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Proposed Plan for Operable Unit 1 at the Velsicol Burn

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Proposed Plan for Operable Unit 1 at the Velsicol Burn US EPA RECORDS CENTER REGION 5 476647 VELSICOL BURN PIT SUPERFUND SITE PROPOSED PLAN FOR OPERABLE UNIT 1 ST. LOUIS, MICHIGAN Community Participation This Proposed Plan identifies the Preferred Alternative for addressing contaminated soil The EPA and MDEQ provide information and groundwater at Operable Unit 1 (source regarding the cleanup of the Velsicol Burn Pit material) at the Velsicol Burn Pit in St. Louis, Superfund site through public meetings, the Michigan (VBP or site) and provides the Administrative Record for the site, and rationale for this preference. In addition, this announcements published in the Morning Sun. Proposed Plan includes summaries of other The EPA and MDEQ encourage the public to gain a more comprehensive understanding of cleanup alternatives evaluated for use at this the site and the Superfund activities that have site. This document is issued by the United been conducted at the site. Additional States Environmental Protection Agency information can also be found at the EPA (EPA), in conjunction with the Michigan Regions 5's web site located at Department of Environmental Quality http://www.epa.gov/region5/cleanup/velsicolbur npit/. A citizens group called the Pine River (MDEQ). The MDEQ was the lead Agency for Superfund Citizen Task Force also has a web the initial Remedial Investigation (Rl) and the page containing a large amount of site EPA has been the lead agency for the Rl information and it can be located at addendum and Focused Feasibility Study www.pinerivercag.org. (FFS) and will be the lead Agency for the The Administrative Record, which contains the Proposed Plan, Record of Decision, Remedial information used to develop the site remedy, is Design, and Remedial Action. The EPA, with at the following location: input from the MDEQ, will select the final Public Library remedy for the site after reviewing and T.A. Cutler Memorial Library considering all information submitted during 312 Michigan Avenue the pubhc comment period. The public St. Louis, MI comment period will run 30 calendar days The public comment period will run for a pursuant to Section 300.430 (f)(3)(i) of the from November 24, 2014 to January 2,2015 National Oil and Hazardous Substances and the EPA will be accepting comments on the Proposed Plan during the public comment Pollution Contingency Plan (NCP), 40 C.F.R. § period. Written comments can be sent to the 300.430(f) (3) (i). The public comment period following address: will begin on November 24,2014 and end on Jena Sleboda Braun January 2,2015. The EPA, in consultation with Remedial Project Manager MDEQ, may modify the Preferred Alternative United States Environmental Protection Agency or select another response action presented in Mail Code SR-6I 77 W. Jackson Blvd. Chicago, IL 60604 this Proposed Plan based on new information slebodaj [email protected] or public comments. A public meeting will be held on December 3, 2014 to discuss all the alternatives and the The EPA is issuing this Proposed Plan to fulfill preferred remedial alternative. Written and oral comments will be accepted at the meeting. The its obligations under the Comprehensive meeting will be held at the following time and Environmental Response, Compensation, and location: Liability Act (CERCLA) Section 117(a), 42 December 3,2014 U.S.C. § 9617(a), and as part of its pubhc 6:30 PM to 9:00 PM participation responsibilities under NCP T. S. Nurnberger Middle School Section 300.430(f)(2), 40 C.F.R. § 300.430(f)(2). 312 Union St., St. Louis, MI This Proposed Plan summarizes information that can be found in greater detail in the Rl, Rl Addendum, FFS reports, and other documents contained in the Administrative Record file for this site. The Administrative Record is located at the T. A. Cutler Memorial Library, 312 Michigan Avenue, St. Louis, Michigan and at the EPA Region 5 Records Center, 77 West Jackson Boulevard, Chicago, Illinois. The library hours of operation are Monday, Tuesday, and Thursday from 10:00 AM to 7:00 PM, Wednesday and Friday from 10:00 AM to 5:00 PM, and Saturday from 10:00 AM to 2:00 PM. The library is closed on Sunday. The EPA and MDEQ encourage the public to review these documents to gain a more comprehensive understanding of the site and Superfund activities that have been conducted at the site. Five remedial alternatives were evaluated for the Velsicol Burn Pit Site in the Focused Feasibility Study (FSS). They include the No Action Alternative, Soil Containment and Capping, In Situ Stabilization and Soil Cover, In Situ Thermal Treatment and Soil Cover, and Hot Spot Excavation and Disposal. For the reasons explained below, the EPA's preferred alternative for the site is Alternative 4: In Situ Thermal Treatment and Soil Cover. I. SITE BACKGROUND From 1978 through 1983 and before inclusion of the site on the National Priorities List (NPL), a preliminary assessment, site inspection, and site characterization investigation were performed by the EPA and MDEQ. In response to investigation findings and in fuhillment of a 1982 Consent Judgment remedy, approximately 68,000 cubic yards of contaminated material was removed from the VBP, transferred to the Former Plant Site (FPS), and placed for disposal beneath a compacted clay cap. From 2004 to 2006, the MDEQ continued characterization work at the VBP to evaluate the presence of residual contamination related to historical waste disposal. Initially, the MDEQ advanced 10 hydraulic direct-push (HDP) borings to the regional till unit beneath the VBP and adjacent area. The MDEQ collected soil and groundwater samples from the HDP borings. The soil and groundwater data confirmed the presence of contaminants, including volatile organic compounds (VOCs), semivolatile organic compounds, pesticides, inorganic compounds, and para chlorobenzene sulfonic acid (pCBSA). Subsequently, the MDEQ installed 5 additional HDP borings, 13 shallow monitoring wells, 6 intermediate monitoring weUs, and 4 deep monitoring wells to complete the initial phase of the investigation. The MDEQ groundwater sampling results from temporary wells at boring locations BA-2 and BA-10 revealed the presence of non-aqueous phase liquid (NAPL); the MDEQ subsequently installed permanent monitoring well clusters at these locations (Rl Addendum Report, CH2M HILL 2013). In 2009, the MDEQ conducted an additional site investigation at the VBP that identified contaminated soil and groundwater within the shallow unit including VOCs, semivolatile organic compounds, pesticides, polybrominated biphenyls, pCBSA, and inorganic compounds. Chemicals were detected at concentrations exceeding one or more of the MDEQ's Part 201 generic criteria in the shallow unit. As concluded in the 2009 Rl addendum report (Weston Solutions of Michigan, Inc. 2009), however, VOCs are the predominant compounds present beneath the VBP in terms of the frequency detected and the observed concentration. The investigation also confirmed the presence of NAPL in monitoring wells BA-2S and BA- 10S. Light and dense NAPL are present at the VBP. The light NAPL is primarily comprised of benzene, and the dense NAPL is primarily comprised of 1,2-dichloroethane (1,2-DCA). However, both light and dense NAPL also contained l,2-dibromo-3-chloropropane, dichlorobenzene, trichloroethylene, and trace amounts of other VOCs. The NAPL composition is consistent with chemicals identified in site soil and groundwater during historical site investigations that exceed the MDEQ's Part 201 standards. Collectively, the compounds and the specialty chemicals previously noted form the basis for identification of VBP contaminants of concern (COCs). In 2012, CH2M HILL, a contractor for the EPA, conducted additional site investigation activities at the VBP to eliminate data gaps and to further define the nature and extent of NAPL and COC impacts to soil and groundwater in the shallow unit underlying and downgradient of the VBP. These more recent site investigation findings are being used in conjunction with previous Rl findings to assess risks to human health and the environment, and to support the selection of a remedy that eliminates, reduces, or controls the risks. The 2012 Rl findings are detailed in the 2013 Rl addendum report (CH2M HILL 2013). A. Relationship between the Velsicol Burn Pit and the Former Plant Site The VBP is related to the Former Plant Site (FPS). The VBP was an offsite disposal area, operated by Velsicol Chemical Corporation (Velsicol), where industrial wastes were burned for volume reduction or other disposal purposes. During plant operation, solid and liquid waste from the FPS was burned at the VBP. In addition, solid waste from the City of St. Louis was also burned at this location. According to records, liquid waste was burned weekly in an open pit. The VBP was proposed for the National Priorities List (NPL) in the early 1980s. However, prior to final Hsting of the VBP, Velsicol excavated the VBP and disposed of the waste from the VBP at the FPS in accordance with a cleanup plan for the FPS required under the 1982 Consent Judgment. The MDEQ historically considered the VBP a part of the Velsicol Chemical Corporation Superfund Site (currently EPA ID#MID000722439). Previous Rl data for the VBP was published in the Rl report documents for the FPS (Remedial Investigation Report for Operable Unit One Velsicol Chemical Corporation Superfund Site, St. Louis, Gratiot County, Michigan [Weston Solutions of Michigan, Inc. 2006] and Remedial Investigation Addendum Report for Operable Unit One Velsicol Chemical Corporation Superfund Site, St. Louis, Gratiot County, Michigan [Weston Solutions of Michigan, Inc. 2009]). Because the VBP had been proposed for the National Priorities List previously, the EPA requested information pertaining to the VBP be removed from the draft FS. The VBP site was re-evaluated and EPA scored the VBP for final Usting on the National Priorities List as a separate site.
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