United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-93/231
September 1993
£EPA Superfund
Record of Decision:
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50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R05-93/231
4. TItle and Subtitle
SUPERFUND RECORD OF DECISION
American Anodco, MI
First Remedial Action - Final
7. Author(s)
2.
3. Recipient's Ac:c8salon No,
5.
Report Date
09/27/93
6.
8.
Performing Organization Ripi. No.
9.
Performing Organization Harne and Add,..
10
Project TukIWortI Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Harne and Addr88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Raport & Plriod Covered
Agency
800/800
14.
15. Supplementary Nat..
PB94-964117
16. Abstract (Umlt: 200 _Ida)
The 8-acre American Anodco site is an aluminum processing site for the automotive
industry located in Ionia Township, Ionia County, Michigan. Land use in the area is
predominantly light industrial with the nearest residences one-eighth of a mile
upgradient of the site. American Anodco cleans, brightens, anodizes, and seals
aluminum parts for automobiles. Beginning in 1962, the facility discharged process
wastewater and ~hemicals from their anodizing process to an onsite seepage lagoon' under
a State permit. From 1965 to 1978, American Anodco began reclaiming the acids instead
of discharging wastewater into the lagoon. In 1978, American Anodco tried to obtain
another permit to discharge wastewater to the lagoon, and this led to an investigation
of the lagoon's impact on ground water by American Anodco and the State. In 1986 and
1987, American Anodco began to phase out the seepage lagoon and discharge wastewater to
a public sewer system. Also in 1987, the lagoon sludge was removed and disposed of in
an off site landfill, and the excavation area was backfilled with clean soil. Soil
sampling confirmed that the sludge removal has decreased onsite contaminant levels over
time and EPA feels no additional remedial action is needed to be protective of human
health and the environment. Therefore, there are no contaminants of concern affecting
this site.
(See Attached Page)
17. Document Analysla a. Descrlptora
Record of Decision - American
First Remedial Action - Final
Contaminated Medium: None
Key Contaminants: None
Anodco, MI
b.
Idantlfiers/OpanoEndad Terms
c.
COSA TI FIaIdIGroup
18. Availability Statemant
19. Security CIau (Thle Report)
None
20. Security Class (ThIs Page)
None
21. No. of Pages
32
22. Price
(See ANSI-Z39.18)
S"" InstlUCtions on R.verse
OPTIONAL FORM 272 (4-71)
(Formerty NTJS.35)
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EPA/ROD/R05-93/231
American Anodco, MI
First Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site is no further action, with ground water
monitoring for two years. Previous removals have decreased contaminant levels at the
and the presence of these compounds no longer pose a risk to human health and the
environment. There are no present worth or O&M costs associated with this no action
remedy.
site.
PERFORMANCE STANDARDS OR GOALS:
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
American Anodco, Inc., lonia, Michigan.
STATEMENT OF BASIS
This decision document presents the selected remedial action for the American Anodea site, in
lonia, Michigan, which was chosen in accordance with the Comprehensive.. Environmental
Response, Compensation, and Liability act of 1980 (CERCLA), as amended by the Superfwid
Amendments and ReauthOrization Act of 1986 (SARA) arid is consistent with the National Oil
and Hazardous SubstanceS Pollution Contingency Plan (NCP) to the eXtent practicable. This
decision is based upon the contents of the Administrative Record for the site. .
The State of Michigan does not concur with this Record of Decision.
DFSClUPI10N OF THE SELECTI!D R~Y
U.S. EPA (EPA) has selected the .No Action. Alternative, with groundwater monitoring.
~
EP A has determined that conditions at the site due to contamination by inorganic chemicals pose
no current or potential threat to human health or the environment. While the American Anodco
site does appear to exhibit trace amounts of inorganic contamination wbich result .in .slightly
. elevated calculations of potential future risk from exposure to the groundwater, EP A has also
determined that the ~Jence of these compounds does not appear to pose an un~ie risk
to human health or the environment since the levels are below Maxinium Coa~mift2l\t Levels
(MCLs). Accordingly, no furtber remedial action will be undertaken. However, monitoring
. of the the inorpnic contaminants in the groundwater will continue for a period of twenty-four
months. .'
EP A has determiDed tbat no remedial action is IleCeS-wy at this site. EP A bas determined that
its respcme 1& Ibis site is complete. Therefore, the site now qualifies for inclusion on the
Construction CGmpJction List. M this.is a decision for 8No Action., the statutory requirements
of CERCLA Section 121 for remedial actions are not applicable and no statutory five year
review will be undertaken.
J~ 7,1)
Am
li/, I//kC
~ Valdas V. Adamlm~
f - Regional Administrator
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EP A bas determined that conditions at the site due to contamination by inoiganic compounds
pose no current or potential threat to human health or the environment. While the Anodc:o. .
site does appear to exhibit trace amounts of inorganic contamination which result in slightly
elevated calculations of potential future risk, EP A has also determined that the presence of
these compounds does not appear to pose an unacceptable risk: to human health or the .
environment, because all chemicals are below MCLs. The MCL for arsenic is SO parts per
billion. However, the state's standard. for arsenic is 0.02 partS per billion, pursuant to
Michigan Act 3(J7 Type B standards. U.S. EPA has taken the position that the State ARAR
is not triggered if there is no risk, and that the MCL is protective of human health and the
environment. Accordingly, no further remedial action will be undertaken. EP A will,
however, require that groundwater monitoring continue for a period of 24 months. If after
twenty-four months U.S. EPA determines that the remedy is no longer protective,
alternatives for addressing the increased risk will be evaluated. At a minimum, if monitoring
has shown that Contaminant concentrations have increased, groundwater monitoring will
continue beyond the twenty-four month period. In addition, altemativessuch as deed
restrictions, additional groundwater monitoring, and/or groundwater treatment will be
evaluated as ways to eliminate any unacceptable risk: posed by the site. .
As this is a decision for .No Action., the statutory requirements of CERCLA Section .121 .
for remedial actions are not applicable and no statutory five year review will be undertaken.
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~
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.ICROMI8. TATTtA
STAft OF WlCHIC'~~
8
JOHN e~R, Covwnor
DEPARTMENT OF NATURAL RESOURCES
~.... T. ..- 1IuIUI'II. P.O. a.. ~. \,.8...",. loll tlOl')
""""0 MAMlU. DlrKtO(
Sept8lber 29, 1993
:
Mr. Valdas V. Adalkus. R-l9J
Administrator, Region 5
U.s. Environ8ental Protection Agency
77 West Jackson Boulevard
Chir.agn. l11ino15 60604-3590
Dear MI". Adallku~:
Tho Michigan OP.partment of Natura' Resources (MOHR), on behalf 0' the State of
Michigan, has reviewed the Record of Decision (ROO) received Septclber 24,
10;3, for the ~ri~an Anodco Superfund site located in the city of 10n1a, ,
lonia County, Michigan. The u.s. Environmental Protection Agency's (EPA)
selected alternative i~ nn action with groundwater DOn1tor1ng. Conceptually,.,
we support lOst aspects of the selected reledy; hoWever, for reasons described
below we cannot concur with thp. ROD.
. . ,
The selected r888dy 15 not con~1~tp.nt with Rule 299.5705(6) of the Michigan
Env iron_ntal Response Act (RERA), 1982 PA' 301, is amended. A 1 though we have
proposed 1egh1ati.on which wou1d an ow U~ to tleaive Rule 705(6) in
ctrcuastances such as exist at t~s ~1te, the a8endlent has not yet been
enacted. Thus, we rec08I8ndtd in our Propo~Ad Plan c08Ient letter of
S~ptefiber 14, 1993, that tht. EPA wive this ru1. to illple118f\t the proposed
reMdy. The EPA chose not Co waive Ru'. 299.5705(6), and tnstead the, EPA
.a1ntltns that state Applicable or Relevant and Appropriate Requ1re8ents
(MARs) are not trt.l'ed if cont.'nant conc8ntrattoM tn 9rnun~ater are
below.lllx'8U1I contalilinant levels and the site poses no other risk. However,
no bas's for the EPA to dtsregard state AlARs 1s g'ven in eith-r thp. '
coaprehens1ve Env1ro18ntal Response, Co8pensatton and Liability Act,
1980 Pl 96-510, or 11 the National ContingenCy Plan.' .
COlKoentrattons of ,arsenic, boron and -.nese in groundwater at the sit.
exceed the lOA drinktng water criteria. Coftsequent11. the lOA Rule 299.5719
require. that 1and-us. restrtctions be 18fQscd until such t1.. as the
conc:eatrations of contllltnants 1n the aqui'er '111 witht" the MERA criteria.
Tbe se1ect8d I"88eCt1 'lIPOSes no 1ancl-uH restrict tons and rtqUtres only two
years of cont1M1ed IfOUnMter. 8On1tor1119. ,
A 1 though' a cursory rev'. of site condit ions suggests that Id tve grounct.iter
reMd1a~ion .1vhL be hipr.,ttcab1., it is illpot"tant that the evaluation of
alternatives t'*Clu4es stte.speciftc tllforaat1on Oft the teclantca1 feas1biHt) ,
and cost ef1ec\1venen or .~tl'e ~"'ter r88dia' ,ctio" to cOliply with'
the IDA Ru1. 299.5717(3)(1). This Cou1d consist af ,eva1«MUng is st.1e a
s1Stel as pu8P1ng fr08 . slny1e extr.,tioft wel1 .nd tr..ting the ' extracted
water. No such eva 1uat ion has been provided. ' '
"I.
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~((j,J ~Vr ~I'U ;.,Jf'4iJ
I~~. ~-Jil-~~J-4oor
~C P ,JU. ~~ U.; 1 ~ "0. ~oI '", ~"..~
Mr. V11~s V. Ada_us
-2-
September 29, 1993
The ROD In~'udes no provision for further IGnitoring of the site's i8pactupon
, Pra 1rte Creek. The re8edill invest 19at ton showed that groundwater d1schlrges
. to th~ ~reek ~nd that concentrations of arsenic, zinc and nicke' exceed the
M£RA groundwater/surface water interface (GS1) criteria 1ft the groundWater.
The data fr08 a 1984 5tudy perfoM88d by Ecology and Environment, Inc.,
indicate that lead concentrations in sedt.ents were higher downstrea. than
they were upstreu ff'UII Ule lite. We recOIIIIend that 8Onitoring or lIOde11ng of
concentrations of site conta.tnants at the &51 be performed in compliance with
the HERA Ru1e 299.5713.
we have'some concerns wHh LI,~ EPA'$ eva1uation of the baseline risk
assesS8Int. We would prefer that the EPA not allow exceedances of their
acceptable r1sk range IS Ute1 hav~ dun" for this site. We ..8.11ze that the
, 51t,'s known point sources haye been relOyed, the groundwater cont~inant
concentrations are continually decreasfny .,~ the a,tive extraction 0'
contamination appears difficult. However, ,the EPA should acknowledge the
risks that exist at the site and require land-u$e restrIctions and 8On1toring,
which would continue unt1T the rtsks become acceptable. Such an Ipproach
would necess1tlte a f1ve-year review.
If you have questions or cOIIIIents, you.y contact Mr. 8ruQt Va" OUeren,
Superfund Section, EnY1ron8ental Response Division, at 517-373-8421, or you
IlliY contact _.
.
, Sincerely,
.." ' ~
41P~.-~ ~ ~
Russe II J. Harding
Delluty Director
517-373-7917
cc:
Ms. Jodi Traub. t'A
Ms. Mary Pat Tyson, EPA
Mr. T1. Prendh111., EPA
Mr. A lln J. HMrd, tI)NR
..... Villi- Bradford. .aut
1Ir. "itch Adel.n, ...
.... 8Jooua Ya.. Ott.eren. ... I Merican Ano<1co Fne (16) .
"
.
. .
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~
AMERICAN ANODCO, INC.
IONIA, MICHIGAN
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
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DECISION SUMMARY
American Anodco, Inc~ (Anodco) is located at 28 N. Beardsley Avenue approximately one mile
east of lonia, Michigan. Tbe PIOpert)' occupies a portion of the SW 1/4 of section 16, and the
NW 1/4 of section 21, lonia Township (TIN, R6W), lonia County. American Anodco, Inc. is
an eight acre site bounded by Beardsley Avenue to the west, Prarie Creek to the north and east,
and Main Street to the south. The area surrounding American Anodco is largely used for light
industrial businesses. The nearest residents are located upgradient of the site, approximately
1/8 of a mile to the east. The nearest downgradient residents are west of Prairie Creek,
approximately 900 feet from the site. The site is shown in Figures 1 and 2. ..
American Anexico, Inc. cleans, brightens, anodizes and seals aluminum parts for the automotive.
industry. Beginning in 1962, the facility discharged process wastewater and chemicals from
their anodizing process to an on-site seepage lagoon under an Order of Determination (permit)
from the State of Michigan. In 1965, instead of discharging to the lagoon, American Anodco
began reclaiming phosphoric acid and nitric acid, and reclaiming nickel acetate and sulfuric acid
in 1978. .
In 1978, Anodco began taking steps to obtain an upgraded groundwater discharge permit from
the State of Michigan to discharge process water to the lagoon. As part of this application,
Anexico conducted a hydrogeologic inv~ption to assess the impact of the lagoon on
groundwater. These studies indicated elevated levels of inorganic chemicals, such as aluminum,
chromium, coppec, and lead, in the groundwater.
. In 1984, the site was ranked by U.S. EPA under the Hazard RQJring System, and the site was
then proposed to the National Priorities list (NPL) on 1une 10, 1986 and finali7ed on the list
on March 31, 1989. Two hydroaeologic studies were performed at the site in 1982 and 1986.
Both stud1es fouDd only devItm phnsphate levels downgI3dient of the lagoon with no impact
on drinkin& water supplies.
In 1986 }.~ ADOdco bepn taking steps to phase out the seepage lagoon and discharge
process wuaewara to a DeW public sewer. The company began discbarging process wastewater
to the pubJjc ... system in 1987. AlJo in 1987, the lagoon sludge was removed and disposed
of in an mr... 1andfi11, and the excavation was backfilled with clean soil. At the time of
removal, B~ of die lagoon sludge were collected and. aD8.lyzed for EP toxicity. None of
the samples takenexhibitalleacbable chemicals. Prior to backfilling with clean soil, samples
were taken again and analyzed for EP toxic metals and organics, and again pas!ed.
In 1uly 1987, U.S. EPA contacted American Anodco and informed Anodco that U.S. EPA
considered it to be a potentially responsible party (8PRP8) with respect to the Beardsley Avenue .
facility. U.S. EPA also offered American Anodco the oppoitunity to conduct a Remedial
Inv~prionl Ftasibility Study (RIIFS) at their facility to ~ the environmental impact of the .
former lagoon. The RIIFS.wort p1an was approved by U.S. .EPA in September 1987. On
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October 27, 1987, an A.dminimative Order on Consent for the RIlFS, U.S. EPA Docket IV-W-
81-C-026, was executed between the sole PRP, American Anodco, Inc., and U.S. EPA. In
August 1989 the RI Report was submitted to U.S. EPA. In February 1990, U.S. EPA requested
that additiOnal poundwater investigations be performed to more fully characterize groundwater
conditions. In April of 1993 a Final RI Addendum, presenting the findings of the additional
work, was completed. The key findings of the studies are summarized below.
m. HIGHLIGHTS OF COMMUNITY PARTICWATION
Community Interest with the site was minimal throughout the RIlFS process. In July of 1988,
a fact sheet was sent out informing the public about the Superfund process and describing the
activities planned for the RIlFS. U.S. EPA held an availability session at the lonia Council
Chamber. on August 2, 1988, to discuss the RIfFS process and the site.
U.S. EPA released the Final RI Report and Addendum to the public on May 3, 1993, for public
comment. These documents were made available to the public in both the administrative record,
maintained at the U.S. EPA Docket Room in Region V and at the lorna Public Library. These
documents were also made available in the information repository maintained at the Ionia Public
Library. The notice of availability of these two documents was published in the' Grand ~ds
fmH, and the Ionia Sentinel on July 20, 1993. .
The Proposed Plan was released to the public for comment on July '18, 1993. The notice
published on July 20, 1993, in the ~ and the Jonia Sentinel announced the
beginnifll of the 3O-day public comment period. The public comment period concluded August
18, 1993. The Proposed Plan, and the published notice provided the public with the opportunity
to request a Public Medina to discuss the Remedial Investigation (RI) ~s and the proposed
alternative. .
The public participation requirements of CERCLA sections 113 (k) (2) (B) (i-v) and 117 have
been met in the remedy selection process. 'Ibis decision document presents the selected remedial
action for'the Anodco site, in Michigan, chosen in accordance with CERCLA, as amended by
SARA aDd, to the extent practicable, the NCP. The decision Jor, this site is based on the
adminimative record. '
IV. SCOPE & '"nl.R OU~NSE ACTION
This ReccmI of~siQQ (ROD) addresses the final remedy for the site. U.S. EPA recommends
that no fuItbcr ~.1 actioo be taken at the Anodco site for the fonowing reasons. Soil
samples CQ~ beneatJ\ die former lagoon were not EP toxic. Although the site bas impacted
site groundwater ~lItina in elevated levels of arsenic and other inorpDic contaniinants, the
cont=a.minant concentrations have decreased over time and the levels detected have been below
Federal Safe Drinking Watu Standards Maximum Contaminant Levels (MCLs), die levels which
U.S~ EPA defiDes as bani protective of .human health and theenvironmenL BecaV~
. con~ift2nt levels are below MCLs, U.S. EPA has determined that exposure to site related
contaminants do not pose an n~table risk to human health or the environment and that
remedial action under Superfund is not warranted. U.S. BFA does believe that continued
monitoring,is warranted to ensure thai contaminant levels do ~ increase. No five year review
will be undertaken, but U.S.',EPA will continue to require monitori.ng of the groundwater for
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.. . a period of twenty-four months. If after twenty-four months U.S. EPA determines that
contaminant levels are increasing, or have exceeded MCLs, alternatives for addressing the
increased risk will be evaluated. At a minimum, if monitoring bas shown that contaminant
concentratiOns have increased, groundwater monitoring will continue beyond the twenty-four
month period. In addition, alternatives such as deed restrictions, additional groundwater
monitoring, anellor groundwater treatment will be evaluated as ways to elimin~te any
unacceptable risk posed by the site. .
V. SITE CHARACTERISTICS
Pursuant to the authorities under CERCLA, as amended, and the National Oil and Hazardous
Substance Pollution Contingency Plan (NCP), an RI was conducted at the site. The RI was
conducted in three phases. Phases I and n began in January 1988 and were completed in March
1989, Phase m was completed ~ April 1993. The RI also included a Risk: Assessment to
evaluate the level of risk to human health and the environment. This section summarizes the
analysis presented in the RI report: .
A) Site Togoaraphy
The topography of the American Anodco site is generally flat" with a gentle slope toward the
southeast. Along the northern boundary of the site, the topography drops approximately 20 feet
to the floodplain of Prairie Creek, which is a tributary of the Grand River.
B) SiBJiaJ.m
The Anodco site is located 011 glacial outwash in the valley of the glacial Grand River. The
geology of this area is charactcrizcd by approximately 100 feet of unconsolidated glacial deposits
consisting of sand, clay, gravel, and mixtures of these materials. The deposits overlie the
Pennsylvanian Age bedrock. of the ~gjn.aw and Grand River Formations. . Generally, these
formations include interbeds of shale, limestone, sandstone, and some gypsum.
Based upon the soil samples collected durina drilling operations, geologic materials at the site
consist of interbedded sands aDd pavels with thin, discontinuous silt seams. Figure 3 is a
geologic cross-S;CCtion illustrating the geologic setting at the site.
C) Site Surf~ WA"" UDroIOJY
Prairie Creek is the only surface water body near the Anodco site. The surface hydrology
around.tbe ADOCIco. site is c:oairolled by this water body.. Prairie Creek is a tribu~ to. the
GIaDd River. 1"be Grand River flows across the lower portion of Michigan and eventually
dischaqes to. Lab Michigan. The groundwater flow pattern at the Anodco site is .clearly
infln~ by Prairie Cteek. The creek flows from the north to the south along. the boundary
of the American AnocIco Property, approximately 600 feet east of the former lagoon area.
. .
, .
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D)~
Groundwater was encountered at depths ranging from approximately 16 to 30 feet below the
ground surface in an unconfined aquifer. Groundwater flows north to northeast acrosS the
former lagoon area toward the creek. Vertical gradients within the aquifer were neglible,
indicating predominantly horizontal flow within the aquifer. The groundwater flow velocity in
the lagoon area was estimated at 180 feet/year, or 0.5 feet/day.
The rate of groundwater flow across the former lagoon area to Prairie Creek was estimated using
the minimum, maximum and average hydraulic conductivities (8.3xlQ-4, 6.3xH)"1 and 2.lxU)"1
em/see, respectively), the horizontal gradient across the former lagoon area to the creek (0.0005
feet/foot), and by assuming that the zone of flow across the former lagoon area is 400 feet wide
and SO feet thick. These calculations resulted in a range in e$tirrnatM flow to Prairie Creek of
0.0003 to 0.02 cubic feet per second (cfs), with an average estimated flow of 0.0007 cfs.
To evaluate the significance of a possible groUndwater discharge from the former lagoon area
to Prairie Creek, the estimated groundwater discharges were compared to worst case creek flow
using 9S ~ lowest creek flow for the lowest flow month. According to the MDNR, July and
August are the lowest flow months with a 9S ~ low flow of 18 cfs. A comparison of tile
estimated groundwater flow to the creek's low flow reveals that, under worst~ conditions,
. groundwater flow from the former lagoon area will account for O.OOIS~ to 0.11 ~ of tile
Creek's flow. Use of the average conductivity results in a contribution of less than 0.041,.
This coupled with the groundwater quality data indicates that groundwater flow from the former
lagoon area will not have any significant impact on Prairie Creek.
EXTENT OF CONTAMINATION
1)Sgjb
In June, 1988, soil samples were colli:cted below the former lagoon to check for residual
contaminants ~ ,could potentially tIueaten future, groundwater quality in the area. Samples
,were collected by drillin& two soil borings (SB-IOI and SB-I02) through the fill material and
into the underlying soils.
For com~!1n8 purposes, one baCkground soil sample was also collected from an area remote
from the Jaaooa near die west px09CrtY boundary. The samples were analyzed for EP toxicity
meIa1s (AnaIic, Barium, C.Mmium, Chromium, Lead, Mercury, Selenium, and Silver) and
ortbo-~ (u pbospborus). ' .
The background soil sample (NS-l) was'collected from a location approIirrna~ly 2S feet west
ofOW-13. The sample was collected at a depth of four-feet with a stainless steel hand auger.
,', It was submitted to the U.S. EPA CLP laboratory (CAL) for analysis ofEP toxicity metals and
total ortho-pbosphate. ' ' ' '
The results of the EP toxicity tests conducted on tWo soil samples from beneath the former
lagoon show that the remaining soils are not EP toxic.
"
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.
'Ibe concmtration of ortho-phosphate in these samples was found to be about 200 mg/kg, which
is bi&ber tban the background soil concentration of < 0.05 mg/kg. 'Ibe phosphate contained in
soils at the Anodco site is probably bound to metal ions, and metal phosphate in groundwater
since removal of the lagoon. The teach!;lhle phosphate bad already migrated through the
groundwater system, and the phosphate remaining in the soil is relatively insoluble. Therefore,
a future groundwater impact due to phosphate in the sub-lagoon soils is not expected.
2) Groundwater
Since 1988, three phases of groundwater sampling, and analysis has taken place at the site.
Phase I sampling was conducted in June 1988, and Phase n took place in July 1989. In those
tWo phases 17 monitoring wells were installed and sampled. Figure 2 shows the locations of
all monitoring wells located at the site. In June 1991, four additional monitoring wells were .
installed to further characterize groundwater conditions. A3 part of the well ,installation
procedures, vertical profile sampling was used to set the well screens at depths where maximum
concentrations of contaminants were detected. In April 1992, all of the monitoring wells were
re-~pled as Phase ill. In September 1992, OW-6 was re-sampled for 1,1,I-TCA based upon
an unusually high reading for the contaminant in the previous round of sampling.
Several inorganic contaminants were detected during the groundwater investigations. Tables 1
and 2 list the reSults of the sampling from Phase ill of the groundwater investigations for bod1 .
inorganic and organic contaminants. None of the contaminants detected were above MCLs,
however, several were above background concentrations, indicating that the former lagoon bas
had some effect on groundwater quality. There appear to be plumes of arsenic, manganese and
boron on;.site. Arsenic was detected in wells OW-4, OW-S, OW-6, OW-7, OW-8, OW-9, OW-
laD, OW-lSD, OW-1SS above background concentrations. Manganese was detected above
background levels in wells OW-I, OW-3 through 12, OW-14, OW-lSD, OW-1SS, OW-16, OW-
17, PWC-l, and PWC-2. Boron was detected above background in all on-site wells except for
OW-l3, OW-14, OW-lSS, and OW-lSD. Other contaminants found above background in the
1992 sampling were magnesium, nickel, zinc, and ammonia. .
Nickel concentrations have decreased significantly since the removal of the lagoon. The highest
level detected in 1988 was 105 ppb. In 1992 the highest level detected was 71.7 ppb, in the'
same well. This lC:vel is below MCLs, and all other federal standards for protection of human
health and the environmenL
Zinc concmtntions, 31thooa" above ~1(ground, may be attributed to the type of casings used
in the wells wIaae zinc was detectaI. In most cases where zinc was detected plv:ani'7ed steel
riser pipes were UIed. In weDs where PVC was used zinc concentrations were in line with
background IeYds. .
In 1988 ammonia was detected at 2.3 parts per million (ppm), eXceeding criteria and standards
f~ 'some 'purposes. The U.S. EPA Water Quality Criteria for Human Health is O.S ppm.
CaJ-cu1ations using the data from 1988 showed that ammonia. cOncentrations, once they reached
Prairie Creek, would not exceed, and in fact be far below any standard set .for surface water.
In 1993 the highest detected concentration of ammonia in the groundwater was 0.88 ppm which
again would not significantly im~ surface water quality in the creek.
. .
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As evi~ from Table 3 the averaae concentrations of iDorpnics in the JIOUDdwater have
been decreasin& OVffl time. Specifically, the average concentratioo. for arsenic went from: 10.9.
'parts per billion (ppb) in 1988 down to 7.1 ppb in 1992. At well OW..Q6, where the highest
level of arsenic on site was detecte4 at. 27.3 ppb in 1988, in 1992 it was ddected at 2S.l ppb.
The' average CODC:ef'tration of boron decreased from 517 ppb to 381 pPb.
Of the organic chemicals analyzed for only 1,1, l-trichloretbane (TCA) Was ddected above its
MCL of 200 ppb at 270 ppb. 'Ibis detection was at only one well and not congruent with
previous sampling results. Subsequent sampling of that well for TCA confirmed that the 270
ppb was an anomoly. The analysis found only 3 ppb, consistent with previous results from that
and the other on-site wells.
3) Surface Water and ~Iments
In June of 1984 as part of the NFL listing process samples were taken from the surface water
and sediments of Prairie Creek at three locations; one upstream, one down stream, and one mid-
stream adjacent to the site. property. The samples were analyzed for 24 inorganic parameters
including arsenic. Table 4 summarizes the results from those samples. The results indicate that .
there is little measured difference between the upstream sample and both the downstream and
adjacent samples, and that the site bas bad little to no effect on the creek. As discussed in
Section V(D) above, the amount of groundwater contributed to Prairie Creek, even under worst
case conditions, is minimal, further supporting the concept that the site bas bad no effect on .
surface water and sediment quality. .
VI. RISK AS-.cmssMENT
The analytical data collected during the RI indicated the presence of contaminants in the
groundwater. Even though all contaminants were detected below MCLs, indicating there are
no un~CN'p1able risks posed to human health or the environment a baseline risk assessment was
performed, pursuant to the NCP, based upon potential future conditions at the site. The baseline
.risk ~4t~t determines actual or potential risks or toxic effects the chemical contaminants
at the site pose UDder current and future land use aSsumptionS. The risk. asses$ment assuri1es no
corrective action will take place.and that no site use restrictions or institutional controls such as
fencing, groundwater use restrictions or construCtion restrictions will be i~. The baseline
risk wessment included the following specific assumptions:
. C~",i...twI aquifers may be used as a drinking water soun:e;
. 'I1Ie - may be used for residential development;
. Access restrictions such as fencing will not preclude pOtential trespaSSerS from getting
into the sUe; and
. No groundwater use restrictions will be enforced.
The only media of poten~ concem for human exposure was identified as groundwater becaU$e
of the prior removal of conmm;~'M . soils and sludges froin the seepage lagoon. A list of
contaminants found at the site was developed to determine ~ contaminants _of concern for the
site. Those cont8.minants that were reported very infrequently. and at low concentrations were
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~iminated from further cnnsideration as contaminants of c:oncem.All carcinogenic contaminants
~ iDcluded as conmminants of concern. The compounds selected as CODmminants of cOOcem
far the ~~ine risk assessment include:
Ammonia
Arsenic
Boron
Nickel
Nitrate
Analytical data gathered from the on-site wells sampled indicated no exceedances in groundwater
of Federal MCLs for inorganic constituents. Only 1-1-1 Trichloroethane (TCA) exceeded the
MCL; however, since this was a one time occurence over a three year period, the presence of
TCA is questionable and TCA was not selected as a contaminaf't of concern. Additional
sampling has. shown the one exceed3nce of the the MCL to be an anomoly.
Current risks for the receptor group was based on concentrations of contaIiUnants actually found
during monitoring in and around the site. For example, current risks to. residents use
concentrations found in the groundwater taken from on-site wells. .
Potential future risks for residents are based on the conservative assumptions that future
concentrations of contaminants in residential wells will be equal to the highest concentration of
contaminants found in groundwater directly under the site, and that.a residence could be built
directly on the site, potentially exposing adults and children to contalninants in the soil through
direct contact (See Section S.O and Appendix E of the 1993 RI Addendum Report for a complete
discussio~ of the. assumptions and formulas used in the Baseline Risk Assessment)
For each exposure pathway evaluated, carcinogenic and noncarcinogenic health risks were
characterized for each risk scenario.
. .
Reference doses (RfDs) have beat developed by U.S. EPA for indicating the potential for
adverse health effects from 'uposure to chemicals exhibiting non-carclnogen1C effects. RIDs,
. which are expressed in units of mg/k&-day, are estimates of lifetime daily exposure levels for
. humans, includina sensitive individuals. Estimated intakes of chemicals from environmental.
media (e.I., tile amount of a chemical ingested from contaJni~ted drinkinl water) can be'
compared to 1bc RID. RIds are derived from human epidemiological studies or animal studies
to which uncatainty factors have been applied (e.g., to account for the use of animal data to
predict effects (8 humans). These uncertainty fadors help ensure that the RIDs will not
unden:stimafe die potential for adverse non-carcinogenic effects to occur. .
Potential concern fot non-carcinogenic effects of a single conmminant in. a single medi",m is
expressed as. the hazard quotient (HQ) (the ratio of the estimated intake derived froin the
contaminant concentration. in a given medium to. the contaminant's
reference dose). By addi"g the HQs for all contaminants within a medium or across all .
media to which a given population may reasonably be exposed, the Hazard Index (HI) can be
generated. The HI provides a useful reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across media. Any Hazard Index
. .
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value greater than 1.0 suggests that a non-carcinogen potentially praalts an tJ~le
health risk. .
The hazard .index for the worst case scenario, using maximum contaminant c:oncen~on, is
3.0, with the HI for arsenic alone at 2.3. Using average site related contaminant
concentrations the HI is 0.8.
Cancer potency facton (CPFs) have been developed by U.S. EPA's Carcinogenic.
Assessment Group for estimating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. CPFs, which are expressed in units of (mgIkg-day)"l t are
multiplied by the estimated intake of a potential carcinogen, in mg/kg-day, to provide an
upper-bound estimate of the excess lifetime cancer risk associated with exposure at that
intake level. The term .upper bound. reflects the conservative estimate of the risks
calculated from the CPF. Use of this approach makes underestimation of the actual cancer.
risk highly unlikely. Cancer potency facton are derived. from the results of human
epidemiological studies or .chronic animal bioassays to which animal-to-human extrapolation
and uncertainty facton have been applied (e.g., to account for the use of animal data to
predict effects on humans).
Two CPFs were used for arsenic. The second, least conservative CPF, includes a downward
modifying factor of 10 (the modified CPF). Because the tumon upon which the CPF was .
based are benign skin tumon, U.S. EPA's Risk Assessment forum considers that risk
estimates for arsenic can be modified downward by an order of magnitude relative to risk
est1mfltH associated with most other carcinogens. Skin cancers bav~ a high cure rate in the
United States because of ease of detection and efficacy of treatment.
Excess lifetime cancer risks are determined by multiplying the intake level with the cancer
POtencY factor for each conmminant of concern. These risks are probabilities that are
generally expressed in scientific notation (e.g. lxlO" or IE-6). An excess lifetime cancer
risk of lxl04 indicates that, u a plausible upper bound, an individual has a one in one
million chance of developing cancer as a result of site-related exposure to a caJcinogen over
a 7o-year lifetime under the specific exposure conditions at a site. The U.S. EPA generally
attempts to reduce the excess . lifetime cancer risk posed by a Superfund site to a range of
Ixl04 to lxl04 (1 in 10,000 to 1 in 1 million), with an emphasis on the lower end of the.
scale (lxlO"). The following are the calculated carcinogenic risks from exposure to
con~minflt~ poundwater usin& the average and maximum contaminant concentrations, and .
both the Uftmod1fied and mndifi$l CPF:
Scenario
Cancer Risk
Average Concentrations/unmodified CPF
Maximum Concentrations/unmOdified CPF
Average Concentrations/modified CPF
Maximum Concentrations/modified CPF
1x1~
Sd04
Id 0-'
Sd 0-5
Under each scenario arsenic is the sole chemical contributing to the risk.
Based upon the calculations described above there does not appear to be an. ww:ceptable
carcinogenic risk posed by the "Site.. When using the the wont case scenario and the
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unnvvfified CPF the risk is 5xl04, just outside the acceptable carcinogenic risk range of
lxl04 to lxl04. However, using the modified CPF the risk falls within the range at Sxl(t'.
The HI caJl!IIU1tf11ff for the site was 3.0 with the m for arsenic alone at 2.3. The maximum
concentration of arsenic detected at the site was 2S ppb. The MCL for arsenic is 50 ppb.
OSWER Directive 9355.0-30, .Role of the Baseline Risk Assessment in Superfund Reniedy
Selection Decisons., states: .
.Chemical specific standards that define acceptable risk levels (e.g., non-zero
MCLGs, MCLs) also may be used to determine whether an exposure is associated
with an unacceptable risk to human health or the environment and whether remedial
action under Section 104 or 106 is warranted. For ground water actions, MCLs and
non-zero MCLGs will generally be used to gauge whether remedial action is
warranted. . .
Therefore, because. the concentration of arsenic, or any other site related chemical~ has
repeatedly been found to be below MCLs, U.S. EPA believes that there are no IIn~c:ceptable
risks, non-carcinogenic or carcinogenic, posed by the site.
VU. EXPLANATWKnF SIGNIFICANT CHANGES
Based upon public comments on the proposed plan U.S. EPA has removed the requirement
. for monitoring of Prairie Creek to assess what impact the site has had on. the surface water
aDd sediments. A review of the existing site data has shown that there were samples taken . .
from both the surface water and sediments of Prairie Creek by a U.S. EPA contractor in
connection with the NPL listing process. These sampl~ were taken around June of 1984,
from three sampling locations; one upstream, one doWnstream, and one midstream adjacent
to the site. Although arsenic was detected in the samples from the sediments, it was detected
at each of the locations, indicating an elevated arsenic concentration in the entire area,. and
not attributable to site operations. Accordingly, U.S. EPA feels no need to monitor the
creek, ~. upon available data. . ..
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EP A bas determined that conditions at the site due to contamination by inorganic compounds
pose no cumnt or potential threat to human health or the environment. While the Anodco
site does appear to exhibit trace amounts of inorganic contamination which result in slightly
elevated calculations of potential future risk, EP A has also determined that the presence of
these compounds does not appear to pose an W'3CN'ptable risk to human health or the
environment, because all chemicals are below MCLs. The MCL for arsenic is 50 parts per
billion. However, the state's standard for arsenic is 0.02 parts per billion, pursuant to
Michigan Act 3m Type B standards. U.S. EPA has taken the position that the State ARAR
is not triggered if there is no risk, and that the MCL is protective of human health and the
environment. Accordingly, no further remedial action will be undertaken. EP A will,
however, require that groundwater monitoring continue for a period of 24 mOnths. . If after
twenty-foUr months U.S. EPA determines that the remedy is no longer protective,
alternatives for addressing the increased risk will be evaluated. At a minimum, if monitoring
has shown that contaminant . concentrations have increased, groundwater monitoring will
continue beyond the tWenty-four month period. In addition, alternatives such as deed
restrictions, additional groundwater monitoring, and/or groundwater treatment will be
evaluated as ways to eliminate any unacceptable risk posed by the site.
As this is a decision for .No Action., the statutory requirements of CERCLA Section 121
for remedial actions are not applicable and no five year review will be undertaken.
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Responsiveness Summary
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"
.e.pon.'! vue.. Su,.,.. rt
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, as amended by the Superfund Amendments and
Reauthorization Act of 1986 (CERCLA), which requires the United
States Environmental Protection Agency (EPA) to respond "...to
each of the significant comments, criticisms, and new data
submitted in written or oral presentations" on a proposed plan
for a remedial action. The Responsiveness Summary addresses
concerns expressed by the public, potentially responsible parties,
(PRPs), and governmental bodies in written and oral comments
received by EPA and the State regarding the proposed remedy for
the American Andoco Inc. site.
A.
overview
1.
B.ekaroUD4/pro~o8e4 Plan
American Anodco, Inc. i. an eight acre site, located on Beardsley
Avenue approximately one mile east of Ionia, Michigan. The site
is bounded by Beardsley Avenue to the west, prarie creek to the
north and east, and Main Street to the south. The area
surrounding the site is largely used for light industrial
businesses. The company cleans, brightens, anodizes and seals
aluminum parts for the automotive industry. Beginning in 1962,
the company discharged process wastewater and chemicals from
their operations to an on-site seepage lagoon. In 1965, instead
of discharging them to the lagoon, the company began reclaiming
phosphoric and nitric acid, nickel acetate and sulfuric acid in
1978. '
Between 1978 and 1986 the company instalied and, sampled several
ground water monitoring wells under the supervision of the MDRR. '
These studies indicated elevated levels of inorganic chemicals in
the groundwater.
In 1986 ~ company began taking steps to phase out the seepage
lagoon and discharge process wastewater to a new public sewer.
The c08p&fty began discharging process wastewater to the public
sewer ayat- in 1987. Also in 1987, the lagoon sludge was.
removed and dipased of in an off-site lanc1fill, and the' ,
excavation was backfilled., In the late 1980'. the company built
a plant ~ens~onover the former lagoon area.
The u.S. EPA became involved with this site in 1984 when it
, scorec1 the site under'the Hazard Ranking System. Based upon that
score, the site was proposed to the National Priorities List
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1
(NPL) on June 10, 1986 and finalized on March 31, 1989.
Samplinq and testinq of the qroundwater was performed durinq the
Remedial" Investiqation (RI) to determined the nature and extent
of contamination. The RI found that although the former lagoon
area impacted qroundwater quality onsite, the levels of chemicals
found in the groundwater are not above acceptable standards, and
therefore pose no threat to human health or the environment. "
The proposed plan for the site suggested that no action be taken,
but that monitorinq of the qroundwater and Prairie creek be
performed to ensure that contaminant levels remain at acceptable
levels.
2.
PUblic Co..ent Period
A public comment period" on the proposed plan for this Site was
held from July 20, 1993 to August 18, 1991. In the proposed plan
and the advertisement in the local newspaper, an opportunity was
extended to the public for a pUblic meeting. only one person"
requested that a meeting be held. Based upon the lack of public
interest in the site it was decided not to hold a meeting. The
one person requesting the meeting was contacted, informed of the "
Agency's decision, and her comments and questions were solicited
at that time.
Four parties commented on the proposed plan dur4ng the public
comment period; the MDNR, the potentially responsible party, and
two private citizens.
B.
C088UDity %nvolv..ent
The level of public interest reqarding this Site has been minimal
since the listinq of the site on the National Priorities List
(NPL). The two private citizens who commented on the proposed
plan had opposing views on the selected remedy; one being for the
no action" remedy and the other beinq opposed to merely studying
the problea rather than takinq action. .
c.
~.~"O~caDt CO".Dt.
The public C0888nts regarding the American Anodco Site are
orqanized in~o the followinq cateqories:
StnnlUllry of comments from the PRPs. regarding the
proposed plan;
" S\UIDD~ . of Comments from the local community reqarding
the proposed plan;
SWlDDary of comments from MDNR and local government
officials reqarding the proposed plan.
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.~
Many of the comments below have been paraphrased in order to
effectively summarize them in this document. The reader is
referred to the Administrative Record for this Site, located
at the Ionia Public Library, which contains copies of all
written comments submitted to EPA.
Comments from the Potentiallv ResDonsible Parties ("PRP-)
Comment 1:
The PRP concurs with the conclusion that there is no unacceptable
risk associated with this site, and that no remedial action is
necessary.
Response. 1
u.s. .EPA acknowledqes the comment.
Comment 2:
The PRP disagrees that there is not sufficient data to adequately
assess what. impact the site has had on Prairie Creek, and further
disagrees that additional samplinq of the surface water. and . .
sediment of the Creek is necessary. They cite several reasons
for their disagreement. First, they state that the ~ Addendua,
. which was approved by u.s. EPA, concluded that even under worst-.
case conditions groundwater flow from the form~r laqoon area
would not have any significant impact on the creek. Second, they
cited samples taken by a u.S. EPA contractor from the surface
water and sediments of Prairie Creek, which demonstrated no
impact from the site. Lastly, they state that the Michiqan
Department of Public Health has concluded that the creek will not
be impacted by qroundwater flow from the site. . .
Response .2:
u.S. EPA ha, reviewed. the data referred to by .the comment or and
agrees. The .data collected by Ecoloqy and Environment, a U.S. .
EPA contractor, do show that the site has not impacted the
quality of the surface water and sediments of prairie Creek.
Therfore, u.S. EPA will. not require that the .c;reek be monitored
at this t.i8e.
Comment 3:
The PRP disagrees with a comment made by - MOHR in a letter to U. S.
EPA which .tated that. all wells downgradient. of the foraer laqoon
area should be monit.ored. They argue that extensivemonit.orinq
of the site has been performed since 1982 and it. has demonst.rated
that the site- poses no unaccept.able ris.ks. They believe that
only the outermost downqradient wells should be requiredt.o be
monitored to ensure that. cont.aminants are decreasinq over t.ime
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~
:""
and are not aigratinq off-site.
Respo~se 3:
u. S . EPA disagrees with the commentor. In order to assess
whether contaminant levels are increasing over time more wells
than those proposed will need to be monitored. The impact of the
site on on-site as well as off-site groundwater is a concern of '
both the MDNR and u.s. EPA. Monitoring the wells farthest
downgradient from the former lagoon area will only indicate if
contaminants may potentially migrate off-site. It will not give
a complete picture of the groundwater quality on the American
Anodco property or tell us if the contaminant levels in on-site
groundwater has exceeded acceptable levels. Monitorinq
additional wells, near the. former lagoon area will indicate if
on-site groundwater conditions are degradinq over time and if
additional action is required to reduce and/or prevent exposure
to those levels. In addition, monitoring the wells furthest
downgradient will indicate whether site-related contaminants may
potentially migrate off-site. The actual number and locations of
monitoring wells that wil~ be sampled will be determined by u.s.
EPA. .
Comment 4:
The PRP disagrees with the MDNR's position that the alternatives
presented in the draft feasibility study fail to comply with Rule
299.5717(3)(1) of the Michiqan Administrative Code (Rule 717(3)
because' it does not provide all of the information required by
the rule. The PRP states that the Rule 717(3) does not require
that all the factors listed in the rule be provided in every
instance; only as appropriate. They state that u.s. EPA .
appropriately determined that an evaluation of an alternative
involvinq active remediation of ~e groundwater was not
necessary. They further argue that Rule 717 (3) is a procedural
rule and therefore is not required to be met fo~ a remedial
action at a S~perfund site. .
Response 4:
u. S. EPA acknowlec:lq.. the comment.
Comment 5:
The PRP diaagrees with MDNR'sposition that Rule 299.5705(6) of
the Michiqan Administrative Code (Rule 705(3» should be'
considered an ARAR at this site and therefore some remediation of
the groundwater which removes the contaminants from the aquifer
must be implemented.
Response 5:
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~
o.S. EPA acknowledqes the comment. In accordance with the April
22, 1991 u.s. EPA Office of Solid Waste and Emerqency Respqnse '
(OSWER) Directive 9355.0-30, u.S. EPA has deterained that because
the contaminant levels in the qroundwater do not exceed federal
safe dri~inq water standards, there is no Unacceptable risk at
this site and, therefore, ARARs are not triqqered. Subsequently,
Rule 299.5705(6) does not apply to this site and remediation of
the aquifer is not required.
Comment 6:
The PRP disaqrees with MONR's position that Michiqan's Act 307
Type A/B standard of 1 ~q/L should be considered. They first
cite the fact that the alternatives considered in the draft
feasibility study were developed to comply with the Type,c
requirements (rather than Type A of Type B) by elimiriatinq site-
specific pathways of exp~sure based upon' reasonably foreseeable
areas of the site and natural resources in ques~ion. Second,
they cite information provided by the Michiqan Department of
Public Health ("MDPH") which indicate that many public water
supply wells routinely contain arsenic levels comparable to those
found at the American Anodco site and much hiqher than the TyPe
A/B standard of 1 ~q/L. Lastly they state that the Michiqan has
hiqh naturally occurrinq arsenic levels, in groundwater in many
areas of the state. They cite an MDPH memo which states, "it i.
unlikely, however, that the qoal of reducinq the maximum observed
arsenic concentration in qroundwater to below 5 ~/L ... can be
achieved. ' - ,
Response 6:
u. S. EPA acknowledqes the comment. At this time o. S. EPA is not
settinq a cleanup standard for the site, because we have
determined that there is not an unacceptable risk posed by the
'site, and, therefore, remediation is not necessary. In reach,inq
our conclusions concerninq the risk posed by the site, MCL's were
used as the standard, ,in accordance with the April 22, 1991 U.S.
EPA Office of Solid 'Waste and Eaerqency Response (ROSNER")
, Directive 9355.0-30. U.S. EPA will continue to .onitor the
qroundwater and a....s the risk posed by the site. As part of
the ass....ent MCLa and/or the risk assessment process will be
used to da~in. if additional action, beyond the liJIi ted
qroundwater aonitorinq, wili be required in the future.
Comments fr01l the General Public:
Comment 7:
One commentor state. that the action already taken by EPA, MONR,
and American Anodco has ,been appropriate and has solved any
contamination problem that existed.
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...
Response 7:
U.S. EPA acknowledges the comment.
Comment 8:
One commentor states that U.S. EPA is using the citizens as
quinea pigs to determine if there are "safe" levels of
contamination. They question why they must wait for further
stu~y and monitoring of the site, and why the previous study was
not sufficient to allow us to come to any decision. They state
that the EPA should act, and not conduct ongoing studies when
there is a possible threat to the health and lives of the
citizens.. . ...
Response 8:.
U. S. EPA disagrees with the commentor. Adequate studies have
been performed at the site to determine what action needs to be
taken. The studies have shown that the site does not pose an
unacceptable risk to the public and therefore we have selected to
take no action here. We do. acknowledge that. the site has ..
impacted groundwater quality in the vicinity of the former lagoon
area, and we are proposing to continue to monitor the groundwater
to ensure that contaminant levels remain at protective levels, .
i.e., below MCLs. If levels increase, above protective levels,
U.S. EPA will evaluate and propose additional actions to ensure
that human health and the environment are protected.
Comments from the State of Michiaan:
Comment 9:
The Mic;higan Department of NatUral Resources ("MOHR") .
conceptually supports the recommended alternative of no action,
with monitorinq of the site. They recognize that the current
language of the Michigan Environmental Response Act (HERA), 1982.
.PA 307 ,as aaended, R299.5705(6) )lay not be consistent with such
a remedy. Bowever, MOHR has already proposed leeJislation to
modify the rule to allow for such conditions as exist at this.
site, vb8r8 it could be technically difficult to remove low level
contualnatloD troa an aquifer. Therefore, they can understand
the EPA -y wish to waive this rule. MOHR must still require
deed re.1:ri~iona be Uaposed until such ti.e as aquifer .
contaminant concentrations fall within HERA criteria. Regarding
the need for deed re.trictions, it ~hould be noted that site.
concentrations of arsenic in groundwater exceed HERA clrinking..
water criteria, and approach the MCL, which is an interim value,
and not yet considere~ final. .
They suggest that at first, review of the site conditions might
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~
indicate that active qroundwater remediation might be
. impracticable. However, it is important in their evaluation of
the alternatives that they be provided site specific information
on the technical feasibility and cost-effectiveness of active
groundwater remediation as required by MERA Rule 299.5717(1).
This could consist of evaluating as simple a system as pumping
from a single extraction well and treating the extracted water..
MDHR has some concerns with u.s. EPA's evaluation of the baseline
risk assessment. They do not like to see u.s. EPA allow
exceedances of the acceptable risk range. They realize that at
this site the point source has been removed, and the qroundwater
contaminant concentrations are continually decreasing, and active
extraction of contamination appears difficult. However, they
would prefer that u.s. EPA acknowledge the risks that exist. at
the site, and require deed restrictions, and monitoring which
continues until the risks become acceptable. Such a plan would
of course include five year reviews.
Response 9:
U. S. EPA disaqrees with the comment or . In accordance with the
April 22, 1991 U.S. EPA Office of Solid Waste and Emergency
Response ("OSWER") Directive 9355.0-30, "Role of the Baseline
Risk Assessment in Superfund Remedy Selection Decisions", U.5.
EPA has determined, based upon a chemical specific standard that
defines acceptable risk levels (i.e., MCLs), th~t this site does
not pose a risk to human health and the environment. Therefore
ARARs are not triggered and Michigan Act 307 and its associated
rules need not be met by the selected remedy. The Agency does
recoqnize that the risk assessment did calculate a risk from
ingestion of the site qroundwater, due solely to the low levels
of arsenic detected there. However this risk is not inconsistent
with risks posed by other drinking water sources in Michigan
which have similar levels of arsenic. Because it has been
determined that there is currently no unacceptable risk posed by
the site, U.5. EPA does not believe it is necessary to impose
deed restrictions on the property. The site will continue to be
monitored, for a period of at least two years, to demonstrate'
that contaminant concentrations will not increase over time. If
that monitoring indicates that concentrations are increasing,
additional actions to address the increasing risk will be
evaluated. Bowever, because this is a no action remedy, five';'
year revi... vill not be required.
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APPENDIX 1: Figures
.'
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" .
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lJ') \1~~~ t""!:-'--'~:\;~!:- . '}, I' ~r(i~::I(~~~~;rr-=C'~'\(,
-~-'- -- o.~.~' -, \.. Jil"" ;,;") \,,~;;1\>~' , '7' '.7y-. ~r:h.( , " '~
1;!/' <~ ' '~J <,;:; -i}t~" <;~. . ~ ~~
-:5} 4' :2: I""';~ ~'v-, ~y~ ~....., Qf~' . . :""~.~~,,/ :~o~t~\
.'; .' .' . ~,' .- '-- -0 .- ,..".,. " . '..;;i'" .:-. ~
.... ~' ~ .a.,. ~ " " '0'. .' .j.
~,',~,~\. , -" ~: i -'~ (' ;;~ ., ',~~~
~, --,'I;, ,- '\~,4 . ,-,-, ~,~'VI ,_...
1:---. . ( 1 ,~ j ,/ :-'.~- / -. ~~" (
-'
~
F1GURE 1
SITE LOCATIOf'J"1\W'
AMERICAN ANODCO, INC.
IONIA, MICHIGAN
o
Takeft
I";"
20GD 3OGO FEET
from tn. Ionio. WidIiIJan. U.$.C.s 7.'
tOt*Jlapllic ~ mao. 1978. ,
1000
ASS ENVIRONMENTAL SERVICES. INC.-
SCAlE
-
SI8 -.-., .. -';" A8NI PIl-""" b..rti4
.."..,.. tII 1118 --- - sa.. ...... ....
-------
f
J
D
18
i
.&H
OW-IOoI
I CJ o"'C:J
<>
L::J
0If- ..
o
Am,ne." Anodeo. Inc.
SA-I". 11SA-11II. ~-IK
& OW-II
OW-lid
"
OW-lit
lEOENJ
llit
...-ue New well
.. II {I EMilling moi1iIOling well
..-.... Soil borlnt/scr..nsd-auger borln9
I .& 6 -'nch production ..11
c . 4 -Inch production ..11
-- former lagoon ar.a
SCAlE
~
o 200
400
.
100 n.
o
FIGURE 1
BASE MAP
AMERICAN ANODCO, INC.
IONIA, MICHIGAN
-------
...
SOUll1
A
.70
American AnOlII:/I
OW-g
ow-a OW-7
k. 5- CRAWl ------"
ow.."
UW.J
650
1 SK~ ~ t
-- ----
---------~------------
--51---------
< ~ CRA\f1.
J 630 l-su
1 S4M)
1 S4MJ
i .10 - S4M)
.
I
590 -
CRAl£t
570
CRAm (_il" cobbl..)
550 @
L!OI!!II)
o
L .'........, ...
I ..,...,............
-1L ..... 1-
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.
- -no
..
s,,'~
Clt4Wt
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A'
-- 670
AttUMIMI.
630
S4M)
- .10
_. 590
SNIIO It ~m
. (orifh c"""'.J
- 570
- 550
Y£RJICAl EICACU£RAIION: !IX
nGURE 3
GEOLOGIC CROSS SECllON A-A'
. AMERICAN A NODCO, INC.
IONIA, MICHIGAN
-------
APPENDIX 2: Tables
, .
-------
'111111
ow-..
OW'"
IIW...
OW...,
OW'"
41__'- AI.'"
"... ~ NL
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ow-u
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OW-.80
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--
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NL
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--
TABLE I
='II....AII V II.' IIII=,II.:III'UII .N..IIIIANII: AHAI.,'SIS
AIIIIIUCAII AHlllx:U.'NC.
''''.. Midoop.
~11I'wJ
I,u.
w........ .......... N.....
..~ -- .!'i..~NL
N.tID
'ULU
.;.
tI. .
...1 .
"I
....
u.. .... 811
...1
1.811
=.-18
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1.1l1li
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NA
----..
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'11
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NA
'1.6'11
II.'IG
11.100
II.""
!!I.IIII
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".!IUII
lUll
U....
U.M
21.100
...
",118
...-
II..
11."
11.100
2UIII
.....
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IV.".'
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lUG'
NA
,..a. ..... n.
IU lUll
"'
111 »'"
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2111 10.11
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6118
"11
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1\... ...... 51.... So..h...lI. v........... :tJ.,
.til .rl ,./1 --~.. .~~:
1.MOII l...u.u'
'.ClUJII U IIClI 1.1110
'.11\0 ita II'" '"
','111 "."11 1
'.6110 II t6.1W1 III
4.100. ''''1111
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UOO 11.11101' JlU nl
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1.0lIl 111.l1li'
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11.II1II 11....,1 "" I"
'..11 ".!IUD' 10111 041
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-------
TABLE 1
.~.
Stl1Ou.J1Y OF aJ!aJL13 FOa oaa.uac ANAL YSJS
AlGUUCAN AHODCO.INC.
108ia. Miaipa
ApriIlt9%
UN1TS
CaIoroforaa
a.JL
1.1.1- Triddol'08U1au
!£.JL
TridaJoroeca...
!£.JL
T.&nc8Jcwoeu....
!£aiI.
Toi....
/&8t!.,
OW-OI
OW -03
OW-04
OW-OS
OW-06
OW-06 19/92)
OW-(J1
OW-OS
OW-~
OW-LOO
OW-IOS
OW -12
OW-13
.OW-13.0\O;:n
-
11
::'tI
3J
21
21
11
Ow -14
OW-ISO
OW-lsS
OW-ISS (Oyp)
OW-16
OW-16 (Ollp)
OW-17
pWC-I
pWC-2
i OFf-Srn: WELLS
OW-llD
OW-llS
OW-180
OW -185
MDNR ACT 3i1i CRrTERIA
Hal&h- 8ueG 6 2m
Aacb8tic NA NA
~ 0 ~
. I FEDERAL MAXIMt1M CONt'AMlNANfLEVEL fOR DRINKING W A1E1l'
~ ~~ ~
I J
2J
11
3 0.7 um.
NA N~ 8IJJ
94 16 110
5 5 l.COD
NOI8I:
L AaaAyt8I ~ ia aD"""",,1iIt8d.
. 2. DuMci =- iadiaaa dial.....,. - ..- - f
. 3. J - Eaimal.eGft1a8. <::1 I~ I11III1 hi eM Mvl.All. ...~ Iimi&
but - ... &b8a &h8 USEPA Caaaws R8qaind 0..,. LimiL
4. ~- ~~CUlS~ lWIIII8rf8aL
S. NA - Noc avaiiabie. .
- 6. MDNR iv:s 3JlI0Cril8ria Soar-= "MEJtA Operlcioaal"'. -- IN; It8witia8 1 -1;p8 8 ~ a....-. MDNR. MardI 16. .1992.
7. Soan:8: 'DriAkiq W.. RquIa&ioaI aad Halda Adl.oiliot..., omc. olW... USEPA. Nowaib8rl99'1. .
9210054. W1CIICR.6J7IS360-07
-------
TABLE 3
-;",
COMPARlSON OF RANGES AND AVDACiE VALUES FOR ON-SITE WELLS
AMEJUCA.'I ANODCO.INC.
lama. MidIipa
, 191111919' ' 1992 .
ON-SrrrWEU.s ON-SITE'WEU.S
No.of I I AVBAGE No. of I I
t:niD S&m~es RANGE ~es ,RANGE A VERACiE
I Aluminum :£giL I 14 I 28.3 t1 - 601 29.3 22 I ND - ND I NO
i , :£;tL I 0 I nOt maiyzed I 22 I 22 U - 38.21 13.1
: A.nWllony
I :£~L I i 28 I I 25.11
I AncIUC 23 1.4U - 10.9 22 2 U - 7.1
I ;£giL I I not maiyzed I I 32..5 I
I Barium 0 22 I U - 21.1
Calcium :£~L I 14 1t.l20 - 141.200 I 114.062 22 I 69.100 ,- 311.000 I 124.217
! Chromium u!lL I 14 I 2.1 U - 31 t.3 22 I 8 U - 11.8 i 4.6
I :£~L I I not uWvzeG I I 5.8 I
, C "bait 0 22 ~U - 2.9
icO)ppet' :£~L I !~ I 2.9 t1 - 61 2.1 22 I ND - NO i NO
I ugiL I I nOt maiy1:ed I I 5.520 I
I Iron, 0 22 39 U - 433
MagnCS1um !£IlL I 14 I 19.890 - 51.8~1 31.951 n 20.200 - 64.900 I, 34.7~
I&WL 0 I nOC maivzeG I n 3 U - 2.910 m
NicUI "WI. 14 17U - 1051 24.0 22 6U - 11.7 14.1
I&IIL I I 14.050 I - 25.400 I
PocuaU&m 14 819 - 4.27'% 22 1.060 U - '.m
Silver ullL ' 0 I noc Ul8lyud I 22 5 U - ul 2..5
Sodium "IlL I 14 2.690 - 7'%.710 I 38.161 22 2.700 U - 112.000 I 44.563
Vaaadium 1&111.1 0 IIOC 8II81yzed I n 3 U - 3..51 1.6
IZiIM: I&s/L I 14 6 - 3.1051 ~ n I 43.4 U - '1.030 I 99.3
Borol1 :£~L I 14 I 100 U - 2.130 I 517 22 I 5 U - t:S60'j 381
I&s/L I 121 . '
Cvuide 14 10 U - 5..5 22' 0.1 U - 6.7 2.1'
"''''-iIo UL 21 0.1 U - 2.3 0.400 22 0.1 U - o.a 0.1
Cb1orid8 III8fL 14 3.9 - 162 79.6 22 1 U - 240 90
NiInIa . NiCri18 aa8L 0 aac III81yDd n 0.01 U - 13.01 2.4
NiInIa .... 1~ 0.$ U - 9.' 3.1 0 aac..,.
Toral "'~"raI" P III8tL 0 aac...,. 13 3.3 - 22 13.4
o-Pb~",h_.. P III8L 14 0.05 U - 9..54 0.10' 0 aac..,.
SIiltal8 aIIfL ' 1~ 33.3 - 230 iOJ 22 1.$ - 610 89
N0888:
I. U - BOO"'" ~ Y8ha. n...u.1bawa ia - iIIIauI8IIC ~..... II.(! " 1id..
2. NO - Noc ....--..
3. A..... ~I-- ... p8I'Coflllld by aiq oarItaIf cbo ~ .I
-------
..:,~
'I
TABLa ..
SlIInmAry of Prairie Creek .
Surface Water aDd ~inua"t RNIIIItc
Surface Water
".alL .
Arsenic
. " ," - ..- - -- - ". - - --- .. ---, ---- .-.------
. .. . .' ~'" ....
'. ' ",.., .
.;. '';:',''''':~$~:- !'.;:~,(~:,~.~,;,><,,:.:.:t:.;. --. ...::>. ""';:':Y",~(':.::- .:.;.~;:.::.',."::,,
. ;. .' .' ~. . '.
.. .
w.. '" . . ,-"",:,~, . .:.~ :::'" .'.'. '.' '-'......w. " . .. ~..' ..;~:::~~.;.. : ~ ~ :'.' ."..,., .. . . ". .) ~:" . .' ... :. '. :'" ...:'. . .
Iron
Manganese
Zinc
<10 <10 <10 <10
484 650 1120 640
59 77 63 65
11 30.9 26.4 36
SecIiment
mg/q
Selenium
ZiDc
1410 1750 1465 1350
3.4 4.2 3.8 3.8
24.5 33.8 27.0 26.4
12 0.06 <0.05 0.15
2.7 3.3 2.8 2.7
4.4 4.8 4.4 4.6
4175 S450 4900 4550
0.8 0.7 4.7 4.1
304 315.5 262.5 241
<2.0 2.6 3~8 <2.0
<0.1 0.2 0.2 0.15
11.1 12.3 13.5 11.5
Aluminum
Arsenic
Barium
~mium
Chromium
Copper
Iron
Lead
Mai1ganese
Nlckel
------- |