&EPA
United State*
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA,ROD/R05-85/02S
September 1985
Superfund
Record of Decision:
Charlevoix, Ml
(Second Remedial Action, 09/30/85)
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TECHNICAL REPORT DATA
(Plt/ut rttld Instructions on tht rt~trst btfort compltting)
1. REPORT NO. \2. 3. RECIPIEIIIT'S ACCESSIOIIIIIIO.
EPA/ROD/R05-85/025
4. TITLE AND SUBTITLE 5. REPOAT DATE
30 lQRe;
SUPERFUND RECORD OF DECISION 6. PERFORMING ORGANIZATION CODE
Charlevoix, MI (Second Remedial Action)
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
a. PERFORMING ORGANIZATION NAME AND ADDRESS '0. PROGRAM EL.EMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency F;"'" Qf'lr'I
401 M Street, S.w. 14. SPONSORING AGINCY CODE
washington, D.C. 20460 800/00
111. SUPPLEMENTARY NOTES
16. ABSTRACT
The City of Charlevoix is located on the shores of Lake Michigan in Charlevoix'
County. The City's single municipal well supplies potable water to a year-round pop-
ulation of 3500 which increases to approximately 5,000 during the summer tourist
season. In September 1981, while conducting tests for trihalogenated methane compounds,
the Michigan Department of Public Health (MDPH) detected trichloroethylene (TCE)
ranging in concentrations from 13 to 30 ppb in the Char1evoix water supply. Data from
the monitoring program showed gradually rising levels of TCE and perch1oroethylene
(PCE) in the raw water. In June 1984, a Record of Decision was signed which approved an
initial remedial measure (IRM) for an alternate water supply to replace the contaminated
. municipal well. The selected IRM consisted of a Lake Michigan water intake structure
and a water filtration/flocculation treatment plant.
The selected remedial action involves discharging the TCE and PCE plumes, under
natural flow conditions, to Lake Michigan. The aquifer would be use able after 50 years.
During that 50-year purging period, institutional restrictions on the installation of
private wells in the contaminated aquifer will be enforced by local health officials.
In addition, long-term monitoring of the plumes will continue. The estimated annual
O&M costs for monitoring are $17,000.
7. KEY WORDS AND DOCUMENT ANAL.YSIS
~. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
~cord of Decision
"'harlevoix, MI
Conta.r:rinated .1~dia: gw
~ey contaminants: trichloroethylene (TCE),
VOCs, perchloroethylene (PCE)
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (TlJis Rrpo,rl 21. NO. OF PAGES
"',,....,.. 20
20. SECURITY CLASS (ThiS pagtl 22. PRICE
None
!'A ,..... 2220-1 (Rn. '-77)
P"EVIOUS EDITION'S 08S0LltTE
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INSTRUCTIONS
1.
REPORT NUMBER
Insert Ihe [PA report number as il appears on Ihe cover o( Ihe publkalion,
LEAVE BLANK
2.
3.
RECIPIENTS ACCESSION NUMBER
Reserved for use by ea.:h reporl re.:ipienl,
TITLE AND SUBTITLE
Tille should indica Ie dearly and briefly Ihe subje~'1 ~'overa~e uf Ihe r~'porl. and be disl'laynll'rumill.'nily. S..t suhtill." ifu....I, m ""ali.'r
type or otherwise subordinale illo main lille. When It reporr is prepared in mOf\' Ihan un~' volume, f\'",'allh.. primary lill~'. a.ld v.ll:u".'
number and include subtille (or Ihe specific lille,
c.
15.
REPORT DATE
Each reporl shaU carry a dale indicalinl allea51 monlh' and year. Indicale Ihe hasis UII \!ihidl il ";as ,,'le,'I~'d (c'.Il.. .m/c' IIlin"c'. ellllc' III
IIpp'olltll. .,e 01 p,eptlnJlion, elr.),
PERFORMING ORGANIZATION CODE
Leave blank.
..
7.
AUTHOR IS)
Give name(5) in c:onvenlional order (John R. lXN, J. Robal /)0('. ('Ic'.). Lisl aUlhur', anilia..un if il diIT~'rs frumll,., I,,'rfurmina: ,"a:allj.
zalion.
8.
'ERFORMING ORGANIZATION REPORT NUMBER
Insert if performinl orpnization wishes 10 aui", Ihls number.
t.
PERFORMING ORGANIZATION NAME AND ADDRESS
Give name, strcel, cilY, slale, and ZIP code. Lisl no more Ihan Iwo levels of an ura:anilaliunal hirellrdl)'.
10. 'ROGRAM ELEMENT NUMBER
Use the propam elemenl number under whi.:h Ihe report was prepared. Subordillah: numbo.'r' mOl)' be indud.'.1 ill 1101,.'111 h.,,,,,.
11. CONTRACT/GRANT NUMBER
Insert contract or panl number under which reporl w.n prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP c:ocIe.
13. TYPE OF REPORT AND 'ERIOD COVERED
Indicale inlerim rlllll, etc., and i( applicable, dales covered,
14. SPONSORING AGkNCY CODE
Insert appropriate code.
1.. SUPPLEMENTARY NOTES
Enter information not included elsewhere bUI use(ul. such as:
To be published in, Supersedes. Supplemenls, etc.
1.. ABSTRACT
Include a brier (200 WOTdI o,/ell) (actual summary o( Ihe mosl siatnilkanl informaliun ~'unlain~,.1 ill Ih., "'111If1. II Ih., "'Iltlf' nl/llalll' a
sipificanl bibliopaphy or lilenlure survey, menlion il here.
Prepared ill cooperation wllh. Transiatiull ,,", l'rl:"'lIkd al ~'ulIl"I"'h'" ..I'.
17. KEY WORDS AND DOCUMENT ANAL YSIS
(a) DESCRIPTORS. Selecl (rom Ihe Thesaurus o( t::nlineerinll and Scielililk Terms Ihl: pruper aulh..ri/~'d I':"IIS Ihal identify Ihl: majm
concept o( the research and are sufficienlly specific and precise 10 be used as indl:x entries for calalu~lIIl!.
(b) IDENTIFIERS AND OPEN.ENDED TERMS. Use idenlifiers (or projeci nalll.., cude names, ~'''Ulpml:nll''',il!nalors. I:lc, Usc "I>CII'
ended terms wrinen in descriplor (orm (or those subjects (or which no deSl:riplur elli51s.
(c) COSATII'tElD GROUP. rield and poup Issianments are to be tllken from the 1965 ('OSA1'1 Suhj~,~.t ('all'J!CIry Ust, Sin~'C the mil'
jority of documents are multidisciplinary in nature, Ihe Primary l-'ield/(;roup ;lssignmenlh' will be 'I~,.ill., di""J'lin.:, ;"'''01 ..I' hUlllan
endeavor. or type o( physical objeci. The applicationls) will be cro5~-referen~'Cd wilh sc,'undary l,d.I/( ;,.,.,1' ''''I!!"1II1:11\ III:., "'1111'..11....
the primary postinll5),
18. DISTRIBUTION STATEMENT
Denole releasabilit)' to the public or lillliialion (or reasons other than SI:.:urily (or I:Jlample "Rcll:;ls\: t;lIhlllll~'II:' 1';11: allY a.ail;I"ili')' I..
the public, with address IInd price.
"..20. SECURITY CLASSIFICATION
DO NOT submil classified reports to Ihe Nalional Teehnicallnformaliun scrvil:c. '
21. NUMBER OF PAGES
Insert the lolal number o( paaes, includinllhis one and unnumbered pages, bUI eJlelude di\tribuliun li\I, I' any.
22. PRICE
Insert the price sel by the National fechnicallnformation Servi~1: ur the Government Printing Offi~c, if knuwn.
I'A ,..'" 2220-1 (R.... .-77) (R....,..)
..
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RECORD OF D~CISION
REMEDIAL ACTION SELECTION
.
Site Ch3rlev)ix Municipal Well
---- Charlevoix, Charlevoix County, Michigan
Documents Reviewed
This Record of Decision is based on the following documents describing the
analysis of cost-effectiveness of remedial action alternatives for the
Charlevoix Municipal Well site:.'
- Feasibility Study, Charlevoix Municipal Well, Charlevoix,
Michigan U.S. EPA, June 10, 1985
- Remedial Investigation Report, Charlevoix Municipal Well,
Charlevoix, i~ichigan, U.S. EPA, February 7, 1985
Sutm1ary of Remedial Alternative Selection (attached)
- ~emorandum from Robert B. Schaefer, Regional Counsel and
Basil G. Constantelos, Director, Waste Management Division
to Valdas V. Adamkus, Regional A~ministrator
.
,
.
- Memorandum from James Mayka, Chief, Michigan Technical
Programs Unit, Solid Waste Branch ~~ Jack Kratzmeyer,
Remedi a 1 Project Manager, Waste i.\a~age;:lent )i vi s ion,
August 2, 1985
Description of Selected Remedy
This Record of Decision recommends a remedy consisting of trlree distinct
elements:
(1)
Allow the contaminant plumes to discharge under natural
flow conditions to Lake Michigan.
Continue long-term monitoring of the plumes during the
natural purging period.
(2)
(3)
Institutional restrictions on the installation of private
wells in the contaminated aquifer will be enforced by local
health officials.
Declarations
Consistent with the Comprehensive Envir~r.m~ntal Response Compensation and
Liability Act of 1980, and the National Contingency Plan (40 CFR Part 300),
1 have deter10ined that the actions d~scribej above represent a cost-effec-
tive remedial action and provide adequate protection of public health,
welfare and the environment. The State of l-1ichigan has been consulted and
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agrees with the approved remedy. In addition. tile action will require
future operation and maintenance activities to ensure the COQtinued effec-
tiveness 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. ..
~~-
Date
aL /~(u.,)
Valdas V. Adamkus
Regional Administrator
U.S. EPA. Region V
..
1
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Summary of Remedial Alternati~e Selection
Charlevoix Municipal Well
Site Location and Descr~ion
The City of Charlevoix is located on the shores of Lake Michigan in the
northwest section of the lower peninsula of Michigan in Charlevoix County
(see Figure 1). The City's single municipal well supplies potable water to
a year-round population of 3500 which increases to approximately 5,000
during the summer tourist season. The City requires an average water
supply 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 setting.
The primary use of the surrounding area is for residential, recreational
and commercial purposes. A major portion of the City's income is derived
from tourism. .
The City's municipal well consists of a shallow large-diametp.r clear well
connected to two 225-foot-long horizontal flumes which are buried beneath
the Lake Michigan beach parallel to the shoreline (see Figure 2 for detail).
The flumes collect ground water and lake water and channel it into the well,
where is it then pumped into the distribution system. Approximately half
of the water entering the flume comes from Lake Michigan, and the remainder
from shallow ground water sources. The collection flumes are located in a
discharge area for the shallow glacial drift aquifer. In the vicinity of
the flumes, the aquifer consists of sand with varying amounts'of silt and
gravel.
Site 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 trichlorethylene (TCE) ranging in concentra-
tions from 13 to 30 parts per billion (ppb) in the Charlevoix water supply.
A monitoring program was begun and continued to detect gradually rising
levels of TCE in the raw water.
In December 1982, concentrations of TCE exceeded 100 ppb. At that point,
the City installed a temporary diffused aeration system in the municipal
well to remove some of the volatile organic chemicals (VOCs). The aera- ,
tion 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 in the area. 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 house in hopes of intercepting the TCE contamina-
tion and establishing its direction of approach. Sampling results from
these monitoring wells (Well * T2, 36 ppb TCE) verified that the source of
. TCE contamination in the municipal well was 9round water rather than surface
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PUMPING STAtiON
LEA. CONeRE IE
ORIGINAL GROUND SURfACE.
lA"[ MICHIGAN
~
225' INTAKE
ru...~ -:J.. - -
-
BAClCfllL
I'" ClEARWUL
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.
,... WATERMAIN to
CItY DiStRIBUtiON SYSnM
PLAN VIEW
GRAVU-
INJAI(E flUME
SECTION A-A
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SCIIE MATIC OF
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OPERATION
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FIGURE 2.
CITY INTAKE fLUME
CIIAHL(VOIX SITE
. .."... .
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~
water. The EPA Technical Assistance Team (TAT) conducted a hydrogeologic
study in June and July, 1982. The TAT developed an additional nine ground
water monitoring wells in the vicinity of the municipal well. ~Tthough
sampling of the test wells found varying amounts of TCE. the source of
contamination could not be located. Also. during the TAT study perchloroe-
thylene (PCE) was detected in a number of the monitoring wells. although
PCE had not been measured in the water supply.
The U.S. Environmental Protection Agency (EPA) began its Remedial
Investigation (RI) during September 1983. Twelve additional borings were
drilled in December 1983. Analysis of water samples taken from these
monitoring wells located areas of high concentration for both TCE and PCE.
The exact sources of TCE and.PCE were not known. but suspected areas were
more closely defined (see Figures 3 and 4) by the data from the RI. The
data collected in December 1983 indicated that concentrations of TCE in the
ground water moving toward the municipal well were much higher than pre-
viously measured. The additional threat posed by the higher concentrations
resulted in a decision by EPA to conduct a Focused Feasibility Study (FFS)
. to evaluate potential remedies for the contaminated water supply. while
work on the remedial investigation continued. In June 1984. a Record of
Decision (ROD) was signed which approved an initial remedial measure (IRM)
for an alternate water supply to replace the contaminated municipal well.
The selected IRM consists of a Lake Michigan water intake structure and a
water filtration/flocculation treatment plant. Construction of the IRM is
expected to be completed by December 1986. After completion of the water
treatment plant. the City will have a clean water supply. and the existing
municipal well will be physically abandoned.
Current Site Status
The second major phase of RI field work began in July 1984 and included
soil borings. monitoring well installation. ground water sample collection
and air monitoring. The objective of this phase of RI work was to locate
and identify the source of TCE and more extensively map the PCE plume. The
results from December 1983 indicated that the highest concentrations of TCE
in the ground water occurred in the vicinity of the Charlevoix Middle
School.
The results were less conclusive regarding the origin Of the PCE contami-
nation. but indicated an area upgradient of the intersection of Hurlbut and
State Streets (see Figure 4). There are a number of. former. or currently
operating commercial facilities upgradient where PCE may have been used. "
including dry cleaners and the Charlevoix airport. An area of PCE contami-
nation in soils underlying a former dry cleaner was discovered by MDNR in
1983. but appears unrelated to the PCE plume. MDNR is presently evaluating.
whether to address PCE contamination from this. and other suspected sources
through its State Superfund program (Act 307).
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fiGURE 3
TRICHLOROETHYLENE CONCENTRATIONS
DECEMBER 1983
CIIARLEVOIX SUE
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FIGURE +
PERCHLOROETHVLENE CONCENTRATIONS (PPBJ
DECEMBER 1983
CftARlEVOIX SITE
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Although extensive soil borings were completed in the Middle School area
during Phase II of the RI, a discrete source of contamination suc~ as an
underground tank or buried drums was not found. In addition, no,contami-
nation was detected in any of the soil samples taken from the borings in
the unsaturated zone above the water table. These results indicate that
there is no current, identifiable source of contamination and that the
origin of the contaminated ground water was either a single spill or a
source that was subsequently removed.
There was fill material found in soil samples collected from borings in the
area of the school playground to depths of up to 14 feet. The existence of
this fill was confirmed in discussions with Charlevoix School District
personnel. At one time, a wing of the Middle School was located in the
area where the playground is now located. This wing was demolished in the
mid-1950's. The fill material was deposited in the basement of the old
wing. A new wing was added to the school in the late 1950's. TCE may have
been spilled during the demolition or construction activities. TCE was
commonly.used as a degreasing solvent in the 1950's and may have been used
with the construction equipment. The total estimated mass of TCE in the
ground water plume is 95 kilograms (16 gallons of 100 percent TCE), indi-
cating that a small spill could have been the source of the contamination.
However, the data obtained during the RI has penmitted an estimate of the
extent of ground water contamination to be made. The areal extent of TCE
contamination greater than 100 ppb is approximately 243,000 ft2 or approxi-
mately 5.6 acres. (Figure 5). The area contaminated with TCE at concen-
trations above the 10-6 excess lifetime cancer risk level (2.7 ppb) is
approximately 3,000,000 ft2 or 70 acres. The volume of water contaminated
with TCE at concentrations greater than 2.7 ppb is 393 million gallons.
PCE contamination greater than 25 ppb covers an area approximately 350,000
ft2 or approximately 8.0 acres. (Figure 6). . The southern end ot the plume
is undefined, so that only rough estimates of volume can be made. An esti-
mate of the volume of water contaminated with PCE above the 10-6 risk level
(.88 ppb) is 260 million gallons.
The area and volume of water contaminated with TCE and PCE at concentra-
tions above the 10 ppb but less than 100 ppb is difficult to define because
ground water samples taken from nearly every boring and monitoring well
detected some level of contamination. As shown in Figures 5 and 6 there
are. two separate contaminant plumes, one of TCE and one of PCE. Each plume
consists of that single contaminant. No other compounds have been consis-
tently detected.
.
,
.
Enforcement
In August 1983, reacting to the continued presence of TCE in the City's
water supply, MDPH issued a Department Order (order) to the City. The
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fiGURE 5
Tt:f CUNCfHJRA TlON MAr - JUl Y 1984
CHARt.YO.8. ..tC"I~AN 1111
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fiGURE 6
PCE CONCENTRA HON MAp. AIL Y 1984
CKA"' twO... M'(.tU~A" AI
.
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order required the City to commit by January 1, 1984 to a definite water
supply alternative to replace or treat the contaminated muni~ipa1 well.
The issuance of this order coincided with EPA's 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 Iny Federal
funding of a remedial solution to the water supply problem.
A November 17, 1983 meeting between EPA, MDPH and the City produced an
a~reement to delay the compliance date of the MDPH order until May I, 1984
to allow sufficient time for EPA to complete the necessary remedial
investigations. When EPA informed the MDPH in early May 1984 that the FFS
would be completed on May 14, 1984 the MDPH decided to adjourn the hearing
until late June 1984. At the hearing it was agreed that the compliance
date for the order be extended to January I, 1987. Completion of the water
treatment plant is scheduled for December 1986.
In January 1985 EPA issued a combination Section 106 notice letter and
104(e) information request to the Charlevoix Middle School. This action
was taken after the results from the RI indicated that the highest concen-
trations of TCE in the ground water occurred in the vicinity of the Middle
School. The Middle Schoo1's response to the information request provided a "
great deal of detailed information, but was of little assistance in
determining the specific source of contaminants.
Alternatives Evaluation
Based on the findings of the remedial investigation and risk assessment,
the objective of remedial action at the site was identified as minimizing
the potential risk to the public from direct consumption of the contaminated
ground water through inadvertent use of private wells by individuals unaware
of the hazard. This objective is consistent with the Agency's previous'
decision to permanently relocate the municipal water supply source.
The data gathered during the RI indicate that there is not a current identi-
fiable source of contamination, and that the origin of the contaminated
ground water was likely a single spill incident or a source that was subse-
quently removed. Because the source(s) of TCE and PCE contamination are
believed to no longer exist, only remedial actions for management of migra-
tion of contaminated ground water were evaluated.
General response actions were identified which could meet the stated
objective of remedial action. These include:
o No action,
o Limited action, which includes ground water monitoring and
restrictions on ground water use after construction of the
water treatment plant is completed, .
o Extraction of the contaminated" ground water by pumping, and
o Treatment of extracted contaminated ground water.
Containment of the contaminated ground water by physical barriers such as
. Slurry walls was also considered as a general response action, but was not
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retained because it does not adequately meet the objective of protecting
against future use of the contaminated ground water. Although it would
prevent further migration of the plumes, which might limit the number of
homes ultimately located above the contaminated ground water, i~would not
reduce the risk for the homes already located above the existing plumes.
A number of technologies were considered for each general response action
that had been identified:
o No action
o Limited action:
- Ground water monitoring
- Institutional restrictions on use of ground water
o Extraction of contaminated ground water:
- Extraction wells
- Extraction wells in combination with shallow
injection wells
o Treatment of contaminated ground water:
- Granular activated carbon adsorption
- Air stripping
- Steam stripping
- Physical/chemical treatment
- Biological treatment
- Chemical oxidation
;
.
Each of the potential remedial technologies was screened based on: (1) appro-
priateness for physical site conditions, (2) impact of chemical and physical
characteristics of contaminants on effectiveness (3) reliability, and
(4) relative cost.
The use of shallow injection wells in combination with extractioo wells was'
eliminated as a contaminated ground water extraction method because of
relative cost; a treatment system similar to that required for surface
discharge would be needed prior to reinjection.
Steam stripping was eliminated as a treatment method, since both TCE and
PCE are compounds that are readily stripped using only air stripping, so
that the increased capital and operation costs to heat the air are not
warranted. Physical/chemical treatment was not considered to be effective
for treatment of dissolved vacs. Any removal through a conventional
physical/chemical treatment plant would probably be due to volatilization,
which in effect would produce an uncontrolled release of vac emissions.
The use of biological treatment as a stand-alone treatment technology was
eliminated because of limited experience with this method. Also site
conditions. and in particular. the organic content of the soils and the
concentration of TCE and PCE are not conducive for effective biological
breakdown. Another general consideration is that the final breakdown
product of TCE and PCE is vinyl chloride, which is more hazardous than
.. either TCE or PCE. However in this case. there is a low probability of
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biological breakdown of the PCE and TCE to vinyl chloride during the natural
pur~ing process because of the sandy soils and lack of the necessary
biological substrate to foster biological degradation.
Chemical oxidation was eliminated because of concern over its ef~ectiveness
in this application. In actual practice. oxidation reactions are not always
complete which can result in the formation of new compounds that are just.
as hazardous as the original compounds.
After the initial screening process, four alternatives were judged to meet
the objectives of the remedial action and were evaluated further:
ALTERNATIVE 11 - Limited Action
ALTERNATIVE '2 - Ground water Pumping with discharge
to Lake Michigan
ALTERNATIVE '3 - Ground water pumping with air stripping
treatment
ALTERNATIVE 14 - Ground water pumping with Carbon
Adsorptio~ treatment
ALTERNATIVE 1:
The Limited Action alternative would not involve actual clean-up of the
contaminated ground water. The contaminated ground water plumes would be
allowed to continue to migrate naturally and disperse into Lake ~ichigan.
Based on the physical properties of the shallow sand and gravel aquifer
and the contaminants, it 15 estimated that under natural flow conditions
the contaminated ground water would be purged in approximately 50 years.
During this periOd the plumes would be monitored through a semi-annual
ground water and lake water sampling program. In addition, institutional
restrictions on the development of ground water in the area of the con-
taminant plumes would have to be implemented.
Table 1
Cost for Limited Action
Capital Cost
Annual 0 & M
$ 0
$ 17,000
$160,000
30-year Present Worth
ALTERNATIVE 2:
Alternative 2 consists of the installation of extraction wells to pump the
contaminated ground water and convey it to Lake Michigan for direct discharge.
The purpose of the pumping alternative is to speed up the natural flushing
process and shorten the estimated 50 year period that the aquifer would be
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unusable under Alternative 1. A pumping scheme was analyzed which would
maximize the rate of flushing and consequently minimize c1ean~p time. We
have estimated the maximum rate of pumping that the aquifer can maintain
without substantial drawdowns. At that rate (750 gpm), pumping ~ould be
necessary for 30 years to reduce the TCE and PCE concentrations ~ the
aquifer to the 10-6 cancer risk level (2.7 ppb and 0.8 ppb respectively).
In this application, the contaminant transport and resulting decrease in
ground water concentration with time is limited by the rate of desorption
of PCE, which is more tightly bound to the soil. Consequently, PCE is
released more slowly from the aquifer materials.
Monitoring requirements would be similar to those necessary for Alternative
1, with the exception that the time period would be reduced to 30 years.
In addition, the same institutional restrictions on the development of
ground water would be necessary.
Alternative 2 would result in a concentrated point source discharge of
untreated ~ontaminated ground water to Lake Michigan. The overall additional
cancer risk presented by this discharge from; (1) water ingestion and skin
absorption during swimming, and (2) fish consumption was found to exceed a
10-5 risk which is unacceptable. Consequently, the use of ground water
pumping will require treatment prior to discharge to Lake Michigan.
ALTERNATIVE 3:
Alternative 3 consists of the ground water pumping system described in
Alternative 2, followed by treatment with air stripping prior to discharge
to Lake Michigan. .
Since air stripping is designed to remove VOCs from water by transferring
them to an air stream, this alternative would create a source of VOC air
emissions. Treatment of the air stripper tower vapor exhaust for removal
of TCE and PCE with a nonregenerable carbon system has been included in
Alternative 3. A nonregenerab1e system was selected over a regenerable
carbon system because of the relatively low contaminant concentrations,
less complexity, and relative equal total costs. Table 2 gives the cost
information for this alternative.
;
.
Table 2
Ground Water Pumping with
Air Stripping Treatment
Capital Cost
Annual 0 & M
S1,600,OOO
$210,000-520,000
30-year Present Worth
. S4 ,800 ,000
There is a range for annual 0 & M costs because the TCE and PCE concentra-
tions from the extraction well system, which affect vapor phase carbon
usage, will decline with time. .
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ALTERNATIVE 4:
Alternative 4. like Alternative 3. relies on treatment of th~ contaminated
ground water from the extraction well system prior to discharge to Lake
Michigan. Treatment of the contaminated ground water would be provided by a
carbon adsorption system. The carbon system would consist of fo~r carbon
columns arranged in two parallel 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. The costs for Alternative 4 are
summarized in Table 3.
Table 3
Ground water Pumping with
Carbon Adsorption Treatment
Capital Cost
Annual 0 & M
$2.100,000
S150.000-400.000
30-year Present Worth
$4.400,000
SummarJ:
Alternative 1 allows the TCE and PCE plumes to continue to migrate naturally
and disperse to Lake Michigan. We estimate that under natural flow condi-
tions. the aquifer would purge itself of contaminants in 50 years. The
results of the endangerment assessment indicate that the only significant
risk to public health or the environment resulting from Alternative 1 is
that posed by direct consumption of the contaminated ground water from future
wells located directly in the contaminant plumes. Therefore, Alternative 1
includes provisions for institutional restrictions on the installation of
private wells in the area of the TCE and PCE plumes. Given that an alternate
water supply will be available after completion of the IRM. the likelihood
of future demand on the contaminated aquifer for potable water is not high.
Alternative 1 also includes a semi-annual ground water sampling and analysis
program so that the plume can be monitored throughout the natural purging
period. Alternative 1 has the lowest. cost.
Alternatives 2,3 and 4 all utilize ground water pumping to reduce the time
period required for ground water cleanup. Alternative 2 does not include
treatment of the extracted contaminated ground water. The extraction wells
would be discharged directly to Lake Michigan. Introduction of the untreated
contaminated ground water into Lake Michigan as a concentrated point source
discharge would result in a significant risk to pUblic health from exposure
to surface water during swimming and from fish consumption. Overall. the'
excess lifetime cancer risk for Alternative 2 is greater than that for
Alternative 1. .'
Alternatives 3 and 4 would reduce the time required to return the aquifer
to a useab1e state from 50 to 30 years. However. this incremental time
benefit would be achieved at a significantly higher cost than that required
for Alternative 1. Also during the 30 year pumping period. the same
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instutitional controls on ground water use necessary for Alternative 1
would be required for Alternatives 3 and 4.
Sununary of Costs
Capital Cost, $
Present Worth of O&M, $
Present Worth, $
(thirty years)
Community Relations
Alternative 1
o
160,000
160,000
Al ternat he 3
1,600,000
3,150,000
4,750,000
A 1 tern4,t i ve 4
2,100,000
2,300,000
4,400,000
Copies of the Feasibility Study (FS) were made available to the community
on June 10, 1985. Three locations served as repositories within the City:
Char1evoix City Hall, District Health Department No.3 and the Char1evoix
Public Library. The EPA placed an advertisement in the local newspaper on
June 3, 1985, which announced the availability of the study and the start
of the 3-week public comment period.
A public meeting was held on June 27, 1985 at the Char1evoix City Hall.
Only six residents attended the meeting. Representatives of the EPA, MONR
and local government were present. The EPA presentation explained the
purpose of the FS, presented the results of the endangerment assessment
under the no action alternative, and described the alternative recommended
by EPA. Questions regarding the project were .150 answered. There were no
formal public comments made. The public comment period ended on July 1,
1985. There were also no written comments submitted.
.
t
.
Consistency With Other Environmental Laws
The NCP £40 CFR 300.68] establishes the procedures for determining appropriate
remedial actions at Superfund sites. Generally EPA will implement remedies
that meet the standards of applicable or relevant Federal public health or
environmental laws. .
Other environmental laws and guidance which may be applicable and/or relevant
to the remedial alternatives evaluated in the FS are the Clean Water Act,
Clean Air Act, the Resource Conservation and Recovery Act (RCRA), EPAls
Ground Water Protection Strategy (August 1984), and the Great Lakes Water
Quality Agreement.
The Resource Conservation and Recovery Act (RCRA) is not considered to be
applicable to the remedial alternatives considered in the FS because of the
lack of a hazardous waste -regulated" unit. RCRA was intended to regulate
facilities used for the treatment, storage and disposal of hazardous waste.
Such a facility does not exist at Char1evoh.However, though not applicable,
the RCRA Subpart F ground water protection standards are considered relevant
in determining the appropriate level of cleanup since the major portion of
the aquifer underlying the community is contaminated with TCE and PCE.
However, certain procedural aspects of implementing RCRA Subpart F ground
water protection standards have not been used because they were developed
for hazardous waste facilities. Specifically, the RCRA ground water protec-
tion standards process of establishing an Alternate Concentration Level
(ACL) has not been used to develop the r~media1 action alternatives. Instead,
, a risk management approach supported by the e"jange~ment assessment in the
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FS, prepared as outlined in the "Guidance on Feasibility Studies Under
CERCLA" has been used. The illl1lediate goal of protecting humaA health and
the environment is the same, only the procedural aspects differ.
EPA's Ground Water Protection Strategy has divided ground water fnto three
major classes based on an aquifer's use and its vunerability to ~ntam;nation.
Guidelines on implementing the classification system will be released by
June 1986. For ground water defined as Class I under the Ground Water
Protection Policy (aquifer of drinking water quality, currently used as the
sole source of drinking water) the Maximum Contaminant Level (MCL) standards
promulgated under the Safe Drinking Water Act (SDWA) would be the applicable
standard for cleanup of an aquifer that presently provided a public water
supply. . .
When an aquifer (current or potential source of drinking water) has been
contaminated, an ACL under the RCRA Subpart F ground water protection
standards can be established as an alternative cleanup level to the MCL.
An ACL can be established at a relatively high level if consumption of the
ground water is prevented by institutional controls. Alternatives I, 3
and 4 include institutional controls on the installation ~r use of private
wells within the City limits. Therefore, the point of use of the ground
water is at Lake Michigan, where the ground water is purged naturally under
Alternative I, or discharged after treatment for Alternatives 3 and 4. The
risk to human health and aquatic life from these discharges to Lake Michigan
has been evaluated in the endangerment assessment in the FS. For Alternative
1 the excess lifetime cancer risk at the point of use is 3 x 10-8. Under
Alternatives 3 and 4 the excess risk is 1.5 x 10-8. The increased cancer
risks resulting from these alternatives at the point of use are not considered
unacceptable.
The current RCRA procedures for establishing an ACL were not intended to
implement corrective action for ground water where contamination cannot be
attributed to individual facilities. Since the remedial action alternatives
considered here include institutional control on the use of the contaminated
ground water, formal procedures to establish an ACL under RCRA Subpart Fare
not considered appropriate. However, the principles of the RCRA ground
water protection standards have been met by the risk management approach
presented in the FS.
The Great Lakes Water Quality Agreement of 1978 commits the United States
to require that releases of toxic substances meet certain criteria. Neither
TCE, nor PCE is classified as a "Persistent Toxic Substance" under the
Agreement, as their half-lives in water are much shorter than eight weeks
(TCE <1 day, PCE <20 days). The projected release levels, under the most
conservative conditions, are estimated to be 4 to 6 orders of magnitude
below known acute and chronic toxicity levels for freshwater aquatic life"
and 2 to 4 orders of magnitude below the 10-6 cancer risk level for inges-
tion. Thus, Alternative 1 is consistent with Ar.ticles II and III, as well
as Annexes 11 and 12. . ,
As part of Alternatives 3 and 4 contaminated ground water would be withdrawn
by ground water extraction wells. The ground water would be discharged to
"
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Lake Michigan after treatment. The Clean Water Act provisions for regulating
the discharge of wastewaters are administered by the State through the
National Pollutant Discharge Elimination System (NPDES) program. Under
that program. the State establishes effluent discharge limits bas~d 00 two
different criteria: 1) ambient water quality. and 2) technolog¥. Water
quality based effluent limits would be derived for each contaminant by
reviewing acute and chronic toxicity data and then calculating allowable
levels in the receiving surface water. In addition. for toxic pollutants.
the best available technology economically achievable (BATEA) must be used.
For the treatment of VaC-contaminated ground water air stripping and carbon
adsorption would be considered as options for BATEA.
Alternative 3 would result in an air emission of vacs. Michigan's State
Implementation Plan. required by Section 110 of the Clean Air Act includes
rules addressing the control of new sources of carcinogenic VOC emissions.
These rules require application of best available control technology (BACT)
to the new source of carcinogenic emissions. The cost of vapor-phase carbon
adsorption control (BACT) on the emissions from the air stripper has been
included in Alternative 3.
Recommended Alternative
It is the recommendation of this document. based on the evaluation of the
cost and effectiveness of each proposed alternative. and State and Federal
env1ronmental requirements that Alternative 1. Limited Action be selected
as the cost-effective alternative.
.
t
The NCP proposed rule [40 CFR 300.68(i)(1)] states that the appropriate
extent of remedy should be determined by the lead agency's selection of a
cost-effective remedial alternative which effectively mitigates and minimizes
threats to and provides adequate protection of public health. welfare and
the environment. The NCP further directs that in selecti~g the approp~iate
extent of remedy. the lead agency should consider cost. technology. relia-
bility. administrative and other concerns. and their relevant effects on
public health. welfare and the environment [300.68(i)(2)].
Table 4 provides summary information comparing the alternatives for these
criteria to permit the selection of a "cost-effective alternative" as
defined in the NCP. .
Alternative 1 allows the TCE and PCE plumes to discharge under natural flow
conditions.to Lake Michigan. The aquifer would return to a useable state
after 50 years. During that 50 year purging period, institutional controls
preventing the installation and use of private wells in the contaminated
area would be required. The necessary institutional mechanism is already..
in place. .The District Health Department '3 administers an existing well
permiting program in Charlevoix County. and has expressly prohibited the
installation of new wells in the City of Charlevoix since the discovery of
the TCE and PCE contamination.
Alternatives 3 and 4 were developed with the intent of reducing the 50 year
period required for ground water cleanup. The analysis indicates that even
with aggressive pumping of the ground water, the aquifer could not be
restored to safe levels for consumption for 30 years. In addition, during
. the 30 year period that ground water pumping would conti~ue, the same
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institutional controls required for Alternative 1 would be needed. The
results of the endangenment assessment indicate that the only-significant
risk to pUblic health or the environment resulting from Alternative 1 is
that posed by the potential future use of the contaminated ground-water.
Alternative 1 includes provisions for institutional restrictions ~n the
installation of private wells in the area of the TCE and PCE plumes~ Since
the IRM will provide an alternate water supply, the likelihood of future
demand on the contaminated aquifer for potable water is not high.
Alternative 1 consists of long-tenm monitoring of the TCE and PCE plumes
during the time period that the plumes are allowed to purge to Lake Michigan
under natural flow conditions. The monitoring program will include 10
observati~n wells selected from the existing monitoring well network. The
selected wells will be sampled semi-annually. In addition, surface water
samples will be taken from Lake Michigan and Round Lake. To prevent
inadvertent use of the contaminated ground water during the natural purging
period, the installation of private wells within the City limits will be
officially'restricted. The institutional control is already in place in
the fonm of the District Health Department ,3's well permitting program.
. The concentrations of TCE and PCE expected in the nearshore surface waters
of lake Michigan as a result of the continued release of the contaminant
plumes under the natural flow conditions of Alternative 1 are 0.008 ppb and
0.01 ppb respectively. This is a conservative estimate based on the
"average" values of TCE and PCE in the area-~ide plumes, rather than the
much lower concentrations measured in the ground water. adjacent to Lake
Michigan. The Federal criteria for the protection of freshwater aquatic
life above which acute effects in aquatic life could occur are 45,000 ppb
for TCE and 5,280 ppb for PCE. These are orders of magnitude higher than
the estimated concentrations for TCE and PCE in the lake water. The
criterion for long-tenm protection of aquatic life from PCE is 840 ppb.
EPA has not established a long-term criterion for TCE. A comparison of the
acute and chronic standards to the expected concentrations of TCE and PCE,
clearly indicates that Alternative 1 will not adversely affect aquatic life
in Lake Michigan.
The estimated annual cost for the monitoring proposed in Alternative 1 is
$17,000. The 30-year present worth value for the selected alternative is
$160,000.
We recommend that EPA fund 90 percent of the first year's monitoring cost.
The State will provide the 101 match for the first year operation and then
will assume all operation and maintenance (O&M) costs for the life of the
project.
Since the school might be considered as a politi-cal subdivision of the
State, under Section 104c(3)C of CERCLA the State could be responsible for
at least 50 percent of the costs of the remedial action. However, the
Office of Emergency and Remedial Response determined that Charlevoix would
not be considered as a 50 percent State match site, since the contamination
on the school property could have been the result of unauthorized, illegal
dumping.
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