United States
Environmental Protection
Agency
Office of .
Emergency and
Remedial Response
EPA/ROD R05-84/002
June 1984
SEPA
Superfund
Record of
Charlevoix Site, Ml (IRM)
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~
TECHNICAL REPORT DATA
(Pleale read Instructions on the revene before completing)
1. REPOAT NO. 12. 3. RECIPIENT'S ACCESSION NO. -
EPA/ROD/R05-84/002
.. TITLE ANO SUBTITLE 5. REPORT DATE -
SUPERFUND RECORD OF DECISION: 06/12/84
Charlevoix Site, MI 6. PERFORMING ORGANIZATION CODE
7. AUTHORISI 8. PERFORMING ORGANIZATION REPORT NO.
e. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EI.EMENT NO.
". CONTRACT/GRANT 1)10.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency "'~ ~~, 'Q('\!')
401 M Street, S.W. 1.. SPONSORING AG~NCY CODE
Washington, D.C. 20460 80C/00
15. SUPPLEMENTARY NOTES
16. A8STRACT
The site involves the city's single municipal well which supplies both the year-
round and summer tourist populations. The well flumes collect ground water and
lake water which are channeled into the system. Levels of TCE and PCE were de-
tected in 1981, and have been gradually rising. Data available indicate that
multiple sources of contamination are likely of historical origin at varying
distances form the well.
The cost-effective Initial Remedial Measure (IRM) selected for this site includes:
provide a safe permanent drinking water supply through conventional treatment of
water from Lake Michigan, and to conduct an RI/FS to evaluate potential sources of
contamination and the hydraulic characteristics of the aquifer. This IRM represents
the First Operable Unit. The capitol cost for the IRM was estimated to be
$1,954,000, with O&M costs of $118,000.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision .
Charlevoix Site, MI
contaminated media: gw
Key contaminants: solvents, VOCs, TCE, PCE
"
19. SECURITY CI.ASS (Tllis Report) 21. NO. OF PAC -
18. DISTRIBUTION STATEMENT
None 38 -
20. SECURITY CLASS (Tllis page) 22. PRICE
None
IPA ,.,'" 2220-1 (Ru. ..-n)
P"EVIOUS EDITION IS oeSOL.ETE
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t)'pe or otherwise subordinate it to main title. Wh~n a report is rr~pared in morc than "nl: YUluII!\:. r~p'at Ihl: fllllllar)' titll:. a~ld ¥\IIIIIU~'
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e.
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Give name(sl in ~'onvcntional order (John R. /)0('. J. Ro/x'" Doc'. c'fe.). list ..uthur's ilffiliilllUII if il .liff~'rs frum .h~' I'l:rfurminj: "'j:ani-
uhon.
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Use the propam element number under which the report was prepared. Subordil1ill~ nUlllber, ma)' be illdu.k" IIIlla"'lIlh.."".
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Include ZIP code.
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16. SUPPLEMENTARY NOTES
Enter information not included elsewhere but useful. such as:
To be published in, Supersedes, Supplements, etc.
11. ABSTRACT
Include I brief (200 words o,'tss) factual summary of the mosl signilkanllnformallon ~'oll!altl'." III Ih,' "'I'ml. It Ih,' fl'p,,'1 ,""1;1111'"
significant bibliography or literature survey, mention II herl:,
Prepared ill cuopl:ratiun wllh. I r;lll,lallllll ,,!', I'r,'wlIl~'" Oil "'"11""'1"\' ,;1.
1'. KEY WORDS AND DOCUMENT ANALYSIS
(I) DESCRIPTORS - Select from the Thesaurus of Engineerinll alld Scielltllk Terms Ihe pruper aulhllllll'.J 1"1111' Ihalldenllfy Ihe majm
concept of the research and are sufficiently specific and predse to be used ;1\ ItIde,\ enlric~ lur "~lalll~lnj:.
(b) IDENTIfiERS AND OPEN-ENDED TERMS. Use identifiers for proJcl:1 nam", cude namcs. e4U1pmeni d~'Ij:nalur" ~'Ic, U\C "11.:n-
ended terms written in descriptor form for those subjects for which no descriptur ellish.
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jority of documents are multidisciplinary in nature, the Primary Held/Group asslgnml:ntl'j will b.: '11l'lII '" di\lIJllin.:, arl'a III' human
endeavor, or type of physical object. The applicationlsl will be cruss.refer.:nced Wllh \\:l'unJary 11,'1.1/(,"'111' a"'j!lIlI1ellh Ihal will f"I1,,~
the primary postingU).
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Denote relusabilit). to the publil: or limitation for reasons uther than \Cl.'urity fur examfllc "f{clca,,' 1;,,1,," ""(1." ('i'c an~ a~;III"hlhl)' ."
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Insenthe total number of pages, including this one and unnumbered page" bUI exclude dl,trlbutiun Ii", " an)'.
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Insert the price set by the National fechnicallnformation Scrvil.'e ur the Government Pnnlltll: Oml.'e, if knuwn.
! PI. 'or", 2220-1 (R.... .-771 (R....,..I
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RECORD OF DECISION
INITIAL REMEDIAL ALTE~NATIVE SELECTION
Si te:
-
Charlevoix Municipal Well, Charlevoix, Charlevoix County, Michigan
Documents Reviewed
I have reviewed the following documents describing the analysis of the
cost-effectiveness of initial remedial action alternatives for the
Charlevoix Municipal Well.
- Focused Feasibility Study, Charlevoix Municipal Well
- Public comments and recommendations
- Responsiveness summary
Description of Selected Remedy
o Construct a buried lake water intake line 1500 feet out
from the present municipal well location into lake Michigan.
o Construct a 2 million gallons per day direct filtration water
treatment plant to provide water supply.
Declarations
Consistent with the Comprehensive Environmental Response Compen-
sation and liability Act of 1980, and the National Contingency Plan
(40 CFR Part 300), I have determined that constructing a lake water
intake line and filtration plant is a cost-effective initial remedial
measure and provides adequate protection of public health, welfare,
and the environment. The State of Michigan has been consulted and
agrees with the approved remedy. In addition, the action will
require future operation and maintenance activities to ensure the
continued effectiveness of the remedy. These activities will be
considered part of the approved action and eligible for Trust Fund
monies for a periOd not to exceed 1 year.
I have also determined that the action has been approved for funding
from the Hazardous Substance Response Trust Fund.
~
.
N: .,.,; ~. ',:
J
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-2-
The U.S. Environmental Protection Agency is continuing its remedial
investigation/feasibility study of the Charlevoix Municipal WeTl to
evaluate potential Sources of con~amination and the hydraulic charac-
~ teristics of the aquifer in order to evaluate potential remedial
actions. If additional remedial actions are determined to be necessary,
a Record of Decision will be prepared for approval of the future
remedial action.
~ I;', Ilfl'L
~ ate I
&~~
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Narrative Summary
Site location and Description
The City of Charlevoix is located on the shores of Lake Michigan in the
northwest section of the lower peninsula of Michigan in Charlevoix Couoty
(see Figure 1). The City's single municipal well supplies potable water
to a year-round population of 3500 which increases to 5.000 during the
summer tourist season. The City requires on an average basis a water
sup~ly of 0.76 MGD (million gallons/day). with a maximum demand of 2.0
MGD during peak periods. The municipal well is located in an urban set-
ting. The primary use of the surrounding area is for residential. re-
creational and commercial purpos~s. A major por,tion of the City's in-
come is derived from tourism. .
The City's muoicipal well coosists of a shallow large-diameter clear well
connected to two 225-foot-long horizontal flumes which are buried under the
beach of Lake Michigan parallel to the shore (see Figure 2 for detail).
The flumes collect groundwater and lake water and channel it into the
well, where it is then pumped into the distribution system. Approximately
half of the water entering the flume comes from Lake Hichigao. and the re-
mainder from shallow groundwater Sources.
History
In September 1981. while conducting tests for trihalogenated methane com-
pounds in the City's chlorinated water supply. the Michigan Department
of PUblic Health (MDPH) detected trichloroethylene (TCE) ranging in con-
centrations from 13 to 30 parts per billion (Ppb) in the Charlevoix water
supply. A monitoring program was started and continued to detect gradually
rising levels of TCE in the raw water intake.
In December 1982, conceotratioos of TCE exceeded 100 Ppb. At that point,
a temporary diffused aeration system was installed in the municipal well
by the City to remove Some of the volatile organic chemicals. The aeration
system is able to remove 30 to 40 percent of the TCE. and it presently holds
the concentration of TCE in the water supply system to below 50 ppb.
Several studies and investigations have been conducted or are underway
in the 'rea. In November 1981, the City of Charlevoix drilled four of
the eventual six monitoring wells that it would install in its effort to
identify the Source and extent of TCE contamination in the aquifer. The
four wells were placed around the City's pump station in hopes of inter-
cepting the TCE contamination and establishing its direction of approach.
It was the sampling results from these monitoring wells (well, T2.
36ppb TCE) that verified the source of TCE contamination as groundwater
in the municipal well.
The EPA Technical Assistance Team (TAT) conducted a hYdrogeologic study
fn June and July, 1982. The TAT developed nfne groundwater monitorfng
wells in the vicinity of the municipal well. Although sampling of the
test wells found varying amounts of TCE. the Source of contamination
could not be located. Also. during the TAT study perchloroethylene (PCE)
was also detected in a number of the monitoring wells. although PCE had
not been measured in the water supply.
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LAkE "'CH,G"N
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22" INTAICE
fLU~:J.. - -
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CITY DISTRIBUTIO.. SYSTfM
PLAN VIEW
l(AN COHCRE TE
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FIGURE 2-
CITY INT AK~ . L~ME
cII"nu VO,x SITE
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4
The Charlevoix Municipal Well was listed as a National Priorities list
site in August 1983.
The U.S. Environmental Protection Agency (EPA) began its remedial inves-
tigation during September 1983. Twelve additional borings were drilled
in gecember 1983. Analysis of water samples taken from these mOnitorin9
wells has located areas of high concentration for both TCE and PCE. The
exact Sources for TCE and PCE are still unidentified, but suspected lo-
cations have been more closely defined by the data from the remedial in-
vestigation (see Figures 3 and 4). 1t is important to point out that al-
though Figures 3 and 4 indicate a definite Source for each contamin~nt, the
contours are interpretive and do not illustrate the fact that in nearly
every test well Some level of contamination from both TCE and PCE was
found. This would suggest that there are multiple Sources at varying dis-
tances from the municipal well.
Since a quantified public health threat had been identified at the munici-
pal well, and precise data on the Source location{s) was not available,
EPA and MDNR decided to prepare a Focused Feasibility Study (FFS) to
evaluate potential remedies for the contaminated water supply, while work
on the remedial investigation continued.
.
Enforcement
There have been no CERCLA related State or Federal enforcement activities
at this site. There have not been any potentially responsible parties
(PRpIS) identified, and cost-recovery actions are not anticipated at
this time. The site has been classified as Fund lead with no responsi-
ble parties. The data available from the RI indicates that there are
likely multiple Sources of contamination, probably of historical origin at
varying distances from the municipal well.
In August 1983, reacting to the continued presence of TCE in the City's water
supply, MDPH issued a Departmental Order (order) to the City. The order
required the City to commit by January 1, 1984 to a definite water supply
alternative to replace or treat the contaminated municipal well. The
issuance of this order coincided with EPAls initiation of a RIfFS. The
January 1984 deadline did not allow sufficient time for EPA to perform
the prerequisite field studies and alternatives evaluation prior to any
Federal funding of a remedial solution to the water supply problem.
A November 17, 1983 meeting between EPA, MDPH and the City produced an
agreement to delay the compliance date of the MDPH order until May 1, 1984
to allow sufficient time for EPA to complete the necessary remedial in-
vestigations. When EPA informed the MDPH in early May .1984 that the FFS
would be completed on Hay 14, 1984 the HDPH decided to adjourn the hearin9
until late June 1984.
Current Situation
TCE and PCE have consistently been found in water samples taken from moni-
toring wells throughout the aquifer. Both of these volatile organic com-
pounds (VOCs) are known animal carcinogens.
-------
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FIGURE J
TRICHLOROETHYLENE CONCENTRATIONS
DECEMBER 1983
CIIAfH EVOIX SlfE
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FIGURE +
PERCHLOROETHVLENE CONCENTRATIONS (PPB)
DECEMBER 1983
CIIAUI.[VOIX Sit E
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-7
Since the initial discovery of the contamination in September 1981 (13-30
ppb), concentrations in the raw water reaching the municipal well h~ve
shown an upward trend with the present raw groundwater supply containing
100 to 200 ppb TCE. Mixing with lake water in the intake flume reduces
this concentration about 50~ and the temporary aeration system installed
by the City in the clear well reduces the concentration an additional
30-40%. As a result, the water in the distribution system has stayed in
the range of 30 to 50 ppb. PCE has not been detected in the water supply
system at the present time. However, based on the preliminary data from
the remedial investigation, it is expected to ~ detected in the municipal
well within the next several months.
At present the City must rely on its single municipal well which is con-
taminated to meet its water needs. The present concentration of TCE in
the distribution system is approximately 45 ppb. Table 1 lists concentra-
tions and associated risk levels for both TCE and PCE.
Ta bl e 1
Measured in Long-Term Cancer Risk Level **
Oi s t r i but i on Health Advisory
System 10-5 10-6
TCE 45 pp b 80 pp b 28 pp b 2.8 pp b
PCE 12 pp b* 20 pp b 7 ppb 0.7 pp b
* Although PCE has not yet been detected in the distribution system, this
concentration is projected based on measured concentrations of PCE in
the monitoring wells near the municipal well.
** These levels were established by U.S. EPAls Cancer Assessment Group.
At the present concentration of contaminants in the distribution system
(see Table 1), the water at the tap presents a 3.3x10-5 risk based upon
EPAls water quality criteria. Since the concentrations in the well have
been increasing and conditions are not expected to remain the same, this
represents the lower bound of risk.
Assuming that the contaminants shown in Figures 3 and 4 move directly
toward the municipal well, eventual peak TCE concentration in the ground-
water will exceed 700 ppb. The peak PCE concentration would be above
300 ppb. Mixing with lake water and the temporary aeration system in the
clear well would combine to reduce those concentrations about 80 percent.
Under these conditions, the water in the distribution system would pre-
-------
B
sent a 2.4 x 10-4 risk according to EPAls water quality criteria. Because
of the uncertainty associated with interpretation of the existing data, the
actual risk could be even higher. .
.
The FFS prepared by EPA in Hay 1984 concluded that the continued deterior-
ation of the municipal well presents an unacceptable pUblic health risk.
As a result, an initial remedial measure (IRM) is necessary to provide
an uncontaminated water SUpply for the City of Charlevoix.
Alternatives Evaluation
Several factors were considered during the evaluation of potential re-
medial alternatives for providing a safe water supply. The first was
cleanup of the Source itself, the actual cause of contamination leach-
ing Into the drift aquifer; second, treatment of the contaminated ground-
water to provide a safe source of potable water; and third, relocation
of the water supply to an uncontaminated Source.
There are several limitations in evaluating,these options:
- lack of precise data on the Source location(s).
- The volume or area of source(s).
- Whether the source(s) is still generating contamination.
- Knowledge of aquifer properties Over a wide area rather
than that provided by individual monitoring wells.
These are significant constraints that will be addressed during the contin-
uing remedial investigation. However, assumptions had to be made in
the FFS to evaluate alternative remedial actions.
Source control was the first approach considered. If it is assumed that
a discrete Source is located within the concentration contours in Figure
3, then the minimum distance of a Source from the intake flume is about
1000 ft. At the velocity the contaminant moves, any action taken at the
Source would not be detected at the clear well for at least 9 years. Such
an approach is unacceptable since levels of contamination in the distri-
bution system would continue to increase over the next 9 years. Con-
sequently, Source control was not considered to meet the objectives of
the IRM, which is to provide an uncontaminated Source of potable water un-
til a final remedial action can be Implemented. The final remedial action
would be implementated within 5 years of taking action.
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9
The evaluation of source control made it clear that for those remedial
options that rely on continued use of t~e contaminated aquifer for"
potable water supply, treatment of the" groundwater would have to con-
tinue for Some periOd of time exceeding 9 years. In order to deter-
mine that time periOd, the area and volume contaminated with TCE and
PCE at levels above the 10-6 risk level were estimated. The direct-
ion and rates of groundwater flow and contaminant movement were then
considered. It was assumed that 5 pore volume exchanges would need
to occur before the aquifer would return to usable conditions. Under
these conditions, 50 years are necessary. This is the minimum number
of years that treatment would have to be provided at the municipal well,
if continued use of the contaminated groundwater for water supply is
considered, since pumping at the well to meet the City's water demand
does not increase the natural rate of groundwater flow.
Alternatives for providing a safe water supply then fell into two cate-
gories: One approach was to develop new sources of water supply. The
other approach relies on treatment of the contaminated groundwater.
During the initial phase of the FFS, the potential remedial options that
had been identified were screened according to the following factors:
1) ability to protect human health; 2) time required to implement; 3) re-
lative cost; 4) complexity; 5) environmental impact; and 6) community
impact. Eight options were considered.
Table 2 summarizes these water supply alternatives and presents the
results of the initial screening process. After the screening, three
alternatives were jUdged to meet the objectives of the IRM and were
evaluated further:
Alternative 11 - Relocate City water supply to a Lake Michigan buried
intake line followed by a 2.0 MGD direct filtration
treatment plant.
Alternative 12 - Treat 2.0 MGD with an air-stripping system at the existing
municipal well.
Alternative 13 - Treat 2.0 MGD with a carbon adsorption syste~ at the
existing municipal well.
All three alternatives have been sized to treat the present maximum day
demand (MOD) of the City. Based on 1983 water use records, the MOD is
2.0 MGO. The annual average day demand (0.76 MGO) has been used to
calculate the annual operation and maintenance costs.
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Table 2
INITIAL SCREtMlNC 0' WATER SUPPLY ALTERNATIVES - Screen In. Criteria
. .
Ability to
Protect
Public TI- Required Relative EnvlrOll8ental Co"'Jnlty Reault of
Al ternaUvea Health to 18pIe8ent Coat C08plexltl l8pac t I.pact Initial Screenlnl
A. No Action Poor "/A Low Low HIA Hllh Hot Acceptable
Mev Supply
H. Lake Nlchl,an Supply Good n 8OI'Itha Moderate tbderate Low Low Conalder further
(Intake ) 6-8 80fttha
D. Water FrQ8 Adjacent 'acUlt, Good 9 8Onth. Moderate Hlah Low Moderate Ell8lnated
8. New well 'Ield Good 1 year Moderate Hlah Low Moderate Ell8lnated
C. Bottled Water Moderate 1 80nth Hllh Hllh tow Hllh Ell8lnated
Uae blattn, "'11 Supply
E. Haae Treat8ent De.lcea Moderate 4 aontha Hlah Hllh tow Hlah Ell8lnated
C. Air Strlppln, Good 5-6 IIOI'Itha Moderate Hlah Low Low Conalder further
,. Carbon Adaorptlon Good 5-6 80fttha tbderate Hlah Low low Conalder further
CLT441/U
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11
The large difference in demand between seasons is due to the summer influx
of seasonal residents.
The costs for each alternative have been evaluated for both 5 and 59 years.
It has been assumed that 5 years will be required to implement the final
remedial action. Treatment of the contaminated groundwater would have to
continue for 50 years before the aquifer could be considered usable.
.
Alternat i ve 1:
Alternative 1 is designed to supply the MDD of 2.0 MGD by pumping water
from a buried screen intake 1.500 feet offshore'in Lake Michigan. The
intake screen would be backfilled with select grade granular material.
The buried lake intake would provide some filtration and result in a
reasonably low turbidity raw water supply.
The treatment configuration for the surface water would consist of chemical
addition and flocculation followed by gravity filtration and chlorination.
Table 3 summarizes the costs for this alternative.
Ta bl e 3
Cost for Lake Michigan
Surface Water Plant
Capital Cost
Annual 0 & M
$1.954.000
$
118.000
5-year Present Worth
50-year Present Worth
$2.395.000
$3.068.000
Alternative 2:
Alternative 2 consists of constructing an air stripping tower at the
existing municipal well site to treat the contaminated groundwater
before it reaches the distribution system. The effluent from the air
stripping tower must be at or below 2.8 ppb for TCE and 0.7 ppb for
PCE. These concentrations will ensure adequate quality for potable use.
Based on the estimated movement of the contaminant plumes and the pro-
jected TCE and PCE concentrations in the raw water supply the required
removal rates are 99 + %.
Since air stripping is designed to remove VOCs from water by transferring
them to an air stream. this alternative would create a Source of air
emissions. Michigan State law requires that any new Source of volatile
organic compounds be treated with Best Available Control Technology.
This rule is incorporated in the State Implementation Plan prepared in
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12
compliance with the Clean Air Act and is a Federally enforceable State
environmental requirement.
Treatment of the tower vapor exhaust for removal of VOCs would be accom-
plished with a nonregenerable carbon a~sorption system. A nonregenerable
system has been selected because it is less complex and the costs compared
to regenerable are relatively equal. Table 4 gives the cost information
for this alternative.
~~e4
Treatment at Existing Water Supply
with an Air Stripping System
Capital Cost
Annual 0 & M
$1.304.000
$166.100 to 361.000
5-year Present Worth
$2.329.500
$4.034.800
50-year Present Worth
There is a range for annual 0 & M costs because the influent TCE and
PCE concentrations, which affect the 0 & M costs. will vary each year
as the contaminants migrate and are purged through the municipal well.
Alternative 3:
Alternative 3, like Alternative 2 relies on treatment of the contaminated
groundwater at the existing municipal well to potable quality. Alter-
native 3 utilizes a carbon adsorption system to remove the VOC contamina-
tion. The carbon system would consist of four carbon columns arranged in
two parallel duplicate flow streams. Two columns are used in each flow
stream so that the carbon in the lead column can be fully exhausted. which
optimizes carbon usage. On the average, carbon in one of the columns would
have to be replaced every 4 to 5 months. The costs for Alternative 3 are
summarized in Table 5.
~~e5
Treatment at Existing Water Supply
with a Carbon Adsorption System
Capital Cost
Annual 0 & M
5-year Present Worth
50-year Present Worth
$1.815,000
$120,000 - 275,000
$2,590,000
$3,934,000
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13
~~a~:
Each of the three alternatives are tech~ically feasible. All three"
woulg require at least 6 months for implementation and all three were
judged to be equally low in potential for community impact.
When evaluated over the short-term (5 years) the alternatives are
essentially equivalent in cost. When" the need fpr continued long-term
(50 years) treatment of the groundwater after implementation of source
control measures is considered. assuming that groundwater would provide
the water supply. Alternative 1 is least costly. Each alternative would
provide the City enough water to meet the present maximum daily demand
of 2.0 million gallons per day.
Alternative 2 has a greater risk for environmental impact. due to the
potential for the release of VOCs to the atmosphere during the treatment
process. It is the most complex to operate and requires air emission
controls.
Alternative 3 also would be complex to operate; monitoring is required
to predict contaminant breakthrough in the carbon beds.
Alternative 1 is considered a conventional form of water treatment. lake
Michigan provides a constant. dependable source of drinking water and
operation of this facility would not present any complex operational
problems. All alternatives are designed to adequately protect public
health. However. Alternative 1 might provide the greatest protection
since Alternative 2 and 3 may still have detectable levels of VOCs
in the water after treatment. Consequently. Alternative 1 is recommended
as the most cost-effective remedial action.
~mmary of Costs
Alternative 1 Alternative 2 Alternative 3
Capital Cost. $ 1.954.000 1,304.000 1,815,000
Annual ° & M, $ 118,000 166,100-361,000 120,000-275,000
5-year Present Worth, $ 2,395,000 2,329,500 2.590,000
50-year Present Worth. $ 3,068,000 4,034,800 3,934,000
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14
Community Relations
Copies of the FFS were made available to the community on May 14, 1984.
Three 1 DC at ions served as repos it ori es with j n the City: Cha r 1 eyoix City
Hall, District Health Department No.3 and the Charlevoix Public l1.brary.
The EPA issued a press release on May 14 which announced the ayailability
of tne study and the commencement of the 2-week pUblic comment period.
EPA also placed an advertisement in the Charlevoix Courier regarding the
pUblic Comment periOd and schedule for a publlC meetlng.
The public meeting was held on May 22, 1984 at the Charlevoix City Hall.
Approximately 30 residents attended the meeting. Representatives
of the EPA, MDNR, MDPH and local government were present. The EPA
presentation explained the purpose of the FFS, described the current
situation regarding contamination of the aquifer, and the alternative being
recommended by EPA. Questions regarding the project were also answered.
The public Comment periOd ended on May 29, 1984. .The responsiveness
summary is attached to this Narrative Summary.
Consistency With Other Environmental Laws
The proposed action will not require on-site treatment, storage or
disposal of hazardous wastes. Therefore, there are no issues involving
the consistency of on-site actions with RCRA.
The air stripping alternative would create an air emission of VOCs.
These emissions would be treated to remove the pollutants before
being discharged. This would comply with the provisions of the Michigan
State Implementation Plan.
Construction of the lake water intake line component of Alternative 1
will require a permit under the State's Great Lakes Submerged Lands Act,
and Department of the Army permits required by Section 10 of the Rivers
and Harbours Act and Section 404 of the Clean Water Act. The City of
Charlevoix has applied for and been granted these permits for construction
of the lake water intake.
Recommended Alternative
The National Oil and Hazardous Substances Contingency Plan (NCP) [40
CFR Part 300.68(j)) states that the appropriate extent of remedy shall
be determined by the lead agency's selection of the remedial measure
which the agency determines is cost-effective (i.e., the lowest cost
alternative that is technologically feasible and reliable) and which
effectively mitigates and minimizes damage to and provides adequate
protection of pUblic health, welfare, or the environment. Based on
the evaluation of the cost and effectiveness of each proposed alternative.
the comments received from the public and the MDNR, and State. and Federal
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15-.
environmental requirements. Alternative 1 has been determined to be cost-
effective as defined by the NCP.
The recommended alternative is considered an off-site remedial action
(provision of a permanent alternative water supply). as defined in .
section 300.68(e) of the NCP. The objective of the action is to provide
a safe drinking water supply to meet the City's present needs. until such
time that final remedial measures may be implemented. The RI/FS cur-
rently underway will examine appropriate final response actions.
a
,
The capital cost of this alternative is estimated to be $1.954.000. The
operation and maintenance costs are estimated to be $118.000 per year.
The 5-year present worth value for the selected alternative is $2.395.000.
We recommend that EPA fund 90 percent of the 0 & M costs for a periOd
not to exceed one-year after completion of construction. The City of
Charlevoix will provide the 10% 0 & M match for the first year and then
aSSume all 0 & M costs for the life of the project.
Schedul e
The Omaha District of the U.S. Army Corp of !ngineers (COE) will manage
the design and construction of the remedial action under an Interagency
Agreement (lAG) with EPA.
Under an existing lAG for technical support during the FFS. EPA tasked the
COE to conduct a technical review of plans and specifications for a lake
water intake structure that the City of Charlevoix had previously prepared.
This review has been completed and the COE has concluded that with minor
design changes and modifications to the bid package. the COE can use this
design to advertise and award a construction contract for the intake struc-
ture. The schedule for this activity is as follows:
Approve Remedia 1 Act ion ('s i gn ROD)
6/8/84
6/8/84
Award Superfund State Contract
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f6
lAG with Omaha District COE
6/8/84
6/13/84
COE assembles specifications front
end and makes design revisions
~OE completes design/specification
revisions
6/29/84
Notice to Bidders
7/2/84
.
Advertise for Competitive Bids
7/10/84
8/9/84
Bid Opening
Contract Award
8/21/84
9/3/84
Notice to Proceed
Estimated Construction Period
90 days
At the same time that procurement of a contractor for construction of
the intake structure is taking place the COE will initiate procedures
for selecting an Architect/Engineering firm to prepare a design for
the direct filtration treatment plant. The plant facilities could
be completed and ready for startup within 15 months after starting
the design.
Future Actions
A RI/FS is underway. The Phase 1 drilling program in the remedial in-
. vestigation has more closely defined a probable area where the source(s}
of contaminants are located. Phase II work will begin within one month.
Phase II will include soil borings and possibly additional monitoring
well installation in the suspected source location. The feasibility
study should be completed by fall 1984.
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-~tO 5r""
oJ" l' oS'
i ~ i
%~t1~
'\ ~. ~
.. of(
~, PRO,tc,
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
RE.GION v
230 SOUTH DEARBORN ST.
CHICAGO. ILLINOIS 60604
REPLY TO ATTENTlC
JW 1 2 1984
Mr. Gary E. Guenther
Deputy Director
Michigan Department of Natural Resources
P.O. Box 30028
Lansing, Michigan 48909
Dear Mr. Guenther:
&
Enclosed is an executed copy of the Superfund State Contract for an Initial
Remedial Measure at the Charlevoix Municipal Well Site, Charlevoix, Michigan. .
The U.S. Environmental Protection Agency has detenmined that constructing a
Lake Michigan intake line and direct filtration water treatment plant at
Charlevoix is a cost-effective initial remedial measure which will limit
the threat of exposure from a significant health and environmental hazard.
The documentation supporting our decision is enclosed.
We look forward to working with you to implement this initial remedial measure
at Charlevoix.
Please call me if you have any questions.
Sincerely yours,
v.f:f:f:;- (~
Regional Administrator
Enclosures
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.
SUPERFUND STATE CONTRACT FOR AN INITIAL REMEDIAL MEASl)qE
AT CHARLEVOIX MUNICIPAL WELL SITE BETWEEN THE STATE OF
MICHIGAN AND THE U.S. ENVIRONMENTAL PROTECTION AGENCY
A~
Authority
This Contract is entered into pursua~t to Sections 104(a)(1).(c)(2).(c)(3).
and (d)(l) of the Comprehensive Environmental Response. Conpensation.
and li abil i ty Act of 1980 (CERCLA), 42 U..5.C. 9601 !!. gg.
B.
Purpose
1.
This Contract is an agreement between the United States Environnental
Protection Agency (U.S. EPA) and the Michigan Department of Natural
Resources (MDNR) on behalf of the State of Michigan (t~e State) to .
undertake an Initial Remedial Measure (IRM) at the Charlevoix Municipal
Well (site).
2.
Attached is Appendix A and incorporated herein is a description of the
site.
3.
Attached is Appendix B and incorporated herein is a Statene~t of Work
(SOW) to be performed under this Contract. This Contract May be anenderl
if the parties agree to undertake additional remedial action beyond the
scope of the SOW.
4.
The purpose of this Contract is to delineate the responsibilities of
the parties and provide the assurances required by CERCLA.
5.
C.
This Contract will become effective upon execution by t~e State and
U.S. EPA and shall remain in effect until completion of activities.
described in the SOW including the State's assurances for all future
operation and Maintenance (O~).
Part i e s
1.
This Contract is entered into by the U.S. EPA and the MDNR. MDNR has
the legal authority to enter into and to fulfill the terMS of this
Contract on behalf of the State as certified hy the Governor.
U.S. EPA has designated Jack kratzmeyer, Environmental Scientist and
Federal On-Scene Coordinator, 230 South Dearborn Street, Chicago,
Illinois 60604, (312) 886-1435 to serve as Regional Site Project Officer
(RSPO) of this Contract. .
2.
3. The State has designaten Thrasos Eftaxiadis, Geologist. MDNR,
Groundwater Ouality Division. Remedial Action Section. P.O. ~ox 30028,
Lansing, Michigan 48907, (517) 373-9892 to serve as Project Coordinator
for this Contract.
4.
The Regional Site Project Officp.r in consultation with the State
Project Coordinator is authorized to make necisions that do not enlarge
the scope of the SOW or increase the cost of the project.
-------
D.
.
Eo
F.
G.
2.
-2-
u.s. EPA ResponSibilities
1.
In addition to its obligations in paragraph G, U.S. EPA shall arrange
for the services of a contractor to perform Task I in the sow. U.S.
EPA shall, at its own cost and expense, furnish the nece~sary personnel.
materials, services, and facilities to perform its other responSibilities
under this Contract.
2.
u.S. EPA shall consult with the State on matters relating to the
implementation of the work described in the SOW.
State Responsibilities
1.
In addition to its obligations under Sections G and I, t~e State shall
at its own cost and expense, furnish the necessary personnel, materials.
services and facilities to perform its responsibilities under this
contract. None Of the expenses incurred by the State in performing -
these other responsibilities will be paid for or be reimbursed froM
the Hazardous Substance Response Trust Fund established by Section
221 of CERCLA, nor counted toward any cost-sh~ring requirenents under
this contract or any future contracts or cooperative agreements relating
to this site.
..
2.
The State to the extent of its legal authority will assure that any
state and local permits that are necessary to implement the activit;-
described in the SOW are obtained and shall assist U.S. EPA in obta
any Federal permits.
IMMe~iate ReMoval Action
The terms of this contract shall not restrict any imMediate removal
activities conducted pursuant to the National Contingency Plan, 40 CFR,
Part 300.65. The U.S. [PA, in consultation with the State, can suspend
the activities described in the SOW during any imMediate removal actions.
Payment
1.
u.S. EPA shall pay 90 percent of the total capital costs of those actions
described in the SOW. The Director of the MDNR, by his signature to
this contract, hereby assures that the State shall pay 10 percent of
the costs of those actions described in the SOW.
The estimated total capital cost of the initial remedial measure,
which includes Task I only, as reflected in the SOW is 1.954 million.
The State share of this estimated cost is $195,400. The cost of the
actions in the SOW shall not exceed $1.954 million unless this Contract
is aMenderl pursuant to Paragraph R. Any such amendment shall provide
payment terms for the State's additional cost share.
-------
.
-3-
3.
The State shdli-P8Y its full estimated share within 60 days after
execution of this contract.
4.
When the IRM is co~plete. the final cost will be determined by U.S. EPA
and any refund by U.S. EPA to the State or additional payment by the
State to U.S. EPA will be made within 90 days of such final cost deter-
mination.
5.
All payments shall be made payable to U.S. EPA and sent to:
U.S. EPA
Accounting Operations
p.O. Box 2971
Washington. D.C. 20013
Attention: Collection Officer
Kevin Brittingham.
Room 3419M
for Superfund
PM-226
H.
Off-Site Storage. Destruction. Treat~ent or Disposition
No off-site treat~ent. storage or disposal is anticipated as part of this
contract. However in the event that the State and U.S. EPA enter into an
agree~ent to take additional remedial 'actions for which off-site treatnent
and disposal is required, the State shall provide the assurances required
under CERCLA Section 104(c)(3)(8).
I.
Operation and Maintenance (O~~)
1.
Pursuant to CERCLA Subsection 104(c)(3)(A), to the extent perMitted by
law, the State shall provide all future O~~ of the re~edial actions
for the expected life of such actions. However the U.S. EPA will
provide 90% of the cost of the first year O&M in accordance with item
2 of this section. The State will secure the necessary funds fro~ the
City of Charlevoix to perform its obligations under this Contract, or
in the event that the City defautts the State will make every applicable
request to the legislature to secure adequate funds to perform its
obligations. MDNR will promptly notify U.S. EPA if the City defaults,
and the legislature fails to appropriate adequate funds to meet MDNR's
0&~1 responsibi lities.
2.
Pursuant to cu rrent Superfund pol i cy, as referenced in the "State
Participation in the Superfund Remedial Program" rlocument. February,
1984, at the completion of Tasks I of the SOW, MDNR and U.S. EPA shall
enter into a cooperative agreement whereby the U.S. EPA shall pay 90%
and the State shall pay 10% of the costs associated with the firs~
year of O&M for the IRM.
J.
Future Payment
If U.S. EPA and the State agree to take remedial action in addition to the
actions descrihed in the SOW. the State shall contribute 10 percent of the
cost of such remedial action.
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Ie
, -4-
Personnel Safety
U.S. EPA or its contractors shall develop and oversee the impl~mentation
of the site safety plan.
L.. Access to the Site
c
M.
N.
o.
.
1.
The State to the extent of its legal authority shall secure access
to the site for U.S. EPA or its contractors to complete the actions
described in the SOW.
2.
With advance notice and the approval by the RSPO. representatives of
the State shall have access to the site to review work in progress.
U.S. EPA shall not be responsible for any harm to any State representative
or other person arising out of. or resulting from any act or omission.
by the State in the course of an on-site inspection.
3.
4.
The State shall not be responsible for any harm to any U.S. EPA
representative or other person arising out of. or resulting from any
act or omission by the U.S. EPA in the course of an on-site inspection.
Availability of Information
1.
At U.S. EPA's request. the State shall make available any information
in its possession concerning the site. pursuant to State law. If sai
information was submitted by the State under a claim of confidentialh",
said information shall be treated in accordance with 40 CFR 2. Absent
such a claim. U.S. EPA may make said information availahle to the public
without further notice.
2.
At the State's request and in ~ccordance with Federal law. U.S. EPA
agrees to share information and reports developed as part of its
responsibilities under this contract. The State agrees not to release
any information or reports prepared pursuant to this contract to the
public. unless approved by both U.S. EPAls Region V Office of Regional
Counsel and the State Project Coordinator. .
Community Relations Plan
U.S. EPA and the State have jointly developed a Community Relations Plan
which U.S. EPA shall implement in carrying out the SOW.
Third Parties
1.
This contract is intended to benefit only the State of Michigan and
U.S. EPA. It extends no benefit or right to any other party.
U.S. EPA does not assume any liability to third persons for losses due
to bodily injury or property damage that exceeds the limitations
contained in the provisions of 28 U.S.C. Sections 1346(b). 2671-2680.
To the extent permitted by State law. the State does not assume liabil
to any thi rd persons for losses due to bodi ly injury or property damagp..
2.
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P.
Q.
.
.' -5-
Negation of Agency RelationShips
Nothing contained in this Contract shall be construed to create, either
expressly or by implication, the relationship of agency between U.S. EPA
and the State. Any standards, prqcedures or protocols prescribed in
~ this contract to be followed by U.S. EPA contractors during the perforn~nce
of its obligations under this contract are for aSsurance of the quality
of the final product of the actions contemplated by this contract, and
do not constitute a right to control the actions of U.S. EPA. U.S. EPA
(including its employees, agents, and contractors) is not authorized to
represent or act on behalf of the State in any matter relating to the
subject matter of this contract, and the State (including its employees,
agents and contractors) is not authorized to represent or act on be~alf
of U.S. EPA in any manner relating to the subject matter of this contract.
Enforcement and Cost Recovery
1.
U.s. EPA and the State agree that, with respect to the claims which
each may be entitled to assert against any third persons (herein
referred to as the "responsihle party", whether one or more) for
reimbursement of any services, materials, monies or oth~r thing of
value expended by U.S. EPA or the State for response activity at the
site described in this Contract, neither U.S. EPA nor the St~te will
enter into a settlement with or initiate a judicial or administrative
proceeding against a responsible party for the recovery of such sums
except after having given notice in writing to the other party to this
Contract not less than (30) days in advance of the date of the proposed
settlement or commencement of the proposed jUdicial or arlministrative
proceedings. Neither party to this Contract shall atte~pt to nego~iate
for or collect reimhursement of any response costs on hehalf of the
other party, and authority to do so is hereby expressly.negated and
deni ed.
2.
U.S. EPA and the State agree that they will cooperate in and Coordin~te
efforts to recover their respective costs of response actions taken at
the site described herein, including the negotiaton of settlement and
the filing and management of any judicial actions against potentially'"
responsible parties. This shall include coordination in the use of
evidence and witnesses available to each in the preparation and presen-
tation of any cost recovery action, excepting any documents or information
which may be confidential under the provisions of any applicable State
or Federal law or regulation.
U.S. EPA and the State agree that any judicial action taken by either
party pursuant to CERCLA against a potentially responsible party for
recovery of any sums expended in response act ions at the site des.cri bed
herein shall be filed in the United States District Court for the
Judicial District in which the site described in the Contract is located,
or in such other Judicial Districts of the United States District Courts
as may be authorized by Section 113 of CERCLA, and agreed to in writing
by the parties to this Agreement.
3.
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.
-6-
4.
Signature of this Contract does not constitute a waiver of U.S. EPA'~.
right to bring an action against any person or persons for liahility
under Section 106 or 107 of the Conprehensive Environmentai Response,
Compensation, and liability Act (CERClA), or any other statutory
provision or common law. -
.
R.
Amendments
Any modifications to this Contract must be agreed to, in writing, by both
parties.
S.
Resolution of Disputes
1.
Any disagreements arising u~der this Contract shall be resolved to the
extent possible by the U.S. EPA Regional Site Project Officer and the.
State Project Coordinator.
If any such disagreement cannot be resolved by the U.S. EPA Regional Site
Project Officer and the State Project Coordinator, it shall be referred
to the Regional Superfund Director for a final resolution in accordance
with the requirenents of Subpart l of 40 CFR Part 30. ~or the purposp.s
of resolving disputes under this Cbntract, the Director is the dis-
putes decision official provided for in Subpart l.
2.
3.
The decision of the disputes decision official will constitute the fi
agency action unless MDNR files a request for review of that decision
with the Regional Administrator, U.S. EPA, Region V in accordance with
the require~ents of Subpart l of 40 CFR Part 30.
4.
If the Regional Administrator confirms the decision of the disputes
decision official, MDNR may seek review from the Assistant Administrator,
OSWER, U.S. EPA, in accordance with the requirements of Subpart l of
40 CFR Part 30.
T.
Termination of the Contract
1.
The parties may enter into a termination agreement which will estahlish
the effective date for the termination of this Contract, the basis for
settlement of termination costs and the anount and date of any sums due
either party. Such settleMent costs will include all project costs
incurred, as well as any close-out costs.
If at any time during the period of this Contract, performance of either
all or part of the work described in the SOW is voluntarily undertaken,
or undertaken for any other reason by persons or entities not party to
this Contract, this Contract will be modified or terminated as appropriate
to allow these actions and, upon modification or termination, shall
relieve the parties of further duties to perform those actions undertaken
by persons or entities not party to this Contract.
2.
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-7-
3.
This Contract re~ains in effect until 311 activities describ~d in the
SOW have heen co~pleted.
In witness whereof, the parties here~o have exe:"ted this Contract in two (2)
Copies. each of which shall he d~en~d an o~igin3l.
.
UNITED STATES ENVIRONMENTAL PROTECTION AGE~CY
tU~~(~
Regional Admin'strator
Date
b~f
.
MICHIGAN DEPARTMENT OF NATURAL RESOURCES
Date
ftjrl
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AHACHMENT A
Site Description:
Charlevoix Municipal Well
The City of Charlevoix is located in Northern Michigan in Charlev01x County on
the shores of Lake Michigan. The City's single municipal well supplies potahle
water to a year-round population of 3;500 which increases to 5,000 during the
SUMmer tourist season. The City requires on an average basis a water supply
of 0.76 MGD (million gallons/day), with a maximum demand of 2.0 MGD during peak
periods.
The City's municipal well consists of a shallow, large-diameter clear well
connected to two 225-foot-long horizontal flumes that are buried under the beach
of Lake Michigan parallel to the shore. The flumes collect groundwater and lake
water and channel it into the well, where it is then pumped into the distri-
bution system. Approximately half of the water entering the flume comes from
lake Michigan, and the remainder from shallow groundwater sources.
&
In September 1981, the Michigan Department of Public Health (MDPH) detected
trichloroethylene (TCE) ranging in concentrations from 13 to 30 parts per
billion (ppb) in the Charlevoix water supply. A monitoring program was hegun
and continued to detect gradually rising levels of TCE in the raw water intake.
In December 1982, concentrations of TCE exceeded 100 pph. At that point, a
diffused aeration system was installed in the caisson to remove some of the
volatile organic chemicals. The aeration system is able to remove 30 to 40
percent of TCE, and it presently holds the concentratiion of TCE in the water
supply system to below 50 ppb.
The site was placed on the National Priorities List dated August 1983. U.S. E~"~
Region V began a remedial investigation and feasibility study at the site in
September 1983. At that time data avail~hle from monitoring wells installed
by EPAls Technical Assistance Team (TAT) indicated that the ~quifer conta~ination
was wide-spread and at low levels, which suggested multiple sources of contami-
nation. Since a quantified public health threat had been identified at the
municipal well, and precise data on the source location(s) was not availahle,
Region V EPA and MDNR decided to prepare a Focused Feasibility Study (FFS) to
evaluate potential remedies for the contaminated water supply, while work on
the remedial investigation continued. The analysis contained in the May 198j ,
FFS forms the basis of the initial remedial measure (IRM) funding request. '
The National Contingency Plan states that IRMs can and should begin if they are
determined to be feasible and necessary to limit exposure or threat of exposure
to a significant health or environmental hazard, and if they are cost-effective
(40 CFR 300.68(e)(1). Based on the conclusions of the endangerment assessment
contained in the FFS, Region V EPA and the Michigan Department of Natural
Resources (MDNR) believe that the present levels of TCE (40 ppb) in the municipal
well represent exposure to a significant health hazard to the residents of the
City of Charlevoix, that requires an IR~ as described in the Statement of Work
(Attachment B).
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ATTACHMENT B
Statement of Wor~:
Charlevoix Municipal Well
. .
1M,;)" t
- Construction of a Surface Water Direct Filtration Treatment Plant.
The CO~ponents would be designed to treat the present maxiMUM day
demand (MDD) flow rate of 2.0 MGD. The major components and processes
are listed below:
.
o Raw water lake int~~e
o low service raw water pumps
o Che~ical feed system
o Rapid mix tank
o Flocculation basins
&
o Gravity Filters
o
Bac~wash pumps
o
Finished water pumps
o
lahoratory
o Clear well storage
o Operations and Maintenance huilding
The construction will be phased. Phase I will consist of constrlJction of the
buried intake and in-line chlorination. The chlorine contact/clear well storage
reservoir and the unit processes required for the direct filtration plant
would be constructed as Phase II. The total capital costs including engineering,
legal, administration and contingency costs is $1,954,000.
First year operation and maintenance (O~n costs will be covered under a
cooperative agreement between the State and U.S. EPA, at the co~pletion of ,:
construction of the IRM. Annual O&M costs are estimated to be $118,000.
The U.S. Army Corps of Engineers (COE) will manage the design, construction
and related activities for the remedial action described in the SOW. The COE
project activities are valid remedial response costs and therefore are subject
to the cost sharing requirements of CfRClA Section 104{c}(3). The State shall
contribute 10 percent of the cost of the COE's services during design and
construction of the remedial action described in the SOW. When the final costs
for the COE's services have been determined, this Contract will be amended
pursuant to Paragraph R. Any such amendment shall provide payment terms for
the State's additional cost share.
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COMMUNITY RELATIONS RESPONSIBILITIES SUMMARY
CHARLEVOIX.MUNICIPAL WELL
CHARLEVOIX, MICHIGAN
INTRODUCTION
This .Community Relations Responsivness'Summary" documents citizen concerns
and 1ssues raised during the planning and preparation of the focused feasi.
bi1ity study for initial remedial measures at the Char1evoix Municipal Well,
Char1evoix, Michigan. It also documents, for the public record, the U.S.
Environmental Protection Agency's (USEPA) response to the comments presented
during the public comment periOd on the focused 'feasibility study.
CONCERNS RAISED DURING THE COMMENT PERIOD
The focused feasibility study (FFS) was completed on May 11, 1984. Copies
of the FFS were made available to the community on May 14, 1984. A public
meeting was held at the Char1evoix City Hall on May 22, 1984, to present
the FFS and solicit public comment. The public comment period closed on
May 29, 1984.
.
Approximately 30 residents attended the public meeting. After the Agency's
presentation, 5 attendees made public statements regarding the proposed
alternatives. The Agency subsequently rece1ved 4 written statements regarding
the proposed initial remedial measures. Written comments include letters
from the District Health Department No.3, the Michigan Department of Public
Health and two area residents.
ISSUE:
Feasibility of Drilling New City Wells
A number of residents expressed dissatisfaction with the City's test well
drilling program and EPA's decision to eliminate this alternative from
further consideration during the initial screening phase of the FFS.
1. COMMENT: The City did not conduct the test well drilling program properly.
RESPONSE: Early on in the preparation of the focused feasibility study,
when the initial list of potential remedial actions for water supply was
developed, drilling new wells in the uncontaminated limestone aquifer
was thought to be a highly feasible option. For this reason, the City
initiated an exploratory drilling program 1n hopes of locating an area in
the aquifer where new production we11s cou1d be developed. Both the
quantity and quality of water from groundwater sources must be considered
when making decisions about the suitability of a groundwater-based water
supply.
I .
The City drilled 17 test wells at 10 different .sites on both the north and
south sides of town. USEPA was not involved in the planning or execution
of the drilling program. However, we have reviewed a preliminary report
prepared by the City on the results of the test well drilling, and have
concluded that none of the well sites developed are suitable for water
supply, considering yield and/or quality requirements.
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.2
Based upon the available test well data, a city water supply totally
derived from groundwater would require installation of a minimum.
of 8 to 10 wells. Some of these wells would require treatment including
iron removal, sulfate removal, and Softening to meet State water quality
standards. Operation of this system wou1d be difficult because of the
scattering of well fields and possible treatment facilities required.
Considering the results of the City's drilling program in the context of the
FFS and the evaluation of remedial actions for water supply, we do not believe
further well exploration should be undertaken. The Agency relied on the best
professional jUdgment of geologists employed by EPA and its consultants in the
development of the alternatives. In our jUdgment, there is no advantage to
continuing well exploration, which would delay implementation of a solution
to the water supply problem and prolong the exposure to TCE and potential PCE
contamination, when a plentiful supply of high quality water is readily available
from Lake Michigan. .
8
Because of the uncertainty associated with development of a new city water
supply and the complexity of operating and maintaining several wells scattered
around the city, this alternative is considered an undesirable solution to
the City's water supply problem. Our estima~e of the 5-year present worth
cost for drilling new city wells was $3.5 million, approximately 30% more
costly than the recommended surface water supply.
ISSUE:
EPA Should Evaluate an Additional Alternative
1. COMMENT: A water treatment system that is used in Dosebacka, Sweden,
would be an effective method to provide potable water for Charlevoix.
z.
RESPONSE: The Agency considered a full range of alternatives to
address the water supply contamination problem during preparation
of the FFS. Early in the process, EPA solicited comments on an
initial list of potential remedial actions from interested Federal,
State and local authorities.
The range of alternatives were evaluated against a screening criteria
that included: 1) ability of alternative to protect the pUblic health;
2) time required to implement; 3) relative cost; 4) complexity; 5)
environmental and community impact. The comments received from the
interested parties were factored into the FFS. Three primary alterna-
tives were identified, which subsequently received a more detailed
evaluation. The FFS concluded that alternative 1, lake Michigan Water
Supply is the cost-effective remedial action. We strongly believe that
there 1s not a need to evaluate additional alternatives to address the
water supply comtamination problem. Such a step would cause needless
delay in the implementation of an initial remedial measure to provide an
uncontaminated water supply. Our position on this issue does not reflect
a value jUdgment on the merits of the water treatment scheme proposed by
the residents. We recognize that there are other feasible alternatives
, .
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3
t.h~t could address the water
Agency is confident that the
technologically feasible and
protection of public health.
supply contamination problem. However. the
recommended alternative (Alternative l) is
reliable and will provide for the .dequate
ISSUE:
Water Supply System Demand Rates
8
1. COMMENT: The maximum day demand (MOD) flow specified in the FFS is
too low. since it does not correlate to actual 1983 water use figures.
;
RESPON~: The MDD of 1.8 mil1io~ gallons/day (MGD) referenced in the
ffS was taken from previous engineering studies prepared by the City.
The FFS incorrectly identified this f10wrate as representative of
1983-84 water system demand rates. In reality. the MOD of 1.8 MGD was
based on 1982 pumping records. The MOPH and the City have both provided
the EPA with the actual pumping records for the water supply system for
1983. We have reviewed those pumping records and agree that
a MOD of 1.8 MGO does not accurately represent the peak demand.
Given the 1983 pumping records. the Agency has revised its estimate of
the existing MDD to 2.0 MGD. .
The MOPH also commented on specific desjgn issues related to Alternative 1.
These comments will be forwarded to the U.S. Army Corps of Engineers (COE).
Omaha. for consideration during the detailed design phase of the project.
CONCERNS RAI~D DURING PRE-MEETING
A pre-meeting was held at the Charlevoix City Hall on May 22. 1984. prior
to the evening public meeting. The pre-meeting was attended by City
officials and the various local. State and Federal agencies that have been
involved in investigating the water supply contamination problem. EPA
outlined for these interested parties the findings of the FFS and described
the recommended remedial action.
Although the City and the MDPH expressed complete support for Alternative 1.
areas of disagreement over specific aspects of this alternative as recommended
by EPA were surfaced. One such area of disagreement concerned the proper ,:
design capacity for the filtration plant. Since the recommended initial
remedial measure involves the permanent relocation of a water supply,
considerations of design and corresponding future capacity needs are
relevant. EPA emphasized that it would only provide funding for capacity
to supply existing population at risk from the TeE contamination. The FFS
defined that capacity as the maximum daily demand based on 1983 pumpage
records. or 1.8 MGO. This number has been revised to 2.0 MGD. The Agency
can utilize the Hazardous Substance Response Trust Fund (Fund) to implement
only those measures found necessary to protect human health and the env1ron-
mente Fund monies are not to be used to pay for expansion or capacity
for future populations.
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. 4
However, this does not preclude the City from paying for increm~ntal capacity
1n excess of the MOD. The City did not indicate to EPA its intentions
regarding the amount of incremental capacity it would seek.
-The City manager indicated that the City had previously done a senSitivity
analysis on plant capacity that had shown that, on a present worth cost
basis, a 2.4 MGD plant was cheaper than a 1.8 MGD plant because of higher
labor costs for the smaller plant. The Cit~ manager was not familiar with
the details of the analysis, however, he fe1t that the analysis was
sufficient to justify EPA's providing funding for a 2.4 MGD design capacity.
.
EPA responded that it would review the study if the City would make it
available before the end of the Comment period. After the close of the
Comment period, the City did provide a 2-page cost summary of the analysis.
We faced several limitations in evaluating the information supplied by the-
City:
- Capital costs for a 2.4 MGD plant had not been prepared by
EPA, so the accuracy of those provided by the City could not
be verified.
- An 8% interest factor was used compared to 101 in the FFS;
lower interest rate favors a higher capital cost project.
- The City's present worth analysis was based on 20 years; the
alternatives in the FFS were evaluated for a 5-year periOd.
A 10ng~r time periOd favors a higher capital project.
The sensitivity analysis prepared by the City focused on the number of
shifts that would have to be run during Summer and winter to meet the
average demand and the resulting personnel cost component of annual operating
costs. The total percent worth cost for a 2.4 MGD plant size is shown
to be lower than that for a 1.8 MGD plant.
This Agency ran two checks on the analysis, using the same assumptions made
by the City regarding operating mode, average demand during summer/winter "
and interest rate and period. In the first check a 2.0 MGD capacity plant
was compared to a 2.4 MGD. The personnel costs for these two plant sizes
do not significantly favor the larger plant, since for both plant sizes the
average winter demand can be met with one shift. As a result, the total
present worth for a 2.0 MGD plant is lower than that for the 2.4 MGD plant.
As a second check, the time period was ,shortened from 20 years to 5 years
(i.e., the basis of cost-effectiveness analysis in the FSS), and a comparison
was made between a 1.8 and 2.4 MGD plant size using the capital and 0 & M
costs in the City's study. In this case, the total present worth cost for
the 1.8 MGD plant size was lower.
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5
Based on our review of the information supplied by the City, we do not
believe that the plant's present worth can be reduced by increa~ing the
capacity from 2.0 MGO to 2.4 MGO.
a
Another area of discussion at the pre-meeting concerned the phased
construction of Alternative 1. The MDPH correctly pointed out that
Phase 1 of construction would not consist of the elements as described
in the FFS. The FFS included construction of the chlorine contact/clear
well storage reservoir as part of the firstlstage of construction, targeted
for completion by November 1984. . In fact, chlorination will consist of an
in-line chlorine feed system that will provide a 3D-minute contact time for
the raw lake water in the intake line. This chlorination system would be
used until the chlorine contact/storage reservoir could be constructed.
The MOPH, during negotiations with the City, had previously approved the
concept of the intake line with in-line chlorination as an interim method
of providing water supply to the City while the remainder of the treatment-
plant was under construction.
However, in discussions at the pre-meeting and in a subsequent Comment
letter on the FFS, the MDPH indicated that the lake Michigan intake line
should not be used until the entire trea~ment plant is constructed. The
MDPH considers the circumstances to be different now, than when the previous
agreements were made. They have decided that the risks to public health
from using unfiltered surface water, with only 30 minutes of chlorine contact
time, are greater than the predicted chronic cancer risk attributable to
concentrations of approximately 40 ppb of TCE in the present water supply
-
The initial remedial measure recommended by EPA consists of both a lake
water intake and direct filtration plant. The reason that construction
will be phased, is because the City had already prepared a detailed design
for construction of the intake line. The COE has reviewed the City's
design and found it acceptable, with minor revisions to the bid package,
for advertisement for a construction contract. The EPA is committed to
completing construction of the entire plant in 15 months and the intake
line portion within in this year's construction season. Our schedule calls
for completion of the intake portion by the end of November 1984, at which..
time lake water would be available to the City. The decision as to when ,.
that water can be used rests with the MDPH, whose responsibility is to
regulate public water supply systems 1n the State.
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ST ATE OF MICHIGAN
$
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'RESOURCES COMMISSION
,. .,-,,,,",5 J ANDEI'ISO,,"
JAMES J BLANCHARD. Governor
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DEPARTMENT OF NATURAL RESOURCES
STEVENS T MASON BUILDING
BOX 30028
LANSING 1.41 ~B909
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STE"",eN F t.lQNSMA
o STEWAR' MVEI'IS.
RAVr.K1ND "OU"ORE
to4ARRV tool WIoo4ITElE''''
May 31, 1984
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Mr. Fred Norling
U.S. EPA, Region V
Remedial Response Branch
230 S. Dearborn Street
Chicago, Illinois 60604
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Dear Mr. Norling:
This is to formalize Michigan's request that the U.S. EPA initiate a lead action
lnitial Remedial Measure (I~~) at the Charlevoix Municipal ~ell Field National
Priority List site. The I~~ action ~ill provide the solution to the potable
water supply needs for the city of Charlevoix. The RI/FS actions at this site
will continue under a U.S. EPA lead and develop the information necessary for
contaminant source control and cleanup.
Sincerely,
.
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~~LJM~
Ronald B. Willson
Remedial Action Section
Groundwater Quality Division
(517) 373-8448
,.
RE'..': cls
cc:
A. Hogarth
R. Johns
T. Eftaxiadis
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