) forboth the areas of concern and process options, as well as a stepwise description of the process of remedial alternativesdevelopment.

Development of remedial action alternatives consists of thefollowing sequence of steps:

o Identification of remedial action objectives forprotecting human health and the environment.

o Identification of the remedial response actions that wouldmeet the remedial objectives.

o Identification of remedial technologies and processoptions associated with the general response actions.

o The process options considered to be implementable arefurther evaluated with respect to effectiveness,implementability, and cost.

o The process options that pass the effectiveness,implementability, and cost evaluation are assembled intoremedial action alternatives representing a range oftreatment, containment, and disposal combinations.

The detailed evaluation of alternatives is contained in Section5.0 and subsequent sections, and will include a more in-depth

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evaluation of each assembled remedial action alternative withrespect to long and short term effectiveness, implementability,and cost, as well as ARAR considerations. Site widecomprehensive remedies are also compiled to address all thepotential threats posed by the areas of concern; and acomparative analysis is conducted to obtain the preferredalternatives.

1.1 SITE DESCRIPTIONS

1.1.1 SPIEGELBERG SITE DESCRIPTION

The Spiegelberg property consists of approximately 115 acres andis located in an area of moderately rolling topography. An areaon the northern part of the property was used for disposal ofwaste materials as early as 1966. Domestic, industrial/ andseptic wastes have been disposed of at this site at least until1977. Domestic wastes continue to be disposed of onsite, insmall quantities.

Gravel mining at this property predated 1940 and continuesthrough the present time. Mining has caused alteration to theproperty topography since the topographic mapping performed forthe RI in 1984. Peat mining has also occurred on the property.

1.1.2 RASMUSSEN DUMP SITE DESCRIPTION

The Rasmussen property has the same general topographic featuresand geology as the Spiegelberg property except that it is whollylocated on hilly topography. The Rasmussen property consists ofapproximately 33 acres and is bounded on the west and south bythe Spiegelberg property. The property is bounded on the east byprivate property belonging to another Rasmussen relative.Spicer Road forms the northern boundary of the site.

The topography of the site has been altered by extensive miningof sand and gravel. The pre-mining topography at the Rasmussenproperty was characterized by hilly topography, which rose to aridge-like crest in the southern portion of the property. Thesite of environmental contamination extends across the southernhalf of the property.

The Rasmussen Dump Site, which was operated as the "Green OakTownship Dump" for a number of years, accepted both domestic andindustrial wastes in both solid and liquid form. Drummedindustrial wastes were disposed of, and drums were reportedlypiled in several areas of the dump site. In addition, bulkdisposal of industrial liquids was also reported to haveoccurred on site. According to MDNR files, a pond used forliquid industrial waste existed on site during 1967 and 1968.


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The Rasmussen Site began gravel mining operations in the 1970's.The mining eventually undermined substantial portion of the dumparea. Currently, about 10 feet of landfilled materials,primarily domestic wastes, are exposed along the vertical faceof the gravel pit excavation.

The gravel mining on site also caused the movement andredisposal of drums containing wastes. Drums were apparentlymoved to the top of the dump and pushed over the side of thehill. The actions apparently crushed drums and mixed the drumswith soils.

The Green Oak Dump waste materials are referred to in thisdocument as the Municipal Landfill, and the soil materialscovering portions of the landfill are the "Top of the MunicipalLandfill."

In October and November 1984, the USEPA, Emergency ResponseTeam, removed drums that were observable on top of the dump, aswell as drums on the lower slope and base of the dump. Inaddition, approximately 250 cubic yards of soils contaminatedwith PCBs were removed from the top of the dump and from thebase of the hill below the dump.

In June, 1987 approximately 7000 cubic yards of sand and gravelwere removed from the Probable Drum Storage/Leakage/DisposalArea for commercial and residential use off site. Testing ofthe excavation and of the of f site sand and gravel from theexcavation indicated the soils were contaminated. The sand andgravel that was placed off site was replaced on the RasmussenSite from November, 1987 through July, 1988.

The field investigation activities for the RI were initiated inDecember 1985, and were completed in July 1987.

1.2 REFERENCE DOCUMENTS

The following documents form the major significant referencesfor this investigation:

1.Risk Assessment and Phased Feasibility Study of Alternatives,September, 1986 {NUS Corporation).

2.Remedial Design for Source Control, April 1988 (NUSCorporation).

3. Remedial Investigation Report, September, 1988- (NUSCorporation).


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4.Risk Assessment, September, 1988 (NUS Corporation)

1.3 IDENTIFICATION OF AREAS OF CONCERN, CHEMICALS OFCONCERN, AND ROUTES OF EXPOSURE

The * Areas of Concern' are those areas where the RemedialInvestigation identified and confirmed the presence of hazardoussubstances on the Spiegelberg and Rasmussen Dump sites. Theareas where hazardous substances are located are generallyassociated with past practices of disposal, redistribution andburning of hazardous substances at various places on the sites.These areas are designated as 'Areas of Concern' because theypose a risk or potential risk to human health and/or theenvironment, as established in the Risk Assessment. Groundwatercontamination plumes are considered separate areas of concern.

The areas of concern identified by the Remedial Investigationand Risk Assessment include the following:

Rasmussen Site -

o Industrial Waste Area

o Probable Drum Storage/Leakage/Disposal Area

o Northeast Buried Drum Area

o Top of Municipal Landfill

o Groundwater Plume

Spiegelberq Site-

o Paint Sludge Area

o Groundwater Plume

The Spiegelberg Paint Sludge Area is also an area of concern;however, a separate Risk assessment, Phased Feasibility Study,and Remedial Design were completed for this area. The remedialaction will involve excavating the buried wastes andcontaminated soils to the groundwater table, thencharacterizing them as either wet or dry wastes and separatingthem. The wet wastes will then be incinerated and the drywastes disposed of at a RCRA approved landfill. Theimplementation of the action is currently being considered by apotential responsible party.


REVISION. 11/10/89

The 'Chemicals of Concern' are those hazardous substances thatpresent the risk in each area of concern. Hazardous substancesare those chemicals, compounds and other substances defined inSection 101 (14) of Title I of the Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 (CERCLA). Thehazardous substances (contaminants) are identified in theRemedial Investigation and their relative risk is evaluated inthe Risk Assessment.

The "Routes of Exposure' are the ways by which the chemicals ofconcern can reach humans and the environment/ thereby causingthe risks. The typical routes ofexposure for humansspecifically addressed in the Risk Assessment for the areas ofconcern are as follows:

- Dermal contact

- Inhalation of fugitive dust

- Accidental ingestion of soil

- Ingestion of groundwater

- Inhalation of vapors from groundwater in household use

The risk assessment established the risks for both thecarcinogenic risks and noncarcinogenic risks for potentialingestion and inhalation of vapors from groundwater use. Boththe Rasmussen and Spiegelberg groundwater plumes exceeded the 10-6 carcinogenic risk level, and the acceptable noncarcinogenicrisk levels for a hypothetical receptor (groundwater user) atSpicer Road. On this basis both the groundwater plumes aredesignated as areas of concern to be considered for remedialaction.

1.4 PHYSICAL DESCRIPTIONS OP THE AREAS OP CONCERN

This section provides a brief physical description of each areaof concern, including an estimate of the depth of contaminationand the volume of materials that may require excavation forremedial alternatives involving removal. The volumecalculations were performed by Warzyn Engineers, Inc., and areprovided in Appendix A of this document.

1.4.1 RASMUSSEN DUMP SITE - PROBABLE DRUMSTORAGE/LEAKAGE/DISPOSAL AREA

The Probable Drum Storage/Leakage/Disposal area consists oflocally contaminated soils, where contaminat ion occurs inpockets and lenses in both the sa tura ted and unsatura ted zonesas a r e s u l t o f a p p a r e n t s p i l l a g e and l e a k a g e


REVISION -11/10/89

from drums and/or bulk dumping. The soils are natural, in situsand and gravel with lenses of finer grained sandy silts. Thearea was partially excavated by the owner in 1987, exposingcontaminated zones in the soils that appear to be associatedwith the finer grained silty lenses of soil. On the basis ofthis observation, the area probably contains large zones ofuneontaminated to low level soil contamination, with fewer,smaller zones of more highly contaminated soils that serve as acontinuing source of leaching into the groundwater.

The Probable Drum Storage/Leakage/Disposal area is an area ofconcern because of risks posed by dermal contact from PCBs, andthe continued threat to groundwater. Contamination wasconfirmed by sampling groundwater beneath this area usingmonitoring wells. Groundwater data shows that a significantamount of organic compounds have leached from this area. Thecontaminant plume emanating from the Probable DrumStorage/Leakage/Disposal Area is designated the Rasmussen Plume.

1.4.2 RASMUSSEN DUMP SITE - INDUSTRIAL HASTE AREA

The Industrial Waste area consists of soils, paint sludge, somerefuse and a few drummed wastes that were deposited in the baseof the Rasmussen gravel pit. The area is contiguous with theProbable Drum Storage/Leakage/Disposal area. The area is ofconcern because of the threat from dermal contact due mainly tothe PCBs, and threat to the groundwater. Groundwatercontamination beneath this area was confirmed by monitor wellsampling.

The Industrial Waste area is adjacent to and could be consideredpart of the Probable Drum Storage/Leakage/Disposal area.However, both areas are distinctly different. The IndustrialWaste area contains actual waste materials (paint sludge, drums,etc.), while the Probable Drum Storage/Leakage/Disposal areaconsists mainly of contaminated soils resulting from spillage,leakage, and/or bulk dumping of drums.

1.4.3 RASMDSSEN DUMP SITE - NORTHEAST BURIED DRUM AREA

The Northeast Buried Drum area consists of drum wastes and mixedwaste soils that were pushed over the edge and side of the hillwhere the municipal landfill is located. The.mixed waste soilsand drums are contiguous with the municipal landfill wastes.

The Northeast Buried Drum area is an area of concern mainlybecause of the dermal threat posed by the dioxin in the surfacesoils, and the threat to groundwater posed by both the wastesand contaminated soils. Some of the highest concentrations oforganic hazardous substances were found in this area, asindicated in Table 1-1 in Section 1.3 of this


REVISION-11/10/89

report. Test pits excavated during the Remedial Investigationshowed soils surrounding the buried drummed waste to be highlystained with contamination.

1.4.4 RASMUSSEN DUMP SITE - TOP OF THE MUNICIPAL LANDFILL

The Top of the Municipal Landfill consists of fine grained,sandy soils that were originally placed as a cover for themunicipal wastes, and were subsequently disturbed by drumdisposal and removal, and soil removal. The soil cover wasrelatively thin generally ranging from one to several feet thickwhere present. The cover was very thin in some portions of thefill where municipal wastes were seen at the ground surface. Inaddition, municipal wastes are exposed along the north face ofthe fill which was excavated for the gravel pit, and along thehillside forming the south face of the landfill.

The Top of the Municipal Landfill is an area of concern mainlybecause of the dermal threat posed by PCB and Benzo(a)Pyrene inthe surface soil; and the threat to groundwater from leachingthrough the contaminated soils.

1.4.5 SPIEGELBERG AND RASMUSSEN DUMP SITES -GROUNDWATER CONTAMINANT PLUMES

The Spiegelberg site groundwater contamination plume originatesfrom the Spiegelberg Paint Sludge area. The Paint Sludge areasource will be removed at some future date, in accordance withthe U.S. Environmental Protection Agency Record-of-Decision(ROD) signed on September 30, 1986. The risk posed by the plumeis the potential threat from ingest ion and inhalation (householduse) of the groundwater, mainly from benzene, methylenechloride, vinyl chloride, and 1,1-dichloroethane.

The Rasmussen Dump site groundwater contamination plumeoriginates from the Probable Drum Storage/Leakage/Disposal areaand the Industrial Waste area, which are contiguous. Both theseareas are considered continuous, ongoing sources. The riskposed by the plume is the potential threat from ingest ion andinhalation (household use) of the groundwater, mainly frommethylene chloride, vinyl chloride, benzene, 1,1-dichloroethane,1,1-dichloroethene, trichloroethene, tetrachloroethene,Bis(2~ethylnexyl)Phthalate, and chloroform.

2.0 REMEDIAL ACTION OBJECTIVES

The principal objective of remedial action is to eliminateand/or reduce the threat or potential threat to human health andthe environment posed by the areas of concern. Remedial actionsare to address the specific threat posed in an area of concern,

EXECUTIVE SUKMARY - 7

REVISION-11/10/89

by considering the chemicals of concern and the routes ofexposure. In addition, an estimate of the acceptablecontaminant levels is made to establish "action levels" in theapplicable media (e.g. air, soil and groundwater. }

The Risk Assessment determined that the most significant routeof exposure where the risk exceeded the acceptable levels(Hazard Index greater than one or Cancer Risk greater than 10-6)was through the ingestion of, or inhalation of vapors frompotentially contaminated groundwater. The only other route ofexposure that exceeded the risk levels was dermal contact.

The Risk Assessment also determined that the risks associatedwith the chemicals of concern for groundwater risks was greaterthan that for dermal contact, and that acceptable concentrationsin soil (soil action levels) calculated for acceptablegroundwater risks would be lower than soil concentrations (soilaction levels) for acceptable risks due to dermal contact.Therefore, the acceptable concentrations in soil, as calculatedfor groundwater protection, can be used as the soil actionlevels for the remediation of each area.

Determination of the acceptable soil concentrations (soil actionlevels) was performed using several different assumptions duringthe Remedial Investigation and Risk Assessment. In all cases,the soil action levels were determined using the revised"Organic Leachate Model" and a linkage model to back-calculatesoil concentrations from assumed concentrations in thegroundwater.

Cleanup levels for the existing groundwater plumes were alsoestimated, and values were provided by the MDNR for inclusion inthis report. Table 2-2 provides the cleanup levels that achievethe 10-6 risk level for both sites.

2.1 RASHUSSEN SITE REMEDIAL OBJECTIVES

2.1.1 NORTHEAST BURIED DRUM AREA

The main threats posed by the buried drum area are potentialdermal contact and fugitive dust inhalation, and leaching ofhazardous substances into the groundwater. Therefore, theremedial action objectives are to prevent dermal contact with,and inhalation of, hazardous substances with a greater than 1 x10-6 cancer risk level, and prevent degradation of thegroundwater environment by potential leaching of organiccontaminants.

EXECUTIVE SUHMARY - 8

REVISION-11/10/89

2.1.2 TOP OF THE MUNICIPAL LANDFILL

The main threat posed by the top of the municipal landfill arepotential dermal contact and fugitive dust inhalation.Therefore, the remedial action objectives are to prevent dermalcontact with, and inhalation of, hazardous substances with agreater than 1 x 10-6 cancer risk level.

2.1.3 INDUSTRIAL HASTE AREA

The main threats posed by the Industrial Waste area arepotential dermal contact and fugitive dust inhalation, andleaching of hazardous substances into the groundwater.Therefore, the remedial action objectives are to prevent dermalcontact with, and inhalation of, hazardous substances with agreater than 1 x 10-6 cancer risk level, and prevent degradationof the groundwater environment by potential leaching of organiccontaminants.

2.1.4 PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREA

The main threats posed by this area are potential dermal contactand fugitive dust inhalation, and the continued leaching ofhazardous substances into the groundwater. Therefore, theremedial action objectives are to: (1) prevent dermal contactwith, and inhalation of, hazardous substances with a greaterthan 1 x 10-6 cancer risk level; and, (2) prevent degradation ofthe groundwater environment by potential leaching of organiccontaminants.

2.1.5 GROUNDWATER PLUME (RASMUSSEN)

The main threat posed by the existing groundwater plume is thepotential risk for ingestion and inhalation due to householduse, and the threat to the groundwater environment. Theremedial action objective is to reduce or eliminate exposure ofpotential receptors to contaminated groundwater and preventfurther degradation of the groundwater environment.

2.2 SPIBGELBERG SITE REMEDIAL OBJECTIVES

2.2.1 GROUNDWATER PLDME (SPIEGELBERG)

The main threat posed by the existing groundwater plume is thepotential risk for ingestion and inhalation due to householduse, and the threat to the groundwater environment. Theremedial action objective is to reduce or eliminate exposure ofpotential receptors to contaminated groundwater and preventfurther degradation of the groundwater environment.


REVISION-11/10/89

3.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)

Under section 121(d)(2)(A) of SARA, remedial actions must atleast attain a level or standard of control which attains anystandard, requirement, criteria, or limitation under any Federalenvironmental law, including but not limited to, the ToxicSubstances Control Act, the Safe Drinking Water Act, the CleanAir Act, the Marine Protection, Research,, and Sanctuaries Act orthe Solid Waste Disposal Act determined to be legally applicableor relevant.

SARA also requires that if any promulgated standard,requirement, criteria, or limitation under a State environmentalor facility siting law is more stringent than any Federalstandard, requirement, criteria, or limitation and is applicableor relevant and appropriate, the level or standard of controlcalled for must be attained. Section 121 (d) (4) of SARAprovides for waivers of ARARs under six different types ofcircumstances.

During the initial stages of the feasibility study potentialARAR's were identified for both the Spiegelberg and Rasmussensites. The first ARARs examined are those that pertain to thespecific hazardous compounds detected in the various areas ofconcern and groundwater plumes at the sites. The chemicalspecific ARARs are presented in Table 3-1.

The potential ARARs were then examined and evaluated todetermine which ARARs may be applicable to the six areas ofconcern, based on the location and type of media effected by theareas of concern.

4.0 DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES

Development of Remedial Action alternatives is a systematicmethod used to identify the range of methods that could be usedto eliminate or reduce the real or potential threat to humanhealth and the environment in the areas of concern on theSpiegelberg and Rasmussen sites. A range of potential remedialalternatives were developed for each area of concern. Thesealternatives were screened for subsequent detailed evaluationsin the detailed evaluation of alternatives.

4.1 GENERAL RESPONSE ACTIONS

General response actions are comprehensive actions, or remediesthat satisfy the remedial action objectives discussed previouslyfor each area of concern. The general response actionsidentified for the Spiegelberg/Rasmussen site include thefollowing:


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No ActionInstitutional ActionsAlternative Water SuppliesContainmentRemovalOnsite TreatmentOffsite TreatmentOnsite DisposalOffsite Disposal

4.2 REMEDIAL TECHNOLOGIES AMD PROCESS OPTIONS

Several general categories of potential remedial technologieswere identified for each general response action. The processoptions considered to be potentially applicable are furtherevaluated and screened with respect to effectiveness/implementability, and cost criteria:

o Effectiveness - Several factors are considered in theeffectiveness evaluation. These include the potential forprocess options to handle estimated volumes ofcontaminated media and meet contaminant reduction goals,protection of human health and the environment duringconstruction, and whether or not the process option isproven and reliable for the contaminants of concern andsite conditions.

o Implementability - The implementability evaluationemphasizes the institutional aspects of implementability,such as the ability to obtain necessary approval fromgovernment agencies, the availability of treatmentstorage, and disposal capacity, and the availability ofequipment and skilled labor.

o Relative Cost - Relative capital and operation andmaintenance <0&M) costs were estimated as high, medium, orlow for each process option. Cost estimates were made forcomparison purposes only and were based on engineeringjudgement and experience.

The remedial technologies and process options evaluated for theSpiegelberg and Rasmussen sites are discussed below:

4.2.1 NO ACTION

The no action response is required for consideration under the40 CFR 300.66, C.3 which is the Nation Contingency Plan (NCP) .The No Action alternative is evaluated to estimate the effect ofnot performing additional remedial actions at the site. The noaction alternative does not restrict the further migration ofcontaminants nor does it reduce the toxicity, mobility or volume

EXECUTIVE SUMMAR* - 11

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of those contaminants at any of the areas of concern wherecontamination has been demonstrated to be a threat to humanhealth and environment at the sites.

4.2.2 INSTITUTIONAL ACTIONS

Fencing-

Fencing is an established technique designed to minimize dermalcontact risks by deterring people from entering intocontaminated areas. An MDNR fence currently encompasses theareas of concern on the Rasmussen site.

Monitoring and Analysis-

Monitoring and analysis technologies will be used to assess theeffectiveness of remedial activities if permanent solutions arenot selected.

Since monitoring and analysis will not remediate the areas ofconcern or the groundwater plumes, the technologies are notretained for further evaluation as a stand-alone option.Monitoring and analysis is retained in conjunction with otherremedial options.

Deed Restrictions (Well Construction)-

Since deed restrictions do not detoxify, reduce or eliminate thecontamination, and the restrictions may be difficult toimplement, they are not retained as a stand-alone option forfurther evaluation. Deed restrictions may be considered inconjunction with other remedial actions.

4.2.3 ALTERNATIVE DRINKING HATER SUPPLY

At the present time, none of the residential or commerciald r i n k i n g water wells in the v i c i n i t y of theSpiegelberg/Rasmussen site have been adversely affected bygroundwater contamination from the sites. Alternative watersupply technologies include:

Municipal Hater System-

Connection of residential homes to a municipal water systemcould ensure protection of the public from future use ofcontaminated water from the plumes, although no offsite watersupplies are presently effected.


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1.0 INTRODUCTION

Preliminary screening of the remedial action alternativesdescribes the process for the development of remedial actionalternatives for the Spiegelberg and Rasmussen Dump siteslocated in Livingston County, Michigan.


Sections 1.0 through 4.0 includes a general description of boththe Spiegelberg and Rasmussen sites, a summary of the areas ofconcern, chemicals of concern, and routes of exposure asidentified in the remedial investigation and risk assessment, anidentification of the Appropriate, Relevantt and ApplicableRequirements (ARARs) for both the areas of concern and processoptions, as well as a step wise description of the process ofremedial alternatives development.


o Identification of remedial action objectives for protectinghuman health and the environment. Remedial actionobjectives aimed at protecting human health should specifyboth a contaminant of concern and an exposure route. Forexample, a human health remedial objective may be toprevent ingestion of water having benzene in excess of0.005 mg/1. Remedial action objectives related toenvironmental protection may seek to preserve or restore aresource or protect plant or animal populations. Anexample of a environmental related objective may be torestore a groundwater aquifer to background concentrationsfor benzene.

o Identification of the remedial response actions hat wouldmeet the remedial objectives. These may include suchgeneral response actions as treatment, containment,excavation, disposal, or a combination of these. Generalremedial response actions are initially defined during theremedial investigation and are refined as more informationabout the site is obtained.

o Identification of remedial technologies and rocess optionsassociated with the general response actions. Remedialtechnologies refer to general categories of technologiessuch as surface capping, thermal treatment or onsitedisposal. For example, under the containment responseaction several technologies could be identified such assurface capping, vertical barriers, and horizontalbarriers.

REVISION-11/10/89

Similarly, process options refer to specific processeswithin each remedial technology. For example, the verticalbarrier technology would include such process options asslurry trench walls, grout curtains, and steel sheetpiling.

Once identified, the remedial technologies and processoptions are evaluated and screened based on potentialapplicability. The evaluation eliminates from furtherconsideration those process options and/or technologiesthat can not be effectively applied to the site. Forinstance, rotary kiln incineration would not be applied asa treatment for metals contamination in soils since thistype incineration does not destroy or detoxify metals.

o The process options considered to be implementable arefurther evaluated with respect to effectiveness,implementability, and cost. Consideration to be madeduring this evaluation include the effectiveness of aprocess option to handle estimated volumes of contaminatedmedia and protect human health and the environment, theability to obtain a necessary approvals and permits, andrelative capital, operation and maintenance costs.


The detailed evaluation of alternatives is contained in Section5.0 and subsequent sections, and will include a more in-depthevaluation of each assembled remedial action alternative withrespect to long and short term effectiveness, implementability,and cost, as well as ARAR considerations. Site widecomprehensive remedies are also compiled to address all thepotential threats posed by the areas of concern; and acomparativeanalysis is conducted to obtain the preferred alternatives.

REVISION-11/10/89



The Spiegelberg property consists of approximately 115 acres andis located in an area of moderately rolling topography, as shownon Figure 1-1 of the Remedial Investigation Report (September1988). The property and vicinity .are characterized byrelatively flat areas on the southern portion of the site andbeyond the site boundaries, and by the rolling, hilly area thatcomprises most of the property. The property is underlain byglacial deposits consisting of sand and gravel, which was, andcontinues to be, commercially mined.

An area on the northern part of the property was used fordisposal of waste materials as early as 1966. Domestic,industrial, and septic wastes have been disposed of at this siteat least until 1977. Domestic wastes continue to be disposed ofonsite, in small quantities.

Gravel mining at this property predated 1940 and continuesthrough the present time. Mining has caused alteration to theproperty topography since the topographic mapping performed forthe RI in 1984. Peat mining has also occurred on the property.


The Rasmussen property has the same general topographic featuresand geology as the Spiegelberg property except that it is whollylocated on hilly topography. The location of the Rasmussenproperty is shown in Figure 1-1 of the Remedial InvestigationReport (September, 1988). The Rasmussen property consists ofapproximately 33 acres and is bounded on the west and south bythe Spiegelberg property. The property is bounded on the east byprivate property belonging to another Rasmussen relative.Spicer Road forms the northern boundary of the site. Thetopography of the site has been altered by extensive mining ofsand and gravel. The pre-mining topography at the Rasmussenproperty was characterized by hilly topography, which rose to aridge-like crest in the southern portion of the property. Thesite of environmental contamination extends across the southernhalf of the property.

The Rasmussen Dump Site, which was operated as the "Green OakTownship Dump" for a number of years, accepted both domestic andindustrial wastes in both solid and liquid form. Drummedindustrial wastes were disposed of, and drums were reportedlypiled

REVISION-11/10/89

in several areas of the dump site. In addition, bulk disposal ofindustrial liquids was also reported to have occurred on site.According to MDNR files, a pond used for liquid industrial wasteexisted on site during 1967 and 1968.

Beginning in 1967, repeated attempts were made to either bringthe dump into compliance with state laws or to shut it down.The dump was closed in 1972, and wastes were no longer allowedto be disposed onsite. During operation of the dump, numerousinstances of burning were reported. One fire involvedsubstantial amounts of industrial wastes and burned our ofcontrol for 3 days.

The Rasmussen Site began gravel mining operations in the 1970's.The mining eventually undermined substantial portion of the dumparea. Currently, about 10 feet of landfilled materials,primarily domestic wastes, are exposed along the vertical faceof the gravel pit excavation.

The gravel mining on site also caused the movement andredisposal of drums containing wastes. Drums were apparentlymoved to the top of the dump and pushed over the side of thehill. The actions apparently crushed drums and mixed the drumswith soils. Inspection of the site by MDNR in December 1979reported about 75 drums filled with solids and 300 crusheddrums. Drum sampling by the MDNR in October 1981, revealed PCBsin concentrations of 640/000 parts per billion (ppb) near a pileof drums, and lesser concentrations at other locations in theimmediate vicinity.

The Green Oak Dump waste materials are referred to in thisdocument as the Municipal Landfill, and the soil materialscovering portions of the landfill are the "Top of the MunicipalLandfill."

Groundwater monitoring wells were installed by MDNR on theSpiegelberg and Rasmussen Sites in 1981. Wells on theSpiegelberg property but in close proximity to the westernproperty line of the Rasmussen property showed low levels oforganic contamination at that time.

In October and November 1984, the USEPA, Emergency ResponseTeam, removed drums that were observable on top of the dump, aswell as drums on the lower slope and base of the dump. Inaddition, approximately 250 cubic yards of soils contaminatedwith PCBs were removed from the top of the. dump and from thebase of the hill below the dump.

In June, 1987 approximately 7000 cubic yards of sand and gravelwere removed from the Probable Drum Storage/Leakage/DisposalArea for commercial and residential use off site. Testing ofthe excavation and of the offsite sand and gravel from theexcavation indicated the soils were contaminated. The sand and

REVISION-11/10/89

gravel that was placed off site was replaced on the RasmussenSite from November, 1987 through July, 1988.



Information from the following documents, reports/ and technicalmemoranda was used during the preparation of the feasibilitystudy:

1. Risk Assessment and Phased Feasibility Study ofAlternatives, September, 1986 (NUS Corporation).

2. Mobile Treatment Technologies for Superfund Wastes,September, 1986 (U.S. Environmental Protection Agency).

3. Remedial Design for Source Control, April 1988 {NUSCorporation).

4. Remedial Investigation Report, September, 1988 (NUSCorporation).

5. Risk Assessment, September, 1988 (NUS Corporation).


The *Areas of Concern' are those areas where the RemedialInvestigation identified and confirmed the presence of hazardoussubstances on the Spiegelberg and Rasmussen Dump sites. Theareas where hazardous substances are located are generallyassociated with past practices of disposal, redistribution andburning of hazardous substances at various places on the sites.These areas are designated as 'Areas of Concern' because theypose a risk or potential risk to human health and/or theenvironment, as established in the Risk Assessment. Groundwatercontamination plumes are considered separate areas of concern,even though the source of contamination is leaching from an areaof concern, because groundwater remediation is evaluatedseparately from source control remediation in the remedialevaluation process.

The areas of concern identified by the Remedial Investigationand Risk Assessment include the following:

REVISION-11/10/89

Rasmussen Site -





o Groundwater Plume

Spieqelberq Site-

o Paint Sludge Area

o Groundwater Plume

The Spiegelberg Paint Sludge Area is also an area of concern;however, a separate Risk assessment, Phased Feasibility Study,and Remedial Design were completed for this area. The remedialaction will involve excavating the buried wastes andcontaminated soils to the groundwater table, thencharacteri2ing them as either wet or dry wastes and separatingthem. The wet wastes will then be incinerated and the drywastes disposed of at a RCRA approved landfill. Theimplementation of the action is currently being considered by apotential responsible party.

The Risk Assessment (September, 1988) also identified the "BermArea" on the Rasmussen site as an area of concern. The area hadcontained several isolated drums and an associated small area ofcontaminated soil. The drums were removed by the EPA immediateremoval, and the soils were subsequently removed. Therefore,the Berm Area is not considered in this Feasibility Study.

The 'Chemicals of Concern1 are those hazardous substances thatpresent the risk in each area of concern. Hazardous substancesare those chemicals, compounds and other substances defined inSection 101 (14) of Title I of the Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 (CERCLA). Thehazardous substances (contaminants) are identified in theRemedial Investigation and their relative risk is evaluated inthe Risk Assessment.

The 'Routes of Exposure' are the ways by which the chemicals ofconcern can reach humans and the environment, thereby causingthe risks. The typical routes of exposure for humansspecifically addressed in the Risk Assessment for the areas ofconcern are as follows:

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- Dermal contact

- Inhalation of fugitive dust

- Accidental ingestion of soil

- Ingestion of groundwater

- Inhalation of vapors from groundwater in household use

Tables 1-1 through 1-4 summarize the Chemicals of Concern forthe four areas of concern where the contaminants are in the soiland/or waste matrix (all areas except the groundwater plumes).The Risk Assessment (September, 1988) determined that the mainchemicals of concern for these four areas were organiccompounds. Column (1) in Table 1-1 through 1-4 lists theorganic compounds that are hazardous substances that weredetected in each of the four areas of concern. Columns (2) and(3) provide the maximum and arithmetic average concentrationsfound for the compounds.

Tables 1-1 through 1-4 also summarize which of the organiccompounds contribute most to the threat to public health and theenvironment. The relative importance of each compound incontributing to the risks was estimated using the Hazard Indicesand Carcinogenic Risks calculated for each compound detected inthe areas of concern, as provided in Appendices B, C, and D ofthe Risk Assessment (September, 1988.) The compoundscontributing most to the risks are indicated in Column 4 ofTables 1-1 through 1-4.

Column (4) delineates those individual compounds that exceed the10-fi carcinogenic risk level for dermal exposures (10~6)

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TABLE 1-1

SUMMARY OP CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISKNORTHEAST BURIED DRUM AREA

RASMUSSEN DUMP SITE

(1)

Chemical of Concern

1,1,1-Trichloroethane1,1-Dichloroethane2,3,7,8,-TCDD (dioxin)2-Methylnaphthalene2-Butanone4,4'-DOTAcetoneBenzeneBis(2-Ethylhexyl)Pht.Buty? Benzyl PhthalateChlorobenzeneDi-N-Butyl PhthalateDi-N-Octyl PhthalateEthylbenzeneFloureneIsophoroneMethylene ChlorideNaphthalenePCBsPhenanthrenePhenolStyreneTetrachloroetheneTolueneTrichloroetheneTotal Xylenes

(2)Maximum Cone,

fug/kg)

(3) . (4)Average Cone. Exceeds Risk

(ug/kg) (see notes)

8501000

4609,700

4,00054

210530

2,60019017

21,000710100500

1,30022,0322,900

4540,000

5430,000

34017,000

,000,000.061,000,000520,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000

1,94050,0060.0256,600

3,435,537

999,030

42,00092,286515,26332,04511,800

1,900,000

47,000137,000179,469

2,590,000361,000

13,702,00018,003

4,780,11492,838

4,630,328

**+ * *

**

* *

* *

Notes:Column (4) indicates the compound exceeded either the one additional case

in 100,000 risk for cancer (10E-6), or was a significant contributor to thenoncarcinogenic "hazard index", as defined in the Risk Assessment (September,1988.)

One asterisk (*} indicates risk levels modeled for groundwater wereexceeded using maximum concentrations only, and two asterisks (**) indicaterisk levels modeled for groundwater were exceeded using maximum and averageconcentrations.

The plus sign ( + } indicates the cancer risk level (10E-6) was exceededfor dermal contact.

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TABLE 1-2

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISKTOP OF MUNICIPAL LANDFILL

RASMUSSEN DUMP SITE

(1) (2) (3) {4)Maximum Cone. Average Cone. Exceeds Risk

Chemical of Concern fug/kg) f ug/kg) (see notes)

1.1.1-Trichloroethane 9 21.1.2-Trichloroethane 42 71,1-Dichloroethane 6 1Trans-l,2-Dichloroethene 8 22,3,7,8,-TCDD (dioxin) 0.002 0.0072-Methylnaphthalene 4,000 3,7202-Butanone 30 54-Methylphenol 1,700 633Acetone 300 57Benzene 11 3Benzoic acid 2,000 667Benzo(a)Pyrene 500 83 +Bis(2-Ethylhexyl)Pht. 14,000 3,430 **Butyl Benzyl Phthalate 218 36Carbon Disulfide 215 37Chlorobenzene 980 259Chloroform 6 3Di-N-Butyl Phthalate 10,000 2,970Di-N-Octyl Phthalate 1,400 253Ethylbenzene 1,600 458Indeno{1,2,3-cd)Pyrene 500 83Isophorone 3,000 500Methylene Chloride 450 181 **Naphthalene 13,000 3,720N-Nitrosodiphenylamine 3,000 583 *PCBs 61,000 16,500 + **Pentachlorophenyl 2,000 333Phenanthrene 1,000 417Phenol 2,300 333Styrene 590 106Tetrachloroethene 10 2 *Toluene 1,700 363Trichloroethene 42 14Total Xylenes 5,300 1,900

Notes:

See notes for Table 1-1.

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TABLE 1-3

SUMMARV OF CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISKINDUSTRIAL WASTE AREARASMUSSEN DUMP SITE

(1)

Chemical of Concern1,1,1-Trichloroethane2-Butanone4-Methyl~2-PentanoneCarbon DisulfideChlorobenzeneEthylbenzeneStyreneTetrachloroethene2-MethylnaphthaleneAcenaphthaleneAnilineBenzo(a)AnthraceneBenzo(ajpyreneBenzo(b)FluorantheneBenzo(k)FluorantheneButyl Benzyl PhthalateDi-n-butyl PhthalateDichlorodifluoromethaneFluorantheneNaphthaleneN-NitosodiphenylaminePentachlorophenolPhenanthrenePyreneAcetoneBenzeneTolueneTotal XyleneTrichloroetheneChloroformMethylene ChlorideBis(2-Ethylhexyl)Pht.PCBs

Notes:

See Table 1-1 for notes

(2)Maximum Cone.

(uq/kq)10

86,000240,000

44150,000300,00050,000

11.67,0003,499566

1,043759

1,1591,159

110,0006,600

601,04335,00013,0003,9786,6001,032

2566661

13024,000

4,600,000

(3)Average Cone

(uq/kq)

86,670230,000

9.35,050

59,5402,447

30

33,500

3,374

823220.376

6,7922,402,600

(4)Exceeds Risk(see notes)

+ * *

10

REVISION- 11/10/89

TABLE 1-4

SUMMARY OF CHEMICALS OP CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISK

PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREARASMUSSEN DUMP SITE

(1)

Chemical of Concern1,1,1-Trichloroethane2-Methylnaphthalene2-ButanoneBenzole acidBis(2-Ethylhexyl)Pht.Butyl Benzyl PhthalateChlorobenzeneDiethyl PhthalateDi-N-Butyl PhthalateDi-N-Octyl PhthalateEthylbenzeneMethylene ChlorideNaphthaleneN-NitrosodiphenylaminePCBsPhenanthreneTetrachloroetheneTolueneTotal Xylenes

(2)Maximum Cone.

fug/kg)11

31,00012

36,0001,552

30,00038,000

13022,000

8253,000

105100,00024,00016,0007,500

10190,000360,000

(3)Average Cone

(uq/kg)0.7

2,5700.8

2,250280

2,8862,750

121,900

515,100

127,6501,9101,740

6160.9

12,70027,900


+ *

Notes:


11

REVISION- 11/10/89

carcinogenic risk level means that there is a risk of one additionalcase of cancer developing in a population of one million who areexposed). No inhalation exposure exceeded the 10-6 cancer risk.

The risk assessment actually assesses the risk for each chemicallisted in Column {1), and provides the total risk of the area ofconcern by adding all the individual risks. Column (4) only showsthe chemicals for which the individual risk exceeds 10-6 to showwhich chemicals are posing the most significant risk in the area ofconcern.

Column (4) in Table 1-1 through 1-4 indicates the exposure route, orroutes from ingestion or inhalation of vapors from groundwater wherethe 10-6 carcinogenic risk level is exceeded. The potential risksin these cases were evaluated by mathematical modeling provided inthe Risk Assessment, and not by actual measurement in thegroundwater. The mathematical models assume several potentialcontaminant concentrations in groundwater as well as several modesof dispersion that tend to dilute the concentrations. Column 4indicates which chemicals exceeded the 10-6 risk for the case where

^ maximum concentration and minimum dispersion were assumed (worstcase); and where average concentration and moderate dispersion wereassumed (possible case.)

•Tables 1-5 and 1-6 summarize the chemicals of concern for the actualgroundwater contamination plumes that occur beneath the Rasmussenarid Spiegelberg sites. As in Tables 1-1 through 1-4, columns (1)and (2) respectively show the chemicals of concern and maximumconcentration detected for monitoring wells in the plumes. Columns(3) and (4) respectively delineate those individual compounds thatexceed the 10-6 carcinogenic risk level or present a non-carcinogenic risk.

The risk assessment established the risks for both the carcinogenicrisks and noncarcinogenic risks for potential ingestion andinhalation of vapors from groundwater use. Both the Rasmussen andSpiegelberg groundwater plumes exceeded the 10 -6 carcinogenic risklevel, and the acceptable noncarcinogenic risk levels for ahypothetical receptor (groundwater user) at Spicer Road. On thisbasis both the groundwater plumes are designated as areas of concernto be considered for remedial action.

The information in Tables 1-1 through 1-6 provide the basis uponwhich the remedial action objectives for each area of concern weredetermined, as discussed in Section 2.0.

12

REVISION-11/10/89

TABLE 1-5

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISK

RASMUSSEN GROUNDWATER PLUMERASMUSSEN DUMP SITE

(1)

Chemical of Concern

Acetone2-ButanoneBenzeneTolueneXylenes1,1,1-Trichloroethane1.1-Dichloroethane1.2-DichloroetheneTrichlorethene4-Methyl-2-PentanoneMethylene ChlorideEthylbenzeneVinyl ChlorideChlorobenzeneBis(2-ethylhexyl)

PhthalateDi-N-Butyl PhthalateChloroformPhenol2-Methylphenol4-MethylphenolIsoporphorone2,4-Dimethylphenol2-ChlorophenolBenzyl AlcoholBenzole acidTetrachloroehene1,1-DichloroetheneCadmiumZinc

(2)Maximum Cone

(rnq/l)

2674

7.0E-17111

5.0E-15.5E-15.9E-15.0E-1

301.12.4

9.6E-23.7

1.2E-22.1E-25.0E-36.2E-2

1.62.8E-14.4E-12.7E-21.7E-21.2E-21.7E-12.0E-35.9E-12.9E-21.9E-1

(3)Exceeds RiskCarcinogenic

(4)Exceeds RiskNoncarcinoqen

A*

* *

A A

A AA A

Notes:Column (2) "Maximum Concentrations ]" in the Rasmussen Plume obtained

from Risk Assessment (September, 1988.) Notation such as "1.2E-2" means valueis 1.2 times 10-2, which is equal to "0.012".

Column (3), "Exceeds Risk, Carcinogenic" indicates the compound exceededthe one addtional case in 100,000 for cancer. One asterisk (*) indicates therisk was exceeded for potential ingestion of groundwater. Two asterisks (**)indicate the compound exceeded cancer risk for both ingestion and inhalationof vapors from groundwater due to household use.

Column (4), "Exceeds Risk, Noncarcinogenfic]" indicates the compoundexceeded the Hazard Index of 1.0, as defined in the Risk Assessment(September, 1988) Appendix B.

13

REVISION-11/10/89

TABLE 1-6


SPIEGELBERG GROUNDWATER PLUMESPIEGELBERG SITE

(1)

Chemical of Concern

Acetone2-ButanoneBenzeneTolueneXylenes1,1,1-Trichloroethane1.1-Dichloroethane1.2-Dichloroethene4-Methyl-2-PentanoneMethylene ChlorideEthylbenzeneVinyl ChlorideChlorobenzeneBis(2-ethylhexyl)

PhthalateDi-N-Octyl PhthalateDi-N-Butyl PhthalateBenzoic acidChloroethane2-HexanonePhenolCadmiumNickelZinc

Notes:

(2)Maximum Cone

(mq/1)

6.9E-15.5E-18.0E-31.2E-15.6E-26.0E-31.7E-11.4E-11.4E-18.0E-31.6E-21.2E-12.6E-2

1.2E-1l.OE-14.0E-31.4E-19.3E-25.1E-29.0E-27.9E-27.3E-196.6

(3) (4)Exceeds Risk Exceeds RiskCarcinogenic Noncarcinogen

**

**

* A

* *

Column (2) "Maximum Concentrations ]" in the Spiegelberg Plume obtainedfrom Risk Assessment {September, 1988.) Notation such as "1.2E-2" means valueis 1.2 times 10-2, which is equal to "0.012".


Column (4), "Exceeds Risk, Noncarcinogen[ic]" indicates the compoundexceeded the Hazard Index of 1.0, as defined in the Risk Assessment(September, 1988) Appendix B.

14

REVISION-11/10/89

1.4 PHYSICAL DESCRIPTIONS OP THE AREAS OP CONCERN

This section provides a brief physical description of each areaof concern, including an estimate of the depth of contaminationand the volume of materials that may require excavation forremedial alternatives involving removal. The volumecalculations were performed by Warzyn Engineers, Inc., and areprovided in Appendix A of this document.

1.4.1 RASM0SSEN DUMP SITE - PROBABLE DRUMSTORAGE/LEAKAGE/DISPOSAL AREA

The Probable Drum Storage/Leakage/Disposal area consists ofsporadically contaminated soils, where contamination occurs inpockets and lenses in both the saturated and unsaturated zonesas a result of apparent spillage and leakage from drums and/orbulk dumping. The soils are natural, in situ sand and gravelwith lenses of finer grained sandy silts. The area waspartially excavated by the owner in 1987, exposing contaminatedzones in the soils that appear to be associated with the finergrained silty lenses of soil. On the basis of this observation,the area probably contains large zones of uncontaminated to lowlevel soil contamination, with fewer, smaller zones of morehighly contaminated soils that serve as a continuing source ofleaching into the groundwater. The most highly contaminatedsoils were distinguished as either dark gray to black, or lightgray. Visual identification was most easily made on the nearvertical high walls of the excavation.

The Probable Drum Storage/Leakage/Disposal area is an area ofconcern because of risks posed by dermal contact from PCBs, andthe continued threat to groundwater. Contamination wasconfirmed by sampling groundwater beneath this area usingmonitoring wells. Groundwater data shows that a significantamount of organic compounds have leached from this area. Thecontaminant plume emanating from the Probable DrumStorage/Leakage/Disposal Area is designated the Rasmussen Plume.The organic contaminants detected in the plume are presented inTable 1-5.

The areal extent of the Probable Drum Storage/Leakage/Disposalarea is shown on Figure 3-1 of the Remedial Investigation reportand Risk Assessment report. The area is shown as approximatesince the exact dimensions are unknown. The depth to whichcontaminated soils extend is also unknown. Because of theuncertainty of contaminant extent and the topography of thearea, two volume estimates were made: The first assumesexcavation to elevation 920 feet (mean sea level), which is thepresent base of the gravel pit. Using this assumption, a volume

15

REVISION-11/10/89

of about 3,600 cubic yards of soils would have to be removed.The second volume will depend on excavation to the top of thewater table.

The elevation of the water table beneath the Probable DrumStorage/Leakage/Disposal area is about 883 feet mean sea level(msl). The existing ground surface ranges from about 920 withinthe pit excavated in June 1987 to 938 feet msl. Therefore theexisting ground surface ranges from 37 to 55 feet above thewater table. The case of excavating to the top of the watertable will be further addressed in the Detailed Evaluation ofAlternatives in Section 5.0 and subsequent sections.


The Industrial Waste area consists of soils, paint sludge, somerefuse and a few drummed wastes that were deposited in the baseof the Rasmussen gravel pit. The area is contiguous with theProbable Drum Storage/Leakage/Disposal area. The area is ofconcern because of the threat from dermal contact due mainly to

, the PCBs, and threat to the groundwater. Groundwatercontamination beneath this area was confirmed by monitor wellsampling.

The Industrial Waste area is adjacent to and could be consideredpart of the Probable Drum Storage/Leakage/Disposal area.However, both areas are distinctly different. The IndustrialWaste area contains actual waste materials (paint sludge, drums,etc.), while the Probable Drum Storage/Leakage/Disposal areaconsists mainly of contaminated soils resulting from spillage,leakage, and/or bulk dumping of drums (see Section 1.4.1).

The ground surface elevation at the Industrial Waste area isabout 924 feet msl. The estimated elevation of the water tableis about 883 feet msl, so that the ground surface is about 40feet above the water table.

The general areal extent of the area is provided on Figure 3-1^ of the Remedial Investigation (RI) report and the Risk

Assessment. The area is also discussed in the GeophysicalTechnical Memorandum in Appendix A of the RI report. The depthof wastes, as determined by test pits, is approximately 15 feet.Therefore, the depth from the base of the waste to the watertable is about 25 feet.

The depth to which leachate may have contaminated soil beneaththe waste has not been adequately defined. The depth ofcontaminated soil may range from about 3 feet below the waste tothe water table. The estimate of 3 feet is based on generalobservations in test pits, and the potential for contaminationto the groundwater table is based on boring data from theProbable Drum Storage/Leakage/Disposal area, which has a similarsubsurface geology.

16

REVISION-11/10/89

The limits of the Industrial Waste area encompass an area ofabout 382 square yards. The volume of excavation was estimatedmade using two different assumptions. The first assumesexcavation of waste and 3 feet of contaminated soil only, whichmeans a total excavation depth of about 15 feet, for a volumeof soil and waste excavation of about 1,900 cubic yards.

The second assumption is for an excavation of the soils to thedepth of the water table, which yields an excavation depth ofabout 40 feet. The case of excavating to the top of the watertable will be further addressed in the Detailed Evaluation ofAlternatives in Section 5.0 and subsequent sections.

1.4.3 RASMUSSEN DUMP SITE - NORTHEAST BURIED DRUM AREA

The Northeast Buried Drum area consists of drum wastes and mixedwaste soils that were pushed over the edge and side of the hillwhere the municipal landfill is located. The mixed waste soilsand drums are contiguous with the municipal landfill wastes.

The Northeast Buried Drum area is an area of concern mainlybecause of the dermal threat posed by the dioxin in the surfacesoils, and the threat to groundwater posed by both the wastesand contaminated soils. Some of the highest concentrations oforganic hazardous substances were found in this area, asindicated in Table 1-1 in Section 1.3 of this report. Test pitsexcavated during the Remedial Investigation showed soilssurrounding the buried drummed waste to be highly stained withcontamination.

The surface elevation of the Northeast Buried Drum area rangesfrom about 984 feet msl at the top of the slope to 944 feet mslat the base of the slope. The estimated elevation to thepermanent water table is about 884 feet msl, which is about 60feet below the base of the actual waste material.

The general areal extent of the Northeast Buried Drum area isprovided on Figure 3-1 of the Remedial Investigation report andRisk Assessment. The relative depth of wastes is estimated fromthe test trenches and the surrounding topography as provided inFigure 3-4 of the RI report. The depth of contaminated naturalsoil beneath the visually contaminated wastes is unknown, butassumed as 3 feet below the wastes for estimating purposes,based on test pit observations.

For estimating purposes, the Northeast Buried Drum area can beconsidered to consist of two waste types. The central portionof the area consists of buried drums and covers an area of about830 square yards, extending to an estimated depth of 12 feet.The remaining 1140 square yards of the area containscontaminated soils to an estimated depth of 2 feet (surfacecover material). This remaining area is similar to the Top ofthe Municipal Landfill with which the Northeast Buried Drum area

17

REVISION-11/10/89

is contiguous. The total volume of waste and soil in theNortheast Buried Drum area is estimated to be about 4,100 cubicyards.

1.4.4 RASMUSSEN DUMP SITE - TOP OF THE MUNICIPAL LANDFILL

The Top of the Municipal Landfill consists of fine grained,sandy soils that were originally placed as a cover for themunicipal wastes, and were subsequently disturbed by drumdisposal and removal, and soil removal, The soil cover wasrelatively thin generally ranging from one to several feet thickwhere present. The cover was very thin in some portions of thefill where municipal wastes were seen at the ground surface. Inaddition, municipal wastes are exposed along the north face o.fthe fill which was excavated for the gravel pit, and along thehillside forming the south face of the landfill.

The Top of the Municipal Landfill is an area of concern mainlybecause of the dermal threat posed by PCB and 8enzo(a)Pyrene inthe surface soil; and the threat to groundwater from leachingthrough the contaminated soils. Table 1-2 in Section 1.3summarizes those chemicals posing the most significant threat.

The elevation of the Top of the Municipal Landfill is about 982feet msl. The estimated depth to the water table is about 884feet msl, so the ground surface is about 100 feet above thepermanent water table.

The approximate areal extent of the municipal landfill is shownon Figure 3-1 of the Remedial Investigation (RI) report and theRisk Assessment. The areas of surface contamination by thechemicals of concern (PCB and Benzo{a)Pyrene ) are shown onFigures 4-5 and 4-6 in the RI report. The depth of contaminationis assumed to be a maximum of several feet (2 feet forestimating purposes) corresponding with the depth of the soilcover. The estimated volume of contaminated cover soils isabout 15,300 cubic yards.

1.4.5 SPIEGELBERG AND RASMUSSEN DUMP SITES -GROUNDWATER CONTAMINANT PLUMES

The Spiegelberg site groundwater contamination plume originatesfrom the Spiegelberg Paint Sludge area. The Paint Sludge areasource will be removed at some future date, in accordance withthe U.S. Environmental Protection Agency Record-of-Decision(ROD) signed on September 30, 1986. The risk posed by the plumeis the potential threat from ingestion and inhalation (householduse) of the groundwater, mainly from methylene chloride, vinylchloride, 1,1-dichloroethane, and benzene. The estimatedhorizontal and vertical extent of the plume is provided inFigures 5-7A and 7B in the Remedial Investigation report.

18

REVISION. 11/10/89

The Rasmussen Dump site groundwater contamination plumeoriginates from the Probable Drum Storage/Leakage/Disposal areaand the Industrial Waste area, which are contiguous. Both theseareas are considered continuous, ongoing sources. The riskposed by the plume is the potential threat from ingest ion andinhalation {household use) of the groundwater, mainly frommethylene chloride, vinyl chloride, benzene, 1,1-dichloroethane,1,1-dichloroethene, trichloroethene, tetrachloroethene,Bis(2-ethylhexyl)Phthalate, and chloroform. The estimatedhorizontal and vertical extent of the plume is provided inFigures 5-8A and 8B in the Remedial Investigation report.

The hydraulic conductivities of the aquifers are provided in theRemedial Investigation report. The hydraulic conductivities arebased on short term pump tests, and slug tests. The hydraulicconductivities provided in the Remedial Investigation report areadequate for use in the detailed evaluation of alternatives forpumping and treatment alternatives; however, additional pumpingtests may be required during the pre-design phase to locate theoptimum placement, and establish the pumping rates for purgewells.

19

REVISION. 11/10/89


The principal objective of remedial action is to eliminateand/or reduce the threat or potential threat to human health andthe environment posed by the areas of concern. Remedial actionsare to address the specific threat posed in an area of concern,by considering the chemicals of concern and the routes ofexposure. In addition, an estimate of the acceptablecontaminant levels is made to establish "action levels" in theapplicable media (e.g. air, soil and groundwater.)

This section of the report defines the general remedial actionobjectives for each area of concern and media where a threat orpotential threat exists to human health and the environment.The chemicals of concern that pose the threat in each area weresummarized in Tables 1-1 through 1-5 in Section 1.3 of thisreport. The Risk Assessment (September, 1989) defined thecumulative contribution of carcinogenic and non-carcinogenicrisk for each chemical in each area of concern, for each routeof exposure (i.e. inhalation, ingestion, and dermal exposures.)

The Risk Assessment determined that the most significant routeof exposure where the risk exceeded the acceptable levels(Hazard Index greater than one or Cancer Risk greater than 10-6)was through the ingestion of, or inhalation of vapors frompotentially contaminated groundwater. The only other route ofexposure that exceeded the risk levels was dermal contact.

The Risk Assessment also determined that the risks associatedwith the chemicals of concern for groundwater risks was greaterthan that for dermal contact, and that acceptable concentrationsin soil (soil action levels) calculated for acceptablegroundwater risks would be lower than soil concentrations (soilaction levels) for acceptable risks due to dermal contact.Therefore, the acceptable concentrations in soil, as calculatedfor groundwater protection, can be used as the soil actionlevels for the remediation of each area.

Determination of the acceptable soil concentrations (soil actionlevels) was performed using several different assumptions duringthe Remedial Investigation and Risk Assessment. In all cases,the soil action levels were determined using the revised"Organic Leachate Model" and a linkage model to back-calculatesoil concentrations from assumed concentrations in thegroundwater.

The differences in soil action values are caused by differencesin the assumptions made regarding the number of compounds toinclude in the calculations. The soil action levels provided inthe Risk Assessment (Appendix B, pages 5 and 6 of the datasheets, September, 1988) were calculated assuming compoundsdetected in soil and waste sampling within each area of concern.If total waste removal from the soils is assumed, then theassumptions should be adjusted to account for removal of some of

20

REVISION -11/1 0/89

the compounds from the areas of concern. If the potential forwaste to remain on site is assumed, then the Risk Assessmentassumptions may be appropriate. Therefore, final calculation ofsoil action levels should be made after the preferred remedialaction(s) is selected for each area. For purposes estimationpurposes in the Feasibility Study, the soil action levelsprovided in the Risk Assessment (September, 1988) Appendix B areprovided in Table 2-1 as target concentrations for remediation.


2.1 RASMUSSEN SITE REMEDIAL OBJECTIVES


The main threats posed by the buried drum area are potentialdermal contact and fugitive dust inhalation, and leaching ofhazardous substances into the groundwater. Therefore, theremedial action objectives are to prevent dermal contact with,and inhalation of, hazardous substances with a greater than 1 x10-6 cancer risk level* and prevent degradation of thegroundwater environment by potential leaching of organiccontaminants. The compounds contributing most to the risks fromthis area of concern are summarized in Table 1- 1 in Section1.3. Estimated soil action levels (cleanup concentrations) areprovided in Table 2-1. Actual soil action levels should bedetermined after the preferred alternative is selected for thisarea of concern.

2.1.2 TOP OP THE MUNICIPAL LANDFILL

The main threat posed by the top of the municipal landfill arepotential dermal contact and fugitive dust inhalation.Therefore, the remedial action objectives are to prevent dermalcontact with, and inhalation of, hazardous substances with agreater than 1 x 10-6 cancer risk level. The compoundscontributing most to the risks from this area of concern aresummarized in Table 1-2 in Section 1.3. Estimated soil actionlevels (cleanup concentrations) are provided in Table 2-1.Actual soil action levels should be determined after thepreferred alternative is selected for this area of concern.

21

REVISION-11/10/89

TABLE 2-1

TARGET CONCENTRATIONS FOR SOILREMEDIATION

RASMUSSEN DUMP SITE AREAS OF CONCERN

AREA OF CONCERNCompound

Carcinogens-

BenzeneIt 1-Dichloroe thaneTetrachloroetheneTrichloroetheneChloroformMethylene ChlorideBis(2-ethylhexyl)

phthalateBenzo(A)PyreneBenzof A) AnthraceneBen zo(B)Pluoran then*Benzof KJFlou rant heneN-Nitrosodiphenylamine2,3,7,8-TCDD (dioxin)PCBs

Noncarcinogens-

Acetone2-butanoneTolueneEthylbenzeneTotal XylenesChlorobenzeneStyrene1,1, 1-Tr ichloroethanePhenolDi-n-butylphthalateCarbon Disulfide

TML

(uq/kq)

4.5

13.324.51.85.9

NEB

(uq/kq)

37.58.1

111.9205.8

49.8

IW

(ug/kg)

268.1493.3

119.4

PDSLD

(ug/kq)

142.0

63.3

1,504

173.4

12,637 30,28537.7

18,138750.098,6863,493

16,037

6.4E-51,850

4.4 37.3 89.3 47.3

fmq/kq) fmq/kq) (mq/kq) fmq/kq)

22.010.6

4,5182,09622,283

30.5

744.060.5

8,107470.2

185.089.6

37,96717,614187,256256.833,6826,252508.268,132

374.4158,73073,637782,858

1,074140,81426,139

284,83816,519

131.063.4

26,87212,466132,533

181.823,8394,425

48,2212,797

Notes:1.) Abbreviations are as follows:

TML- Top of Municipal LandfillNEB- Northeast Buried Drum AreaIW- Industrial Waste AreaPDSLD- Probable Drum Storage/Leakage/Disposal Area

2.) Target concentrations for soil remediation were obtained from theAssessment (September, 1968) Appendix B, for the analytical Case 01 forarea of concern.

Riskeach

22

REVISION-11/10/89

TABLE 2-2

TARGET CONCENTRATIONS FOR GROUNDWATERCLEANUP

SPIEGELBERG AND RASMUSSEN DUMP SITES(all values in ug/1)

Michigan FederalCompound and Group Level Level

Carcinogens

benzene1,1-dichloroethanevinyl chloridemethylene chloridetetrachloroethenetricnloroethene1,1-dichloroethenechloroformbis(2-ethylhexyl)

phthalate

Spiegelberg10E-6 Level

0.1790.0960 . 0 0 30.534

0.1

Rasmussen10E-6 Level

0.0700 .0400.0010.2000.0700.2000 .0040.070

0.277

Total Ketones 30.0

acetone2-butanone2-hexanone4-methyl 2-pentanone

Total VolatileOrganic Compounds 20

toluene 2,000ethylybenzene 700xylene 10,000chlorobenzene1,1,1-trichloroethane 2001,1-dichloroethanedi-n-butylphthalatephenol

Metallead 5

218109

580210

1,15019193169218

4421678821514713016766

(Note: all values provided by MDNR.)

23

REVISION-11/10/89

The case of excavating to the top of the water table will befurther addressed in the Detailed Evaluation of Alternatives inSection 5.0 and subsequent sections.

2.1.3 INDUSTRIAL WASTE AREA

The main threats posed by the Industrial Waste area arepotential dermal contact and fugitive dust inhalation, andleaching of hazardous substances into the groundwater.Therefore* the remedial action objectives are to prevent dermalcontact with, and inhalation of, hazardous substances with agreater than 1 x 10*6 cancer risk level, and prevent degradationof the groundwater environment by potential leaching of organiccontaminants. The compounds contributing most to the risks fromthis area of concern are summarized in Table 1-3 in Section 1.3.Estimated soil action levels (cleanup concentrations) areprovided in Table 2-1. Actual soil action levels should bedetermined after the preferred alternative is selected for thisarea of concern.


The main threats posed by this area are potential dermal contactand fugitive dust inhalation, and the continued leaching ofhazardous substances into the groundwater. Therefore, theremedial action objectives are to: (1) prevent dermal contactwith, and inhalation of, hazardous substances with a greaterthan 1 x 10-6 cancer risk level; and, (2) prevent degradation ofthe groundwater environment by potential leaching of organiccontaminants. The compounds contributing most to the risks fromthis area of concern are summarized in Table 1-4 in Section 1.3.Estimated soil action levels (cleanup concentrations) areprovided in Table 2-1. Actual soil action levels should bedetermined after the preferred alternative is selected for thisarea of concern.


The main threat posed by the existing groundwater plume is thepotential risk for ingestion and inhalation due to householduse, and the threat to the groundwater environment. Theremedial action objective is to reduce or eliminate exposure ofpotential receptors to contaminated groundwater and preventfurther degradation of the groundwater environment. Theestimated groundwater cleanup goals are presented in Table 2-2.Remediation of the groundwater plume may require discharge tosurface water in the vicinity of the site. Table 2-3summarizes the compounds that will be considered for compliancewith the National Pollution Discharge Elimination System (NPDES)for discharges from a treatment system to the surface water, andthe values for compliance with Michigan Rule 57 for surfacewater discharges. These values were provided by MDNR.

24

REVISION-11/10/89

2.2 SPIBGELBERG SITE REMEDIAL OBJECTIVES

2.2.1 GROUNDWATER PLUME (SPIEGELBERG)

The main threat posed by the existing groundwater plume is thepotential risk for ingestion and inhalation due to householduse, and the threat to the groundwater environment. Theremedial action objective is to reduce or eliminate exposure ofpotential receptors to contaminated groundwater and preventfurther degradation of the groundwater environment. Theestimated groundwater cleanup goals are presented in Table 2-2.Remediation of the groundwater plume may require discharge tosurface water in the vicinity of the site. Table 2-3summarizes the compounds that will be considered for compliancewith the National Pollution Discharge Elimination System (NPDES)for discharges from a treatment system to the surface water, andthe values for compliance with Michigan Rule 57 for surfacewater discharges. These values were provided by MDNR.

25

REVISION-11/10/89

TABLE 2-3

SUMMARY OF COMPOUNDS REQUIRING CONSIDERATION FOR NPDESAND CONCENTRATIONS TO COMPLY WITH MICHIGAN RULE 57

FOR SURFACE WATER DISCHARGESPIEGELBERG AND RASMUSSEN DUMP SITES

Compoundxylene2-methylphenol4-methylphenol2-chlorophenolBis (2-ethylhexyl) phthalateIsoporphoroneBenzo(a)anthracene2,4-Dimethylphenol1.1-Dichloroethane1.2-DichloroethyleneMethylene ChlorideTrichloroethylene1t1,1-TrichloroethaneTetrachloroethyleneVinyl ChlorideChloroform1,1-Dichloroethylenetrans-1,2-DichloropropeneBenzeneEthylbenzeneChlorobenzeneToluene2-Butanone2-Hexanone4-methyl-2-pentanonePCSBenzoic AcidAcetonePhenolCadmiumChromiumHexavalent ChromiumCopperLeadNickelZincSilverSeleniumArsenicMercury

Rule 57(2) Value, ug/159

860

300599411716

432.6

603071100

0.00002

5002300.9125656182062410.1221840.0006

Information provided by MDNR, Surface Water Quality Division

26

EXECUTIVE SUMMARY

1.0 INTRODUCTION

The preliminary screening of the remedial action alternatives isa portion of the feasibility study that describes the process forthe development of remedial action alternatives for the Spiegelbergand Rasmussen Dump sites located in Livingston County, Michigan,


Sections 1.0 throygh 4.0 of this report constitute the PreliminaryScreening of remedial alternatives. Altenatives that pass thescreening are then evaluated in greater detail in subsequentsections of the report. Sections 1.0 through 4.0 include a generaldescription of both the Spiegelberg and Rasmussen sites, a summaryof the areas of concern, chemicals of concern, and routes ofexposure as identified in the remedial investigation and risk'assessment, an identification of the Appropriate, Relevant, andApplicable Requirements (ARARs) for both the areas of concern andprocess options, as well as a step wise description of the processof remedial alternatives development.


o Identification of remedial action objectives for protectinghuman health and the environment.

o Identification of the remedial response actions that wouldmeet the remedial objectives.

o Identification of remedial technologies and process optionsassociated with the general response actions.

o The process options considered to be implementable arefurther evaluated with respect to effectiveness,implementability, and cost.

o The process options that pass the effectiveness,implementability, -and cost evaluation are assembled intoremedial action alternatives representing a range oftreatment, containment, and disposal combinations.

The detailed evaluation of alternatives is contained in Section5.0 and subsequent sections, and will include a more in-depth

EXECUTIVE SUMMARY- 1

evaluation of each assembled remedial action alternative withrespect to long and short term effectiveness, implementability,and cost, as well as ARAR considerations. Site wide comprehensiveremedies are also compiled to address all the potential threatsposed by the areas of concern; and a comparativeanalysis is conducted to obtain the preferred alternatives.



The Spiegelberg property consists of approximately 115 acres andis located in an area of moderately rolling topography. An areaon the northern part of the property was used for disposal of wastematerials as early as 1966. Domestic, industrial, and septicwastes have been disposed of at this site at least until 1977..Domestic wastes continue to be disposed of onsite, in smallquantities.

Gravel mining at this property predated 1940 and continues throughthe present time. Mining has caused alteration to the propertytopography since the topographic mapping performed for the RI in1984. Peat mining has also occurred on the property.

1.1.2 RASHOSSEN DOMP SITE DESCRIPTION

The Rasmussen property has the same general topographic featuresand geology as the Spiegelberg property except that it is whollylocated on hilly topography. The Rasmussen property consists ofapproximately 33 acres and is bounded on the west and south by theSpiegelberg property. The property is bounded on the east byprivate property belonging to another Rasmussen relative. SpicerRoad forms the northern boundary of the site.

The topography of the site has been altered by extensive mining ofsand and gravel. The pre-mining topography at the Rasmussenproperty was characterized by hilly topography, which rose to aridge-like crest in the southern portion of the property. The siteof environmental contamination extends across the southern half ofthe property.

The Rasmussen Dump Site, which was operated as the "Green OakTownship Dump" for a number of years, accepted both domestic andindustrial wastes in both solid and liquid form. Drummedindustrial wastes were disposed of, and drums were reportedly piledin several areas of the dump site. In addition, bulk disposal ofindustrial liquids was also reported to have occurred on site.According to MDNR files, a pond used for liquid industrial waste


existed on site during 1967 and 1968.

The Rasmussen Site began gravel mining operations in the 1970 's.The mining eventually undermined substantial portion of the dumparea. Currently, about 10 feet of landfilled materials, primarilydomestic wastes, are exposed along the vertical face of the gravelpit excavation.

The gravel mining on site also caused the movement and redisposalof drums containing wastes. Drums were apparently moved to thetop of the dump and pushed over the side of the hill. The actionsapparently crushed drums and mixed the drums with soils.

The Green Oak Dump waste materials are referred to in this documentas the Municipal Landfill, and the soil materials covering portionsof the landfill are the "Top of the Municipal Landfill."

In October and November 1984, the USEPA, Emergency Response Team,removed drums that were observable on top of the dump, as well asdrums on the lower slope and base of the dump. In addition,approximately 250 cubic yards of soils contaminated with PCBs wereremoved from the top of the dump and from the base of the hillbelow the dump.

In June/ 1987 approximately 7000 cubic yards of sand and gravelwere removed from the Probable Drum Storage/Leakage/Disposal Areafor commercial and residential use off site. Testing of theexcavation and of the offsite sand and gravel from the excavationindicated the soils were contaminated. The sand and gravel thatwas placed off site was replaced on the Rasmussen Site fromNovember, 1987 through July, 1988.



The following documents form the major significant references forthis investigation:

1. Risk Assessment and Phased Feasibility Study of Alternatives,September, 1986 (NOS Corporation).

2. Remedial Design for Source Control, April 1988 (NUSCorporation) .

3. Remedial Investigation Report, September, 1988 (NUSCorporation) .


4. Risk Assessment, September, 1988 (NUS Corporation}

1.3 IDENTIFICATION OP AREAS OF CONCERN, CHEMICALS OFCONCERN, AND RODTES OF EXPOSURE

The 'Areas of Concern' are those areas where the RemedialInvestigation identified and confirmed the presence of hazardoussubstances on the Spiegelberg and Rasmussen Dump sites. The areaswhere hazardous substances are located are generally associatedwith past practices of disposal, redistribution and burning ofhazardous substances at various places on the sites. These areasare designated as 'Areas of Concern' because they pose a risk or"potential risk to human health and/or the environment, asestablished in the Risk Assessment. Groundwater contaminationplumes are considered separate areas of concern.

The areas of concern identified by the Remedial Investigation andRisk Assessment include the following:

Rasmussen Site -





o Groundwater Plume

Spiegelberg Site-

o Paint Sludge Area

o Groundwater Plume

The Spiegelberg Paint Sludge Area is also an area of concern;however, a separate Risk assessment. Phased Feasibility Study, andRemedial Design were completed for this area. The remedial actionwill involve excavating the buried wastes and contaminated soilsto the groundwater table-, then characterizing them as either wetor dry wastes and separating them. The wet wastes will then beincinerated and the dry wastes disposed of at a RCRA approvedlandfill. The implementation of the action is currently beingconsidered by a potential responsible party,


The 'Chemicals of Concern' are chose hazardous substances chatpresent the risk in each area of concern. Hazardous substancesare those chemicals, compounds and other substances defined inSection 101 (14) of Title I of the Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 (CERCLA). Thehazardous substances (contaminants) are identified in the RemedialInvestigation and their relative risk is evaluated in the RiskAssessment.

The 'Routes of Exposure* are the ways by which the chemicals ofconcern can reach humans and the environment, thereby causing therisks. The typical routes of exposure for humans specificallyaddressed in the Risk Assessment for the areas of concern are asfollows:

Dermal contact

Inhalation of fugitive dust

Accidental ingestion of soil

Ingestion of groundwater

Inhalation of vapors from groundwater in household use

The risk assessment established the risks for both the carcinogenicrisks and noncarcinogenic risks for potential ingestion andinhalation of vapors from groundwater use. Both the Rasmussen andSpiegelberg groundwater plumes exceeded the 10 -6 carcinogenic risklevel, and the acceptable noncarcinogenic risk levels for ahypothetical receptor (groundwater user) at Spicer Road. On thisbasis both the groundwater plumes are designated as areas ofconcern to be considered for remedial action.

1.4 PHYSICAL DESCRIPTIONS OP THE AREAS OF CONCERN

This section provides a brief physical description of each area ofconcern, including an estimate of the depth of contamination andthe volume of materials that may require excavation for remedialalternatives involving removal. The volume calculations wereperformed by Warzyn Engineers, Inc., and are provided in AppendixA of this document.

1.4.1 RASMUSSEN DUMP SITE - PROBABLE DRUMSTORAGE/LEAKAGE/DISPOSAL AREA

The Probable Drum Storage/Leakage/Disposal area consists of


sporadically contaminated soils, where contamination occurs inpockets and lenses as a result of apparent spillage and leakagefrom drums and/or bulk dumping. The soils are natural, in situsand and gravel with lenses of finer grained sandy silts. The areawas partially excavated by the owner in 1987, exposing contaminatedzones in the soils that appear to be associated with the finergrained silty lenses of soil. On the basis of this observation,the area probably contains large zones of uncontaminated to lowlevel soil contamination, with fewer, smaller zones of more highlycontaminated soils that serve as a continuing source of leachinginto the groundwater.

The Probable Drum Storage/Leakage/Disposal area is an area ofconcern because of risks posed by dermal contact from PCBs, andthe threat to groundwater. Contamination was confirmed by samplinggroundwater beneath this area using monitoring wells. Groundwaterdata shows that a significant amount of organic compounds haveleached from this area. The contaminant plume emanating from theProbable Drum Storage/Leakage/Disposal Area is designated theRasmussen Plume.


The Industrial Waste area consists of soils, paint sludge, somerefuse and a few drummed wastes that were deposited in the base ofthe Rasmussen gravel pit. The area is contiguous with the ProbableDrum Storage/Leakage/Disposal area. The area is of concern becauseof the threat from dermal contact due mainly to the PCBs, andthreat to the groundwater, Groundwater contamination beneath thisarea was confirmed by monitor well sampling.

The Industrial Waste area is adjacent to and could be consideredpart of the Probable Drum Storage/Leakage/Disposal area. However,both areas are distinctly different. The Industrial Waste areacontains actual waste materials {paint sludge, drums, etc.), whilethe Probable Drum Storage/Leakage/Disposal area consists mainly ofcontaminated soils resulting from spillage, leakage, and/or bulkdumping of drums.

1.4.3 RASMUSSEN DUMP SITE - NORTHEAST BURIED DRUM AREA

The Northeast Buried Drum area consists of drum wastes and mixedwaste soils that were pushed over the edge and side of the hillwhere the municipal landfill is located. The mixed waste soilsand drums are contiguous with the municipal landfill wastes.

The Northeast Buried Drum area is an area of concern mainly becauseof the dermal threat posed by the PCB's and dioxin in the surfacesoils, and the threat to groundwater posed by both the wastes and


contaminated soils. Some of the highest concentrations of organichazardous substances were found in this area, as indicated in Table1-1 in Section 1.3 of this report. Test pits excavated during theRemedial Investigation showed soils surrounding the buried drummedwaste to be highly stained with contamination.

1.4,4 RASMDSSEN DUMP SITE - TOP OF THE MUNICIPAL LANDFILL

The Top of the Municipal Landfill consists of fine grained, sandysoils that were originally placed as a cover for the municipalwastes, and were subsequently disturbed, by drum disposal andremoval, and soil removal. The soil cover was relatively thingenerally ranging from one to several feet thick where present.The cover was very thin in some portions of the fill wheremunicipal wastes were seen at the ground surface. In addition,municipal wastes are exposed along the north face of the fill whichwas excavated for the gravel pit, and along the hillside formingthe south face of the landfill.

The Top of the Municipal Landfill is an area of concern mainlybecause of the dermal threat posed by PCS and Dioxin in the surfacesoil; and the threat to groundwater from leaching through thecontaminated soils .

1.4.5 SPIEGELBERG AND RASMDSSEN DUMP SITES -GROUNDWATER CONTAMINANT PLUMES

The Spiegelberg site groundwater contamination plume originatesfrom the Spiegelberg Paint Sludge area. The Paint Sludge areasource will be removed at some future date, in accordance with theU.S. Environmental Protection Agency Record-of-Decision (ROD)signed on September 30, 1986. The risk posed by the plume is thepotential threat from ingestion and inhalation (household use) ofthe groundwater, mainly from methylene chloride, vinyl chloride,and 1 , 1-dichl or oe thane.

The Rasmussen Dump site groundwater contamination plume originatesfrom the Probable Drum Storage/Leakage/Disposal area and theIndustrial Waste area, which are contiguous. Both these areas areconsidered continuous, ongoing sources. The risk posed by theplume is the potential threat from ingestion and inhalation(household use) of the groundwater, mainly from methylene chloride,vinyl chloride, benzene, 1, 1-dichlo roe thane, 1, 1-dichloroethene,and trichloroethene.


The principal objective of remedial action is to eliminate and/or


reduce the threat or potential threat to human health and theenvironment posed by the areas of concern. Remedial actions are toaddress the specific threat posed in an area of concern, byconsidering the chemicals of concern and the routes of exposure.In addition, an estimate of the acceptable contaminant levels ismade to establish "action levels" in the applicable media (e.g.air, soil and groundwater.)

The Risk Assessment determined that the most significant route ofexposure where the risk exceeded the acceptable levels (HazardIndex greater than one or Cancer Risk greater than 10-6) wasthrough the ingestion of, or inhalation of vapors from potentiallycontaminated groundwater. The only other route of exposure thatexceeded the risk levels was dermal contact.

The Risk Assessment also determined that the risks associated withthe chemicals of concern for groundwater risks was greater thanthat for dermal contact, and that acceptable concentrations in soil(soil action levels) calculated for acceptable groundwater riskswould be lower than soil concentrations (soil action levels) foracceptable risks due to dermal contact. Therefore, the acceptableconcentrations in soil, as calculated for groundwater protection,can be used as the soil action levels for the remediation of eacharea.

Determination of the acceptable soil concentrations (soil actionlevels) was performed using several different assumptions duringthe Remedial Investigation and Risk Assessment. In all cases, thesoil action levels were determined using the revised "OrganicLeachate Model" and a linkage model to back-calculate soilconcentrations from assumed concentrations in the groundwater.


2.1 RASMOSSEN SITE REMEDIAL OBJECTIVES


The main threats posed by the buried drum area are potential dermalcontact and fugitive dust inhalation, and leaching of hazardoussubstances into the groundwater. Therefore, the remedial actionobjectives are to prevent dermal contact with,_-and inhalation of,hazardous substances with a greater than 1 x 10 cancer risk level,and prevent degradation of the groundwater environment by potentialleaching of organic contaminants.



The main threat posed by the top of the municipal landfill arepotential dermal contact and fugitive dust inhalation. Therefore,the remedial action objectives are to prevent dermal contact with,and-inhalation of, hazardous substances with a greater than 1 x10 cancer risk level.


The main threats posed by the Industrial Waste area are potentialdermal contact and fugitive dust inhalation, and leaching ofhazardous substances into the groundwater. Therefore, the remedial"action objectives are to prevent dermal contact with, and,inhalation of, hazardous substances with a greater than 1 x 10cancer risk level, and prevent degradation of the groundwaterenvironment by potential leaching of organic contaminants.


The main threats posed by this area are potential dermal contactand fugitive dust inhalation, and leaching of hazardous substancesinto the groundwater. Therefore, the remedial action objectivesare to: (1) prevent dermal contact with, agid inhalation of/hazardous substances with a greater than 1 x 10~ cancer risk level;and, (2) prevent degradation of the groundwater environment bypotential leaching of organic contaminants.


The main threat posed by the existing groundwater plume is thepotential risk for ingestion and inhalation due to household use,and the threat to the groundwater environment. The remedial actionobjective is to reduce or eliminate exposure of potential receptorsto contaminated groundwater and prevent further degradation of thegroundwater environment.

2.2 SPIEGELBERG SITE REMEDIAL OBJECTIVES

2.2.1 GROUNDWATER PLUME (SPIEGELBERG)

The main threat posed by the existing groundwater plume is thepotential risk for ingestion and inhalation due to household use,and the threat to the groundwater environment. The remedial actionobjective is to reduce or eliminate exposure of potential receptorsto contaminated groundwater and prevent further degradation of the


groundwater environment.

3.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

Under section 121(d)(2){A) of SARA, remedial actions must at leastattain a level or standard of control which attains any standard,requirement, criteria, or limitation under any Federalenvironmental law, including but not limited to, the ToxicSubstances Control Act, the Safe Drinking Water Act, the Clean AirAct, the Marine Protection, Research, and Sanctuaries Act or theSolid Waste Disposal Act determined to be legally applicable orrelevant .

SARA also requires that if any promulgated standard, requirement,criteria, or limitation under a State environmental or facilitysiting law is more stringent than any Federal standard,requirement, criteria, or limitation and is applicable or relevantand appropriate, the level or standard of control called for mustbe attained. Section 121 (d) (4) of SARA provides for waivers ofARARs under six different types of circumstances.

During the initial stages of the feasibility study potential ARAR'swere identified for both the Spiegelberg and Rasmussen sites. Thefirst ARARs examined are those that pertain to the specifichazardous compounds detected in the various areas of concern andgroundwater plumes at the sites. The chemical specific ARARs arepresented in Table 3-1.

The potential ARARs were then examined and evaluated to determinewhich ARARs may be applicable to the six areas of concern, basedon the location and type of media effected by the areas of concern.


Development of Remedial Action alternatives is a systematic methodused to identify the range of methods that could be used toeliminate or reduce the real or potential threat to human healthand the environment in the areas of concern on the Spiegelberg andRasmussen sites. A range of potential remedial alternatives weredeveloped for each area of concern. These alternatives werescreened for subsequent detailed evaluations in the detailedevaluation of alternatives.


General response actions are comprehensive actions, or remediesthat satisfy the remedial action objectives discussed previouslyfor each area of concern. The general response actions identifiedfor the Spiegelberg/Rasmussen site include the following:


No ActionInstitutional ActionsAlternative Water SuppliesContainmentRemovalOnsite TreatmentOffsite TreatmentOnsite DisposalOffsite Disposal

4.2 REMEDIAL TECHNOLOGIES AND PROCESS OPTIONS

Several general categories of potential remedial technologies wereidentified for each general response action. The process opcionsconsidered to be potentially applicable are further evaluated andscreened with respect to effectiveness, implementability, and costcriteria:

o Effectiveness - Several factors are considered in theeffectiveness evaluation. These include the potential forprocess options to handle estimated volumes of contaminatedmedia and meet contaminant reduction goals, protection ofhuman health and the environment during construction, andwhether or not the process option is proven and reliable forthe contaminants of concern and site conditions.

o Implementability - The implementability evaluation emphasizesthe institutional aspects of implementability, such as theability to obtain necessary approval from governmentagencies, the availability of treatment storage, and disposalcapacity, and the availability of equipment and skilledlabor.

o Relative Cost - Relative capital and operation andmaintenance (O&M) costs were estimated as high, medium, orlow for each process option. Cost estimates were made forcomparison purposes only and were based on engineeringjudgement and experience.

The remedial technologies and process options evaluated for theSpiegelberg and Rasmussen sites are discussed below:

4.2.1 NO ACTION

The no action response is required for consideration under the 40CFR 300.66, C.3 which is the Nation Contingency Plan (NCP). TheNo Action alternative is evaluated to estimate the effect of notperforming additional remedial actions at the site. The no action


alternative does not restrict the further migration of contaminantsnor does it reduce the toxicity, .-nobility or volume of thosecontaminants at any of the areas of concern where contamination hasbeen demonstrated to be a threat to human health and environmentat the sites.


Fencing-

Fencing is an established technique designed to minimize dermalcontact risks by deterring people from entering into contaminatedareas. An MDNR fence currently encompasses the areas of concernon the Rasmussen site.


Monitoring and analysis technologies will be used to assess theeffectiveness of remedial activities if permanent solutions arenot selected.

Since monitoring and analysis will not remediate the areas ofconcern or the groundwater plumes, the technologies are notretained for further evaluation as a stand-alone option.Monitoring and analysis is retained in conjunction with otherremedial options.


Since deed restrictions do not detoxify, reduce or eliminate thecontamination, and the restrictions may be difficult to implement,they are not retained as a stand-alone option for furtherevaluation. Deed restrictions may be considered in conjunctionwith other remedial actions.

4.2.3 ALTERNATIVE DRINKING WATER SUPPLY

At the present time, none of the residential or commercial drinkingwater wells in the vicinity of the Spiegelberg/Rasmussen site havebeen adversely affected by groundwater contamination from thesites. Alternative water supply technologies include:

Municipal Water System- -

Connection of residential homes to a municipal water system couldensure protection of the public from future use of contaminatedwater from the plumes, although no offsite water supplies arepresently effected.


This alternative does not detoxify, reduce or eliminate thecontamination, nor does it restrict the migration of thecontaminant plumes.

There are no municipal water systems in close proximity to thesite. The nearest system is the Saxon-Wilmore system locatedapproximately 3.5 miles north of the site along Lee Road betweenU.S. 23 and Rickett Road, This system serves a small residentialdevelopment and does not have the available capacity to supplywater to the residences surrounding the Spiegelberg/Rasmussen site.

Since municipal water supply does not remediate the existingplumes, and the nearest reasonable municipal water supply can notsupport the area that would require connection, connection to anexisting municipal system is screened from further consideration.

Bottled Water, Above-ground Tanks, Individual Treatment Systems-Supply of residential homes to bottled water, tanks or individualtreatment systems could ensure protection of the public from futureuse of contaminated water from the plumes.

Bottled water, above ground tanks and individual treatment systemsare alternatives that do not reduce, detoxify or eliminate thecontamination, nor do they restrict the migration of the existingcontaminant plumes. These alternatives are most commonly used foremergency water supply when a water supply has been contaminated.To date, offsite water supply wells have not been affected bygroundwater contamination from the Spiegelberg or Rasmussen sites.

On the basis of these options being more appropriate as temporaryoptions, and that they do not remediate the contamination, theseoptions are not retained as stand-alone options.

Deeper or Op-gradient Water Supply Wells-

Construction and use of deeper or up-gradient water supply wellsas a source of potable water for onsite or nearby residents doesnot detoxify, reduce or eliminate the contamination, nor does itrestrict the migration of the existing plumes. The hydrogeologyof the Spiegelberg site, is not conducive to constructing deeperwells, but placement of upgradient wells are possible. Thehydrogeology of the Rasmussen dump site would allow for deeperwells, but the property lines and existence of the municipallandfill in most up-gradient locations on the Rasmussen propertymay preclude up-gradient wells.


If deeper or up-gradient wells were to be further considered, anextensive groundwater investigation and pumping test would berequired near proposed well locations to ensure the existingcontaminant plumes would not be drawn to the wells.

4.2.4 CONTAINMENT

Surface Capping-

Clay and Multi-media Caps

Capping technologies are used to minimize infiltration, to reduceoffsite transport of exposed water materials, and to minimizedirect contact with contaminated materials. Surface capping doesnot eliminate or detoxify the source of contamination. Claycapping involves installation of a compacted clay layer over thewastes and includes an overlying layer of topsoil and vegetativecover to protect the cap.

The following types of capping materials or combinations thereof,are retained for further consideration based on technical criteria:

o Synthetic membranes

o Clay

Construction of this process option would be easy to implement atall the areas of concern. Considerable grading to achieve stableslopes would be required at the Northeast Buried Drum area and theProbable Drum' Storage/Leakage/Disposal areas, as well as on theperimeter of the Top of the Municipal Landfill. This processoption, which includes both a clay cap or a. multi-media cap, isretained for further detailed evaluation.

Vertical Barriers

Vertical barriers may be utilized to prevent migration ofcontaminated groundwater from a site and/or prohibit lateral(horizontal) groundwater flow through a waste disposal orcontaminated soil area. Vertical barriers do not eliminate ordetoxify the source of contamination.

Since groundwater on both the Spiegelberg and Rasmussen sites isnot flowing laterally through the wastes in any of the waste areas,vertical barriers would not be applicable for remediation ofcontaminated soils.


Vertical barriers would also not be applicable for the remediationof contaminated groundwater on the Spiegelberg site due to the lackof a continuous clay layer and the considerable depth to bedrockon this site. Although vertical barriers could be used to containcontaminated groundwater on the Rasmussen site, they would only beeffective when used in conjunction with a removal and treatmentsystem. Furthermore, use of vertical barriers along with removaland treatment would not provide significantly greater effectivenessthan removal and treatment alone. Therefore, vertical barriers arescreened from further consideration.

Block Displacement Grouting

Encapsulation of the waste material may be achieved by the blockdisplacement method which involves installing side and bottombarriers consisting of a bentonite slurry. This method is onlyapplicable above the water table. The encapsulation does noteliminate or detoxify the source of contamination.

Use of block displacement method would necessitate a surface capand leachate collection system for the small amount of leachatethat may enter the encapsulated zone. The block displacementmethod is experimental and has been attempted on several sites, asa demonstration project, with mixed success.

This technology is not applicable to the Top of the MunicipalLandfill (too shallow), or the Northeast Buried Drum area and theProbable Drum Storage/Leakage/Disposal area (too much variation indepth of overburden). This technology could be applicable to theIndustrial Waste area, but the uncertainty of successfulimplementation of the method due to site geology, and the fact thatit is not applicable to the other areas of concern reduce itsviability as an option. Block displacement grouting will not beretained in lieu of other options that are more applicable to theother areas of concern, thereby allowing selection of morecomprehensive remedial options that can be used for several areasof concern.

4.2.5 REMOVAL

Excavation

Excavation of the buried contaminated waste would be effective asa source control measure and would eliminate or reduce furthercontaminant migration associated with the waste. However,excavation alone does not reduce the volume or toxicity of thewastes, and must be used in conjunction with other technologies tohandle the excavated material. Excavation is a standard andreliable technology frequently used on waste disposal sites.


Excavation, when used in conjunction with incineration, onsite oroffsite disposal, or onsite or offsite treatment will minimize anylong-term effects of the contaminants at the site. Excavation isretained as a technology to be used in conjunction with otherremedial process options.

Groundwater Pumping

Groundwater pumping can be used to lower the water table, containand extract a contamination plume, reinject treated groundwater,or discharge groundwater offsite.

One or more groundwater extraction wells are commonly used to lowerthe water table and/or contain a contaminated plume.

Groundwater pumping will require treatment and handling of thedischarge water. Discharges to the surface water will requireattaining discharge concentrations of contaminants that comply withlevels established for National Pollution Discharge EliminationSystem (NPDES) limits.

Groundwater pumping and remediation may also require monitoring ofdown gradient residential wells. MDNR will consider monitoringwells within 1/2 mile down gradient from the site.

Pumping technologies are applicable to the Spiegelfaerg/Rasmussensite. Subsurface conditions and aquifer characteristics willdetermine the quantity of groundwater that can be pumped. Theoptimum location of groundwater purge wells, estimation ofdischarge rates and time required for plume remediation willrequire groundwater modeling and additional aquifer testing.Groundwater pumping, in conjunction with water treatment, isretained for further evaluation.

4.2.6 ONSITE TREATMENT

Thermal TreatmentIncineration

Mobile incinerators have-been developed for onsite use that operateas effectively as offsite facilities. Mobile incinerators can beused to reduce or eliminate organic compound contamination insoils, wastes and water. At this time, the rotary kiln is the onlytype of incinerator commercially available as a mobile unit.


Onsite incineration is applicable to the Spiegelberg/Rasmussen siteand is retained for further evaluation.

Infrared Incineration

Infrared incineration systems destroy organic compoundcontamination in soils, wastes and water through thermal oxidation,using infrared energy as the primary heat source. Infraredincineration may be applicable to the Spiegelberg and Rasmussensites and is retained for further evaluation.

Immobilization

Solidification

Solidification technologies typically involve the mixing of wasteconstituents with materials that physically and/or chemicallyincorporates the waste into a solid, relatively impermeable mass.The process is designed to reduce the rate of contaminant leachingand volatilization from the wastes.

Solidification technologies may be applicable to areas of theSpiegelberg/Rasmussen site that have elevated levels of PCS andheavy metal contamination.

Solidification methods may also be useful for treating incinerationresidue. Therefore, they are retained for further evaluation.

Vitrification

Vitrification is a process of solidification using extremely hightemperatures to fuse contaminated soils into a solid, impermeablemass.

The topography of the Northeast Buried Drum and the Probable DrumStorage/Leakage/Disposal areas are not appropriate forvitrification. The Top of the Municipal Landfill is too shallowfor effective electrode placement. The method may be applicableto the Industrial Waste area, however, this technology does notproduce substantially greater benefits than other proventechnologies. The equipment used is unproven on a large scalebasis. Long term leaching of organic contaminants is uncertain andthe control of volatilized organics during the process may bedifficult. Therefore, vitrification is screened from furtherevaluation at the Spiegelberg/Rasmussen site.


Physical Treatment

Soil Flushing-

Soil flushing is a processes that use solvents to extractcontaminants from soils and sludge. Soil flushing is an in-situmethod that mimics the natural infiltration process. Flushingfluids are introduced to the soils via leach-fields, injectionwells, or recharge trenches and are allowed to percolate throughthe waste material to the water table. The leachate is thenextracted through the use of pumping wells, treated, andrecirculated. Soils and sludge may need several flushing/washingcycles for effective contaminant removal.

The effectiveness of in-situ soil flushing may be limited by a lackof subsurface process control. The effectiveness of soil flushingis suspect in areas where soils contain high to moderatepermeability sands and gravels interlayered with low permeabilitysilts and clays. Introduction of the solvents to the ground forthe flushing is also the creates the potential for soil andgroundwater contamination.

Soil flushing is not retained for further evaluation on the basisof the observed layered geology that may impede the flushingprocess, the potential for creating further contamination of thegroundwater by the process, and the lack of process control.

Soil Washing

The soil washing process involves placing excavated soils or sludgeinto a liquid/solid container (e.g. cement mixer, pug mill, countercurrent extraction equipment) along with the extraction solvent.Following extraction the solvent is treated to remove contaminationand recycled through the washing unit. The clean soil can be usedto backfill the excavation.

Soil washing systems furnish a greater degree of process controlthan in-situ methods. Soil washing technologies may be applicableto the Spiegelberg/Rasmussen site when used in conjunction withother remedial technologies, and are retained for futureevaluation.

Soil Aeration

Soil aeration is a process that uses air stripping to detoxifysoils contaminated with volatile organics. Several differentsystems are available and include enclosed mechanical aeration,pneumatic conveyor, and low temperature thermal stripping.


Soil aeration is applicable to both volatile and semi-volatileorganic chemicals, but not to PCS or dioxin. Pilot testing willbe required to determine the effectiveness of the method.

Soil aeration is not applicable as a stand-alone option for thefour areas of concern (Top of the Municipal Landfill, Probable DrumStorage/Leakage/Disposal, Northeast Buried Drum, and IndustrialWaste areas) because they contain PCS and dioxin. However,aeration might be used on portions of the soils that arecontaminated only by volatile organic compounds. Such soils mayexist in the Probable Drum Storage/Leakage/Disposal area, andbeneath the wastes in the Industrial Waste area. Therefore, theoption is screened out for the Top of the Municipal Landfill andNortheast Buried Drum areas; and retained in conjunction with other-options for the Probable Drum Storage/Leakage/Disposal and beneaththe Industrial Waste areas.

Air Stripping (Groundwater)-

Air stripping is a mass transfer process that uses a high volumeair flow to remove volatile organic contaminants from thegroundwater or waste water. This technology is applicable fortreatment of the contaminated Spiegelberg groundwater plume. TheRasmussen groundwater plume contains high concentrations ofkeytones which are not readily removed by air stripping, precludingthe option as a stand-alone remedial action. Therefore, airstripping is not retained as a stand-alone option, but is retainedas an option in conjunction with other groundwater treatmenttechnologies.

Chemical Treatment

Dechlorinatiori

Dechlorination is a process that involves the addition of an alkalimetal and polyethylene glycol (PEG) reagent to remove chlorineatoms from chlorinated organic compounds (PCB's, dioxins).

Dechlorination could be applicable to the Rasmussen site, however,the testing required to demonstrate the process, the handling ofthe by-products produced by the process, and its relative high costmake other equally effective options more attractive.

Activated Carbon Adsorption

Activated carbon adsorption is widely used process that involvescontacting an aqueous or gaseous waste stream with activatedcarbon, which adsorbs or bonds organic molecules onto its surface.


The activated carbon adsorption process is applicable to theSpiegelberg/Rasmussen site when used in conjunction with othertechnologies. It is retained for further evaluation.

Biological Treatment

Biological treatment employs naturally occurring processes thatutilize microbial metabolism to degrade organic contaminants(biodegradation).

The basic biodegradation treatment processes include aerobic andanaerobic treatment:

Aerobic Biodegradation

Aerobic treatment consists of conventional activated sludgeprocesses, trickling filters, and rotating biological contactors.A brief discussion of each of these processes is as follows:

o Activated Sludge Process

The activated sludge process is applicable to theSpiegelberg/Rasmussen site, when used in conjunction with agroundwater pumping system.

o Trickling Filter System

Since, the trickling filter is extremely sensitive to temperatureand difficult to control, it is screened from furtherconsideration.

o Rotating Biological Contactors

Rotating biological contactors (RBC's) have been demonstrated tohave excellent treatment efficiencies, but shaft breakage andfailure has been a chronic problem.

Rotating biological contactors {RBC's) are screened from furtherconsideration because of the problems with maintenance.

Anaerobic Siodegradation

Anaerobic treatment systems biologically degrade organic compoundsin the absence of oxygen to produce carbon dioxide and methane gas.


Anaerobic systems are screened from further consideration due totheir sensitivity to non-uniform waste streams and long retentiontimes. The production of methane gas may be a problem if it cannotbe utilized as an energy source.

in-situ Treatment

Vacuum Extraction

Vacuum extraction consist of high volume pumping of soil gas usinga network of wells positioned in the zone of soil contamination.Air is pulled through the wells, strips volatile organiccontaminants from the soils, and is subsequently fed to an airpollution control device for treatment. It is not effective formetals, PCB's, dioxins and base and acid extractable organics.

The vacuum extraction process is not applicable to the Top of theLandfill, Buried Drum area, Probable Drum Storage/Leakage/Disposalor Industrial Waste area because of the presence of PCBs anddioxins (landfill and drum storage areas), and high concentrationsof organic in wastes and drums (buried drum and industrial wasteareas). The method may be applicable in removing soil contaminantsin soils beneath the wastes in the Northeast Buried Drum andIndustrial Waste areas, but it is not a stand-alone option and mustbe used in conjunction with other technologies. Since equallyeffective options are more comprehensive in application, the vacuumextraction option is screened from further consideration.

In-situ Biodegradation

In-situ biodegradation involves using native or mutant strains ofaerobic bacteria to degrade organic compounds in the soils andgroundwater.

An in-situ biodegradation system may have to be operated forseveral months, and final results may not be apparent for one totwo years. Pilot testing will be required to demonstrate theeffectiveness of the system.

Since the process control is poor with in-situ biodegradation, andcontaminants may be widely and intermittently dispersed in the soilmedia, in situ biodegradation is screened out.

4.2.7 OFFSITE TREATMENT

Thermal Treatment


Incineration-

Incineration is a process that uses thermal oxidation to convertorganic substances to a less bulky inorganic material. Generally,only organic and combined inorganic-organic wastes are consideredfor incineration. At present, there are only a few commercialfacilities permitted under RCRA interim status. Lack of availablecapacity at an incineration facility could cause delays in thetransport and subsequent disposal of waste materials from the site.

Offsite incineration is retained for further evaluation. It is aproven effective technology for reducing the volume, toxicity, andmobility of wastes containing organic contaminants and PCB's.

4.2.8 ONSITE DISPOSAL

Onsite disposal necessitates the construction of a secure hazardous, waste landfill. Elements of such a site must meet the applicable

RCRA requirements and regulations (40 CFR 264.300 - 264.317) andmeet the requirements of the Michigan Solid Waste Management Act(Act 64) and Hazardous Waste Management Act (Act 307).

The Michigan Solid Waste Management Act regulations are morestringent than federal RCRA standards. If this regulation isstrictly adhered to, the Spiegelberg/Rasmussen properties would notsatisfy this requirement due to the sandy nature of the existingsoils. In addition, the Michigan regulation requires 150 metersset-back of the facility from the property lines. This regulationwould make placement of a facility that would handle the Top of theMunicipal Landfill soils not implementable.

If excavation and onsite disposal is selected for more than onearea, excavated material can be consolidated and disposed of inone RCRA landfill facility in the interest of practicality andcost-effectiveness.

In order to meet the requirements of the National Contingency Plan(NCP) and EPA technical guidance, if offsite disposal is evaluatedas a remedial alternative, then onsite disposal must also beevaluated. Therefore, onsite disposal in a RCRA-approved facilityis retained for further evaluation at the Spiegelberg/RasmussenSite.

4.2.9 OFFSITE DISPOSAL

Landfill disposal of solid waste material can be implemented off


site in an existing landfill. Offsite disposal involves excavationof all soils, drums, or sludge contaminated in excess of the targetcriteria and transport of material to the nearest approved RCRApermitted hazardous waste disposal facility. Commercial disposalfacilities must meet stringent 3CRA, and state permitting andcompliance standards.

The implementation of RCRA land restrictions (Part 268) is ofparticular impact to this site since the wastes contain restrictedwastes, or wastes that will soon be restricted. Certain hazardoussubstances, including liquid wastes and solid wastes specified inPart 268, are subject to land disposal restrictions according toa schedule set by the regulation. The land restrictions in RCRAmust be considered for each area of concern during the detailedevaluation of alternatives.

Offsite disposal is retained for further consideration for theareas of concern.

Removal to a POTW-This process would involve removing contaminated groundwater andplumbing it to a publicity owned treatment works (POTW) fortreatment. The nearest POTW is approximately 1.5 miles south ofthe site and located north of eight mile road just west of LemenRoad.

This option is retained for further evaluation for both theSpiegelberg and Rasmussen groundwater plumes.

Removal to a Treatment Facility-

This process would involve pumping contaminated groundwater intotank trucks for transport to a commercial treatment facility.Licensed hazardous waste transporters are required to haul thematerial to the treatment facility.

This option is applicable to the Spiegelberg/Rasmussen site andretained for further evaluation.

4.3 ASSEMBLY OP ALTERNATIVES

The process options that passed the effectiveness,implementability, and cost evaluation were assembled into remedialaction alternatives for each area of concern. The assembledprocess options are listed in Table ES-1 for each soil and wastearea of concern; and in Table ES-2 for each groundwater plume.The alternatives listed in Tables ES-1 and ES-2 are passed to thenext step of the Feasibility Study (Detailed Evaluation), which


involves a more detailed evaluation of implementability and costto allow further screening.


TABLE ES-1

ASSEMBLY OF REMEDIAL ACTION ALTERNATIVES(SOIL AND WASTE AREAS OF CONCERN)

Alternative _______Assembled Process Options___

A NO ACTION

B CLAY CAP/RESTRICTED ACCESS

C MULTI-MEDIA CAP/RESTRICTED ACCESS

D EXCAVATION/ON-SITE DISPOSAL

E EXCAVATION/OFF-SITE DISPOSAL

F EXCAVATION/ON-SITE INCINERATION/ON-SITESOLIDIFICATION

G EXCAVATION/ON-SITE INCINERATION/OFF-SITEDISPOSAL

H EXCAVATION/OFF-SITE INCINERATION/OFF-SITE DISPOSAL

I EXCAVATION/SOIL AERATION/ON-SITESOLIDIFICATION

J EXCAVATION/SOIL WASHING/OFF-SITEDISPOSAL OF METAL RESIDUE, BACKFILL ON-SITE.

APPLICATION OF ASSEMBLED ALTERNATIVES TO THE AREAS OF CONCERN

PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREA- A through J

INDUSTRIAL WASTE AREA- A through J

NORTHEAST BURIED DRUM AREA- A,B,C,D,E,F,G,H,J

TOP OF THE MUNICIPAL LANDFILL- A,B,C,E,F,G,H,J


TABLE ES-2

ASSEMBLY OF REMEDIAL ACTION ALTERNATIVES(GROUNDWATER PLUME AREAS OF CONCERN)

Alternative _______Assembled Process Options____

A NO ACTION

B MONITORING AND ANALYSIS

C DEED RESTRICTIONS

D EXTRACTION WELLS/AIR STRIPPING

E EXTRACTION WELLS/CARBON ADSORBTION

F EXTRACTION WELLS/CARBON ADSORBTION/AIR STRIPPING

G EXTRACTION WELLS/BIODEGRADATION

1 DISCHARGE TO GROUNDWATER VIA INJECTIONWELLS

2 DISCHARGE TO GROUNDWATER VIA SEEPAGELAGOONS

3 DISCAHRGE TO SURFACE WATER OTHER THANHURON RIVER

ASSEMBLED REMEDIAL ACTION ALTERNATIVES BY GROUNDWATERPLUME

RASMUSSEN PLUME- A,B,C,E,F,G with 1 or 2 or 3

SPIEGELBERG PLUME- A through G with 1 or 2 or 3


1.0 INTRODUCTION

Preliminary screening of the remedial action alternatives describesthe process for the development of remedial action alternatives forthe Spiegelberg and Rasmussen Dump sites located in Livings tonCounty, Michigan.

Each of these sites are separate federal National Priority List(NPL) sites as assessed under the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA) and theSuperfund Amendments and Reauthorization.Act (SARA) collectivelyreferred to as Superfund.

Sections 1.0 through 4.0 includes a general description of boththe Spiegelberg and Rasmussen sites, a summary of the areas ofconcern, chemicals of concern, and routes of exposure as identifiedin the remedial investigation and risk assessment, anidentification of the Appropriate, Relevant, and ApplicableRequirements (ARARs) for both the areas of concern and processoptions, as well as a step wise description of the process ofremedial alternatives development.


o Identification of remedial action objectives for protectinghuman health and the environment. Remedial action objectivesaimed at protecting human health should specify both acontaminant of concern and an exposure route. For example,a human health remedial objective may be to prevent ingestionof water having benzene in excess of 0.005 mg/1. Remedialaction objectives related to environmental protection mayseek to preserve or restore a resource or protect plant oranimal populations. An example of a environmental relatedobjective may be to restore a groundwater aquifer tobackground concentrations for benzene.

o Identification of the remedial response actions that wouldmeet the remedial objectives. These may include such generalresponse actions as treatment, containment, excavation,disposal, or a combination of these. General remedialresponse actions are initially defined during the remedialinvestigation and are refined as more information about thesite is obtained.

o Identification of remedial technologies and process optionsassociated with the general response actions. Remedialtechnologies refer to general categories of technologies suchas surface capping, thermal treatment or onsite disposal.For example, under the containment response action severaltechnologies could be identified such as surface capping,vertical barriers, and horizontal barriers.

Similarly, process options refer to specific processes withineach remedial technology. For example, the vertical barriertechnology would include such process options as slurrytrench walls, grout curtains, and steel sheet piling.

Once identified, the remedial technologies and processoptions are evaluated and screened based on potentialapplicability. The evaluation eliminates from furtherconsideration those process options and/or technologies chatcan not be effectively applied to the site. For instance,rotary kiln incineration would not be applied as a treatmentfor metals contamination in soils since this typeincineration does not destroy or detoxify metals.

o The process options considered to be implementable arefurther evaluated with respect to effectiveness,implementability, and cost. Consideration to be made duringthis evaluation include the effectiveness of a process optionto handle estimated volumes of contaminated media and protecthuman health and the environment, the ability to obtain anecessary approvals and permits, and relative capital,operation and maintenance costs.


The detailed evaluation of alternatives is contained in Section5.0 and subsequent sections, and will include a more in-depthevaluation of each assembled remedial action alternative withrespect to long and short term effectiveness, implementability/and cost, as well as ARAR considerations. Site wide comprehensiveremedies are also compiled to address all the potential threatsposed by the areas of concern; and a comparativeanalysis is conducted to obtain the preferred alternatives.



The Spiegelberg property consists of approximately 115 acres andis located in an area of moderately rolling topography, as shownon Figure 1-1 of the Remedial Investigation Report (September1988). The property and vicinity are characterized by relativelyflat areas on the southern portion of the site and beyond the siteboundaries, and by the rolling, hilly area that comprises most ofthe property. The property is underlain by glacial depositsconsisting of sand and gravel, which was, and continues to be,commercially mined.

An area on the northern part of the property was used for disposalof waste materials as early as 1966. Domestic, industrial, andseptic wastes have been disposed of at this site at least until1977. Domestic wastes continue to be disposed of onsite, in smallquantities.

Gravel mining at this property predated 1940 and continues throughthe present time. Mining has caused alteration to the propertytopography since the topographic mapping performed for the RI in1984. Peat mining has also occurred on the property.


The Rasmussen property has the same general topographic featuresand geology as the Spiegelberg property except that it is whollylocated on hilly topography. The location of the Rasmussenproperty is shown in Figure 1-1 of the Remedial InvestigationReport (September, 1988). The Rasmussen property consists ofapproximately 33 acres and is bounded on the west and south by theSpiegelberg property. The property is bounded on the east byprivate property belonging to another Rasmussen relative. SpicerRoad forms the northern boundary of the site. The topography ofthe site has been altered by extensive mining of sand and gravel.The pre-mining topography at the Rasmussen property wascharacterized by hilly topography, which rose to a ridge-like crestin the southern portion of the property. The site of environmentalcontamination extends across the southern half of the property.

The Rasmussen Dump Site, which was operated as the "Green OakTownship Dump" for a number of years, accepted both domestic andindustrial wastes in both solid and liquid form. Drummedindustrial wastes were disposed of, and drums were reportedly piled

in several areas of the dump site. In addition, bulk disposal ofindustrial liquids was also reported to have occurred on site.According to MDNR files, a pond used for liquid industrial wasteexisted on site during 1967 and 1968.

Beginning in 1967, repeated attempts were made to either brir.g thedump into compliance with state laws or to shut it down. The dumpwas closed in 1972, and wastes were no longer allowed to bedisposed onsite. During operation of the dump, numerous instancesof burning were reported. One fire involved substantial amountsof industrial wastes and burned our of control for 3 days.

The Rasmussen Site began gravel mining operations in the 1970's.The mining eventually undermined substantial portion of the dumparea. Currently, about 10 feet of landfilled materials, primarilydomestic wastes, are exposed along the vertical face of the gravelpit excavation.

The gravel mining on site also caused the movement and redisposalof drums containing wastes. Drums were apparently moved to thetop of the dump and pushed over the side of the hill. The actionsapparently crushed drums and mixed the drums with soils.Inspection of the site by MDNR in December 1979 reported about 75drums filled with solids and 300 crushed drums. Drum sampling bythe MDNR in October 1981, revealed PCBs in concentrations of640,000 parts per billion (ppb) near a pile of drums, and lesserconcentrations at other locations in the immediate vicinity.

The Green Oak Dump waste materials are referred to in this documentas the Municipal Landfill, and the soil materials covering portionsof the landfill are the "Top of the Municipal Landfill."

Groundwater monitoring wells were installed by MDNR on theSpiegelberg and Rasmussen Sites in 1981. Wells on the Spiegelbergproperty but in close proximity to the western property line of theRasmussen property showed low levels of organic contamination atthat time.

in October and November 1984, the USEPA, Emergency Response Team,removed drums that were observable on top of the dump, as well asdrums on the lower slope and base of the dump. In addition,approximately 250 cubic yards of soils contaminated with PCBs wereremoved from the top of the dump and from the base of the hillbelow the dump.

In June, 1987 approximately 7000 cubic yards of sand and gravelwere removed from the Probable Drum Storage/Leakage/Disposal Areafor commercial and residential use off site. Testing of theexcavation and of the offsite sand and gravel from the excavationindicated the soils were contaminated. The sand and gravel thatwas placed off site was replaced on the Rasmussen Site from

November, 1987 through July, 1988.



Information from the following documents, reports, and technicalmemoranda was used during the preparation of the feasibility study:

1. Risk Assessment and Phased Feasibility Study of Alternatives,September, 1986 (NUS Corporation).

2. Mobile Treatment Technologies for Superfund Wastes,September, 1986 {U.S. Environmental Protection Agency).

3. Remedial Design for Source Control, April 1988 (NUSCorporation).

4. Remedial Investigation Report, September, 1988 (NUSCorporation).

5. Risk Assessment, September, 1988 (NUS Corporation).


The "Areas of Concern' are those areas where the RemedialInvestigation identified and confirmed the presence of hazardoussubstances on the Spiegelberg and Rasmussen Dump sites. The areaswhere hazardous substances are located are generally associatedwith past practices of disposal, redistribution and burning ofhazardous substances at various places on the sites. These areasare designated as "Areas of Concern' because they pose a risk orpotential risk to human health and/or the environment, asestablished in the Risk Assessment. Groundwater contaminationplumes are considered separate areas of concern, even though thesource of contamination is leaching from an area of concern,because groundwater remediation is evaluated separately from sourcecontrol remediation in the remedial evaluation process.

The areas of concern identified by the Remedial Investigation andRisk Assessment include the following:

Rasmussen Site -





o Groundwater Plume

Spiegelberg Site-

o Paint Sludge Area

o Groundwater Plume

The Spiegelberg Paint Sludge Area is also an area of concern;however, a separate Risk assessment, Phased Feasibility Study, andRemedial Design were completed for this area. The remedial actionwill involve excavating the buried wastes and contaminated soilsto the groundwater table, then characterizing them as either wetor dry wastes and separating them. The wet wastes will then beincinerated and the dry wastes disposed of at a RCRA approvedlandfill. The implementation of the action is currently beingconsidered by a potential responsible party.

The Risk Assessment (September, 1988) also identified the "BermArea" on the Rasmussen site as an area of concern. The area hadcontained several isolated drums and an associated small area ofcontaminated soil. The drums were removed by the EPA immediateremoval, and the soils were subsequently removed. Therefore, theBerm Area is not considered in this Feasibility Study.

The * Chemicals of Concern' are those hazardous substances thatpresent the risk in each area of concern. Hazardous substancesare those chemicals, compounds and other substances defined inSection 101 (14) of Title I of the Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 (CERCLA). Thehazardous substances (contaminants) are identified in the RemedialInvestigation and their relative risk is evaluated in the RiskAssessment.

The "Routes of Exposure-' are the ways by which the chemicals ofconcern can reach humans and the environment, thereby causing therisks. The typical routes of exposure for humans specificallyaddressed in the Risk Assessment for the areas of concern are asfollows:

Dermal contact

Inhalation of fugitive dust

Accidental ingestion of soil

Ingestion of groundwater

Inhalation of vapors from groundwater in household use

Tables 1-1 through 1-4 summarize the Chemicals of Concern for thefour areas of concern where the contaminants are in the soil and/orwaste matrix (all areas except the groundwater plumes). The RiskAssessment (September, 1988) determined that the main chemicals ofconcern for these four areas were organic compounds. Column (1)in Table 1-1 through 1-4 lists the organic compounds that arehazardous substances that were detected in each of the four areasof concern. Columns (2) and (3) provide the maximum and arithmeticaverage concentrations found for the compounds.

Tables 1-1 through 1-4 also summarize which of the organiccompounds contribute most to the threat to public health and cheenvironment. The relative importance of each compound incontributing to the risks was estimated using the Hazard Indicesand Carcinogenic Risks calculated for each compound detected inthe areas of concern, as provided in Appendices B, C, and D of theRisk Assessment (September, 1988.) The compounds contributing mostto the risks are indicated in Columns 4 and 5 of Tables 1-1 through1-4.

Column (4) delineates those individual compounds that-exceed the10~ carcinogenic risk level for dermal exposures (10

TABLE 1-1

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISKNORTHEAST BURIED DRUM AREA

RASMUSSEN DCJMP SITE

£D

Chemical of Concern

1,1,1-Trichloroethane1,1-Dichloroethane2,3,7,8,-TCDD (dioxin)2-Methylnaphthalene2-Butanone4,4'-DOTAcetoneBenzeneBis(2-Ethylhexyl)Pht.Butyl Benzyl PhthalateChlorobenzeneDi-N-Butyl PhthalateDi-N-Octyl PhthalateEthylbenzeneFloureneIsophoroneMethylene ChlorideNaphthalenePCBsPhenanthrenePhenolStyreneTetrachloroetheneTolueneTrichloroetheneTotal Xylenes

(2)Maximum Cone.

(uq/kq)

(3) (4)Average Cone. Exceeds Risk

(ug/kg) (see notes)

8501000

4609,700

4,00054210530

2,60019017

21,000710100500

1,30022,0322,900

4540,000

5430,000

34017,000

,000,000.061,000,000520

,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000

1,94050,0060.0256,600

3,435,537

999,030

42,00092,286515,26332,04511,800

1,900,000

47,000137,000179,469

2,590,000361,000

13,702,00018,003

4,780,11492,838

4,630,328

**+ **

**

******

**

**

**

*******

Notes:Column (4) indicates the compound exceeded either the one additional

case in 100,000 risk for cancer (10E-6), or was a significant contributor tothe noncarcinogenic "hazard index", as defined in the Risk Assessment(September, 1988.)

One asterisk (*) indicates risk levels modeled for groundwater wereexceeded using maximum concentrations only, and two asterisks (**) indicaterisk levels modeled for groundwater were exceeded using maximum and averageconcentrations.

The plus sign (+) indicates the cancer risk level (10E-6) was exceededfor dermal contact.

TABLE 1-2

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISKTOP OF MUNICIPAL LANDFILL

RASMUSSEN DUMP SITE

U) (2) (3) (4)Maximum Cone. Average Cone. Exceeds Risk

Chemical of Concern (ug/kg) (uq/kgj (see notes)

1.1.1-Trichloroethane 9 21.1.2-Trichloroethane 42 71,1-Dichloroethane 6 1Trans-l,2-Dichloroethene 8 22,3,7,8,-TCDD (dioxin) 0.002 0.0072-Methylnaphthalene 4,000 3,7202-Butanone 30 5 *4-Methylphenol 1,700 633Acetone 300 57 *Benzene 11 3 *Benzole acid 2,000 667Benzo(a)Pyrene 500 83 •*-Bis(2-Ethylhexyl)Pht. 14,000 3,430 **Butyl Benzyl Phthalate 218 36Carbon Disulfide 215 37Chlorobenzene 980 259 *Chloroform 6 3 **Di-N-Butyl Phthalate 10,000 2,970Di-N-Octyl Phthalate 1,400 253Ethylbenzene 1,600 458 *Indeno(l,2,3-cd)Pyrene 500 83Isophorone 3,000 500Methylene Chloride 450 181 **Naphthalene 13,000 3,720N-Nitrosodiphenylamine 3,000 583 **PCBs 61,000 16,500 + **Pentachlorophenyl 2,000 333Phenanthrene 1,000 417Phenol 2,300 333Styrene 590 106Tetrachloroethene 10 2 **Toluene 1,700 363 *Trichloroethene 42 14 *Total Xylenes 5,300 1,900 *

Notes:


TABLE 1-3

SUMMARY OF CHEMICALS OF CONCERN, CONCENTRATIONS,AND CONTRIBUTION TO RISKINDUSTRIAL WASTE AREARASMUSSEN DUMP SITE

(1)

Chemical of Concern

(2)Maximum Cone

(ug/kq)

(3)Average Cone

uq/kg)1,1,1-Trichloroe thane2-Butanone4-Methyl-2-PentanoneCarbon DisulfideChlorobenzeneEthylbenzeneStyreneTetrachloroethene2-MethylnaphthaleneAcenaphthaleneAnilineBenzo(a) AnthraceneBenzo(a)PyreneBenzo(b) FluorantheneBenzo( k ) FluorantheneButyl Benzyl PhthalateDi-n-butyl PhthalateDichlorodifluorome thaneFluorantheneNaphthaleneN-NitosodiphenylaminePentachlorophenolPhenanthrenePyreneAcetoneBenzeneTolueneTotal XyleneTrichloroetheneChloroformMethylene ChlorideBis ( 2-Ethylhexyl JPht .PCBs

1086,000240,000

44150,000300,00050,000

11.67,0003,499566

1,043759

1,1591,159

110,0006,600

601,04335,00013,0003,9786,6001,032

2566661

13024,000

4,800,000

86,670230,000

9.35,050

59,5402,447

30

33,500

3,374

823220.376

6,7922,402,600

Notes:

See Table 1-1 for notes.


****

**

+ **

10

TABLE 1-4


PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREARASMUSSEN DUMP SITE

(1)

Chemical of Concern1,1,1-Trichloroethane2-Methylnaphthalene2-ButanoneBenzole acidBis(2-Ethylhexyl)Pht.Butyl Benzyl PhthalateChlorobenzeneDiethyl PhthalateDi-N-Butyl PhthalateDi-N-Octyl PhthalateEthylbenzeneMethylene ChlorideNaphthaleneN-NitrosodiphenylarainePCBsPhenanthreneTetrachloroetheneTolueneTotal Xylenes

(2)Maximum Cone.

(ug/kg)11

31,00012

36,0001,55230,00038,000

13022,000

8253,000

105100,00024,00016,0007,500

10190,000360,000

(3)Average Cone


0.72,570

0.82,250280

2,8862,750

121,900

515,100

127,6501,9101,7406160.9

12,70027,900

***

Notes:


11

carcinogenic risk level means chat there is a risk of oneadditional case of cancer developing in a population of one millionwho are exposed). No inhalation exposure exceeded the 10-6 cancerrisk.

The risk assessment actually assesses the risk for each chemicallisted in Column {!), and provides the total risk of the area ofconcern by adding all the individual risks. Column (4) only showsthe chemicals for which the individual risk exceeds 10 to showwhich chemicals are posing the most significant risk in the areaof concern.

Column (5) in Table 1-1 through 1-4 indicates the exposure route>or routes frog ingestion or inhalation of vapors from groundwaterwhere the 10 carcinogenic risk level is exceeded. The potentialrisks in these cases were evaluated by mathematical modelingprovided in the Risk Assessment, and not by actual measurement inthe groundwater. The mathematical models assume several potentialcontaminant concentrations in groundwater as well as several modesof dispersion that tend to dilute the concentrations. Column 5indicates which chemicals exceeded the 10-6 risk for the case wheremaximum concentration and minimum dispersion were assumed (worstcase); and where average concentration and moderate dispersion wereassumed (possible case.)

Tables 1-5 and 1-6 summarize the chemicals of concern for theactual groundwater contamination plumes that occur beneath theRasmussen and Spiegelberg sites. As in Tables 1-1 through 1-4,columns (1) and (2) respectively show the chemicals of concern andmaximum concentration detected for monitoring wells in the plumes.Columns (3) and (4) respectively delineate those individualcompounds that exceed the 10-6 carcinogenic risk level or presenta non-carcinogenic risk.

The risk assessment established the risks for both the carcinogenicrisks and noncarcinogenic risks for potential ingestion andinhalation of vapors from groundwater use. Both the Rasmussen andSpiegelberg groundwater plumes exceeded the 10 -6 carcinogenic risklevel, and the acceptable noncarcinogenic risk levels for ahypothetical receptor (groundwater user) at Spicer Road. On thisbasis both the groundwater plumes are designated as areas ofconcern to be considered for remedial action.

The information in Tables 1-1 through 1-6 provide the basis uponwhich the remedial action objectives for each area of concern weredetermined, as discussed in Section 2.0.

12

TABLE 1-5


RASMUSSEN GROUNDWATER PLUMERASMUSSEN DUMP SITE

1)

Chemical of Concern

Acetone2-ButanoneBenzeneTolueneXylenes1,1,1-Trichloroethane1.1-Dichloroethane1.2-DichloroetheneTrichlorethene4-Methyl-2-PentanoneMethylene ChlorideEthylbenzeneVinyl ChlorideChlorobenzeneBis(2-ethylhexyl)

PhthalateDi-N-Butyl PhthalateChloroformPhenol2-Methylphenol4-MethylphenolIsoporphorone2,4-Dimethylphenol2-ChlorophenolBenzyl AlcoholBenzoic acid

(2)Maximum Cone

(mq/1)

2674

7.0E-17111

5.0E-15.5E-15.9E-15.0E-1

301.12.4

9.6E-23.7

1.2E-22.1E-25.0E-36.2E-2

1.62.8E-14.4E-12.7E-21.7E-21.2E-21.7E-1

(3) (4)Exceeds Risk Exceeds RiskCarcinogenic Noncarcinoqen

**

A A

A A

A*

A A

A

A

Notes:Column (2) "Maximum Concentrations]" in the Rasmussen Plume obtained

from Risk Assessment LSeptember, 1988.) Notation such as "1.2E-2" meansvalue is 1.2 times 10 , which is equal to "0.012".


Column (4), "Exceeds Risk, Noncarcinogen[ic]" indicates the compoundexceeded the Hazard Index of 1.0, as defined in the Risk Assessment{September, 1988) Appendix B.

13

TABLE 1-6


SPIEGELBERG GROQNDWATER PLUMESPIEGELBERG SITE

1)

Chemical of Concern

Acetone2-ButanoneBenzeneTolueneXylenes1,1,1-Trichloroethane1.1-Dichloroethane1.2-Dichloroethene4-Methyl-2-PentanoneMethylene ChlorideEthylbenzeneVinyl ChlorideChlorobenzeneBis(2-ethylhexyl)

Phthalate ..Di-N-Octyl Phthalate -Di-N-Butyl PhthalateBenzole acidChloroethane2-Hexanone -Phenol -^

Notes:

(2)Maximum Cone

(mg/1)

6.9E-15.5E-18.0E-31.2E-15.6E-26.0E-31.7E-11.4E-11.4E-18.0E-31.6E-21.2E-12.6E-2

1.2E-1l.OE-14.0E-31.4E-19.3E-25.1E-29.0E-2

(3)Exceeds RiskCarcinogenic

Exceeds RiskNoncarcinoqen

**

Column (2) "Maximum Concentrations]" in the Spiegelberg Plume obtainedfrom Risk Assessment _^September, 1988.} Notation such as "1.2E-2" meansvalue is 1.2 times 10 , which is equal to "0.012".

Column (3), "Exceeds Risk, Carcinogenic" indicates the compound exceededthe one addtional case in 100,000 for cancer. One asterisk {*} indicates therisk was exceeded for potential ingestion of groundwater. Two asterisks (**)indicate the compound exceeded cancer risk for both ingestion and inhalationof vapors from groundwater due to household use.

Column (4), "Exceeds Risk, Noncarcinogen[ic]" indicates the compoundexceeded the Hazard Index of 1.0, as defined in the Risk Assessment(September, 1988) Appendix B.

14

1.4 PHYSICAL DESCRIPTIONS OF THE AREAS OF CONCERN

This section provides a brief physical description of each area ofconcern, including an estimate of the depth of contamination andthe volume of materials that may require excavation for remedialalternatives involving removal. The volume calculations wereperformed by Warzyn Engineers, Inc., and are provided in AppendixA of this document.

1.4.1 RASMOSSEN DUMP SITE - PROBABLE DRUMSTORAGE/LEAKAGE/DISPOSAL AREA

The Probable Drum Storage/Leakage/Disposal area consists ofsporadically contaminated soils, where contamination occurs inpockets and lenses as a result of apparent spillage and leakagefrom drums and/or bulk dumping. The soils are natural, in situsand and gravel with lenses of finer grained sandy silts. The areawas partially excavated by the owner in 1987, exposing contaminatedzones in the soils that appear to be associated with the finergrained silty lenses of soil. On the basis of this observation,the area probably contains large zones of uncontaminated to lowlevel soil contamination, with fewer, smaller zones of more highlycontaminated soils that serve as a continuing source of leachinginto the groundwater. The most highly contaminated soils weredistinguished as either dark gray to black, or light gray. Visualidentification was most easily made on the near vertical high wallsof the excavation.

The Probable Drum Storage/Leakage/Disposal area is an area ofconcern because of risks posed by dermal contact from PCBs, and thethreat to groundwater. Contamination was confirmed by samplinggroundwater beneath this area using monitoring wells. Groundwaterdata shows that a significant amount of organic compounds haveleached from this area. The contaminant plume emanating from the

^-- Probable Drum Storage/Leakage/Disposal Area is designated theRasmussen Plume. The organic contaminants detected in the plumeare presented in Table 1-5.

The areal extent of the Probable Drum Storage/Leakage/Disposal areais shown on Figure 3-1 of the Remedial Investigation report andRisk Assessment report. The area is shown as approximate since theexact dimensions are unknown. The depth to which contaminatedsoils extend is also unknown. Because of the uncertainty ofcontaminant extent and -the topography of the area, two volumeestimates were made: The first assumes excavation to elevation 920feet (mean sea level), which is the present base of the gravel pit.Using this assumption, a volume of about 3,600 cubic yards of soilswould have to be removed. The second volume will depend onexcavation to the top of the water table.

15

The elevation of the water table beneath the Probable DrumStorage/Leakage/Disposal area is about 883 feet mean sea level(msl). The existing ground surface ranges from about 920 withinthe pit excavated in June 1987 to 938 feet msl. Therefore theexisting ground surface ranges from 37 to 55 feet above -the watertable. The case of excavating to the top of the water table willbe further addressed in the Detailed Evaluation of Alternatives inSection 5.0 and subsequent sections.

1.4.2 RASMOSSEN DUMP SITE - INDUSTRIAL HASTE AREA

The Industrial Waste area consists of soils, paint sludge, somerefuse and a few drummed wastes that were deposited in the base ofthe Rasmussen gravel pit. The area is contiguous with the ProbableDrum Storage/Leakage/Disposal area. The area is of concern becauseof the threat from dermal contact due mainly to the FCBs, andthreat to the groundwater. Groundwater contamination beneath this

, area was confirmed by monitor well sampling.

The Industrial Waste area is adjacent to and could be consideredpart of the Probable Drum Storage/Leakage/Disposal area. However,both areas are distinctly different. The Industrial Waste areacontains actual waste materials (paint sludge, drums, etc.), whilethe Probable Drum Storage/Leakage/Disposal area consists mainly ofcontaminated soils resulting from spillage, leakage, and/or bulkdumping of drums (see Section 1.4.1).

The ground surface elevation at the Industrial Waste area is about924 feet msl. The estimated elevation of the water table is about883 feet msl, so that the ground surface is about 40 feet above thewater table.

The general areal extent of the area is provided on Figure 3-1 ofthe Remedial Investigation (RI) report and the Risk Assessment.

^ The area is also discussed in the Geophysical Technical Memorandumin Appendix A of the RI report. The depth of wastes, as determinedby test pits, is approximately 15 feet. Therefore, the depth fromthe base of the waste to the water table is about 25 feet.

The depth to which leachate may have contaminated soil beneath thewaste has not been adequately defined. The depth of contaminatedsoil may range from about 3 feet below the waste to the watertable. The estimate of 3 feet is based on general observations intest pits, and the potential for contamination to the groundwatertable is based on boring data from the Probable DrumStorage/Leakage/Disposal area, which has a similar subsurfacegeology.

16

The limits of the Industrial Waste area encompass an area of about382 square yards. The volume of excavation was estimated madeusing two different assumptions. The first assumes excavation ofwaste and 3 feet of contaminated soil only, which means a totalexcavation depth of about 15 feet/ for a volume of soil and wasteexcavation of about 1,900 cubic yards.

The second assumption is for an excavation of the soils to thedepth of the water table, which yields an excavation depth of about40 feet. The case of excavating to the top of the water tablewill be further addressed in the Detailed Evaluation ofAlternatives in Section 5.0 and subsequent sections.

1.4.3 RASMDSSEN DUMP SITE - NORTHEAST BURIED DRUM AREA

The Northeast Buried Drum area consists of drum wastes and mixedwaste soils that were pushed over the edge and side of the hillwhere the municipal landfill is located. The mixed waste soils anddrums are contiguous with the municipal landfill wastes.

The Northeast Buried Drum area is an area of concern mainly becauseof the dermal threat posed by the PCB's and dioxin in the surfacesoils, and the threat to groundwater posed by both the wastes andcontaminated soils. Some of the highest concentrations of organichazardous substances were found in this area, as indicated in Table1-1 in Section 1.3 of this report. Test pits excavated during theRemedial Investigation showed soils surrounding the buried drummedwaste to be highly stained with contamination.

The surface elevation of the Northeast Buried Drum area ranges fromabout 984 feet msl at the top of the slope to 944 feet msl at thebase of the slope. The estimated elevation to the permanent watertable is about' 884 feet msl, which is about 60 feet below the baseof the actual waste material.

The general areal extent of the Northeast Buried Drum area isprovided on Figure 3*1 of the Remedial Investigation report andRisk Assessment. The relative depth of wastes is estimated fromthe test trenches and the surrounding topography as provided inFigure 3-4 of the RX report. The depth of contaminated naturalsoil beneath the visually contaminated wastes is unknown, butassumed as 3 feet below the wastes for estimating purposes, basedon test pit observations.

For estimating purposes, the Northeast Buried Drum area can beconsidered to consist of two waste types. The central portion ofthe area consists of buried drums and. covers an area of about 830square yards, extending to an estimated depth of 12 feet. Theremaining 1140 square yards of the area contains contaminated soils

17

to an estimated depth of 2 feet (surface cover material). Thisremaining area is similar to the Top of the Municipal Landfill withwhich the Northeast Buried Drum area is contiguous. The totalvolume of waste and soil in the Northeast Buried Drum area isestimated to be about 4,100 cubic yards.

1.4.4 RASMCSSEN DUMP SITE - TOP OF THE MUNICIPAL LANDFILL

The Top of the Municipal Landfill consists of fine grained, sandysoils that were originally placed as a cover for the municipalwastes, and were subsequently disturbed by drum disposal andremoval, and soil removal. The soil cover was relatively thingenerally ranging from one to several feet thick where present.The cover was very thin in some portions of the fill wheremunicipal wastes were seen at the ground surface. In addition,municipal wastes are exposed along the north face of the fill whichwas excavated for the gravel pit, and along the hillside formingthe south face of the landfill.

The Top of the Municipal Landfill is an area of concern mainlybecause of the dermal threat posed by PCB and Dioxin in the surfacesoil; and the threat to groundwater from leaching through thecontaminated soils. Table 1-2 in Section 1.3 summarizes thosechemicals posing the most significant threat.

The elevation of the Top of the Municipal Landfill is about 982feet msl. The estimated depth to the water table is about 884 feetmsl, so the ground surface is about 100 feet above the permanentwater table.

The approximate areal extent of the municipal landfill is shown onFigure 3-1 of the Remedial Investigation (RI) report and the RiskAssessment. The areas of surface contamination by the chemicalsof concern (PCB and dioxin) are shown on Figures 4-5 and 4-6 in theRI report. The depth of contamination is assumed to be a maximumof several feet (2 feet for estimating purposes) corresponding withthe depth of the soil cover. The estimated volume of contaminatedcover soils is about 15,300 cubic yards.

1.4.5 SPIBGBLBERG AND RASMUSSEN DOMP SITES -GROONDWATER CONTAMINANT PLUMES

The Spiegelberg site groundwater contamination plume originatesfrom the Spiegelberg Pa-int Sludge area. The Paint Sludge areasource will be removed at some future date, in accordance with theU.S. Environmental Protection Agency Record-of-Decision (ROD)signed on September 30, 1986. The risk posed by the plume is thepotential threat from ingestion and inhalation (household use) ofthe groundwater, mainly from methylene chloride, vinyl chloride,

18

and 1,1-dichloroethane. The estimated horizontal and verticalextent of the plume is provided in Figures 5-7A and 7B in theRemedial Investigation report.

The Rasmussen Dump site groundwater contamination plume originatesfrom the Probable Drum Storage/Leakage/Disposal area and theIndustrial Waste area, which are contiguous. Both these areas areconsidered continuous, ongoing sources. The risk posed by theplume is the potential threat from ingestion and inhalation(household use) of the groundwater, mainly from methylene chloride,vinyl chloride, benzene, 1,1-dichloroethane, 1,1-dichloroethene,and trichloroethene. The estimated horizontal and vertical extentof the plume is provided in Figures 5-8A and 8B in the RemedialInvestigation report.

The hydraulic conductivities of the aquifers are provided in theRemedial Investigation report. The hydraulic conductivities arebased on short term pump tests, and slug tests. The hydraulicconductivities provided in the Remedial Investigation report areadequate for use in the detailed evaluation of alternatives forpumping and treatment alternatives; however, additional pumpingtests may be required during the pre-design phase to locate theoptimum placement, and establish the pumping rates for purge wells.

19


The principal objective of remedial action is to eliminate and/orreduce the threat or potential threat to human health and theenvironment posed by the areas of concern. Remedial actions are toaddress che specific threat posed in an area of concern, byconsidering the chemicals of concern and the routes of exposure.In addition, an estimate of the acceptable contaminant levels ismade to establish "action levels" in the applicable media (e.g.air, soil and groundwater.)

This section of the report defines the general remedial actionobjectives for each area of concern and media where a threat orpotential threat exists to human health and the environment. Thechemicals of concern that pose the threat in each area weresummarized in Tables 1-1 through 1-5 in Section 1.3 of this report.The Risk Assessment (September, 1989) defined the cumulativecontribution of carcinogenic and non-carcinogenic risk for eachchemical in each area of concern, for each route of exposure (i.e.inhalation, ingestion, and dermal exposures.)

The Risk Assessment determined that the most significant route ofexposure where the risk exceeded the acceptable levels (HazardIndex greater than one or Cancer Risk greater than 10-6) wasthrough the ingestion of, or inhalation of vapors from potentiallycontaminated groundwater. The only other route of exposure thatexceeded the risk levels was dermal contact.

The Risk Assessment also determined that the risks associated withthe chemicals of concern for groundwater risks was greater thanthat for dermal contact, and that acceptable concentrations in soil(soil action levels) calculated for acceptable groundwater riskswould be lower than soil concentrations (soil action levels) foracceptable risks due to dermal contact. Therefore, the acceptableconcentrations in soil, as calculated for groundwater protection,can be used as the soil action levels for the remediation of eacharea.

Determination of the acceptable soil concentrations (soil actionlevels) was performed using several different assumptions duringthe Remedial Investigation and Risk Assessment. In all cases, thesoil action levels were determined using the revised "OrganicLeachate Model" and a linkage model to back-calculate soilconcentrations from assumed concentrations in the groundwater.

The differences in soil action values are caused by differences inthe assumptions made regarding the number of compounds to includein the calculations. The soil action levels provided in the RiskAssessment (Appendix B, pages 5 and 6 of the data sheets,September, 1988) were calculated assuming compounds detected insoil and waste sampling within each area of concern. If total

20

waste removal from the soils is assumed, then the assumptionsshould be adjusted to account for removal of some of the compoundsfrom the areas of concern. If the potential for waste to remainon site is assumed, then the Risk Assessment assumptions may beappropriate. Therefore, final calculation of soil action levelsshould be made after the preferred remedial action(s) is selectedfor each area. For purposes estimation purposes in the FeasibilityStudy, the soil action levels provided in the Risk Assessment(September, 1988) Appendix B are provided in Table 2-1 as targetconcentrations for remediation.


2.1 RASMUSSEN SITE REMEDIAL OBJECTIVES


The main threats posed by the buried drum area are potential dermalcontact and fugitive dust inhalation, and leaching of hazardous'substances into the groundwater. Therefore, the remedial actionobjectives are to prevent dermal contact with,_-and inhalation of,hazardous substances with a greater than 1 x 10~ cancer risk level,and prevent degradation of the groundwater environment by potentialleaching of organic contaminants. The compounds contributing mostto the risks from this area of concern are summarized in Table 1-1 in Section 1.3. Estimated soil action levels (cleanupconcentrations) are provided in Table 2-1. Actual soil actionlevels should be determined after the preferred alternative isselected for this area of concern.


The main threat posed by the top of the municipal landfill arepotential dermal contact and fugitive dust inhalation. Therefore,the remedial action objectives are to prevent dermal contact with_,and inhalation of, hazardous substances with a greater than 1 x 10cancer risk level. The compounds contributing most to the risksfrom this area of concern are summarized in Table 1-2 in Section1.3. Estimated soil action levels (cleanup concentrations) areprovided in Table 2-1.- Actual soil action levels should bedetermined after the preferred alternative is selected for thisarea of concern.

21

TABLE 2-1

TARGET CONCENTRATIONS FOR SOILREMEDIATION

RASMUSSEN DUMP SITE AREAS OF CONCERN

AREA OF CONCERNComoound

Carcinogens-

Benzene1,1-DichloroethaneTetrachloroetheneTrichloroetheneChloroformMethylene ChlorideBis(2-ethylhexyl)

phthalateBenzo(A)PyreneBenzo(A)AnthraceneBenzolBJFluorantheneBenzo(K)FlourantheneN-Nitrosodiphenylamine2,3,7,8-TCDD (dioxin)PCBs

Noncarcinogens-

Acetone2-butanoneTolueneEthylbenzeneTotal XylenesChlorobenzeneStyrene1,1,1-TrichloroethanePhenolDi-n-butylphthalateCarbon Disulfide

TML

(ug/kg)

4.5

13.324.51.85.9

1,504

173.4

4.4

(mg/kg)

22.010.6

4,5182,09622,28330.5

744.060.5

8,107470.2

NEB

{ ug/kg)

37.58.1

111.9205.8

49.8

12,637

6.4E-537.3

(mg/kg)

185.089.6

37,96717,614187,256256.833,6826,252508.268,132

IW

(ug/kg)

268.1493.3

119.4

30,28537.7

18,138750.098,6863,493

89.3

(mg/kg)

374.4158,73073,637782,8581,074

140,81426,139

284,83816,519

PDSLD

(ug/kg)

142.0

63.3

16,037

1,850

47.3

f mg/kg)

131.063.4

26,87212,466132,533181.823,8394,425

48,2212,797

Notes1.) Abbreviations are as follows:

TML- Top of Municipal LandfillNEB- Northeast Buried Drum AreaIW- Industrial Waste AreaPDSLD- Probable Drum Storage/Leakage/Disposal Area

2.) Target concentrations for soil remediation were obtained from theRisk Assessment (September, 1988) Appendix B, for the analytical Case01 for each area of concern.

22

TABLE 2-2

TARGET CONCENTRATIONS FOR GROUNDWATERCLEANUP

SPIEGELBERG AND RASMUSSEN DUMP SITES{all values in ug/1)

Michigan Federal Spiegelbecg RasmussenCompound and Group Level Level 10E-6 Level 10E-6 Level

Carcinogens

benzene1,1-dichloroethanevinyl chloridemethylene chloridetetrachloroethenetrichloroethene1,1-dichloroethenechloroformbis(2-ethylhexyl)

phthalate

Total Ketones

acetone2-butanone2-hexanone4-methyl 2-pentanone

Total VolatileOrganic Compounds

tolueneethylybenzenexylenechlorobenzene1,1,1-trichloroethane1,1-dichloroe thanedi-n-butylphthalatephenol

Metal

lead

00000000

0

30

.1

.1

.1

.1

.1

.1

.1

.1

.1

.0

20

0.1790.0960.0030.534

0.0700.0400.0010.2000.0700.2000.0040.070

0.277

218109

2,000700

10,000

200

580210

1,15019

193169218

4421678821514713016766

(Note: all values provided by MDNR.)

23

The case of excavating to the top of the water table will befurther addressed in the Detailed Evaluation of Alternatives inSection 5.0 and subsequent sections.


The main threats posed by the Industrial Waste area are potentialdermal contact and fugitive dust inhalation, and leaching ofhazardous substances into the groundwater. Therefore, the remedialaction objectives are to prevent dermal contact with, andinhalation of, hazardous substances with a greater than 1 x 10cancer risk level, and prevent degradation of the groundwaterenvironment by potential leaching of organic contaminants. Thecompounds contributing most to the risks from this area of concernare summarized in Table 1-3 in Section 1.3. Estimated soil actionlevels (cleanup concentrations) are provided in Table 2-1. Actualsoil action levels should be determined after the preferredalternative is selected for this area of concern.


The main threats posed by this area are potential dermal contactand fugitive dust inhalation, and leaching of hazardous substancesinto the groundwater. Therefore, the remedial action objectivesare to: (1) prevent dermal contact with, and inhalation of,hazardous substances with a greater than 1 x 10 cancer risk level;and, (2) prevent degradation of the groundwater environment bypotential leaching of organic contaminants. The compoundscontributing most to the risks from this area of concern aresummarized in Table 1-4 in Section 1.3. Estimated soil actionlevels (cleanup concentrations) are provided in Table 2-1. Actualsoil action levels should be determined after the preferredalternative is selected for this area of concern.


The main threat posed by the existing groundwater plume is thepotential risk for ingestion and inhalation due to household use,and the threat to the groundwater environment. The remedial actionobjective is to reduce or eliminate exposure of potential receptorsto contaminated groundwater and prevent further degradation of thegroundwater environment. The estimated groundwater cleanup goalsare presented in Table 2-2. Remediation of the groundwater plumemay require discharge to-surface water in the vicinity of the site.Table 2-3 summarizes the compounds that will be considered forcompliance with the National Pollution Discharge Elimination System(NPDES) for discharges from a treatment system to the surfacewater, and the values for compliance with Michigan Rule 57 forsurface water discharges. These values were provided by MDNR.

24

2.2 SPIEGELBERG SITE REMEDIAL OBJECTIVES

2.2.1 GROONDWATER PLUME (SPIEGELBERG)

The main threat posed by the existing groundwater plume is thepotential risk for ingestion and inhalation due to household use,and the threat to the groundwater environment. The remedial actionobjective is to reduce or eliminate exposure of potential receptorsto contaminated groundwater and prevent further degradation of thegroundwater environment. The estimated groundwater cleanup goalsare presented in Table 2-2. Remediation of the groundwater plumemay require discharge to surface water in the vicinity of the site.Table 2-3 summarizes the compounds that will be considered forcompliance with the National Pollution Discharge Elimination System(NPDES) for discharges from a treatment system to the surfacewater, and the values for compliance with Michigan Rule 57 forsurface water discharges. These values were provided by MDNR.

25

TABLE 2-3

SUMMARY OF COMPOUNDS REQUIRING CONSIDERATION FOR NPDESAND CONCENTRATIONS TO COMPLY WITH MICHIGAN RULE 57

FOR SURFACE WATER DISCHARGESPIEGELBERG AND RASMUSSEN DUMP SITES

Compound

xylene2-methylphenol4-methylphenol2-chlorophenolBis (2-ethylhexyl) phthalateIsoporphoroneBenzo(a)anthracene2,4-DimethylphenoI1.1-Dichloroethane1.2-DichloroethyleneMethylene ChlorideTrichloroethyleneI,It1-TrichloroethaneTetrachloroethyleneVinyl ChlorideChloroform1,1-Dichloroethylenetrans-l,2-DichloropropeneBenzeneEthylbenzeneChlorobenzeneToluene2-Butanone2-Hexanone4-methyl-2-pentanonePCBBenzoic AcidAcetonePhenolCadmiumChromiumHexavalent ChromiumCopperLeadNickelZincSilverSeleniumArsenicMercury

Rule 57(2) Value, ug/1

59

860

300599411716

432.6

603071100

0.00002

5002300.9125656IS2062410.1221840.0006

Information provided by MDNR, Surface Water Quality Division

26

3.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

Under section 121(d)(2)(A) of SARA, remedial actions must at leastattain a level or standard of control which attains any standard,requirement/ criteria, or limitation under any Federalenvironmental law, including but not limited to, the ToxicSubstances Control Act, the Safe Drinking Water Act, the Clean AirAct, the Marine Protection, Research, and Sanctuaries Act or theSolid Waste Disposal Act determined to be legally applicable orrelevant.

SARA also requires that if any promulgated standard, requirement,criteria, or limitation under a State environmental or facilitysiting law is more stringent than any Federal standard,requirement, criteria, or limitation and is applicable or relevantand appropriate, the level or standard of control called for mustbe attained. Section 121 (d) (4) of SARA provides for waivers ofARARs under six different types of circumstances. These include:

o the remedial action is an interim measure where the finalremedy will attain the ARAR upon completion.

o compliance will result in greater risk to human health andthe environment than other options.

o compliance is technically impractical.

o an alternative remedial action will attain the equivalent ofthe ARAR.

o for State requirements, the State has not consistentlyapplied the State requirement in similar circumstances.

o for Section 104 remedial actions, compliance with the ARARwill not provide a balance between protecting public health,welfare, and the environment at the site with theavailability of Superfund money for response at other sites(fund-balancing).

During the initial stages of the feasibility study potential ARAR'swere identified for both the Spiegelberg and Rasmussen sites. Thefirst ARARs examined are those that pertain to the specifichazardous compounds detected in the various areas of concern andgroundwater plumes at the sites. The chemical specific ARARs arepresented in Table 3-1.

The potential ARARs were then examined and evaluated to determinewhich ARARs may be applicable to the six areas of concern, basedon the location and type of media effected by the areas of concern.The "location specific" ARARs are presented in Table 3-2. TheARARs that were determined to be potentially applicable to any oneof the areas are denoted by the symbol "o" in Table 3-2. Those

27

ARARs without a symbol do not apply to a particular area ofconcern. Table 3-2 also includes a general description oc eachARAR listed.

The final aspect of ARARs that requires evaluacion is that relatedto the various remedial processes that may be implemented ac eacharea of concern. These are referred to as "process specific"ARARs. The process specific ARARs are discussed in Section 4.4 ofthis report, after the discussion of the process options. Thedetailed evaluation of alternatives (Section 5.0 and subsequentsections) will further identify which ARARs apply to each of theassembled remedial alternatives. Each alternative will then beevaluated for its ability to attain the identified ARARs.

28

TABLE 3-1

Chemical

CHEMICAL SPECIFIC ARARsSPIEGELBERG AND RASMUSSEN DUMP SITES

(See notes at end of table)

Area of ConcernWhere Present

Media ofConcern ARAR

Limit(mg/1

Benzene

Chlorobenzene

Chloroform

Ethylbenzene

NEB, TML, IW,PDSLD, RGWP,SGWP.


TML, IW, RGWP


Methylene Chloride NEB, TML, IW,PDSLD, RGWP,SGWP.

PCBs

Styrene

NEB, TML, IW,PDSLD.

NEB, TML, IW.

Tetrachloroethane NEB, TML, IW,PDSLD.

SurfaceWater

Ground-water

Ground-water

Ground-water

Ground-water

SurfaceWater

Ground-water

Ground-water

Soil

Ground-water

Ground-water

CWA/WQASDWA/MCL 0.005SDWA/MCLG 0.000

SDWA/MCLSDWA/MCLG

SDWA/MCLSDWA/MCLG

SDWA/MCLSDWA/MCLG

CWA/WQASDWA/MCLSDWA/MCLG

SDWA/MCLSDWA/MCLG

SDWA/MCLSDWA/MCLG

**TSCA

SDWA/MCLSDWA/MCLG

SDWA/MCLSDWA/MCLG

0,0050.000

0.060

SDWA/MCL 0.10

0.680

11.0000.0050.000

0.0050.000

0.000

500

0.140

0.000

29

TABLE 3-1 (continued)

Chemical

CHEMICAL SPECIFIC ARARsSPIEGELBERG AND RASMUSSEN DUMP SITES

Area of ConcernWhere Present

Media ofConcern ARAR

Limit(mg/1

Toluene

1,1,1-Trichloro-ethane

Trichloroethene



NEB, TML, IW,RGWP.

Ground- SDWA/MCL ——water SDWA/MCLG 2.000

Ground- SDWA/MCL 0.200water SDWA/MCLG 0.200

Ground- SDWA/MCL ——• water SDWA/MCLG 0.070

Vinyl Chloride

Total Xylenes

NOTES:

RGWP, SGWP.


Ground- SDWA/MCL 0.002water SDWA/MCLG 0.000

Ground- SDWA/MCL ——water SDWA/MCLG 0.440

Limit values of "0.000" indicate the acceptable MCLG is zero.

Abbreviations are as follows:

NEB- Northeast Buried Drum Area.TML- Top of Municipal Landfill.IW - Industrial Waste Area.PDSLD- Probable Drum Storage/Leakage/Disposal Area.RGWP- Rasmussen Groundwater Plume.SGWP- Spiegelberg Groundwater Plume.

CWA- Clean Water Act.WQC- Water Quality Criteria under the CWA.SDWA- Standard Drinking Water Act.MCL- Maximum Concentration Limit.MCLG- Maximum Concentration Limit Goal.TSCA- Toxic Substance Control Act.

* - Value for chloroform is an interim MCL for total halomethanes.** - Level of PCBs allowed in soil is based primarily on risk. Howeverguidance may require removal is levels are over SOOppm.

30

TABLE 3-2


REQUIREMENTS

FEDERAL

t. Protection of National Natural Landmarks (36 CFR Part 62)

ReguI at ton* prescribing the processes and criteria used to taunti f ystudy, designate, recognize arid monitor national natural landmarks.

2. protection ot National Historic Landmark* ( 36 CFR Part fab)

These regulatIons set forth the criteria and procedures used Dy meDepartment ot the Interior to iUent i f y. designated, and moni tor nat i oiid Ihlstor tc landmarks.

3. P i u t M i l i o n of Historic and C u l i m a l Properties (36 CFR Part dOU)

Regu Iat tons that daf ine the process used by a FederaI agency to tdkuinto account the affect:, of the agency'» undertaking un proper t iei.Included in. or e l i g i b l e foi the National Register of H i s t o r i c Place*.Th t s process, commonly caI Ied the Sect ion 106 process (out IIned inSection 106 of the National H i s t o r i c Preservation Act), IncludesIdentIfylng historic pi aces, assess Ing effects, afforotng the Counc iI onHistoric Preservation an opportunity to comment, agreements w i t h Statesfor section 106 reviews, documentatIon requirements. and criteria ofeffect and adverse effect .

AREA OF CONCERN

RASMUSSEN SP

PD |iw |NB |TL law aw

4. Protection of ArcheoIogtcaI Resources (36 CFR Part 296. 43 CFRPart 7. 32 CFR Part 229, 18 CFR Part 1312)

These regu I at Ions estau I i sh uni tut m d e t I n t t Ions , standards , andprocedures to bu f o l l o w e d by Fedeial land managers tri providingprotection for archaeological resources located on public lands andIndian lands of the united States.

S. Rivers and HaDor Act (33 CFR Parts 320-330)

Parts 320 - 330 prescribe the p o l i c i e s and procedures to bu t o l l u w u Uby the Army Corpus of Enginuvi s In connect ion with the review ofapplications for Department of the Army permits to authorize c e r t a i nactivities In waters of the United States or the oceans. Thesea c t i v i t i e s Include dam and d i k e construction, other structures (pier,boat, dock, breakwater, etc.) or work (dredging, excavation, f i l l i n g .etc.) In or affecting navIgable water, discharges of dredgud or f i l lm a t e r i a l , and ocean dumping of diedged m a t e r i a l .

I

I I

CJtsj

TABLE 3-2

LOCATION SPECIFIC ARARs.

REQUIREMENTS

6. Dental or Restriction of Disposal Sites {40 Cf=H 231)

The regulation* In t h i s part include the procedures to be f o l l o w eby tha EPA In p r o h i b i t i n g , denying, or restricting any defined orspecified area as a disposal s i t e for dredged or f i l l m a t e r i a l puto section 404 (c) of the C*A .

AREA OF CONCERN

RASMUSSEN |SP_ _ - _ _ _ _ _ _ _ - _ _ _ - . _ _ _ _ I __.PD |iw |NB |TL |GW |Gw._...______,._-.._..__.

STATE OF MICHIGAN

I. Hazardous Wasta Management Act (HWMA) Act 64, P.A. 1979 -Construction Permits and Operating License* (R 299.9501 -R 299.9S23)

These rules st ipuI ate tne variuui requ tremants for obtain 109 a permitfor the construction, enlargement, or alteration of a treatment,storage, or dispose I facI I i ty . The rules also praseriba procedures furacquiring an operating license for managing, maintaining, or operatinga treatment, storage or d I spasa I f ac t 1 i ty .

2. HWMA Appl icaut I i ty Standard:. (R299.9601 )

Th l& rule de&cr Ibes the t ypes of f ac I 1 i t tes that are raqul red to tump I yw i t h the standards contained in Part 6 of tha HWMA - OHners andOperators of Hazardous Wastw Treatment. Storage, and DisposalFact I 11ies.

3. HWMA - Location Standards (H 299.9603)

R e g u l a t i o n s Fur tne l o c a t i o n or nan treatment, storage, orf a c i l i t i e s or e.pant. Ions, enl aryttmunt s. or alteration of ent&tingf a c i i l t i e s .

Michigan Water Rei»uurce:> Cuimni s,s ion Act (MWRCA), P.A. 21b,Floodplain Regulatory Au t h o r i t y Act, PA 245, 1929 as anunenjed.

for the cunt r uI uf <ii t i v 11 iu& and us*»;> of landsas f I uoilp la ins .

i i j iui ui

b. MWHCA- Act 24b, Stictton 6(t>), MCL 323.6(a).

Prohtb I is a) rue t or ina i rec t di bbiiurgtts of substances that are , ur

o oI

TABLE 3-2


REQUIREMENTS

become injurous to potential uses of groundnetar or surface water.

fa. Water Supply and Sewers Act - Act 360, P.A. 197B Part 127(R32S.IftOl - R325.1781)

Ru les governing the location of *at#r w e l l s (di stance fi out jju I I nt ionsources, relation to buildings, areas subject to flooding), construct tonof we I Is, end abandonment of we I Is.

7. Goemara-Anderson Wetlands Protection Act - Act 203, P.A. 1979

Tha purpose of this Act is to provide for tha prosarvat ton. management,protection, and use of wetlands by prohibiting certain a c t i v i t i e s ,requiring a permit to altar certain Mat lands, and Imposing penalties andfee> for v i o l a t i o n s of tna Act.

6. Natural River Act - Act 321. P.A. 1970 - Huron River Natural R i v e rZoning (R 281.151 - R 281.164)

Tha purpose of these toning roles are to promote public health andprevent ecological damage due to unwise development w i t h i n the naturalriver d i s t r i c t . The rules a I so protect the free flow Ing condltIons,fish and w i l d l i f e , water quality, and recreational value of the HuronRiver and adjoining land.

9. Endangered Species Act - Act 203, P.A. 1974 - Endangered andThreatened Species (R 299.1021 - R 299.1028)

These rul e s contain a M u t i n y or the F i s h , w i l d l i f e , and plant speciesthat have been determined to be endangered or threatened,

10. Thomas J . Anderson, Gordon Hockw* I I Environment a I Pro tec t ion Ai_ t -Act 127, P.A. 1970.

The purpose of this act is to uiolect air, water, and other i i d t u i a lresources and the p u b l i c trust thertn from p o l l u t i o n , impairment, amidestructIon.

tl. MWHCA- Act 246. Section 6(a). MCL 323.6(»>.

Prohibits direct or indirect discharges of substances that are. or m«iybecome Injurous to potential uses or groundwatar or surface water.

1ut ton

an t ,

s and

AREA OF CONCERN

RASMUSSEN |SPI

PDZB =

o

IWE=B =

O

NB

o

TLe fs =

O

GWE =S =

U

1*

O

Gw

O

o

U

1o o I

TABLE 3-2


REQUIREMENTS

12. MWRCA - GraundHater Quality (R 323.2201 ' N 323.2211).

The ragulat Ions In thts part prov tdu for the nondegradat Ion ofground*atar qua! I ty , def 1 ne th« requt remtint* for hydrogeo log leu 1 & tuuyD«for« permitting a discharge Into groundMatars. astabllah orounuwaturmonitoring r«qu(r«*«nt • . and «»tabll»h procedures for obtatnlngvar lancaa -

t13. Inland Lak«» and Strwam Act, P. A. 346. 1972.

Tha purpose of this act Is to re on late activities occur! ng be low theordinary high water mark on Inland lakes and streams. Including allnatural or artificial lakes or rivers over five acres In size.

AREA OF CONCERN

RASMUSStN

PDcas

IW NB...

SP

TL |uw low

o u

u u

TABLE 3'2

ABBREVIATIONS USED IN TABLE 3~2

(I) PO - Probable Drum Storaue/Laakaae/OlsposaI areaIW - Industrial Waste areaNB - Northeast Burled Oru« areaTL - Top of the Municipal LandfillGW - Groundwatar Plume


Development of Remedial Action alternatives is a systematic method usedto identify the range of methods that could be used to eliminate orreduce the real or potential threat to human health and the environmentin the areas of concern on the Spiegelberg and Rasmussen sites. A rangeof potential remedial alternatives were developed for each area ofconcern. These alternatives were screened for subsequent detailedevaluations in the detailed evaluation of alternatives. The processutilized for developing alternatives is as follows:

o Develop general remedial response actions that satisfy theremedial action objectives (Section 4.1). The remedial actionobjectives are presented in Section 2.0.

o Identify potential remedial technologies and their associatedprocess options (Section 4.2).

o Screen potential remedial technologies and process options) based on technical implementability (Section 4.2).

o Evaluate technologies and process options for effectiveness,implementability, and relative cost (Section 4.2).

o Assemble media-specific technologies and process options intosite alternatives (Section 4.3).

o Identify process-option (action) specific ARARs to be furtherevaluated during the detailed evaluation of alternatives(Section 4.4).


General response actions are comprehensive actions, or remedies thatsatisfy the remedial action objectives discussed previously for eacharea of concern. The general response actions identified for theSpiegelberg/Rasmussen site include the following:

No Action (Section 4.2.1)Institutional Actions (Section 4.2.2)Alternative Water Supplies {Section 4.2.3)Containment (Section 4.2.4)Removal (Section 4.2.5)Onsite Treatment (Section 4.2.6)Offsite Treatment (Section 4.2.7)Onsite Disposal (Section 4.2.8)Offsite Disposal (Section 4.2.9)

35

4.2 REMEDIAL TECHNOLOGIES AND PROCESS OPTIONS

Several general categories of potential remedial technologies wereidentified for each general response action. For example, foronsice treatment various broad technologies were identified, suchas thermal treatment, immobilization, and in-situ treatment.Furthermore, for each remedial technology category numerous processoptions may exist. A process option refers to the specifictechnique, methodology, or process used to implement a remedialtechnology. For instance, the thermal treatment technologycategory may include such process options as rotary kilnincineration, super critical water oxidation, molten saltdestruction, fluidized bed incineration, and infrared destruction.

The identified process options are then evaluated or screened based-on potential applicability. This evaluation eliminated fromfurther consideration those process options and/or technologiesthat can not be effectively applied to the site for technicalreasons. The remedial action objectives, general response actions,remedial technologies, and associated process options for each areaof concern are presented in Table 4-1, along with potentialapplicability screening information, based solely on technicalapplicability.

The process options considered to be potentially applicable arefurther evaluated and screened with respect to effectiveness,implementability, and cost criteria:

o Effectiveness - Several factors are considered in theeffectiveness evaluation. These include the potential forprocess options to handle estimated volumes of contaminatedmedia and meet contaminant reduction goals, protection ofhuman health and the environment during construction, andwhether or not the process option is. proven and reliable forthe contaminants of concern and site conditions.

o Implementability - The implementability evaluation emphasizesthe institutional aspects of implementability, such as theability to obtain necessary approval from governmentagencies, the availability of treatment storage, and disposalcapacity, and the availability of equipment and skilledlabor.

o Relative Cost - Relative capital and operation andmaintenance (O&M) costs were estimated as high, medium, orlow for each process option. Cost estimates were made forcomparison purposes only and were based on engineeringjudgement and experience.

36

Table 4-2 provides a summary of the effectiveness,implementability, cost evaluation and the process options that willbe assembled into remedial alternatives, as indicated in the"Screening Status" column cf the table. This represents the finalscreening prior to assemble into remedial alternatives for eacharea of concern. Assembly of the alternatives is provided inSection 4.3 of this report. The remedial technologies and processoptions evaluated for the Spiegelberg and Rasmussen sites arediscussed below:

4.2.1 NO ACTION

The no action response is required for consideration under the 40CFR 300.66, C.3 which is the Nation Contingency Plan (NCP). TheNo Action alternative is evaluated to estimate the effect of notperforming additional remedial actions at the site. The no actionalternative does not restrict the further migration of contaminantsnor does it reduce the toxicity, mobility or volume of thosecontaminants at any of the areas of concern where contamination hasbeen demonstrated to be a threat to human health and environmentat the sites.


Fencing-

Fencing is an established technique designed to minimize dermalcontact risks by deterring people from entering into contaminatedareas. Fencing is also used to prevent vandalism of facilitiesused for remediation. The long term reliability of fencing torestrict access to contaminated areas on site is questionable,especially when compared to other more effective removal ortreatment techniques. However, full site fencing will very likelybe part of any large-scale remedial measure implemented on the siteto minimize trespassing. An MDNR fence currently encompasses theareas of concern on the Rasmussen site.


Monitoring and analysis technologies will be used to assess theeffectiveness of remedial activities if permanent solutions arenot selected. A long-term monitoring and analysis program couldbe established to provide information to help identify and detectpossible adverse public health or environmental effects andminimize their impact. The site would also have to be reevaluatedevery five years as mandated by SARA. Monitoring and analysis doesnot address the remediation of the sludge, drums, and contaminatedsoils, nor does it address the potential threat to the environmentor public health via the associated contamination pathways. Also,it does not reduce the toxicicy or volume of the wastes.

37

SUNNttl OF REHCMCAL ACTION OBJECTIUES AND ASSOCIATED UHfMAl TECMNOLM1ES MID PROCESS OPTIONS If ENVIRONMENTAL HEDIA

AHEA OF CONCERN - HiOMIlE WiUfl SIDKAGE/LEAKAtt/IUSFOSAL AfcEA

ENVIRONMENTAL GENERAL RESPONSEACTION OIJECIIKS ACTIONS tthCIIAL TECHMLOH PROCESS Of I IONS

)«tchinf into Ue

POJENllAl IECHNICAL

Soil For HUM* Hc«tb

Prcvntioi of dtCMtKt Md/ar •llftftlM/l*k«U

Kl tonlwiMttdPottibU »rtvtit

Nu Ait ion NM* Not ApplicablemlCcfdMUlIIM of iRitittilimal Aictis MritrictiMf FeAcingMill. fcltoni

1M Of

fi^.red for io»ifcr<li<* br

Potentiullr opplicofale. Present HDNA fenceMCMp«»tft Ut ii U.

Co00

For EnvironwntglProtKtion

o(

0(

into thi (rou

Surftct Cappmf Soil Cover

H'jlti «edi'i Cup

Urrticol ihirriets Slurrr Trench Uills

6rt»t CurUins

Stcf) Shwt

applicable.

Hot apylusible. Qptiu* uud to reitrut thel*ler*l flow of 941*1 «nl/or 9rouriw<it«r.Sitt qrouftdwater i* iot Honing laterallythro>ioh iwstci Scremcil oul,

Hot apfluablr. Option u«d to retitrut thelateral flon of g«t«t anl/or grounduattr.SiU grwriwiter is lot flwiog lateral!)'through w-i&te. kremcd out.

Hot 4pf) liable. Option u&ed Lo restrict theUUral f)M of g*»t <iiid/or gitHiidualer.Sitt groundwaUr it tat flwing laterally

unite. Screened oul.

Hod BntuiU Potentially Appluuble.

ReHval Exctntion Soil! ond£x<ivatiun

Pulvnlially applic<ible.

TAKE 4-1 (CWIlttDI

SUHHAftl OF fcEKHCAL AC110N OBJICIIUES AMD ASSOCIAIEK REflEDlAL UOWLOGIES AND FKOCESS OPIIOHS BY EMVIfiOHHENIftL HEIIA

AREA OF COHCEM - HOMILE IMH SIOMGE/LEAKPOSAl AftEA

fcEHEBlAL ACttON OBJECTIVESENVIRONMENTALMEDIA

GENERAL K5PU6EACTIONS KNEIIAL IfCHtaOGr fftOCESS QfTlONS

InTrared

fOIENIIAl TECHNICAL AftLICABILIir

Salidifuaiion

Mot tppltciblt. Lunf ttr* leiwliin^ yaK noun.UaUliln Hill be drive* off. frweii utro4tinelr applied to hazardous N4ile sit*s.S< retted out,

TmtMnt Soil Flusfemj

Sail Ma slung

Soil Aeration

Imtwnt

Hoi applicatle due to larcrH ^ealof)'.Strewed twt>

PoUntiallr Qfipluable.

f'alentinllx •pplliatle only for volatilecupoundi in soils,

Hot Applicable far nun-ihlcrin-iled arquniScreened out.

Off site IreaUent

U*iiU

Ibtrwl Ireattenl

Ontitf

Offiite

Vatum Ext roc I ion

Biodeqrod'itiou

Idiiner-ilion

fttsilt

Off, He landfill

PaLentiullr •ipplunble.

foLmitiullr

TAW.E 4-1 (CONTINUE!)

SUrlHAfil Of REMEDIAL ACUON OHJECT1WS AND ASSOCIATE!' KEMEIHAt lECHHOLKICS Mil PROCESS OPTIONS til ENVlMMflENlAL ttHIA.

Of CQNCEftH - 1NMJSIRIAL BASIE AREA

ENVIMWHEHIALHEIllA

GENEML BSPOUSEhi«SIN. ACUOH OIJECIIUES ACTIONS MHCIIM. TECHNDLOtt PROCESS VI IONS Potential Technical ApplK<itiihlr

Sail for

»t f«f«tivftill [«tui*atf4 HiUPCI's.

Mo Action

Action*

None Not

Atctu RHtrutiwt feacini)

for icnitJtralion br Nit,

fulentigllr applicable, fre^nl rfDMft teniethe iitt.

O

Fur E*vironwAtalf'rottction

Conlainwnl Soil Cuvir

F' i fvent i oa ofof

contatinantt i*lo the Vertic4l Carriers Slurrr Trrncb Ualls

Groul Curt-iiii s

Sleel Sheet f'lling

folentt'tllf appluuble.

«ppluabl*.

NaL jppln •ibie. Uptiun used to rtilriU thelatcrdl flew of (<jsti ond/or ^roundvatet.Site frtMAdunttr i& iot flwin) lutenllrthrough «.iste. Serened o-it,

Nat applicable. Option used Lu reitrul llirlotvral flou of (Oiei «i<d/ar fruutfMter-Silt froufldiNler is wl flowing l-iter«llrUtougli tfi&te. Screened O'lt.

Hal tppluibte. Option u*td tu r*itntl theliitrrdl flew of utset oad/«r |ruwidMler.Sit* growfwtitir is Ml flmnf Uterillr

Mile. Serened oul.

liocL litaltctwnt iMtMitc Slunr applicable.

Anavol Exctvtiio* So tit <wdExctvotion

Potentially applicable.

lucinerdtion

Infrared f'olentiallr applicable.

IAH.E 4-1 (UMTINUEID

SUNWfel Of REHEIiIAL ACIION OIJCCIIVES AMD ASSOCIAKIi RCHCIIM TECHNOIMIES AM PROCESS OMIOMS HI CHVlKOHntNIM ItEDIA.

ENUIRONHEHIALNEIM

GENERAL ttSNWStKHEIIA1 ACIION OUCCIHES ACTIONS TECHMOLOST PROCESS WIIOHS F'otenliiil Applii<)btlitx

SolidificationVtlrif i(*t)on Ntt «pplU«tlt. InHnitiun ••!» nnltni to

Uklti Hkul iifcifeiti mtkori.o«t.

Soil

Sail Itahing

Soil Arrotion

Mot of pi it at I* t'te to lax* re* qeolojy, PoorprocHi CMtrol.^alMtltl)r gwl'ti'ilf '»r tontonnal*d soil

the u»tt.of pi leak le for tonU»inot*d 101)

the

ImUtnt Mot 'tppluable lor non^chlonn-itedScttmei o-il.

U-tiU £i;tr-ntion Fulenliatlx upplicabl* far conttunated iuilwidtrlyini tht wt&U.Fatntullr applicable far ccwiU»inui*d soil

the wist*.

Offsit* Irt4tM*t Incmerilion

Oniit» Landfill

Off lit* lispoMl Omitv Landfill

faleutiolb

SUMMM OF

(CQNilNUEJ)

ACMON OUECIIVES AND ASSOCIAIEK KHIIJAL IECHNOLOCIES MI PROCESS OFIIONS tn IOIA.

nFiEA Uf ClWUh* - NOhlHtASI SWtltli AhtA

ENVIKMHENIALHflilA

Soil

Mm HAL ACHON ouaims

For H«*M Health

FrevntiM of iftftitlM/inhalation if fiifttiv*d«tt to«tMin<ited) NiUrcr*.

Preveniion of futurein|ettlM/iik-ilitiM Ujttovld octur «* iteep elope

GENERA! USf OMSEACTIONS

No Ait ion

InillUlion.ilActlMf

ConUiAkent

KMEIIAL ICCHNDLOer

Hunt

Aft*** leitrictiMi

Sirftct Coppmi

FKKFSS DPI IONS

Nut Appliiiible

Fencing

Soil CoverItallt-Mdia C-ip

fOIENIIAL IKHHICAt rVFLlCAtiUlIt

FiegmreJ fur iun^i4er<itiui> tii tilt-.

Foleatiollr applicable, heivnt flWtff fenceencofepastes the site.

Fotenlially applicable.fotentiflU* applicable

Nl

itwtslrs.

(ot F-nvirooientalProlHtlon

of »n)r«lion,through Ictickinf ofcmtMiN'inti i*to thef rwin^woltt,

f'rcvenl potenliul e:;posuf<

by (MtlAUMl CroilM ofthe ttetp tlopi of Uit«re>t.

WertK«l lorrurs Slurrr Irenth Uoll-,

Grout

Steel Sheet

IUcl ftttplMewnt leatooitc Slurrr

Nut up(jln. jblt-, Upliun u&ed lo reitrutlatrrol flow of j«**i antf/or iruunilwMter-Siti afouMujler is iol flowing

. Survenrd on I.

Nut applK'ibli*. Option uwJ tu r fit rutlolffol flow of jii*1* «»</Bf grSite |ro«ndwler it not floMini)

noil*. Screened u>it<

Not ipplit'ibl*. Option uieJ toIfltirttl flow af (flsei and/orSite irDwtfwtef it not floMina. loterally

Mite. Strewed out.

Nat <ippli(oble> Klotk dii|>Uct-wnl qroulinyit not tpphcoble on ilopiHt) topoqrupbr.

Soils wd B-isteIwtvation

Poltntifllly •iBpluuble.

0*tite ThtrMl Irttlwnt IncinerationInfrared

F'otrntmllr oppliiabl^.F'olenliolly applicable*

IAILE 4-1

SUMMM OF REnEUIAl ACIION 01 JCUVtS AMD ASSOCIAIfC MflfDIAl TECHNOLOCIES AW PROCESS » MOWS PI FNVIflONHINIAi H£*IA.

AhEA OF CONCEHtt - NOftlHtAS) bUhlEP AWA

EWIMHhEHTAlHEOIA

GENE8AL KSFONSEhint 111 At ACI1UH OlJfCIIWb ACTIONS MHEIIM. TECHNOLOGY PROCESS OfTIOMS f'OIEHIIAL TECHNICAL APHICAflll IU

Uilritmtiwif'utentioll)'Net tppluotle. lopofrofhr of theit nol «M#atible will) Ue option,

out.

Flirtical IreaUenl Soil Flushing Nut applicable fur coataiien.'e^ wdite. Natapplicable '• Uyrrad feologr. Foor prottiscontrol. StreenH out.

Soil Fulfill)*!!* applicable for conluiinuted sll»* uajl». Not ipplutble for

wtstes.

UJ Soil Aeration Hot iiiiphtible for dru»wd tioilv^i nor forPCJt.. Screwed out.

CfcMic«l Ireatwnt liechlonn-ition

folenliullythe

fur conU»inaledHot «pplic«bl* f^

applicable for tunl>i»iiiult>t) ^the wite. Hot applicable foi

Offilte Ireutkent Treat ten I Intinn-ilion 'ipphcable.

Oailtl

Offiitt Bi&pota)

ftliltf I'Kldflll

Offsite landfill

uble.

TAItE 4-1 ICMMMCPI

5UWMM OF REMEDIAL ACTION OIJECTIUCS AMI) ASSOCIATE!' ttHEtlM TECHWIOSIES AM PROCESS OFIIONS P> ENV1 ROME HIM MEDIA.

AMA OF CDNCEFiN - I Of OF SUNICIfAl LAWFUL

GENERAL fcESHWSEHE bin

Soil

UHEIIAt AC1IOH OIJKIIMS

Fur MUM HnlU

F'rtvntiu of fiftitiai/labtUtiM tf fnfttlvtAlft COlUoil4lt4 MitbFtl's.

F-rolcctiM

ACTIONS

At t tons

ContdiAient

MNEIIAt TECHNttOCT

AccHt ItitfirtiMs

Svrftct Cupfinf

fMCESS Of IIOHS

Feacmi

Soil CoverNllltl-Mdl4 C-lf

F-OIENMAL TECHNICAL AftLICAlll IIV

f'Otentialtr' «pphc«blt, Present HIttft fence«i(«p«iei the iitt,

Potentially <ippliC'ib)e.fotenlullj' applic-ihle

fr*vwticfl of tigrttiM ofPCI CMtMlD-ltfd Mil frNthe top of the (outfit) to

lw Irmf areas.

Vertical larriirs Slurry Irene* Ualli

Grout Curtains

SUel Sheet f

Mat .i^plKjlle. Dptiua used toIdUral flow of aa^ei and/or fruundu«tcr.Site fronndtNLer i» not flawing laterallyUrouqn yule, Sut-encd (tut<

Nut •pplitibU. Option u-, 1 [alateral flow of ga&ei tnd/or graundwiUr.Siti froundiciUr is »ot flouinq Uter«llrthro>jfh iciste. Screened {,<>{.

Hot tpplictblt. Option a±fi tu rfilntt1'iltrttl flow of uib» oud/or qrouadMter.Site |ro«n*Nter it Mt flowing Ittertllrtkrou|h wsle. Screened out.

Hack Iliilacewnt lefltoaite SlirrrfifMti»|

Not <ifpluable. ContiwinttH sail is luo(hollow for block dis»l«ei«flt frvtinq to beeffective. Screened out.

Eumtio* Soil* and F'otentiollr

Incin(r<ilionIifr4red

fotentiollyfutentully

TAKE 41 IL Will HUE ID

SUWAht OF hEHEUIAl ACIION IMCIIIICS AHI> ASSOCJAHI' KErlEblAl lECHHOtKlES AN WOCESS OPIIOHS HI FNVIfcOmtfHlAL HHUA.

AREA OF COMCEM - IOF OF ftUIUCIrViL tAN&fILL

EWIMWHENlrt GENEhAL KE5FOHSEftEHCIIAL ACIIIW OIJeCHUCS ACTIONS KHEIIAL TECHN&OGr PROCESS OHIDHS FOIENTIAl TECHNICAL AfflICrtBU lit

Solidification

VitrifuQtion Not -i^plKQtle, depth of contQkin«ltd ioilis ualr 1-2 feet on lap of

out.

IfwtMnt Soil

Soil

Soil Aeration

Nut applicable, fay i*creait threat tofro'iriiMter by le*thi«) nt<ttt \ntiqScreened out.

Mat tpplKtble for fCI's. 0(ilion u*ed tornovt volatile and Screened out.

Chnko! Iftotwnl (iKhloc inition fotentiailx applicable.

U-siU Trntwnt Extinction

biode|r-idalioii

Mat appluabli- far f'Cl's. Option med tornovt valotile and &Mi-volalile or(*niti.Screened <wl.

applicable.

flffiite Ire-iUent

In sf osi) 1

DTffiU

Landfill

OffiiU Undfill

F'otentialW

F'otenlioltr

WLE 4 I ICUHMNUEN

SUHrMAT OF fiEHEMAl nCHON DIJECNUES ANIi ASSUCIAltli hihUUAL lECIMDLKIES AW FWCtSS OH IONS M ENVIfrtWrlENlrU «UIA.

AREA OF CONCERN - RALflUSSEN HUM SHE GHDUNMAIEfl CMIAIimilUI

EHVIMMrlEHTAL GENERAL RESFOHSEREMEDIAL AC110N Ob-tCUWS ACTIONS

O\

KHEI1AL KCHNOLNV fhOCESS OHlONS [ECHNJCAl AFtl ICADll ITT

Ero'indiMler For HUM* HMllli

FrevtfttiM of maettiM of

in. e*(«i ef HCLi andVor lnstilition<iluaiiceattble kealU riUi. Attioas

rreveot inhaldtiM ofmfors that Mr awnate

1 friM fnwndwaUr Uat Mrexceed leveli Mucceplableto htifei* tietltk.

for EnvironaenlalF'rotK I ion

None Not rtpplitotilt Ft^uired fur Lunbider>ition b> HCf .

Honitoriitf, and rtonitorinj und totenliglU uppluublt in toiijuiitt ion uilhAMlritt Anolysii othtr rektdi-il optio»( not u &tund-nlone

oetton.

Hell CMStruttion l*ed restrutioni Foteititlly u^l liable in cun,juni tiun wtlliKectrictlMf other reaeJul options, nut i ^t<ind-olane

option.

Alteraatlve U>it«r bottled tbter r ulenlikillc ^(jliublt in iuajm«liuH uilhother ree.Hiul uptions, nut •) ilund Jlont-option.

Move Ground lanKs Fctentully upplicuble in ton-junction withother medial op I ion*, not a sUnd -lion*option.

I'etper or Upqr<idienl F'atentialli' iipplutble in lunjunc tiun mthHell& othrr re»ediiil up t IMS, not ire no Kuntrtlm utUin the minitt of the titr.Screened out.

Surface Capping Soil Cover

Hulti-iedu Cup

Vertical barriers Slurry Irentli U>i)]-.

Grout lurtaidi

Steel Shttft f i hug

Not (pplittaU fur presentScrewed out!

Hot ipplittkle tut presentScreened out.

plti»t.

<ip|ila<ible uKmq uilh

upplifiblv alunij uilh

FuUntiallr upplitnble ilonq with

1MLE 4 1 (tONUNUCIt)

OF MIOIM ACIIOH OI-JKIMS ANI< ASSOUAN t.inn>it* UCHHQLOGICS AW noctss Of IJONS M HE MA.

AMA Of CONCERN MSriuSSEN LUfflF SHE dffOUNI'UAIEh CONlWIIrMIIW

CNUlhOHNENIALttUIA

KWKALACIIUN UIJICIMS ACIIDNS MHEIIAL TECHNOLOGY fftOCESS 01 IIONS fOIEHIIAl TECHNICAL AH'UCAIIl IIY

l,;tr.)itlon Mi-lib

Onsit* UeiUent fhnsic*! Irnttwl Air Slrippmij

Chetlt-il Irealient Curbuu

in toiijuftdiunoftiMS requircil to r»ove

loltntnlly -ifflM'itilt.

u(j(j|i

In Situ tutentiul lr

Off site Ii^ltent f'hciu«l Irealaent Kftoval to IUIU

to trt- i

Groundw-Uer KechnrqB

U<itei

tre-ilin) Injection w e l l ( b )

lre«ti*fto

svrfttt Htter

lu H<iruu hi

Hot «pplic«tl*i usuffitient sire afor lufoon on site. Screened out.

Fuleuliiil It A|)|j 11( uble.

IAILE 1 1 (LtMUNUEbt

SUWMM of UHCUAL ACIION OCJECIIVES AND ASSOCIAIEU UHEDIAL UCHNOLMIES AM FUKESS OFIIONS in EWIMMHENIAL

AKIA OF CUC£fJ - Sf l fKLKKG S.1IE GftDUNl'UAfEft CONIAllJfMIIlri Himl

EWIfdMHCNIAL CENEkAl hESIONSENttlft htltClllrU ACJIOH OBJECIIUES AC1KWS

liruundwater For HUMQ Health- - - - - - - - - - - - - - - - - - ' - - - - • - ft! Al lUM!

f revenliwi of ingettioti ofMt*r htVlfl) (MtMIAMti

i* f«crii of Wfl* «nd/of Inshtuliun.il•iOuitvpUbU fce-illh ruti. rVtiofli.

( revent indolalian ofMpofi thai ••» CMnite

MHENAL HDlHOtOCI fhOCESS ffllUIS

None Nut Applicable

Honitorui) ind Honilunn^ 'iiiilAnal put Anolriii

Hell CMitruclion ked rtstruti*^RKtrictioof

EOIENIIAL HCHNILAl rtlll ItflHl 111

heq'iirvd for mmidf i J

folenti-jJlKother re*edOftlOfl.

luttntiallr

applitubleill oplmns

ujjfl liableOilier rewditl jptiooi

tiun t» mi .

in luiij'iiK lion. Nut -i blend !

in lun.fiM Hun

HI III

jlwie

Ulltl

> Hoi -i itind aluiiefret qroundtMiUr Uiot koyexceed levels. «n'ic[rpUblela buAun health* Altfffnat ive Uater U-it^r

aption>

folenti-illr applicable in < wijiim tian nth(ilhfr iMediol uptiu(it> Nut .1 iUfid--ilui>eOption.

00 Above Dro>in* Unl.s o^pl liable in con.funilionother rnedidl aplioni. Hal o itand-iOfllM,

For

|ruundtMt*raquifer to ciMCutrationl*v«l* that to tot «xc«d

or Upqi'idientUelli

ftnniLip.il U-iter Srble*

Individ'i'il Irt'.ilitnl

futeiili-illy

Hoi apphoible. Ikeie 'irt nosrttn& in tht vitinilr of Ihv site.Scretuit o-i t.

futen* i«ll» •i^pliuble,

SurftKf Ctppinq

Vtrtuol barriers

Suit

Hulti ftfdia Top

illO'll I'll Ull'i

Steel Stiff I I i

Hut tp|ilic«bte fur (iri-iwl tunt.ihin<intScreestd out.

Mut tpplicablf FurScreened out.

Hut apflicjbU d'li; lo Hie luiunlerotle Jrflltu tiedroi*. Si re mud out.

li'lfiiUullr a(.(i 111 'iblf along will i ln->tl«ml.

Nut .((JplHiit. l# >lu« lo ^e lto liediud. S.tfi'Hfd cut.

lAfclE M iCOlllIMUdil

SUWMKIf OF kEHEI'lAl nCIION OIJCUIVES Ml ASSOC1MEI' MHFUAl UCHMLMIES Ml FMKESS OPIUMS H EWIRONflENlrtl HEDIA.

AWA » CDNCEKN SHEtfl KM SHE GHWNWIIER CONIMIHAllUt (IUH£

GENERAL fiESf (USEACIIOH OIJCCMUES ACIIOHSHE IIA KHEI1AL TfCHNOLOiT fhOCESS WIIDttS I-OIEHIIAL TECHNICM

fciiplateunl benlonil* S lu r i *Imettio*

Not appluuble (or pie^enl lunUfcinant plute.Suenetf oil.

E:;tr<iLlion

Onsite IrraUent Ire-iLwnt Air ( o l f n t m l l y

TrroUeiit

Ireatunt

It Situ Treatment f o t e n l i u l l .

Offiite IreatiMt fliysktil Iredtwnl

CrwindiMter t MiU Groin*

f'Mpi TtMt, <indDtub«rf« to

f>ttuvul to ffllu

to li»<itkriitF-uilily

Injection IMII-J

Coflilr'(i.tioft i ' f lir«i Fnver CotMtially in con.j>jnttioft

Mttt 4~2

SUrVMRf OF EfFECNVENESS, IrtfLEhENIAIIim, Ml GENERAL COST FGR KMCJIft TECHNOLOGIES Ml ASSOCIATED PROCESS OPI10HS

AflEA Or CONCERN - HiOMILE W*W SIWAGE/LEAKAGE/BISJDSAl AREA

SOIL GENERALRESPONSE ACTIONS KEMEDIAL 1ECHNOLOCT rkOCESS OfllONS EFFECTIVENESS 1HKEMENIAKILIII COS I SCREENING 5UIUS

No AiLion Ni.ne Not ApplictUe Dues dot achieve rntditl Mtionobjectives.

Institution^ Access Restriction f«KinfAction

Subject to public and None.regulatory octrpUnce.

Effect ively rrttricts num. rliniMlCWtnct. No Present HUM fence

into Mcoopgssti area.

heluinetl fur further rvuluution.

Lav cnplttli Ion Retained for further evaluation.

Cm U invent Surface Cappikq Soil Cwtr Nininim direct coattct with Mites.IMS tat providi M itftriMblt lorer.

Cap Effective 41 M (•pcriMllt layer,susceptible U

Low c«pllolf lou Retained for further

Nuderate c«|}itaJi Hftained for further•uderate

U) ftewvul Cxcavotion Soils ead *ifteEkC«V<)tlM

Onsite trealwnt Ih«rMl Irnlwnt Iiciwratioa

lifr«rtd

tfftiiive, reh«bl«( vtt provM process. Easily lapleMntfd, but fhider*t« topttulitnantion to <nter ttble M4er«te oftr«tiM.require large value.

fur further evaluation.

Effective for r*Mvi*f orfuics and Sub.ject to tvoilabiltf. High captul. kiyb fteUined for further evaluation,f-CCs. ReiidM Mft b* diffottd sf. Air Missions pernit OM.

rtqutrcMnts nvst be net,Pernit not required.

ExperiMnUl proem* HtMwn ornMit>> Subject to iv-ul-ikilty. Hi«n capital, high Retained for further evaluation.•etalf, Md PCI'*. ftttUM Mist be Air Misiions pernit BIN.disposed of. requirement* Mist be net.

ftrait not required.

Sol i<i f nation Effective for trfMitti MUU« PCI's,and mciiioMtiM mid«n<

•ench stile ond pilotrequired.

capittlt IOM Retained for further evaluation,

Phrsiul IrMUMt Soil Hushing Effect ive for wUIti bilo|M*t*dfolvnts, •roMticii Md) PCk. L«tK ofprocess control. Nut effective in1'irered

Pilot testinq required. Hodrrute tupitoi,Nifh OM.

Mat retained beituse of luck ofprocess coitr«l end petvritialiwffectivenest n lureredfeoloqy.

4-2 ICDMIlHUEIi)

SlMAAftr Of EFfECllUfNESS, IfUlfrtEIUMIlirY, AW GEtCRM COST FOR KHEIIrU lECrfWI (ffilf S ANI ASSOCIATE!) MtOCfSS Of (IONS

AUA OF CLWCfM * IWWiHf l*IM SlOfcAGE/lEAKAGE/NSrOSAt AW A

ttHEDIM KCMatfV tttttSS OfllONS EFfECIIVFKSSSOU GENERALhESfONSE AC1IOH5 COSI SCHEMING SMIItS

Soil tfleitiv* forsolvwls,

frattit control

k«|»tM-itrit <inJttslinq

Hud«r>iU capital i•igh OU.

fur further

Soil

IrMtMAt Mcuuk Extraction

Effeillve fur volitllf Md seii-volntil* tenth u<j)t <ind pilulorfdHUi. Not tffKtiw for FCI or Ustinq requiffJ.DlO;l»S.

Effective for voUttltfCh and tiaxin*.

but not filot leslmij ritjuiied.

fludrr«it« ctpitul,hi 4! DM.

Hoderate L*piU),hifh Mr).

Ketiiined fgi furtherfor portions of HiSLIi not

Hot retained far furtherin lieu of other equallyeffectivet coreoptima It. il inn hmdle

Effeitive for hydrocarbonno«-haloi»n«ted OKMtlcfi utf KB'i.LiBit«d prKfii CMtral. Htr not beeffective for widely Jisttrttd

tench scale <i»d pilot touttettinq required. OKI.

, »oder<ilif N»t iet<jmt-d fui evul'inliunbK'iuse uf liiilfd procBscontrol, and

Off&ile IreaUrnl Ther»il IreotiMl Incineration ff lecl iv« for reMvihf orfanics and Sub.jett totapacilr.

HiahDIN.

lou for further

Onsite lisposal Oniite landfill (ip|i<it>le and effective if (an«tr>icted fleq<iritary Hiyti high liel-tinrd iur fur ther eval'iihoti

jhj in)

'H10 si mad01

-jo

'HIO *jo *npt»|fJOJ

JOJ pw

01 '1tlJ*P°1(

0)

dT-3

fMin

'uoi)T)i<|r<A4 pan i PISH m( 'juitdcj m-|in apiAojrf IQU 1*04

•imiii.>.(nia ^niji.j jo)•*}U»W}UIM

KC\ '{oiidti MIHH,]|| IMMJJ OH *

IMIUIU

J"

OH

SOIVIS 9NIK33S3S 1SOO 11I1I4V1N3U3UUI SS»1(11I33JJ3 SNOIUO SS331HJ 1VI01MH SHOIIW 35MMSNWJ3H39 11 OS

5MI1JO SSlTOyj H31VI30S5V IHV S3IOD1WH331 1V1QH33 HOJ 1503 TVM3H35 '5S)N]n]n3333 JO

3I5VB

pautt>)a<J,

•Kinn| inno 01

<|oiid<<) i|fcrn si road*X|j*dojd

jt '»Alpajja put> diqMfay HUP'"'! |i*wtlsi|| »lisuo

'HIDpin HIUdjD iUtAOHJ iO)

•"(1 II" *|pH<>l| 101)1 IIKM) (fa (UlJ|JMQ

*H10JDJ

II1' '(pui-t 11*11

•no

'HID

pi)i'*Jl'U|Q (I'll *<

V'M-t

pus]fpn1 1 nb.it 6011^1

|V]raii pur4 isni a]snn

]n|t<1 put'

•silinljo •ffii'toA joj

tof «A|ii«jj4 inn

'»isiwJQJ

JOJ

iim|j»AQ 01 puttjo p»i 'I,

tsaxud

nils u|

1105

r-1IP

SOIVIS ONIHUOS 1501

.m SSIDOKJ aiivijtrssv «NV ^uiniowHjn IVIMIN WJ 1S03 WJWB wv 'IIIIMVIHJMIHWI '

SWIlffl SSIaVM WOWKUI W103H3HHMJR39 HOS

JlSVfl 1VIH1SWN1 - (Watt! W V3W

JO

TAKE 4-2 (CWUNUEm

SUNUM Of EFFECTIVENESS, INHEflENTAIIUIY, AW GENEIAt COSI FOR REHCIIAL TECHNOLOGIES Ml ASSOCIA1EH PROCESS ONIONS

ftttA OF CONCERN • NM1HEAST UftlEI WttJfl AREA

SOU GENERALMSTDNSE ACTIONS MHEIlrU TECrMOLOM ihflCESS OFTIONS

Ha Hilian None Hot Applicable

Institutional Acctfi Restriction! feelingActiMf

EFFECTIVENESS

Cots not •thieve retetfHlon jet lives.

action

Effectivtlr reftriiU access NlDlMlprotection «|ti*tt dJirttl CM tact. Mo•reveal ion af inteatiil leacklM iato

,ml,B,,HN,,

Sutjed to public tndrtquUtorr acceptance.

E-Jiily itpleaented.rreiwt MUM fmeMcoapotset ofe«.

COST SCMENIN6 SIA1US

Nwie, hrtaitied fur further evaluation.

Lau cupitdl, low ftetiiined for further evoluutioA'Mi*te**iicr.

frouBdMttr.

Con tu intent Surface Capping Soil Cover

Cap

H u 1*1 res dirtct cottdct »ith Mittt<IMS »oi providt w iipcnMkU Uyrr.

Effectiw# as <M i^tratoklc l«irtr.LMtl

tw topilol, lou fieluined for further evul<Mtion.

Hodfrate c«plU), f(ftuin*d far further evolutionNtuttMnct.

Excawotion SaiU «Ext •« I ion

rrltdkltt and provffi |rocMf. laplnrnteil. noderule tapital, hetatned for further evaluation,moderate

treotknt Itwrwl IrMttMl Incintrolion Effectivt for rtMvin| OTfMtci w4 SuljecL to nvailobilti" Hiqh i apt nil, high hdamed fu( further evaluuliun.fCk'i. Reside Hslfcf dii»<»Mlf. OU.

Ufnrtd proctii. Rnavts arfMict, Svlljtct to «v«l)gbilitx. High c-ipitil, |>i|h Retained for furtherfc, and ftl't. ftttitfw Nil It OU.

disposed of.

1 Mobilization Solidification Efftclivt ford«d inciwr-itiM

, MUUi hnck stale and pilot High copitnl, low Retimed for further evoluitioa.

IrtotKMt Soil Effective for Mtili,»lvHtt» troMtict, Midi fCTt,Itller ptocn* CMtroli Not •Iftctivtfor

lencb &c4le <)nd pilot for further tval'idtiM.bifb DM.

Ovtrlrinf Mitt M&t betxc«vdtt4 «4 trttted brother Mlhods.

TAME 4-2 1C OK II (WO I

SUMIAM tf EFFECJWENESS, IMfLlht MIAMI UK, AH» GCHEML COS! FOfi KHEIIAL TECHNOLOGIES AND ASSOClAIEU FhOCESS OH IONS

At [A OF CONCERN - HOMHEASI HftlEb Ittlfl Aft£A

MMEUlAl IECHNQLOGT PMCESS OPTIONSSOU GENERAL

ACTIONS EFFECIIVENESS COS I SCREENING SIAIUS

uiui

Cbee,icdl IreotMnt

In-Mtu I ret tint Vacwift Extraction

Iheridl Incineration

Ef fec t ive fur Kl's and sow chlorinatedHot effective for 4tm*tt

Ef(ectiv« for vuUtll* •rfMltt. Nottffcctivt for FCI* nor

m this «fM.

Ef fec t ive for hydrotarlmAon-h<itt<4en<tted *fOMticir Md PCI's.lUitrd ^rotess control. Mot efftttlv*far (ont<iineri;ed wo lies in this area,

filut testing rtq-med.Ke^uirtt tKfiv«tiM of

PilotOvtrlriRf Mil* Hit betxiavtted and treated byother

It-nil, it'll* and pi Ut

nuit brand titnteJ by

other neltiods.

Effective for reuvinf orftnici Md Subject tuPCk's.

High•odenlt OUI.

Hoderate tapiUl,hiak DM.

Nut rvldiiird in hvu«feffective, toreoptiont thit toil with thfother w>iilt4 in Uiii ore>i>

Hut fetmned in litu ofeffective i toreDftioni that deal with Ueother udstc*s in tins <irea.

lo« to^i t»l, noderdle Not re tamed in lieu of01*1. effect ive! kure Liiaprehvrii

options thul dtdl yitk Ueother iMste-i in tins DIM.

Hiqh ('ipit-il, low Relumed for furtherOUI.

Qasite Oniite Landfill

Offute Iti&potdl Offsite Londfill

ftell-ible dnd efftctivti if CMt true ted ItpIewnUblt for nunproperly. liquUt Hit bt rtMvcd «nd liqvid uastet.treated by other MtlUdls.

heh 'id Ir <Kid effective with proper Oil). Subject tu

Hiqh tm|h hetuined for Further

High cofitdlr hiijh tieliined fur further ?vg|'j<iliuu.BIN.

TMU 4-2 (CONIINUEli)

SUrlHARY OF EFFECTIVENESS, MtElfNIMILlTYi AM GENERAL CDS! FOR REMEDIAL TECHNOLOGIES ANI ASSOCIAIEIi PROCESS OPUONS

AW A OF COHCEkH - TOP OF HlWlCIPAi I (W WILL

SOIL GENERALUSIDNSC ACTIONS REMEDIAL TECHNOLOGr FFfflCESS OPIUMS EFfEtllWNESS IHPlEKNlAtlim COST SCREENING SIAIUS

HofUlion

InstitutionalActioni

None Not Atpliuble

Access ftfUrictiou FMUM

nat iichievt rtMdul «tloii

Eff«tiwelr rtttrictt Meets. HIRIM)pratectiu «fai»t lirtct CMtact. HoprrvntiM of potntUl iHchinf into

Subject U pub In

NfiMl feic*urrg.

Nixit!.

LDM ctpitol, lowkainlMtnct.

heluincd fut l<nth«r rvalutitiun.

ftettiined fur further tvilu-itian.

Cont-iinwnt Surface Capping Soil Caver

HuUi-kedia Cap

flinibiies direct conUct witk mites.lues Ml piovitfe « itptrtMble layer.

Ef fect ive as an iftperietble Uver.least SMStepltelc to

E-isilj-

Low 1 4p i till, lauMinUnanct.

Retained fur furllwr (volualiun.

flodrrate cupitdlr ftetdined for further evaluation.•uder>ite Htntenantr.

Excavation

cn[Incite

Sails and VotteExcavation

Ir«t»nt Ituinirulion

Mr. red

relioblt, and proven process. Easily iBplewnted.

Effntwe for rMOviif •rfMlci aidICH's, fctid'ie Mtt ke diipotcd of.

Subject to availdbiltx.Airrequired.

pnKfts. KttAvtl orguicd Subject toMtah. Mi F-CI'ft* KMit t Mil be Air eitiiiMs per»ittdisposed of. required*

Node rate topiUl>Mderale operation.

Htqlt C'lptial, hiijhOU.

Hi^h toill«li bighOU.

Detained for further evaluutiun.

fur further eviluutiun.

Kelmoed for further evuliliua.

luobiliMtion Solidification Ef fec t i ve for orf*njc*r MUlif ftl's» lench stale and pilotand i« inertliw miAwti testing reauired.

Hia,h <<ipitdl, low far further ev'ilu<it)on.

Physical !r»«tienl Soil Effective far MUls,solvents, trtMtici* Md) Kl't.Effective proem CMtral*

tenth st'tl* -Mid pilotrequired.

ModeratebiQh OUI

Fteluined for further evaluation.

IAIIE 4-2 (CONUNUtbl

Of EFFECMVENESS, lltUntNTMILIU, AMI GENERAL COST FOR REKIIA1 IKHHOlOCJl S AMI ASSOCIAKI UOCESS OfMONS

Af>£A (tt COMUHN I Of" Of HUHIClfAl IANW III

SOU GENERALhFSMWSE ACIIOHS MflEl'IAl l£l[H«aM.I f-MCESS OKIONS [fFECIIVENESS

Mtwut [lettilormalian £ * f n t i v < ? for fCCs and io*e cblonnflled

inKF-rlfNlAftlUK

f'llut tebtinij leq.iired.

COS!

Hiqh tapitd),*o*er«te tin.

SCKEEMIItG SIAIUS

Nut r^Unifd in In•ore (Oftprehenuve

"i of oilier4ltd COit

In situ Ii«-il*nt fii(Hle9r<i<f<iliun for brdrottrbM solvents)Mtic*. Md PCIS.

•rocrsi CMtr«l> Lulled•Am CMlMliHnti are

, low

bench sc*lr tind |>ilot

eff*ilive options.

luu ctpiUI, loilerate Nut rt-tamed in I leu of otherOUt. nore travttn, ctMlrolled

•f

OFfiit« lreul»fnt Incintmtioo fur rewvtufl itrftnici und Subjett tocipaotr.

High c>ipit'ilf luuOil).

ftctdined for furlber

Ontitr L-wdfill und effective^ if constructed heijut-jtory pertili Hiu> (<ipit<ili bi>jh Not retained due lo iniufhuenl, r^uir^BHti iyit be tel, DIM, s^gcr to teel tct-baih

Pfftit not required. refuireients farSite does not hattsufficienl *pj(* for st-tbull

Offitte Piif.oi.il Offsiti L.i.dftll and cfftctiv* vitk proper Did. Subject toctp-Kitr-

High c-ipitol, highDM.

Retained for further

IWLE 4-2 tCOHHNUEH)

SUMHAfcr OF EFFECMWNESS, lltfl WNIAHLW, AHI GENERAL COST FOR REHEBIAL TECHNOLOGIES AW ASSOCIA

AKCA Of COCEfJ - RASHUSSW WJW SHE MMWAIER KUHE

GfNEWW. HE MOUSEAC 1 1MS fit

Nil Ai t ion Ni

:ntI'lM lECHHOlOGir FhOttSS OF-MONS

»He Hot Applicable

UFECIIUENESS

l"oei nut ackieve rwedial actionol.je(tives<

infLEttfNIflHIIir

Sub in I tu public andregulatory oueplance.

COSI

Hone.

SLMMlNt, 5IAIUS

he U me J fur further ev^luati

At t IMSHoBilorin| (tailoring unJ

Atclrsitfar wmotorin) the flw

dirtctitM of tbt c«t«lMtim |]UH>•mi Ut Itvcls of CMU*i*a*lsthe iluM. tecs not rnedidtr p

E u * i l r Moderate captUI, low heUmed for farther evaluIB (onjmittion with ulhrrretedia) option*.

U?llfmstnctiont

leti depmdnt an continuedit*letvNtatian tHtll iito the future.I'ws not rcttort Ue «^<iifer tofttt

Subject to tOM for fijrlhfr evulIN (onjunction with utlieruplions.

UiCO Supply

Muter baUIrd Uiittir tff«livt fur preventing ntgrstio* orinhiUtion of (OfllMiMted froundwiter.I'o«s not restore •fulfffr to

i luu UIH. Nat

Above Ground Isnl4 Ef f t t l iv t? for prevntini mqe&lion orinhtUttM of foatMiMteil |ro«itdMttr.Oofi not restore ttjUifcr topre-contit»i*4tlOfi conditions.

Ho4ente c-lptlul,)o«OU.

Hot

lietper or UpgradintWell*

Effective for BrtvMliM ingettion orIN).tUlion of intUftiMled irowtdMiUr.Dots not restore tf ifer to»rt-cMt«*iMti« CMlitiMt. f'otrntialfar wells to totow cMtMiialed » tfte1'iturr.

Readily ItoderaleIwOU.

Hot

Individual Effective for pnvetiiftf inaestian orinh«l«tion of contuiMted |roundu«ter,Does not r»to» ifvlfer to

fceadilr i«|jle*tnled. tou capilalr low OIH. Hut reUinfd.

IAM.E 4-2 tCMTIlUEt)

SUMAM OF EFFEC11VENE SS, IHf LtflEHMIILIIV, AMI GtKML COS I FOR REHF.BIAL lECHNQlOGlES AND ASSOCIA

AKEA Of CONCERN - HkStUSSEN WflP SHE GRONMAIEfl (tlME

GENERAL HESfONSEACTIONS KKblAL 1ECHNOLOGI MfOCESS OPIUMS

Vertical torrier* Slurry Irench Holts

EFFECTIVENESS COS I SCREENING SIAIUS

Con tainted I Effective only trim uicd in conjuction Iiiffic-ilt to inplenenl. Hiqh coiiU)« Not retained.uiIk a retool on* tmUenl M»l«. ouderate Minlendnce.Don not provide ftigoff icanllr (rottereffectiveness Uwn rtMv«l «nd treattent

Grout Curtains Ef fect ive only nWi vsel )• CM jut I ionuita * r*Mv«l aM IrMUcntloef not providf *i|iificMtli«effeilivewsb Lb*M re»ov4l tntf•lone.

l<iffic«It to Hiffe cipiUlMderite

Not retained.

"leel Sheet I iling llie< live only «k*n used in tonjucliuimtk d rtMv«I ««4 tmtMnt wstet.Ikjes *ot provide sit«lfk4ntly frHlereffectiveness Uan reMn) «nd trwtuntdlone.

Hiffitull tu Hiqli (upiUl, Nut•odtrole Mintenance*

Extraction uells Iffeclivt on! relitklf kroceis forreiovioq

rto<er«te topi to),IDM 01(1.

Detained for further e*alu<iti<iN.

OnsiU Irealkent Ulrica 1 Ire»t«*nt Air Stripping Effective far r>Mvi»| volatile ii.plei.wUrt,hlol testing «nd nireBi&sions pern lirequired.

ltoder<ite cofil*!,•oderate OU.

feetained for further evaluationia cotjmction Milk olkeroptions Uial handle ley tones.

ChNical IreatMAt Carbon tdsorption Effective far « m4t rMff of or|anics•»d MtaU. Spent C*rk« Mit >fl

of or r*f(MMl*d.

Hodertte toil,md*r«te DM.

ftet'iinel for further evol'iotion.

liological IrcntkMt Effective far IOM levels of non^ f ilot testmq required. LIM capital.haloqHated arOMicit Volatile org«nut iodente Oth,Mr ke driven off tAd rtfuireand trroUeil.

for forthei ev>iluutiiin,

In Situ Ire-iUeftt l<iod«fruJati(ui tfleilive fur krdrocirboR ulventt» bench suit»on*h«|o|enoted iroMtkt, «nd PCI'f. testing rtfiI i»ited proceu control.

p i l o t LUH capital)•ode rule flIH.

Nat retained in lieu at aotkiller process tontrol u*dpotential effeLtivenest.

MLE 4-2 (CONTINUED

SUflMftf OF EFFECTIVENESS, IMI[fltWIrtSILHI, AM GCNERM. COSI FOR REHED1AI IECWNHOGIES AUK ASSOClA

OF COtCEM - M5NJSSEN DWlP SUE GMNMMTEIt FlUHE

UMEMl RESPONSEAC IIONS KEMEDIM. lECHHOLDGI PROCESS ONIONS

fk»K«l IrntHAt RrMVfll to POM

EFFECIIUENESS COS! Sf.WtHINO SIM US

Qf f t i t e i tffrcUv*ttjmrt pre-lrHtMit.

hn» »r* Hiqh c-if11*1, lowa tigiufiMnt Jiilutt DM.Fro* the iit*.

Hot rediiard keti'i%t ofof lot«l t-OIU,

InjKtion Itclldt

to IreatMnt

, Ttfat andlito CrouAd

ind tfFKtiv*

tfftttivt

No local I rallied I ctpilal, no OU, Not rtl>nned betduse ofof

if Hoderite(oncentrition (ktdtrol* Oltl

hilts tan be athitvrtf.

Rel-nned (or fuitlirr

Surface Uulfr

ChO

t ift to Huron River fu*?r lrt«t andhsth'irit ta Huron (i

Fielin*l« «nd efFittive Eaulr i«plt*fiKeJ, bulmtrictions oil rkiton Moderate OUfliver »<>r rule mil option

for furllift evaluation.

1WU 4-2 ICWIIHUEb)

OF EfFECIMHESS, IWLEHFNIAIlim, Ml KNCML COS! FOR REMEDIAL TECHMOIQGIES Mil ASSQCIA

AfcEA OF CONCEKN - SFIEGEIKM SUE GfKMIWlUk H.IME

GENERAL KSTONSEACIIOHS

Mo Ai tim

InstitutionalAction

flEflEblAL TECHNOLOGY PROCESS OPTIONS

None Hot Applicable

NooitoriHf tad NMiioriAt andfaolrsis toolrtli

EFFECTIVENESS

does aot achieve medial actionobjectives.

Effective for OMotoriAf the flwdirittioK of Uw CMtMiMtio* pluui

i.,,,.,,,,,,,Subject to public andre9<iliitorr accepl-mce.

E«sily iBpletented.

COST

Hone.

Moderate capital, low•unlcnoKce.

SCREENING STATUS

heiuKfJ far Further rvulu-tl

Rctdined for further tvgluatla CMjvnctiM with ulher

•1*4 UM levoli of caoUoiodnU withinthe il«M. loot not rtoediatt

rn«di<il options.

Hell Caiitnictioo [if«d reftrutioosfltttrictiMt

ElFKtiveACts deptadMt on continueditlleontotioi Mil Uto Ue («iUre>[<«e« tot reitore tkt ofoifer U

Subject to leaal Law capital , ION for furtherti (anjwictiok uith uthtrOftlOAi.

Attern.itive Uater fcottled Hater for prevent!**, inoftlion orikhtUtlon of tont««iMted frowdtMttr,[IMS «at retton ofulfor to

Low capital, law OU. Nut retained.

Move Ground TtuiHi Effective for BftVMtitf in^ettiM oruhaUtiM if (MUeOMltd (romtdtMter.Does not rcttort oyiiftr lo

Keadilf i*pl»ented. HoderatelOH Old.

Not reUi«ed.

Deeper or UpgrtdmtWilt

EFfecLive for prfvnli»| Ufestiai oriitlioUtlofl of CHltaiMM |touMw«ter.[iofs ml restore oo/iiftr toprt-contuiMtiea conlUioJis. Potentialfor uellt to becoM contoiioated it UM

fteadilr uplekented. Noderote capital,louOU.

Not rftoineil.

Individual IreatoMt EffKtive for prtvNtiaf tifntion or»h«Ulion of CMttaittltdtoes ool reitore oovifor topre-(onta»u«tlM

fteadilr uplcaented. tou CdpiUl, low OIH, Hut retained.

pinMini|do ftt ION 10]id pun

IMJOJdWM

nqj»MJMq JO} IUMIMJ[ nit; uj

14

jo

-UIOt»

jo

tr>f "V

'HOJOJ

01

pup (BAHHM

uoiimruoj HI pnn »•" 4|uo

•p*uit<)fU IOH '1U9M|dt( 0)

""**)*u saoflt l)llh

ut paw

nW}f jflttl «f1MJ< 10* 1'OQ

1UH1MJ) •» (HMIJ I tf|lflUl PMR »H*» l<1

1S01 SMIUO S53KTM

Will

TVI1WW SW1I3V

- IN33H03 JO

VI30SSV 4NV S3iOO)DNH331 1VH)3H]H WJ ISffl 1W3BM fMV 'A1PIIVIH3U31IU] JO AVVUW1S

TAH.E 4-2 ICOHMNUED)

OF EFFECTIVENESS, iitfLinEHi AUDIT, MI CENEKAL COST FOR REHEBIAL TECHNMOCUS AM ASSUCIA

AhEA DF CDWCffW - 5fJEGELKKfi SHE GfcONHWAIEri HUflE

GEHEWH tf SHM5EftUUWS fiEBEI'lAl 1ECHNUOG! rhOCESS OFUQHS

Physical Irntwul kewval to FOIU

fffECIIUEHESS

in* effective procets. Htr

IHFlEnEHIAMlllf COS)

Elisting ^ewei hoes ire Hiqh ctpitul,• siodifidnl tfiai the itte.

SIM U ING SIAIUS

llffiile Ire-atml Nut ntiiintd bec.iuie ofunavuilabililr of l«*l IOIM,

fi«v>v«l to

Urauntfuoter Injection Vellls) Futp( Ir*gt andfteiitjed into Gi wind

f*h-tl]( <ind *(f«tivt process.

fcvlialile 4nd itftclive prwess,

No lotolfan lit/

High capital, no 01H> Nut rttoined tfiu<i^« ofunavMihbilitr of localtresitkcnt fac i l i ty .

t'Jiily iiiple*friUJ if rloderite capital,discharge cMientratian rloderote 01H.hills c-ifi be othifved.

Re I 'lined for fu rider

Seep •) e lagoonli)

(T.Ui

l<t*i>t 1re.il >JH<J[>istkiifc to Sttp^cUaoan on Site

<tnd efFKtivc

Surf.it* U<i(er F'lpt to H>iron ftivcr (uip, Imt and ftth-ibl* ud (ffKtivt procc&t.to Huron hiver

t'jiilr i*(jli-**nled ifiite (fologx is

Hudente upttul,Hodertte (IU.

t^iily i»(ile»ehled, but Hodertte capital,restriction* on Hurofl ftoder<ile Oil.kivtr My nilt out option

(w In i ned fur furlliei evaloutiun

hdointd fur further evaluation,

The potential for future groundwater contamination would stillremain. The potential for direct contact with onsite wastes wouldnot be addressed. There is also the possibility of offsitemigration via airborne particulates.

Since monitoring and analysis will not remediate the areas ofconcern or the groundwater plumes, the technologies are notretained for further evaluation as a stand-alone option.Monitoring and analysis is retained in conjunction with otherremedial options. For example/ monitoring and analysis ofresidential wells within a 1/2 mile down gradient from the siteswill be considered during groundwater remediation activities.


This option would restrict the construction of new drinking waterwells in the path of the groundwater contamination plume. It wouldfurther prohibit construction of wells near the contamination plumeif the area of influence created from pumping would causecontamination to enter the wells. Periodic groundwater monitoringwithin and at the boundary of the restricted area should beimplemented to ensure the appropriate area is restricted.

This option would prevent the ingestion and inhalation ofcontaminated groundwater from drinking water wells, but would notrestore the aquifer to pre-contamination condition. Theeffectiveness of this option is dependent upon its enforceabilityand continued implementation for many years into the future.Regulatory agencies may difficulty implementing authority andcontrol over property owned by private landowners, and the aspectsof authority, enforcement and responsibility for deed restrictionsshould be further investigated if the option is considered.

Since deed restrictions do not detoxify, reduce or eliminate thecontamination, and the restrictions may be difficult to implement,they are not retained as a stand-alone option for furtherevaluation. Deed restrictions may be considered in conjunctionwith other remedial actions.

4.2.3 ALTERNATIVE DRINKING WATER SUPPLY

At the present time, none of the residential or commercial drinkingwater wells in the vicinity of the Spiegelberg/Rasmussen site havebeen adversely affected by groundwater contamination from thesites. However, the potential for future contamination maynecessitate the need for an alternate drinking water supply if theplumes are not remediated. Alternative water supply technologiesinclude bottled water, above ground tanks, deeper or upgradient

65

wells, connection co an existing municipal water system, andindividual treatment devices.

Municipal Water System-

Connection of residential homes to a municipal water system couldensure protection of the public from future use of contaminatedwater from the plumes. This alternative is viable as long as noone continues to utilize existing wells, or establishes new wellsin the future. Therefore, this alternative would requireinstitutional controls (well drilling and use restrictions) inaddition to constructing the system.

This alternative does not detoxify, reduce or eliminate thecontamination, nor does it restrict the migration of thecontaminant plumes.

There are no municipal water systems in close proximity to thesite. The nearest system is the Saxon-Wilmore system locatedapproximately 3.5 miles north of the site along Lee Road betweenU.S. 23 and Rickett Road. This system serves a small residentialdevelopment and does not have the available capacity to supplywater to the residences surrounding the Spiegelberg/Rasmussen site.

Since municipal water supply does not remediate the existingplumes, and the nearest reasonable municipal water supply can notsupport the area that would require connection, connection to anexisting municipal system is screened from further consideration.

Bottled Hater, Above-ground Tanks, Individual Treatment Systems-

Supply of residential homes to bottled water, tanks or individualtreatment systems could ensure protection of the public from futureuse of contaminated water from the plumes. This alternative isviable as long as no one continues to utilize existing wells, orestablishes new wells in the future. Therefore, this alternativewould require institutional controls (well drilling and userestrictions) in addition to providing the water or treatmentsystems.

Bottled water, above ground tanks and individual treatment systemsare alternatives that do not reduce, detoxify or eliminate thecontamination, nor do they restrict the migration of the existingcontaminant plumes. These alternatives are most commonly used foremergency water supply when a water supply has been contaminated.To date, offsite water supply wells have not been affected bygroundwater contamination from the Spiegelberg or Rasmussen sites.Use of these alternatives without other groundwater remediationactions would require very long term maintenance. On the basis of

66

these options being more appropriate as temporary options, and thatthey do not remediate the contamination, these options are notretained as stand-alone options.

Deeper or Up-gradient Hater Supply Wells-

Construction and use of deeper or up-gradient water supply wellsas a source of potable water for onsite or nearby residents doesnot detoxify, reduce or eliminate the contamination, nor does itrestrict the migration of the existing plumes. The hydrogeologyof the Spiegelberg site is not conducive to constructing deeperwells, but placement of upgradient wells are possible. Thehydrogeology of the Rasmussen dump site would allow for deeperwells, but the property lines and existence of the municipallandfill in most up-gradient locations on the Rasmussen propertymay preclude up-gradient wells.

If deeper or up-gradient wells were to be further considered, anextensive groundwater investigation and pumping test would berequired near proposed well locations to ensure the existingcontaminant plumes would not be drawn to the wells.

4.2.4 CONTAINMENT

Surface Capping-

Clay and Multi-media Caps

Capping technologies are used to minimize infiltration, to reduceoffsite transport of exposed water materials, and to minimizedirect contact with contaminated materials. Surface capping doesnot eliminate or detoxify the source of contamination. Claycapping involves installation of a compacted clay layer over thewastes and includes an overlying layer of topsoil and vegetativecover to protect the cap. A multi-media cap would consist of animpermeable synthetic membrane overlain by a layer of compactedclay or other low permeability material and would also include alayer of topsoil and vegetative cover for protection. Excavationand/or regrading of some of the material in preparation for cappingis often required. Extensive regrading would be required to reduceside slopes for the buried drum area, perimeter of the top of themunicipal landfill, and probable drum storage/leakage/disposalarea.

Synthetic membranes and clay have been used extensively as cappingmaterials. Disadvantages may exist with respect to materialavailability, costs, and extended exposure/deterioration, but thesecapping materials will be retained for further evaluation.

67

Other potential capping materials include the following:

o Polyurethane foam

o Resins

o Sprayed bituminous membrane

o Soil additives and/or concrete

Cap materials such as polyu re thane foam and resins are materialthat have not had widely-practiced, site-specific applications.Their ability to meet the requirements of an impermeable cap isquestionable, therefore are not considered for use at this site.

Sprayed bituminous membranes, such as asphalt, are susceptible tocracking due to weathering, frost heave and settlement that reducesthe effectiveness of the cap. Special 'handling and applicationprocedures are required, which can increase the cost for this typeof cap. Sprayed bituminous membranes are eliminated from furtherconsideration based on their likely inability to minimizeinfiltration.

The Spiegelberg/Rasmussen properties consist mainly of sand andgravel. Therefore, soil additives and/or concrete may beapplicable at this site with reliable results. Disadvantages arethat caps made with soil additives or concrete are also susceptibleto cracking and deterioration, and special handling and applicationprocedures would be required during installation. The cost of soiladditives and/or concrete is usually greater than the cost of moreeffective capping materials such as clays, or synthetic membranes.

The following types of capping materials or combinations thereof,are retained for further consideration based on technical criteria:

o Synthetic membranes

o Clay

Capping will protect public health by reducing the potential fordirect contact with contaminated materials. It will also reducethe potential for offsite migration of contaminated materials viaairborne particulates or surface water run-off and subsequenttransport. The amount of water infiltration and consequentleachate reduction provided by a multi-media cap is greater andmore reliable than that provided by a soil cover or clay alone.However, neither a clay or multi-media cap will eliminate or reducethe volume of the underlying contaminated materials.

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According to the requirements of the RCRA, caps must be designedand constructed to: provide long-term minimization of migrationof liquids through the closed site; function with minimummaintenance; promote drainage and minimize erosion of the cover;accommodate settling and subsidence to maintain the cover'sintegrity; and have a permeability less than or equal to thepermeability of any bottom liner system or natural subsoils (40CFR 264.310) .

Sources of sand and topsoil material are expected to be availablelocally. However, the availability of clay in the local area isnot known at this time. The synthetic membrane and geotextilefabric would have to be shipped from the manufacturer.

Construction of this process option would be easy to implement atall the areas of concern. Considerable grading to achieve stableslopes would be required at the Northeast Buried Drum area and theProbable Drum Storage/Leakage/Disposal areas, as well as on theperimeter of the Top of the Municipal Landfill. This processoption, which includes both a clay cap or a multi-media cap, isretained for further detailed evaluation.

Vertical Barriers-

Vertical barriers may be utilized to prevent migration ofcontaminated groundwater from a site and/or prohibit lateral(horizontal) groundwater flow through a waste disposal orcontaminated soil area. Vertical barriers do not eliminate ordetoxify the source of contamination. Several types of methodsand materials for the construction of impermeable vertical barriersare available. These include:

o Slurry Trench Walls- soil/bentonite- cement/bentonite

o Grout Curtains

o Steel Sheet Piling

Vertical barriers for hazardous waste containment should bedesigned to intersect with an impervious layer (clay or bedrock)in order to atop or impede groundwater flows. The use of verticalbarriers on the site would involve trenching or driving sheetpiling a significant vertical distance. A silty, clayey confininglayer, approximately 30-50 feet thick exists beneath the Rasmussensite. The depth of the confining layer ranges from approximately80-105 feet below ground level in the vicinity of the groundwatercontamination plume. The confining layer is present on theSpiegelberg site, but is discontinuous in the area of groundwatercontamination. Thus, the vertical barriers would have to be keyed

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into the bedrock shale formation located approximately 180-200 feetbelow the ground surface.

Since groundwater on both the Spiegelberg and Rasmussen sites isnot flowing laterally through the wastes in any of the waste areas,vertical barriers would not be applicable for remediation ofcontaminated soils.

Vertical barriers would also not be applicable for the remediationof contaminated groundwater on the Spiegelberg site due to the lackof a continuous clay layer and the considerable depth to bedrockon this site. Although vertical barriers could be used to containcontaminated groundwater on the Rasmussen site, they would only beeffective when used in conjunction with a removal and treatmentsystem. Furthermore, use of vertical barriers along with removaland treatment would not provide significantly greater effectivenessthan removal and treatment alone. Therefore, vertical barriers arescreened from further consideration.

Block Displacement Grouting-

Encapsulation of the waste material may be achieved by the blockdisplacement method which involves installing side and bottombarriers consisting of a bentonite slurry. This method is onlyapplicable above the water table. The encapsulation does noteliminate or detoxify the source of contamination. The side andbottom barriers are installed using slurry jetting and injectionmethods. The successful installation of the side and bottombarriers are highly dependent on the size and depth of thecontaminated zone to be encapsulated, and the geology of the site.

Use of block displacement method would necessitate a surface capand leachate collection system for the small amount of leachatethat may enter the encapsulated zone. The purpose of the surfacecap would be to prevent rainfall from flooding the encapsulatedarea (the "bowl" effect). The leachate collection would beachieved using a small pumping well screened within theencapsulated zone.

The block displacement method is experimental and has beenattempted on several sites, as a demonstration project, with mixedsuccess. On sites where complete encapsulation was not achieved,it may have been the result of a lack of information about geologicand soil stress properties. Greater success may have been achievedif more detailed engineering and subsurface geology testing andinvestigation were made prior to construction.

The reliability of the barriers depends upon the integrity of thebottom barrier, and, to a lesser extent, the side barriers. Theintegrity of the bottom should be measured by installing

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representative borings and sampling through the bottom of thebarrier after installation. The reliability of the barriers willalso depend on the compatibility of the grouting material and theorganic present within the encapsulation.

This technology is not applicable to the Top of the MunicipalLandfill (too shallow), or the Northeast Buried Drum area and theProbable Drum Storage/Leakage/Disposal area (too much variation indepth of overburden). This technology could be applicable to theIndustrial Waste area, but the uncertainty of successfulimplementation of the method due to site geology, and the fact thatit is not applicable to the other areas of concern reduce itsviability as an option. Block displacement grouting will not beretained in lieu of other options that are more applicable to theother areas of concern, thereby allowing selection of more-comprehensive remedial options that can be used for several areasof concern.

4.2.5 REMOVAL

Excavation

Excavation of the buried contaminated waste would be effective as'a source control measure and would eliminate or reduce furthercontaminant migration associated with the waste. However,excavation alone does not reduce the volume or toxicity of thewastes, and must be used in conjunction with other technologies tohandle the excavated material. Remove all waste contaminated inexcess of the target cleanup criteria will have beneficialenvironmental and public health effects. Field screening duringexcavation activities will be required to provide the necessarydata that would more accurately define the areal extent ofcontamination and to determine when target cleanup levels have beenachieved.

Excavation is a standard and reliable technology frequently usedon waste disposal sites. This technology can be implemented usingcommon construction equipment and procedures. Typical equipmentincludes drag lines, loaders/ dozers, backhoes, and trucks.However, if the waste intercepts the water table, a well pointdewatering system or any similar wet excavation procedure would berequired. Since the waste areas under investigation lie above thewater table, wet excavation is not anticipated to be a problem.Some wet subsurface soils may still be encountered on the Rasmussensite due to leakage of containerized liquid wastes and infiltratedliquids. Extremely wet, materials may be stabilized with limeduring excavation to facilitate removal and disposal. Excavatedmaterial can be loaded onto trucks and hauled to an approveddisposal facility or disposed of onsite. In addition, stagingareas, decontamination facilities, and storage areas may berequired. Dust and vapor controls may be needed during excavation

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activities. There are no site restrictions which would prevent atimely completion of this alternative.

Excavation, when used in conjunction with incineration, onsite oroffsite disposal, or onsite or offsite treatment will minimize anylong-term effects of the contaminants at the site. Excavation isretained as a technology to be used in conjunction with otherremedial process options.

Groundwater Pumping

Groundwater pumping can be used to lower the water table, containand extract a contamination plume, reinject treated groundwater,or discharge groundwater offsite.

One or more groundwater extraction wells are commonly used to lowerthe water table and/or contain a contaminated plume.

Lowering the water table in an area of buried waste can minimizefurther degradation of the aquifer by eliminating direct contactwith the waste. At the Spiegelberg and Rasmussen sites, wastesare above, and not in contact with the water table. However, somecontamination of the groundwater may still occur due toinfiltration of water through the waste.

Pumping can also contain a contamination plume by creating conesof depression around the extraction wells, thus preventingadditional contaminant migration. Groundwater extracted from thewells may then be treated and returned to the aquifer usinginjection wells or recharge basins. Contaminated groundwater couldalso be extracted with no subsequent recharge to the aquifer (e.g.discharge to a POTW or treatment facility). However, since thetypes of treatment provided by a POTW (biological) would noteliminate all of the contaminants of concern in the groundwaterthis option is not being considered for further evaluation.

Groundwater pumping will require treatment and handling of thedischarge water. Discharges to the surface water will requireattaining discharge concentrations of contaminants that comply withlevels established for National Pollution Discharge EliminationSystem (NPDES) limits. Table 2-3 in Section 2.0 of this reportsummarizes the anticipated NPDES limits for discharge, as providedby the MDNR.

Groundwater pumping and remediation may also require monitoring ofdown gradient residential wells. MDNR will consider monitoringwells within 1/2 mile down gradient from the site.

Pumping technologies are applicable to the Spiegelberg/Rasmussensite. Subsurface conditions and aquifer characteristics will

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determine the quantity of groundwater that can be pumped. Theoptimum location of groundwater purge wells/ estimation ofdischarge rates and time required for plume remediation willrequire groundwater modeling and additional aquifer testing.Groundwater pumpingf in conjunction with water treatment, isretained for further evaluation.

4.2.6 ONSITE TREATMENT

Thermal Treatment

Incineration

Mobile incinerators have been developed for onsite use that operateas effectively as offsite facilities. Mobile incinerators can beused to reduce or eliminate organic compound contamination insoils, wastes and water. At this time, the rotary kiln is the onlytype of incinerator commercially available as a mobile unit. Amobile incinerator treatment system requires severaltractor-trailer units to transport the necessary equipment to thesite. The capacity of commercially available mobile incineratorsvary depending on the size and the type of unit that is utilized.Utilities needed for the operation of a mobile unit includeelectric power, auxiliary fuel, and clean water. The residueremaining after incineration will require disposal in RCRA approvedonsite or offsite landfill. Air emission scrubbers required toreduce air pollution potential will generate waste effluent andparticulates that must be properly treated and disposed.The efficiency and ability of the incinerator will have to betested to determine its ability to destroy the organic contaminantsto compliance levels. Destruction of PCS, dioxin, furan and otherorganic compounds should be demonstrated through a trial burn.

Installation of a mobile unit will require a clear, level areacapable of supporting heavy equipment. At the present time, thereare only a limited number of equipment vendors and mobileincinerators available. The availability and capacity of themobile unit will determine the site remediation schedule.Governmental approval and the required permits may be difficult toobtain, although SARA requires the EPA to select remedies thatutilize permanent solutions at contaminated sites.

Onsite incineration is applicable to the Spiegelberg/Rasmussen siteand is retained for further evaluation.

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Infrared Incineration

Infrared incineration systems destroy organic compoundcontamination in soils, wastes and water through thermal oxidation,using infrared energy as the primary heat source. Wastes arecarried through the primary furnace on a conveyor belt that isgently sifted to ensure mixing and combustion. Electricallyinfrared rods located above the conveyor heat the furnace toapproximately 1800°F. The residence time varies from 10-180minutes depending on the waste type. Ash residue from the furnaceis discharged into a hopper, and is then conveyed to a collectionsystem for contaminant, testing, and subsequent disposal in a RCRAapproved onsite or offsite landfill.

The organic vapor generated in the primary furnace is exhausted toa secondary chamber, which is heated to 2300°F using propaneburners. A residence time of 2.2 seconds ensures completedestruction of the remaining organics. Exhaust gases from thesecondary chamber pass through air pollution control equipmentprior to discharge.

The types of contaminants and wastes that can be processed includecontaminated soils, PCB's, dioxin wastes, and spent activatedcarbon.

This technology was recently used to treat a small quantity of soilcontaminated with organics, metals, and PCB's at the Rose TownshipSuperfund site, located in Oakland County, Michigan. Results of thetest are forthcoming from the MDNR.

Infrared incineration may be applicable to theSpiegelberg/Rasmussen site and is retained for further evaluation.

Immobilization

Solidification

Solidification technologies typically involve the mixing of wasteconstituents with materials that physically and/or chemicallyincorporates the waste into a solid, relatively impermeable mass.The process is designed to reduce the rate of contaminant leachingand volatilization from the wastes. The process does not eliminateor detoxify the specific hazardous substances causing thecontamination. Materials commonly used for mixing and subsequentsolidification include portland cement, lime, fly ash, and asphalt.

Solidification has several uses including improved handling ofwastes, fixation of liquid phases, immobilization of sludge wastecomponents, minimized leaching potential, and waste detoxification.

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Control of contaminant leaching and volatilization is dependent onthe solidification process and the wastes.

Bench-scale and pilot testing of the solidification process withonsite wastes is required to determine compatibility, mixingcharacteristics/ and curing time. Further testing should beperformed on the solidified mass to ensure that contaminantimmobility is adequate.

The equipment required for fixation includes standard cement mixingand handling equipment. Although asphalt materials must be heated(260-450°F) prior to mixing with the wastes. The solidificationprocess by design, increases the volume of waste treated.

Solidification has been demonstrated to be an effective processfor immobilizing sludge, most inorganic wastes, PCS's, and heavymetals. However, elevated levels of organics can interfere withthe curing of the fixing agent. Consequently, the long termleaching and volatilization of these chemicals will not becurtailed. The high temperatures used to heat asphalt materialswill also cause the volatilization of organic contaminantscontained in the waste.

Solidification technologies may be applicable to areas of theSpiegelberg/Rasmussen site that have elevated levels of PCB andheavy metal contamination.

Solidification methods may also be useful for treating incinerationresidue. Therefore, they are retained for further evaluation.

Vitrification

Vitrification is a process of solidification using extremely hightemperatures to fuse contaminated soils into a solid, impermeablemass. Vitrification was originally developed for treatment ofnuclear wastes, but has recently been tested for use withcontaminated soils and sludge. Electrodes are placed in the soilat a predetermined spacing. A high electric current is passedthrough the electrodes to heat the soils to their melting point,forming a glass or ceramic-lilce mass. High temperatures generatedby the electrodes will volatilize organic contaminants which mustbe captured and treated.

Extensive bench-scale and pilot testing would be required prior touse onsite as a demonstration of effectiveness. Volume reductionmay occur since water is evaporated and soil pore spaces areeliminated.

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The topography of the Northeast Buried Drum and the Probable Dr'jmStorage/Leakage/Disposal areas are not appropriate forvitrification. The Top of the Municipal Landfill is too shallowfor effective electrode placement. The method may be applicableto the Industrial Waste area, however, this technology does notproduce substantially greater benefits than other proventechnologies. The equipment used is unproven on a large scalebasis. Long term leaching of organic contaminants is uncertain andthe control of volatilized organics during the process may bedifficult. Therefore, vitrification is screened from furtherevaluation at the Spiegelberg/Rasmussen site.

Physical Treatment

Soil Flushing-

Soil flushing is a processes that use solvents to extractcontaminants from soils and sludge. Soil flushing is an in-sicumethod that mimics the natural infiltration process. Flushingfluids are introduced to the soils via leach-fields, injectionwells, or recharge trenches and are allowed to percolate throughthe waste material to the water table. The leachate is thenextracted through the use of pumping wells, treated, andrecirculated. Soils and sludge may need several flushing/washingcycles for effective contaminant removal.

Soil flushing solvents may be composed of water, organic liquids,acids, or bases. The addition of chelating agents and/orsurfactants to water may enhance its extraction efficiency. Soilwashing and flushing systems can effectively remove heavy metals,halogenated solvents, aromatics, gasoline, and PCB's, dependingupon the type of washing/flushing fluid used.

Soil flushing can be incorporated into a pump and treat system forgroundwater to produce accelerated flushing and decontamination ofboth soils and groundwater. Combined groundwater/soil flushingsystem eliminate the need for separate soil washing and groundwatertreatment systems. The effectiveness of in-situ soil flushing maybe limited by a lack of subsurface process control. Theeffectiveness of soil flushing is suspect in areas where soilscontain high to moderate permeability sands and gravelsinterlayered with low permeability silts and clays. Visualobservation an analytical testing of the subsurface soils in theProbable Drum Storage/Leakage/Disposal area indicates that siltylenses may contain the highest levels of soil contamination in thesubsurface of this site.- Soil flushing may not be effective inleaching the contaminants from these lenses. Pilot testing of themethod will be required to establish operating parameters.

Introduction of the solvents to the ground for the flushing is alsothe creates the potential for soil and groundwater contamination.

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Soil flushing is not retained for further evaluation on the basisof the observed layered geology that may impede the flushingprocess, the potential for creating further contamination of thegroundwater by the process, and the lack of process control.

Soil Washing

The soil washing process involves placing excavated soils or sludgeinto a liquid/solid container (e.g. cement mixer, pug mill, countercurrent extraction equipment) along with the extraction solvent.Following extraction the solvent is treated to remove contaminationand recycled through the washing unit. The clean soil can be usedto backfill the excavation.

Soil washing systems furnish a greater degree of process controlthan in-situ methods. Excavated soils provide better liquid/soilcontact which results in more effective contaminant removal, andreduces the volume of washing solvent needed compared to anequivalent soil flushing system. Soil washing can increase thevolatilization of PCBs, and this aspect of the method should beconsidered in the detailed evaluation of alternatives.

Soil washing systems will require pilot testing to demonstrate theeffectiveness in removing onsite contaminants and to verify systemdesign.

Soil washing technologies may be applicable to theSpiegelberg/Rasmussen site when used in conjunction with otherremedial technologies, and are retained for future evaluation.

Soil Aeration

Soil aeration is a process that uses air stripping to detoxifysoils contaminated with volatile organics. Several differentsystems are available and include enclosed mechanical aeration,pneumatic conveyor, and low temperature thermal stripping.

Enclosed mechanical aeration consists of mixing excavated soils ina rotary drum system. Increased air/soil contact provided duringmixing releases volatile organic from the soils. Forced air flowwithin the system captures volatile organic emissions and carriesthem to an air pollution control device (e.g. scrubber, vapor phasecarbon adsorption) for treatment.

Pneumatic conveyor systems involve feeding soils into a highvelocity air stream. A typical systems is comprised of a long,high velocity air duct, blower fan, solids feeder, cyclonecollector or other separation equipment for solid recovery, and anair pollution control device to treat the air stream. The inletair stream may be heated :o enhance the removal of less volatile

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organics. These systems allow for high air/solid ratios foreffective contaminant removal.

Low temperature thermal stripping systems are similar to enclosedmechanical aeration except that the rotary drum is designed toallow the soils to be heated. Heating enhances the removal of lessvolatile organics from the soils. As with the enclosed mechanicalaeration system, volatile organic emissions will have to be treatedprior to discharge.

Soil aeration is applicable to both volatile and semi-volatileorganic chemicals, but not to PCS or dioxin. Pilot testing willbe required to determine the effectiveness of the method.

Soil aeration is not applicable as a stand-alone option for thefour areas of concern (Top of the Municipal Landfill, Probable DrumStorage/Leakage/Disposal, Northeast Buried Drum, and IndustrialWaste areas) because they contain PCS and dioxin. However,aeration .Tiight be used on portions of the soils that arecontaminated only by volatile organic compounds. Such soils mayexist in the Probable Drum Storage/Leakage/Disposal area, andbeneath the wastes in the Industrial Waste area. Therefore, theoption is screened out for the Top of the Municipal Landfill andNortheast Buried Drum areas; and retained in conjunction with otheroptions for the Probable Drum Storage/Leakage/Disposal and beneaththe Industrial Waste areas.

Air Stripping (Groundwater)-

Air stripping is a mass transfer process that uses a high volumeair flow to remove volatile organic contaminants from thegroundwater or waste water. The most common type of air stripperused is the packed tower unit. Contaminated water is pumped tothe top of the packed tower and distributed over the packingmaterial. Large volumes of air are passed upward through thetower. The packing material is designed to cause the water to formfilms and droplets that have large surface areas exposed to the airflow. The volatile organics vaporize and are transferred to themoving air. Contaminated air emissions can be discharged throughthe top of the stripper tower, or passed through an air pollutioncontrol system (e.g. vapor phase carbon adsorption), if necessary.The treated effluent may require further treatment for metals andnon-volatile organics prior to discharge.

A packed tower is typicaJ-ly constructed out of lightweight fiberreinforced plastic. The packing material is also made of alightweight inert material. The influent water may requirepretreatment to remove iron or other compounds than can inhibitthe performance of the stripper. Heating of the influent may aidin the removal of semi-volatile organic chemicals. Pilot testing

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would be required to determine the optimum air to liquid ratio formaximum removal efficiency.

The efficiency of the air stripper for removing organic compoundsdepends greatly upon their volatilization characteristics, and theefficiency of removal will vary depending upon the compounds in thegroundwater. The use of this option is dependant, in great pare,upon the volatilization characteristics of the contaminants. Thelevel of contaminants allowed in the water discharges and the airemissions produced by the system also influences the applicabilityof air stripping as an option. For these reasons, air strippingis often used in conjunction with other technologies such as carbonadsorption or biodegradation systems.

This technology is applicable for treatment of the contaminatedSpiegelberg groundwater plume. The Rasmussen groundwater plumecontains high concentrations of keytones which are not readilyremoved by air stripping, precluding the option as a stand-aloneremedial action. Therefore, air stripping is not retained as astand-alone option, but is retained as an option in conjunctionwith other groundwater treatment technologies.

Chemical Treatment

Dechlorination

Dechlorination is a process that involves the addition of an alkalimetal and polyethylene glycol (PEG) reagent to remove chlorineatoms from chlorinated organic compounds (PCB's, dioxins) .Dechlorination processes have been commercially developed primarilyfor the treatment of PCB's in electric transformer fluids.However, the process may be applicable to soils contaminated withPCB's, dioxins, pesticides, and other chlorinated hydrocarbons.Residues from the process include chloride salts, polymers, andoccasionally heavy metals. The heavy metals may require treatmentbefore disposal.

The alkaline metal and PEG reagent is air and water sensitive.Thus, the process should be dewatered prior to treatment. Benchscale and pilot testing will be necessary to demonstrate theeffectiveness of the process.

Dechlorination could be applicable to the Rasmussen site, however,the testing required to demonstrate the process, the handling ofthe by-products produced-by the process, and its relative high costmake other equally effective options more attractive.

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Activated Carbon Adsorption

Activated carbon adsorption is widely used process that involvescontacting an aqueous or gaseous waste stream with activatedcarbon, which adsorbs or bonds organic molecules onto its surface.The typical activated carbon adsorption system consists of pumpinga contaminated waste stream through one or more carbon columns, orcanisters. When the carbon has exhausted its capacity foradsorption, it is removed and either disposed of or regenerated.Compounds that can be effectively removed by carbon adsorptioninclude volatile organics, chlorinated hydrocarbons, ?CB's,phenols, aromatic hydrocarbons, and some heavy metals.

Mixtures of organics may cause reduced adsorption of a particularcontaminant due to the preferential adsorption of othercontaminants by the carbon. Waste streams with high solids contentand unassociated metals, as well as high humidity gas streams arenot amenable to carbon adsorption treatment. Pilot testing shouldbe performed on the waste to determine the effectiveness of theprocess.

Activated carbon may also be mixed with contaminated excavatedsoils to immobilize organic compounds and PCB's. The soil carbonmixture would then be backfilled and capped. The process isconsidered experimental and would require bench scale and pilottesting as a demonstration of effectiveness.

The activated carbon adsorption process is applicable to theSpiegelberg/Rasmussen site when used in conjunction with othertechnologies. It is retained for further evaluation.

Biological Treatment

Biological treatment employs naturally occurring processes thatutilize microbial metabolism to degrade organic contaminants(biodegradation).

Indigenous or adapted mutant microorganisms can be used to removeorganics from the soil or groundwater. Mutant microorganisms areselectively developed and have the ability to degrade specificorganic compounds.

The basic biodegradation treatment processes include aerobic andanaerobic treatment. Each of these are discussed in more detailas follows:

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Aerobic 3iodegradation

Aerobic treatment consists of conventional activated sludgeprocesses, trickling filters, and rotating biological contactors.A brief discussion of each of these processes is as follows:

o Activated Sludge Process

The process of activated sludge utilizes a diverse mix ofmicroorganism contained in an aeration tank to convert organicmaterial to carbon dioxide and water. Following treatment, themicroorganisms are separated from the waste water in asedimentation tank. After sedimentation, the majority of the"starved" microorganisms are returned to the aeration tank and a-portion is wasted. Periodic wasting of the biomass maintains anoptimum food-to-microorganism (contaminant to biomass) ratio whichis unique to the waste treated and the settling characteristics ofthe biomass.

Activated sludge systems can treat most non-halogenated organics.Pesticides, herbicides, metals and halogenated hydrocarbons andsolvents can be removed through the addition of powdered activatedcarbon. Retention times in the aeration tank vary from 2 to 5hours. Abrupt changes to the waste stream can inhibit themicrobial degradation process. Thus, waste stream and biomasscharacteristics must be carefully monitored. Volatile organics maybe driven off from the aeration tanks and require collection andtreatment. Undesirable odors may also be generated. Wasted sludgefrom the aeration tank will require dewatering and disposal.

The activated sludge process is applicable to theSpiegelberg/Rasmussen site, when used in conjunction with agroundwater pumping system. The soils and groundwater arecontaminated with a sufficient amount of organics to supply anadequate food source for the microorganisms. Pilot testing willhave to be conducted to determine if the system is adequate andeffective.

o Trickling Filter System

A trickling filter system uniformly distributes contaminated wastewater over a biological growth attached to a bed of stone orsynthetic support media. As the waste water flows over the supportmedia, contaminants are consumed by the microorganisms. Over time,the microorganisms grow and thicken on the media until theyeventually slough off and are washed out of the filter along withthe treated water. As in the activated sludge system, the biomassis separated from the waste water in a sedimentation tank.Trickling filters are extremely sensitive to changes in temperature

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and waste loading, which may result in a long recovery time formicrobial growth.

Since, the trickling filter is extremely sensitive to temperatureand difficult to control, it is screened from furtherconsideration.

o Rotating Biological Contactors

Rotating biological contactors (RBC's) consist of a series ofclosely spaced, slowly rotating disks that are partially submergedin the waste water. Microbiological growth attaches to the surfaceof the disks. As the disks rotate, a thin film of waste wateradheres to the disks, and the microorganisms consume the organicmaterial in the waste water. When the microbial growth gets toothick it sloughs off into the waste stream and is removed in asedimentation tank. RSCs have been demonstrated to have excellenttreatment efficiencies, but shaft breakage and failure has been achronic problem.

Rotating biological contactors (RBC's) are screened from furtherconsideration because of the problems with maintenance.

Anaerobic Biodegradation

Anaerobic treatment systems biologically degrade organic compoundsin the absence of oxygen to produce carbon dioxide and methane gas.Two anaerobic processes commonly used are the anerobic digester andthe anerobic filter. Anaerobic systems are capable of handlingsome halogenated organics and produce less biomass sludge thanaerobic systems. Abrupt changes to the waste streamcharacteristics or environmental conditions can disrupt thebiodegradation process. Elevated levels of heavy metals or somehalogenated organics may be toxic to the microorganisms. Anaerobicsystems have significantly longer retention times than aerobicsystems and require careful monitoring to ensure efficientoperation. Sludge produced from the digester or filter willrequire dewatering and disposal. Undesirable odors may begenerated. Pilot testing will be required to determine theeffectiveness of the system.

Anaerobic systems are screened from further consideration due totheir sensitivity to non-uniform waste streams and long retentiontimes. The production of methane gas may be a problem if it cannotbe utilized as an energy, source.

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In-situ Treatment

Vacuum Extraction

Vacuum extraction consist of high volume pumping of soil gas usinga network of wells positioned in the zone of soil contamination.Air is pulled through the wells, strips volatile organiccontaminants from the soils, and is subsequently fed to an airpollution control device for treatment. It is not effective formetals, PCB's, dioxins and base and acid extractable organics.

Vacuum extraction reduces the source of groundwater contamination.The system can also be used to efficiently recover free productcontained in the vadose zone. Pilot testing will be required todetermine the effectiveness of the system.

The vacuum extraction process is not applicable to the Top of theLandfill, Buried Drum area, Probable Drum Storage/Leakage/Disposalor Industrial Waste area because of the presence of PCBs anddioxins (landfill and drum storage areas), and high concentrationsof organic in wastes and drums (buried drum and industrial wasteareas). The method may be applicable in removing soil contaminantsin soils beneath the wastes in the Northeast Buried Drum andIndustrial Waste areas, but it is not a stand-alone option and mustbe used in conjunction with other technologies. Since equallyeffective options are more comprehensive in application, the vacuumextraction option is screened from further consideration.

In-situ Biodegradation

In-situ biodegradation involves using native or mutant strains ofaerobic bacteria to degrade organic compounds in the soils andgroundwater. Nutrients and oxygen are supplied to the contaminatedaquifer and soils to enhance microbial degradation. A groundwaterpumping system can be used to effectively circulate nutrients andoxygen. Circulated groundwater may be re-introduced to the aquiferby a variety of methods, such as spray irrigation, injection wells,or recharge basins.

The feasibility of using in-situ biodegradation is dependent onseveral factors. These include:

o site geology

o soil characteristics

o aquifer parameters

o water quality parameters

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Since in-situ biodeqradation occurs in the subsurface environment,process control is limited. Effectiveness may be limited ifcontaminants (nutrients) are widely dispersed in otherwise "clean"soil media. In-situ biodegradation has been successfully appliedto nonhalogenated organic compounds (gasoline, hydrocarbonsolvents, aromatics, alcohols). Compounds that inhibit degradationinclude halogenated organics, and elevated levels of metals andinorganics. Soil and water quality parameters must be monitoredfrequently to ensure efficient system operation.

An in-situ biodegradation system may have to be operated forseveral months, and final results may not be apparent for one totwo years. Pilot testing will be required to demonstrate theeffectiveness of the system.

Since the process control is poor with in-situ biodegradation, andcontaminants may be widely and intermittently dispersed in the soilmedia, in situ biodegradation is screened out.

4.2.7 OFFSITK TREATMENT

Thermal Treatment

Incineration-

Incineration is a process that uses thermal oxidation to convertorganic substances to a less bulky inorganic material. Generally,only organic and combined inorganic-organic wastes are consideredfor incineration. This process can reduce the waste volume anddestroy toxic compounds by a number of methods currently available.The total destruction of organic contaminants can be obtained bythe use of incinerators that operate at temperatures in excess ofl,000°C. At present, there are only a few commercial facilitiespermitted under RCRA interim status. The incinerator typesconsidered for use on wastes found on site include:

o Rotary kiln

o Fluidized bed

o Multiple hearth

o Cement kiln

The process used by all of the commercial solid waste destructionfacilities is the rotary kiln. This unit has proven to be a very

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flexible unit that can withstand the rigorous conditionsexperienced during heterogenous waste type destruction. The rocarykiln incinerator is relatively simple and rugged while exhibitinga good performance and maintenance record.

Buried wastes will have to be repacked into containers acceptableto the incineration facility. Specific chemical analysis of thewastes are also required prior to acceptance by the incinerator.Due to the limited number of RCRA approved facilities available,the waste materials may have to be transported a significantdistance from the site.

The residue generated after burning may still require land disposalat a RCRA approved landfill. However, this would be theresponsibility of the operators of the offsite incinerator. Airemissions would be controlled through the required use of airpollution control equipment. Lack of available capacity at anincineration facility could cause delays in the transport andsubsequent disposal of waste materials from the site.

Offsite incineration is retained for further evaluation. It is aproven effective technology for reducing the volume, toxicity, andmobility of wastes containing organic contaminants and PCB's,

4.2,8 ONSITE DISPOSAL

Onsite disposal necessitates the construction of a secure hazardouswaste landfill. Elements of such a site must meet the applicableRCRA requirements and regulations (40 CFR 264.300 - 264.317) andmeet the requirements of the Michigan Solid Waste Management Act(Act 64) and Hazardous Waste Management Act (Act 307).

The Michigan Solid Waste Management Act regulations are morestringent than federal RCRA standards. Under Section R299.9603 ofthe Solid Waste Management Act, requirement (5) states that alandfill shall not be located in an area where there is not lessthan 6 meters of soil with a permeability of 1 x 10" cm/sec or less,immediately below and lateral to the liner. If this regulation isstrictly adhered to, the Spiegelberg/Rasmussen properties would notsatisfy this requirement due to the sandy nature of the existingsoils. The Michigan regulation require 150 cm (5 feet) ofcompacted clay in the landfill liner and cap, substantially morethan the 2 feet of clay required in the federal RCRA regulations.In addition, the Michigan regulation requires 150 meters set-backof the facility from the property lines (R299.9603(2a ).) Thisregulation would make placement of a facility that would handlethe Top of the Municipal Landfill soils not implementable.

In order to provide an evaluation and cost estimate for the onsite

85

RCRA landfill alternative, the federal RCRA-type landfill designcriteria and operating requirements can be used for the detailedevaluation.

If excavation and onsite disposal is selected for more than onearea, excavated material can be consolidated and disposed of inone RCRA landfill facility in the interest of practicality andcost-effectiveness.

Landfills, designed in accordance with appropriate RCRAregulations, are standard disposal alternatives, which effectivelyisolate and contain contaminated wastes. The effectiveness of thelandfill in containing wastes will depend on using properconstruction techniques and high quality construction materials.Installation of synthetic liners must be performed by qualifiedcontractors to ensure proper placement and_.sealing procedures.Clay must be properly compacted to achieve 10~ cm/sec permeability.Sources of sands and gravels for landfill construction should beavailable locally; however, availability of a sufficient quantityof clay in the area is unknown at this time.

In order to meet the requirements of the National Contingency Plan(NCPJ and EPA technical guidance, if offsite disposal is evaluatedas a remedial alternative, then onsite disposal must also beevaluated. Therefore, onsite disposal in a RCRA-approved facilityis retained for further evaluation at the Spiegelberg/RasmussenSite.

4.2.9 OFFSITE DISPOSAL

Landfill disposal of solid waste material can be implemented offsite in an existing landfill. Offsite disposal involves excavationof all soils, drums, or sludge contaminated in excess of the targetcriteria and transport of material to the nearest approved RCRApermitted hazardous waste disposal facility. Offsite disposal willnot require a permit for hazardous waste transport; however,licensed transporters are required to haul the material to thepermitted facility. All aspects of offsite disposal are based onstandard engineering practice, provided an approved hazardous wastelandfill is used as the disposal site.

Offsite landfill disposal will reduce any long-term effects of thewastes and contaminants presently at the site. Short-term effectswould be more severe upon the environment and public health because

of the potential risks associated with the transport of the wasteform the site and through the community.

Commercial disposal facilities must meet stringent RCRA, and state

86

permitting and compliance standards. EPA requires that a facilitydesigned to receive hazardous wastes from a Superfund site bepermitted and in compliance under RCRA. Transport of the materialsoff site also must comply with DOT and state/federal shipping andmanifesting requirements.

The implementation of RCRA land restrictions (Part 268) is ofparticular impact to this site since the wastes contain restrictedwastes, or wastes that will soon be restricted. Certain hazardoussubstances, including liquid wastes and solid wastes specified inPart 268, are subject to land disposal restrictions according toa schedule set by the regulation. The land restrictions in RCRAmust be considered for each area of concern during the detailedevaluation of alternatives.

Offsite disposal is retained for further consideration for theareas of concern.

Removal to a POTW-

This process would involve removing contaminated groundwater andplumbing it to a publicity owned treatment works (POTW) fortreatment. The nearest POTW is approximately 1.5 miles south ofthe site and located north of eight mile road just west of LemenRoad. This process would require construction of a sewer line inorder to tie into the existing system. In addition, the POTW mayrequire that the groundwater be treated prior to discharge to thesewer system.

This option is retained for further evaluation for both theSpiegelberg and Rasmussen groundwater plumes.

Removal to a Treatment Facility-

This process would involve pumping contaminated groundwater intotank trucks for transport to a commercial treatment facility.Licensed hazardous waste transporters are required to haul thematerial to the treatment facility. Transport of -he material offsite must also comply with state and federal DOT shipping andmanifesting requirements. The commercial treatment facility mustmeet stringent RCRA, and state permitting and compliancerequirements.

This option is applicable to the Spiegelberg/Rasmussen site andretained for further evaluation.

87

4.3 ASSEMBLE OF ALTERNATIVES

The process options that passed the effectiveness,implementability, and cost evaluation are listed in Table 4-3 foreach soil and waste area of concern; and in Table 4-4 for eachgroundwater plume. These process options were identified throughthe screening evaluation as being applicable for assembly intoremedial action alternatives. In assembling alternatives, processoptions were combined to form a range of containment, treatment,and disposal alternatives, including a no action alternative.Under SARA, treatment alternatives should be developed ranging frcman alternative that eliminates the need for long term managementto those that reduce the toxicity, mobility, or volume of thewastes. Table 4-5 lists the various remedial action alternativesassembled for each of the soil and waste areas of concern; andTable 4-6 for the groundwater plumes on the Spiegelberg andRasmussen sites. The alternatives listed in Tables 4-5 and 4-6 arepassed to the next step of the Feasibility Study (DetailedEvaluation), which involves a more detailed evaluation ofimplementability and cost to allow further screening.

88

TABLE 4-3

PROCESS OPTIONS THAT PASSED SCREENINGFOR ASSEMBLY INTO

REMEDIAL ACTION ALTERNATIVES(SOIL AND WASTE AREAS OF CONCERN)

PROCESS OPTION

No Action

Fencing

Clay Cap

Multi-media Cap

Excavation

Incineration (onsite)

Infrared Treatment

Solidification

Soil Washing

Soil Aeration

Incineration (offsite)

Onsite Landfill

Offsite Landfill

PDSLD

X

X

X

X

X

X

X

X

X

X

X

X

X

IW

X

X

X

X

X

X

X

X

X

X

X

X

X

NEB

X

X

X

X

X

X

X

X

X

X

X

X

TML

X

X

X

X

X

X

X

X

X

X

Key- PDSLD - Probable Drum Storage/Leakage/Disposal AreaIW - Industrial Waste AreaNEB - Northeast 'Buried Drum AreaTML - Top of the Municipal Landfill

TABLE 4-4

PROCESS OPTIONS THAT PASSED SCREENINGFOR ASSEMBLY INTO

REMEDIAL ACTION ALTERNATIVES(GROCJNDWATER PLUME AREAS OF CONCERN)

PROCESS OPTION RAGWP SPGWP

No Action X X

Monitoring andAnalysis X X

Deed Restrictions X X

Extraction Wells X X

Air Stripping X X

Carbon Adsorption X X

Biodegradation(Treatment) X X

Injection Wells X X

Seepage Lagoons X X

Key - RAGWP - Rasmussen Groundwater PlumeSPGWP - Spiegelberg Groundwater Plume

90

TABLE 4-5

ASSEMBLY OF REMEDIAL ACTION ALTERNATIVES(SOIL AND WASTE AREAS OF CONCERN)

Alternative _______Assembled Process Options____

A NO ACTION

B CLAY CAP/RESTRICTED ACCESS

C MULTI-MEDIA CAP/RESTRICTED ACCESS

D EXCAVATION/ON-SITE DISPOSAL

E EXCAVATION/OFF-SITE DISPOSAL

F EXCAVATION/ON-SITE INCINERATION/ON-SITESOLIDIFICATION

G EXCAVATION/ON-SITE INCINERATION/OFF-SITEDISPOSAL

H EXCAVATION/OFF-SITE INCINERATION/OFF-SCEEDISPOSAL

I EXCAVATION/SOIL AERATION/ON-SITESOLIDIFICATION

J EXCAVATION/SOIL WASHING/OFF-SITEDISPOSAL OF METAL RESIDUE, BACKFILL ON- SITE.

APPLICATION OF ASSEMBLED ALTERNATIVES TO THE AREAS OF CONCERN

PROBABLE DRUM STORAGE/LEAKAGE/DISPOSAL AREA- A through J

INDUSTRIAL WASTE AREA- A through J

NORTHEAST BURIED DRUM AREA- A,B,C,D,E,F,G,H,J

TOP OF THE MUNICIPAL LANDFILL- A,B,C,E,F,G,H,J

91

TABLE 4-6

ASSEMBLY OF REMEDIAL ACTION ALTERNATIVES(GROUNDWATER PLUME AREAS OF CONCERN)

Alternative Assembled Process Ootions

A NO ACTION

B MONITORING AND ANALYSIS

C DEED RESTRICTIONS

D EXTRACTION WELLS/AIR STRIPPING

E EXTRACTION WELLS/CARBON ADSORBTION

F EXTRACTION WELLS/CARBON ADSORBTION/AIR STRIPPING

G EXTRACTION WELLS/BIODEGRADATION

1 DISCHARGE TO GROCJNDWATER VIA INJECTIONWELLS

2 DISCHARGE TO GROONDWATER VIA SEEPAGELAGOONS

3 DISCAHRGE TO SURFACE WATER OTHER THANHURON RIVER

ASSEMBLED REMEDIAL ACTION ALTERNATIVES BY GROUNDWATER PLCJE

RASMUSSEN PLUME- A,B,C,E,F,G with 1 or 2 or 3

SPIEGELBERG PLUME- A through G with 1 or 2 or 3

92

4.4 PROCESS-OPTION (ACTION) SPECIFIC ARARs

Process-option specific ARARs, which are also referred to as"action" specific ARARs, are those rules and regulations thatpertain to the implementation, construction, maintenance andimpacts of the various remedial alternatives. The ARARs associatedwith process options and the assembled remedial alternatives willbe discussed, in detail, in the subsequent sections of thisFeasibility Study. A summary of the process-option specific ARARsis provided in Table 4-7 on the basis of area of concern. TheARARs are cited and briefly described, and those areas of concernto which they may pertain are identified in Table 4-7. Thedetailed evaluation will discuss exactly how each ARAR effects theprocess-options and assembled alternatives that passed screening.

93

TABLE 4-7

f'HOCtSS-OPTION (ACTION) SPECIFIC AKAH;,

VO

1KtUUlRfcMENTS

FEDERAL

1 . RCRA - Standards for Owners and Operators of Permi t led n^tat uuusWaste FaciHt1es(4a Lftt 2b4.IO - 264.16)

Subpar t containing r uyti 1 a t i uiii, tut i eu,u i red nu t i ces , ijtntji j 1 MJ u 1 uanalysis, secur 1 1 y and t nspe< t i on r equi r ement s . persunnul 1 1 n in my ,1 ocat Ion standards , and obta in iny an 1 dent 1 f 1 cat ion numbei .

2. HCHA - Preparedness and Pi even t i on ( 40 Cf"R 264.30 - ^b4.J7)

Requires that owners and operators design and operate hazardous nu^tef a c i l i t i e s to minimise tiiti p o s s i b i l i t y or a r i re . e*p 1 os i on , or r u I ea:>eof nazardous waata to tfiu env i ronment . Tn« regulations tn tnii suDpartinc lude requ 1 red equipment , te& t ing and maintenance of requ t reduqu Jpmunt . access to communication or alarm systems, required a i :> 1 espace, and arrangements to Lie made with local authorities.

3. NCHA - Cunl iiijtftiLy Plan ami Linui yttrtcy Procedures ( 4U tl~R i"b4 tin264.56)

Htiyuldtiona requtriny unnti i, antl upurators of haiardouj. wtii. t yf a c i l i t i e s to pr«pat a a tout mjeocy plan conta inlny em*r gancy pi m edm esdeatgnetl to minimize hazards to human health or the environment t i omfires, explosions, or releases of hazardou* waste.

4. HLKA - Man i fest my. Hvt-ui Uktsep i rig . and Reportiny(40 Ct-H 2b4 /u -264. /7)

these r li'ju 1 a t i ons r<*«|uire tho .ibu of a manifest system to t • ai k t(1L-waste recicwed at. or shtppud f rum a hazardous waste facility. Adetailed operating record must be maintained that describes the qua n t i t yof waste received, and its location within the facility. Thepreparation of a biennial fejiort is also required under this suiipai t .

5. RCKA • u< i..,nii«at e< Pi L. t t-i I 1 uii 1 40 CfR 264.90 - ^64.1Uy)

Th i s suUpar t contains standards speclfyiny the coniuntratiun lim i t : , t uiha/ai duus LO.IS t t t uen 1 s unlei IDIJ the U'OuitdMatei from a reyulaltuifacility. A yroundwater mo'i i l ui Ing pray ram and a cotruttiwe ac i i unproyram t i. alsu required.

fa, HCHA - Clusuie anU Pust l.lus>iie(40 Ct-R 2b4.tlU - ^t>4 . 1 L) }

!HU

u

u

l>

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u

L>

ARfeA OF CONCLHN

RAbMUSStN

1W NO IL

u

u

LI

O

U

u

U

l)

11

U

<J

u

u

u

11

u

u

u

UW

O

o

u

u

11

( 1)i,p1 - - -UM

u

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u

1)

Ul

TABLE 4-7

CNOLfciS-OPTION (ACTION) SPEC If - 1 C A«AHt>

NtqUIHEMENTS

AHtA OF CONCERN (I)

HAbMUSSEN

Owner* and operators of hazardous wast a management f ac t 1 1 t las nms tprepare a w r i t t e n closure p 1 an that identifies the steps necess^r/ toperform part la 1 and /or t ii.a 1 C 1 a sure of tntt f a c i l i t y . A post -c 1 us i irep 1 an must a 1 so be SuDun t ttd riio t identities the moni t 01 ing , ma i iu enoni-e .and other a c t i v i t i e s t h a t H i l l im cat r led on a f t e r c 1 osure .

7. RCRA - Use diid Mdfidgeiimnt ut Cunt d t tiers, ( 40 CFR 2ti4 . 1 70 /lj-1 .1

Theau regu 1 d 1 t ons apply to uwnei s dnd operators of lidiai Uuus H O ^ I Cf a c i l i t i e s that (, loru cunt j i nt;i i , dind Inc ludtt ConcJ i t ion, cuiiipd I in i 1 i i y

n t . i n s p e c t i o n , i_ontd i ni'xsn t . and closure requiiejinenti.

dct Impoundment & ( 4U LrR 264.22U - ^fc

Hequ i rumen is for tht des ign , op£rat Ion, monl tor ing and in spue t i on .emergency repair, dnd cIosutc dnd post closure Care ofimpoundment s.

y. HC:HA Wdbt« piies(40 CTH 64.251) - 2ti<

R e y u t d t i o i i t i yovern iny the ilet. iyn , ope rat Ion, mon i t or iny , in>pei I i > . uiidc lusu ie <>(id pa»t c l o s u r e i_di a ot w a s t e p i les .

IU. KCMA Tf eati i iuit t (-111 (. h W 204.270 - 264.2iJ9)

This buOpar t con t d n*b (etjiiljlioMJ. fur the use of 1 dnu t i tn linen I[he l e y u l d t f o n s Incluim p r o v i s i o n s for a treatmunt program <mudemons t r d t 1 on . design and o p e r d t i n y requirements, unsaturo t ed ^m o n i t o r i n g , and c l o s u r e and post closure C*ra .

KLKA I aiidf i II ul 4U LtH ,'), . Jill) . 3 J9)

Regu la t i ons for thti desiyn. upu rd t i on . monitoring, i nspeo I i tin, i I| and pas t c ) uiui u ca< e , dnd u tliei spec ia I requi rements of I andf i I I

HLHA In o t 4U

tAt-Lu id iny ty t f i i s bnt /u ine rd t t i I tn^ardxub wa^tediml/ i is. upera t iun , per t 01i us pec t i ur i . ai nJ i. I ijaiii t* .

H -'1.4 . J40 -

iu is ui operators of f a c i l i t i e s , t n ^ tl L.'unply w i t h t e < j u l d t t o n s c oncer n i n«j wJ i l c

IL e standards, perm i t t t ny . inun i t o i i M<J ji id

1 J . i 1 c an Wu I ui At 1 ( L WA ) L. 1 1 'J-IO . j i. ummeiidud ( IU LHJ 1 »'-

PD | 1W | NB | [L | I'M GW

TABLE 4-7

OPTION (ACTION) bPELlMC AKAKi

\Ocn

\ ~ A R E A OF'CONCERN ( i>HtqiJIKEMENTS

Part 122 regulations contain provisions for the National PollutantDischarge Elimination System (NPDES) p rug ram. The regulations cuvetgenera 1 requ Iranian Is . per mi t app 1 icat Ion and spec la 1 programrequt reman ts , permt t cond 1 t Ions . and thtt transfer , mudi f 1 tut i un .re vocal ion, ruiaiudnm, and terminal Ion of per mi t s .

14. CWA (40 CrR I2b)

The ragu 1 at tons in part 1 2b tsstdU 1 i s>h thu criteria and s tdnddr us t o> it itsNPOES. These include imposing technology based treatment requi r«=m«n t s .determining a 1 ternat 1 ve off Itiant 1 imi tat Ions . and ocean d i & char ye . amongothers .

(•j . I WA (4U CrH 4UJ)

Pdrt 4O3 contains yenern) pr v t r tttt tutwnt regulations fur new sour LCI, ufpu 1 1 u t i on .

Ib. T u n i c Substani.a Control At t or 1976 (TSCA) - Po 1 yen 1 01 i rid t e.lBipheny 1 s (PCBs ) Manuf at. tur ing . Processing , Dt&t r Ibut i on inCommerce, and use Proh ib 1 t ionst 40 CFR 761.10 - 761.79)

Regulations establishing requirements for the manufacture, proct.^^ my .distribution in commerce, usu, storage, disposal and marking at PCds> andPCB items.

17. TSCA - Rticordi, diid Rupuitt, (40 CrN 761.160 ~ 76l.lUb, dlsu (.rH129. 10t))

Part 761 . ItiO ttirou-jh 7bl . lUb LUVL.-I Mm recordkeupiny amj i HIKII i myreLfu i ( minjntb fur inu iner a t or :> . Lntjintta 1 wast a landt i l l s , liiyh ef I i > ium yboilers, and othur disposal arm aturaga facilities that hand 1 u PCBt, diuJPCB itaiitt. The ruyuldtiona in 40 CPR 129.105 contain tl>tt ufMuentstandards and ptuhibitions tur PCBs .

18. Cltian Aii A it ur 19b/ (LAA) Nat ton* 1 Pr imary and ^euoinJui yAmbient Air Qu a l i t y Standard* 140 CrR 60.1 - SU.l^J

(dubu r uyu 1 j t i oni> u b t d U l i s h I lit: lutioiul pr'imary diid j.ui .untlj r y . i m l i i i r i i lair quality standards tur boltui dlOKide, par t i Cu 1 u t e nidtler. > di l>unmonuKidti. Oione. nitruytjn diuxiJu'. dnd lead.

I'J . CAA S I jr.il ji d^ u 1 J'ti t ..i muni u f in l i i L l n e i c J l u r i ( 4() l t H Lll Ml60. b4)

RASMUSSEN

PO iw |NB Tt,

u

u

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u

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u

u

1

U

It

u

u

SP

uW Gw

u

ii u

TABLE 4 -7

I'KULt ii. OI'UON ( A C T I O N ) bl'tCII-JL AHAH-

HtCIUIREMtNTS

Requires owners or operators of tncnerattan facilttes to monitor andtest emission* for compliance * i t h the standard for participate malleicontained In 40 CFH liO-52.

20 . CAA - Nat lona 1 tun ss i on iiandai eta for Hazardous A i i Pu 1 uian 1 s(40CFR 61.01 - bl .252)

Regulations l i s t i n g standards tor eight (8) hazardous air p o l l u t a n t s .I a 1 ong with the mon i tor ing, tes t inu . report ing , and r ecordkeep inyrequ 1 reman ts for each .

2\ . OSHA - Cieiieral Industiy Standards (29 CfK Part 1 J I U J

Occupational safely arid health standards adapted to provide salu u<healthful employment or places of emp 1 oyemnt . Standaids ha«e tje<;iideveloped for wa 1 K ing~Mork t ng surfaces, means of egress, haiai ito.ismaterials, machinery and machine guarding, electrical systems, anillitany others .

22 . USMA - Saf et y and Htsa t th fteyu 1 at ions fur Cons t rue t ion ( 29 Lt i<Part 1926)

These regu 1 at ions set fur th me safety and hea I th s taridards forconst ruct Ion and construction related activities. Standards adopt «dInclude those for excavations, trenching and sharing, ladders andscafolding, demolition, personal protective and life saving equipment,e l e c t r i c a l , and many others.

2 J . P< ot ect i on or Nat ion a 1 Nat ui a 1 Landmarks t 3 fa ChR Pai t b_' )

Reju 1 at ions prescr ib iny the processes and criteria used to i d e n t i t y ,study , Jes i jnate , recugn f e and mont tor nat lona 1 natura 1 1 andmar h s .

24. Protection Of National Historic LanUmarkk ( Jb CrR Part bb )

ABfcA OJ CONCLliN

RASMUSSEN

PO iw |NB

o

o

o

o

o

o

u

u

U U

O o

These regulations set forth the criteria and procedures used by tncDepartment of the Interior to l u u n t t f y , desi united . and mon i t or nut i on a 1his tor Ic 1 andmarks .

^b. Protection of Historic unil cultural Properties (lib CrP. H a i l auu t u u

Reyii la t t uns that .lefine ttiu pi in ess itsed tty a federal ajurii_y to luht;lit to account the affects ut t lie agency's unJetteking on p i o p t i r t i c s

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TABLE 4-7

(ACTION) lUt AH AH

REQUIREMENTS

of the aquatIc env tronment. Thu guide IInea a I so specIfy thu a c t i o n s tobe taken to minimise the adverse effect* of a discharge.

30. Denial or Restriction uf Disposal Sites (40 OH 2JI)

The regulations In t h i s part include the procedures to ue f u l l o w u i Jby the EPA In proh ibi t Ing. deny iny. or rest r let ing any clef Inea orspecified area as a disposal site for dredged or f i l l material pursuantto section 404 (c) of the CWA.

111. UiDenzo-para-diOH iris/L) i Uenzoturans ( 4U Cf

Hetju la t i tins requiring the testing of certain specified chemicalsubstances to ascer tain wri ether or not they mihalogenated d ibenzodio*ins or d iben^ofurans. Test standards,yu (de I ines , pro toco I s . and reuor t Ing requi rentereuuIition,

32. Safe Or ink iny Water Act(40 CFH 1 4 1 . 1 1 - 141 . 16)

and organic enemies Is. turbidity, c o l t f u r m bacterla, radium 226.I radium 228. aIpha part icles, and photon radloactivi t y In pub Iic

ater systems. MCLs are enforceable standards.

AREA OF CONCERN (" 1 )

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3J. CAA - National Air Q u a l i t y Standards (40

These regulations establish the national primary and secondaryatnb tent air qua Ii t y standaids r ur SuIfur dlOAIde. nai t iculatecarbon mono*ide. ozone, nit royen dio*ide, and lead.

34. SDWA - Maximum Contaminant level Goals (40 CFH 1 4 1 . 5O

Doth organic and inorganic contaminants. MCLG:> arehea 1 th goa Is .

S T A T E OP MICHIGAN

bb. 1 - 706. Jd )

i f i dd chdoii ca 1e ton l ami na t u J M i tnt standards ,are included in the

iiiuiin Cun t tjin I nil' 1 1 1 c vc 1 t>

s (MCLs) tor i ii u r <j i n i ula , radium 226 .vi t y In publ ic

50. 1 - bU. 12)

and secondarynai t i cu la te mu t lei .

d.

FH 14 1 . 5O - 14 1 . b 1 )

we 1 Goa Is (MCI Gs ) furre non^esnfortL'iitjIt!

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TABLE 4-V

I'KUttbS-OHl ION (ACTION) SHttlHL AH AH;.

HtUUIHtMENTS

I I. Hazardous Wd&te Management Act (HWMA), ACT 64, P.A. 1979I Construction Peiitiits and Operating License.. (R 299.9501 -

R 299.9523)

These rules st tpu1 a t U the war i uns» i eqti I renutnt i» fur obta in iny a pui MU tfor trie construct t on, en I aryeoient , or a I taratIon ot a treatment,storage. or dtsposa I f a c i l i t y . Th« rule* alto prescr ibe procedure:! f uiacquiring an operating Itcense for managing, maintaining, or opeiat inga treatment . storage or al sposa I f ai_ * I I ty .

MWMA - Appl itabi I i ty bla.i.iards (R 299.9601)

Mi it. rule Jescrides the type;, u f f a c i l i t l a s that are require^ tuH i tn thu standards contained in Part 6 of the HWMA - Owners andOperators of Ma*ardous Wd&te I raatment . Storkye and Oi sposa Ifac i 1 1 1 tes .

13. NMMA Lucdtiui. <li, (H 299.9603)

Regu I at ions for the I oca t ion ot new treatment , storage . or a i spot, a If a c i l i t i e s * or e»pan;> ions , en I aryumeiit* . or altaration of e* i*t ingfact I I ties.

HWMA - f a c i l i t y Ue±.iyn ai>a Operating Standards (R 299.9DU4)

Heyu I at ions requ i r ing ownerb or operators of treatment, storage, uidlsposd I f a c i l i t i e s to ma i ta in r un-ori and run-off cont ru I system^ ,and to prevent the uncont ro 1 letJ re lease of hzardous waste to ttiuunv I roiintent .

HWMA Gene i a I Requ i reiiitMit i fur Owners and Opera I 01 s> ( R299 .

Requires Owners or uperdtur^ uf hd^arUOuS was te t r ea tmen t , sor disposal f d c i l i t i u ^ to cu.i,(ilv w i t h 40 Lf-R 264.10 - 2b4. l t i(set> A . I . I ) .

IIWMA Pi opur e(Jnc-; ami Ci evi;nt ion ( H tlljy .

uis in i)|'»; ' • " ' " ' - >i I i I i t-t- tu Luiiipl

li<ii «ji iJiiu* w a s t r t r e a t (hen 1 . ^ I in Jiitn 4t) CrH 263 . JO 264. J/ t seu A

AREA OF CONCERN ( 11)

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TABLE 4-7PHUCtbi-OPTION ( A C T I O N ) iPfcdflt A M A H *

REQUIREMENTS

7. HWMA - Contingency Plan anu Emergency Procedures (H 29y.9bU/)

or operators of hazardous waste treatment, storage, anddt*po*a I fact I 1 1 tes sha II ma lot a in a cortt InQency plan and enmr>jem yprocedures a* required in 40 CFft 264.50 - 264.56 (see A. 1.3).

a. HWMA - Use Of Manifest System (H299. 9606 JVRequirements for u t i l i z i n g a manifest system to track the type t»mJq u a n t i t y of hazardous mast** r ecu i vud by, or shipped from a f a c i l i t y

9. HWMA - Recordkeepina (ft !J99.9b09)

Tnts rule specifies the types of records an owner or operator mubt|maInta in unst te. These Include a wr i tten operatIng record thatdescrlues the quant ity of the waste received »nd Its location w i t h i nthe f act I i ty , waste ana I yt.es records, tnc fd*nt and Inspec t ion repuf tmoni tor Ing and test ing data, and a record of hazardous waste MIrejected by the f a c i l i t y .

I10. HWMA - Re p o r t i n g (H299. 9blO)

Hequi rements for the prepareti on and submt t taI of b l u n n i a I .unman i fested, and month I y r epot t a t>y the Owner or oper a I or uf afact I I t y .

I I . HWMA - EnvIrunmanta I and droundwater Monitor Ing(R299.961I, R299.96I2)

HeguI at ions requir ing owners or operators of hazardous was tetreatment , storage, or disposa I faciMtle* to deve lop s o i l , a i r -groundwater moni tor ing programs to detect hazardous cons t I t u a n tre I eases ftum a f a c i l i t y . Hule R ^99.9612 conta ins dela I I uurequi ramurtt & rui comJuc t i mj gru«n>twater moni tor I fly .

HWMA

(disposal

1 tlllU Pob t C I Ublll

oper d t u< b u t lid.i t U CUinjJ | y H I t ll

(H 29U.9ulJ)

duus w a s t e t r u d t m u r i tIM L: lusure and

AREA OF CONCERN (1)

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CHUt.ti,b-OPI ION ( A C T I O N ) i^tt.lHL AKrtU:

1Lj L. ftt i fDtUCfcjfCntkjLJfni.lfll_iil j

provisions of 40 CFR 263.110 - 264.120 except 40 CFR 264.115 (see A. 1.6).

1 J . HWMA - Use and Mandyeiner > t ut Curita iners (R 2y9 . yb 1 <J )

Owners or operator* of ha^druuns waste f a c i l i t i e s that stuiuConta Inert) must comp 1 y w i t h 40 CFR 264 . 1 70 - 2b4 , 1 78 and flirt ke the wui Us."Hazardous Waste" on the cont a iner along w i t h the hazardous wab tenumber (see A . t . 7) .

*14. HWMA - Tanks (R 29y.9bl!>)

Hules yawerning the deiiyn. upeiution, inspections, and c 1 ojnii e uthazardous wa^te tanhs.

It*. HWMA • iturfoLU loipuuiuKoui.lte (R 299.9616. R 299.9621)

Rules governing the design, operdtion. Con t rue t t on , moniluriiuj amilitsac t ion , emertjenc y i epa i ' . c. 1 oûi u, and qua Hty i_ontro 1 of =,ui t amImpoundments .

16. HWMA - Waste Piles (R 29U.9bl7, R 299.9621)

Hulas requiring owners ur operators of waste pltes to comply n i t Mdus lyn . uperat iny, man i toi iny and inspect Ion, and c losure and pot> iclosure care, and quality control requirements.

17. HWMA - Land treatment (H ûy.yblti)

fiequi res owners arid operators of faclltttas that utilize land tina (mentunits to treat ur dispose ot na/ardous n*st« to comp ly with 40 CFFt264.270 - 264.299 (see A.l.lu).

AREA OF CONCERN

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Id. HWMA - L a n d t i l l s (H ây.-Juiy, H 2B9.962I) u u

Keyulatiuns for the design, opera t ton. monitoring, inspectiun. c l u b u i cand post c lusuru , older spec ia 1 requ i reman t s , and qua 1 i t y cont i o 1 orlandf i l l s .

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TABLfc 4-7

ION (ACT ION) iHtL It- I L AKAH:

O

1HtUUIHtMtNTS

19 . HWMA - L tner requi rement t, for landf Ills, sur face impoundment s. .and -aitte p i les (R 299.96.'0)

Hules describing the ( euu i i tmmn I t. fin th« locat ion , Uebiyn.cons t( uct ion, anU uperdt iun ut d Itnttr byjttitm.

1|20 . MWMA •- Leak d w I e L l i o n iy3lciiib (H 299.9622)

|Thi:> rule requires, that each nun unit and la tera l expansion urreplacement of an ex i s t i ng unit dt d landf i l l . Surface impoundment ,wdbta pi le, or land treatment f dc i t i ty inc lufle a 1 eal* de tec t ion £>y^ lam.

2\ . HWMA Jim inut a t o i :, (H ."J'J . 'JI>2J H 2UU,y62b)

Rit 1 ei r eijit i i i ng UHIUM s. dnU upe' d t o* :. at f ac i 1 i t ies t lid t i IK. i nt: i u t u

t r i a l burn/ t r ia l opera t ion a t a n t t d f d s .

22. MWMA 1 dnu Ut2,pu^dl H«i4i i c t iun t , (R 299.9627)

Requires owiiwi i» ur upt-Mdtuib ut tftjutrtient storaye and Ui^pubalf d c i l i t i t ^ t t to cuinpiy n i tn tiic :>chudulti for land disposal p ionib i i iuhcontained in 40 CFH Har t 2bb .

23. Air Pul lu t iuo Act (APAI A^t J4ti . P. A. I96b - MiLtiiyd'i An PulUillunContro 1 Commi £>s ion ( jeneidl Hu 1 es - Air Use Approve 1 (K ^Jb . l ^u i -R 33b. 1285)

Hequ i r ei trie i binjm e ut u p^ i in i l piiur tu i n ^ ta l l d t i on uiconstruct ion of equipment Hhii_l i may ba a source of air con t diimid t i un .The regulations provide for p e r m i t application requirements, dirqtia 1 i ty mode 1 iny <tnd pai mi t e«t,-inpt i ons and wa i wttrs .

24. AHA - )i i lernii ltt: i i l 1 es 1 in.j unit ^jilrp 1 i ny(H J Jt) . 2001 - R ,JJb.20JJ)

t debt! ruguldt iun^ LUII t d in t tiu i i i r u t i d for LOriUuLtmy pur f oritidiiLe t u±, t ±>d()U include Uttd i led unit b ion let. t iny methoilfa.

2\j . AI'A UiJjJij i t iui;i i l u 1 Nil 1 ur u 1 H c ;.uu i i. c x. Air (J,ia 1 1 1 y U iv i t . i i . i i i AMI utti IHupui t l riy tinU All b u r v e i l l u M i _ u huesv ( H 3 Jt> , ^U 1 - H j Jb /U'.iJ

A R E A Of CUNCtkN ( 1 )

HASMUSbtN

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TABLE 4-7

OPfION (ACTION) SPttlr1L AKAUs

1RfcQUlREMENTS

These rules descr tbe thw dnnud 1 r sport Ina requi rementK and theaquat ton for calculating aiuiud 1 survet 1 lane* f ees .

1

26. Sdfe Drinking Water AH ( bDWA ) Act 399. P. A. 19/b AUmiii i i»l u t i veRules - Treatment Systems and Pumping f a c i l i t i e s IR 326.IIOUI -R 325. 1 1009)

Regulations containing treatment system requi rente n t tu be met Uysupp 1 tars of drink ing water .

1

AREA OF CONCERN

RASMUSSEN

( I)l^p

PD iw |NB | TL |aw |GW

4? . SDWA - Const i ui_ t iuii P 1 ana unU Spwt. t M«_dt iun^ and Poi "ti t b(R 325. t 1301 ~ 325. 1)3)1)

Hei|uifiii suppliuib of 1 ype 1 <inii t ypw 11 wdtur t.up(il)tj^ In butjinit (J 1 ani>and specifications for the cunt, t < uc t i on or alturation of d wattsrwur**ssy&tem. The procedures for the i ssudncu of parnit ts are d 1 so conta inedin thesa reguldtions.

2ti . bDwA ' t * dint nn i ion dnU L*j( 1 i t i ca t 1 on of Operators(R 3^5.11901 - R 3 5. 1 ISIti)

Rugulatiods describiny the clo^sificdtion of treatment sys ternsand dt str ibut Ion systems . Ti.e requiramants for the ewdminat ion dudcertification of operators of classified treatment and d1 str tbut Innsys terns Is inc luded in these reyulat ion* .

^9 . SDWA - Approve* I of Cliuni i t.u 1 i and Otner Mdtur id 1 s,(H 3^5. 12101 - R 325.)21)0)

Prescribes certain i equ t remen t s tor the «tppruval of criumttdls. mdter l a l i .or otlier Skibstdncui> prupus«d tu be used, in the tie«*im«nt or d i s t r i b u t i o nof dr ink ing water .

30. Michiydii Water Resuun.es CuiiMiii b& i on Act (MWNCA) Act 245. P. A. 1929Wastexater Reporting and Surveillance Fees (R 323.123) - R323.I236)

Regulations contdintiiy waituwatti repurt tng requirement:, dmisurve i I lance fee cult-ulation;..

31. r 1 uuup 1 d in Reiju 1 d 1 oi y Ant Inn i t y Ac t 245 . PA 24 b . I92b ds juiirniiul^d .

Regulates and r e b t r J L l s a c t i v i t i e s and uses of dredS uusiyiidttif cj bf loodpl d tns. .

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TABUE 4-7OHM ON (ACTION) iPLCUIL AKAH:.

REQUIREMENTS

32. MWRCA- Act 245, Suction 6(a), MCL 323.6(0).

Prohibi ts dtract or indi rat; t <ji scharges of Substances that are , or maybecome tnjurous to p o t e n t i a l uses of groundtvatar or surface w a t e r .

33. MWHCA - Treatment Plant operators (H 323.I2SI - N 323 . 1 b'J )

Indust rial or comma re ia I entities which discharge waste to surfaceor ground**tars are raqui red to have treatment facI I11 tea undersuparv i s ton of parsons cart i f ted by the Matar Resources Commi ssi on.These regulations set forth the rules for cart 1f teat ion of t reatmentft I ant operators.

MWRCA Wd!,tttwaie( Discharye Permits (R 323.2102 - R 323.21B9)

These ru les. imp) ttmunt a waste ef f I uent discharge pernti t sys terncumpat tb I e w 1 In the Nat iona I Po I 1 ut ton Discharge E I inttnat ton Syn l e(NPDES) . The rules raqu t re «* M persons discharging waste tnto thesurface or grountiwaters of the bta t e , or tha ground to app ly for aor waste e f f l u e n t dt scharge pet mi t, Other procedures for t ssuance ordttnia I of per mi ts . and appaa Is are ou I tned. as w a l l as permit cond 111 onsand monitoring requirements. The regulations also contain pret rttstandards for various sources of wastetiatar a f f l u e n t .

35. MWfcCA - Grounciwater Q u a l i t y (R 323.2201 - R 3 2 3 . 2 2 1 I J .

The reuulations In th is part p rov ide for tha nondegradatIon ofgroundwater qua I I t y , det ine I he requt remants for hydrogeuIoyicaI siudybefore permi 11Ing a discharge into groundwatara, as tab IIsh grounuwat ermoni toi Iny requ i rumen ts , and estab I ish procedures for obta ining

36. Soil Erosion and SediniL-ntat ton Control Act - Act 347. P . A . 19/2 -Soil Erosion and Sedimentation Control (R 3 2 3 . 1 7 0 1 - J 2 3 . 1 / I 4 )

Heyu I at '<>():> pr e;>c f i D i ny the i ei|u i rumen t $ for earth thaityus. b o i lj«roilon and bud linen t d I i un cur.tiul plans, permits, and soil uruii,,| ttttdiitiertt at iun con t ro l measures anu procedures.

ft I We I I At. t i j ib. \>. A . iyby (R

I Ku I eu Uwst i ib t ny I lie pei in i 1 t i M«J i equ i r umunls tui iJr i I t imj in i m| s>t ur*iye , d i iput-d I . dml t e> I H ^ M ^ . ueuphys, tea l t es t tio I «s . anil

AREA OF CONCERN (I). _ _ _ _ _ . . _ - _ - - _ _ - _ - - - -RASMU5SEN |SP

PO |iw |NB ITL |GW juw„..._.._......__—._..

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TABLE 1-7

HUOCtSS-OPTION (ACTION) SPtCIML AHAK:

REQUIREMENTS

foundation boring*.

38. Waterworks and Sewage Systems Act (WSSA) - Act P. A. 1913 -Treatment F a c i l i t y C l a s s i f i c a t i o n and Operator Car t i f teat i on(R 200.2901 - R 299.2927)

Rules for classification of sewage or waste treatment plants andthe requirements for c e r t i f i c a t i o n of treatment pi ant operators .

JU. WSSA - Sewage System Plans and Speci f t ca t ton (H 299 . 2UJ 1R 299.2945)

Tlitt&u i u I es c o n t a i n the p r t t i - e i l i i r e ^ fur u U t a i i i i n y a p U f i n i t lu L i i i i t -or a I ter a seN<*ge System or t r watmunt tac t I 1 1 y . Ttie requ i rement sIrtc luae subml t tal of pi ans . spec I f Icat Ion, and eng tneer tne repor t ±

4U. W^SA - Operation and Ma in 1 (R 29i* . 29b I - R

The rules in this part prescr ibe pi ucedures and requtrements for thuoperation and maintenance of auwti aye to ensure continuous protectionof public health, fish, plants, M i l d l t f e . and water resources.

J 4 I . S o l i d Waste Manaua.nent Act ( SWMA ) Act 641. P. A. 1978 - S a n i t a i yLandfills (R 299.4301 - R 299.431b)

Ru I es prescr tb ing the requ i rumen t s for new and «» ist tnu san i tai yl a n d f i l l f a c i l i t i e s . The r u l w s cover cun»tructlon p e r m i t t i n gprocedures , landf til d«s lyn ( Type 1 1 and Type III), ground water ijua I i I ystandards, p e r m e a b i l i t y testing, licencing procedures, andope rat ing i equ t rement s .

42. SWMA - S o l i d W aste Processinu Plant* (R 299.4401 - R 299.4408)

Ru I es governing the construe t f on . I icenalng, and ope rat ton of so I idwaste processing plants.

4J. SWMA - Solid Waste TransftM F a c i l i t i e s (R 299.4501 - R 299 4blJU J

Rules con t a i n t ng the requi renient s for construct ion. ope rat I on .l i c e n s i n g , i nspection, and eieinpt ion uf solid waste transfer t m i I i t i •

AREA OF CONCERN

RASMUSSEN

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(ACTION) SPtLIrlL AHAK*

KfcQUIREMENTS

AREA OF CONCERN (1}

RASMUSSEN | SP

44. SWUA - Soltd Wa*te Transpor I ing Unit* (R 299.4601 - R 299.460?)

Rules governing the c u n & t i U L t i u n . maintenance, anil operation ul s u l iwaste transport inu »n i t s .

45. Water Supply and Sewers Act - Act 368, P.A. 19/0 Part \2I(R325.1601 - R325.1781)

H u l e s governing the l o c a t i o n of water we I Is (distance fran) pa I Iut ionsources . re la t ion tu tiui Id mys . areas subjac t to f I ood ing ) . const rue i i unof we I 1s. and abandonment of we I 1s.

Pulychlurinateil t) I pheny I t,R 299.33)9)

Act 60, P.A. 1976 - (R 2U9.JJU I

Tnese r u l e s p r e s c r i b e r u q u i i c m e n t u fur not t fy iny the MltNH ut the i n t e n tto use, se l l , or manufacture PCb's or a PC0 product. The rules alsocontain requirements tor annual reporting, exemptions, arid e»c I us. t ons .and 1abeIiny. as we I I as prov i sions tor the storage, hand Iiny,transport at ton . and d i spusaI of PCB ' s or PCS contaminated nid t cr i j I i, .

*!/. Michiuan Compiled Auoutdted - Section .) 12

Rules governing the reduction ot the maximum aile loads duriny Hieperiod ot March, Apri I , and Muy ( t .a. frost laws) .

40. HWMA(R 299.9602)

fcnv i r otiuieiita I and Human Health Standard!)

R u q u i i K i t r ea tin wot , iiornye. din) Uiiposml f a c i l i t i e s to preventviolations of thu CWA or Act 245. violation* of tne CAA or Act J4H• Hposura ot humans to h u i m f u l l e v e l s of nazcrdous waste const tuentand pollution of natural resources.

41 . APA - Emissions L i m i t a t i o n arid H r o h i b t t i o n s - Car I iti. t^te Mailer(R 336.1301 - R 336.1331. H 336.1370 - R 336.1372)

f

The r«ynldtJui ib in p<irt JJb.l.ltll JJ6.I33I cunt in i t jrmji Us t in(Jens i ty ot enti ss tons anu flrad in^ v i s iol • tt«i&s ions , and reqoi rmiiciiit ^for compliance programs, e l e c t r o s t a t i c pr«ctpHator cont ro l s y s t e m s ,and emissions of p a r t i c u l a t a m a t t e r . Parts 336 .1370 - 3 3 6 . 1 3 7 2 containrequ t remeri t s for c o l l e c t i o n of air contaminants and f u i j t t i v a du^tc o n t r o l p iogiams.

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TABLE 4-7

HKUCfcSS-OPTlON (ACTION) SPECIFIC AH AH*

REQUIREMENTS

42. APA - Em lesion» Llmltat ions and Prohlbl t Ions - Nat* Sources ofVolatile Organic Compounds tmiaslonB (ft 336.1701 - ft 336.1702)

Oef ines and dascr tbes the genera I provisions for new sources ofvo lat 1 le organic compound em i ss> i ons .

43 . A PA - t in i si ion i f in i I at iun:i diiU Prod ib i 1 ion:.(R 336. 1901- R 336. 1912)

I

Rule* prohibit 1 ny air COM t «nhinuiil ui water vapur em i s s. i «jnt> . dfuJ d i l u t i onand cuiiceallng of emissions. The^M iul«l also cower tne instal lat ion«f stir cl ean Iny o«»v leas and pi e pa rat ion of equ f pment did 1 func t ion

t plans.

•44 bUWA(H 3^4.10601 - R 32b.lObU/)

itdfidards and A i i d l y t i t d )

1 n«be regulationstu the FttUdral MCl 's for o» ycomt aminant s . and turbid i ty .bdc ter l«* . rad ium 226 , rdd 1 uwi

MCt

and photon raJloctc t i v i t y .cump 1 iancu with MCL'» are

For curtain cunt ami i ion t s inn i L , tnuroanlcs. mlcrobl o loy d.a 1Ihase contanlnant s inc lude co 1 1 Toi m

?2fl , gr oss a 1 ph* par t ic 1 e:» , he t a fiai 1

l i I i uii

And ) y t i c<* 1 techniques Fur datuf min iny1 t,u fnc luUud in the regu 1 at i on^ .

4b. MWRCA- Act 24t>. Section b I a J , MCL 323. 6(d).

Prohibi t s di rect or indt ret tbecojuw (njuroufi to poittiitial

d i &ch<*i yos of substances that are . or mayuses of QroundNittar or surface water.

46. MWRCA - Water q u a l i t y :> t d'nidi d* (H 323.1041 - R 3 2 J . l l l b J

These regulations establish water quality requirements applicableto the Great Lakes, connecting waters, and all other surface watei!>.The reujui remants inc lude pH, U i s.so I ved o«ya«n, nut r tents , tempt)ratur cant ide8r<*<Jat Ion , and des ignar eu uses .

I

AREA Of CONCERN (I)

RASMUS5EN | SPI

PO fiw I HO |TL |uw lewssîi = -î:=;-ii= = is=îii;-

O O

4 / . Env i r unmuntd 1 Ac 1 307 , P . A .

Provides for the identification. r i i > h ass0&sment , and pr 101 i t yeva 1 uat ion of unv t runtnenta 1 cont miilnai ion at s i te:> where the a t i u d l 01potential release of haârous bubs tances may become in jurous tu thuunw t ronmenl or puU 1 t L health .iiul »<ifety.

o I o

TABLE 4-7

HNOCESS-OPTIUN (ACTION) SPECIFIC AHANs

REQUIREMENTS

AREA Of CONCERN

RASMUSSEN_ _ _ _ _ _ _ _ _ - - , _ .PD |iw |NB |TL |GW

1 1 1 1

M >SP

GW

FEDERAL (Ralated to Environmenta1 Concern*)

I. CWA - General Pretrealment Regulations For Existing and NUN Sourcesof Pollution (40 CFH Part 403)

Thesa r«gu I at tons cant a in tnu HationaI Pretreatment Standards andestablishes reqot remants for t-ederal. Stata. and local government*.Industry, and the public to implement the National PretreatmentStandards to contro I p o I l u t a n t s which mmy interfere M l t h treatmentprocesses at a P u b l i c l y Owned Treatment works (POTW). or which mayContaminate sewage sIudya.

2. Pnu e limns tui I nip I em an I i ity the Requirements of the Count t I miEnv tronmantaI UudIt ty on the Nat ionaI Env i ronmentaI PoI icy Act(40 CFR Part 6)

The r t*i>ii I d t i ons in t l i i i > part ut, I db I i &htf& EPA polity drul pi I»L tijui t» tuitha identification and diialybis of the environmental impacts of EPArelated a c t i v i t i e s , and the preparation nn<J processing of anv I ronmeii td I

I Impact statement* (ElSs).

3.225. 402.

Spec i es450-453)

Act (It, U.S.C. 153). 50 CFR Parts 17. Bl, 222.

This Act requires all FederdI departments and agencies to consulveand protect endangerdU and tn.aatened species of fish. N l l d l i f a . andplants. The Act also provides for tha determination of endangered andthreatened specie*, land acquisition. Stat* and Interagency cooperation,and enforcement.

4. WilU and Scenic Rivers Act (16 U.S.C. 1271)

Provides for the preservation and protection of certain selected rivers,a long w i t h the ir Immediate anv truoinent* , which possess remarked I uscenic, recreational, gaologtc. fish and M l l d l l f a . historic, c u l t u r a l ,or other similar values. The Act ImplMwnt* a national w i l d andscenic rtvers system for classification, da*Ignat Ion. admin 1 b t r a t I o n .and management of w l I d and scenic rivers.

b. Fish and w i l d l i f e Conservation Act (16 U.S.C. t>61 Note)

Author i 2es the Secretary of the Interior to provide ass istance to,and coopoarate Ml t h . Federal. State, and public and priva t e a0uncl*:> intha deve topmant. protect i on, r ear Ing, and stock ing of all spec itts of

I t I

TABLE 4-7

(ACTION) SPEC 1 ML ANAKi

REQUIREMENTS

of w i l d l i f e . The adverse effects of species overpopulation•re to be controlled by providing public shooting *nd fishing areas.Including ••••wants acro»k public t«nd* for access, w i l d l i f e surveysand investigations are alsu to tt« conducted under the Act.

6. Fish and W i l d l i f e Conservation Act (16 U.S.C. 2901. 50 ChH Pu. t H3)

Tna purpose of this Act Is to provide fInane fa I and technics I aba istanceto States for the development, revision, and Implementation orconservation plans and programs for nan gam* flan and w i l d l i f e . It also^encourages all Federal departments and agencies to conserve ana promoteconservation of nan game fish and wildHfa and their nafiitats. Tnerules for implementing the Fish and WUdHfa Conservation Act at >9tiOare contained In SO CFR Part S3.

"AREA7"OF "CONCERN TlT

RASMUSSEN |SP

ITL GW

I t

I o

7. Coa&tal Zona Manaum»«nt Act (16 U.S.C. 1451, 15 CFR Part*, 930, 923)

I I

The purpose of this Act Is tu proserve, protect , duve 1 op. anil i fpos&tble, restore or enhance, the resources of the Nation's cuaszones and Implement management prograM for coastal cone areas.

8. Ocean Dumping Regulations (40 CFR 220-229)

These regulations esiaDti&h procedures and c r i t e r i a for the tsinanceof ocean dumping permits by CPA persuant to the Marine Protection.Research, and Sanctuaries Act. The regulations also establishcriteria to be applied by the U.S. Army Corp* of Engineers In it*review of a c t i v i t i e s i n v o l v i n g the transporation of dredged m a t e r i a lfor the purpose of ocean dumping.

STATE OF MICHIGAN (Related to Environmental Concerns)

Goemaru-Antlerson Wetland;. Hrutaction Act - Act 203, P.A. iy/a

The purpose of thts Act is tu provide for the preservation, managumunt,protection, and use of wetlands by prohibiting certain activ i t i e s .requiring a permit to alter certain wet lands, and ImposInfl penaIt(MS andfees for violations of the Act.

I I

TABLE 4-7

PROCESS-OPTION (ACTION) SPECIFIC ARAH-,

REQUIREMENTS

f- t-f | » W | IW | I *- | \JBV U«*

2. Natural River Act - Act 321. P.A. 1870 - Huron River Natural RiverZoning (R 281.151 - R 261.164)

The purpose of these zoning rules are to promote p u b l i c h e a l t h anuprevent ecological damage due to unwise development * I thin the naturalriver district. The rules also protect the free flowing condlt ions.fish and wildlife, water quality, and recreational value of tne HuronRiver and adjoining land.

3. Endangered Species Act ~ Act 203, P.A. 1974 - EndangeredThraatanad Specie* (R 299.1021 - R 299.1020)

These rules contain a Hstfng of the fish, w i l d l i f e , and p l a n t speciesthat have been determined to be endangered or threatened.

4. Thomas J. Anderson. Gordon Rockwe I I Environmenta I Pr otect i un Ac l -Act 127. P.A. 1970.

The purpose of t h i s act is to protect air, water, and other natixresources and tne public trust therln from pollution, impairment, anddestruct ion.

5. MWRCA- Act 245, Section b(d). MCL 323.6(a).

Prohibits direct or indirect dischargee of substances that are, orbe coma Injurous to potential uses of grountlwater or surface water.

6. MWRCA - Graundxater Quality (R 323.2201 - R 323.2211).

The regulations in this part provide for the nondegradation ofgroundwater q u a l i t y , define the requirements for hydrogeologlcaI studybefore permitting a discharge Into groundwaters. establish groundwatermonitoring requirements, and establish procedures for obtainingvariances.

7. FlooUplain Regulatory A u t h o r i t y Act 245, PA 245, 1929 as aiimi

J R e y u l a t a s and restricts a c t i v i t i e s and uses of areas deslynatudf looilpta ins.

B. Iiildttd LdKes *nd Stream A c t . P.A. 346. 1972.

The purpose of t h i s act Is to regulate a c t i v i t i e s occuring be I O

Iver

'it I

in

es

d

dyer

AREA OF CONCERN (l)

RASMUSSEN

PD |iw |NB |TI_ |GW

o o u u

o

o

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u

o

SP

GW

O

u

o

1

U

u u

TABLE 4 7

PROCESS-OPTION (ACTION) SPECIFIC

REQUIREMENTS

ordinary high water mark on in) and lakes and streams. Includlng allnatural or A r t i f i c i a l lake* or rlvera over flwa acres in size.

AREA OF CONCERN (1)

RASMUSSEN

PD |iw |NB |TLSP

|GW

(I)' PO - Probable Drum Storaga/Laakaga/OlspovaI areaIW - Industrial wa»ta araaN8 - Northeast Burfad Oru» araaTL - Top of thy Municipal L a n d f i l lGW - Groundwatar Plum*SP - SpUgalbary Sits

APPENDIX A

VOLUME CALCULATIONS FOR WASTES AND SOILS

Appendix A provides the raw back-up materials used to calculate thevolumes of wastes and soils that may require removal and/ortreatment on the Rasmussen Dump Site. The calculations andmaterials contained in this appendix were provided by WarzynEngineering, Inc. as part of their performance of the detailedevaluation of alternatives.

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