PB93-964113
~
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPAIROD/R05-92/199
June 1992
&EPA
Superfund
Record of Decision:
Metal Working Shop, MI
u. S. Env~ronmentai Prot~1on Agency
~on II Hazardous Waste
TeclWeal information Center
841 Chestnut Street. "Floor
PbifadelPhia. PA 1910,
Hazardous Waste Collection
fnformafion Resource Center
US EPA Region 3
Ph(fadefphia. PA 19107
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request 01
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document. All supplemental material is, however, contained In the administrative record
for this site.
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REPORT DOCUMENTATION 1" REPORT NO. I 2. 3. Reclplenr. -Ion No.
PAGE EPA/ROD/R05-92/199
4. Tille end Suballe 5. Report DeI8
SUPERFUND RECORD OF DECISION 06/30/92
Metal working Shop, MI 6.
First Remedial Action - Final
7. Aulhor(.) 8. Perfonnlng OrgenIz8llon RepL No'
9. Perfonnlng Org8lnlz8llon - end Addr- 10. ProIectlTakIWork Unit No.
11. ConIr8cI(C) or Grenl(G) No.
(C)
(G)
12. Sponaorlng OrgenlZllllen N8me end Addra. 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplemenl8ry No...
PB93-964113
16. Ab.1r8CI (Umlt: 200 worda)
The 2.7-acre Metal working Shop (MWS) site is a manufacturing facility in Lake Ann,
Benzie County, Michigan. Land use in the area includes residential, recreational,
agricultural, and timberlands. The site is adjacent to three lakes: Lake view to the
north, Bryan Lake to the east, and Lake Ann to the south. The surrounding residents
use private well systems for drinking water. A variety of metal finishing and tool and
die operations have been conducted at the site during the past 26 years. It was
reported that from 1975 to 1977, water from two site operation rinse tanks was disposed
of on the ground surface onsite. Subsequently, from 1983 to present, Lake Ann
Manufacturing used the site for assembling mechanical shaft seals for pumps and
compressors. As a result of an 1984 investigation, EPA identified three suspected
areas of disposal that included the alleged disposal area, the alternate disposal area,
and the septic system. Although samples were not collected, historical information was
gathered during the site investigation. A 1987 investigation conducted by an
independent contractor included collecting several soil samples and installing three
groundwater monitoring wells. This investigation revealed that there was no soil or
ground water contamination; however, it did not prove the absence of potentially
(See Attached Page)
17. Document Anllly". .. De8crlptora
Record of Decision - Metal Working Shop, MI
First Remedial Action - Final
Contaminated Media: None
Key Contaminants: None
b. ldenaflor8l0pen-Ended T ann.
c. COSA TI FIoIdIGroup
18. Av..l8blllty SlIII8ment 19. Security CI888 (Thl. Report) 21. No. 01 Pegea
None 28
20. Security CI888 (Thl. Pege) 22. PrIce
Nnnp
272 (4.77)
50272.101
(Soe ANSI Z39.18)
See InlltructJons on RtlwrstJ
(Formerly NTJS..35)
Oepertment 01 Commerce
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EPA/ROD/R05-92/199
Metal Working Shop, MI
First Remedial Action - Final
Abstract (Continued)
present contamination based on historical dumping. This ROD provides a final action, and
no additional OUs or additional separate actions are planned. No site-related organic
contamination was identified during the RI and inorganic constituents approximated
background levels; therefore, there are no contaminants of concern onsite.
The selected remedial action for this site includes no further action because no
significant levels of contaminants exist onsite. No additional action is necessary to
protect human health or the environment. There are no costs associated with this no
action remedy.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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Record of Decision
Remedial Alternative Selection
SITE NAME AND LOCATION:
Metal Working Shop, Lake Ann, Benzie County, Michigan
STATEMENT OF BASIS AND PURPOSE:
This decision document presents the selected remedial action for
the Metal Working Shop Site, in Lake Ann, Benzie County, Michigan,
which was chosen in accordance with the Comprehensive Environmental
Response Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and, to the extent practicable, the National oil and
Hazardous Substances Pollution Contingency Plan (NCP). This
decision is based on the administrative record for the site.
The State of Michigan concurs with the selected remedy.
DESCRIPTION OF THE SELECTED REMEDY:
u.S. EPA has selected "No Action".
DECLARATION:
u.S. EPA has determined that inorganic constituents exist at the
site in concentrations comparative to background levels. No
organic contamination exists at the site. The presence of
inorganic constituents detected at the site does not appear to pose
an unacceptable risk to human health or the environment.
u.S. EPA has determined that no further remedial action is
necessary at this site. Therefore, the site now qualifies for
inclusion in the sites Awaiting Deletion subcategory of the
'Construction Completion category of the National Priorities List.
As this is a decision for "No Action", the statutory requirements
of CERCLA section 121 for remedial actions are not applicable and
no five year review will be undertaken.
k
June Jo - IqffJ
Date
Valdas V. Ada
Regional Admi
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-
METAL WORKING SHOP
LAKE ANN, MICmGAN
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
JUNE 1992
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DECISION SUMMARY
SITE DESCRIPTION
The Metal Working Shop (MW$) site, occupying approximately 2.77 acres, is located in central
Almira Township, Benzie County, Michigan, approximately 12 miles west of Traverse City
Michigan. Metal Working Shop is located at 6892 N. Reynolds Road between Lake View and
Lake Ann along the northwest. corporate boundary of Lake Ann Village (Figure 1).
INTRODUCTION
This Record of Decision provides information on the final remedy selected by the U.S.
Environmental Protection Agency (U.S.EPA) and the Michigan Department of Natural
Resources (MDNR). The U.S.EPA and MDNR selected "No Action" at the Metal Working
Shop (MWS) site and recommend that the site be removed from the National Priorities List
(NFL). This Record of Decision is for a final action (Le. no action) and no operable units or
additional separate actions are contemplated. The recommendation is based on the findings of
a Superfund Remedial Investigation (RI) conducted in-house by the U.S.EPA as the lead agency
with MDNR as the support agency.
Based on the RI data, U.S. EPA has determined that no cleanup action at the MWS site is
necessary to ensure protection of human health and the environment. Section 117(a) of the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the
federal Superfund law, requires that a plan explaining proposed actions at Superfund sites be
developed and presented for public review and comment. The public comment period provided
an opportunity for the public to comment on this plan. The public comment period was from
May 11, 1992 to June 9, 1992. A public meeting was held on May 28, 1992 in Lake Ann,
Michigan. A responsiveness summary is attached to this ROD responding to comments received
during the public meeting and comment period.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The MWS site occupies 2.77 acres along Reynolds road outside the northwest village limit of
Lake Ann, Michigan. The site is situated between three nearby lakes, Lake View to the north,
Bryan Lake to the east, and Lake Ann south of the. site. The surrounding land use is
characterized as residential, recreational, agriculture, and timberland. Several summer resorts
are located in the area. Both. Lake View and Lake Ann have summer resorts located on their
shores. Depth to ground water beneath the site is approximately 60 feet. The aquifer consists
of glacial sands and gravel. Surrounding residents are currently using private well systems for
drinking water. .
The site has been used for a variety of metal finishing and tool and die operations over the past
26 years. The basis of environmental concern dates back to the period of October 1975 to
February 1977, when the operator conducted metal finishing operations using an iron phosphate
treatment process. The process consisted of five steps, each performed in a separate tank
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REGIONAL
Lake
TOPOGRAPHIC
Ann, Michigan
MAP
to
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METAL WORKING
SHOP
SITE
USGS Thompsonville & Maple City
Michigan Quadrangles
1956 & 1957 Respectively
Scale: 1 :62,500
Contour Interval 20 Feet
.
FIGURE 1
2
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approximately three feet on a side with a capacity of approximately 200 gallons. First, the metal
parts were cleaned in a heated sodium hydroxide solution. Following a rinsing step in ordinary
water, the parts were treated ina heated hydrochloric acid solution containing iron phosphate.
After a second rinse in ordinary water, the parts were dipped in a bath containing a water-
soluble oil. It is reported that water from the two rinse tanks only, was then disposed of on the
ground surface at the site. The largest and current operator, Lake Ann Manufacturing, occupied
the facility in 1983 and has assembled mechanical shaft seals for pumps and cOmpressors since
that time.
The site was evaluated by the U.S.EPA in December 1984. U.S.EPA identified three suspected
areas of disposal, the alleged disposal area (currently covered by a warehouse), the alternate .
. disposal area (near MWl), and the septic system (near SB4). No samples were collected at that
time but historical information was gathered during the site investigation. The site was proposed
to be placed on the National Priorities List (NPL) in January 1987 on the basis of its potential
for causing groundwater contamination. ThJLsite became final on the NPL in February 1990.
A soil and ground water investigation of the site was performed by a private contractor for the
current operator in May 1987. This investigation included the collection of several soil samples
and the installation of three ground water monitoring wells. MDNR split samples with the
contractor at the time of the investigation. Evaluated collectively, the analytical data from the
May 1987 investigation did not indicate the presence of soil or ground water contamination;
neither, however, did it prove the absence of potentially present contamination based on
historical dumping. No enforcement or removal actions have been conducted at the MWS site.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
On April 23, 1991 EPA hosted a remedial Investigation KiclE-eff meeting at the Almira
Township Office, Lake Ann, Michigan. Approximately 50 citizens attended this meeting. .
The Proposed Plan was released to the public for comment on May 11, 1992. The public
comment period concluded June 9, 1992. The Proposed Plan provided the public with the
opportunity to attend a Public Meeting to discuss the RI findings and proposed alternative.
The Proposed Plan public meeting was held on May 28, 1992 with nine citizens in attendance.
The public participation requirements of CERCLA section 113(k)(2)(B)(i-v) and 117 have been
met in the remedy selection process. This decision document presents the selected remedial
action for the MWS site, in Michigan, chosen in accordance with CERCLA, as amended by
SARA and, to the extent practicable, the NCP. The decision for this site is based on the .
administrative record. .
3
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SCOPE & ROLE OF RESPONSE ACTION
U.S. EPA and MDNR recommend "No Action" at the Metal Working Shop. No site related
organic compounds were found during the RI, however, inorganic constituents similar to
background levels were found during the RI. Levels of inorganic constituents present in site
soils and ground water do not pose an unacceptable risk to human health or the environment.
The findings of the MWS RI showed no organic or inorganic constituents that exceed any federal
standards or drinking water criteria, except for beryllium, in filtered ground water samples.
Beryllium exceeded its MCL of 1.0 ug/L in residential well RWOI-0l upgradient of the site.
This beryllium detection is most likely from naturally occurring soil constituents and not site
related.
The risk level associated with beryllium is 6.6 x 10.5 which is within the acceptable U.S. EPA
risk range of 1 x 1 Q4 and 1 x 10-6.
U.S. EPA informed the Michigan Depanment of Public Health of this beryllium detection for
evaluation and possible future monitoring consideration even though this residential well is not
used for drinking water purposes.
U.S. EPA and MDNR concur that all necessary action has been completed at the MWS site.
Because this remedy will not result in hazardous substances remaining on site above health based
levels, the 5 year review will not apply to this action.
SITE CHARACTERISTICS
U.S.EPA performed field activities during the remedial investigation beginning in April 1991.
These activities included a ground penetrating radar survey, evaluations and sampling of existing
monitoring wells, surface and sub-surface soil sampling, surface water and sediment sampling,
permeability test of the aquifer, and natural gamma logging of the monitoring wells. U.S.EPA
completed the remedial investigation report in February 1992 which should be referenced for
details involving the components of the remedial investigation. Sample locations, site features,
and topography of the MWS site are shown in Figure 2. A generalized cross-section of the local
stratigraphy is given in Figure 3. Significant results from sample analyses are discussed below.
Soil Samples
In general the inorganic constituent concentrations in site soil samples were detected at low
levels and in similar concentrations to background soil samples. Review of all collected soil
samples by a U.S.EPA toxicologist resulted in selecting two inorganic constituents, (lead and
arsenic) to be carried through the Risk Assessment process. Maximum concentrations for these
two constituents are summarized in the following table and discussed below in greater detail for
surface soil samples and sub-surface soil samples.
4
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5B - son Boring
MW - Monitoring Well
TOPOGRAPHIC AND SAMPUNG LOCATION MAP
METAL WORKING SHOP SITE
LAKE ANN. MICHIGAN
FIGURE 2
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ODNIOUA IIfItRVAi. - 1 FOOT
E1LVAlIOII DA1UU tail.
sc..u: IN FttT
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FEET
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900
880
860
840
820
800
780
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720
700
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Surface Samples (mg/kg)
Sub-Surface Samples (mg/kg)
Background
Sample
Characterization
Sample
Inorganic
Constituent
Background
Sample
Characterization
Sample
1.0
2.7
3.9
11.2
Arsenic
Lead
1.8
0.8
1.3
23.0
The maximum concentration of lead for surface soil characterization samples was 11.2 mg/kg
in duplicate sample SS03 (characterization sample SS03 detected a concentration of 7.0 mg/kg).
A lead concentration of 2.7 mg/kg was found in background sample SS07. Arsenic was found
at a maximum of 3.9 mg/kg in surface soil sample SS05. In background sample SS07 arsenic
was found at a concentration of 1.0 mg/kg.-
Analysis of site inorganic sub-surface samples show maximum concentrations of lead at 23.0
mg/kg in SBOI and arsenic at 1.3 mg/kg in SB05. Corresponding background results revealed
-lead at 1.8 mg/kg and arsenic at 0.8 mg/kg in SB06. In summary, analytical results indicate
inorganic constituents exist on-site at low levels. However, site characterization concentrations
are similar to background concentrations for inorganic constituents.
Only two organic compounds were detected in soil samples, 2-butanone and
bis(2-ethylhexyl)phthalate. The maximum concentration of 2-butanone detected was 1500 ug/kg
and the maximum concentration of bis(2-ethylhexyl)phthalate detected was 450 ug/kg. Both of
these organic compounds can be attributed to laboratory contamination as common artifacts of
the analytical techniques employed and are not considered to be site derived.
Ground Water Samples
Inorganic constituents exist in all of the ground water samples coHected and analyzed. Both
filtered and unfiltered samples were collected from the three site monitoring wells. From the
ground water samples collected on-site, a U.S. EPA toxicologist identified two inorganic
constituents of concern (lead and arsenic) to be carried through the risk assessment process.
Beryllium was found upgradient of the site ground water flow at a concentration of 1.2 ug/L in
one residential well sample (RW01), which exceeds the Federal Maximum Contaminant Level
(MCL) of 1.0 ug/L (see Figure 4 for residential well locations). Historically, beryllium has not
been a contaminant of concern at the MWS site, however beryllium was carried through the risk
assessment process even though it is most likely naturally occurring. Beryllium was not found.
in any other groundwater sample. -
The average ground water flow velocity is approximately 255 feet/year traveling in a
southeasterly direction. Ground water flow direction is shown in Figure 5.
7
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METAL WORKING SHOP SITE
RESIDENTIAL 'W'Eil
SAMPLING LOCATIONS
-
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MWS
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DATE OF" SAMPUNG: APRIL 24.
1991
c
ROADS
BUILDING
LOCAT10N OF' RESICEN'T1A1.
wElL SAMPL£C
SAMPLL NUMBER
.
LEGEND
o
o 125 2!10
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SCAU: IN FEEl'
Agure 4
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ACCESS ROAD
USfJIA - II£GIIIM V
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.
GROUND WATER CONTOUR MAP
METAL WORKING SHOP
APRIL 23, 1991
LAKE ANN, MICHIGAN
IS IS 311
-
a:AU: Of FEET
DASHED LINES ... EXT~OLATED DATA
CONTOUR INTERVAl ... 0.2 fEET
FIGURE 5 .
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Maximum concentrations for constituents of concern are summarized in the table below:
Monitorim! Well Samnles- (ug/U
Residential Well Samples (ug/U
Background
Sample
Characterization
Sample
Inorganic
Constituent
Background
Sample
Characterization
Sample
ND
ND
ND
10.0
3.0
ND
2.0
12.0
Arsenic
Beryllium
Le4d (flltered)
Le4d (unflltered)
ND
ND
2.0
NA
ND
1.2
3.0
NA
ND = Not Detected
NA = Not Applicable
Le4d was detected at low levels (below the MCL of 5.0 ug/L) in several residential wells. The
maximum concentration of lead detected in residential wells w~ 3.0 ug/L in samples RW04 and
RW08. The residential well background sample RW02, detected lead at a concentration of 2.0
ug/L. Arsenic was not found in any residential well sample.
Le4d was detected in all of the unflltered monitoring well samples but only two of the flltered
monitoring well samples. The site unflltered samples had visible sediment present within the
sample whereas the filtered samples did not have visible sediment present in the sample. The
maximum concentration of lead detected in the filtered monitoring well samples was 2.0 ug/L
in both MW2 and MW1. Lead was detected in all unfiltered monitoring well samples with the
maximum concentration of 12.0 ug/L in monitoring well MW1.
EP A believes the 12.0 ug/L detection of lead in MWI is the result of soil constituents (sediment)
being present within the sample for laboratory analysis and not entirely due to the dissolved
concentration of lead in the water. This is evident in the fact that MWI's filtered sample had
a lead concentration of 2.0 ug/L which is more representative of"1l:fea drinking water.
Arsenic was detected in one unflltered monitoring well sample, MWl, at a concentration of 3.0
ug/L. Arsenic was not detected in any other groundwater sample, residential or monitoring
well. Arsenic does not exceed its MCL of 50.0 ug/L but was still selected as a constituent of
concern by the EP A because of its toxicity.
Remaining ground water inorganic constituents that were detected do not exceed their respective
MCLs for monitoring well and residential well samples. Sporadic occurrences of cadmium and
manganese exist in the residential well samples. Cadmium was detected in RW06 at a
concentration of 0.4 ug/L. Manganese was found in RW02 at a concentration of 80.4 ug/L.
Remaining inorganic constituents that. were detected in the residential wells occur more
frequently but at variable levels. Monitoring well samples detected inorganic constituents
frequently, but at variable levels except for antimony, arsenic, copper, nickel, potassium,
10
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vanadium and zinc which had sporadic occurrences.
constituents are naturally occurring.
U.S.EPA believes these inorganic
Organic analysis of all groundwater samples revealed the presence of two organic compounds,
bis(2-ethylhexyl)phthalate and methylene chloride. Bis(2-ethylhexyl)phthalate is a semivolatile
compound which was detected in monitoring well MW3 at a concentration of 4.0 ug/L. The
field blank detected the highest concentration of bis(2-ethylhexyl)phthalate which was estimated
at 220 ug/L. One volatile organic compound (methylene chloride) was detected at an estimated
concentration of 0.6 ug/L in monitoring well MW1. Methylene chloride was also detected in
all pure water trip blanks at an estimated concentration of 0.5 to 0.6 ug/L. Both bis(2-
ethylhexyl)phthalate and methylene chloride are common artifacts of the analytical method
employed and are not considered to be site derived. Common artifacts can result from the
chemical compounds used by the laboratory to analyze samples.
Lake Samples .
The only constituents of significance found in the lake samples consist of inorganic constituents.
Sample collection from four nearby lakes and a wetland consisted of shallow and deep samples
(when sufficient water depth was allowable) at each sampling location to account for such
differences potentially due to stratification or incomplete mixing. The surface water bodies
sampled were Lake Herendeene (background location), Lake View, Bryan Lake, Lake Ann, and
the small wetland area in the depression area south of MWS. Lake Ann was sampled at two
separate locations.
The maximum inorganic concentrations detected above background levels for both surface water
samples and sediment samples are listed below in units of ug/L for water samples and mg/kg
for sediment samples:
Surface Water Samnles (ug:/D Sediment Samples (mg/kg)
Background Characterization Inorganic Background Characterization
Sample Sample Constituent Sample- Sample
84.90 96.20 Aluminum 5730 7540
9.40 22.30 Barium 43.90 118
1.50 2.60 Beryllium ND ND
27,800 42,600 Calcium 39,000 337,000
170 2970 Iron 11 ,300 12,800
ND ND Lead 57.50 96.70
5780 8590 Magnesium 3490 4040
18.90 445 Manganese 255 486
665 2560 Potassium ND ND
950 2090 Sodium ND ND
ND ND Vanadium ND 29.80
ND ND Zinc 208 211
11
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. .
-
No obvious pattern of site related inorganic constituents exists in surface water or sediment
samples collected near the MWS site. Due to the absence of proven site related constituents
between the site and surface water bodies, and the fact that natural variation from lake to lake
is expected, the constituents appear to be naturally occurring. The small wetland has the highest
levels of inorganic constituents above background in both the surface water sample and sediment
sample. Because of the inherent nature of wetland chemistry, it is difficult to compare these
samples with the background samples from Lake Herendeene. Inorganic....compounds such as
iron, manganese, and potassium are commonly elevated in wetlands such as the one sampled
near the site. The reducing environment, stagnant water, and organic content of the wetland can
result in elevated concentratio~ of naturally occurring metals. Since water samples from the
-wetland were unfIltered, these elevated concentrations may also be due to high particulate matter
in the wetland surface water. Therefore,_EPA believes the higher concentrations of inorganics
in the wetland are naturally occurring.
RISK ASSESSMENT
During the RI, an analysis was conducted to estimate the health and environmental threats, if
any, that could result if contamination at MWS was not addressed in some manner. This
analysis is commonly referred to as a baseline risk assessment. In the Superfund Program, a
baseline risk assessment is generally conducted on all sites at the time of the remedial
investigation. The baseline risk assessment is an analysis of potential health risks to the public
that would exist at a site if no action were taken. The routes of exposure evaluated in the
exposure assessment, based on contaminated media, current land use, and potential future land
use;-are as follows:
1.)
2.)
Direct exposure to co.ntaminated soils through ingestion;
Exposure via groundwater through ingestion and vapor inhalation.
Various media at the MWS site were sampled and underwent several analyses. Although nearly
all of the results showed "non-detects" or low levels of inorganic constituents, arsenic, beryllium
and lead underwent a quantitative risk assessment. A screening type of assessment was
performed to see if the highest detects in the future residential land use scenario (ingestion of
potable water and soil and inhalation of beryllium), the most conservative scenario, would
produce a significant risk. Listed below are the maximum concentrations of the three
constituents of concern at the MWS site.
Constituent
Maximum Concentrations
Arsenic
Lead
Beryllium
sOIl (mg/kg)
3.9
23
0.2
ground water (ug/U
3
12 (unfIltered)
1.2
12
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-
The National Contingency Plan (NCP) established a range of acceptable carcinogenic risk for
determining appropriate level of cleanup and whether a remedial action iswarranted. Generally,
where the baseline risk assessment indicates a cumulative site risk to an individual that exceeds
1 in 10,000 lifetime excess cancer risk, action under Superfund is generally warranted. At sites
where the cumulative site risk is less than 1 in 10,000, based on protectiveness, action is
generally not warranted. The NCP indicates that on those sites where action is warranted, the
ultimate cleanup for carcinogens will be within the range of 1 in 10,000 (1 x 10"") excess
lifetime cancer risk to I in 1,000,000 (1 x 1~) excess lifetime cancer risk.
- -The current risk for ingesting potable water was evaluated for the resident whose upgradient well
showed 1:2 ppb beryllium. Beryllium showed a carcinogenic risk through potable water, soil
ingestion and inhalation in the future residential land use scenario of 6.6 x 10>5. The estimated
inhalation risk from beryllium is 2.8 x 10-11, well below any risk levels of concern.
The 6.5 x 10-5 risk figure is based on a conservative risk scenario from a detection of 1.2 ppb
in nearby upgradient residential well. The risk is within the acceptable range of 1 x 10"" to 1
~10-6 upper bound lifetime cancer risk indicating no remedial action is necessary. Furthermore,
since beryllium was detected in an upgradient residential well and no other ground water sample,
EPA believes the beryllium to be an isolated local anomaly. However, for the sake of
determining any possible risk and wanting to favor a conservative risk approach, beryllium was
carried through the risk assessment process. Under the Superfund program no remedial action
is necessary for this risk level, however, EP A did notify the Michigan Department of Public
Health (MDPH) of this beryllium detection for Possible future monitoring. -
Exposure to contaminants that resultin a noncarcinogenic risk are also calculated in the baseline
risk assessment. These risks are calculated by comparing an exposure level (dose) over a
specific period of time with an established "reference dose" derived for a similar exposure time
period for that contaminant. If the exposure level dose exceeds that of the reference dose, an
unacceptable risk may exist at the site. This comparison is represented by a ratio whereby if
the resulting number is one (1.0) or greater, an action may be warranted at the site. For site
contaminants (inorganics) at MWS, the maximum noncarcinogenic risk from arsenic and
beryllium in both the soil and ground water is 0.16. .
Lead exposure was evaluated through the Uptake/Biokinetic Model. The purpose of the model
is to estimate the total lead uptake in humans that results from diet, inhalation and ingestion of
soil, dust, and paint and to predict a blood level based upon total lead uptake. The curren~ lead
program estimates lead uptake and blood lead levels in children of ages 0 to 6 years old. The
lead risk predicted through the Lead Uptake Biokinetic Model indicated that 99.97 % of the most
sensitive population, children, were belo~ the level of concern, 10 ug/deciliter, an estimated
insignificant risk.
13
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EXPLANA TION OF SIGNIFICANT CHANGES
There are no significant changes from the recommended alternative described in the May 1992
Proposed Plan. -
STATUTORY AUTHORITY FINDING
u.s. EPA and MDNR have determined that conditions at the site pose.no current or potential
threat to human health or the environment. No site related organic contamination was found
during the RI, however, inorganic constituents comparable to background levels were found
during the RI. Levels of inorganic constituents present in site soils and ground water do not
pose an unacceptable risk to human health or the environment. Accordingly, no action is
necessary at the MWS site.
As this is a decision for n Action Completion", the statutory requirements of CERCLA Section
121 for remedial actions are not applicable and no five year review will be undertaken.
14
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RESPONSIVENESS SUMMARY
Metal Working Shop site
Lake Ann, Michigan
The u.s. Environmental Protection Agency (U.S. EPA) has gathered
information on the types and extent of constituents found, and has
recommended actions to address the Metal Working Shop Superfund
site located along the northwest village limit of Lake Ann, Benzie
County, Michigan. As part of the remedial action process, a publ ic
meeting was held at the Almira Township Hall on May 28, 1992, and
was attended by nine people. The purpose of the meeting was to
explain the intent of the project, to describe the results of the
Remedial Investigation study (RI), and to receive comments from the
public. A court reporter was present to record the proceedings of
the public meeting. A copy of the transcript is included in the
Administrative Record.
Public participation in Superfund projects is required by the
Superfund Amendments and Reauthorization Act of 1986 (SARA).
Comments received from the public are considered in the selection
of the remedial action for the site. The Responsiveness Summary
serves two purposes: To provide the u.S. EPA with information
about the community preferences and concerns regarding the remedial
al ternati ves and to show members of the community how their
comments are incorporated into the decision-making process.
This document summarizes the oral comments received at the May 28,
1992 public meeting and written comments received during the public
comment period which ran from May 11, 1992 through June 9, 1992.
The comments from the community have been summarized and responded
to as follows:
Comment #1
One commentor pointed out that the site history, with its numerous
small shop/manufacturing operations, had the potential to cause
soil/ground water contamination triggering (and justifying) an
evaluation of the site. However, the 1984 U.S. EPA evaluation did
not define the presence of a real or potential problem at the site.
Furthermore, there is no excuse for not collecting soil boring
samples or existing water well samples during the 1984 evaluation
'by the U.S. 'EPA and that two years later in 1987 proposing to place
the site on the National Priorities List (NPL) was based entirely
on conjecture.
Response:
U.S. EPA agrees with the first part of this comment in which the
site history had a potential to cause soil/ground water
contamination. In response to the concern that the 1984 U.S. EPA
evaluation did not define a real or potential problem and that
without any sampling the site was placed on the NPL simply on
conjecture, U.S. EPA believes a potential problem was defined after
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"
2
reviewing site records and interviewing site owner/operators which,
even in the absence of sample data, permitted the site to be scored
under the Hazard Ranking Score (HRS) system and proposed to be
placed on the National priorities List (NPL).
Comment #2
A comment was received stating that even after Lake Ann
Manufacturing (LAM) conducted a hydrogeological investigation of
the site, splitting samples with the MDNR and having the split
samples analyzed by MDNR laboratories, which did not find soil or
ground water contamination, the site was still listed on the NPL in
1990 based on the not accurate speculation that contamination might
be present at the site.
Response:
U.S. EPA believes that the hydrogeological investigation conducted
by LAM and the MDNR in 1987 did not completely confirm the absence
of potential soil contamination at the site, therefore, at the
request of the State of Michigan and the approval of the' U.S. EPA
the site advanced from being listed on the proposed NPL to being
listed on the final NPL.
Comment #3
One commentor stated that the April 1991 February 1992
investigation of the site by the U.S. EPA appears, without
exception, to have substantiated and confirmed the results and
findings of Lake Ann Manufacturing's May 1987 investigation.
Additionally, the U.S. EPA investigation ran the risk assessment
process on constituents which were at background levels and
therefore not site specific and that the 1984 constituents have
since discharged into Lake Ann. .
Response: . .
The U. S. EPA investigation not only confirmed the results and
findings of LAM's May 1987 investigation, but also by conducting a
more in depth investigation of site soils than the LAM
investigation it alleviated all doubts that contamination may be
present at the site above health based risk levels. In response to
the second part of this comment it is U.S. EPA policy to conduct a
risk assessment on all sites that undergo remedial investigations
and since. no constituents were found above background levels U.S.
EPA had to select constituents at background levels to conduct the
risk assessment. In response to the third concern of this comment,
the commentor is correct, that the constituents suspected in 1984
would have since discharged into Lake Ann. However, if the
investigation would have discovered a source of contamination, a
constant source of contaminants discharging into Lake Ann could
have been a possibility. Fortunately no such source of
contamination was found to exist at the site.
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3
Comment #4
A comment was received concerning the detection of arsenic at 3
parts-per-billion (ppb) which is at 6% of its level of concern 50
ppb. The commentor would like to know if it was pertinent of the
EPA toxicologist to select arsenic since it was a single anomaly in
one unfiltered monitoring well sample and that while arsenic is
toxic per se, will it cause any toxic response to consumers at such
a concentration.
Response:
Even though arsenic was only detected in one sample at a low
concentration the u.s. EPA toxicologist selected it to run through
the risk assessment process based on its widely known and accepted
toxicity. The inclusion of arsenic in the risk assessment process
was to prevent any unnecessary public concern. The answer to the
last concern of the comment is no, arsenic will not cause any toxic
response to consum~rs at such a low concentration on its own, but
in addition to other possible contaminants, it could have been a
contributor to an unacceptable risk at the site. The level of
concern is more than 10 times the level detected at the site. See
also response to comment #6 concerning arsenic.
Comment #5
A comment was received concerning the organic compounds detected in
soil and ground water samples. It was stated that while these
compounds were detected as a resul t of analytic
materials/methods/procedures and not site derived, why was this
extraneous information included in the fact sheet.
Response: .
The inclusion of the organic data in the Fact Sheet was intended to
show what organic compounds were detected during the investigation
and that no organic contaminants of concern were found to be
contributing to the site.
. Comment #6
A comment was received stating that nearly all of the results
showed non-detects or low levels of inorganics. The commentor
would like to know why, what purpose, and what justification is
there for arsenic, beryllium, and lead to be evaluated in the
quantitative risk assessment process.
Response:
As stated in the remedial investigation risk assessment lead was
the only constituent which required an evaluation. Lead was
detected at a maximum concentration of 12.0 ppb in one unfiltered
monitoring well sample. This is slightly higher than the Maximum
contaminant Level (MCL) of 5.0 ppb for drinking water. Arsenic was
-------
4
selected because of its known toxicity value and not an exceedence
of any level of concern. Beryllium was selected because of its MCL
exceedence in one upgradientresidential well. u.s. EPA believes
that these three constituents, arsenic, beryllium, and lead, would
be the preferred constituents to be carried through the risk
assessment process even though the concentrations were, for the
most part, found at background levels. See response to comments #3
and #4.
Comment #7
A comment was received concerning the length of time involved with
making a final decision on the site. The commentor expressed
concern about the site going on for so long and that people and the
u.s. EPA put money into the site, and people worried about the
effects the site had on their residences.
Response:
U.S. EPA acknowledges that the Superfund process can be lengthy and
expensive, but in this case, both the time and money spent were far
below the national site average. U.S.. EPA streamlined the
investigation and used no contractor support to conduct the RI,
hence reducing the expense of time and money. U. S. EPA understands
the concern of residents neighboring a Superfund site and is
pleased in this case, to be able (based on site data) to recommend
the no action alternative and propose that the site be removed from
the NPL, therefore alleviating the concerns of all involved.
-------
ERD' SUPERF'UND
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STATE OF MICHIGAN
NATURAL RESOURCES
COMMISSION
LARRY DEVUYST
PAUL EISELE
GORDON E. GUYER
JAMES P. HILL
DAVID HOW
O. STEWART MYERS
JOEY M. SPANO
.
JOHN ENGLER. Governor
DEPARTMENT OF NATURAL RESOURCES
Stevens T. Mason Building. P.O. Box 30028, Lansing, MI 48909
ROLAND HARMES. Director
July 7, 1992
Mr. Valdas V. Adamkus, R-19J
Administrator, Region 5
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago, Illinois 60604-3590
Dear Mr. Adamkus:
'.I
The Michigan Department of Natural Resource~ (MDNR) has reviewed the U.S.
Environmental Protection Agency's (EPA) proposed Record of Decision for the
Metal Working Shop site in Lake Ann, Benzie County, Michigan. The MDNR
concurs with the "No Action" alternative selected by the EPA.
s;nc70?fl
}i;/OI6~~ )
1 517-373-7917
cc:
Mr. James Mayka, EPA
Ms. Rose Freeman, EPA
Ms. Susan Louisnathan, EPA
Mr. Sam Borries, EPA
Mr. Alan J. Howard, MDNR
Mr. Andy Hogarth, MDHR
Mr. William Bradford, MDNR
Ms. Claudia Kerbawy, MDNR
Ms. Denise Gruben, MDNR
Metal Working Shop File
R 1028
2/92
Oi
~
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..---..---
---.- ...---------------.--- -.
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I
ADMINISTRATIVE RECORD INDEX FILE COpy
METAL WORKING SHOP
LAKE ANN, MICHIGAN
ORIGINAL
04/07/92
um D~;E AUTHu~ RECIPJD;i TliLE/uESCF.IFTIDN PACtS
.... _.=0 1:::....8 ======= ===:::-.:::::===: =====
03/23/&7 Brown, J. Attorney lIyer, R., Director' COllenti- in opposition to EPA ~ proposd 14
H.z.rd Site Control,
USEPA
2 07l14lEi Brulb.ugh! C., Sht4fr.ro, F.! L.ke Letter' reI Site "
- I-
Sosling tzub.l Ann IIfg.
Allot.
.;, 07 miS':' L.k. Ann IIf~. lIyer. R.. Dir. Second Suppl.lent.l D~~asition tOllent' 4
Huirli~~! Si te
C~;.t..~~ ~ U:~~;'
l:miEi Fta.l,n. D.. r.D~r. lIark, i., IIDNR ue-li!ting of L.lt Aror. IIfO. 2
5 ell/30/iiB mDR USEFA rreiilinary He.~th A;sessser.t 4
',1
6 10119/;0 B:~r;es. S.! USEFA mt fli liork PI.n 32
7 O. ... ,-. ...~"". me LA~ ijA rrQjec~ Flan eo:,
:'/.0,"'. J~:'~~
E {\(ll1i;: Eorri&:, S., US£?A Pi:e PitH Suplinq Plar. ".
1.:.=
q C'2;2BiQ: :crr~ S., USEFA Fill - ."et.: !larking Shwp (~ike Ar.~ ~~;): Final Ri m
Report
u.s.
EPA ADMINISTRATIVE RECORD INDEX
UPDATE 11
METAL WORKING SHOP
LAKE ANN, MICHIGAN
-
00/17/92
DOCI mE AUiHCR RECIFIENT TliLE/DESCRIFiICN
---- a==: ===:.:.. =====811== ===::::::::::::::
OSm/92 Northwest Ke~orting U.S. EPA Public I!eetin~: 5i2S/92
F~DtS
-----
..'
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--------.--
.--------------... ----------.-.-
GUIDANCE DOCUMENTS
FOR
METAL WORKING SHOP
LAKE ANN, "ICHIGAN
(These Documents "ay Be Viewed at Region V Offices)
DOC' DATE AUTHOR
- - --
1 f1l01l85 U.S. EPA
2 04/01185 U.S. EPA
3 04/01185 U.S. EPA
4 06124/85 U.S. EPA
:1
5 09/01185 laretlona, II.J.
lIater Survey
6 011/01186 U.S. EPA
7 09/24/86 U.S. EPA
8 10/01186 U.S. EPA
9 12/01186 U.S. EPA
10 12/01186 U.S. EPA
11 12/24/86 U.S. EPA
12 03/01/87 U.S. EPA
13 03/01187 U.S. EPA
Doc.#
---
--
9285.2-01
9285.2-04
9285.2-05
EPA/600J2-85/104
9355.0-4A
Federal Register
9/24/86
9285.4-1
9355.1
9355.2-1
9355.0-19
9355.0-078
9355.0-078
06/25/92
TITLE/DESCRIPTION
a:::Inf--
Field Standard Operating Procedures llanual
'4-Si te Entry
Field Standard Operating Procedures llanual
l6-!1ork lones
Field Standard Operating Procedures llanual
'9-Site Safety Plan
RCRA/CERCLA DecisiOns lade on Rtltdy
Selection
Practical Sui de for Sround-liater Salpling
Superfund Reledial Design and Reledial Action
guidance
Suidelines for Carcinogen Risk Assesslent
Superfund Pubtic Hlalth Evaluation lIanual
Superfund Federal-Lead Reledial Projlct IIlna-
gellnt Handbook
Superfund State-Llad Reledial Project lIanagl-
lent Handbook
Interil Suidance on Superfund Selection of
Ruedy
Data Duality Objectives for Reledial Response
Activities Developlent Procesl
Data Duality Objlctives for Reledial Response
Activities Scenario: RI/FS Activities at a
Site lith Contalinated Soils and 6roundlater
PAGES
.......
29
19
26
3
175
100
13
500
179
120
10
150
120
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o
..... .. . -. .-....... - --&-
i .
~-_._- _..
. - - -- -~ -. .._. ~
,
f
DDC' DATE AUTHDR :Doc;'."" TITLE/DESCRIPTIDN PA6ES
-- ...... ....... ..===-- ===c::c======---= ...::8
14 05/01/87 Dffice of IIIter EPA/440/5-86-o01 Duality Critieria for liter 1986 .325
bgulations .
~) Standards
15 OS/21/B7 U.S. EPA EPA's I.ple.entation of the Superfund 4
A.end.ents and Reauthorization Act of 19B6
16 04/D1I88 U.S. EPA 9385.5-1 Superfund ElpDsure Assesslent Klnull 160
17 04/19/88 U.S. EPA Infor.ation on Drinking Mattr Action Ltytls 17
IB 06l01l8B U.S. EPA 9230.0-03B COllunity Relations in Superfund: A Handbook IBB
19 10/QO/88 U.S. EPA 9355.3-01 6uidanct for Conducting Rtltdial 195
Inyestigations and Feasibility Studitl
(RI/FS) Under CERCLA
20 OB/00/89 U.S. EPA 9234.1-01 CERCLA COIplianct lith Dther Lals "anual, 176
part 21 Cltan Air Act and Dther Environlentll
Statutes and State Requirellnts
21 06104/90 U.S. EPA 9230.0-06 Suplrfund Responsiveness SUllaries 190
22 OB/2BI90 U.S. EPA 9835.15 Perforlancl of Risk Assessllnts in Reledial 4
Inyestigation/Feasibility Studies
23 11/30190 U.S. EPA 9230.0-20 Innoy.taive "ethods to Incre.se Public 5
Involvelent in Superfund COllunity Relations
24 12/03190 U.S. EPA 9833.3A-l Final 6uidance on Adlinistr.tiye Record's for 110
Selecting CERCLA Response Actions
25 04/22/91 U.S; EPA 9355.0-30 Role of the Baseline Risk A55eSSIent in 10
Superfund Reledy Selection Decisions
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