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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Record of Decision Amendment Sturgis Municipal Well Field Superfund Site

Sturgis, Michigan

Record of Decision Amendment for the

Sturgis Municipal Well Field Superfund Site Sturgis, Michigan

Site Name and Location

Sturgis Municipal Well Field Superfund Site City of Sturgis, Saint Joseph County, Michigan

Statement of Basis and Purpose

This decision document amends the September 30, 1991, Record of Decision (ROD) for the Sturgis Municipal Well Field Superfund Site, in Sturgis, Michigan. This decision document presents the selected remedial action for the Sturgis Municipal Well Field Superfund Site, and was developed in accordance with the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Specifically, this decision document has been prepared in compliance with CERCLA Section 117 and NCP Section 300.435(c)(2)(ii). This decision document explains the factual and legal basis for selecting the remedy for this site. The information supporting this remedial action decision is contained in the administrative record for this site.

Assessment of the site

Actual or threatened releases of hazardous substances fi'om this site, if not addressed by implementing the response action selected in this ROD Amendment, may present an imminent and substantial endangerment to public health, welfare, or the environment.

Description of the Selected Remedv

The selected remedy is the final remedy for the site. The purpose of this remedy is to eliminate the source of groundwater contamination and restore the aquifer to its beneficial use.

The major components of the selected remedy include the following:

Soil vapor extraction of VOCs in the Kirsch Property source area soils to cleanup levels contained in Part 201 of the Natural Resources and Environmental Protection Act (NREPA), 1994 PA 451, as amended, Mich. Comp. Laws, § 324.20101 et seq (hereinafter NREPA Part 201 cleanup levels) which are based on the need to protect groundwater;

Extraction and treatment of groundwater using air stripping with vapor phase granular activated carbon to be used to treat the off-gases and/or treatment of groundwater with liquid phase carbon. Extraction and treatment will be conducted until Federal drinking water standards (Maximum Contaminant Levels-("MCLs")) are reached for VOCs. In addition to achieving Federal cleanup levels, a risk evaluation shall be performed to verify that there is no unacceptable risk associated with the groundwater;

Discharge of treated water to surface waters (via storm sewer) or to the municipal system;

A minimum of a 30-year groundwater monitoring program to assure the effectiveness of remedial action and the quality of the municipal water supply.

Declaration of Statutory Determinations

The selected remedy is protective of human health and the environment, complies with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost effective. This remedy uses permanent solutions and alternative treatment or resource recovery technologies to the maximum extent practicable, and satisfies the statutory preference for remedies that employ treatment that reduces the toxicity, mobility, or volume as a principal element. Because this remedy will not result in hazardous substances on site above health based levels, the five year review will not apply to this action.

William E. Muno, Director/ Date Superfund Division

STATE OF MICHIGAN

JOHN ENGLER, Governor

DEPARTMENT OF ENVIRONMENTAL QUALITY HOLLISTER BUILDING, PO BOX 30473, LANSING Ml 48909-7973

RUSSELL J. HARDING, Director

August 23, 1996

Mr. Valdas V. Adamkus, R-19J Administrator, Region 5 U.S. Environmental Protection Agency < 77 West Jackson Boulevard Chicago, Illinois 60604-3590

Dear Mr. Adamlms:

The Michigan Department of Environmental Quality (MDEQ) is pleased to concur with the July 3, 1996 draft amendment to the September 1991 Record of Decision for the Sturgis Municipal Well Field Superflmd site in St. Joseph County, Michigan. We agree that the amended remedy better reflects current site conditions and compliance with current state and federal environmental cleanup regulations.

If you have any questions, please contact the project manager, Mr. Robert Franks, Superflmd Section, Environmental Response Division, at 517-335-3392, or you may contact me directly.

Sincerely,

RussdTj. Harding Director 517-373-7917

cc: Mr. Alan J. Howard, MDEQ

EQP 0100e (10/95)

DECISION SUMMARY AMENDED REMEDIAL ALTERNATIVE STURGIS MUNICIPAL WELL FIELD SITE

STURGIS, MICHIGAN

I. INTRODUCTION

The Sturgis Municipal Well Field Site is located in the City of Sturgis, Michigan. The city is located in south central Michigan in St. Joseph County. The city encompasses approximately five (5) square miles and approximately 10,000 people reside in the city.

The aquifer beneath the city supplies the city's residents and numerous industries with water. Several of the wells have been contaminated with trichloroethene (TCE) or tetrachloroethene (PCE) and have either been shut down or used for non-consumptive purposes. Two primary source areas have been identified for the aquifer contamination; the Kirsch Company Plant No. 1 property (Kirsch) and the former Wade Electric property (Wade).

The Kirsch property currently consists of ofiBces for the Kirsch Co. and a vacant lot. The vacant lot and existing buildings had previously been a large manufacturing facility. The manufacturing facilities previously located on the vacant lot have been demolished.

The Wade property is currently occupied by the Sturgis Archery Center. The Wade Electric facility closed in 1966 and burned down in 1974. The current property owner removed six underground tanks from the rear of the Wade facility. According to the owner, these tanks contained a thick oily substance and were not leaking.

II. SITE fflSTORY AND ENFORCEMENT ACTIVITIES

On September 30, 1991, U.S. EPA signed a Record of Decision (ROD) for the final remedy at the site. The ROD required soil vapor extraction of volatile organic compounds (VOCs) (the principal threat) in the source area soils to Type B cleanup levels established pursuant to the Michigan Environmental Response Act (MERA), 1982 PA 307, as amended, Mich. Comp. Laws, § 299.601 et seq. and the administrative rules promulgated thereunder; excavation and disposal of soils contaminated with low-level polynuclear aromatic hydrocarbons (PAHs) to MERA Type B Cleanup Levels; extraction and treatment of groundwater by air stripping, with discharge of treated water to surface water (via storm sewer) or to the municipal system; and a minimum of a 30-year groundwater monitoring program to assure the effectiveness of the action and the quality of the municipal water supply. On October 23, 1992, U.S. EPA issued a Unilateral Administrative Order ("UAO") to Cooper Industries, Inc., ("Cooper") the parent company of Kirsch, for remedial design and remedial action for an Interim Groundwater

Extraction/Treatment System. Since its issuance. Cooper has been in compliance with the UAO. The Interim system was designed to contain the majority of the groundwater contamination in order to prevent any further degradation of the aquifer and to prevent groundwater contamination from affecting any other municipal wells.

The interim system was installed and has been operational since May 1994.

in. ROD AMENDMENT COMPONENTS

Soil data collected from the Wade and Kirsch source areas as part of the predesign investigation indicate significant decreases in soil contamination due to natural processes; most notably VOCs at the Wade source area. This current data prompted U.S. EPA to reevaluate the necessity of soil remediation for VOCs and PAHs. In addition, U.S. EPA has reevaluated cleanup standards at the site to reflect current Federal and State regulations for soil and groundwater and has reevaluated risk at the site to reflect current Federal guidance on calculating risk at Superfimd sites. Cleanup standards for ground water and soil which were included in the September 30, 1991 ROD were developed to meet requirements of the Michigan Environmental Response Act (Act 307). In 1994, Act 307 was revised and incorporated into Part 201 of the Natural Resources and Environmental Protection Act (NREPA). In light of the 1995 amendments to NREPA Part 201, cleanup standards at the Sturgis Municipal Well Field site will be revised to reflect current State and Federal regulations. U.S.EPA and the State of Michigan have determined that the following changes to the ROD cleanup standards are appropriate and are protective of human health and the environment.

The major components of the alternate remediation consist of:

• Soil vapor extraction of VOCs in the Kirsch source area soils to cleanup levels contained in Part 201 of the Natural Resources and Environmental Protection Act (NREPA), 1994 PA 451, as amended, Mich. Comp. Laws, § 324.20101 et seq (hereinafter NREPA Part 201 cleanup levels) which are based on the need to protect groundwater;

• Extraction and treatment of groundwater using air stripping and/or liquid phase carbon with vapor phase granular activated carbon to be used to treat the off-gases. Extraction and treatment will be conducted until Federal drinking water standards (Maximum Contaminant Levels-MCLs) are reached for VOCs. In addition to achieving Federal cleanup levels, a risk evaluation shall be performed to verify that there is no unacceptable risk associated with the groundwater;

• Discharge of treated water to surface waters (via storm sewer) or to the municipal system;

• A minimum of a 30-year groundwater monitoring program to assure the effectiveness of remedial action and the quality of the municipal water supply.

This ROD amendment differs from the ROD remedy as follows:

• Soil cleanup levels are changed to reflect current State requirements.

• No action for PAH-contaminated soils at the source areas.

• No action for VOC-contaminated soils at the Wade source area.

• Liquid-phase carbon absorption to treat contaminated groundwater as a possible substitution or addition to air stripping.

IV. REASONS FOR AMENDING THE 1991 RECORD OF DECISION

Soil data collected from the Wade and Kirsch source areas as part of the predesign investigation indicate significant decreases in soil contamination due to natural processes; most notably VOCs at the Wade source area. This current data prompted U.S. EPA to reevaluate the necessity of soil remediation for VOCs and PAHs. In addition, U.S. EPA has reevaluated cleanup standards at the site to reflect current Federal and State regulations for soil and groundwater and has reevaluated risk at the site to reflect current Federal guidance on calculating risk at Superfund sites.

Cleanup standards for ground water and soil which were included in the September 30, 1991 ROD were developed to meet requirements of the Michigan Environmental Response Act (Act 307). In 1994, Act 307 was revised and incorporated into Part 201 of the Natural Resources and Environmental Protection Act (NREPA). In light of the 1995 amendments to NREPA Part 201, cleanup standards at the Sturgis Municipal Well Field site will be revised to reflect current State and Federal regulations.

U.S.EPA and the State of Michigan have determined that these changes to the ROD cleanup standards are appropriate and protective of human health and the environment.

A. PAH Contaminated Soils

U.S.EPA reevaluated the human health risks associated with direct contact and incidental ingestion of PAH contaminated soils to reflect current Federal guidance on calculating risk at Superfund sites and found that there is currently no unacceptable health risks associated with PAH contaminated soils at the source areas. In general, the 1991 ROD baseline risk assessment used maximum chemical concentrations and an exposure frequency/duration of 365 days/year over 70 years (lifetime) to calculate risk. The recalculated risk value used the 95% Upper Confidence

Limit on the Mean (UCLM) for chemical concentrations and an exposure frequency/duration of 350 days/year over 24 years for adults and 6 years for a child under a residential scenario in accordance with U.S. EPA's Risk Assessment Guidelines ("RAGS"). The recalculated cancer health risk numbers for dermal and incidental ingestion of carcinogenic PAH's was 3.9e-05 (total) for children and 1.8e-05 (total) for adults at the Kirsch property and 7. Ie-06 (total) for children and 3.2e-06 for adults at the Wade property. These cancer health risk numbers are within the acceptable risk range under the NCP.

In addition, MERA Type B Cleanup levels for site specific indicator PAH compounds in soil were changed as a result of the 1995 amendments to NREPA 451 Part 201. The following table presents a comparison of the former and current cleanup standards which are based on the need to protect groundwater:

SOIL PAH CLEANUP LEVELS

COMPOUND 1991 RODAct 307 Cleanup

Standards Based on Protection of Groundwater, (pg/kg)

1996 ROD Amendment NREPA Part 201 Cleanup

Standards based on Protection of Groundwater, (pg/kg)

Benzo(b)fluoranthene 330 14,000

Benzo(a)pyrene 330 1,400

State Cleanup levels for PAH contaminant compounds in soil were substantially amended under the new law. Investigation for the cleanup of soil at the source areas indicated that PAH levels in the soil are generally below the current State cleanup levels. In addition, at the two source areas, PAHs have not been detected in the groundwater.

Based on the information presented above, excavation and disposal of soils contaminated with low-level PAHs is no longer necessary. The remedy regarding PAH remediation is amended to no action.

VOC Contaminated Soils

As part of the pre-design investigation conducted in the fall of 1994, extensive soil data were gathered at the Wade and Kirsch locations. Analytical data from the soil investigation indicated that levels of contamination at the Wade location have decreased since the time the ROD was

written. In fact, when compared to ROD Amendment cleanup levels, the Wade location soil levels have generally decreased to the point that active remediation is no longer necessary to protect groundwater at the site. Moreover, the trend of decreasing VOC concentrations in soils at the Wade location are expected to continue over time. The U.S.EPA and State agree that implementing a remedy for VOC contamination at the Wade location would not currently add any benefit to the protection of groundwater at the site. However, VOC soil contamination at the Wade location will be evaluated over time to insure that the trend of decreasing VOC concentrations in soil continues. This approach at the Wade location will be protective and complies with State and Federal ARARs.

State cleanup levels for VOCs in soil were substantially amended under the new law. MERA Type B Cleanup levels for VOC compounds in soil were changed as a result of the 1995 amendments to NREPA Part 201. The following table presents a comparison of the former and current cleanup standards in the 1991 ROD for selected VOCs which are based on the need to protect groundwater:

SOIL VOC CLEANUP LEVELS

COMPOUND 1991 RODAct 307 Cleanup

Standards Based on Protection of Groundwater, (pg/kg)

1996 ROD Amendment NREPA Part 201 Cleanup

Standards based on Protection of Groundwater.

(Pg/kg)

Trichloroethene (TCE) 60 100

Tetrachloroethene (PCE) 14 100

Vinyl Chloride 1 40

Soil vapor extraction of VOCs at the Kirsch property will still be performed to meet the new State cleanup criteria, because contamination still consistently exceeds the revised standards.. Verification that cumulative risk associated with the Kirsch and Wade source areas falls within the acceptable NCP risk range and Hazard Quotient (HQ) ratio requirements was demonstrated in the original baseline risk assessment. The baseline risk level was calculated using direct contact and incidental ingestion of VOC Contaminated soils under a residential use scenario.

C. Contaminated Groundwater

MERA Type B Cleanup Levels for VOCs in groundwater were changed as a result of the 1995 amendments to NREPA Part 201. New State cleanup levels for groundwater VOCs are similar to Federal drinking water standards (MCLs) which are part of the Safe Drinking Water Act 40 CFR 141. Therefore, U.S. EPA chose to use Federal standards (MCLs) for initial VOC cleanup goals in groundwater with the exception of bromodichloromethane (explained below). The following table presents a comparison of the former and current cleanup standards for selected VOCs and cyanide;

INITIAL GROUNDWATER CLEANUP LEVELS

COMPOUND 1991 ROD Act 307 Initial

Cleanup Standards. (Pg/kg)

1996 ROD Amendment Federal MCL Initial Cleanup

Standards, (pg/kg)

Trichloroethene (TCE) 3 5

Tetrachloroethene (PCE) 1 5

1,2 Dichloroethane 1 5

Bromodichloromethane 1 *100

1,1,2 Trichloroethane 1 5

Vinyl Chloride 1 2

Benzene 5

Cyanide 100 200

* Current NREPA Part 201 initial cleanup number.

An MCL has not been established for bromodichloromethane. In addition, the cancer risk from incidental ingestion of bromodichloromethane was 7.4e-06 which is within the acceptable risk range under the NCP. U.S. EPA determined that it was not necessary to establish a risk-based cleanup standard because risk was within the acceptable risk range under the NCP and, therefore, Michigan's 201 cleanup standard which is based on residential groundwater consumption will be used as an initial cleanup goal.

Once initial groundwater cleanup standards have been achieved for all VOCs, a risk evaluation shall be performed in accordance with U.S. EPA RAGS to verify that the ultimate goal of the remedy is met in accordance with the NCP; specifically, that the cumulative risk associated with the groundwater falls within the acceptable cancer risk range and Hazard Quotient (HQ) ratio requirements under the NCP. If it does not, U.S. EPA (in consultation with MDEQ) may determine that additional remedial actions such as additional extraction wells and/or different extraction well pumping rates are necessary.

V. COMPARATIVE ANALYSIS

The amended remedial alternative will address all remaining principal threats to the public health, safety, welfare and the environment presented at the site. This section compares the performance of the amended remedy and the alternative selected in the September 30, 1991 ROD.

The principal difference between the remedy selected in the ROD and the alternative remedy is that the alternative remedy includes no action for the PAH-contaminated soil at the Kirsch and Wade sites and no action for the VOC-contaminated soil at the Wade site. The remedy for the VOC-contaminated soil at the Kirsch site, the VOC-contaminated groundwater in the well field and the requirement for groundwater monitoring all remain the same. However, the cleanup standards for these media have been revised to reflect current Federal and State regulations for soil and groundwater.

A. Threshold Criteria

1. Overall Protection of Human Health and Environment

This criterion addresses whether a remedy provides adequate protection and describes how risks posed through each pathway are eliminated, reduced or controlled through treatment, engineering controls, or institutional controls.

Both the amended remedy and ROD remedy minimize the risks posed by direct contact or ingestion of site-related contaminants by treatment and/or containment. Both remedies are considered protective of human health and the environment.

The groundwater component of the amended remedy and ROD remedy are equally effective in remediating the contaminated aquifers because contaminants are actively contained or extracted, until health-based cleanup criteria are achieved. Both alternatives are equally reliable in protecting the water quality of the existing municipal system and private well users.

The soil component of both remedies result in soils which do not pose unacceptable risks due to direct contact or ingestion and which are protective of groundwater.

2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs^

Compliance with ARARs addresses how the proposed remedy complies with all applicable or relevant and appropriate requirements of federal and more stringent state environmental laws (ARARs). This section also considers how the alternatives comply with advisories, criteria or other guidance to be considered (TBCs) that do not have the status of law, but that the U.S. EPA and the state have agreed are "appropriate" for protectiveness or to carry out certain actions or requirements.

A summary of identified ARARs for the groundwater and soil alternatives is included below. Only ARARs necessaiy for on-site remedial activities have been identified. In some instances, rules cited contain both substantive and procedural or administrative requirements. Only the substantive requirements are ARARs for the purpose of on-site activities.

a. Closure

i Federal

Portions of 40 CFRPart 264, regarding standards for owners and operators of hazardous waste treatment, storage and disposal facilities, are ARARs. 40 CFR 264.94 and 264.100 requirements are relevant and appropriate. They regulate circumstances sufficiently similar to those at the site because source area soils are likely to be characteristically hazardous. The requirements in 40 CFR § 264.301, 264.303-304, 264.310, 264.91-100, 264.111, and 264.116-117 are applicable since RCRA hazardous wastes (i.e., chemical precipitation sediments) may be placed in a landfill after treatment to satisfy land disposal restrictions (LDRs).

ii. State

Certain Hazardous Waste Management requirements, which are contained in Part 111 of NREPA, Mich. Comp. Laws, § 324.11101 et seq. are ARARs. MAC Rule 299.9612 requirements are not applicable because source area soils are not contaminated with hazardous waste, which is regulated under Part 111 of NREPA. However, the requirements are relevant and appropriate since they regulate circumstances sufficiently similar to those at the site. Levels of contamination

in the source area soils indicate that these soils would be characteristic hazardous wastes. MAC Rule 299.9602-9604, 299.9611-9613, and 299.9619.9622 are applicable ifNREPAPart 111 wastes are placed in a landfill.

iii. Discussion

Residuals from groundwater and soil treatment alternatives can be handled in such a way that federal LDR requirements relating to the on-site activities will be met.

b. Groundwater Standards

i. Federal ARARs

Maximum Contaminant Levels (MCLs), and to a certain extent. Maximum Contaminant Level Goals (MCLGs), the federal drinking water standards promulgated under the Safe Drinking Water Act (SDWA), 40 CFR 141, are applicable to municipal water supplies servicing 25 or more people. MCLs and MCLGs are relevant and appropriate to circumstances at the site, since the aquifers are used for drinking water. MCLGs are relevant and appropriate when the standard is set at a level greater than zero (for non-carcinogens). Otherwise, MCLs are relevant and appropriate at Superfimd sites. The point of compliance for MCLs and MCLGs is throughout the plume.

The selected remedy will attain MCLs contained in the SDWA and 40 CFR 141.

ii. State ARARs

The Michigan Department of Environmental Quality has promulgated administrative rules governing "Environmental Remediation" pursuant to Part 201 of NREPA (NREPA Part 201 Rules). The NREPA Part 201 Rules contain provisions establishing procedures for response activities, selection of remedial action and cleanup criteria at sites of environmental contamination where response activities are taken. These Rules contain requirements that are applicable to remedial action at the Sturgis site because: (1) contaminant levels currently found in the site groundwater exceed levels set by application of the cleanup criteria and (2) contaminants currently found in the Kirsch site soils are a potential continuing source of contamination to the groundwater.

The Michigan Safe Drinking Water Act, 1976 PA 399, as amended, Mich. Comp. Laws, § 325.1001 et seq, provides regulations establishing MCLs for certain contaminants in addition to federal MCLs and would be relevant and appropriate for all groundwater alternatives. MAC Rule 325.10601-10607 requirements are applicable since the aquifer underlying the site is used to supply a community water system.

Part 31 of NREPA (formerly the Water Resources Commission Act, 1929 PA 245), Mich. Comp. Laws, § 324.3101 et seq. contains state water quality standards, treatment plant operator requirements and wastewater reporting requirements. NREPA Part 31 Rules also implement a waste effluent discharge system compatible with NPDES requirements and provide for the non-degradation of groundwater. Because NPDES requirements regulate discharge, these water quality standards are applicable to both alternatives for on-site discharge to surface water.

hi. Discussion

Both alternatives comply with the requirements of the NREPA Part 201 and its Rules, NREPA Part 31 and its Rules and the federal and state Safe Drinking Water Acts, as they pertain to groundwater.

Both the federal and state Safe Drinking Water Acts are relevant and appropriate (the aquifer under the site is used for a community water supply) to Sturgis groundwater considerations since they regulate Maximum Contaminant Levels in drinking water for protection of human health. Both treatment alternatives would meet federal and state groundwater ARARs.

c. Soil Standards

i. State ARARs

NREPA Part 201 and the NREPA Part 201 Rules establish the procedures for determining cleanup criteria for contaminants in soils. NREPA Part 201 and its Rules are applicable for all soil alternatives.

ii. Discussion

The ROD remedy was selected based in part on former MERA Type B cleanup criteria, which have been changed as a result of the 1995 amendments to NREPA Part 201. While still protective of human health and the environment, the new cleanup criteria allow for less stringent soil cleanup standards for VOC and PAH compounds. Based on the amended Part 201 soil standard, the selected alternatives would meet federal and state ARARs.

d. Air Standards

i. Federal ARARs

Regarding the Clean Air Requirements, 40 CFR 50.1-50.12 requirements are applicable because emissions from the groundwater and soil treatment systems would be subject to Primary and Secondary Ambient Air Quality Standards. Construction and treatment system activities are potential sources of fugitive dust, particulates and VOCs and would be subject to the TSP standard.

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ii State ARARs

Certain state Air Pollution requirements, which are contained in Part 55 of NREPA, Mich. Comp. Laws, § 324.5501 et seq. together with the administrative rules promulgated thereunder are ARARs. NREPA Part 55 Rules contain requirements for emission limitations and prohibitions for particulate matter, fugitive dust and VOCs. MAC Rule 336.1702, 336.1901, and 336.1371-1373 requirements are applicable since emissions from the treatment system would be subject to state standards for VOCs. Construction activities are potential sources of fugitive dust.

iii. Discussion

It is expected that selected alternatives for soils and groundwater will meet state and federal air standards. Appropriate practices and controls will be used to achieve compliance.

e. RCRA Land Disposal Restrictions (LDRsI

i. Federal ARARs

RCRA LDRs, 40 CFR Part 268, are applicable for all action alternatives considered for the Sturgis Municipal Well Field site. Filter media for both groundwater and soil treatment alternatives are likely to become characteristically hazardous, and therefore, LDRs are applicable prior to re-use or disposal. If characteristic spent carbon is to be land disposed, it must be placed into a Subtitle C landfill. When treatment standards for newly identified Toxicity Characteristic (TC) wastes are promulgated, the characteristic carbon will have to be treated to below the treatment standard, but then may be disposed in a Subtitle D landfill.

ii. Discussion

Although it is expected that alternatives considered for soil and groundwater could meet RCRA LDR restrictions, a Treatability Variance for contaminated carbon residuals would be established to address the possibility that regeneration/thermal destruction cannot reduce TCE and PCE in the spent carbon to LDR acceptable levels. The treatment level range established through a Treatability Variance that regeneration/thermal destruction will attain for each constituent of concern are:

TCE 95-99.9% reduction (Time Weighted Average) PCE 95-99.9% reduction (Time Weighted Average).

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f. Transportation Regulations

i. Federal ARARs

Certain Department of Transportation requirements concerning on-site activities are ARARs at this site. If contaminated treatment byproducts (i.e., chemical precipitation, spent carbon, etc.) are determined to be hazardous wastes under RCRA and are transported off-site, the Department of Transportation rules for transportation of hazardous materials (40 CFR Part 263) and RCRA would be applicable to any off-site transportation or handling of the hazardous wastes. In addition, 49 CFR 107 and 171 requirements are applicable when hazardous wastes are transported to an off-site disposal facility.

ii. State ARARs

MAC Rule 299.9301-299.9311 generator requirements are applicable for all wastes transported off-site.

iii. Discussion

It is expected that selected alternatives will meet the transportation ARARs and all legal requirements for off-site activity identified above.

g. Miscellaneous ARARs

i. Federal ARARs

Since the levels of TCE and PCE in the groundwater are high enough to make the groundwater a characteristic RCRA hazardous waste, any unit in which the groundwater is treated is subject to RCRA regulations for tanks, 40 CFR Part 264 Subpart J and/or RCRA regulations for miscellaneous units, 40 CFR Part 264 Subpart X.

If characteristic carbon is to be regenerated, RCRA regulations for miscellaneous units are applicable, as set forth in 40 CFR Part 264 Subpart X.

ii State ARARs

Construction activities must comply with substantive requirements promulgated pursuant to Part 90 of ISIREPA (formerly Soil Erosion and Sedimentation Control Act), Mich. Comp. Laws, § 324.9001 et seq. NREPA Part 90 Rule requirements are applicable since construction would involve earth changes and the potential for soil erosion.

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Certain requirements of Part 625 of NREPA (formerly the Mineral Well Act), Mich. Comp. Laws, § 324.62501 et seq. are ARARs. NREPA Part 625 requirements are applicable if extraction and monitoring wells are installed on-site.

iii. Discussion

It is expected that both alternatives will comply with the miscellaneous ARARs identified above.

B. Primary Balancing Criteria

1. Long-Term Effectiveness/Permanence

This criterion delineates the residual risk and evaluates the ability of an alternative to maintain reliable protection of human health and the environment over time, once cleanup objectives have been met.

Both alternatives would offer protection of public health and the environment over the long term by treating contaminants where necessary to meet NREPA Part 201 cleanup criteria.

2. Reduction of Toxicity. Mobilitv or Volume Through Treatment

This criterion evaluates the anticipated performance of the treatment technologies a remedy may employ.

Both alternatives would reduce the toxicity, mobility, or volume (TMV) by removing contaminants from the groundwater. Although air stripping and liquid phase carbon adsorption only transfer contaminants from groundwater to another media (and thus do not reduce TMV), the regeneration of the filter carbon used in the processes would reduce the TMV through treatment. Both alternatives reduce TMV through the regeneration of the carbon filter media.

3. Short-term Effectiveness

Short-term effectiveness addresses the period of time needed to achieve protection and any adverse impacts on human health and the environment that may be posed during the construction and implementation period.

The groundwater alternative for both the ROD remedy and amended remedy would actively reduce levels of contamination. Because of less stringent cleanup criteria, the amended remedy wiU achieve cleanup in a shorter time frame. Until groundwater cleanup levels are achieved, only institutional restrictions on the placement of private wells can be used to discourage the use of private wells. The potential also exists for worker exposure to contaminated material during treatment of groundwater for either alternative.

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The amended remedy for PAH-contaminated soil requires no time to implement as the soils would remain in place. The ROD remedy which required excavation and disposal of PAH-contaminated soil is no longer appropriate due to the amended Part 201 soil cleanup criteria and the reevaluation of risk using current U.S. EPA guidelines. The amended remedy eliminates the potential for worker exposure to contaminated material that would be present under the ROD remedy.

The amended remedy for VOC-contaminated soil at the Wade site requires no time to implement as the residual concentrations are protective of groundwater and do not require installation of an SVE system. The amended remedy for VOC-contaminated soil at the Kirsch site will require less time than the ROD remedy to achieve protection because the amended Part 201 soil cleanup criteria are less stringent.

4. Implementabilitv

This criterion considers the technical and administrative feasibility of implementing an alternative, including the availability of material and services needed to implement a particular option.

Both alternatives considered for groundwater remediation would be relatively simple to implement and would include construction of new wells for extracting groundwater. Careful planning of new well installation will reduce the risk of spreading existing contamination. Both discharge options for treated groundwater are implementable.

Both alternatives for soil remediation are easily implementable at the site. The use of SVE and excavation with the ROD remedy would be more difficult to implement than the no action component of the amended remedy.

5. Cost

The net present worth (NPW) costs for both alternatives considered are presented on the following table. Costs are based on estimates provided in the Feasibility Study and the September 30, 1991 ROD. The estimated cost to implement the ROD remedy is $13,524,000 and the estimated cost to implement the amended remedy is $11,712,000. To date, approximately $4,400,000 have been spent on the interim groundwater extraction/treatment system.

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Groundwater Kirsch Soils Wade Soils

TOTAL Alternative voc PAH VOC PAH

TOTAL

ROD Remedy

$11.20M $.512M* $1.664M $.057M $.091M $13.524M

Amended Remedy

$11.20M $.512M* 0 0 0 $11.712M

M = Million *Current estimates by MDEQ are at $1.1M.

C. Modifying Criteria

1. State Acceptance

The State of Michigan supports the amended remedial alternative.

2. Community Acceptance

Community acceptance of the amended alternative has been evaluated in the Responsiveness Summary which is a part of this Record of Decision Amendment.

VI. THE AMENDED REMEDY

Based upon consideration of the requirements of CERCLA, as amended by SARA, and the NCP, the detailed analysis of alternatives and public comments, U. S. EPA and MDEQ have selected the amended remedy for remediation of contamination at the Sturgis Municipal Well Field site. The amended remedy includes groundwater extraction with treatment, using liquid phase carbon and/or air stripping and vapor phase granular activated carbon to be used to treat the off-gases for remediation of groundwater contamination. The agencies have also determined that an ISVE system shall be implemented to remediate source area soils contaminated with VOCs at the Kirsch site. No action will be required for the PAH-contaminated soils at the Kirsch or Wade sites and no action will be required for the VOC-contaminated soils at the Wade site.

15

The soil alternative will use NREPA Part 201 residential standards for establishing cleanup levels. The groundwater alternative will use as initial cleanup goals SDWA, 40CFR141 MCL standards with the exception of bromodichloromethane which (due to a lack of an MCL) will use NREPA Part 201 residential standards. In addition, once initial groundwater cleanup standards have been achieved for all VOCs, a further risk evaluation shall be performed in accordance with U.S. EPA RAGS to verify that the cumulative risk associated with the groundwater falls within the acceptable cancer risk range and Hazard Quotient (HQ) ratio requirements under the NCP. If it does not, U.S. EPA (in consultation with the MDEQ) may determine that additional remedial actions such as additional extraction wells and/or different extraction well pumping rates are necessary.

Based on the information available at this time, the U.S. EPA and the State of Michigan believe that the amended remedy will reduce the risks to human health and the environment by removing and treating solvent contamination in the groundwater and the source area soils. It is important to note that the amended remedy will eventually allow for unrestricted use of the city's aquifers and will remove contamination in the soils to levels protective of groundwater. The amended remedy will also attain ARARs and use permanent solutions to the maximum extent practicable.

The goal of the amended remedy is to restore groundwater to its beneficial use, which is, at this site, a drinking water source. Based on information obtained during the RI and on careful analysis of both remedial alternatives, U.S. EPA believes that the selected remedy will achieve this goal. It may become apparent, during implementation or operation of the groundwater extraction and treatment system and its modifications, that contaminant levels have ceased to decline and are remaining constant at levels higher than the cleanup levels over some portion of the contaminated plume. In such a case, the system performance standards and/or the remedy may be reevaluated by the U.S. EPA. However, the groundwater will be monitored for at least 30 years to ensure that the groundwater remedy is protective of human health and the environment.

The amended remedy will include groundwater extraction for an estimated period of 20 years, during which the system's performance will be carefully monitored on a regular basis and adjusted as warranted by the performance data collected during operation. Modifications may include any or all of the following:

• Discontinuing pumping at individual wells where cleanup levels have been attained; • Alternating pumping at wells to eliminate stagnation points; • Pulse pumping to allow aquifer equilibrium and to allow adsorbed contaminants to

partition into groundwater; and • Installing additional extraction wells to facilitate or accelerate cleanup of the

contaminant plume.

16

VII. STATUTORY DETERMINATIONS SUMMARY

The selected remedy must satisfy the requirements of Section 121 (a-e) of CERCLA, as amended by SARA, to:

a. Protect human health and the environment; b. Comply with ARARs (or justify a waiver); c. Be cost effective; d. Utilize permanent solutions and alternative treatment or resource recovery

technologies to the maximum extent practicable; and, e. Satisfy the preference for treatment as a principal element or provide an explanation as

to why this preference is not satisfied.

The implementation of the amended remedy satisfies the requirements of CERCLA, as amended by SARA, as detailed below:

A. Protection of Human Health and the Environment

This selected remedy will provide protection of human health and the enviromnent through treatment.

Implementation of the selected alternative will reduce potential risks to human health and the environment posed by possible use of contaminated groundwater and will eliminate the Kirsch property as a source of groundwater contamination. Re-evaluation of site risks also indicates there is no unacceptable direct contact or incidental ingestion risk from PAH and VOC contaminated soils to potential residential receptors.

No unacceptable short-term risks or cross-media impacts would be caused by the implementation of the remedy. During the period required for remediation, institutional controls would be used to mitigate the interim threats from possible use of contaminated groundwater and possible exposure to contaminated soils. The community and site workers may be exposed to TCE and PCE in the soils and air, and to dust and noise nuisances during implementation of the groundwater and soil remedies. Standard safety programs, such as fencing, use of protective equipment, monitoring and dust control measures, should mitigate any short-term risks.

17

B. Compliance with ARARs

The amended remedy will meet or attain the applicable or relevant and appropriate federal and state requirements, and will be implemented in a manner consistent with these laws.

In particular, the remedial action selected for implementation at the Sturgis site is consistent with the National Contingency Plan, SDWA (40CFR 141), the state's NREPA Part 201 Rules, and the NREPA Part 31 (MAC Rule 323.1041 - R323.1116).

U.S. EPA has selected extraction and treatment of the hazardous substances in the soils to Part 201 generic residential levels. U.S. EPA has selected extraction and treatment of the hazardous substances in the groundwater to SDWA, 40CFR141 MCL standards as an initial goal. Once groundwater cleanup standards have been achieved for all VOCs, a risk evaluation shall be performed in accordance with U.S. EPA RAGS to verify that the cumulative risk associated with the groundwater satisfies a l.Oe-05 cancer risk and an HQ of 1.

The cleanup levels for NREPA Part 201 carcinogens are based on a 1 x 10 ' cancer risk and are consistent with NREPA Part 201 Rules 299.5709 and 299.5723. Where the cleanup level for a particular chemical is based on analytical detection (MDL), Rule 299.5707(b) has been applied. Rules 299.5709(b) and 299.5725 provide for cleanup levels based on Human Lifecycle Safe Concentrations (HLSC); taste and odor (T&O) thresholds are consistent with Rule 299.5709(d); and Rule 299.5725(b)(1) is the citation for Maximum Contaminant Levels (MCLs), where used.

1. Chemical Specific

The treatment system will comply with the requirements of Michigan Safe Drinking Act, 1976 PA 399, as amended, Mich. Comp. Laws, § 325.1001 et seq. to provide water of an acceptable quality. Monitoring, with the provisions of installing necessary treatment, provides water supply protection. If treatment is needed, the water will be treated to levels at or below the Act's Maximum Contaminant Level (MCL) for TCE and PCE.

The selected alternative for groundwater shall comply (for an initial goal) with the SDWA, 40CFR 141 MCLs with the exception of bromodichloromethane which shall comply (for an initial goal) with the NREPA Part 201 Rules for generic residential clean-up levels. SDWA initial cleanup levels for selected chemicals of concern in groundwater are identified in the following table.

18

SDWA 40CFR141 MCLs Selected VOC Initial Cleanup Levels for Groundwater (pg/1)

Trichloroethene (TCE) 5

Tetrachloroethene (PCE) 5

1,2 Dichloroethane 5

Bromodichloromethane *100 (total trihalomethane)

1,1,2 Trichloroethane 5

Vinyl Chloride 2

Benzene 5

Cyanide 200

* Current NREPA Part 201 initial cleanup number.

The selected alternative for soils shall comply with the NREPA Part 201 Rules for generic residential cleanup levels. NREPA Part 201 generic residential cleanup levels for ISVE removal of VOCs in soils, based on twenty times the groundwater standard, are identified in the table below.

NREPA Part 201 VOC Generic Residential Cleanup Levels for Soil

Protective of Groundwater (pg/kg)

Trichloroethene (TCE) 100

Tetrachloroethene (PCE) 100

Vinyl Chloride 40

The levels of contamination reaching the groundwater extraction wells could exceed the TCLP limits. The TCLP replaces the Extraction Procedure (EP) in determining if CERCLA wastes are characteristically hazardous wastes. Under NREPA Part 111, when the TCLP replaces the EP, hazardous substances exceeding the TCLP limits would also be a hazardous waste under the

19

NREPA Part 111 Rules. To comply with those requirements contained in the NREPA Part 111 and its Rules, the water would be managed as a hazardous waste.

The spent carbon from the air or water adsorption systems could potentially be a characteristically hazardous waste. The spent carbon would be tested to determine if it would be a hazardous waste. The generator and transportation requirements of NREPA Part 111 will be followed and this alternative, therefore, will be in compliance with ARARs.

The soil and groundwater treatment systems will comply with NREPA Part 35 (Air Pollution) requirements. Best Available Current Technology (BACT) requires treatment of the air emissions from the air stripper system. These requirements are satisfied through the use of a vapor phase activated carbon system to remove VOCs from the air stream.

2. Location-Specific

N/A

3. Action-Specific

NREPA Part 90 regulates erosion and sediment control measures during construction. The selected alternative will comply with these requirements during construction of the treatment systems.

The Michigan Vehicle Code, 1994 P. A. 300, as amended, Mich. Comp. Laws, § 257.1 et seq. requires a lower maximum axle load on some highways during March, April, and May to prevent roadway damage. Depending on the weight of the spent carbon units, special routes or scheduling around these months may be needed to allow unit replacement.

C. Cost Effectiveness

A cost-effective remedy is one for which the cost is proportional to the remedy's overall effectiveness. The summarized costs associated with the implementation of the selected groundwater and soil alternatives can be found in Section V.

The selected soil remedy for the Wade Electric source area includes no action for the PAH-contaminated soil. The selected remedy for the Wade source area also includes no action for the VOC-contaminated soil.. As the selected soil remedy for the Wade site is no action at no cost, it is more cost effective than the previous ROD remedy.

20

The selected soil remedy for the Kirsch source area includes no action for the PAH-contaminated soil.. As the selected PAH-contaminated soil remedy for the Kirsch source area is no action at no cost, it is more cost effective than the previous ROD remedy.

The selected VOC-contaminated soil remedy for the Kirsch source area and the selected groundwater remedy for the site are the same as in the previous ROD remedy; therefore, the cost effectiveness is similar except that the soil and groundwater cleanup criteria are less stringent under the selected amended remedy and can perhaps achieve cleanup in a shorter time period and, therefore, at a lower cost.

D. Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the Maximum Extent Practicable

U.S. EPA, with the State of Michigan's concurrence, has determined that the selected remedy meets the statutory requirement to utilize permanent solutions and alternative treatment technologies to the maximum extent practicable for the Sturgis Municipal Well Field site. Of the alternatives that are protective of human health and the environment and comply with ARARs, U.S. EPA has determined that the selected remedies for addressing soil and groundwater contamination provide the best balance of tradeoffs in terms of long-term effectiveness and permanence, reduction of TMV through treatment, short-term effectiveness, implementability, cost and state and community acceptance.

The selected remedy represents the maximum extent to which permanent solutions and treatment can be practicably utilized for this action. The principal threat present in the Kirsch source area soils will be treated through ISVE of VOCs. Groundwater contamination, which represents the principal source of site risk, will be actively remediated to restore the resource to its beneficial use. Institutional controls will be used during remediation to mitigate the risks posed by use of contaminated groundwater and exposure to contaminated soils.

E. Preference for Treatment as a Principal Element

The selected remedy uses treatment as a principal element. The groundwater remedy will utilize air stripping and/or liquid phase carbon to remove contaminants from the groundwater. Although air stripping and liquid phase carbon only transfer contaminants from groundwater to their filter media (and thus do not reduce TMV), the regeneration of the filter carbon used in the processes would reduce the TMV through treatment.

The soil remedy utilizes ISVE to remove volatile contamination from the Kirsch source area soils. Regeneration of the filter media used for the ISVE will reduce TMV through treatment.

21

Vm. DOCUMENTATION OF SIGNIFICANT CHANGES

U.S. EPA did not receive any written comments during the public comment period. Therefore, U.S. EPA determined that no significant changes to the remedy, as it was originally identified in the Proposed Plan for the amended remedy, were necessary.

RESPONSIVENESS SUMMARY

This Responsiveness Summary has been prepared to meet the requirements of Sections 113(k)(2)(B)(iv) and 117(b) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986, which requires the United States Environmental Protection Agency (U.S. EPA) to respond"... to each of the significant comments, criticisms, and new data submitted in written or oral presentations" on a proposed plan for remedial action. The Responsiveness Summary addresses concerns expressed by the public and potentially responsible parties (PRPs) in the written and oral comments received by the U.S. EPA and the State regarding the proposed remedy for the Sturgis Municipal Well Field Site.

PUBLIC COMMENT PERIOD/COMMUNITY INVOLVEMENT

A public comment period was held from July 10, 1996 to August 9, 1996 to allow interested parties to comment on the Proposed Plan in accordance with Section 117 of CERCLA. In the Proposed Plan, the U.S. EPA offered to hold a public meeting to explain the Record of Decision (ROD) Amendment if there was any public interest. U.S. EPA received no indication that there was any public interest in a public meeting, therefore, none was held.

Public interest regarding the Site since the original ROD was signed has been minimal. During the 30-day public comment period, U.S. EPA received no written or oral comments concerning the Proposed Plan. Therefore, no comments are documented in this Responsiveness Summary and no significant changes to the remedy, as it was originally identified in the Proposed Plan for the amended remedy, were necessary.

22

AR U.S. EPA ADMINISTRATIVE RECORD

REMEDIAL ACTION STURBIS MUNICIPAL WELL FIELD

STURGIS, MICHIGAN UPDATE #3 07/08/96

DOC» DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PABES

1 06/19/96 Herrill, D., Padovani, S,, U.S. Henorandum re: Sturqie Well Field Risk 4 Bradient Corporation EPA; et al. ABsessient

U.S. EPA ADMINISTRATIVE RECORD REMEDIAL ACTION

STURGIS MUNICIPAL WELL FIELD STURGIS, MICHIGAN

UPDATE #2 04/29/96

AR

DOCI DftTE AUTHOR ==== sss: ssssrs

RECIPIENT rssssssss

TITLE/DESCRIPTION PAGES

1 08/00/94 R.E. Nright Associates, Inc.

U.S. EPA Operation and Haintenance Manual for the GroundHater Reiediation Systei: Voluie 1 of 2 (Text, Figures, and Tables)

94

2 08/00/94 R.E. Nright U.S. EPA Associates, Inc.

Operation and Haintenance Manual for the 1292 Grounduater Reiediation Systee: Volute 2 of 2 (Equipient Manuals)

3 08/00/94 Snell Environiental MDNR/U.S. EPA Group, Inc.

Reiedial Design Nork Plan 243

4 03/24/95 Gradient Corporation Cooper Industries/ U.S. EPA

Modification to Air Stripping Report for the Cooper Industries-kirsch Site

11&


Pilot Soil Vapor Extraction Test Report 78

i 04/00/95 Snell Environiental MDNR/U.S. EPA Group, Inc.

Reiedial Design Geoprobe Soil Investigation Hork Plan

ISB


Task 2: Reiedial Design Soil Investigation Technical Meiorandui

257

B 06/00/95 Snell Environiental MDNR/U.S. EPA Group, Inc.

Task 8: Deep Aquifer Reiedial Investigation Technical Meiorandui

144

9 06/09/95 Hydro-Search, Inc. Cooper Industries/ U.S. EPA

Sturgis Municipal Hell Field Interii Ground Hater Extraction and Treatient Systei Construction Cupletion Report i/Attachients and March 5, 1996 U.S. EPA Approval Letter

36


Task 2t Reiedial Design Geoprobe Soil Investigation Technical Meiorandui

214

i

I ,fHB PAGES DATE TITLE

ADHIHISTRATIVE RECORD IMOEX UPDATE IKI

STURGIS WELL FIELD SITE STURGIS, HICHIGAN

AUTHOR RECIPIENT DOCUHEHT TYPE DOCHUHBER

'BOTH RAW AND VAUDATED DATA CAN BE MADE AVAILABLE THROUGH THE U.S. EPA AND THE MICHIGAN DEPARTMENT OF NATURAL RESOURCES (MDNR). INTERESTED PARVES SHOULD CONTACT MS. TERESE VANDONSEL OF THE U.S. EPA AT (312) 333-6364 OR MR. ROB FRANKS OF MDNR AT (317) 333-3392-

91/06/12 Letter re; Sturgle Fomlry Corporation'a options to remedial action plan (Attached EP Toxicity and TLCP results)

91/06/19 Letter re: Thank you for 30 day extension to conment on Feasibility Study Reports and request for meeting

Ol/Of/I/ Letter re; Cooperation of USEPA with Kirsch Division of Cooper Industries and their concerns about coBfileteness of RI/FS

91/07/17 Letter re: Installation of fence at Kirsch Plant No. 1 and enclosed diagram

91/07/23 Letter re: Copy of Michigan Risk Assessment Guidelines

91/07/24

91/07/25

Frank J. Kalasky, Sturgla Foundry Corp.

T. VarOonsel, USEPA Correspondence

Robert W. Teets, Cooper Industries

Paul Wartner, State Senator, State of Michigan

Nelson M. Olavarria, Cooper Industries

Terese A. VanOonsel, USEPA

Letter re: Clarification Robert W.,Teets, concerning data or Cooper In^tries docunents available in the acbiinistrative record for Sturgis Well Field

Letter re; Copy of Appendix A and Appendix D of the Quality Assurance Project Plan dated August 1987

Terese A. VanOonsel, USEPA

T. VanOonsel, USEPA Correspondence


T. VerOonsel, USEPA Correspondence

R. Perod, Gradient Correspondence Corp.


Jl

R. Perod, Gradient Correspondence Corp.

91/07/30 Letter re; Request Nelson M. Olavarria, T. VanOonsel, USEPA Correspondence

age No. 9/19/91

ICHE/FRAHE PAGES DATE TITLE

ADHIHISTRATIVE RECORD INDEX UPDATE «l

STURGIS UELL FIELD SITE STURGIS, MICHIGAN

AUTHOR RECIPIENT DOCUHENT TYPE DOCHUHBER

1 91/08/01

5 91/08/01

6 91/08/05

1 91/08/12

18 91/08/12

2 91/08/12

25 91/08/12

3 91/09/05

for hydroseologlcal information

Letter re; Thank you for affording Gradient Corp. the opportwlty to review CLP data

Letter re: Status of data request made by Cooper Industries

Letter re: Additional deficiencies to Uarzyn RI/FS docunent

Letter re: City of Sturgis appreciates efforts of EPA and HOHR to obtain clean-up of water contamination

Letter re: Enclosed copy of sunaary of the trichloroethylene end tetraehloroethylene toxicological literature for Inclusion to adiinistrative comaents

Cooper Industries

Ralph J. Pared, Gradient Corporation

Teresa A. Vatfionsel, USEPA

Christopher L. Smith, Cooper Industries

John Brand, City of Sturgis

Hark E. Hulhollam, Gray, Plant, Hooty, Hooty, & Bennett, Attorneys for Cooper Industries, Inc.

Letter re: Kirsch Glenn Oxender, State Division of Cooper Representative, State Industries concerns about of Michigan completeness of RI/FS

Letter re: USEPA making most of the records requested available and "FOIA" request for additional docunents (attached FOIA requests)

Letter re: Response to letter dated August 26, 1991 referencing a telephone conversation regarding Cooper Industries request to meet with the USEPA '


T. VanDonsel, USEPA Correspondence

R.Teets, Cobperlndustries

Correspondence ID

N.Hyde, G.P.N.M.t B. Correspondence 11

T. VOnDonsel, USEPA Correspondence 12

T. VanDonsel, USEPA Correspondence . 13

T. ifaiioonsel, USEPA Correspondence H

T. VanDonsel, USEPA Correspondence .15

Mary HcAuliffe, USEPA H. Hyde, G.P.H.H.B. Correspondence 16

. v-i.

0. 3 91

FRAME PAGES DATE TITLE

AOHINISTRATIVE RECORD INDEX UPDATE «1

STURGIS WELL FIELD SITE STURGIS, MICHIGAN

AUTHOR RECIPIENT DOCUMENT TYPE «

DOCHUMBER

74 91/09/12 Letter re: Cooper's concerns about denial of meeting with USEPA and the remedial investigation


T. VarDonsel, USEPA Correspondence 17

2 91/08/30

24 00/00/00

275 00/00/00

37 89/12/13

43 91/06/20

News Article Entitled: Cooper presents city well cleanup plan

Robin Johnson, Sturgis Journal

Newspaper Article 18

Cooper Industries, Inc.'s Cooper Industries, Inc. Comnent in Regard to USEPA/HONR Identification of Potentially Responsible Parties

Cooper Industries, Inc.'s Cooper Industries, Inc. Connents on the Remedial Investigation/Feasibility Study with attached CERCLA Coapliance with Other Laws Manual)

USEPA, MDNR Other 19

USEPA and MDNR Other

Letter re: Enclosed response of Cooper Industries, on behalf of Kirsch, to Information Request letter dated Novendber 7, 1989

Transcript of Public Hearing in the matter of Sturgis Miaiicipal Uell Field Superfund Site

Uillette A. Lemelle, Cooper Industries

G. Watts, USEPA

Other

m.:

22

1160 91/08/07 Letter re: Literature review of Effectiveness of Puip and Treat Remedy to Attain ARARs (Attached copies of all publications referenced in letter and additional pertinent articles listed in the bibliography)

Hark J. Simonett, Gray, Plant, Moody, Moody & Bennett, Attorneys for Cooper Industries

N. Olavarria, Cooper Other Ind.

23

Page No. 4 09/19/91

ADHINISTRATIVE RECORD INDEX UPDATE #1

STURGIS WELL FIELD SITE STURGIS, HICHIGAH

FICHE/FRAHE PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUHBER

97 90/12/03

869 91/08/00

Draft, State of Michigan Risk Assessment Guidelines

Critique of Warzyn's Baseline Risk Assessment for the Sturgis Well Field Superfund Site and attached referenced doctiaents

Council on Enviromental Quality Comnittee on Risk Assessment

Gradient Corporation

Reports/Studies 24

Attorneys for Cooper Reports/Studies 23 Ind.

158 91/08/09 Letter re: Nearby municipalities which consune treated contaminated groundwater (Attached Record of Decision, Selected Remedial Alternative, West XL Avenue Landfill site)

Christopher L. Smith Cooper Industries

M. Hyde, G.P.H.H.& Reports/Studies B.

26

30 91/08/09

321 91/08/09

Report Entitled: Alternative Ground-Water Remediation Concept, Sturgis Well Field, Sturgis, Michigan

Review Comnents, Sturgis Well Field Remedial Investigation/ Feasibility Study

Hydro-Search, Inc. Attorneys for Cooper Reports/Studies Ind.

27

Hydro-Search Inc. USEPA Reports/Studies 28

52 91/08/U Letter re: Copies of the Alternative Remediation Concept, Review Cooments for Remedial Investigation/ Feasibility Study and Curriculum Vitae for the professional staff at Hydro-Search, Inc.

Maclay R. Hyde, Gray, Plant, Moody, Moody S Bennett, P.A. Attorneys for Cooper Industries, Inc.

T. VarOonsel, USEPA Reports/Studies 29

•3 -..-J. "S.-i:.

Page Mo. 09/19/91

TITLE

GUIDANCE DOCUMENTS INDEX, UPDATE #1 STURGIS UELL FIELD SITE, STURGIS, MICHIGAN

Guidance Docunents are available for review at USEPA Region V-Chicago IL

AUTHOR DATE

Connunity Relations in Superfund: A Handbook (Interim Guidance)

Guidance for Conducting Remedial Investigations and Feasibility Studies (RI/FS) Under CERCLA

Policy for Superfund Compliance with the RCRA Land Disposal Restrictions

Superfund LOR Guide #1; Overview of RCRA Land Disposal Restrictions (LDRs)

USEPA

USEPA

RCRA/HSWA

RCRA/HSUA

88/06/0D

88/10/D0

89/04/17

89/07/00

The Feasibility Study: Development and Screening of Remedial Action Alternatives

A Guide to Developing Superfund Proposed Plans

Risk Assessment Guidance for Superfund, Volume I: Hunan Health Evaluation Manual, Part A

Basics of Punp and Treat Ground Water Remediation Technology

USEPA

USEPA

USEPA

USEPA

89/11/00

89/11/00

89/12/00

90/09/00

Page No. 1 09/19/91

•• ••• •• '••W •• ••' 'f

ACRONYH

ARARS

EP FS

GPNKB

HDNR

QAPP

RI

RI/FS

TCLP

USEPA

ACRONYM GUIDE for the Adninistrative Record Update «1

Sturgis Well Field Site Sturgis, Michigan

DEFINITION

Applicable or Relevant and Appropriate Standards, Liini tat ions. Criteria, and Requirements Extraction Procedures Feasibility Study

Gray, Plant, Moody, Moody & Bennett Michigan Department of Natural Resources Quality Assurance Project Plan Remedial Investigation

Remedial Investigation /Feasibility Study Toxicity Characteristic Leachate Procedure United States Environmental Protection Agency

Page No. 1

06/05/91

FICHE/FRAHE PAGES DATE

• M;

AOHINISTRATIVE RECORD INDEX

STURCIS WELL FIELD SITE STURGIS, MICHIGAN

TITLE AUTHOR RECIPIENT DOOJHEHT TYPE DOCHUHBER

91/04/30

130 91/05/20

James S. Linton, HichiBan N. Tyson, USEPA Department of Natural

Resources

Letter re: Belief that Sturgis Well should be cleaned up to Michigan . Environmental Reponse Act Type B levels for both ground water and source area soil contamination

Copies of Act 307 and Michigan Department of

the Adninistrative Rules Natural Resources

to Act 307 (with cover

letter)

Correspondence

T. Van Oonsel, USEPA Pleadings/Orders 2

1 87/08/19 Sturgis Groundwater

Study to Be Discussed at Public Meeting

Public Notice

1 88/04/20 Notice, Public Meeting Sturgis Groundwater Study

44 00/00/00 City of Sturgis - Gove Associates Preliminary Investigation of Trichloroethylene Contamination

Public Notice 4

Reports/Studies 5

6 00/00/00

4 87/04/25

64 87/07/00

Cconunity Relations Plan

Progress Report #1,

City of Sturgis,

Ground Water Contamination Study

Michigan Department

of Natural Resources

Final Work Plan, Uarzyn Engineering, Inc. MDNR

Remedial Investigation/ Feasibility Study

Reports/Studies 6

Reports/Studies 7

Reports/Studies 8

12 87/07/31 Health and Safety Plan, Warzyn Engineering, Inc. MDNR

Remedial Investigative

Activities

Reports/Studies 9

199 87/08/00 Final OAPP, Remedial Uarzyn Engineering, Inc. MDNR Investigation/ Feasibility Study

Reports/Studies 10

247 88/02/00 Phase 1 Technical Warzyn Engineering, Inc. MDNR Reports/Studies 11

RAHE PAGES DATE

ADHINtSTRATIVE RECORD INDEX STURGIS WELL FIELD SITE

STURGIS, MICHIGAN

TITLE

HemoranduB, Sturgis Well Field RI/FS

AUTHOR RECIPIENT DOCUMENT TYPE DOCNUHBER

3 88/04/08 Progress Report #Z Sturgis Municipal Uellfield Si^rfund Site

Michigan Department of Natural Resources

Reports/Studies 12

131 88/05/00

24 88/05/00

9 88/07/18

Phase II QAPP,

Revision 1, Reawlial

tnvestigation/Feasiblity

Study

Phase II Work Plan, Revision 1,

Remedial Investigation/ Feasiblity Study

Cover letter with

attached Health ~

Safety Plan Addendun,

Remedial Investigative

Activities

Uarzyn Engineering, Inc. MDNR


Kenneth J. Quinn, S. Luzkou, MDNR

Uarzyn Engineering, Inc.

Reports/Studies 13

Reports/Studies 14

Reports/Studies 15

36 89/03/00

11 89/03/10

19 89/04/00

5 89/04/05

228 89/05/00

86 90/02/00

22 90/09/12

Phase I IB Work Plans, RI/FS

Preliminary Health

Assessment

Work Plan Addendun,

Feasbility Study

Progress Report <13

Sturgis Municipal

Uellfield Site


Center for Environmental ATSOR

Health Services (CEHS),

Michigan Department

of Public Health (MDPH)


Michigan Defiartment

of Natural Resources

Preliminary Findings and Uarzyn Engineering, Inc. MDNR Interpretations, Phase II Technical Memorandun, Sturgis Uell Field RI/FS

Phase MB Technical Memorandun, RI/FS


Quality Assurance Terese Van DenseI, Project Plan, Addendun USEPA

USEPA, MDNR

Reports/Studies

Reports/Studies

Reports/Studies

Reports/Studies

Reports/Studies

Reports/Studies

16

17

18

19

Reports/Studies 20

21

22

Page Ho. 3 06/05/91

FICHE/FRflHE PAGES DATE

•: -.'A-'

TfTLE

ADMINISTRATIVE RECORD INDEX STURGIS UELL FIELD SITE

STURGIS, MICHIGAN

AUTHOR RECIPIENT DOCUMENT TYPE DOCHUMBER

248 91/D3/00

42 91/03/00

Remedial Investigation Report, Remedial Investigation/ Feasibility Study

Volune I of 5

Remedial Investigation

Report, Reaiedial

Investigation/

Feasibility Study

Volune 2 of S

Uarzyn Engineering, Inc. HDNR

Uartyn Engineering, Inc. HDNR

Reports/Studies 23

Reports/Studies 24

364 91/03/00 Remedial Investigation

Report, Remedial

Investigation/

Feasiblity study

Volune 3 of 5

Uarzyn Engineering, Inc. HDNR Reports/Studies 25

295 91/03/00

165 91/03/00

189 91/05/00

Remedial Investigation Uarzyn Engineering, Inc. HOUR Report, Remedial

Investigation/

Feasibility Study Volune 4 of 5

Remedial Investigation Uarzyn Engineering, Inc. HDNR Report, Remedial

Investigation/

Feasiblity Study

Volune 5 of 5

Feasibility Study,

Sturgis Uell Field, Volune 1

Uarzyn Engineering, Inc HDNR

Reports/Studies 26

^ Reports/Studies 27

Reports/Studies 28

179 91/05/00 Feasibility Study,

Sturgis Uell Field,

Volune 2

Uarzyn Engineering, Inc. HDNR Reports/Studies 29

Paqe No.

06/0S/91

GUIDANCE DOCUMENTS INDEX STUHGIS WELL FIELD SITE, STURGIS, MICHIGAN

Guidance Oocunents are available for review at USEPA Region V-Chicago IL

TITLE AUTHOR DATE

Risk Assessment Guidance for Superfund, Volime I: Hunan Health Evaluation Manual, Part A

USEPA 89/12/00

Basics of Puip and Treat Ground Water Remediation Technology

USEPA 90/09/00

Connuiity Relations in

Superfund: A Handbook (Interim Guidance)

USEPA 88/06/00

The feasibility Study:

Development and Screening of Remedial Action

Alternatives

USEPA 89/11/00

A Guide to Developing Superfund Proposed Plans

USEPA 89/11/00

Policy for Superfund CoiiRiliance with the RCRA Land Disposal Restrictions

RCRA/HSUA 89/04/17

Superfund LDR Guide

#1: Overview of RCRA

Land Disposal

Restrictions (LDRs)

RCRA/HSUA 89/07/00

Page No. 1 06/05/91

ACRONYM DEFINITION

ACRONYM GUIDE for the Administrative Record Sturgis Uell Field Site

Sturgis, Michigan

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ATSOR

CEHS

FS

KDNR

HOPH

OAPP

RI

RI/FS

USEPA

Agency for Toxic Substances and Disease Registry Center for Environmental Health Services Feasibility Study

Michigan Department of Natural Resources Michigan Department of Public Health Quality Assurance Project Plan Remedial Investigation

Remedial Investigation /Feasibility Study United States Environmental Protection Agency

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^EPA United States Region 5 Illinois, Indiana Environmental Protection 77 West Jackson Boulevard Michigan, Minnesota Agency Chicago, Illinois 60604 Ohio, Wisconsin

U.S. EPA Invites the Public to a I

Listening Session Reference the Armco Superfund Site (aka AK Steel)

November XX, 2002 New Miami, Butler County, Ohio November 2002

iGeneral Information? T

:;:tf ^5u have,questions about this site or would like to added to the mailing list,, .

Robert-Paulson •. • • Community Involvement'!;'

(312) 886-02727 (800)^21-8431. Paulson [email protected]

•PabloValentin •- •,!, ;,7 • Remedial Project Manager " • (312) 353-2886 / (800)'621-8431 Valentin pablo(5)epa.aov'

•• •Of :th|S;f actbi^ . other information can be ' ' •

""found in the site information t l^patory: • f'; 7-

Lane Public Library,;' -;'; -300 North.y^^ Street' -,,

Hamilton, Ohio 40511

or on the EPA Region'5 Web,

i h ttp: //vAvvv lepa .'abv/reai o n 5/si les y;.

U.S. Environmental Protection Agency (EPA) invites the public to a listening session Nov. XX, 2002, from X a.m. to X a.m. and X p.m. to X p.m., in the xxxxxxxxxxxxxxxx, xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxx Street, Hamilton, Ohio.

The session agenda is:

Opening - Bob Paulson, U.S. EPA Superfund 101 - Dave^fevak, U.S. EPA

, Site History - Pablo Valentin, U.S. EPA " " ! Nita Nofstiiiin, Ohio EPA . Site Present & Future - Pablo Valentin . Questions & Answers - EPA team Closing - Bob Paulson

Procedures for the Questions & Answers are 1. Each person can ask one question with one follow-up 2. Questions must be asked within 3 minutes

Rules for the EPA team: All comments will be acknowledged. All questions will be answered. , Public session will begin and end on time.

How does Superfund work?

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or "superfund") provides for a federal "Superfund". EPA has the primary responsibility to manage the cleanup and enforcement activities under Superfund. A comprehensive regulation known as the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) contains the guidelines and procedures for implementing the Superfund program.

The first step in the Superfund program is to identify abandoned or uncontrolled hazardous waste sites. EPA does this through a variety of methods, including reviewing records and information on hazardous substance disposal and storage provided by States, handlers of hazardous materials and concerned citizens. The NCP requires facility owners or operators to reportj releases exceeding the reportable quantity (RQ) of hazardous substances to the National Response Center. This center is continuously staffed and acts as the single point of contact for all pollution incident reporting.

Once an abandoned or imcontrolled hazardous waste site is identified, information regarding the site is entered into a data base known as CERCLIS, the Comprehensive Environmental Response, Compensation, and Liability Information System. CERCLIS maintains a permanent record of all information regarding all reported potential hazardous waste sites.

After discovery or notification of a site or incident EPA or the State conducts a preliminary assessment (PA) to decide if the site poses a potential treat to human health

and the environment. If the site presents a serious imminent threat, EPA may take an emergency "removal" action. If the PA shows that a contamination problem exists but does not pose an imminent threat, or if the site continues to pose a problem following EPA actions, EPA may proceed to the next step of the evaluation process, and conduct a site inspection (SI). If at any point during the assessment and inspection process the site is determined to not present a potential threat, the site can be eliminated from further CERCLA consideration with a decision that the site evaluation is accomplished (SEA).

From the beginning of the Superfund process, EPA makes every effort to identify the primary responsible parties (PRPs) for the hazard and encourage them to respond. If efforts to ensure responsible party response do not lead to prompt action, EPA may act using Trust Fund monies.

Every Superfund site is unique, and thus cleanups must be tailored to the specific needs of each site or hazardous substance release. EPA may respond with enforcement or Trust Fimd-financed removal actions or remedial actions, collectively known as response actions.

Removal Actions are usually short-term actions designed to stabilize or clean up a hazardous site that poses an immediate threat to human health and the environment. Also, removal actions are conducted in response to accidental releases of hazardous substances. Typical removal actions include removing, tanks or drums of hazardous substances or the surface, installing security measures such as a fence as a site, or

providing a temporary alternate source of drinking water to local residents.

Remedial Actions are generally longer-term and usually more costly actions aimed at a permanent remedy. EPA may use Trust Funds monies for remedial construction only at sites on the National Priorities List (NPL).. The NPL is EPA's list of the nation's priority hazardous waste sites. Typical remedial actions may include removing buried drums from the site; thermally treating wastes; pumping and treating ground water; and applying bioremediation techniques or other innovative technologies to contaminated soil.

Enforcement Actions to obtain voluntary settlement, or if necessary, to compel PRPs may be taken to implement removal or remedial actions. Once the PRP has agreed to take response actions as a site, the enforcement program ensures that the studies or cleanup activities are preformed correctly and in accordance with the order or decree, the statute, the NOP, and relevant guidance.

The PRPs may include the owners and operators, generators, transporters, and disposers of the hazardous substances. If sufficient evidence is present to show that PRPs are liable and the PRPs are financially viable (i.e. not bankrupt), they are generally given te opportunity to make a voluntary, good faith effort to settle and take responsive actions. Alternatively, EPA may issue orders directing them to conduct the response, or take court action to secure the necessary response.

CERCLA also authorizes the use of Trust Fund money for response actions and

provides the authority necessary to seek repayment from PRPs. EPA generally uses Trust Fund money to respond it: (1) PRPs have not been identified or are not financially viable; (2) litigation against a PRP is pending; (3) insufficient evidence has been collected linking a PRP to the waste; or (4) the threat is substantial and imminent enough to warrant immediate action. Where a PRP refuses to comply with an order, and EPA uses Trust Fund monies to preform the ordered work, EPA may recover triple the costs.

Criminal statutes also support CERCLA's enforcement tools. There are criminal penalties for failure to notify proper authorities of releases exceeding an RO. Submitting false information about sites or releases are also criminal offenses.

How can I get involved in this cleanup?

To ensure the local public is involved in this cleanup, the EPA team will developed a community involvement plan (CIP). This plan is designed to inform local officials, residents, and media about conditions and developments at the Armco Superfund Site (aka AK Steel) and to make sure that the -community's concerns are communicated to EPA and State of Ohio officials. This plan will describe the activities that will be conducted to encourage citizen input and inform the community of Site progress. CIP activities may include holding periodic meetings or sessions, producing information or fact sheets highlighting various aspects of this Site and maintaining an Information Repository (IR). The IR is located in the

Lane Public Library 300 North 3^" Street Hamilton, Ohio

Do you want to be on this site's mailing list? If so, please full out the following and either hand it to a member of the EPA team, drop it in the box provided or mail to the address on page one. Please print. I thank you for your interest.

'Ro&ent "Piudtim

Name Address Telephone Number ( ) -Environmental Group Affiliation Main Concern

This area is provided for note taking.

united states environmental protection agency · 2021. 2. 8. · -rpa)j ^ /stof united states...

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