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EPA Region 5 Records Ctr.
255955
PB98-963120EPA 541-R98-099March 1999
EPA SuperfundRecord of Decision Amendment:
Springfield Township DumpDavisburg, MI6/10/1998
U.S. tnvironnienial Protection ARegion 5, Library (PL-12J)77 West Jacksorj Spulevard, 12Ul fkwChicago, IL 60604-3590
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 5
RECORD OF DECISIONAMENDMENT
for the
Springfield Township "Dump" Superfund SiteOakland County, Michigan
June 1998
CONTENTS
Section Eage
I. Declaration ii
II. Administrative Record Index iv
III. State Letter of Concurrence xi
t
IV. Decision Summary 1
Introduction ' 1
Background IFigure 1 2Figure 2 2
Site History Post-1990 ROD 3
Proposed ROD Amendment/Community Participation 7Tables 1-4 8
Detailed Description of ROD Amendment 9
Evaluation of Proposed ROD Amendment (The Nine Criteria) 12
Statutory Determinations 17
V. Responsiveness Summary (follows page 17)
-i-
DECLARATIONf
SELECTED REMEDIAL ALTERNATIVEFOR THE
Springfield Township "Dump" SiteOakland County, Michigan
Statement of Basis and Purpose
This decision document presents the amendments to the remedial action for the SpringfieldTownship "Dump" site, Oakland County, Michigan, which was chosen in accordance with theComprehensive Environmental Response, Compensation, and Liability Act of 1980(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986(SARA), and, to the extent practicable, the National Oil and Hazardous Substances PollutionContingency Plan (NCP). This decision is based on the administrative record for the site. Theattached index identifies the items that comprise the administrative record upon which theamendment determination is based.
Description of the Amended Remedy
The amended remedial action changes the selected method of addressing PCB-laden soils and|gi also changes certain soil and groundwater cleanup standards previously selected in the 1990
Record of Decision (ROD) to reflect current state standards:
• PCB-laden soils will be excavated and treated on-site using one of the following threetreatment alternatives - soil washing, solvent extraction, or low temperature thermaldesorption - instead of on-site incineration.
• PCB-laden soils will be excavated to achieve a cleanup standard of 1 part per million(ppm) in the upper 6 feet of the soil horizon and then 50 ppm to depth.
• PCB-treatment residuals containing 5 ppm or less may be backfilled on-site. Uponcompletion of the cleanup action, the excavated area will be regraded and a minimum1-foot cover of clean soil shall be placed and maintained over the backfilled treatmentresiduals. Deed restrictions shall be placed on the site property to prevent disturbanceof the soil cover and the treatment residuals below the soil cover.
• Groundwater and soil cleanup standards shall be modified as shown in Tables 1 -4 of the' attached Decision Summary.
The groundwater and soil vapor extraction and treatment systems and the arsenic and leadgroundwater cleanup standards identified as part of the selected remedy in the 1990 ROD and
», t in the 1993 Explanation of Significant Differences remain unchanged.
DedaiaUoo Stat
The selected amended remedy is protective of human health and the environment, attainsFederal and state requirements that are applicable or relevant and appropriate for this remedialaction, is cost-effective, and is otherwise in compliance with CERCLA. This remedy satisfiesthe statutory preference for remedies that employ treatment that reduces toxkity. mobility, orvolume as a principal element and utilizes permanent solutions and alternative treatmenttechnologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining on-site above health-basedlevels, a review will be conducted every 5 years after commencement of remedial action toensure that the remedy continues to provide adequate protection of human health and theenvironment.
U.S. EPA provided the State of Michigan widi an opportunity to concur with the amendedremedy and the State of Michigan has indicated that it does not object to the changes in the* soilremedy and cleanup standards included in this ROD Amendment. A letter from the State ofMichigan signifying its position on the ROD Amendment is attached.
^ William E. Muno. Director DateSuperfund Division
-Hi -
U.S. ENVIRONMENTAL PROTECTION AGENCYREMEDIAL ACTION
ADMINISTRATIVE RECORDFOR
8PRINQFIELD TOWNSHIP SITESPRINGFIELD TOWNSHIP, OHFT.MID COUNTY, MICHIGAN
RODMARCH 25, 1998
&12I
05/15/87
08/00/88
Huff, S.U.S. DOI
D.S. BPA/OSNBR
Constanteloe,B., U.S. BPA
U.S. BPA
3 08/00/88 U.S. BPA/OSHER
4 03/01/89 Porter, J.,U.S. BPA
U.S. BPA
U.S. BPA/Regional
Administrators
5 07/00/89 U.S. BPA/OSHER
U.S. BPA
07/00/89 U.S. BPA
247
Memorandum re:Preliminary NaturalResource SurveyRegion 5
Guidance: CKRCLACompliance with OtherLara Manual; InterimFinal (OSWER Directive540/6-89/006)
Guidance: CERCLACompliance with Other'Lawa Manual (DRAFT)[OSHER Directive 9234.1Oil
Memorandum re: Interim 77Guidance on AdministrativeRecords for Selectionof CBRCLA ResponseActions (OSNBR Directive9833.3)
244
Interim final Guidanceon Preparing SuperfundDecision Document?: TheProposed Plan, the Recordof Decision, Explanationof Significant Differnces,the Record of Decia ionAmendment (OSHER Directive9355.3-02)
Final Remedial Invest-igation Report for theSpringfield TownshipDump Site: 3 Volumes(DOCUMENT INCORPORATEDBY REFERENCE: SEE U.SEPA ADMINISTRATIVERECORD--UPDATE #2--DOCUMBNTS #2-4)
198
-IV-
Springfield Township ARit
11/20/S9 Fred R. Bart& Associates
SpringfieldTownshipSteeringCOMittee
Report: Distributionof Arsenic and Pesti-cides at the SpringfieldTownship Dusp Site(DOCUMEWT XHCORPORATBDBT REFERENCE: SBB U.S.EPA ADMINISTRATIVERECORD—UPDATE §3--
•27)
02/09/90
07/00/90
McBride, R.;Keep, Klein,Usphrey.
Beer
U.S. BPA
Martin, M.U.S. SPA
Letter Forwarding 103Attached Notice LettersThat Were Sent to PRPsDated January 23, 1990w/Copiea of the CertifiedMail Receipts
Final Feasibility StudyReport for the Spring-field Township Dusp Site(DOCUMENT INCORPORATEDBY REFERENCE: SEE U.S.BPA ADMINISTRATIVE
-UPDATE §3--§28)
10 OS/00/90 U.S. EPA/ U.S. EPA =e on Remedial 160Action for SuperfundSites with PCB Contam-ination (OSNBR Directive9355.4-01)
11 08/00/90 U.S. EPA/ U.S. EPA
12 09/02/90 U.S. EPA
13 04/00/91 U.S. EPA/OSWER
Public
U.S. EPA
Quick Reference FactSheet: A Guide coRemedial Action acSuperfund Sites withPCB Contasunation(OSMKR. Directive935S.4-01PS)
Record of Decision forthe Springfield TownshipDuep Site
Guide to AddressingPre-JtOD and Post-RODChange* (OSWER Directive935S.3-02PS-4
172
-V-
.a iowusu-LyROD
KQ. DATE AJZXBQE TITLK/DBSQtlPTIOM PXOKfl
14 04/00/91 U.S. EPA/OSWBR
U.S. EPA
IS 11/00/91 GradientCorporation
16 01/00/92 CH2M Hill
17 01/00/92 CH2M Hill
18 03/20/92 Ullrich, D.,U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
Lerminiaux, K.;Dickinson,Wright, et al.
19 04/17/92 Merrill, D.,GradientCorporation
Clarizio, R.and M. Martin;U.S. EPA
20 12/11/92 CH2M Hill U.S. EPA
21 03/26/93 Gorka, J. andD. Cleveland;SpringfieldSite ActionCommittee
Ullrich, D.U.S. EPA
Guide to Developing €Super fund No Action,Interim Action andContigency Remedy RODa(OSWER Directive 9355.3-02PS-3)
STSSC Type B/C Remedy 49Proposal for the Spring-field Township Dump Site
Predesign Report for 132the Springfield Town-ship Dump Site
Remedial Design Field 265Investigation for theSpringfield TownshipDump Site
•Administrative Order onConsent w/Attachmenta(DOCUMENT INCORPORATEDBY REFERENCE: SEE U.S.EPA ADMINISTRATIVERECORD FOR THE BSD--DOCUMENT #15)
Methodology for Estab-lishing Background Levelsfor Arsenic and Leadin Groundwater Reportw/Cover Letter (DOCUMENTINCORPORATED BY REFERENCE:SEE U.S. EPA ADMINISTRA-TIVE RECORD FOR BSD--DOCUMENT #17)
Assessment of ResidualRisk (DOCUMENT INCORPORATEDBY REFERENCE: SEE U.S. EPAADMINISTRATIVE RECORD*-UPDATE #7--DOCUMENT #22)
Letter re: SSAC's 2Involvement in thePlanning Process of theCleanup at the Spring-field Township Dump Site
-VI-
Springfield Township A*it
22 04/01/93
OS/02/93
Martin. M.U.S. EPA
ONCE. Inc.
Gorka, J.,SpringfieldSite ActionCommittee
U.S. EPA
Letter re: U.S. EPA'aResponse to SSAC'sRequest for a Meeting(UNSIGNED)
Final Design Report forthe Ground Water Recoveryand Treatment System(DOCUMENT INCORPORATEDBY REFERENCE: SEE U.S.EPA ADMINISTRATIVERECORD FOR THE ESD--
•102)
24 09/13/93 Merrill. D..OradlentCorporation
Martin, M.,U.S. KPA
25 11/10/93 0.8. EPA Respondents
Evaluation of BackgroundArsenic and Lead inGroundwater Report w/Cover Letter (IINCORPORATED BY R!SEE U.S. BRA ADMINISTRATIVERECORD FOR BSD--DOCUMENT•113)
Administrative Orderfor Rf9fdial Action forthe Springfield Township
Site
45
11/10/93 U.S. EPA Public Explanation of Signifi-cant Differences for theSpringfield TownshipDump Site (DOCUMENTINCORPORATED BY REFERENCE:SEE U.S. EPA ADMINISTRATIVERECORD FOR THE BSD--DOCUMENT §137)
03/09/94 Bradford. M.
28 07/21/94 . Inc.
Tyson, M.U.S. EPA
D.S. EPA
Letter re: MDNR'a 351Identification of ARARsfor the SpringfieldTownship Duap Sitew/Attachaenta
Construction Completion 162Report: GroundwaterRecovery and TreatmentSystem for the Spring-field Township Site
-VII-
Townatiip AKROD Amendment
MO. DATE AUTHOR
29 09/29/94 Geraghty &Miller, Inc.
RKCIPIPtT
U.S. EPA
TTTtJI /D PAOK3
30 11/14/94 Geraghty &Miller, Inc.
31 00/00/95
U.S. EPA
32 05/00/95 U.S. BPA/RREL
U.S. BPA
33 06/05/95 MDNR U.S. BPA
34 06/05/95 MDNR U.S. EPA
35 06/21/95 Kratzmeyer, J.; Martin, M.,Geraghty & U.S. EPAMiller, Inc.
36 10/00/95 U.S. EPA/OSWER
37 03/00/98 U.S. EPA
U.S. EPA
Report: Alternative PCB s^Treatment TechnologyEvaluation for theSpringfield TownshipSuperfund Site
Results of the Soils 90and Leachate Testingat the SpringfieldTownship Site (DRAFT)
Solvent ExtractionTechnology Report(CURRENTLY UNAVAILABLE)
Project Summary: 25Removal of PCBs fromContaminated SoilUsing the CF SystemsSolvent Extraction •Process.- A TreatabilityStudy (BPA/540/SR-95/505) w/Cover Letter
MBRA Operational Memo 16#8, Revision 4: GenericResidential CleanupCriteria
MERA Operational Memo#8, Revision 4: DermalContact Standards andGroundwater Standards(CURRENTLY UNAVAILABLE)
Letter re: Estimated 2Costs for Treatment ofPCB Soils at the Spring-field Township Site
Soil Vapor Extraction 40fSVEJ Enhancement Tech-nology Resource Guide(EPA/542-B-95-003)
ARARs Finding and Anal- 27ysis for the ProposedPlan for the ROD Amend-ment for the SpringfieldTownship Dump Site
-Vlll-
Springfield Township AKit
03/00/91 O.S. BPA Public
39 03/00/99 U.S. EPA
Fact Sheet: Proposed 10Plan for the BOO A»end-•ent for the SpringfieldTownship Duap Site
Proposed Plan for the 18ROD AsMndaant for theSpringfield Township
Site
-IX-
DRAFTU.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORDFOR
SPRINGFIELD TOWNSHIP DUMP SITESPRINGFIELD TOWNSHIP, OAKLAND COUNTY, MICHIGAN
UPDATE #8MAY 19, 1996
NO, DATE
1 05/00/95
AJTTHOR
U.S. EPA/RREL
RECIPIENT
U.S. EPA
TITLE/DESCRIPTION
05/00/97 U.S. EPA/OERR
U.S. EPA
PAGES
Project Summary: Removalof PCBs from ContaminatedSoil Using the CF SystemsSolvent ExtractionProcess: A TreatabilityStudy (EPA/540/SR-95/505)
Engineering Bulletin:Separa tion/ConcentrationTechnology Alternativesfor the Remediation ofPesticide-ContaminatedSoil (EPA/540/S-97/503)
16
i f : ft '
STATE OF MICHIGAN
JOHN ENGLER. Governor
DEPARTMENT OF ENVIRONMENTAL QUALITYHOLUSTER BUILDING. PO BOX 30473. LANSING Ml 48909-7973
INTERNET www.d«q §!•!• mi us
RUSSELL J. HARDING, Director
March 20, 1998
Mr. William E. Muno, DirectorSuperfund DivisionUnited States Environmental Protection AgencyRegion 5 '77 West Jackson Boulevard, S-6JChicago, Illinois 60604-3590
•
Dear Mr. Muno:
The Michigan Department of Environmental Quality (MDEQ), on behalf of the state of Michigan,has reviewed the Proposed Plan for a Record of Decision (ROD) amendment receivedDecember 8, 1997, for the Springfield Township Dump Superfund site located in OaklandCounty, Michigan. The MDEQ does not object to the changes in the soil remedy and cleanupstandards outlined in the Proposed Plan for the ROD amendment.
If you have any questions, please feel free to contact Ms. Kim Sakowski, Superfund Section.Environmental Response Division, at 517-335-3391 , or you may contact me.
Sincerely,
Russell . HardingDirector517-373-7917
cc: Mr. Kevin Adler, U.S. EPAMr. Alan J. Howard. MDEQMs. Claudia Kerbawy, MDEQDr. George Carpenter, MDEQMs. Kim Sakowski, MDEQSpringfield Township Dump File
EQPOlOOe(Rev 10/96)
Record of Decision AmendmentSpringfield Township "Dump" Site
Oakland County, Michigan
Introduction
This Record of Decision (ROD) Amendment describes changes to the 1990 ROD for theSpringfield Township "Dump" Superfund site ("Site"), Oakland County, Michigan. TheUnited States Environmental Protection Agency (U.S. EPA) is making these changes to the1990 ROD as pan of its responsibilities under the Comprehensive Environmental Response,Compensation, and Liability Act of 1980 (CERCLA), as amended.
The ROD Amendment includes modifications to the estimated volume of soil to be treated on-site, revisions to certain soil and groundwater cleanup standards, a modification of the methodof on-site treatment of certain contaminated soils, and the placement of deed restrictions on thefuture use of a portion of the Site.
•
Background
The Springfield Township "Dump" Site is located at 12955 Woodland Trail, about 3 milessouth of Davisburg, Springfield Township, Oakland County, Michigan (see Figure 1). The
. Site is a rural, residential lot surrounded by dense woods. During the 1960's, approximately*** 4 acres of the property were contaminated by the unauthorized dumping of liquid chemical
wastes (see Figure 2). Liquid wastes were drained into low areas of the site and eventuallyabout 1500 55-gallon drums of wastes were deposited on the ground. The State of Michiganwas able to perform a partial cleanup of the Site in 1979. Since that lime, the Site has beenextensively studied and tested to determine the nature and extent of residual chemicalcontamination.
The studies conducted at the Site have used data collected from the sampling and analysis ofgroundwater from 38 monitor wells and of soil from the more than 400 surface and subsurfacesampling locations. In addition, several tests of treatment technologies have been performedto determine potential Site cleanup alternatives and an extensive evaluation of the sampling andanalysis data was made to determine the actual or potential risks to human health and theenvironment caused by the unauthorized dumping.
The 1990 ROD contains a detailed description of the results of the testing and studies that hadbeen performed at the site up to that time. The pre-1990 studies indicate that certain areas ofthe ground surface are contaminated with organic compounds such as polychiorinatedbiphenyls (PCBs) and with heavy metals such as lead and arsenic. Volatile organic compounds(VOCs) are found below the ground surface; further, these substances have the potential toleach from the soils into the groundwater. Lastly, variable concentrations of VOCs, lead, andarsenic have been detected in several groundwater monitor wells at the Site.
\J
Figure 1
Mcfcson A
Presented below is a brief chronology of the cleanup actions dnd studies which had beenperformed at the site until the 1990 ROD was issued:
• 1979 - The Oakland County Health Department filed a complaint against the propertyowner regarding the illegal dumping of chemicals at the Site.
• 1979 - The Michigan Toxic Substances Control Commission declared an environmentalemergency at the Site and commenced the excavation, removal, and off-site disposal of55-gallon drums of liquid wastes and contaminated soils.
• 1980 - The Michigan Department of Natural Resources (MDNR) initiated ahydrogeological investigation at the Site and subsequently discovered a plume ofgroundwater contamination beneath the property. '
• 1983 - U.S. EPA placed the Site on the Superfund National Priorities List (NPL).•
• 1985 - MDNR began a Remedial Investigation (RI) to determine the nature and extentof soil and groundwater contamination.
1989 - MDNR completed the RI.
• 1990 - The Feasibility Study (FS) report and a Proposed Plan for Site cleanup werecompleted and released to the public for comment. U.S. EPA selected a cleanupremedy for the site as described in the 1990 ROD.
The 1990 ROD details the approach U.S. EPA selected for addressing groundwater,subsurface soil, and surface soil contamination at the site. U.S. EPA determined that, toprotect human health and the environment, the Site groundwater contaminant plume must becleaned up to meet certain groundwater cleanup standards and that surface and subsurface soilsmust be cleaned up to meet certain soil cleanup levels. The methods to be used to perform thecleanups were:
• the extraction and treatment of the groundwater contaminant plume;• the excavation and on-site incineration of soil contaminated with PCBs; and• the conduct of a soil vapor extraction (SVE) remedy on VOC-contaminated soils after
the incineration step was completed.
U.S. EPA estimated that it would cost $9.3 million (present worth) to conduct the selectedcleanup action at the Site ($9.0 million capital plus operation and maintenance costs).
Site History Post-1990 ROD
The 1990 ROD required that PCBs in the soil column, regardless of depth, be excavated to a
cleanup standard of 1.0 rag/kg (part per million (ppm)) and then incinerated on-siie. Theselection of the PCB cleanup level (1 ppm) and of the treatment method (incineration) wasconsistent with the Agency's goal to clean up the chemical contaminants at the Site to levelsthat would allow for unrestricted residential use of die property in accordance with U.S. EPA's(1990) risk assessment guidance. Stale identified regulations and laws, and with the PCBdisposal requirements of the Toxic Substance Control Act (TSCA) (40 CFR 761.60).
In selecting the remedial action for the PCBs in die soil, U.S. EPA had relied upon, amongother factors, a volume estimate drawn from the Remedial Investigation (RI) report. Basedupon the soil sampling data in the RI, U.S. EPA estimated that there were 12,000 cubic yardsof PCB-cootaminated soils to be excavated and incinerated at the Site. After releasing the1990 ROD. and in preparation for implementation of the cleanup. U.S. EPA conductedadditional soil sampling at the Site in 1991 to ascertain the1 accuracy of the soil volumeestimate. (The results of this sampling effort are contained in the "Remedial Design FieldInvestigation (RDFI) Report" (1991). which was placed in the administrative record.)
•
The RDFI Report indicated that an estimated 28.000 cubic yards of PCB-coniaminatcd soilswould have to be excavated and incinerated in order to meet the PCB-cleanup level containedin the 1990 ROD. The soil volume estimate had more than doubled; thus. U.S. EPA prepareda Predesign Report to re-evaluate die original ROD remedy. Based upon the findings of theRDFI. the Predesign Report contained a recalculated cleanup cost estimate totalling $34million (present worth), a substantial increase from the original $9.3 million cost estimate.
The new cost estimate information, coupled wini poor site logistics (the land area is notthought to be conducive to on-site incineration), die availability of new Site risk information(Assessment of Residual Risk (ARR) Report (1992)). and issues regarding worker safety withhaving to excavate to very deep depths to effect die PCB cleanup, caused U.S. EPA to proposean amendment to the 1990 ROD in 1992. The 1992 ROD Amendment proposal limited thedepth of soil excavation for the cleanup of PCBs and allowed for the treatment of die PCB-contaminated soil in die on-site mobile incineration unit at the nearby Rose TownshipSuperfund site (which was operating at the time the proposal was made). The proposal alsocalled for construction of a soil cap over a portion of the Site and for institutional controls tobe placed on the capped area. U.S. EPA later withdrew the 1992 ROD Amendment proposalbased on public comments received during the public comment period.
Immediately following the withdrawal of die 1992 ROD Amendment proposal, U.S. EPA metwith citizens and elected officials of Springfield Township (who formed the Springfield SiteAction Committee (SSAC)) and with die potentially responsible party group, the SpringfieldTownship She Steering Committee (STSSC), to discuss alternatives to the implementation ofthe 1990 ROD. The discussions centered around the Agency's goal of cleaning up the Site tolevels that allow for unrestricted use of the property to the maximum extent possible, althoughh was recognized that institutional controls would have to be placed on the property should aremedy change cause residual PCB levels in treated soil or non-remediated soil (at depth) to
exceed the original PCB cleanup level (1 ppm to depth) detailed in the 1990 ROD.
As a result of these discussions, the U.S. EPA and the STSSC conducted a number of studiesand tests at the Site during the next four-year period. In 1993, U.S. EPA performed pilottesting of solvent extraction to determine whether it could be a viable alternative to the on-siteincineration of PCB-contaminated soil. The pilot test was completed in 1995 and the resultsindicated that solvent extraction could be an effective and less expensive treatment alternativeto the on-site incineration of PCB-contaminated soil. (The results of this testing effort arecontained in the "Removal of PCBs from Contaminated Soil Using the CF Systems SolventExtraction Process: A Treatability Study" (May 1995), which was placed in the administrativerecord.)
Further, the STSSC, in cooperation with U.S. EPA, also evaluated several alternativeremediation technologies capable of treating PCB-contaminated soil. The results of thisevaluation were presented in the Alternative PCB Treatment Technology Evaluation Report(September 1994). This report indicated that both soil washing and low-temperature thermaldesorption could also be effective and less expensive alternatives to on-site incineration ofPCB-contaminated soil.
Next, the STSSC conducted a soils and leachate testing program to evaluate whether theresidual concentrations of PCBs and metals (lead and arsenic) under the 1992 RODAmendment proposal could be harmful to the Site groundwater quality. The evaluationconsisted of batch leaching tests and soil column studies. The soil column tests wereconducted on actual soil samples collected from the Site to determine the leaching potential ofPCBs and metals under simulated field conditions. The results of the leachate studies werepresented in the Soils and Leachate Testing Report, Springfield Township Site (November1994). The test results indicated that, upon completion of a cleanup action as described in the1992 ROD Amendment proposal, residual PCBs and metals in the site soil would not pose ahazard by leaching at levels above the cleanup standards into the groundwater beneath the Site.
Lastly, the STSSC performed pre-design groundwater studies and treatment testing prior to theconstruction of the groundwater extraction and treatment system. The STSSC began operatingthe groundwater cleanup system at the Site in 1994.
Presented below is a brief chronology of the cleanup actions and studies which have beenperformed at the site after the 1990 ROD was issued:
• 1991 - U.S. EPA conducted the Remedial Design Field Investigation (RDF1) at the Siteto further define the extent of contamination. Based on the RDFI, U.S. EPA re-evaluated the selected remedy and its costs.
• 1992 - U.S. EPA and the STSSC signed an Administrative Order on Consent to initiatedesign of the SVE system and the ground water extraction and treatment system.
1992 - U.S. EPA prepared the Assessment of Residual Risk Report for the Site, basedupon the findings of the RDF1 and Predesign Report.
1992 - U.S. EPA prepared a ROD Amendment proposal and presented the proposal forpublic comment. U.S. EPA withdrew the proposal upon consideration of the publiccomments received.
1993-1995 - U.S. EPA began meeting with local citizens on an informal basis toexplore methods for citizen participation in die Site cleanup process and to addresscitizen concerns and questions.
1993 -1995 - U.S. EPA evaluated the solvent extraction process as an alternative to on-site incineration of PCB-contaminated soil.
1993 - U.S. EPA published an Explanation of Significant Difference (ESD) (which wasa minor modification to the 1990 ROD) document, in which a change was made to thegroundwater treatment system and to the published background concentrations forarsenic and lead in the Site-area groundwater.
1993 - The STSSC agreed to construct and operate the groundwater extraction andtreatment system at die Site.
1994 - The STSSC began operating die groundwater treatment system.
1994 - The Springfield Site Action Committee (SSAC) began Site cleanup optiondiscussions with die STSSC.
1994 and 1995 - "Part 201" of the Michigan Environmental Response Act was passed,triggering significant changes to existing state cleanup standards.
1994 - The STSSC conducted soil PCB, arsenic, and lead leach-tests.
1994 - The STSSC evaluated the effectiveness of the soil washing and low temperaturethermal desorption treatment methods as alternatives to the on-siie incineration of PCB-contaminated soil.
19% - Discussions between the SSAC and STSSC continued.
1997 - Discussions between the SSAC and the STSSC were concluded.
Proposed 1998 ROD Amendment*
In March 1998, U.S. EPA determined that it had sufficient data to select an alternative cleanupremedy to on-site incineration of PCB-contaminated soil. Additionally, the discussionsbetween U.S. EPA, the STSSC, and citizens of Springfield Township had led to anunderstanding of community preferences. Therefore, U.S. EPA proposed that the followingcleanup remedy be implemented at the Site in place of the on-site incineration of PCB-ladensoil:
• All soils which contain semivolatile organic contaminants (such as PCBs) in excess ofthe Remedial Action Standards (RAS) shown in Table 1 would be excavated to a depthof 6 feet.
t
• AH soils which contain over 50 ppm of PCBs would be excavated regardless of depth.
• Excavated soils which are contaminated with semivolatile organics would be treated*using either the soil washing, low temperature thermal desorption, or solvent extractiontreatment methods (described below). Treated soil containing residual levels of up to5 ppm of PCBs and 620 ppb of dieldrin (a pesticide) may be backfilled into theexcavated area.
VTreated soil that exceeds the RAS for metals (Table 2) would be solidified andbackfilled on-site or disposed of off-site at a permitted facility.
• All areas of excavation would be returned to grade, covered with a J-foot thick, cleansoil cover (cap), and revegetated.
• All soils on the portion of the site which is on the "Nickson property" (Figure 2) andoutside of the area of semivolatile organic contamination, and which exceed the RASfor metals to a depth of 1.5 feet, would be excavated and either treated (solidification)and backfilled on-site or disposed of at a permitted facility.
• The future use of the south 500 feet of the "Nickson property" would be restricted toprevent activities which would disturb the soil cap or the backfilled soils.
• All contaminated soil outside of the "Nickson property" (the former "Tinsley property"(Figure 2)) woi-Sd be excavated to depth to meet the RAS in Table 2, and eithersolidified and backfilled on the "Nickson property" or disposed of at a permittedfacility. Soil treatment residuals would not be placed on the "Tinsley property."
Further, the following changes were proposed to be made to the 1990 ROD:
• Soils containing VOCs would still be treated using the soil vapor extraction cleanup
Table 1Remedial Action Standards for Semivolatile Organks in Soil
Contaminant 1990 HOP IMS 7998 ROD Amendment RAS
PCBs 1 ppm 1 ppm U)
Dieldrin 80 ppb 620 ppb (cl
Table 2Remedial Action Standards for Metals in Soil
1990 ROD RAS '1998 ROD Amendment RA.S
Arsenic background 9 ppm *'Barium 100 ppm 30,000 ppm"Lead background ' 4OOppm(c)
Table 3Remedial Action Standards for Volatile Organics in Soil
199O ROD RAS 1998 ROD Amendment RAS
Toluene 0.8 ppm 16 ppm **Chlorobenzent; 2.8 ppm 2 ppm '*Trichloroethylene 0.06 ppm 0.10 ppm'*
Table 4Remedial Action Standards for Groundwater
Contaminant 1990 ROD RAS 1998 ROD Amendment RAS
Toluene .04 ppm 1 ppm(c>
Trichloroethyfene 3 ppb 5 ppblcl
Nates:
ppm=mampermittiom.M I fp*fint tfett *m* 50 ppm below ffeel.W Buekgnmmd level for orseaic eaaNislud im 1991 RDFI(e) Dermol comloct stamtkml. MEM Opentiomel Memo t8. Her. 4. June 1995.(4) Gnmmt»*er protection standard. MERA Op. Memo §8. Rev. 4, Jane 1995.(e) Gnmm4mm*raamoo*d, MERA Operational Memo t8. Rev. 4, Jane 1995.
remedy previously selected in the 1990 ROD; however, certain cleanup levels would beadjusted to current state standards (see Table 3)
• Ground water would continue to be extracted and treated as under the 1990 ROD and asdesigned and currently operated by the STSSC; however, certain cleanup levels wouldbe adjusted to current state standards (see Table 4)
U.S. EPA released a proposed plan for public comment on March 26, 1998. The commentperiod was scheduled to run from March 26, 1998, through April 27, 1998. U.S. EPA hosteda public meeting at the Springfield Township Hall, Davisburg, Michigan, on April 2, 1998, at7:00 pm, and presented the proposed 1998 ROD Amendment and took official publiccomments from the audience. The comments have been addressed in the ResponsivenessSummary attached to this ROD Amendment. '
Detailed Description of 1998 ROD Amendmentt
The 1998 ROD Amendment provides for the protection of human health and the environmentthrough a combination of the following:
fc t 1. the excavation and treatment of contaminated surflcial soils,"|p* 2. a limitation on the potential for future exposure to contaminants,
3. the in-situ treatment of subsurface soils through SVE, and4. the extraction and treatment of contaminated ground water.
The first two cleanup actions are described below. For the SVE and the groundwatercomponents, the remedy remains as described in the 1990 ROD (as modified by the 1993ESD). The 1998 ROD Amendment merely updates certain RAS to meet current state law, asshown in Tables 1-4.
1. Excavation and treatment of contaminated surficial soils
Surficial soils on portions of the Site are contaminated with organic chemicals and metals:
a. Semivolatile Organic Contamination
All soils within 6 feet of the ground surface which exceed 1 ppm of PCBs and/or 620 parts perbillion (ppb) of dieldrin will be excavated and treated on-site. In addition, all soils whichexceed 50 ppm of PCBs will be excavated, regardless of depth, and treated on-site.Approximately 11,500 cubic yards of PCB-laden soils would be excavated and treated.Excavated soils will be treated on-site using one or more of the following treatment methods:i) soil washing; ii) solvent extraction; or iii) low-temperature thermal desorption.
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i) Soil Washing is a process in which the fine-grained fraction of soil containing the bulk ofthe contaminants is physically separated from the coarser-grained soil material. The techniquethen uses water and emulsifying or surfactant additives as an extraction agent to treat thecoarse-grained fraction to remove the contaminants of concern. The soil is first broken up andthen mixed with water to form a slurry. Some of the contaminants are removed from the soilinto the water phase and are then treated using various water treatment technologies.However, most contaminants usually remain in the fine-grained fraction, which is separatedfrom the cleaned, coarse-grained fraction and is then disposed of in a permitted facility. It isestimated that the overall remedy would cost about S3.3 million (present worth) to implementif soil washing was used to treat the PCB-laden soil.
ii) Sotreat Extraction uses an organic liquid (such as propane) as a solvent to extract PCBsand other organic compounds from the soil. The contaminated soil is first broken up and thenit is mixed in a container filled with die solvent. The solvent dissolves the contaminants out ofthe soil and the soil is then removed from the container. The solvent is then treated to recoverthe contaminants which are then properly disposed of. The cleaned solvent is then re-used tonthe next batch of contaminated soil and the treated soil is placed back into the ground. It isestimated that the overall remedy would cost about $12.3 million (present worth) to implementif solvent extraction was used to treat the PCB-laden soil.
iii) Low Temperature Thermal Desorption is a process through which contaminated soils areheated to high temperatures, but to lower temperatures than in an incinerator. Thecontaminants are removed as a vapor. The contaminated soils are first broken up. then theyare fed into an oven which is heated to a temperature which will volatilize the PCBs and otherorganic compounds but not bum them. An inert "carrier" gas. such as nitrogen, is sweptthrough the hot oven, displacing oxygen and preventing burning. Instead, the vaporizedcontaminants are condensed from the carrier gas and collected for proper off-site disposal.The cleaned soils are then replaced back into the ground. It is estimated that the overallremedy would cost about $5.7 million (present worth) to implement if low temperature thermaldesorption was used to treat the PCB-laden soil.
The three technologies have been demonstrated to be capable of cleaning Site soils to a PCBconcentration of 5 ppm or less and are readily available from vendors who specialize in siteremediation. Final selection of the cleanup remedy to be used would be made by the STSSCfor implementation by the STSSC. subject to U.S. EPA review and approval. The selectionwill be based upon a technology vendor's documentation and track record, capability to meetthe performance standards, compliance with applicable laws and regulations, health and safetyconcerns, and the cleanup cost.
Treated soil that exceeds 5 ppm of PCBs and/or 620 ppb of dieldrin will be reprocessed on-siteuntil it meets the RAS. Soil that does not meet the RAS after re-processing may be disposed ofoff-site at a permitted facility. Treated soils thai contain 5 ppm or less of PCBs will be placedback into the excavated area and covered with a 1 -foot clean soil cap. If the treated soils
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contain metals concentrations which exceed the RAS, the soils will either bestabilized/solidified (see next section) and backfilled on-site, or will be disposed of at apermitted facility off-site.
b. Metals Contamination
Site soil is also contaminated with heavy metals, such as lead and arsenic. Much of this soilcontains PCBs and will be excavated and treated as described above. Areas of metalscontamination within the "Nickson property" that are not to be addressed in combination withPCBs will be excavated to a depth of 1.5 feet, stabilized, and backfilled on the site or disposedof at a licenced facility off-site. Soils treated for semivolatile organic contamination that haveheavy metals in them will also be stabilized and backfilled on-site or disposed of off-site.
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Stabilization/Solidification is a technique by which contaminants are immobilized so that theycannot be released throughout the environment. In this case, the purpose of solidification is tominimize the potential for intake of metals-contaminated soil by mixing cement with affectetisoil into a solid mass. This step can be achieved either by mixing the contaminated soil in-place or by excavating the soil, mixing it with cement, and returning the soil mass into theground.
Soil on the former "Tinsley property" with metals contamination will be excavated regardlessof depth until the RAS are met. This soil will be then be treated using soil washing orsolidification and then it will be backfilled on the "Nickson property" or it will be disposed ofoff-site at a permitted facility. Excavated areas on the former "Tinsley property" will bebackfilled with clean soil and revegetated.
2. Limitations on the potential for future exposure to contaminants
U.S. EPA requires that two methods be used to isolate residually-contaminated areas of theSite to prevent future exposure to site contaminants:
a. Capping
All areas of the Site at which excavation and/or backfilling of treatment residues occurs will bebackfilled to grade and covered with 1 foot of clean soil and revegetated to stabilize the soilagainst erosion. The soil cap shall be inspected on a quarterly basis and repaired as necessary.Thus, potential exposure to PCBs on the ground surface will be limited to 1 ppm or less.
The former "Tinsley property" will be backfilled with clean fill to return excavated areas tograde and revegetated. Inspection and repair of any soil cover will not be required on theformer "Tinsley property."
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b. Institutional Controls
A legally enforceable deed restriction (or "easement") will be placed on the "Nicksonproperty" so that the future use of the south 500 feet of the "Nickson property" will berestricted to those activities which do not interfere with the performance of any cleanupactivities listed in the 1990 ROD and the 1998 ROD Amendment or disturb the integrity of thesoil cap to be placed over the treatment residuals.
3. In-sita treatment of subsurface soils through soil vapor extraction
Upon completion of the surface soil cleanup activities, an in-situ soil vapor extraction systemwill be installed in the subsurface soils. Numerous vapor recovery wells will be screened inthe VOC-contaminant zone above the groundwater table. Vaporized contaminants will bepumped out of these wells and recovered using granular activated carbon canisters. Once fullyloaded with VOCs. die carbon canisters will be replaced with fresh ones and the used canisterswill be taken off-site for destruction of the VOCs and reuse of the carbon. This portion of Theoverall cleanup remedy is iMM-hMyrf from the 1990 ROD, except that the RAS for certainorganics are to be changed to meet current stale law (see Table 3).
4« Extraction and trmtiBfiit of contaminated gi ouoJwater
This portion of the overall cleanup remedy, too, is unchanged from the 1990 ROD, except thatthe RAS for certain organics are to be changed to meet current state law (see Table 4). Agroundwater extraction well has been installed at the site and is currently pumping 8-10 gallonsper minute from the contaminant phone. The contaminated groundwater is passed through agranular activated carbon canister to remove VOCs from the water and then the treated wateris reinjected into the ground upgradient of the pumping well. The system has been inoperation since July 1994.
Evaluation of Proposed ROD Amendment
U.S. EPA has evaluated the 1998 ROD Amendment proposal in comparison to the 1990 RODremedy using the nine criteria below:
PrnttCtiftP of Human Health and the Environment - addresses whether or not a remedyprovides adequate protection and describes how risks posed through each pathway areeliminated, reduced, or controlled through treatment, engineering controls, or institutionalcontrols.
with ARARS ( Applicable or Relevant and Appropriate Requirements) - addresseswhether or not a remedy will meet all of the applicable or relevant and appropriaterequirements (ARARs) of Federal and State environmental laws.
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Long-Term Effectiveness and Permanence - refers to the ability of a remedy to maintainreliable protection of human health and the environment over time, once cleanup goals havebeen met.
Reduction of Toxicity. Mobility, or Volume - refers to the anticipated performance of thetreatment technologies a remedy may employ.
Short-Term Effectiveness - involves the period of time needed to achieve protection and anyadverse impacts on human health and environment that may be posed during the constructionand implementation.
Implementability - is the technical and administrative feasibility of a remedy, including theavailability of goods and services needed to implement the chosen solution.
Cost - includes estimated capital and operation and maintenance costs and estimated presentworth costs.
Support Agency Acceptance - indicates whether, based on its review of the Proposed Plan, thesupport agency concurs, opposes, or has no comment on the preferred alternative. Thisacceptance will be assessed from support agency comments received during the publiccomment period.
Community Acceptance - will be assessed following a review of any public comments receivedon the Proposed Plan.
The nine criteria outlined above are commonly divided into three groups: threshold criteria,balancing criteria, and modifying criteria. The first two criteria are threshold criteria and mustbe satisfied by any proposed remedial action under consideration. The rest are balancing andmodifying criteria and are used to evaluate the strengths and weaknesses of the thosealternatives that satisfy the threshold criteria, leading to the selection of a cleanup alternative.
For reference, the 1990 ROD selected the following cleanup remedy:
1. Excavation and treatment of contaminated surficial and subsurface soils
Organic contaminants: All soils which exceed 1 ppm of PCBs or other listed RAS would beexcavated and incinerated, regardless of the depth of contamination. The incinerator ashwould either be solidified and disposed of on-site or would be placed in a properly designedwaste disposal unit on-site. The excavated areas would be re-contoured to control ash or dustemissions.
Metals contaminants: All soils contaminated only with metals would be excavated regardlessof depth, solidified, and backfilled on-site.
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2. Limitations on the potential for future exposure to contaminants
The potential for future human exposure to contaminants would be limited by destruction of thecontaminants and through solidification of contaminated soils and residues. No deedrestrictions would be necessary.
3. In-situ treatment of subsurface soils through SVE
An in-situ SVE system would be installed in the soil zone above the ground water table.Contaminated vapors would be pumped out of the wells and treated using granular activatedcarbon.
4. Extraction and treatment of contaminated ground water'
An extraction well has been installed and is being pumped to capture and treat the plume ofcontaminated groundwater This system has been in operation since July 1994.
Overall Protection of Human Health and the Environment
Both of the soil cleanup remedies set forth in the 1990 ROD and in the 1998 ROD Amendment ,*will protect human health and the environment. Potential routes through which humans and/orenvironmental receptors could be exposed to site contaminants (pathways) include ingestion ofcontaminated groundwater. direct contact of contaminants in surface soil, and the movement ofVOC-contaminants from the subsurface soil into the groundwater.
The 1990 ROD remedy addressed the surface soil exposure pathway through the excavation ofcontaminated soil to the RAS regardless of depth, with the subsequent incineration of PCB-contaminated soil and the solidification of soil contaminated with heavy metals. The 1998ROD Amendment addresses the surface soil pathway through the excavation of soilscontaminated with PCBs and pesticides to the RAS within six feet of the ground surface withfurther excavation of PCBs to a cleanup level of 50 ppm regardless of depth. The excavatedsoil will be treated to remove organic contaminants and/or solidified to stabilize heavy metals.Upon backfill of treated soils into the excavation areas, a 1 -foot clean soil cap and a deedrestriction will be placed on the property. Thus, while the 1990 ROD cleanup remedy reliedsolely on the destruction and/or solidification of soil contaminants, the 1998 ROD Amendmentrelies on a combination of treatment methods and the on-site management of residualcontaminants to minimize exposure pathways.
The 1998 ROD Amendment does not change the groundwater and subsurface soil cleanupmethods. The only difference is that the cleanup standards (RAS) set forth in Tables 3 and 4have been changed to meet current state standards pursuant to Michigan Act 201. Thesestandards remain protective of groundwater quality and of human health and the environment. ^Further, the results of the teachability testing performed by the STSSC indicate that residual
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PCBs and metals in the subsurface soils will not pose a hazard to groundwater quality.
Compliance with ARARs
The 1990 ROD complied with the ARARs listed in that document. The 1998 RODAmendment will comply with all ARARs as well. (U.S. EPA has placed a detailed analysis ofthe ARARs in the Administrative Record for the Site - See document entitled "ARARsFindings and Analysis, Springfield Township Superfund Site, Proposed Plan for RODAmendment" (March 1998 and Addendum dated May 1998).)
Long-Term Effectiveness and Permanence
The 1990 ROD remedy achieved long-term effectiveness and permanence through the removaland destructive treatment of groundwater, subsurface soil, and surface soil contaminants(except heavy metals, which cannot be destroyed).
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The 1998 ROD Amendment achieves an identical level of long-term effectiveness andpermanence for the groundwater and subsurface soil, since no changes are proposed for thesecleanup methods.
The 1998 ROD Amendment achieves a lower level of long-term effectiveness and permanencefor the surface soil since it is anticipated that 11,500 cubic yards of soil would be treated forPCB-contamination versus the projected 12,000 to 28,000 cubic yards of soil to be treatedunder the 1990 ROD provisions. However, the residual contaminant levels will be managedover the long-term using conventional means, including the placement of a soil cap andinstitutional controls on affected portions of the Site.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Both the 1990 ROD and the 1998 ROD Amendment utilize permanent treatment technologiesto address site contaminants. Again, whereas the groundwater and subsurface soil cleanupmethods are exactly the same, the surface soil cleanup methods are not the same although theendpoints each would reach are very similar. Incineration of site soil under the 1990 RODwould have destroyed PCBs and other organic compounds on-site. The soil washing, solventextraction, or low temperature thermal desorption methods, however, separate thecontaminants from the soil on-site, leaving the contaminants to be shipped off-site for furtherdestructive treatment methods at the point of disposal.
In addition to the sheer soil volume differences cited above (see Long-Term Effectiveness),another difference between the 1990 ROD and the 1998 ROD Amendment is that, followingtreatment, the volume of the concentrated waste stream removed from the soil is estimated torange from 400 cubic yards to 1,800 cubic yards, depending on the treatment technology
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selected. This would represent a reduction in the volume of contaminated soil of 85% to 97%.given the estimated 11.500 cubic yards of PCB-contaminated soils that would be excavated andtreated under die 1998 ROD Amendment.
Sbort-Tenn Effectiveness
Short-term impacts due to site cleanup work are estimated to be lower under the 1998 RODAmendment than under the 1990 ROD. The short-term impacts typically associated withexcavation activities (such as the generation of nuisance dust and worker safety issues) and themethods to alleviate the impacts (conventional dust-control methods and adoption of a healthand safety plan) would be similar in scope under either cleanup method. However, since thesoil volume that would be excavated under the 1998 ROD Amendment is significantly less thanthai for the 1990 ROD. die duration of these impacts are expected to be much shorter under the1998 ROD Amendment.
In addition, due to other factors besides die soil volume difference, die length of time the *cleanup activities to be performed under the 1998 ROD Amendment is estimated to be muchshorter than under the 1990 ROD. It is estimated that the 1998 ROD Amendment would takeabout 5-6 months to complete the PCB-cleanup work - from the time equipment is brought todie site to begin work to die time die last of die treated soil is backfilled and covered with aclean soil cap. The 1990 ROD remedy would have required about 18-24 months to completedie excavation and incineration process.
Imptementabflhy
The 1998 ROD Amendment is expected to be less difficult to implement than die 1990 ROD.Construction and operation of a mobile incinerator at the site would be more difficultlogistically than construction and operation of any of die PCB-extraction technologies (soilwashing. low temperature thermal desorption. or solvent extraction) under consideration. Dueto emission requirements, die mobile incinerator would require extensive site-specific designspecifications and trial burn tests prior to full-scale operation. Space for siting the incineratoris a strong consideration. In contrast, each of the alternate treatment technologies are availableon a commercial scale and have been previously used for the treatment of PCBs. Trial burnswould not be needed and equipment siting requirements are not as limiting as for mobileincinerators.
Note that the PCB-extraction technologies would each produce a concentrated PCB-wastestream that will require off-site treatment and/or disposal. These requirements are similar inscope to die off-site disposal component of the 1990 ROD remedy. Off-site transportation.treatment, and disposal services must be performed by licensed and permitted operators andfacilities. Adequate levels of vendor services are currently available for cleanup of PCBs atthe Site.
. . 17wCost
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The 1998 ROD Amendment would cost significantly less to implement in comparison to thei estimated cost for the 1990 ROD cleanup (as revised by the RDFI data which reflected both a
greater volume of PCB-contaminated soil to be incinerated and a higher cost per unit volume ofsoil to be incinerated). The estimated cost for completing the cleanup remedies under the 1998ROD Amendment, using one or more of the various PCB-laden soil cleanup methods, rangesfrom $3.3 million to $12.2 million (present worth). The revised cost estimate forimplementing the 1990 ROD was $34 million (present worth) in 1991.
Support Agency Acceptance
U.S. EPA provided the State of Michigan with an opporturiity to concur with the amendedremedy and the State of Michigan has indicated that it does not object to the changes in the soilremedy and cleanup standards included in this ROD Amendment.
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Community Acceptance
Community acceptance of the 1998 ROD Amendment has been evaluated in the attachedResponsiveness Summary.
Statutory Determinations
Superfund law requires U.S. EPA to clean up NPL sites to achieve the protection of humanhealth and the environment in compliance with Federal and state environmental laws andpolicies (ARARs). Selected cleanup remedies must also be cost-effective and utilize permanentsolutions and alternative treatment (or resource recovery) technologies to the maximum extentpracticable, with an emphasis on cleanup remedies that employ treatment to permanently andsignificantly reduce the toxicity, mobility or volume of the hazardous substances, pollutants orcontaminants. Based upon the evaluation of the nine criteria, U.S. EPA believes that the 1998ROD Amendment presented herein satisfies the requirements set forth in CERCLA in that theROD Amendment would be protective of human health and the environment, would attainARARs. would be cost-effective, and would use treatment technologies to permanently andsignificantly reduce the toxicity, mobility or volume of the hazardous substances, pollutants orcontaminants to the maximum extent practicable.
RESPONSIVENESS SUMMARY
Springfield Township "Dump" SiteOakland County, Michigan
The public participation requirements of CERCLA §113(k)(2)(B)(i-v) and CERCLA §117 havebeen met during the 1998 Record of Decision (ROD) Amendment process for the SpringfieldTownship "Dump" site ("Site"). Sections 113(k)(2)(B)(iv) and 117(b) of CERCLA requireU.S. EPA to respond "...to each of the significant comments, criticisms, and new data submittedin written or oral presentations" on a proposed plan for a remedial action. This ResponsivenessSummary addresses those concerns expressed by the public, potentially responsible parties(PRPs), and governmental bodies in written and oral comments received by U.S. EPA regardingthe proposed 1998 ROD Amendment for the Site.
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Background
U.S. EPA issued a fact sheet/proposed plan for this ROD amendment in March 1998 to thepublic in Springfield Township, Michigan, prior to the start of the public comment period. U.S.EPA placed advertisements announcing the availability of the proposed plan and the start of thecomment period in the Oakland Press, Holly Herald-Advertiser. Clarkston News, and theClarkston Eccentric.
Information repositories were maintained at the two following locations: U.S. EPA Region 5,77 W. Jackson Blvd., Chicago, IL and at the Springfield Township Hall, 650 Broadway Street,Davisburg, Michigan. The Administrative Record was made available to the public for reviewat each of these locations as well.
The public comment period ran from March 26, 1998, to April 27, 1998. U.S. EPA receivedno requests for an extension to the 30-day comment period.
The Agency hosted a public meeting in Springfield Township on April 2, 1998, to providebackground information on the Site, provide details of the proposed 1998 ROD Amendment,and to take oral public comments regarding the proposed amendment to the Site cleanup action.U.S. EPA answered questions about the Site and the 1998 ROD Amendment alternative underconsideration. Formal oral comments on the Proposed Plan were documented by a courtreporter. A verbatim transcript of this public meeting has been placed in the informationrepositories and in the Administrative Record. Written comments were also accepted at thismeeting. The meeting was attended by approximately 40 persons, including local residents.
During the comment period, U.S. EPA received 8 written comments and 10 oral commentsconcerning the proposed plan. Comments received during the public comment period and theU.S. EPA's responses to those comments are included in this Responsiveness Summary, below,which is a part of the 1998 ROD Amendment.
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Siimmary of Significant Comments
A. Written
1A: Township Board, Charter Township of Springfield, MI
"Now. therefore, be it resolved: That the Township Board of the Charter Township ofSpringfield supports the proposed amendment to the [1990] Record of Decision andconcurs with residents in urging its speedy implementation." Note: see AdministrativeRecord for entire submittal.
1A:
U.S. EPA acknowledges the support of the Township Board in this matter.
2A. Mr. &. Mrs. Rick Rubenacker, Springfield Township, MI
"...We are anxious to see this project completed as it has been 19 years since the publichas been aware of the problem. We are in full support of the proposed plan."
2A:
U.S. EPA acknowledges the support in this matter.
Comment 3A: Dave and Diana Hopper. Springfield, MI (via e-mail)
*....we would like to again express our support of the proposed 1998 ROD amendmentfor the Springfield Township Supertund Site. The proposed ROD [Amendment] allows forprotection of the environment and is a cost-effective alternative that can be implemented in atimely fashion. We feel that the ROD [Amendment] is acceptable with the proposed fencingaround the site, one foot minimum of clean soil, in addition to the amount necessary to maintainthe site topography over the entire PCB excavation area We understand that following thecompletion of the clean-up, the site and fencing will be monitored and maintained on a quarterlybasis to ensure continued safety to the community and the environment.**
Response 3A:
U.S. EPA concurs with the above analysis and acknowledges the support in this matter.
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Comment 4A: Gisela Lendle King, Co-chair, Friends of Rose! Township, Holly, MI
"....These proposed cleanup standards in the 1998 ROD [Amendment] are significantlyhigher than the 1990 ROD standards, in some cases reflecting a 300 fold increase in levels oftoxins left in the soil and ground water.
"Coincidentally, this has reduced cleanup cost for the polluting industries by Millions ofDollars from 34 million to 3-12 Million.
"Although the residues allowed for PCBs in Table-1 [of the proposed plan] state 1 ppm,the text on page 4 of the EPA newsletter reveals that treated soils containing residual levels ofup to 5 ppm may be backfilled into excavated areas. This is inconsistent with the statements aspresented in Table 1 of the same publication, and justifiably raises doubt about the validity ofthe rest of the standards.
"How high are the residual levels of the other toxins allowed to remain in the soils andground water? What will be the levels (true levels) that will remain, and how far will theyexceed standards that are considered protective of human health and the environment?
"The proposed deed restriction is absolutely essential to the protection of human healthand the environment, especially since the significantly higher residual levels of toxins may notbe. But I am strongly opposed to the possibility of amending or lifting this deed restriction, aswas mentioned at the public hearing. To be protective this should be an ironclad, strictlyenforced deed restriction, particularly since urban sprawl is changing land use in the area tohigher density residential and newcomers may be totally unaware of the fact that this is a relative[sic] poorly remediated toxic site.
"There also must be long term monitoring of the ground water with continuous samplingrather than endpoint sampling."
Response 4A:
The changes to some of the cleanup levels at the Site serve to bring the cleanup levels inline with current state standards. The "300 fold" increase cited above refers to the change in thebarium standard for soil, in that the 1990 ROD cleanup standard of 100 ppm is being changed to30,000 ppm. While it is a 300-fold increase, there is no corresponding impact on risk, for theoriginal cleanup standard of 100 ppm was based on dermal contact risk and the current level isbased on protection of groundwater quality. Since a soil cap, deed restriction, and fence will beplaced on the impacted area, routine dermal contact with or ingestion of soils containing higherlevels of barium is not anticipated. The 30,000 ppm level is the current state standard designedfor protection of groundwater quality, in that rainwater or snowmelt leaching through soilcontaining barium at 30,000 ppm would not be expected to leach barium into the water tableabove the barium groundwater quality standard. The combination of the unchanged 1990 ROD
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requirements and the 1998 ROD amendment standards still yield a residual risk within the 10-4to 10-6 risk range that U.S. EPA considers to be the standard cleanup goal for Superfund sites.
Cost reduction is a legitimate goal at Superfund cleanup actions, as long as protection ofhuman health and the environment is not compromised.
The PCB cleanup level of 1 ppm is applicable everywhere in the first 6 feet of soil. Ifthe PCB levels exceed 1 ppm in the upper 6 feet, the soil will be excavated and treated.Treatment residuals containing up to 5 ppm PCBs will be placed back into the main excavationarea and covered with a 1-foot clean soil cover (i.e. no PCBs in the cover). Thus, to the extentanyone conies in contact with the excavated areas, they will encounter the clean soil at thesurface first. Exposure for metals-contaminated soils will be limited in a similar manner (i.e., aclean soil cover over the area of excavation) on die "Nickson" property with additionalprotection on die former "Tinsley" property where the soil will be excavated to depth until themetals cleanup levels are met.
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The residual levels of other compounds of concern are noted in the 1990 ROD and inTables 1-4 of the ROD Amendment. These are actual levels and will be verified by soilsampling upon completion of die excavation stage. Each cleanup standard is at or below levelsthat are protective of human health and environment.
U.S. EPA agrees that deed restrictions are an integral part of the remedy. U.S. EPA.however, did not propose to amend or remove diem at the public meeting. This was ahypothetical question raised by another commenter.
U.S. EPA disagrees with die implication mat this ROD amendment will result in a"poorly remediated toxic site." A "poorly remediated toxic site" is one that has residual risksabove human health or environmental protective levels and/or improperly managed risks uponcompletion of the work. At the Springfield site, the cleanup standards and proposed remedialaction approach are protective and meet ARARs. Additionally, any residual risk will bemanaged properly so that it will not be a "poorly remediated" site.
Groundwater monitoring is an integral pan of the cleanup remedy - it will show us whento turn off the groundwater cleanup equipment in the future. The endpoint sampling referred toin the comment above is sampling performed to protect against discharge of improperly treatedwater into the aquifer.
5A: Cynthia Balk we 11. West Bloomfield. MI
"....it appears that cost rather than extent of treatment has played a major role in thedesign of this plan.... A compromise in cost would be somewhere between $9 million and$34 million, not the estimated cost of $3.3 to $12 million for treatment under this amendment.Given a 3% average inflation factor from 1990 to 1998. $9 million would he equivalent to
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$11.4 million today. I would not object to an amended plan that provided a comparable level oftreatment at a reduced cost. However. I strongly object to the approval of an amendment thattreats a substantially reduced volume of soil and treats it to a reduced standard of cleanup at asavings to the potentially responsible parties.
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"I am concerned about the large gap in levels of PCBs that would trigger soil treatmentabove and below 6 foot in depth. Is the risk of 30 or 40 or 49.9 ppm that substantially less thatno treatment is recommended or required? Honestly, would you build your family home, digyour well and raise your children and grandchildren with this proposed cleanup abutting yourbackyard?
"I also find the proposed depth of one foot of clean soil for purposes of capping thecleanup site to be inadequate. The natural inhabitants of the area include many burrowinganimals and ant colonies known for their huge anthills. As more and more of the surroundingland is developed more of these inhabitants are likely to seek refuge on this site. If this cap ofsoil is to provide protection for humans from contact with semi-treated soils it will have to <bedeep enough to accomodate the instinctive habits of the area's wildlife to prevent them fromraising soil unsuitable for dermal contact to the surface.
"I am concerned about the limit of access and ongoing maintenance of the site following\.j cleanup under the proposed plan. A deed restriction alone will not prevent the use or abuse of
the land by unauthorized persons, just as trespassing laws don't prevent trespassing. Fourwheelers, dirt bikes and other ATVs have torn up vegetation and created considerable erosion onproperties adjoining the Nickson's property. Will the access to the deed restricted area belimited to the property owner and authorized persons by a gated fence high enough and of adesign adequate [to] prevent trespassing? Who will be responsible and at what intervals, formonitoring and maintaining the soil cap and any fencing limiting access? Who will haveenforcement authority for the maintenance and protection of future generations?"
Response 5A:
Cost effectiveness is one of the nine statutory criteria which U.S. EPA must use whenevaluating and selecting cleanup alternatives. As such, cost savings is a legitimate factor forU.S. EPA to consider for Superfund cleanup actions as long as human health and theenvironment are protected, ARARs are complied with, and the other statutory criteria areconsidered. The commenter assumes that the cost savings will be realized by the PRPs simplybecause U.S. EPA is pursuing them to perform the cleanup remedy. Although U.S. EPAexpects the PRPs to conduct the cleanup at this site, the cost savings will be realized by anyentity who will implement the remedial action activities required for this site. Consequently, in
. the event that the PRPs do not implement the ROD Amendment, U.S. EPA, and thus theSuperfund and the taxpayers, would realize this cost savings.
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U.S. EPA disagrees with the "make them pay dearly" tone of the comment. Although itis reasonable to want and required by Superfund to have the responsible panics cleanup the site.U.S. EPA is not allowed under Superfund to select a cleanup based on punitive factors or factorsother than the nine statutory criteria. U.S. EPA also believes that this commenter hasmisunderstood the role of cost in U.S. EPA's proposed plan. Costs will be reduced from thoseestimated in the 1990 ROD due the change in the depth of excavation (i.e., six feet for PCBs asopposed to throughout the soil column) and the treatment technology (allowance for selection ofone of three proven technologies in lieu of incineration). As explained in the proposed planU.S. EPA proposed to amend the ROD not only due to cost concerns but also due to workersafety issues and site logistical issues. The ROD amendment crafts a cleanup remedy that takesinto account all these issues and the other statutory criteria and still provides an equivalent levelof protection of human health and the environment.
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PCBs below 6 feet are not anticipated to be routinely encountered by humans or others.Therefore, leaving PCBs below that depth at concentrations of less than 50 ppm is acceptable.provided that the other portions of the remedy are implemented - deed restrictions, fencing*, andquarterly monitoring of the soil cover. Levels above SO ppm could present a leaching hazard togroundwater quality beneath the Site. thus, those areas will be excavated and treated to reducePCB levels to below 50 ppm
The cleanup remedy is designed to not have adverse impacts on off-site receptors such asabutting properties.
The cover of 1-foot of clean soil will be adequate to protect human health and theenvironment as long as the other portions of the remedy are implemented as well. Depending onthe treatment remedy used on the PCB-laden soils, a small percentage of the excavated soilswould be transported off-she for disposal (the PCB-concentrates). The displaced volume of soilwould be made up with clean fill material or with soil containing residual PCBs up to 5 ppmalong with the 1-foot clean soil cover. Thus, the thickness of clean soil in the backfill area maywell exceed 1 foot which provides an extra measure of protection. In addition, quarterlymonitoring of the soil cover will assure that any breeches in the cover integrity due to animalburrowing will be timely identified and repaired as mis ROD Amendment specifies.
Except for the small portion of the former "Tinsley" property, trespass to adjacentproperties is irrelevant to this ROD amendment since U.S. EPA does not have information toindicate that those properties are contaminated. The site fence will be adequate to prevent casualtrespass onto the areas where the contamination remains on-site Elsewhere, the ATV's. etc..will not be exposed to chemical contaminants above cleanup levels because soil above thecleanup levels will have been excavated and treated or disposed of off-site. The fence and soilcover will be monitored on a quarterly basis for as long as necessary.
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Comment 6A: Donald Balk well. West Bloomfield, MI
"I do not support the proposed amendment [for the following reasons].
"1. I can accept the alternate [PCB-laden soil treatment] technologies only if they willadequately remediate PCBs and Dieldrin their efficacy for treatment of Dieldrincontamination is not mentioned [in the fact sheet].
"2. I support deed restrictions in concept, but believe they need to be strengthened byexplicitly permitting enforcement by private citizens, and-requiring direct notice to surroundingproperty owners and residents if any amendment, modification, or termination of the restrictionsis contemplated.
i"3.1 support surficial capping in principle, but I believe that the requirements of the
proposed amendment are not adequate to prevent leaching by rainwater of the residualcontaminants left in the soil after treatment, eventually contaminating the ground water. As* aminimal alternative, I would suggest that the entire contamination area be graded, covered withan impermeable cap such as three feet of clay, subsequently covered by a drainage layer ofperhaps one foot of sand and/or gravel, protected by a geomembrane to prevent plugging of thedrainage layer, and, finally, topped by the proposed one-foot cap of clean soil and re-vegetated.
"4. I feel that long-term security of the deed-restriction area is inadequate. I believe thata chain-link fence topped with barbed wire (equivalent to that which is presently in place aroundpart of the area) should enclose and secure the entire deed-restriction area. This is madeparticularly necessary by the rural nature of the area, which attracts numerous recreationaltrespassers on motorized vehicles (dirt bikes, 4-wheelers, etc.) which can readily breach a 1-footsoil cap. Please be aware that on a summer weekend, it is common for there to be sufficientsuch activity that a heavy cloud of dust hangs over the surrounding area; if that dust happens tobe contaminated, it doesn't require great imagination to suppose that not only the trespassers,but residents and others could be exposed to not only dermal contact, but also breathing andingesting the dust, not to mention the airborn transport of the contamination to otheruncontaminated areas.
"5. I do not believe that the proposed amendment addresses in any way the potentialcontamination of wildlife ... which could subsequently enter and climb the food chain.
"6. Perhaps most importantly, I am greatly opposed to the substantial relaxation of thecleanup standards, particularly those for PCBs and Dieldrin in the soil, and also for VOCs inboth the soil and in the groundwater. I am especially opposed to the proposed provision for useof soil with a residual PCB contamination level of to 5 ppm (500% of the Michigan Part 201standard for dermal contact!) as backfill in excavated areas. This effectively relaxes the cleanupstandard to 5 ppm in the upper 6 feet, and 50 ppm at all depths below 6 feet, far in excess of the
-8-
1990 ROD or the Michigan 201 standard. I believe any treated soil which still fails to meet theapplicable standard should be disposed of off-site at an appropriate facility.
"7. As it is known that the use of soil boring for the determination of soil VOC levels isunreliable (tending to under-report those levels). I believe that it would be prudent to obtainmore-reliable data by re-testing using the readily available method (used by U.S. EPA inWisconsin and other areas) of methanol extraction testing. As a minimum, this method shouldbe used for process checking during the soil vapor extraction procedure.
"8. ...previously published studies ...showed that PCB contamination levels at manydepths down to the water-table depth (although less than the new proposed 50 ppm level) weresubsequently greater than those levels at or near the surface. Inasmuch as they were dumped onthe surface, this indicates that considerable downward migration has taken place (and probablycontinues), invalidating the premise that the PCBs are bound to the soil and cannot migratedown to die groundwater (at this she. die indigenous soils are almost entirely sandy, withminimal organic fines which can be capable of binding PCBs). As the mechanism for this •migration is most probably (predominantly) transport by solvents (which remain at high levels atall depths), this fact argues strongly for most urgent attention being given to the expeditiousimplementation of the soil vapor extraction procedure which was agreed to nearly eight yearsago! This seems to me to be the single most effective step that could be taken to protect thegroundwater from contamination (or further contamination) not only by solvents/VOCsthemselves, but also by PCBs by greatly reducing their downward mobility.
"9.1 am concerned that little is said in the proposed amendment about Dieldrin. In the1990 ROD. it was to be remediated along with the PCBs by incineration. Considering the hugereduction in the volume of soil to be treated, together with the lack of information presentedregarding the effectiveness of the alternative technologies in eliminating Dieldrin contamination.I feel that this issue requires greater attention.
"I believe the soil vapor extraction procedure as already agreed to could be implementedimmediately, which would reduce the immediacy of the need to settle on and to implement eitherincineration or an acceptable alternative to remediate soil contamination with SVOCs andmetals...."
Response 6A:
1. The alternate PCB-treaiment technologies will adequately remediate both PCBs andDieldrin. U.S. EPA acknowledges that their efficacy for treatment of Dieldrin contaminationwas not mentioned in the fact sheet. U.S. EPA will place the Superfund Engineering Bulletinentitled "Separation/Concentration Technology Alternatives for the Remediation of Pesticide-Contaminated Soil" (May 1997) in the Site information repository for the commenter. U.S.EPA examined various treatment technologies for cleanup of pesticides in soil and the threetechnologies proposed for use at the Site to cleanup PCBs are also recommended for use to clean
-9-
^ up pesticide-contaminated soils. The recommendations are based on pilot testing of soilsderived from cleanup sites around the country and containing dieldrin as a contaminant ofconcern. Efficiency of removal ranged from 86-91 % for soil washing to greater than 99.95%for a solvent extraction method. A low temperature thermal desorption unit was tested on soilscontaining DDT and showed an effective removal rate of 90-99% of that pesticide.
2. The institutional controls proposed for this ROD Amendment (i.e., the deedrestrictions, cover and fence maintenance provisions), are an integral part of this remedy sincecontamination will be left on-site. Superfund does not provide private citizens with the explicitenforcement authority which this commenter requests. To ensure that these activities areimplemented, U.S. EPA is provided with authority under Superfund to either issue anAdministrative Order (AO) or enter into a Consent Decree with the responsible parties to effectthese activities. Both the AO and the Consent Decree may be enforced through judicialproceedings if the responsible parties fail to complete the required activities under either anissued AO or agreed-upon Consent Decree. Additionally, prior to entry of a Consent Decree thepublic is provided with the opportunity to comment on the provisions of the Consent Decree.
If after issuance of an AO or entry of a Consent Decree the citizens in the area detectviolations of the deed restrictions, as embodied in either of these documents, they should reportsuch violations to U.S. EPA for investigation. U.S. EPA then may proceed with the appropriate
|^| enforcement action as authorized by Superfund. If the citizens believe that the violations havenot been resolved or that U.S. EPA's actions are inadequate, then they have the ability to Hie acitizen's suit pursuant to Section 310 of Superfund (42 U.S.C. 9659). Consequently, U.S. EPAdoes not believe that the ROD amendment or the deed restriction need to be strengthened toexplicitly allow for private citizen enforcement.
In the event that U.S. EPA wished to modify these requirements in the future, then bothSuperfund and the National Oil and Hazardous Substances Contingency Plan (NCP) wouldrequire U.S. EPA, at a minimum, to issue either an Explanation of Significant Differences(ESD) or another ROD Amendment. Both the ESD and ROD Amendment provide the public,including adjacent property owners, with notice of the proposed modification and an opportunityto provide comments on them. Consequently, U.S. EPA believes that adjacent property ownerswill be provided with adequate notice required by Superfund and the NCP prior to a deedrestriction modification such as hypothesized by the commenter.
3. The cleanup standards for residual compounds in the soil at the site, whether beneaththe soil cap or not, are set to protect groundwater quality. That is, the residual levels would beexpected to leach, but at levels that would not cause the groundwater quality standards to beexceeded. The soil cover is intended to prevent casual contact with treatment residuals. The
. RCRA-type cap as suggested in the comment is excessive for prevention of casual dermalcontact of PCBs in the soil. Prevention of leaching is not a goal at this site since the soil vapor
la 4! extraction remedy will remove solvents that would tend to mobilize PCBs.
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4. It is not necessary 10 enclose the entire deed restricted area with a fence if cleanupstandards have been met in the soils. The soil cover is the only area that would need to beprotected from casual trespass since the soil cover would be placed to protect against dermalcontact of treatment residuals. Adjacent property owners need to restrict access to their ownproperties against recreational trespassers on motorized vehicles on their properties. The sitefence will prevent vehicular trespass on the soil cover. U.S. EPA agrees that contaminated dustclouds would be a concern: fortunately that is not the case here as contamination has only beenfound in areas already delineated in the remedial investigation and other reports.
5. The cleanup standards take into account ecological receptors. The soil cover will helpprevent exposure to residual levels and prevent potential contamination of wildlife andsubsequent food chain considerations.
t
6. U.S. EPA disagrees with the term "substantial" as a decription of the change incertain cleanup standards. From a percentage basis, a change from 1 ppm to 5 ppm is a largepercentage increase, but the effect is not nearly so dramatic in terms of risk. For example/changing Che cleanup standard for TCE in groundwater from 3 ppb to 5 ppb is a 67% increase inthe standard but is still well within the target risk range (10-4 to 10-6) for Superfund cleanups(3 ppb of TCE equates to a 1x10-6 risk for long term use of the water as a drinking watersource, 5 ppb TCE would equate to a 1.6x10-6 risk). The PCB cleanup level remains at 1 ppmas described in a previous response to comments. The cleanup level is not 5 ppm. so no 400%increase occurs. Although 5 ppm may be used as backfill, the relative risk is decreased by anorder of magnitude by the presence of the soil cover over the treated residuals. The 50 ppmstandard for PCBs below 6 feet, when coupled with the other remedial actions proposed for thesite is protective of human health and the environment, was set due to concerns regarding shortterm effectiveness and site logistical reasons as well as cost effectiveness. Finally, treated soilwhich tails to meet the 5 ppm residual standard for placement beneath the soil cover may bedisposed of off-site at an appropriate facility, should the PRP group choose to do so.
7. The commenter does not indicate what the purpose of the additional sampling wouldaccomplish. From a practical perspective, assuming the commenter is suggesting that higherVOC concentrations might be found, delaying implementation of the cleanup to re-test for soilVOC levels would be imprudent. The data we have is reliable, and it is reliable enough to havecaused a remedy to be chosen (soil vapor extraction) and scheduled for implementation. Furtherdelay is not warranted and would lead to the possibility of additional VOCs being leached intothe water table. Additionally, the soil vapor extraction component of the remedy was notproposed for revision and thus is not open to modification at this time. U.S. EPA may considerthe use of methanol extraction testing following completion of the soil vapor extraction cleanupremedy when soil sampling is performed to ensure that the cleanup has met soil cleanup levels.
8. U.S. EPA believes that the soil vapor extraction procedure is an important step in thecleanup at the Site; however, the proper sequence would be to implement it after the surfacesoils have been cleaned up to protective levels. The surface soils present greater potential risks
to receptors in relation to the subsurface soils based upon dermal contact or ingestion; thus, itwould be prudent to take care of these risks first.
Additionally, it is more efficient to treat the PCB-laden soil first before installing the soilvapor extraction remedy because some of the excavated soils for PCB treatment may containVOCs that can be removed as well. PCB contamination at depth is due to the co-disposal ofsolvents that leach them down towards the water table. Once the solvents are removed by soilvapor extraction, based on the PCB leaching tests, it is not anticipated that PCBs at levels of50 ppm or less will leach into the groundwater at levels above groundwater standards. Withoutthe actions of solvents, the PCBs will bind to the soils despite the relative absence of organicfines and therefore not leach into the water table above standards. U.S. EPA agrees that theexpeditious implementation of the soil vapor extraction procedure is warranted upon completionof the PCB cleanup step. ,
9. The PCB-treatment technologies will reduce Dieldrin levels to below the soil cleanuplevel and the treatment concentrates containing PCBs, Dieldrin, and other compounds will beproperly disposed of off-site.
U.S. EPA believes that the soil vapor extraction procedure is an important step in thecleanup at the Site; however, the proper sequence would be to implement it after the surfacesoils have been cleaned up to protective levels. The surface soils present greater potential risksto receptors in relation to the subsurface soils based upon dermal contact or ingestion, thus, itwould be prudent to take care of these risks first.
Comment 7A: Dave Dempsey, Policy Director, Michigan Environmental Counsel, Lansing, MI
"We are concerned that the proposed amendment leaves in place an unacceptable level ofPCB contamination in soils. The effective cleanup levels of 5 ppm in the upper six feet of soiland SO ppm below that level are inconsistent with the previous ROD and good public healthpractice. We support requiring cleanup to levels that are consistent with the previous ROD orthe Michigan Part 201 standard.
"The one foot of capping required in the proposed amendment is simply inadequate.This will permit penetration by rainwater and animals. An adequate cap would require threefeet of clay for impermeability and an additional one foot of sand or gravel, and capped by theproposed foot of clean soil.
"We are also concerned about long term security of the site in accordance with theamendment. The area must be secured to prevent access by motorized recreational vehicles andother visitors. This requires a chain link fence and barbed wire around the entire site.
"As an altenative to your agency's proposal, we support implementation of the soil vaporextraction method at once. This cost-effective remediation can be conducted white the issueswe've raised above are further explored."
Response 7A:
See responses to comments 6A, above. There is no need to fence the entire Nicksonproperty based on contamination being found primarily in the currently fenced area.
8A: Nancy Strole. Clerk. Charter Township of Springfield. Davisburg. MI
"I want to reiterate that I support the remedy proposed by U.S. E PA.i
"At the public meeting held by U.S. EPA on April 2. an adjacent propertyowner...expressed concern that the integrity of the cap would be breached by soil erosion, byburrowing animals, or by other naturally-occurring, non-human events. I believe .. .that herconcern will be addressed by the following: (1) the remedy will require that the PRPs regularlyinspect and maintain the cap and fence. A quarterly inspection schedule will assure that anybreaches of the cap will be quickly discovered and fixed; (2) potential soil erosion problemswould be minimized by the final grading plan, which will require a fairly level grade in therestricted area; (3) depending on the technology selected for treatment of PCBs. the remedycould result in 15-20% of excavated soils being removed for off-site disposal. These soils willhave to be replaced on site by clean fill. As a result, it's likely that portions of the site willexceed the required minimum of one foot of clean soils and will further reduce the possibility ofexposure to contaminants beneath the cap."
Response 8A:
U.S. EPA agrees with the above analysis regarding the soil cover area of the Site.
B Oral
Comment IB: Chip Acey. Springfield Township. MI
"...It's taken 20 years to get to this point, and I don't think really it's going to satisfyeveryone, but at some point we jusi have 10 bite the bullet and let this thing go forwardand get the .... job done."
Comment 2B: Steve Ausum. Springfield Township. MI
"....I stand in support of the site cleanup, and I would like to see it implemented as soonas possible."
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Comment 3B: Mary Oosterhof, Springfield Township, MI
"...I support what has been done and appreciate all the actions that have taken place....!would like to see things move forward on the project."
Comment 4B: Doug McGinnis, Springfield Township, MI
"I support what has been proposed here tonight, and I just... got the feeling that thesooner you can start on this project the better opportunity of seeing the land being put in the bestpossible condition, that the longer you wait to do any of this work it's just going to be moredifficult to clean up the land and it's not going to benefit to waste any more time."
Comment 5B: Dave Hopper, Springfield Township, MI ,
"...I fought through this long and hard and I echo the sentiments [support for the RODAmendment] said earlier."
Comment 6B: Jim Carlton, Springfield Township, MI
"...I support this also. I think it's a doable thing."
Comment 7B: Mark Heringhausen, Springfield Township, MI
"...I support it [ROD Amendment] a hundred percent, and I would really like to see itmove forward and be taken care of and we can all put it behind us and move on..."
Responses IB through 7B:
U.S. EPA acknowledges and appreciates the support in this matter.
Comment SB: Don Balkwell, West Bloomfield, MI
"I have a couple of reservations. The primary one has to do with restriction of access tothe Site after cleanup is finished, and I would like to see that addressed in some manner, fencingis what comes to mind of the entire 500 feet area of deed restriction. And also I would like tosee some way of permitting ordinary citizens to do something to enforce the deed restrictions iffor any reason the other parties to the agreement don't."
Response 8B:
The area of the Site to be capped with a 1-foot soil layer will be fenced to restrict casualaccess; however, this area may not entirely coincide with the entire 500-foot parcel subject todeed restrictions. It is not necessary to restrict the property owner's access to uncontaminated
-14-
ponions of her property. Adjacent property owners must do their pan to restrict trespassing onthe adjacent properties, which will in turn further restrict access to the soil cover area.
See response to written comment 6A.2 regarding the issue of citizen's enforcement of thedeed restrictions.
9B: Cynthia Balk well. West Bloomfield, MI
"I nave concerns about using only one foot of soil as top covering."
Response 9B:
One foot of clean soil will be adequate to prevent casual access to the treatment residualsbackfilled beneath the soil cover. Periodic inspection and maintenance will preserve theeffectiveness of the soil cover. (See also the response to the written comments regarding thissame point.)
Comment 10B: Tom Middlcton. State Representative
"There's been concern about people getting into that fenced-in area. ...either put wildraspberries in that area or poison ivy. That would keep them out."
JOB
Thank you for the idea, but wild raspberries (thorns) or poison ivy may cause concern tothose charged with periodic inspection and maintenance of the soil cover, as well as to theproperty owner.
U.S. ENVIRONMENTAL PROTECTION AGENCYREMEDIAL ACTION
ADMINISTRATIVE RECORD FOR THE RECORD OF DECISION AMENDMENTFOR
SPRINGFIELD TOWNSHIP DUMP SITESPRINGFIELD TOWNSHIP, OAKLAND COUNTY, MICHIGAN
UPDATE 11JUNE 23,1998
NO.
1
DATE
05/00/95
05/00/97
03/18/98
03/21/98
04/02/98
04/10/98
AUTHOR
U.S. EPA/RREL
RECIPIENT
U.S. EPA
U.S. EPA/OERR
U.S. EPA
U.S. EPA Public
CharterTownship ofSpringfield
Hill. S.U.S. EPA
Merrill &Associates.Inc
Strole. N..CharierTownship ofSpringfield
U.S. EPA
Hill. S,U.S. EPA
TITLE/DESCRIPTION
Project Summary: RemovalofPCBs from ContaminatedSoil Using the CF SystemsSolvent ExtractionProcess: A TreatabilityStudy (EPA/540/SR-95/505)
Engineering BulletinSeparation/ConcentrationTechnology Alternativesfor the Remediation ofPesticide-ContaminatedSoil (EPA/540/S-97/503)
Public Notice: Announce- 1ment of April 2.1998Public Meeting and theMarch 26-April 27,1998Public Comment Period onthe Proposed Plan for theROD Amendment for theSpringfield Township DumpSite
Letter ForwardingAttached March 21. 1998Newspaper Article: LocalDump Site Targeted as aPriority on FederalCleanup List (OaklandPress)
Transcript of Public 85Hearing re: the ProposedPlan for the ROD Amend-ment for the SpringfieldTownship Dump Site
Letter ForwardingAttached April 9, 1998Springfield TownshipBoard's Resolution re:the Proposed Record ofDecision Amendment forSpringfield TownshipDump Site
_ROD
UpdaPa
NO.
7
DATE
04/27/98 ConcernedCitizens
H*. S.US EPA
Five Pubic CommentLeHtis ve~ the ProposedRecord of DecisionAmendment for ttie
04/27/96 UndteKmg.G.. Friendsof Rose
04/27/96
10 0409*8
Stole. N.CharierTownship ofSpringfeM
Dempsey. D.
H*. S.US EPA
H*. S.U.S. EPA
H*. S.US EPA
Cound
Dump Site ReceivedMarch 19-Apri 27. 1998
Letter re: Comments on 1the Proposed Record ofDecision Amendment torthe SpringieU TownshipDump Site
Letter re: Comments on 3the Proposed Record ofDecision Amendment forthe Springirid TownshipDump Site
Letter re:MEC's Comments 1on ne Proposed Recordof Decision Amendmentfor the SpringfieldTownship Dump Site
U.S. ENVIRONMENTAL PROTECTION AGENCYREMEDIAL ACTION
ADMINISTRATIVE RECORD FOR THE RECORD OF DECISION AMENDMENTFOR
SPRINGFIELD TOWNSHIP DUMP SITESPRINGFIELD TOWNSHIP, OAKLAND COUNTY, MICHIGAN
UPDATE 02JULY 27,1998
NO. DATE AUTHOR
1 06/10/98 U.S. EPA
07/23/98 Clarizio. R.,U.S. EPA
RECIPIENT
Public
Lerminiaux,K.; Dickinson.Wright, Moon.VanDusen &Freeman
TITLE/DESCRIPTION
Record of DecisiorAmendment for theSpringfield TownshipDump Site
Letter Forwarding theRecord of DecisionAmendment and U.S. EPAAdministrative RecordIndexes for Updates #1and #2 for the Spring-field Township DumpSite