PUBLIC HEALTH ASSESSMENT
IONIA CITY LANDFILL
IONIA, IONIA COUNTY, MICHIGAN
The Ionia City Landfill site, on the U.S. Environmental Protection Agency (U.S. EPA) National Priorities List, was owned and operated by the City of Ionia as a landfill from the mid-1950s to the late 1960s, and accepted both industrial and municipal waste. After the landfill operation was discontinued, part of the site was used as a baseball field. In 1981, the Michigan Department of Natural Resources (MDNR) removed exposed drums containing wastes and ordered the ballfield structures dismantled. Part of the site was fenced in 1984, but the fence has not been adequately maintained. In late 1994, the U.S. EPA excavated 7,000 cubic yards of contaminated soil and waste, including all known buried drums, and disposed of them off-site.
The site poses an indeterminate public health hazard because of the lack of surface soil data and the potential for human exposure via direct contact with site soils, inhalation of fugitive dusts, or inhalation of volatile organic compounds. With future erosion of the site, buried wastes may become exposed and human exposure may occur through direct contact, ingestion, or inhalation of volatile chemicals.
Groundwater at the site is contaminated with metals and organic chemicals but is not currently being used. The site is adjacent to the Grand River and an intermittent unnamed tributary to the river. Sampling of water and sediment from the river and the tributary has detected some site-related contamination, probably from storm run-off and groundwater break-out, though not at contaminant levels of public health concern. Exposed waste on the site and continued public access pose a potential public health hazard through direct contact with the wastes and potentially with contaminated soil. There is no information available on the extent of contamination of the surface soil. The chemicals found on the site include a number of proven, probable, and potential human carcinogens. Exposure to high levels of some of the organic chemicals found on the site can harm the central nervous system, liver, and kidneys. This assessment recommends increased restriction of access to the site, further characterization of the contamination on the site, implementation of institutional controls on use of the contaminated groundwater, and the clean-up of contaminated groundwater.
A. Site Description and History
The Ionia City Landfill (ICL) site, also called the Cleveland Street Dump, covers approximately 20 acres on the north bank of the Grand River in the City of Ionia, between Cleveland Street to the west and an unnamed seasonal tributary of the Grand River to the east, and includes the channel of the tributary adjacent to the landfill (Figure 1). A residential area borders the site to the north. An abandoned railroad right-of-way crosses the site from approximately east to west, dividing the site into two sections. The older fill area to the north (Area A in Figure 1) is inadequately fenced and the more recent fill to the south (Area B) is not fenced at all. The fence around Area A extends across the tributary, although the fence is in bad repair at this location and does not restrict access to the site.
The City of Ionia owns the landfill property, and operated the landfill from the mid- to late 1950s until 1969. The City acquired Area A around 1950, Area B in the late 1950s or early 1960s. The previous owner had operated a landfill under a city contract on Area B for at least 5 years before the City bought the land. During the early years of the landfill's operation, the trash was burned regularly, almost nightly, according to a long-time Ionia resident. Nearby residents also reported occasional explosions at the site while it was in operation. In October 1965, one of these fires touched off an explosion that resulted in the death of a waste hauler. In 1966, the Michigan Department of Natural Resources (MDNR) classified the ICL as an open landfill. The City stopped burning waste on the site and applied for an operating license for the landfill in 1967, but the application was denied. The landfill was officially closed in 1969. Unauthorized dumping on the site has continued (1, 2).
Surveys of the site indicate that while the landfill was in operation, industrial wastes were primarily deposited in the northeast portion of Area A. The primary identified industrial users of the landfill were engaged in painting of parts for the automobile industry. Municipal or commercial wastes were placed throughout the site. Historical records, based on citizens' recollections, indicated that drums had been dumped in Area B. Site surveys have not found drums in Area B. It is most probable that the recollections were mistaken, that the citizens had failed to distinguish between the two sections of the site, although some industrial wastes may have been relocated to Area A from Area B (Reference 1, p. 1-12).
At some time between the landfill's closure in 1969 and 1981, a baseball diamond was built on the southern part of Area A. In 1981, a citizen complaint to the MDNR led to an investigation that detected a large number of barrels in Area A the landfill. An estimated 100 barrels were excavated, and their contents were sampled and analyzed. The barrels were found to contain paint sludges, paint thinners, and industrial solvents. Specific constituents included lead, chromium, zinc, iron, methylene chloride, trichloroethylene, ethylbenzene, styrene, and toluene. The excavated drums were temporarily enclosed by a snow fence. The backstop for the baseball diamond was removed to discourage further use of the site. Open rusted barrels were found and discolored soil, sediment, and water were observed on the east side of Area A during various investigations. In 1984, exposed drums were removed from the site, depressed and eroded areas of the site were filled with clay, and Area A was fenced, including the adjacent section of the east tributary. The railroad tracks that crossed the site were removed in 1987.
The U.S. Environmental Protection Agency (U.S. EPA) placed the Ionia City Landfill site on the National Priorities List (NPL) in June 1984. In 1986, the U.S. EPA, the MDNR, and the Ionia Potentially Responsible Parties (PRP) Committee entered into an agreement to begin a Remedial Investigation/Feasibility Study (RI/FS) for the site. During the RI/FS survey, an estimated 2,000 additional drums containing paint solids and solvents were found buried beneath a clay cap in the northeast section of Area A. Most of these drums were no longer intact. The RI/FS was completed in May 1988 (1).
The Agency for Toxic Substances and Disease Registry (ATSDR) released a Preliminary Health Assessment (PHA) for the Ionia City Landfill on March 15, 1989. The PHA concluded that the site was of potential public health concern because of the risk from potential exposure to contaminated groundwater, soil, sediments, and surface water. The PHA identified data gaps regarding all these environmental media and recommended further investigation to fill these gaps (3).
In September 1989, the U.S. EPA issued a source control Record of Decision (ROD) to use In-Situ Vitrification (ISV) to destroy or immobilize the wastes around the drums (4). After this remediation action and additional groundwater monitoring, a ROD will be issued regarding the groundwater at the site. In November and December 1992, MDNR and U.S. EPA contractors excavated the drum area to remove liquid wastes from intact drums for off-site disposal in preparation for the ISV remediation (5). The City of Ionia recently issued bonds to finance their share of the remediation of the ICL site (6).
In November 1993, groundwater monitoring detected new contamination attributed to the December 1992 liquid waste removal action. From October through December 1994, the U.S. EPA carried out an emergency removal action to remediate this contamination, excavating approximately 7,000 cubic yards of waste, including all known buried drums, from the highly contaminated area in Area A, and backfilling the excavation. The proposed ISV application was cancelled. The groundwater treatment program is still under development as of August 1995. A fence has been constructed along the Cleveland Street side of Area B, however, the east and south sides of that part of the site remain open for access (7, 8).
The site is relatively flat, with steep slopes down from the site to the creek on the east and on the west side of Cleveland Street and a gentler slope south to the Grand River. The surface cover is largely local sandy soil, with a partial clay cap, 2 feet thick, covering an area where industrial wastes were found in Area A. Excavations during the RI found clay beneath the wastes at 10 to 17 feet below the surface, depending on location, shallower in Area A. This clay is more probably native subsoil than a constructed floor for the landfill, and the available information does not indicate how thick the clay is. Boring logs for monitoring wells indicate that undisturbed subsoil is clay, between 5 and 10 feet thick depending on location, with the greater thicknesses at the south, closer to the Grand River. Several of the trenches encountered water at between 14 and 16 feet below the surface.
The groundwater beneath the ICL site flows in at least five aquifers, with the shallowest clearly affected by contamination from the site. This shallow aquifer starts at 5 to 16 feet below the surface and extends to a depth of 20 to 30 feet. An intermittent clay layer, which was found in borings under the landfill but not along the river at the south edge of the landfill, separates the shallow aquifer from an intermediate depth aquifer which lies at 30 to 45 feet below the surface and extending to a depth of 50 to 110 feet. Though the clay layer may not completely separate the aquifers, there is no evidence from sampling of contamination of the intermediate-depth aquifer. The pressure in the intermediate-depth aquifer is higher than that in the shallow one. Water in both aquifers flows to the southwest with the aquifers presumably terminating at the Grand River. Three aquifers in the bedrock beneath the site area (100 to 200 feet deep and deeper) provide the main drinking water source for the area. There is also no evidence that the bedrock aquifers have been affected by contamination associated with the Ionia City Landfill site.
B. Actions Implemented During the Health Assessment Process
This public health assessment has been in preparation by MDPH since June 1989. An agency review draft was circulated to the U.S. EPA in April 1990. A later draft was released for public comment on March 8, 1991. The ATSDR released the then-current version of the document as an Interim Health Assessment in April 1992 (9).
As described above, during this period the U.S. EPA has issued a Record of Decision for the remediation at the site, performed preparatory work for the selected remedy, and conducted an emergency removal of waste from the site. The MDPH has provided the U.S. EPA with signs for posting at the site to increase public awareness of the hazards. The Ionia County Health Department, at MDPH request, surveyed the community near the site for complaints about odors in their basements.
C. Site Visits
On June 6, 1989, John W. Filpus of the Michigan Department of Public Health (MDPH) visited the site with the MDNR site manager. They spent approximately an hour walking the site, gaining access to the fenced part of Area A by climbing over a fallen section of the fence. Much of the fence along the eastern side of Area A was down. They noticed trash on the ground surface, and the site manager pointed out stained soil in Area A. While they were in Area A, a deer spooked at their approach and bounded away. The river and the unnamed tributary were high that day, and some of the boundaries of the site were flooded. The agricultural land across Cleveland Street from Area B was also flooded. There was no visible sign of the baseball diamond that had once been located in Area A.
On January 10, 1992, Filpus and Brendan Boyle of the MDPH visited the site area. They observed the site from the railroad grade separating the sections of the landfill, noting no major changes, then toured the residential areas north of the site. Other information and observations obtained on these site visits are included in the relevant sections of this assessment.
MDNR personnel report that, as of August 1995, the drum area excavation was complete and the excavation backfilled, covered with a clay cap and topsoil, and seeded with grass and wildflowers. The only trace remaining of the emergency removal operation is a gravel drum staging area. The fence remains down along the east and northeast sides of Area A. An additional fence has been constructed along the Cleveland Street side of Area B, though the south and east sides of Area B are still open for access (8).
D. Demographics, Land Use and Natural Resource Use
Approximately 3,500 people live within 1 mile of the site. A 3-mile-radius circle around the site includes the entire City of Ionia and most of Ionia Township which has a combined population of approximately 10,300. The nearest residence is approximately 200 feet north of the site fence. A recreational park is to the west of ICL, across Cleveland Street, and north of the railroad right-of-way. The land west of Cleveland Street and south of the right-of-way is used for agriculture. The area north of the site is largely residential, with scattered light commercial properties. Across the Grand River, to the south, land use is a mixture of residential, light commercial, and recreational use. There are two golf courses south of the river, set back from the riverbank on higher ground above the river valley, about 0.5 mile from the site. Some of the land across the east tributary from the site is used for agriculture; the rest has not been developed.
A hospital is less than 0.5 mile northwest of the site. There are a total of four parks within 1 mile of the site: one across Cleveland Street from Area A (mentioned above), one 0.5 mile to the north, one to the east-northeast, and one to the northwest. Three schools and seven churches are located within 1 mile of the site, generally to the northwest, towards the center of the City of Ionia, approximately 1 mile west-northwest of the site (Reference 10, Figure 3-2).
The Grand River is used for recreational boating, fishing, and swimming in the site vicinity. There is a boat launching ramp approximately 1 mile downstream (west) of the landfill. The only recorded municipal water supply intake on the river was at Grand Rapids, approximately 30 miles downstream from the site, and the City of Grand Rapids closed that intake in October 1992 (11).
E. Health Outcome Data
Based on the evaluations performed as part of this health assessment, there are no indications that humans have had significant exposure to site-related contaminants. In addition, there were no community health concerns identified during this evaluation. Therefore, health outcome data were not evaluated in conducting this health assessment.
There have not been many expressions of community health concern regarding the ICL site addressed to local or state health departments (6). While the landfill was operating, the neighbors occasionally complained of odors from it and reported fires and explosions on it. The Ionia County Health Department, at MDPH request, surveyed the community near the site for complaints about odors in their basements. No resident reported any odors.
A draft of this public health assessment was released for public comment on March 8, 1991. The public comment period lasted until April 8, 1991. The comments received and MDPH's responses are attached (page RS-1). Although the official comment period has ended, further information and comments will be considered during future assessments of, or consultations on, the site.
The MDPH released a second draft of this Public Health Assessment for public comment on December 14, 1994. The comment period lasted until January 13, 1995. The MDPH received no additional comments in this period.
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