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Final Amended Remedial Design Project Plan

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Final Amended Remedial Design Project Plan - 941381 ...- FINAL AMENDED REMEDIAL DESIGN PROJECT PLAN VOLUME 1 DESIGN REPORT ANO SPECIFICATIONS PREPARED ON BEHALF OF THE BUTTERWORTH SITE GROUP PREPARED BY: RMT, INC. JUNE 1999 RM T, INC. 744 Hr~rn,1:10 TR~1t 53717-1934 P.O . Bo.< 8923 S3708-8913 M~DISOII, WI 608/ 83 1- 4444 608/ 831-3334 fAX ,, '-~ .... -May 28, 1999 Mr. Dion Novak Remedial Project Manager USEP A Region 5 77 West Jackson Boulevard Chicago,IL 60604-3590 RE: Butterworth Landfill Remedial Action Grand Rapids, Michigan Dear Dion, On behalf of the Butterworth Site Group (BSG), RMT, Inc., is submitting the attached responses to the USEPA's May 12, 1999, comments on the Amended Remedial Design Project Plan (Amended ROPP). It is the BSG' s understanding that these responses are acceptable to the agencies, as they were discussed orally with the you and the MDEQ during the meeting on J\Iay 26. We further understand that you are not planning to respond to tlus submittal in writing since your May 12 letter provided approval of the Amended RDPP Additionally, while your May 12 letter stated that responses were due by May 26, you approved the BSG' s request during the May 26 meeting to extend the due date to today. Please call either Phill Mazor, at 616-688-5777, or me if you have any questions. Sincerely, R:V1T, Inc. Linda E. Hicken, P.E. Senior Project Manager Attachment cc: Brian vonGunten, ~!DEQ BSG Technical Committee Donna Brunner, Tetra Tech EM Rav Mastrolonardo, Tetra Tech E~I Bhu pen Gandhi, Tetra Tech E~f RMT, INC. 744 HEA~TLANO TRAIL • 53717-1934 P.O. Box 8923 - 53708-8923 MADISON, WI 608/831-4444 - 608/831-3334 FAX /. I WPM SN\ P/T\ OO-a3938' 63 \ LDOOJ938/il-003DOC 05(28/]9 RESPONSES TO THE USEPA'S MAY 12, 1999, COI\.11\.fENTS CONCERNING THE ~IENDED RE1\.1EDIAL DESIGN PROJECT PLAN FOR THE Bu 11 ERWORTH LANDHLL, GRAND RAPIDS, MICHIGAN 1. Response to comment 11. Attachment 3 to Appendix A of the Soil Cover proposal presents engineering testing results for the imported soil. The comment was referring to any contaminant testing done on these soils that is typical when importing soil to a Superfund site, to ensure that the soil is contaminant free. Please provide this information to the Agencies. No contaminant testing has been performed on the material to be used for the soil cover because the source of the material is a greenfield. The soil will be imported from previously undeveloped land at the Waste Management, Inc., Autumn Hills Recycling and Disposal Facility near Zeeland, Michigan. This material was excavated from the area of the Autumn Hills facility where the landfill was constructed. The land use in this area was formerly agricultural. Prior to importing the proposed soil cover material from the Autumn Hills facility, the BSG will collect and analyze two samples of this material for the TCL and TAL parameters. 2. Response to comment 13. The condition to trigger increased monitoring should be revised to include comparing the pressure in the probe during a monitoring event with the pressure recorded immediately after completion of the cap. This method would more accurately account for LFG accumulation after the cap is installed, rather than from one sampling event to another, and would measure gas buildup under the cap over time as well. This method will also help the proposed monitoring probes provide accurate information on gas conditions at the site. As requested, the pressure recorded in a probe during a monitoring event will also be compared with the pressure recorded in that probe immediately after comple~on of the cap. 3. Response to comment 19. Specification 02230 should state that large clumps "will be" broken dawn rather than as stated II capable of being broken down." This eliminates pathways for vertical migration of water. The text in Specification 02230, Subpart 2.05 B, will be changed as requested. 4. Response to comment 20. The specifications for Folkertsma required the rock size to be 2 inches or less, not 6 inches as referenced here. The BSG acknowledges that the technical specifications for the Forkertsma Landfill call for a rock size of 2 inches. The increase to a maximum of 6 inches was approved by the MDEQ as a field modification. In addition to the other supporting information previously provided on this issue, the BSG notes that the Michigan Solid Waste Rules in effect when the ROD was signed do not address the size of the rocks that can be used. Moreover, the proposed material from the I: I WPMSN\ Pfrl 004J9J8\ 6J \ ZOOOJ9.3863-002.00C a5{.?~ Autumn Hills RDF has previously been approved by the MDEQ for similar use at other landfills in Michigan. 5. Response to comment 22. Ht:roe the specifications been revised to include the new seed mixtures as they are presented to the contractors? The BSG purchased the seed mixtures directly from the supplier to save contractor mark-up and to take advantage of a limited opportunity to purchase the seed before a significant price increase was expected to occur. The seed mixtures presented in Appendix C of the RA Work Plan were ordered. 6. Response to comment 28. Signage should also include signs that identify the site as a Superfund site. The signs will also identify the landfill as a Superfund site. 1: \WPMSN\PfT\OO-OJ9J8\ 63\ZOOOJ9J86.J.002.DOC Q$'24,'99 . ' - April 14, 1999 Mr. Dion Novak Remedial Project Manager USEPA Region V 77 West Jackson Boulevard Chicago, IL 60604-3590 RE: Response to Comments - Amended Remedial Design Project Plan Butterworth Landfill, Grand Rapids, Michigan Dear Dion: On behalf of the Butterworth Site Group (BSG), RMT has prepared the attached responses to the April 6, 1999, consolidated comments from the USEPA, the MDEQ, and Tetra Tech EM's review of the Amended Remedial Design Project Plan (ROPP). While we appreciate the timely response to this latest submittal of the design document for this Site, we were somewhat disappointed at what appears to have been limited consideration of the BSG's previous responses to agency review comments that were documented in the Pre-Final ROPP, the Final ROPP, and the Revised Final ROPP. Agency concerns involving the limits of capping, soil sampling, landfill gas (LFG) management, and the construction of the clay cap that are raised in the current comments were previously reviewed by the USEPA, the USEPA's oversight consultant at the time (E&E), and the MDEQ. These issues were resolved as part of the Pre-Final RDPP, which was approved by USEPA on July 13, 1997, and on September 16, 1997 (regarding LFG issues). Moreover, with the exception of details related to the soil cover to be constructed over the Radio Tower and Station Building (RTSB) Area, the concepts and components questioned by these comments were included in the Revised Final ROPP, which was approved by the USEPA. RMT, INC. 744 HEARTLAND TRAIL • 53717-1934 P.O. Sox 8923 - 53708-8923 MADISON, WI 608/831-4444 - ~08/831-3334 FAX -----------· .. --------- .. ... .. ---- ------ I \WPMSN\PJi\00-03938I641L393864B DOC 04/1-'199- •Mr. Dion Novak USEPA Region V April 14, 1999 Page2 We have also attached pages and a drawing, revised as a result of the April 6, 1999, comments, for insertion into the Amended ROPP. The BSG requests approval of the Amended ROPP on the basis of the attached responses and the revised pages and design drawing. Please call either Phill Mazor at (616) 688-Sm, or me, if you have any questions. Sincerely, RMT, lnc. Linda E. Hicken, P.E. Senior Project Manager cc: Rob Franks, MDEQ Leslie Kirby, EPA ORC Donna Brunner, Tetra Tech EM (2 copies) SSC Technical Committee Gary Connor, RMT Wally Kurzeja, RMT "':, i Frank Griffin, Enterprise Environmental & Earthworks RMT, INC. 744 HEARTIAHO TRAIL • 53717-1934 P.O. Box 8923 • 53708-8923 MADISON, WI 608/831-4444 • &08/831 .3334 FAX --------- -------------- - .111111 I 1WP!ASNIPJ1'00-03938\&&IL3938648 DOC 04/14199 RESPONSES TO THE USEPA'S APRIL 6, 1999, COMMENTS ON THE MARCH 1999 AMENDED REMEDIAL DESIGN PROJECT PLAN 1. Page 5. Please delete tire summan1 histonJ of the plan development as outlined on this page. This information is unnecessan1 as the soil cover request has been memorialized in an ESD for tlte radio tower area. Response: The summary is justifiably included in the section entitled "Background" because it documents the process and the effort expended by the Butterworth Landfill Cooperating Parties (BLCP, the PRPs who conducted the Remedial Design) and the BSG to comply with the consent decrees for both the Remedial Design and the Remedial Action. 2. Page 9, RTSB investigations. The information presented here should be revised to reflect the findings of the ESD. Response: The discussion in this section has been updated by adding a reference to the Group's "Proposal to Place a Soil Cover over the RTSB Area," (RMT, June 1, 1998), and by inserting text from the relevant portion of the ESD. 3. Page 14, Section 2.4. As disa,ssed recently, com1ersations about site reuse should lznppen shortly. If there are any Agency concerns regarding reuse plans, they are addressed more easily when constntetion is active. I would encourage tire BLCP to organize their ideas and present them to the Agendes as soon as possible. Response: Acknowledged. No modification to the Amended ROPP appears to be necessary. 4. Page 15, Section 3.1. It is stated ltere that the cor1er will extend over an area of waste on tire Consumers Energ,.J properhJ. Has this waste been characterized as part of the Buttenvorth investigations? Was this waste from Buttenuortlz operations? v\llwt is tile purpose of covering this area? ls it for slope stabzlihJ? Please address.
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