"
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPNROD/R05-921220
September 1992
PB93-964126
&EPA
Superfund
Record of Decision:
Cannelton Industries, MI
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U. S. Enviro
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EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
.. .HazardoUs Waste Collection
< fOfqfmaffon Resource Center
: USePA RegIon 3
. PhlQdeIPhIa, PA 19107
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. NOTICE.
The appendices Itsted in the index that are not found in this dOcument have been removed at tt\e request ot
the issuing agency. They contajn material which supplement. but adds no ,.".. ~ informatiOn to
the content of the document. All supplemental material is. howaw. contBined in the admiIli8b4t1ve record
for this site.
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REPORT DOCUMENTATION 1" REPORT NO. I~ 3.: Recipient's Acce88lon No.
PAGE EPA/ROD/R05-92/220
4. 11l1e.nd Subtille 5. Repon Dete
SUPERFUND RECORD OF DECISION 09/30/92
Cannelton Industries, MI
First Remedial Action - Final 6.
7. Author(.) 8. ""rfomting Organization Rept. No.
9. ""rfomtlng Org.lnlzation Name .nd Addre.. 10. ProjectlT.llkJWork Unit No.
11. Contrect(C) or Grant(G) No.
(C)
(G)
12. Sponaoring Organlz8ll0n Name and Addreaa 13. Type 01 Repon & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
washington, D.C. 20460 14.
1 S. SUpplementary Note.
PB93-964126
'6. Ab8,...ct (Limit: 200 worda)
The 75-acre Cannelton Industries site is a former tannery facility located in the Upper
Peninsula of Michigan, in Sault Sainte Marie, Chippewa County. Land use in the area is
predominantly residential and light industrial, with 400 single-family residences and
an elementary school located within 1/2 mile of the site. Nearby residents and the
school are connected to the City's municipal water system, the source of which is the
Saint Marys River intake, 1 mile upstream of the Cannelton site. The Saint Marys
Ri ve r, which is used both as a drinking water source and for recreational purposes, is
adjacent to the lower area of the site. Part of the site lies within the 100-year
floodplain of the river, and several wetlands areas surround the site. Additionally,
the site overlies two aquifers that are hydraulically connected. From 1900 to 1958,
Northwestern Leather Company operated a tannery facility onsite. The plant had no
sewer system , and three drains discharged approximately 250,000 gallons per day of
chemical waste to the Saint Marys River and adjacent wetlands. Discharge wastes from
the tannery included metals, cyanide, sulfide, calcium carbonate, salts, formaldehydes,
thinners, acids, and alcohols. The primary discharge area covers 4 acres along the
(See Attached Page)
17. Document AnIIlyala L De.criptora
Record of Decision - Cannelton Industries, MI
First Remedial Action - Final
Contaminated Media: soil, sediment, debris
Key Contaminants: VOCs (TCE, xylenes), other organics (PAHs, PCBs, pesticides,
phenols), metals (arsenic, chromium, lead), inorganics
b. IdentifierslOpen.Ended Terma
c. COSA 11 FIeIdIGroup
18. Availability Statement 19. Security Cia.. (Thia Report) 21. No. of Pagea
I None 52
20. SecurIty CI... (This Page) n Price
None
See ANSI.Z39.18 lio"" on Re 2n (4-77)
50272.101
See '''''!rUt:
Vtlf8f1
(Formerty NTlS-35)
Deparlment of Commerce
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EPA/ROD/R05-92/220
Cannelton Industries, MI
First Remedial Action - Final
Abstract (Continued)
river to the north of the former plant site. Of this, approximately 1 acre ("the barren
zone") contains multi-colored soil and waste residues, has little vegetation, and has had
reportedly spontaneous fires occur in the past. A second area along the river at the
west end of the site was used as a dump site for barrels and "general" waste from the
tannery. In 1958, the tannery was destroyed by a fire; since then, the property has
remained unoccupied. EPA's removal program has been involved at the site on three
different occasions. In 1988, they responded to recurring fires and excavated five
trenches in the barren zone area. In 1989 and 1991, shoreline stabilization systems were
developed around the site to prevent waste materials from eroding into the river a fence
currently exists around the majority of the site. This ROD addresses a final remedy for
onsite contaminated soil, sediment, and debris and will mitigate impacts to surface water
and ground water through the containment of source materials. The primary contaminants
of concern affecting the soil, sediment, and debris are VOCs, including TCE and xylenes;
other organics, such as PAHs, pesticides, phenols, and PCBs; metals, including arsenic,
chromium, and lead; and inorganics.
The selected remedial action for this site includes excavating, dredging, and dewatering
debris, waste, soil, and sediment that exceed the clean-up criteria; placing these media
in an onsite solid waste landfill, and closing the landfill in accordance with RCRA
subtitle D, or more stringent state standards; filling in onsite excavated areas with
clean s9il to stabilize the shoreline; collecting ground water from the
dewatering/construction activities and treating the water, if needed, prior to offsite
discharge to POTW, or onsite discharge to surface water; conducting additional ecological
studies; monitoring ground water and surface water; and implementing institutional
controls to control land use, and potentially, deed restrictions to control ground water
use. The estimated present worth cost for this remedial action is $19,700,000, which
includes an annual O&M cost of $458,000 for years 0-1; $449,000 for years 2-3; $579,000
for year 4; and $303,000 for years 5-30.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil, sediment, and debris excavation standards are based on state
direct human contact (DHC) standards and include cadmium 100 mg/kg (DHC); lead 400 mg/kg
(DHC); arsenic 12.8 mg/kg (background); and carcinogenic PAHs 0.33 mg/kg (MDL). A
chemical-specific excavation goal for chromium was established using back calculations
based on a 10-6 cancer risk level for hexavalent chromium and an HI of 1 for trivalent
chromium, resulting in a clean-up standard of 5,300 mg/kg for trivalent chromium and
54 mg/kg for hexavalent chromium.
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Declaration
selected Remedial Alternative
for the
Cannel ton Industries site
site Name and Location
Cannel ton Industries site
Sault Ste. Marie
Chippewa County, MI
statement of Basis and Purpose
This decision document presents the selected remedial action for
the Cannelton Industries site, in Sault Ste. Marie, Michigan,
which was chosen in accordance with the requirements of 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 document explains the
factual and legal basis for selecting the remedy for this site.
The information supporting this remedial action decision is
contained in the administrative record for this site.
Assessment of the site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to pubic health, welfare,
or the environment.
Description of the Selected Remedv
The selected remedy is the final remedy for the site. The remedy
addresses the threats posed by contaminated soil and sediment,
and contaminated groundwater at the site.
The major components of the selected remedy include the
following:
.
Removal and disposal of debris, waste, soils, and sediments
in an on-site Michigan Act 641/RCRA Subtitle D landfill.
.
Collection and treatment of groundwater from
construction/dewatering activities.
.
Groundwater monitoring.
.
Land use restrictions for landfilled area.
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Declaration of statutorv Determinations
The selected remedy is protective of human health and the
environment, complies with federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. The remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies, to the maximum extent practicable.
"However, because treatment of the principal threats of the site
was not found to be practicable, this remedy does not satisfy the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
every five years after commencement of remedial action to ensure
that the remedy contin es to provide adequate protection of human
health 1;k 7iro ent. 9/~/tZ
Valdas V. da s
Regional Admin strator
Date
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RECORD OF DECISION
CANNELTON INDUSTRIES SITE
SITE NAME, LOCATION AND DESCRIPTION
The Cannelton Industries site is located in the Upper Peninsula of
Michigan in Sault ste. Marie, Chippewa County, in the NE 1/4 of
Section 11, 500 Township (T4 7N , R1 W) . Figure 1 depicts the
location of the site. The Cannelton site is located 1.5 miles west
of downtown Sault ste. Marie along the south shore of the Saint
Marys River. The site occupies approximately 75 acres, bounded by
the St. Marys River to the north; 4th Avenue and the 500 Railway to
the south; 18th Street to the west; and 12th Street to the east.
See Figure 2 for a site map with site features marked.
The Cannelton site is physiographically divided into two distinct
areas by a small bluff located adjacent to South Street on its
south side. This bluff constitutes an elevation change of
approximately 12 feet. The lower area, north of South Street, is
adjacent to the 5t. Marys River at an elevation generally less than
610 feet mean sea level. The upper area south of South Street is
typically at an elevation ranging from 630 to 640 feet. The lower
area is divided further by a smaller bluff, with about 6 feet of
relief, which may represent the former st. Marys River shoreline as
it existed prior to industrial activity in the area. This smaller
bluff is evident across the site and runs basically parallel to
South Street and the two-track in the western portion of the site.
Most of the area north of this smaller bluff is wetland and is
located in the 100-year floodplain, with an elevation of 3-5 feet
above average river level, which is 600.2-601.2 feet. The
remaining areas of the site are not in the 100-year floodplain.
other pertinent site features include a small bay located adjacent
to the site to the northeast called Tannery Bay. The eastern side
of Tannery Bay is formed by a dock, while the southern and western
sides are bordered by the site. The peninsula adjacent to Tannery
Bay that forms its western shoreline is referred to as Tannery
Point and is mostly wetland. Four ponds exist on Tannery Point and
are called Dump Pond, Middle Pond, Long Pond, and Beaver Pond.
Approximately 14,689 people live in Sault 5te. Marie. The current
land use surrounding the site is residential and light industrial.
There are approximately 400 single-family residences located wi thin
one-half mile of the site boundary, the majority of which are south
and west of the site. The nearest residence is a small apartment
building adjacent to the site, directly south of Tannery Bay on
South Street. McKinley Elementary School is located 100 feet south
of the western. portion of the site across 4th Avenue and is
attended by approximately 320 students. The nearby residences and
the school are connected to the city's municipal water system. The
source for Sault ste. Marie's municipal water is the st. Marys
River intake, approximately one mile upstream of the Cannelton
site. Sault ste. Marie, ontario, also obtains its municipal water
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2
from the river upstream of the site.
The tannery property is currently zoned for heavy industrial use.
The proposed twenty-year City Master Plan designates the majority
of the property for general industry, with the exception of the 4th
Avenue and 18th street corner, which has been projected as high
density residential.
The st. Marys River connects Lake Superior and Lake Huron via the
Soolocks and is the boundary between the United states and Canada.
Currently, the st. Marys River is being used as a major
navigational channel and a drinking water source for Sault ste.
Marie, Michigan and Sault ste. Marie, ontario. other uses are
primarily recreational, such as fishing and boating. The
groundwater beneath the site is not currently being used as a
drinking water source and is not expected to be used as such in the
future. The wetlands and Tannery Bay is currently used by wildlife
as habitat. Some recreational use of the bay is probably occurring
at present, although this use may be limited to fishing. Tannery
Bay is quite shallow so that boating and swimming would be
difficult, although wading would be possible.
Significant. surface water features occurring at. or near the
Cannelton site are the st'. Marys River; wetlands along the river;
Seymour Creek, which enters the St. Marys River approximately 200
feet west of the site; and Ashmun Creek, which enters the river
about 0.5 miles east of the site. The st. Marys River is the sole
outlet for Lake Superior, the largest fresh-water lake in the
world, and forms a connecting channel to Lake Huron, the third
largest fresh water lake in the world.
Most of the shore areas at the Cannelton site are wetlands with
wetland vegetation, soils, and hydrology. The st. Marys River is
the major hydrologic influence on these wetlands. The largest area
of wetlands are those located on Tannery Point, comprising
approximately 15 acres. These wetlands are primarily forested
wetlands and emergent cattail marshes. There are also a number of
springs/ponds that provide wetland hydrology. Some water also
originates from a sewer that probably services a nearby house
located on South Street in the eastern portion of the site.
The activities of two industries, the tannery and a sawmill
previously located in the eastern portion of the site, created the
potential for the existing physical setting and waste deposition
patterns at the site. Tannery Point originated as part of a large
pier which extended out into the river. The pier created the
western shoreline of Tannery Bay, and it appears that the sawmill
filled in much of the western side of the pier with scrap lumber
and sawdust. The pier also stopped some of the discharged tannery
waste from going downstream and allowed the waste to fill in on the
pier I s upstream side. This combination of f illing activities
created what is now called Tannery Point and accounts for the fact
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3
that much of Tannery Point consists of tannery waste as well as
sawmill waste material.
Although the entire site has been disturbed by human activity, in
most areas these disturbances occurred long ago, and the plant
communi ties have since adapted and the area is well vegetated.
While Tannery Point seems to have soils consisting mostly of
sawmill and tannery wastes, this area supports dense vegetation and
is mostly wetland. Tannery wastes are high in nitrogen and are
sold as fertilizer and soil conditioners, which may explain the
lushness of the vegetation. The plant communities which exist at
the site are diverse and generally of good quality, by wetland
standards. The wetlands contain four ponds and variety of other
habitat types, making it suitable for many types of small wildlife
and birds. Several species have been observed at the site,
including white-tailed deer, beaver, ground hog, green heron, wood
thrush, mallards and Canada goose. There are no known occurrences
of Federal- or State-listed endangered, threatened, or otherwise
significant species, natural plant communities, or natural features
at the Cannelton site.
There are two aquifers which are hydraulically connected beneath
the site. The shallow aquifer consists of glacial deposits and is
primarily characterized as silty sand, but there are also site-wide
variations such as a linear deposit of gravels and cobbles, a
fairly continuous layer of sand and gravel above the bedrock and a
thin layer of clay serving as a discontinuous confining layer in
some of the deeper wells along the river. The bedrock underlying
the unconsolidated deposits, the Jacobsville Sandstone, has
considerable topography at the site. There is a buried bluff in
the bedrock located near South Street, which causes the depth to
bedrock to vary from approximately 30 feet south of South Street to
approximately 60 feet near the river. In spite of this, there is
a continuous aquifer connecting the upper and lower areas of the
site and the st. Marys River. The depth to the water table ranges
from approximately 8 feet to 23 feet in the plant area and 1 foot
to 7 feet in the area north of South Street.
The site-wide groundwater gradient is towards the st. Marys River.
vertical gradients are downward in the southern portion of the
site, indicating a recharge zone, and upward in the northern
portion, indicating discharge to the river. The average
groundwater velocity for the site was calculated to be 0.19 ft/day
or 70 ft/year. The velocity may vary based on the different soil
types found across the site. .
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Cannelton Industries site is the location of a former tannery
called the Northwestern Leather Company. During its period of
operations, roughly 1900 to 1958, the tannery processed primarily
cowhides using a sophisticated and multi-step process which
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4
transformed raw animal hides to a finished leather. The plant had
no sewage system other than three drains, which included pipes and
open ditches, running to the shores of the st. Marys River to what
is referred to as the waste discharge zone. According to
historical records and interviews with former employees, no liquid
waste was discharged to the east, west or south of the plant.
During busy times of operation, the plant might discharge up to 132
chemical vats per day, or approximately 250,000 gal/day, through
the drainage system. Historical aerial photographs indicate that
waste was discharged directly to the st. Marys River and adjacent
wetlands.
A second area along the st. Marys River, located at the west end of
the site, was used as a dump site for barrels and "general" wastes
from the tannery. According to former employees of the tannery, up
to two truck loads of plant wastes were disposed of per day. These
wastes were typically burned after disposal.
The known and expected wastes discharged from the tannery in the
area adj acent to the river included metals, cyanide, sulf ide,
calcium carbonate, salts discharged as brine solutions, and various
leather finishing solutions such as shellacs, thinners, formic and
carbolic acids, formaldehyde, ammonia, octoalcohol and other
alcohols. Chromium is the primary metal known to be disposed.
Tannery waste has been exempted as a listed hazardous waste under
the Resource Conservation and Recovery Act (RCRA).
The pr imary tannery waste discharge area covers a 4 -acre area north
of South street and includes an irregularly shaped area of
approximately one acre which is partially devoid of vegetation and
contains multi-colored soils and tannery waste residues. This area
is referred to as the "barren zone". The barren zone was likely
the location where solid waste byproducts of the tanning process
were dumped. Spontaneous fires have reportedly occurred in this
area in the past.
Aerial photographs indicate that some of the tannery waste
deposited 'on the st. Marys shoreline has eroded over time. Both
this eroded material and material dumped into the river during the
plant's operation were likely carried by the river downstream and
deposi ted both along the shoreline of Tannery Point and in the
low-energy water found downstream in Tannery Bay.
The 75 acre property was once owned by the now defunct tannery,
Northwestern Leather Company (Northwestern). The plant was located
in northern Michigan due to the location of the hemlock forests,
hemlock bark being a major source of tanning extract. The tannery
operated from 1900 until 1958, going out of business for a number
of reasons. The tannery was destroyed by fire in 1958.
In 1955, Fiborn Limestone Company (Fiborn), a sUbsidiary of the
Algoma Steel Corporation (Algoma), purchased a portion of the site,
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5
granting an easement to Northwestern for the tannery drains.
Following the tannery closing in 1958, Fiborn acquired the
remainder of the site from Northwestern. The property was then
transferred to Cannelton Coal Company, which became Cannelton
Industries, Inc., a wholly owned subsidiary of Algoma. The
property was to be used by Algoma for a fabricating plant for steel
pipe, a project which was never realized. The last of the
buildings were torn down by Algoma in the 1970's and at present
only scattered debris and concrete foundations remain in the plant
area. In .1991, AMAX Coal Industries, Inc., of Indianapolis,
Indiana, purchased Cannelton Holding Company, which owns Cannelton
Industries, Inc.
Prior to the Remedial Investigation (RI), environmental sampling at
the Cannelton site from 1978 through 1988 had partially delineated
the nature of contamination. Sampling was performed by the
Michigan Department of Natural Resources (MDNR) in 1978, 1979 and
1980, and by the property owner periodically from 1979 to 1986. In
1987, the United States Geological Survey (USGS) installed a
monitoring well at the Cannelton site. The majority of the
historical sampling performed on-site had been limited to the area
in or adjacent to the barren zone. A minimal amount of ground
water, surface water, and sediment sampling had also been
performed.
The sampling prior to the remedial investigation suggested soil
samples from the barren zone were contaminated with cadmium,
chromium, copper, nickel, lead, zinc, arsenic, and cyanide. River
sediments adjacent to the site contained many of the same
compounds. Limited ground water sampling indicated the presence of
cyanide, chromium, lead, manganese, and iron. The surface water
sampling and analyses conducted prior to the RI did not indicate
extensive contamination of the. surface water. Historical
detections were few and generally unverified.
U.s. EPA's removal program has been involved at the site on' three
different occasions. In June 1988 the Sault Ste. Marie Fire
Department contacted the MDNR, who in turn called the U.s. EPA
Emergency Response section, due to recurring fires at the Cannel ton
site. The fires, which were located within the barren zone,
reportedly occurred spontaneously during the dry summer months and
had been increasing in intensi ty. U. s. EPA responded to the
request and excavated five trenches within the barren zone, in
order to delineate the source of the fires, reduce methane build-up
from biological activity, and to disperse heat build-up within the
soils. The excavations did not reveal a readily apparent source
for the fires. At that time the property owners fenced and
padlocked the barren zone area.
In 'May 1989, the u.s. EPA removal program issued a Unilateral
Administrative Order (UAO) to the Potentially Responsible Parties
(PRPs), who were the property owners, Cannelton Industries, Inc.
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6
and its parent company, Algoma steel corporation. The UAO directed
the PRPs to install a sprinkler system to help reduce the incidence
of fires, to further investigate the cause of .the fires, and to
construct a shoreline stabilization system in front of the barren
zone to prevent waste materials from eroding into the river. The
sprinkler system was installed immediately, and rip-rap was
installed along the shoreline in front of the barren zone in
November 1989. The investigation did not determine the cause of
the fires.
In September 1991, Cannel ton Industries, Inc. entered into an
Administrative Order on Consent (AOC) with U. S. EPA under the
authority of the removal program. This AOC required the PRPs to
fence a larger area of the site to prevent access to contaminated
areas and to extend the shoreline stabilization both to the east
and west of the existing rip-rap to protect other shoreline areas
from erosion. This work was conducted from September to November
of 1991.
In June 1988, U.S. EPA proposed that the Cannelton Industries site
be added to the National Priorities List (NPL). Also that month,
U.S. EPA issued Special Notice Letters to Cannelton Industries and
Algoma Steel corpora~ion, requesting that they conduct a Remedial
Investigation and Feasibility Study (RIfFS) at the site. Since no
settlement with the companies was reached, U. S. EPA funded the
RIfFS and issued a work assignment in September 1988 under the ARCS
contract to WW Engineering & science to conduct the RIfFS. The
site was added to the NPL on August 30, 1990 (55 Federal Register
35501-35525).
Field work for the RIfFS took place over the period from June 1989
to October 1990. Samples were collected during two sampling
phases: phase one field work occurred from June to December 1989,
while phase two field work occurred in October 1990. Sediment
samples were collected from 57 locations during Phase I and II.
Surface water samples were collected only during Phase I from 17
locations. Soil samples were collected from 78 locations during
Phase I and 16 locat:.:- - iuring Phase II. soil samples were also
collected off-site at ~ :esidential properties and one sample from
the school yard during Phase I. Sixty-two monitoring wells were
installed with each well sampled twice. during the Phase I
investigation. Samples were analyzed according to the approved
Quality Assurance Project Plan (QAPP) for inorganic and organic
compounds on the Target Analyte List (TAL) and the Target compound
List (TCL). Sediment toxicity, groundwater toxicity and benthic
macro invertebrate studies were also conducted.
Additional field work was conducted by U.S. EPA's Environmental
Response Team (ERT), Edison, New Jersey, in October 1991 and May
1992. The first study involved additional sediment and soil
toxicity tests and benthic macro invertebrate studies. The May 1992
field work consisted of a habitat survey of the wetlands on site
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7
and some preliminary mapping of the extent of tannery waste in
Tannery Bay. Reports for each of these studies were prepared by
ERT.
In preparation for the FS, two bench-scale treatability studies
were conducted on soils/wastes and sediments from the site. These
treatability studies evaluated stabilization and soil flushing as
two potential technologies for treating the contaminants at the
site.
The RI Report was published in September 1991. A Baselin~ Risk
Assessment, bound under separate cover, was completed in October
1991. The FS was published for public review and comment in April
1992 and contained six remedial alternatives. A FS Addendum, which
added an alternative to be considered for the site, was completed
in July 1992.
HIGHLIGHTS OF COMKUNITY PARTICIPATION
A community relations plan was developed in 1989 to document
community concerns and to plan an information strategy. U.s. EPA
has held three public meetings to keep the public informed about
the activities at the site. U.S. EPA has also sent out fact sheets
at various times during the RI/FS process.
As part of its community relations program, U.S. EPA has maintained
an information repository at the Bayliss Public Library, 541
Library Drive, Sault Ste. Marie, Michigan. Documents and reports
regarding the Cannelton Industries site prepared by u.s. EPA and
the MDNR are contained in this repository.
u.s. EPA notified the local community, by way of the Proposed Plan,
of the recommendation of a remedial alternative for the Cannel ton
Industries site. To encourage public participation in the
selection of a remedial alternative, U.s. EPA scheduled a public
comment period from July 15 through August 13, 1992. Based on
requests from the MONR and community members, the public comment
period was extended an additional 30 days to September 14, 1992.
On July 28, 1992, U.S. EPA held a public meeting to discuss the
recommended remedial alternative and the other alternatives.
identified and evaluated in the FS. A transcript of the meeting is
included as part of the Administrative Record for the Cannelton
Industries site. U.S. EPA's responses to comments received during
this public meeting and to written comments received during the
public comment period are included in the Responsiveness Summary
which is attached to this ROD.
Press releases were sent to Sault Ste. Marie, Michigan media, and
advertisements were -placed in the Sault Evening News concerning the'
public meetings, the comment period, and the extension to the
comment period.
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8
The public participation requirements of CERCLA Sections
1~3(k) (2) (B) (i-v) and ~17 were met in the remedy selection process.
SCOPE AND ROLE OF RESPONSE ACTION
The remedial action will address risks to people due to ingestion
of and dermal contact with soils and waste material, inhalation of
dust from the site, and ingestion .of groundwater beneath the site.
Another goal of the cleanup is to address impacts to the surface
water due to groundwater discharge or resuspension of contaminated
sediments, and to minimize the effect of contaminants on such
aspects of the environment as benthic (bottom-dwelling) organisms
in the river, the on-site wetlands, and fish, bird and terrestrial
populations. Included in the evaluation of overall environmental
threat was the relative impact to the environment due to excavation
or dredging as well as contaminants.
This remedial action is expected to be the final action for the
site. All media (groundwater, surface water, air, soil, sediment)
at the site are addressed by the selected remedy. The main
component of the remedy includes excavation, consolidation and on-
site containment of debris, wastes and soils and sediment
contaminated above clean-up criteria. Groundwater and surface
water would be addressed by removal of the source material and
would be monitored. Additional monitoring of the environment would
be conducted to ensure protection. Land-use restrictions in the
containment area and restrictions on groundwater use would also be
sought. The selected remedy is described in more detail in the
section titled "Selected Remedy".
No principal threat which warrants treatment at the site has been
identified. While the waste at the site does not readily fit the
definition of a principal threat, it also cannot be classified on
the whole as a low level threat. Treatment options were evaluated
for the source material (soils, wastes and sediments), and two
bench -scale treatability studies were conducted. It was determined
that no added benefit would be derived from treating the source
material using anyone of the three technologies evaluated, making
treatment impracticable. It was also determined that, given the
waste characteristics, chiefly the low mObility of the principal
contaminants, containment of the source material would be a safe
and reliable option when coupled with institutional controls and
monitoring.
SUMMARY OF SITE CHARACTERISTICS
The source of contamination at the site"was the discharge to the
river and shoreline of primarily liquid tannery waste through the
drains from the plant and the dumping of solid tannery waste and
debris along the river shoreline. This release created the present
accumulation of waste and contaminated soils and sediments, which
is a continuing source of actual and potential contamination to the
-------
9
groundwater, surface water and air.
The primary contaminants found at the site are metals. The
concentrations of inorganic compounds in soils and sediments at the
Cannelton site closely follow the historical land use and the
currents in the st. Marys River. The highest values are associated
with the former tannery drains and discharge areas, while elevated
levels of metals are also present in the soils along the western
shoreline of the site where general refuse was dumped, in the
former plant area, and along the shoreline east of the main
discharge area and in the adjacent wetlands. Based upon their
distribution within the soils and sediments, the following
inorganic compounds were found to be elevated at the site due to
former tannery practices: chromium, arsenic, lead, mercury, barium,
and cadmium. Chromium is the most wide-spread inorganic
contaminant in the soils and sediments at the site. Following are
the maximum concentrations (in mgjkg) detected in soils and
sediments of each of the above-listed metals:
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
SOILS
3,600
10,300
341
328,000
10,100
25
SEDIMENTS
29.6
202
26.1
40,000
603
2.3
Both the EP Toxicity test and the Toxicity Characteristic Leaching
Procedure (TCLP) analysis were performed on samples of site soils,
wastes and sediments. The results of these tests indicate that the
site soils, wastes and sediments are not classified as RCRA
characteristic hazardous waste.
The analysis for organic compounds in soils and sediments indicate
a sporadic distribution of volatile, semi-volatile, pesticide and
poly-chlorinated biphenyl (PCB) compounds. Several polynuclear
aromatic hydrocarbon (PAR) compounds are found at the site. These
are more prevalent at the surface and may be due to historical
fires at the site in the barren zone, the plant area and the
western dump area. Total concentrations of carcinogenic PAHs in
the 0-2 foot depth ranged up to 16.7 mg/kg.
The groundwater at the Cannelton site is not widely impacted from
the former tannery operations. In the tannery waste discharge area
the ground water is impacted only at one well, MW45, with arsenic
(31,600 ~g/L), cadmium (30.2 ~g/L) and chromium (79.5 ~g/L) from
the tannery wastes. The arsenic and cadmium concentrations exceed
the Maximum contaminant Levels (MCLs) of 50~g/L and 5~g/L,
respectively. The site-wide elevated levels of iron and magnesium,
and localized elevated levels of lead are believed to be consistent
with background conditions. Elevated aluminum concentrations may
be associated with the tannery waste, although aluminum was also
-------
10
encountered in upgradient monitoring wells. Vanadium, detected in
only a few samples, and above Michigan Act 307 standards at MW36
(111 ~g/L), could be related to the former tannery.
Volatile and semi-volatile organic compounds are not found
consistently within the ground. water at the site.
Tetrachloroethene was detected at 7 ~g/L (MCL = 5 ~g/L) in one
well, but was only detected in two other wells on site at lower
levels.
The surface water was not found to be highly impacted. Chromium
was detected in some samples of river water and pond water above
water quality criteria, with the range of detected concentrations
being 1.1 ~g/L - 485 ~g/L. An analysis for hexavalent chromium was
performed, but it was not detected in the surface water at a
detection limit of 10 ~g/L.
Much of the chromium at the site is present in tannery wastes,
which significantly affects the mobility of chromium at the site.
Trivalent chromium is used in tanning because it forms very stable
coordination complexes that can bind and cross-link hide protein
fibers (collagen tissue) in leather. The waste material consists
partially of leather which was treated with chromium in the tanning'
process, as well as other organic material which would also bind up
chromium. Leachate tests (both EP toxicity and TCLP) were
conducted on tannery wastes and other soils and sediments as part
of the remedial investigation. The results of the leachate tests
indicated that the wastes, soils and sediments have low potential
for leaching and are not characteristically hazardous with respect
to chromium or other metals. In addition, the groundwater data
show that chromium was detected above the quantification limit
(which is 5 times the maximum field blank contamination; for'
chromium the limit is 33 ppb) in only three wells out of 65 at the
site. At 21 wells sampled, concentrations of chromium were low
enough to be below the quantification limit, making it uncertain
whether the detection was significant or not. None of the chromium
detections were above the MCL or Act 307 Type B (heal th-based)
standard. These results suggest that there is little potential for
chromium to leach from waste materials at the site.
Estimates of contaminated material depend on the criteria used to
differentiate contaminated from non-contaminated material. If
background concentrations for metals are used, the volume and
weight of impacted soils and sediments are approximately 406,500
cubic yards or 605,500 tons. If specifically human health-based
criteria are used (1 x 10~ or a hazard index of 1 for ingestion,
dermal contact or inhalation), the volume and weight of impacted
soils and sediments are approximately 199,700 cubic yards or
290,600 tons.
The soil boring and well logs indicate that almost all parts of the
-------
11
site are covered by some fill. The fill consists of materials such
as scrap leather, leather waste, hair, cinders, bricks, concrete,
scrap wood, scrap metal, glass and cans. The most extensive fill
occurs between South Street and the river: along the river in the
west part of the site; and in the barren zone. Relatively little
fill occurs in the west part of the site south of the two-track
along the river; the east part of the site south of South Street;
and in the far east part of the site. River sediments adjacent to
and downstream from the tannery waste discharge area contain both
tannery waste and lumber scraps. The thickest accumulation of
tannery waste (up to five feet) in the sediments occurs in Tannery'
Bay where the river currents deposited suspended tannery waste.
Generally speaking, contaminated areas correlate relatively well
with filling performed by the tannery operations, but with varying
levels of contaminant concentrations. The vertical extent of
contamination does not appear to go deeper than 10 feet below the
ground surface, and in most cases it is shallower. contaminated
material does extend below the water table, particularly in the
area north of South Street.
The environmental transport media at the Cannelton site are air,
surface water, and ground water. site-related sediments and any
absorbed chemicals of potential concern could be transported
downstream from the site by the flow of the st. Marys River. From
aerial photographs, one pattern of sediment deposition can be
identified in which sediments and shoreline debris from the site
are transported downstream .and into Tannery Bay. Surface water
could become contaminated by resuspension of sediment or erosion of
contaminated site soils and waste. Erosion of site soils/wastes
could further contaminate sediments as material is transported and
deposited downstream.
The leaching of water through contaminated soils and wastes and
into ground water may result in the transfer of chemicals of
potential concern from the soils and wastes into ground water and
then into surface water. Leaching of contaminants from sediments
may similarly affect surface water. This' transfer depends on
several physical and chemicals characteristics of both the
chemicals and the soils/wastes or sediments. Sampling and analyses
of ground water and surface water at the tannery site indicate that
extensive leaching is not occurring at present.
Air may transfer chemicals of potential concern any distance from
the site. Chemicals may volatilize or wind may disrupt surface
soils resulting in fugitive dust emissions.
Potential receptors could be residents in the area or adjacent to
the site, elementary school children, and recreational users of the
property. However, the potential for exposure, with the exception
of the air pathway, has been reduced due to the fence now enclosing
most contaminated areas.
-------
12
As for natural resource receptors, the site is located on the shore
of the st. Marys River, which is an important navigational waterway
as well as an Area of Concern as designated by the International
Joint Commission. Possible targets in the river would be fish and
benthic organisms. A large portion of the site north of South
Street has been identified as wetlands. This area includes Tannery
Point as well as areas east of Tannery Point along the southern
shore" of Tannery Bay. Possible targets in the wetlands would be
plants, birds, amphibians and a variety of mammals.
SUMMARY OF SITE RISKS
In order to characterize the current and potential threats to human
health and the environment that may be posed by the contaminants at
the site, a Baseline Risk Assessment (RA) was prepared according to
U.S. EPA's Risk Assessment Guidance for Superfund (RAGS): Volume
1 - Human Health Evaluation Manual (Part" A) and RAGS: Volume 2 -
Environmental Evaluation Manual.
In order to calculate risks to human health and the environment
posed by the Cannelton Industries site, chemicals of potential
concern were identified. Chemicals of potential concern are
defined as chemicals that are potentially site-related and whose
data are of sufficient quality for use in the quantitative risk
assessment. Chemicals of potential concern were identified'based
on sampling of soil, ground water, surface water, and sediments at
the site and at background locations. The site history, analytical
methods, quantitation limits, data qualifiers, concentrations in
blanks, and background concentrations were evaluated as described
in RAGS. A summary of chemicals of potential concern based on this
evaluation is presented in Table 1. This is the same as Table 2-9
of the Baseline Risk Assessment.
As can be seen in the table, the site was divided into seven areas
for evaluation: disposal and plant area soils, other soils at the
property, groundwater under the site, surface water of the st.
Marys River, surface water in four on-site ponds, sediments along
the property shoreline in the st. Marys River and Tannery Bay, and
sediments in four on-site ponds. An eighth area which is evaluated
is air. No air samples were collected during the RI, therefore the
potential risks due to this media are modelled.
After evaluating the contaminated media and migration pathways
present at the site, several current and future populations which
could be exposed to the contaminants at the site were identified.
Current populations are: adjacent residential adults and children
and on-site recreational adults and children. Future populations
are: on-site residential adults and children, on-site recreational
adults and children and occupational adults if a business was built
on-site.
Routes by which a person could be exposed to contamination were
-------
1'.11;1: I III" j
Table
Summary of Concentration Ranges of Chemicals or Potential Concern
Disposal and River Pond River Pond
Chemical Planl ~a Olher Soil Ground Water Surface Waler Surface Water Sediment I SedimtOI
(maJtl) (maJts) (man) (msJI) (msJI) (mglks) (mglkg)
Aluminum 450 - 13000 491 - 6170
Antimony 4.5 - 1860 0.006 0 0.006 1.1 0 149 62 - 62
Arsenic 0.19 - 3600 9.3 - 23 0.02n . 31.6 0.54 o' 29.11 0.69 - 9.11
Barium 6.5 - 10300 247 - 350 0.0663 - 0.374 0.0111 - 0.0291 0.0491 - 0.0881 15 - 202
Cadmium 0.' - 341 0.0156 .0.0302
Calcium 2200 - 221000 23600 - 23600 4.56 - 240 13.1 - 19.1 33.2 . 43.8 2310 - 11100
Chromium, lotal 9.1 - 328000 120 - 120 0.0333 - 0.0795 0.0011 - 0.485 0.0033 - 0.0283 2.2 0 31000 34.8 06210
Chromium, VI 120 - 15000 nol analyzed nol analyzed 22 - 2100 440 . 440
Coball 0.9 - 62 0.0033 - 0.0075 0.0063 - 0.0063
Copper 1.1 - 651 0.0069 - 0.0069 12.4 - 82
Cyanide 0.4' - 4.9 0.94 - 1.2 3.3 - 1.2
Iron 149 - 239000 12.1-47.3 934 - 13100
Lead 1.6 - 10)(10 9.3 - 266 0.003 - 0.012 3.5 - 603 30.8 - 1220
Magnesium 120 - 22300 1.51 - 134 2.63 - 3.82 9.93 - 16.1
Manganese IS - 1230 33.1 - 866 0.0504 - 3.62 8 - 280
Mercury 0.04 - 25 0.1 - 0.5 0.11 . 1.9
Nickel 2.9 -III
Polassium 115 - 1300 342 - 1040 0.917 - 37.3 1.93 - 2.17 82.3 - 756 191 - 968
Selenium 0.61 -110 0.0031 - 0.0031
Silicon 270 - 410 nol analyzed nOi analyzed nol analyzed nOI analyzed nol analyzed nlll analyzcd
Sliver 0.92 - 32.8 '
Sodium 4.7 - 732 18.9 . 23.3 81.9 - 448
Slronlium 6.3 - 18 nOI analyzed nOi analyzed 0.0216 - 0.0396 0.145 0 0.288 nOi analyzed nol allalyzcd
Thallium 0.33 - 22 0.25 - 0.59 0.36 - 1.5
Vanadium 2.3 - 163 5.6 . 45.3 0.0223 - 0.111 0.n053 0 0.n056 2.1 041.5
Zinc 4.2 - 4950 4.8 0252 6.8 - 60.6
Acelone 0.11 - 9.2 0.14 - 0.14 1101 analyzed
2-Bul8nonc 0.001 - J5 0.009 - 0.012 nol analyzed
Chlorobenzcnc 0.002 - 0.012 nol analyzed
Melhylene OItoride 0.12 - 22 nol analyzed
Wdl/lllo j;'c:IIIIIClloIMLL.T81.XLS 04001.14 P,iulcd; 6/28/91
-------
Pal;'- 1. o( 3
Table
Summary of Concentration Ranges of Chemicals of Potential Concern
Disposal and River Pond River Pond
Chemica' 8anl Aree Olher Soil Ground Waler Surface Waler Surface Waler Sedimenl Sedimenl
(milks) (msJks) (mall) (mall) (mg/l) (mgJks) (mg/kg) .
TClrachloroelhene 0.002 - 0.026 0.002 - OJ)02 0.002 . 0.001 0.002 - 0.003 nol analyzed
Trichloroelhene 0.002 - 0.027 0.0006 - 0.0006 nOI analyzed
Toluene 0.003 - 0.017 nol analyzed
1,1,1- Trichloroelhane ().0001 - 0.O()()1 nol analyzed
Xylene (lolal) 0.002 - 0.04 nol analyzed
Acenaphlhylene 0.OS4 - 7.8 0.057 - 0.057 nnl analyzed
Anlhracene O.OSI ~ 22 0.039 - 0.039 nol analyzed
Benzo(a)Anrhrncene 0.078 - 56 0.1 - 0.12 nol analyzed
Benzo(a)Pyrene 0.061 -18 0.13 - 0.18 nol analyzed
Benzo(b )FllJoranrhene 0.092 . 46 0,32 - 0.38 nol analyzed
Benzo(g.h.i)Perylene 0.11 .42 0.04 - 0.066 nol analyzed
Benzo(k)f1lJoranlhene 0.098 - 35 0.13 - 0.11 nol analyzed
Benzoic Acid 0.16 - 0.16 nol analyzed
Benzyl Alcohol 0.006 ~ 0.006 nol analyzc;d
bis(2.Elhylhexyl)Phlhalale 0.001 .0.018 0.002 - 0.002 nol analyzed
Chrysenc 0.09" - 10 0.16 .0.19 nol analyzed
Oibenz(a.h)Anlhracene 0.34 - 21 nol analyzed
OibenzoflJran 8.01 - 3.9 0.081 - 0.081 nol analyzed
Oi-n-Bulylphthalale 0.24 - 0.24 0.001 - 0.001 0.002 . 0.002 nol analyzed
Fluoranlhene 0.046 - 95 0.28 - 0.33 nol analyzed
Fluorene 0.11 - 12 nol analyzed
Indeno( 1,2.3-cd)Pyrene 0.018 - 38 0.047 - 0.074 nol analyzed
2-Melhylnaphlhalene 0.068 - 8.8 0.21 - 0.21 1101 analyzed
3-Melhylphenol 1.4 - 1.4 1101 analyzed
4-Melhylphenol 0.11 - 0.31 nol analyzed
Naphlhalene o.on - 10 0.18 - 0.18 nol analyzed
Phenanlhrene 0.043 - 100 0.14 - 0.26 nol analyzed
Phenol 0.001 - 0.019 nol analyzed
Pyrene 0.022 . 130 0.21 - 0.25 1101 analyzed
2,4"- Trichlorophenol 0.24 - 3' nol analyzed
wd.'m - J:~lIInellon\ALL-11IJ.xLS 0400'1.14 Prinlcd; 6128191
-------
C:hemica'
alpha-Chlordane
gamma-Chlordane
4,4'.DDD
4,4'-00E
4,4'-001
Aroclor-12S4
Aroclor-1260
Table' i
Summary of Concenlration Ranges of Chemicals of Polenlial Concern
Disposal and
Plnnt Areq
(mllka)
0.11 - 0.11
0.0021 - 0.11
0.0091 - 0.11
0.006.5 - 0.2
0.002 - 0.2S
0.021 - 2.8
0.62"- 0.65
Olher Soil
(msJkl)
Ground Waler
(man)
-- - = nol dClecied or nol del~led in blanks.
wd.,.... J:'Unncllon\ALL-TB~.XU IHOIIU4
River
Surface Waler
(mall)
Ppnd
Surface Waler
(mall)
River
Sedimenl
(maJka)
Pag~ j of 3
Pond
Stdiowtl
(maJkg)
nlll analyzed
nol analyzed
nol analyzed
not analyzed
1101 analyzed
1101 analyzed
nol analyzed
l'rinlcd: 6nB/91
-------
13
also identified.
These are:
I. Ingestion of or dermal contact with soil
II. Ingestion of groundwater
III. Dermal contact with and/or inhalation of groundwater
through showering
IV. Inhalation of vapor or particulates at site, workplace or
residences
Ingestion of or dermal contact with surface water or
sediments
V.
Each route of exposure was evaluated for each population with a few
exceptions: current residential and recreational populations were
not evaluated for the groundwater ingestion scenario because there
are no drinking water wells currently on-site, only the future
residential population was evaluated for the showering scenario,
and the future occupational population was not evaluated for
ingestion or dermal contact with surface water or sediments.
For each exposure pathway evaluated, carcinogenic and
noncarcinogenic health risks were characterized for the reasonable
maximum exposure risk scenario. Exposure assumptions made for each
pathway can be found in Table 3-11 of the RA. In general, the
standard and default exposure assumptions recommended by u.s. EPA
guidance were used, as well as conservative estimates and best
professional judgement. In general, residential and recreational
exposure assumed 350 days/year for soil ingestion and dermal
contact scenarios, groundwater scenarios and the inhalation
scenario. occupational exposure was assumed to be 250 days/year.
Exposure to surface water and sediments while swimming or wading
was assumed to be 7 days/year.
Intake equations from RAGS Volume 1 and the exposure assumptions
were used to estimate potential chemical intakes by the various
populations.
The toxicity assessment identified the available and appropriate
toxicity values for each chemical of potential concern, including
chronic and sub-chronic reference doses and slope factors. The
IRIS database, Health Effects Assessment Summary Tables, and the
u.S. EPA Environmental criteria and Assessment Office (ECAO), were
consulted for information. Inadequate carcinogenic and/or
non-carcinogenic toxicity information was available for several
chemicals of potential concern. The possible health effects of
these chemicals and consequences of their exclusion from the risk
assessment are unknown.
Reference doses (RfDs) have been developed by u.S. EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting non-carcinogenic effects. RfDs, which are
expressed in units of mg/kg/day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
-------
14
Estimated intakes of chemicals from environmental media (e.g., the
amount of a chemical ingested from contaminated drinking water) can
be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors help
ensure that the RfDs will not underestimate the potential for
adverse non-carcinogenic effects to occur.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from the
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The
HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposure within a single
medium or across media. Any Hazard Index value greater than 1.0
suggests that a non-carcinogen potentially presents an unacceptable
health risk.
Table 2 provides a summary of hazard indices for all exposure
routes and exposed populations evaluated.
Slope factors have been developed by U. S. EPA' s Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals.
Slope factors, which are expressed in units of (mg / kg / day) -I, are
multiplied by the estimated intake of a potential carcinogen (in
mgjkgjday), to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level.
The term "upper bound" reflects the conservative estimate of the
risks calculated from the slope factor. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. Slope
factors are derived from the results of human epidemiological
studies or chronic animal bioassays to which animal-to-human
extrapolation and uncertainty factors have been applied (e.g., to
account for the use of animal data to predict effects on humans).
Cancer risks are determined by multiplying the intake level with
the slope factor for each contaminant of concern. These risks are
probabilities that are generally expressed in scientific notation
(e.g. lxl0~). A cancer risk of 1xl0~ indicates that, as a
plausible upper bound, an individual has a one in one million
chance of developing cancer as a result of site-related exposure to
a carcinogen over a 70-year lifetime under the specific exposure
conditions at the site. The U.S. EPA generally attempts to reduce
the cancer risk posed by a Superfund site to a range of 1xl04 to
1Xl0~, with lxlO~ as the starting point.
Table 3 provides a summary of cancer risks for all exposure routes
-------
TABLE ~
SUMMARY OF HAZARD INDICES FOR ALL EXPOSURE ROUTES AND' EXPOSED POPULATIONS
Environmenlal Areas
Occupational
Adull
nc
ne
ne
ne
nc
ne
nc
ne
Disposal and Planl Area SoU
Ollter Sile Soil
Ground Waler
51. Marys River Surface Waler
Pond Surface Waler
51. Marys River S~dimenl
Pond Sedimenl
Ambienl Air ,
Total: .
ne
Shaded values exceed a hazard index or one.
ne = no cxposure
wcla - J~l&INmAKSUN.XIJ! CHOClU4
Currenl future
Residential Recrealional Occupalional Residential ecrea.ional
Child Adult Child Adul! Adull Child Adnl. Child Adult
:i:il'~~!!iliiii:i:i:i;i;!ii~1:' i' iliJli;:H :ii:'ii!IU!i!Fi:i'i:iq:~i~F:: :i:i:~tHt~::i:~ i:'i'!lliliIUF;;;~:;:::~'f"i;:::,::::i9.:~;at.Q'::::::::::'fine f':
"t. ift!I1f:if.f:I'!I'*:';'ili'".~ .:,.,,;t!/I.!lj' ;.!I",.,..,:,..,..:.,:.,:,.;:,:;:"..:,,:,....,:.,:!:,: ;:;:;::.;1,.;:,...,.".:,.:, :,!;I!!!I!!!".....:,.:::;:,:!:;::..,!:.::.,.:.,:..;;;:, :::;::,,:!:.::..,:,:.,,;:::;:::::::,.~:,::.,.~:.:::;:
:J.1E-1 1.2£-1 l'lE-1 6,SE-2 1.2E-2 ~ I,BE-I 6.6£-2 4,6E.2 2.4E.2
ne he lie ne i)iJ~~it+2,i:: :t~:iH:3.:::H:Hii~;~~S~~:iL :njJa.t,~:>Hd'J~+j:::
S.] E-3 6,] E-3 5.3 E-3 6.3 E-] ,.,.,...."~~,.....".., "'ii'E~j"""""""6:fE~:r'" ""'ii'E~'i""""""6j E~i""
9.0 E.2 3.0 E-2 9.0 E-2 3.0 E-2 ne 9,0 E-2 3.0 E-2 . 9.0 E-2 3,0 E-2
1.1 E-2 1.6 E-2 1.4 E-2 1.7 E-2 nc 1.1 E-2 1,6 E-2 1.4 E-2 1.7 E-2
1.2 E-2 9.7 E.] 1.4 E-2 1.0 E-2 nel.2 E-2 9,7 E-3 1.4 E-2 1.0 E-2
::i:;:~' ;~"'::S.,:.:," i:;;';i!iii:~":il':'~"'::'t":ii:: :iiii;~":ioi:S"':':a":;::;i%:::J'::';J'::tm' '::i':;::, ':::::'~":'~';:~":;fj4'::- :~:;:: :::k1.":$":fi"'~";"i:;;;:;:::::9.":'-"':m":":' :;:~, ;;:Y'::J,":6";"!5:' ':;:;:::::;:J':'~': e":"ii" ::::
"'1' '., if; :",":'1" ,', ,.iIi. ..,: .:", ~" + ,:,:,..:.,.,. " , :..., '.':.. " : :.,.., :.,.,. " . :.,...:.:.:. " , ':'.' ;.', "': :1;. ;.":':':':' :,", .,. ".:
'."' '" ,'11°0. . ':J= 10 '.,°0 .t' .. '0""'" . . . '0"'" ""'0 I . "'1"0'" otl"'" . ""'"01.','.'.' .,' . ',',", ,,:T: ":"""'.-. of" '", ":',
r ii" ,.:tJ!!i;~!" ., !li!'~;!i'1i!m~!" "'!ij'i1!'!tt!;;!!ti'" ",'i!;'i'i,'!I:t. ,."iiti!!!i:'!l:t1ii!~"" "'~'I!t.'~1ii;~": "'~:~"Ei:i:!iI"" , "~,:,;",,,: :':':"':"':""',"':".:
hl:~~ .1~~jj i,li,.,~:;'imi~ij HI~i!':1~iJ.1!i 1hi81i~i~~, j!h~io?,1~~m1 !!!:~~!i.!!~~m !!!if!:~...11",~m:; }~*~11! :iilJ.~~n~ifj4:W
Ponied: 9/J0/9:
-------
Environmental Areas
Disposal and Plant Area Soil
Other Sile Soli
Ground Waler
" SI. Marys River Surface Water
Pond Surface Waler
St. Marys River Sediment
Pond Sediment
Ambienl Air
Total:
TABLE. ~"3
SUMMARY OF CARCINOGENIC RISKS FOR AI.I. EXI)OSURE ROUTES
AND EXPOSED POPUI.A TIONS
Octupatlonal
Adult
nc
ne
nc
nc
nc
ne
nc
ne
ne
Cuaenl Future
Residential Recrealional Occupational Residential Recrealional
Child Adult Child Adult Adult Child Adllil Child Adllh
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15
and exposed populations.
Based on total estimated exposures and current toxici ty
information, total carcinogenic risk levels to exposed populations
from chemicals of potential concern at the Cannel ton site range
from ~. 5xlO-3 to 7. 5x.1 . These risk levels exceed the target risk
range of lx10-4 to lxlO-6 excess lifetime cancer risk. These
exceedances are primarily caused by exposures to disposal and plant
area soils, other site soils, ground water (future potential
populations only), and ambient air.
Hazard indices exceed one for all populations evaluated. These
exceedances are primarily caused by exposures to disposal and plant
area soils and ground water (future potential populations only).
The carcinogenic risks associated with exposure to river water,
river sediments, pond water, and pond sediments are less than lxlO-6
for all populations. The hazard indices associated with exposure
to river water, river sediments, pond water, and pond sediments
were less than 1.0 for. all populations. Based on the exposure
assumptions and available toxicity information, the risks to human
health associated with surface water and sediments are not
significant.
The estimated risks from inhalation of ambient air are most likely
overestimated for all populations because the air models are very
conservative.
As mentioned earlier, sediment and soil toxicity testing and
benthic macro invertebrate studies were performed in order to better
assess impacts to the environment. Following is a summary of the
ecological assessment performed at the site.
The site consists of field, young forest, and wetland habitat. The
site is suitable habitat for a variety of small wildlife. The area
of the st. Marys River in whic~ the Cannelton site is located is a
spawning and nursery area for several fish species. This area is
also a critical spawning area for whitefish (Coregonus
clupeaformis) and walleye (stizostedion vitreum vitreum). The'site
and nearby areas provide good habitat for water fowl and are
located along an important bird migration route. There are no
known occurrences of Federal- or State-listed endangered,
threatened, or otherwise significant species, natural plant
communities, or natural features at the Cannelton site.
Detected concentrations of chromium in the surface water of the st.
Marys River exceed specific federal and state standards. The
maximum detected concentration of chromium exceeds the acute and
chronic freshwater quality criteria, the Great Lakes Water Quality
Agreement of 1978, and the Michigan Act 245 (Rule 57) guidelines.
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16
Several studies were done to assess risks to various aspects of the
environment. Specifically, sediment toxicity studies, benthic
macro invertebrate community studies, and a soil toxicity study were
performed. The results of these studies were compared to the
results of sediment and soil chemical analyses. A wetlands quality
assessment was also done.
An attempt was made to use these types of tests to derive
ecologically based clean-up standards for sediments and soils in
wetland areas, which proved to be unsuccessful due to a lack of
correlation between effects and concentrations of contaminants.
The following is a brief summary of the results of sediment
toxicity studies performed on the organisms Chironomus riparius and
Hvalella azteca and soil toxicity studies performed on earthworms.
For Chironomus riparius, the toxicity tests indicate that sediments
are not acutely toxic to this organism. There were no
statistically significant differences in mortality between sample
locations and the reference location or the laboratory control.
Some statistically significant differences in mean growth were
observed in sediments from locations ERT-Sd1 and ERT-Sd2.
The results of the Hvalella azteca test were mixed. Mortality was
observed in all sediment sample locations, including the upstream
reference location, and ranged from 45% to 100%. There was no
correlation between observed mortality and chromium concentrations,
nor with any other metal concentration or physical" parameter
measured. For instance, the sample with the highest concentration
of chromium, which was location ERT-Sd2 with 40,000 ppm chromium,
resulted in mortality of 53.35%. The reference location, ERT-Sd3
with 10 ppm chromium, resulted in a similar percentage of mortality
of 56.65%. These results indicate that chromium concentrations
were not the major or sole factor influencing the test results,
making interpretations difficult.
The results of the earthworm toxicity test were similar to the
Hvalella azteca results in that mortality was observed in some
samples, but no correlation between any chemical concentration and
percent mortality was found. The highest mortality (100%) was
observed in soil sample 8 (ERT-S8), where total chromium was 22,000
ppm. No mortality was' observed in the sample with the highest
chromium level, ERT-S13 with 26,000 ppm chromium. Earthworms in
soil from the reference location had the third highest mortality
observed, where total chromium was only 28 ppm. The results were
similar in the bioaccumulation studies, where the amount of
chromium accumulated did not correlate with chromium concentrations
in the samples.
The results of these studies were in some cases diff icul t to
interpret. When looking at test mortality, none of the results
showed that there was a relationship between chemical
concentrations or other measured parameters and the effects seen in
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17
the laboratory tests.
appear to be stressed
these effects could
concentrations.
Benthic communi ties in Tannery Bay did
relative to reference locations, but again
not be associated with any chemical
There are several confounding factors which could have influenced
the test results'. Sediment type, presence of tannery waste
material and saw dust in the sediment may have been factors in the
sediment toxicity tests conducted in the laboratory. In the
benthic community studies, communities could be affected by
physical habitat of the bay with the presence of tannery waste
material, saw dust and scrap lumber; constantly changing water
levels due to seiche effects and boat passage; and inherent
differences between bay communities and river communities. While
some effects were observed, no cause and effect relationship could
be established between site contaminants and impacts to the
environment based on the studies done to date.
The wetlands quality assessment indicated that the wetlands
contained diverse habitats ranging from open water to forested
wetlands. These wetlands appear to be functioning as quality
habitat, supporting diverse plant and animal life.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
DESCRIPTION OF ALTERHATrvES
Seven alternatives were developed and evaluated for the Cannelton
Industries site. Alternatives 1 through 6 are presented in more
detail in the Feasibility Study document, while Alternative 7 was
developed later and can be found in a Feasibility Study Addendum.
Both of these documents are available in the information repository
and the Administrative Record file for the site.
It should be noted that all the alternatives, with the exception of
Alternatives 1 and 6, are similar in that they require the
excavation of waste, soils and sediments and disposal in a
landfill. The differences are in the amount of material to be
excavated, whether the contaminated material is deposited in an on-
site or off-site landfill, and whether the waste is treated before
disposal. Alternative 1: No Action, and Al terna ti ve 6, which
involves capping, or covering, the waste material in place, are the
other two approaches considered. All alternatives are described in
more detail below.
The site has been divided into five different zones because of the
potential for location-specific remediation strategies within the
site. Zone A includes the western shoreline where general refuse
was dumped. Zone B is the main tannery waste discharge area. Zone
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18
C is comprised of the soils and wetlands of Tannery Point as well
as some additional soils along South street. Zone D includes all
the affected sediments in the st. Marys River and in Tannery Bay.
Zone E is the former plant area. The zones are shown in Figure 3.
These designations will be used throughout the remainder of this
ROD. ..
The costs presented for each alternative include capital costs
(such aS'equipment, labor and other construction expenses to put
the remedy in place) and operation and maintenance (O&M) costs
(such as monitoring the groundwater or maintaining the cap). These
costs are then presented as a "net present worth, II a method of
economic calculation that estimates the total amount of money which
would need to be invested today at 5 percent interest, assuming a
30 year project life, in order to cover initial construction costs
as well as future maintenance costs.
A list of Federal and state Applicable or Relevant and Appropriate.
Requirements (ARARs) which apply to the site are listed and
described in the Statutory Determinations Section of this ROD. The
major ARARs for the following alternatives include: Michigan Act
307; Michigan Act 245, Part 4, Rule 57; Michigan Act 641; RCRA
subtitle D; Safe Drinking Water Act; and the Clean Water Act.
*****************************************************************
Alternative 1:
No Action
superfund regulations, which are contained in the National
contingency Plan (NCP), require that a "no action" alternative be
considered at every site. This alternative serves as the basis to
which all other alternatives can be compared. Under this remedial
alternative, no active remedial action or institutional action
would be taken regarding the site.
Timeframe: Not Applicable
Capital Costs: $0
o & M Costs: $0
Net Present Worth: $0
***************************************************************
Alternative 2: Removal and Disposal of Debris, Waste, soils, and
Sediments in an on-site Landtill; Dewatering of Areas During
Excavation; Treatment and Disposal of Groundwater from Dewatering
operation.
Under this alternative, debris, waste and soils would be excavated
from Zones A, B, C and E. Before and during excavation in Zones B
and C, groundwater from the excavation area would have to be
collected to aid in excavation. A passive drain system could also
be used to lower the water table in Zones Band C. Collected
-------
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19
groundwater would be disposed after analysis and any necessary
treatment in compliance with appropriate regulations. All
excavated and dredged material would be placed in an on-site solid
waste (Subtitle D, Michigan Act 641) landfill, and the landfill
would be closed after the removal of soils, waste and sediment was
complete. Excavated areas in Zones A, Band C would be filled with
clean soil to stabilize the shoreline and revegetated to minimize
erosion. Groundwater would be monitored over time to see if
removal of contaminated soils was effective in. improving
groundwater quality and to detect any potential releases from the
on-site landfill.
In order to determine how much soil and sediment would be
excavated, cleanup criteria were developed for each site
contaminant. The criteria are the highest concentrations of a
chemical which could be left behind after the cleanup is done. For
this alternative, the cleanup criteria for soils are based on
background concentrations of a chemical found near the site, or on
a calculation of 20 times the groundwater standard, whichever
number is higher. If both of these numbers are below the level at
which the' chemical can be detected, then the cleanup number is set
at the detection limit. This approach is based on Michigan I s
Environmental Response Act 307. The sediment criteria for chromium
were based on a model which attempted to predict how much chromium
might leach out of sediments into surface water. The groundwater
is expected to meet drinking water standards at completion of the
remedial action. .
.Estimated volume to be removed: 406,500 cubic yds
Timeframe for remedial action: 3-4 years
capital Costs: $27,400,000
.0 & M Costs: Year 1 -- $458,000
Years 2-3 -- $449,000
Year 4 -- $579,000
Years 5-8 -- $303,000
Years 9-30 -- $185,000
Net Present Worth: $30,200,000
*******************************************************************
Alternative 3: Removal and Disposal of Debris, Waste, soils, and
Sediments in an Off-site Landfill; Dewaterinq of Areas Durinq
Excavation; Treatment and Disposal of Groundwater from Dewaterinq
operation.
All ground water collection and treatment, excavation, dredging,
removal actions and cleanup criteria would be identical to that of
Alternative 2. Disposal of excavated and dredged material would be
in an off-site solid waste landfill, permitted and in compliance
with RCRA Subtitle D and Michigan Act 641. Groundwater monitoring
would be done for a shorter period because there would not be an
on-site landfill.
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20
Estimated volume to be removed: 406,500 cubic yds
Timeframe for remedial action: 3-4 years
Capital Costs: $32,700,000
o & M Costs: Year 1 -- $458,000
Years 2-3 -- $449,000
Year 4 -- $444,000
Years 5-8 -- $156,000
Years 9-30 -- $0
Net Present Worth: $34,800,000
**************************~**************************************
Alternative 4: Removal of Debris, Waste, soils, and Sediments; On-
site Incineration of orqanic Waste Material from Zones Band D;
Dewaterinq of Areas Durinq Excavation; Treatment and Disposal of
Groundwater from Dewaterinq operations; and Disposal of Debris,
waste, soils, and Sediments in an on-site Landfill.
All ground water collection and treatment, excavation, dredging,
removal, cleanup criteria, on-site disposal actions and monitoring
will be identical to that of Alternative Two. Incineration would
be used to reduce the volume of the waste in Zone B and a portion
of the sediments in Zone D to be placed in the on-site landfill.
The ash residue might have to be treated prior to disposal because
it may then be a RCRA characteristic waste. A transportable,
rotary kiln incinerator would be mobilized on-site to carry out
this alternative.
Estimated volume to be removed: 406,500 cubic yds
Timeframe for remedial action: 3-4 years
capital Costs: $45,700,000
o & M Costs: Year 1 -- $458,000
Years 2-3 -- $449,000
Year 4 -- $579,000
Years 5-8 -- $303,000
Years 9-30 -- $171,000
Net Present Worth: $49,800,000
******************************************************************
Alternative 5: Removal of Debris, Waste, Soils, and Sediments; On-
site Incineration of Orqanic Waste Material from Zones Band D;
Dewaterinq of Areas Durinq Excavation; Treatment and Disposal of
Groundwater from Dewaterinq operations; and Disposal of Debris,
Waste, Soils, and Sediments in an Off-site Landfill. .
All ground water collection and treatment, excavation, dredging,
removal, cleanup criteria, and incineration actions would be
identical to that of Alternative 4. Disposal of removed/treated
material would be in an off-site RCRA subtitle D/Act 641 solid
waste landfill. Monitoring requirements would be the same as those
for Alternative 3.
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21
Estimated volume to be removed: 406,500 cubic yds
Timeframe for remedial action: 3-4 years
Capital Costs: $49,500,000
o & M Costs: Year 1 -- $458,000
Years 2-3 -- $449,000
Year 4 -- $444,000
Years 5-8 -- $156,000
Years 9-30 -- $0
Net Present Worth: $51,500,000
*****************************************************************
Alternative 6: Removal and Disposal of Debris and Sediments in an
on-Site Landfill; Cap All Other Areas; and Collect Groundwater from
Zones Band E and Treat and Dispose.
Under this alternative, only the debris and soils in Zone A and the
waste and sediments in Zone D would be excavated and disposed of in
a subtitle D/Act 641 solid waste landfill that would be constructed
on-site. These Zones would be excavated because of the difficultly
of in-place containment. Cleanup standards for the excavation.
would be the same as for Alternatives 2, 3, 4 and 5. The rest of
the waste and contaminated soil would be left in place, and these
areas would be regraded to facilitate drainage, capping, and
revegetation. A solid waste cap with a low permeability layer
would be placed over Zone B to minimize infiltration/leaching. A
single-media, permeable cap would be placed over Zones C and E to
prevent direct human contact. The cap systems would also reduce
the potential for particulate air emissions and contaminant
migration to surface water via storm water run-off and erosion.
Groundwater discharging from Zone B would be collected via an
interceptor trench, discharged by pumping to the sanitary sewer,
and treated off-site at the POTW. Wetlands losses in Zones Band
C could be mitigated by backfilling a portion of Zone D (Tannery
Bay) to the average water level of the st. Marys River and by
vegetating. The area excavated along the st. Marys River in front
of Zones Band C would be backfilled with sand, and a break wall
(rip-rap barrier) would be installed to minimize erosion.
Excavated areas in Zone A would be filled with clean soil to
stabilize the shoreline and revegetated to minimize erosion.
Estimated volume to be removed: 166,800 cubic yds
Timeframe for remedial action: 3-4 years, plus long-term
groundwater collection and treatment
Capital Costs: $20,000,000
o & M Costs: Year 1 -- $458,000
Years 2-3 -- $420,000
Year 4 -- $598,000
Years 5-8 -- $363,000
Years 9-30 -- $363,000
Net Present Worth: $25,900,000
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22
*******************************************************************
Alternative 7: Removal and Disposal of Debris, Waste, Soils and
Sediments in an On-site Landfill; Dewatering of Areas During
Excavation; Treatment and Disposal of Grounawater from Dewatering
operation; Preservation of on-site Wetlands to the Extent Possible.
This alternative is similar to Alternative 2, except that the
cleanup criteria which determine the volume to be excavated are
different. The cleanup criteria for soils are based on
concentrations which would be protective if people were to ingest
or contact soils or sediments or inhale dust from the site. The
effects of contamination and waste material on the environment were
also taken into account. Soils and sediments which exceed these
criteria and tannery waste material in Tannery Bay and in the st.
Marys River would be removed and placed in an on-site solid waste
landfill. Sediments in Tannery Bay which do not exceed the clean-
up criteria would be contained in place.
. Groundwater would be addressed by excavation of the contaminated
source material (soils and waste) and would be monitored after the
cleanup was complete. Since groundwater would be collected and
treated during excavation activities and the majority of the source
of contamination would be removed, it is expected that groundwater
would meet health-based drinking water standards in the aquifer and
would be protective of surface water. If it was found that health-
based drinking water standards were not met after removal of soils
and waste, deed restrictions would be placed on groundwater beneath
the site so that no drinking water wells would be installed. Long-
term monitoring of the groundwater would be performed.
Surface water would also be addressed by removal of soils and
sediments above the cleanup criteria as well as removal of tannery
waste material from the river and Tannery Bay. Surface water would
also be monitored and would be expected to meet Michigan surface
water criteria under Act 245, Part 4, Rule 57. Since contamination
above background levels of chemicals such as chromium and mercury
would be left in the wetlands and sediments of Tannery Bay,
additional monitoring of the environment would be performed. The
main shoreline would be stabilized as necessary to allow for
revegetation and to prevent erosion.
Estimated volume to be removed: 199,700 cubic yds
Timeframe for remedial action: 3-4 years
capital Costs: $14,400,000
o & M Costs: Year 1 -- $458,000
Years 2-3 -- $449,000
Year 4 -- $579,000
Years 5-30 -- $303,000
Net Present Worth: $19,700,000
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*****************************************************************
SUMMARY OF COKPARATIVE ANALYSIS OF ALTERNATIVES:
THE NINE CRITERIA
In accordance with the NCP, the relative performance of each
alternative is evaluated using the nine criteria [Section
300.430(e) (9)-(iii)] as a basis for comparison. An alternative
providing the "best balance" of tradeoffs with respect to the nine
criteria is determined from this evaluation.
Threshold cri~eria
overallPro~ec~ion of Human Heal~h and the Environment: determines
whether an alternative eliminates, reduces, or controls threats to
human health and the environment.
compliance wi~h Applicable or Relevant and Appropriate Requirements
(ARARs): evaluates whether the alternative meets federal and state
environmental laws pertaining to the site.
Balancina Cri~eria
Lonq-Term Effectiveness and Permanence: considers the ability of
an alternative to protect human health and the environment over
time.
Reduc~ion of Toxicity, Mobility or Volume Through Treatment:
evaluates an alternative's use of treatment to reduce the harmful
nature of contaminants, their ability to move in the environment,
and the amount of contamination present.
Short-Term Effectiveness: considers the length of time needed to
implement an alternative and the risks it poses for workers,
residents, and the environment during implementation.
Implemen~abili~y: considers the technical
feasibility of implementing an alternative.
and administrative
Cos~: includes estimated capital and operation and maintenance
(O&M) costs, as well as present-worth costs. .
Modifvina cri~eria
Sta~e Acceptance: considers whether the state agrees with u.s.
EPA's analyses and recommendations as presented in the RIfFS and
the Proposed Plan.
communi~y Accep~ance: summarizes the public's general response to
the alternatives described in the Proposed Plan and the FS. The
specific responses to public comments are addressed in the
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24
Responsiveness Summary attached to this ROD.
EVALUATION OF THE ALTERNATIVES AGAINST THE NINE CRITERIA
The following analysis evaluates the seven alternatives under each
of the nine evaluation criteria.
1) Overall protection of human health and the environment. All
alternatives, except Alternative 1, would be expected to provide
long-term protection of human health by reducing or eliminating
exposure pathways. In addition, the environment would be protected
in the long-term by all alternatives (except Alternative 1) through
reduction of the quantity of contamination that is released or
exposed to the environment. .
Alternatives 2, 3, 4 ,and 5 are similar in terms of their
protection of human health and the environment. In each of these
alternatives, the materials of concern (wastes, soils, and
sediments) would be removed from the environment and placed in a
secure landfill, where the potential for migration of the
contaminants into ground water, surface water, and ambient air is
significantly reduced and the potential for direct contact with
contaminants is eliminated. Removal of the quantity of soils
proposed in these alternatives would eliminate a diverse, high-
quality 15-acre wetland. Excavation and dredging of the sediments
would eliminate the potential leaching of contaminated sediments to
surface water and would provide a clean habitat for bottom-dwelling
animals, but these activities could resuspend contaminated sediment
in the short-term.
Alternative 6 would use a solid waste landfill cap for reducing the
infiltration of water through the most severely impacted areas and
a modified, single-media cap of porous soils for minimizing the
possibility of human dermal contact in other impacted areas. The
caps would also be intended to limit migration of contaminants in
storm water run-off to surface water and air emissions to
acceptable levels. Erosion controls would be implemented along the
st. Marys River and Tannery Bay shorelines to reduce potential for
transport of contaminated solid waste or soil particulates into
surface water. The contaminated sediments at the site would be
isolated from human contact through removal and disposal in an
on-site landfill with a cap.
Alternative 7 removes a lesser volume of soils and sediments, hut
the remaining chemical concentrations would be below levels wh~ch
present a human health risk due to ingestion or dermal contact o;:ith
soils and sediments or inhalation of dust from the site. All
removed material would be contained in an on-site landfill. Since
chemical concentrations in the wetlands and in the sediments also
have not been shown to be significantly toxic to organisms in the
studies done to date, Alternative 7 is also protective of the
environment. Additional benefit is realized by preserving the
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2S
wetlands to the extent possible and by reducing the amount of
dredging and potential resuspension of contaminated sediments.
Removal of tannery waste material from the bay will improve the
physical habitat for benthic organisms and reduce the potential for'
resuspension of exposed tannery waste material on the shorelines of
Tannery Bay.
Public health may be affected by short-term emissions of airborne
contaminants during construction activities for all the remedial
alternatives except Alternative 1. However, these emissions would
be reduced or eliminated via implementation of dust control
measures in all the alternatives.
2) Compliance with ARARs: with the exception of Alternative 1, all
alternatives would meet the chemical-specific, action-specific and
location-specific requirements set forth in federal and state laws.
Michigan's Act 307 is a comprehensive law and regulation which
applies to this site. Alternatives 2, 3, 4, and 5 meet specific
cleanup standards presented in Act 307, while Alternatives 6 and 7
meet the site-specific requirements in Act 307. Further
explanation of Michigan Act 307 and the other ARARs for this site
can be found in the statutory Determinations Section.
3) Long-term effectiveness, and permanence:
Alternatives 2 and 4 would be effective in the long-term. Although
the amount of contamination on the site would not be reduced
(simply transferred from one point to another), the contamination
in the soils and sediments would be effectively isolated from the
environment by the on-site landfill cap and liner. Residual
contamination accessible to the general public after completion of
remedial activities would be minimal and would be below acceptable
levels. The long-term effectiveness of these alternatives is a
function of the long-term integrity of the landfill, which is
expected to be good if the landfill is well-designed and maintained
over time. .
Alternative 7 also provides long-term effectiveness and is similar
to Alternatives 2 and 4. Highly contaminated soils and sediments
would be isolated in the on-site landfill, while some soil and
sediment contamination below acceptable human health-based levels
would be managed in place. Evidence to date indicates that
contaminant levels being left in place are also not harmful to the
environment. The long-term effectiveness of these alternatives
is a function of the long-term integrity of the landfill, which is
expected to be good if the landfill is well-designed and maintained
over time.
Alternatives 3 and 5 would also be effective in the long-term. The
amount of contamination on the site would be reduced via
transportation off-site. Residual contamination that would remain
after completion of remedial activities would be minimal and would
be below acceptable levels. The long-term effectiveness of these
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26
alternatives would be a function of the long-term integrity of the
landfill. If the waste is disposed of in a properly designed
facility, the long-term effectiveness would be similar to that of
waste stored in an on-site landfill.
The ground water cleanups for Al ternati ves 2, 3, 4, and 5 are
expected to be effective in the long-term because the soils which
exhibit potential for leaching unacceptable levels of conta~ination
would be removed and the ground water which exceeds acceptable
levels would be recovered. Alternative 7 'is expected to be as
effective as Alternatives 2, 3, 4 and 5 even though levels of
contaminants above background will be left in soils. Levels in the
groundwater after remediation are expected to be protective of
human health and the environment and will be monitored. The
long-term effectiveness of the ground water cleanup for
Alternatives 3 and 5 may be more reliable than that for
Alternatives 2, 4 and 7 because no wastes, soils, and sediments
would remain on-site.
Alternative 6 would be effective in the long-term provided that the
landfill cap, soil cover and shoreline erosion control were
properly and effectively maintained. since waste material would
continue to be in contact with groundwater in Zone B, collection of
groundwater and off-site i;reatment in a POTW may be necessary.
This approach would probably not be as effective as removing highly
contaminated waste and soils from contact with groundwater.
4) Reduction in toxicity, mobi1.ity or volume throuqh treatment: In
Alternatives 2, 3, 6, and 7, no treatment process is used to
address soils or sediments. Therefore, there is no reduction in
toxicity, mobility or volume through a treatment process.
Alternatives 4 and 5 utilize incineration to treat organic waste
materials from Zone B and part of Zone D. This treatment of soils
and sediments will reduce the volume of waste to be disposed, but
it may increase the mobility of metals in the resulting ash,
because the organic material to which the metals are probably
currently bound will be destroyed.
5) Short-term effectiveness: For all alternatives, there could be
dust emissions during excavation activities to which workers and
the surrounding communi ty could be exposed. To address this
threat, dust control measures will be implemented during excavation
activities, and workers will wear protective clothing to reduce the
risks associated with remediation. There will also be a higher
than usual -'olume of construction traffic for Alternatives 2-7
because of tr.e transport of materials either to or from the site.
All alternatives would take a similar amount of time to implement.
Alternatives 2, 3, 4, and 5 will create a short-term impact to the
environment by excavating the 15-acre wetlands on Tannery Point.
This would result in a loss of habitat .for numerous birds, mammals
and amphibians which currently occupy the area. The wetlands would
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27
probably be re-established, although it may be difficult to re-
establish a wetlands of similar quality and diversity. Alternative
6 would create a similar impact to the wetlands by clearing the
vegetation and putting a soil cover over the area. While
Alternative 7 would require some wetlands to be excavated, an .
objective of the alternative is to preserve the wetlands area to
the extent possible and allow some localized areas of contamination
to remain in place.
6) ImplementGility: All the alternatives are technically feasible
because the technology exists for the various remedy components,
including excavation, dredging, incineration and landfill
construction. Administratively, the alternatives which call for
-on-site landfilling would be somewhat easier to implement because
a permit for landfill construction would not have to be obtained
from the state. Dep~nding on the off-site landfill chosen for
Alternatives 3 and 5, a permit for construction of a new landfill
cell may be required to accommodate the volume of waste material
removed from the site. This is based on contact with the landfill
in Chippewa County. If Alternatives 2 or 4 were to be implemented,
additional land adjacent to the former plant site may have to be
used for the landfill in order to accommodate the large volume of
material.
For all alternatives, if the remedy chosen is not found to be
protective of human health and the environment, additional remedial
action could be undertaken fairly easily if determined to be
necessary. Clean soil used to backfill excavated areas would have
to be removed before additional contaminated soils or sediment
removal could take place. For Alternatives 2, 4 and 7, the on-site
landfill options, any additional soil or sediment removed would
require off-site disposal or construction of another on-site
landfill cell, since the on-site landfill would probably have
already been closed. .
7) Cost: The capital costs, operation and maintenance costs and
net present worth of each remedial alternative are listed after
each alternative description above. Cost-effectiveness is
discussed in the statutory Determinations section below.
8) state Acceptance: The state of Michigan has not concurred with
the remedy as sele~ted in this ROD.
9) community Acceptance: Community acceptance is assessed in the
attached Responsiveness Summary. The Responsiveness Summary
provides a thorough review of the public comments received on the
Proposed Plan, and the Agency's responses to those comments.
THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, as amended
by SARA, the NCP, the detailed analysis of alternatives and public
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28
comments, U. S. EPA has selected Al ternati ve 7, as the remedial
action for the Cannelton Industries site. Given the available
information, the Agency believes that this alternative is
protective of human health and the environment, complies with
ARARs, provides the best balance of trade-offs under the nine
criteria, and also represents a cost-effective solution. The main
differences between this alternative and the other excavation and
dredging alternatives being considered are the chemical clean-up
criteria being used to determine how much excavation is necessary
and the location of disposal.
Alternative 7 involves the excavation and consolidation of waste
material, soils and river sediments which exceed specific chemical
standards into an on-site landfill. The chemical standards and
their derivation are described below, but, in general, the.
remaining concentrations in soils and sediments will attain, for
each contaminant, a 1x10~ carcinogenic risk level or a hazard index
of 1.0 or less for exposure due to ingestion, dermal contact or
inhalation. Application of the groundwater model showed that
current levels of chromium, lead and mercury in soils may not be
protective of surface water. Additional testing of chromium, lead
and mercury will help determine what residual levels of these three
contaminants in soils and sediment will be protective of surface
water and the ecosystem. Once standards are derived, short-term
and long-term effectiveness and cost-effectiveness will be taken
into account when delineating excavation areas. Only material from
the site will be placed in the landfill, which will be closed after
all excavation is complete. The landfill will be constructed and
closed according to the technical standards of RCRA subtitle D and
Michigan Act 641 regulations. Sediments in the st. Marys River
which do not exceed the cleanup criteria will be left in place.
Groundwater will be addressed by excavation of the contaminated
source material (soils and waste) and will be monitored after the
cleanup is complete. Surface water will be addressed by removal of
soils and sediments above the cleanup criteria, removal of tannery
waste material from the river and Tannery Bay, and long-term
monitoring.
The estimated capital costs are $14,400,000 and the net present
worth is $19,700,000. Estimated Operation and Maintenance costs
are $458,000 for the first year, $449,000 for years 2-3, $579,000
for year 4, and $303,000 for years 5-30.
Rationale for Selection
The criteria used for Alternatives 2, 3, 4, 5 and 7 would protect
people from health. effects due to ingestion of and dermal contact
with the soils and sediments and inhalation of dust particles from
the site. The criteria for Alternatives 2, 3, 4 and 5 would also
protect groundwater, and subsequently surface water, from leaching
of contaminants from the soils, based exclusively on the "twenty
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times groundwater" standards presented in Michigan Act 307.
However, based on the current groundwater and surface water
information which shows that these two media at present are only
minimally contaminated and currently present no unacceptable risk
to human health, the soil clean-up standards proposed under
Alternative 7, including those to be derived through additional
testing, would be protective of groundwater and surface water,
especially when taking into account the large flow volumes of both
the groundwater discharge and the St. Marys River.
It is likely that after cleanup standards are derived and
excavation is complete, levels of contaminants above background
will remain. Contaminants above cleanup standards in select areas
may also remain. EPA believes that management of some
contamination in place under Alternative 7 is protective of the
environment, based on the relative impacts of contaminant effects
compared to the effects of excavation and dredging acti vi ties. The
environmental benefits which may result from removal of all
contamination must be weighed against the destructive nature of the
excavation activities which would be required.
Although it cannot be definitively stated that the contaminants are
having no effect on the environment, no impacts to the environment
have been clearly associated with even the high levels of
contamination, in the ecological toxicity studies done to date. In
applying any newly derived cleanup levels for chromium and mercury
in soils and sediment, the short-term and long-term effectiveness
and cost-effectiveness of removing the material will be taken into
account. This may result in some levels of contaminants above
derived standards to be left in soils and/or sediment. u.s. EPA's
opinion is that large-scale destruction of a quality wetland
habitat and dredging and possible resuspension of a large volume of
sediments would degrade the environment more than leaving some
elevated levels of chemicals in place and may not be cost-
effective. Removing tannery waste material from the st. Marys
River and Tannery Bay will remove areas with the highest levels of
contaminants found in the sediments, and will greatly improve the
habitat for benthic organisms. All concentrations left will be
below acceptable human health-based levels, and monitoring of the
residual contamination and its effect on the environment will be
done to ensure that the remedy is protective.
Performance Standards
1. Soil -- In general, clean-up standards for individual
chemicals are based on the Direct Human Contact (DHC)
standard, as presented in Michigan Act 307 under a Type B soil
clean-up, to protect human health based on ingestion and
dermal contact threats. DHC numbers are derived based on the
algorithm set forth in Michigan Act 307 R 299.5711(5). These
calculations use the most recent toxicological data, and are
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based on a carcinogenic risk level of 1x10~ or a hazard index
of 1. o. Other factors, such as the method detection limit and
background concentrations, were also taken into account. ~t
is required that remaining soils concentrations will also be
protective of groundwater and subsequent discharges to surx:..ce
water.
For cadmium and lead, the DHC, as calculated per Act 307, is
selected as the cleanup level. The DHCs are 100 mgjkg for
cadmium and 400 mg/kg for lead. To confirm whether these
concentrations will ultimately be protective of groundwater
and surf~ce water, leachate tests pursuant to Act 307 R
299.5711(2) (b), or another appropriate method developed by EPA
will be performed. For any leachate studies performed, the
concentration of the leachate will be evaluated against the
health-based standard for the medium with which the soil
interfaces,and its ability to comply with Act 307, R
299.5713. In accordance with Act 307, R 299.5707, if soil
leachate or other approved studies as described above find the
contribution of contaminants from site soils to be within the
range of the contribution from background soils, compliance
with the Act will be considered to have been attained.
In the case of arsenic, the DHC was very low. Since the DHC
was below background levels near the site, the background
concentration, calculated using existing data to be 12.8
mqlkg, was chosen as the clean-up standard. For the'
carcinogenic polynuclear aromatic hydrocarbons (PAHs), the DHC
values are all the same and are below the method detection
limit (MDL) for PAHs. Therefore, the clean-up number for
carcinogenic PAHs is the MDL, which is 0.33 mg/kg. Samples to
determine background concentrations of PAHs in the vicinity of
the site can be collected and will be applied as the cleanup
standard if less stringent.
A slightly different approach was taken with chromium, b~sed
on the fact that the inhalation route of exposure, rather than
the DHC route, is the most toxic for both hexavalent and
trivalent forms of chromium. Using the air model developed
for the Baseline Risk Assessment, under the current
residential scenario, acceptable soil concentrations were
backcalculated based on a 10~ cancer risk level for hexavalent
chromium and a Hazard Index of 1 for trivalent chromium. The
results of this calculation are a cleanup standard of 5300
mgjkg for trivalent chromium and 23 mg/kg for hexavalent
chromium. To confirm whether this concentration will
ultimately be protective of groundwater and surface water,
leachate tests pursuant to Act 307 R 299. 5711 (2) (b), or
another appropriate method developed by EPA will be performed,
as described above for lead and cadmium.
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For mercury, it appears that the Act 307 DHC may not be
protective of the groundwater and surface water, after
comparison with the groundwater model presented in the FS
Addendum. Upon applying the leachate approach dictated under
R 299.5711(2)(a), using TCLP data from the RI, it is found
that the present levels of mercury for the soils tested do not
leach above the acceptable method detection limit. According
to the rule, as stated in R 299.5711(2) and R 299.5721,
present levels of mercury at the si te may meet a Type B
cleanup.
However, EPA acknowledges that, while potentially compliant
with the rules, the mercury levels at the site may not be
protective of surface water, and believes that further
assessment of the site's contribution of mercury to the st.
Marys River and the ecosystem is warranted. It will be the
obj ecti ve of the cleanup to reduce the levels of mercury
discharging from the site to health-based or background
levels, whichever is less stringent. EPA believes that
methods with lower detection' limits may be necessary to
adequately assess the site's impact on the environment due to
mercury.
2. sediments -- Excavation, dewatering and placement in an
on-site landfill is proposed for those on-shore and near-shore
sediments which pose a threat to human health through direct
contact or to the river through resuspension and transport.
The same clean-up standards which apply to soils also apply to
sediments. Tannery waste, consisting of hair and hide
material, will also be removed, since the highest levels of
contaminants appear to be associated with these materials and
since these wastes provide a poor substrate for benthic
macro invertebrate communities. To evaluate those contaminant
levels which may remain after the above remediation,
additional testing will be conducted prior to excavation to
ensure that the cleanup will be protective of human health and
the environment. As described above for soils, leachability
studies or other appropriate studies shall be performed for
chemicals of concern to ensure that sediments do not cause an
exceedance of Michigan Act 245, Rule 57 surface water
criteria, or background, whichever is less stringent.
3. Groundwater -- It is probable that groundwater will meet
health-based drinking water standards after the performance
standards for soil are met. If health-based drinking water
standards are not met, institutional controls in the form of
deed restrictions will be sought to prevent installation of
drinking water wells. The other performance standard for
groundwater is that the discharge of groundwater to surface
water is protective of surface water, per Michigan Act 307, R
299.5713. It is eXpected that 'after source removal,
groundwater conditions will improve and surface water will be
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protected. If groundwater conditions do not improve and/or
groundwater is found to be adversely impacting surface water,
additional measures may be evaluated. To assess the impact of
groundwater on surface water, groundwater will be monitored
for attainment of surface water criteria in wells lining the
site shoreline, or equivalent.
During excavation, groundwater will be collected, analyzed and
treated, if necessary, prior to disposal. If it meets the
relevant pre-treatment requirements, water can be disposed at
the Publicly Owned Treatment Works (POTW). If applicable
NPDES standards are met, water can be discharged to the river.
If the water analyses show that it does not meet requirements
for either of these options, alternate off-site treatment
would be required.
4. Surface Water -- Surface water will be addressed through
the removal of soils and sediments above cleanup standards.
After removal, surface water will be monitored and will be
expected to meet Michigan Act 245, Rule 57 standards, assuming
a site-specific hardness of 40 mg/L, when necessary for the
calculation of a standard. The point of standards application
will be at all points within the st. Marys River and Tannery
Bay. Any exceedance detected will only be considered an
exceedance if there is a statistically significant difference
between background and site sample concentrations. If
background concentrations for a particular contaminant are
found to be above the Rule 57 standard, then a background
standard will be calculated and will apply. Also, if the Rule
57 standard is below acceptable method detection limits (MDL) I
then the MDL will apply. Surface water monitoring results
will assist in determining whether groundwater and sediment
are in fact protective of surface water.
5. Landfill The on-site containment area will be
constructed to meet the minimum technical standards of RCRA
subtitle D or Michigan Act 641, which regulates solid waste
disposal, and will be closed in accordance with the same Act.
Given the location of the site, an adequate frost protection
layer will be required to ensure the integrity of the cap.
6. Ecoloqical Toxicity Testinq -- Additional ecological
toxicity studies will be done to ensure that remaining levels
of contaminants in soils and sediment are protective of the
environment. These will include studies to assess the
bioaccumulative threat of mercury.
7. Shoreline stabilization -- Based on sound engineering
practice, the shoreline will be stabilized to the extent
necessary after excavation is complete. This is particularly
important given the location of South st. I which must be
protected from potential erosion.
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STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of Section 121
(a-e) of CERCLA, as amended by SARA, to:
c.
Protect human health and the environment;
Comply with ARARs;
Be cost-effective;
utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable; and,
satisfy the preference for treatment as a principal
element or provide an explanation as to why this
preference is not satisfied.
a.
b.
d.
e.
The implementation of Alternative 7 at the Cannel ton Industries
site satisfies the requirements of CERCLA, as amended by SARA, as
detailed below:
a.
Protection of Human Health and the Environment
This selected remedy provides protection of human health and
the environment.
Implementation of the selected alternative will reduce and
control potential risks to human health and the environment
posed by exposure to site contaminants by excavating waste
material and soils and sediments above human health-based
criteria and containing this material in an on-site landfill.
The risk will be reduced to a risk level of 1XI0-6 for
carcinogens, and the Hazard Indices for non-carcinogens will
be less than one. Removal of waste, soils and sediments will
reduce the source of groundwater and surface water
contamination.
The selected remedy removes a lesser volume of soils and
sediments than other alternatives considered, but the
remaining chemical concentrations would be below levels which
could cause a human health risk due to ingestion or dermal
contact with soils and sediments or inhalation of dust from
the site. Since chemical concentrations in the wetlands and
in the sediments have not been shown to be significantly toxic
to organisms in the studies done to date, Alternative 7 is
also protective of the environment. The remedy attempts to
balance wetland preservation and reduction of dredging and
potential resuspension of contaminated sediments with removing
contaminant threats from the environment. Removal of tannery
waste material from the bay will improve the physical habitat
for benthic organisms and reduce the potential for
resuspension of exposed tannery waste material on the
shorelines of Tannery Bay. There are no unacceptable short-
term risks associated with the remedy.
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b.
Compliance with ARARs
The selected remedy will comply with all Federal and/or state,
where more stringe;;.t, ARARs. The following ARARs will be
attained.
1.
Chemical-specific ARARs
Chemical-specific ARARs regulate the release to the
environment of specific substances having certain chemica 1
characteristics. Chemical-specific ARARs typically determine
the extent of clean-up at a site. By removal of the source
and continued monitoring, EPA believes that all chemical-
specific Federal and state ARARs will be met.
Federal ARARs
Safe Drinking Water Act MCLs and MCLGs -- Maximum contaminant
Levels (MCLs) and non-zero Maximum contaminant Level Goals
(MCLGs), the federal drinking water standards promulgated
under the Safe Drinking Water Act (SDWA), are applicable to
municipal water supplies servicing 25 or more people. At the
Cannelton Industries site, MCLs and MCLGs are not applicable,
but are relevant and appropriate since the aquifer in the area
of contamination could be suitable for use as a source of
drinking water in the future. MCLGs are relevant and
appropriate when the standard is set at a level greater than
zero (for non-carcinogens), otherwise, MCLs are relevant and
appropriate. The point of compliance is beyond the waste
management boundary, which at the Cannelton Industries site
will be beyond the edge of the capped containment area.
Clean Water Act -- Under the Federal Water Pollution Control
Amendment of 1972, commonly known as the Clean Water Act of
1972 (CWA) , the U.S. EPA has established federal guidelines
for development of water quality criteria to protect human
health and aquatic life from exposure to pollutants. These
federal ambient water quality criteria (AWQC) are developed as
guidelines from which states determine their water quality
standards. While the AWQC themselves have no direct
regulatory impact, they are used to derive regulatory
requirements which can include water quality-based effluent
limitations, water quality standards, or toxic poll~tant
effluent standards. The use of the AWQC is based on the
designated or potential use of the surface water. These are
then translated into enforceable effluent limitations in a
point source permit National Pollutant Discharge Elimination
System (NPDES) for direct discharge to surface waters. Before
any facility may discharge into surface water, a NPDES permit
is required under the CWA. The st. Marys River is a potential
source of drinking water. If there is a discharge to the st.
Marys River planned during remediation activities, due to
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dewatering
requirements
remediation
requirements
activities for example, the substantive
of a NPDES permit will be met. In addition,
will comply with storm water discharge
under the CWA.
Clean Air Act National Ambient Air Quality standards 40 CFR 50
-- These regulations provide air emission requirements for
actions which may release contaminants into the air. As the
selected remedy involves excavation and construction
activities which may release contaminants or particulates into
the air, emission requirements promulgated under this act are
relevant and appropriate. .
state ARARs
Michigan Act 307 -- The state of Michigan has identified the
Michigan Environmental Response Act (referred to as "MERA",
"the Act ", or "Act 307") and its implementing rules as ARARs
for this site. u.s. EPA finds that only Rules 705(2) and (3),
707 715, 717(2), 719(1) and 723 qualify as ARARs in
compliance with Section 121 (d) (2) of CERCLA. These rules
provide for the selection of a remedy which attains a degree
of cleanup which conforms to one or more of three levels of
cleanup - Type A, B, or C. A Type A cleanup generally
achieves cleanup to background or non-detectable levels (R
299.5707); a Type B level meets specified cleanup levels in
all media (R299.5709-5715 and 5723) and a Type C cleanup is
based on a site specific risk assessment [R299.5717(2) and
5719(1)]. .
u.S. EPA's selected soil cleanup standards for this site are
in compliance with Act 307 and its implementing rules in that
they meet the standard for selection of a Type C [R299.5717(2)
and 5719(1)], although the standards contain elements of Type
A and Type B requirements for particular contaminants in order
to achieve protection of human health and the environment.
Derivation of the numeric soil cleanup standards is described
previously in the "Selected Remedy" section.
u.S. EPA's selected sediment cleanup standards for this site
are in compliance with Act 307 and its implementing rules in
that they meet the standard for selection of a Type C
[R299.5717(2) and 5719(1)]. There are no provisions for Type
A or Type B sediment cleanup standards in Act 307. The
derivation of standards for sediments is the same as for
soils, with the addition of a visual standard for removal of
tannery waste material from the st. Marys River and Tannery
Bay.
u.S. EPA's selected groundwater cleanup standards for this
site are in compliance with Act 307 and its implementing rules
in that they meet the standard for selection ot a Type C
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[R299.5717(2) and 5719(1»). While is anticipated that
groundwater will meet health-based drinking water standards
presented under a Type B (R 299.5709) after removal of the
source, if groundwater does not achieve these standards, deed
restrictions will be sought so that no drinking water wells
can be installed at the site. The other performance standard
for groundwater is that its discharge to surface water does
not adversely affect surface water, per R 299.5713. To assess
the impact of groundwater on surface water, groundwater will
be monitored for attainment of surface water criteria in wells
lining the site shoreline, or equivalent.
u.s. EPA's selected surface water cleanup standards for this
site are in compliance with Act 307 and its implementing rules
in that they meet the standard for selection of a Type B (R
299.5713). The numeric surface water cleanup standards were
derived pursuant to the provisions of Act 245, . Rule 57, using
a hardness of 40 mg/L where appropriate. Since no mixing zone
applies under a Type B, the point of standards application
will be throughout the st. Mary River adjacent to the site.
Any exceedance detected will only be considered an exceedance
if it is significantly different than background samples
collected. If background cc:"' ..~ ..:1trations for a particular
contaminant are found to be ai::::. ."~ the Rule 57 standard, then
a background standard will be calculated and will apply.
Also, if the Rule 57 standard is below acceptable method
detection limits (MDL), then the MDL will apply.
u.s. EPA does not consider the other provisions of Act 307 and
its implementing rules identified by the state as ARARs
because they are either procedural, not more stringent or do
not establish cleanup standards. Additionally, u. s. EPA
believes that even if certain of these provisions were
considered as ARARs [e.g. the considerations listed in section
299.5717 (3) ), the remedial actions and cleanup standards
selected for this site are in compliance with these state-
identified ARARs since they have been selected in accordance
with CERCLA and the NCP.
Michigan Act 245, Part 4, Rule 57 -- This act provides general
prohibition of concentrations in surface water for substances
which impart unpalatable flavor to food, fish, or oth~rwise
interfere with the reasonable use of the surface water in the
state. Rule 57 specifically requires that surface water
discharges not be toxic to aquatic life or human health.
Michigan Air Pollution Act 348 -- This act provides air.
emission requirements for actions which may release
contaminants into the air. The selected remedy involves
excavation and construction activities which may release
contaminants or particulates into the air. This act is
relevant and appropriate. This act is also referenced in Act
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307 under a Type B (R299.5715) for air quality.
Michigan Safe Drinking Water Act 399 -- This act is an ARAR to
the extent that it is more stringent than the SDWA discussed
above under Federal ARARs.
2.
Location-Specific ARARs
Location-specific ARARs are those requirements that relate to
the 'geographical position of a site. These include:
Federal ARARs
Executive Order 11988 - Protection of Floodplains -- This
Executive Order is applicable at this site since a portion of
the site north of South street lies wi thin the 100-year
floodplain of the st. Marys River. It requires the
minimization of potential harm to or within floodplains and
the avoidance of long- and short-term adverse impacts
associated with the occupancy and modification of floodplains.
Executive Order 11990 - Wetlands Management -- This order is
applicable to the site. The order requires federal agencies
to avoid, to the extent possible, the long- and short-term
adverse impacts associated with the destruction or
modification of wetlands.
'Clean Water Act, Section 404 -- This section regulates the
discharge of dredged or fill material to water of the United
states., Activities during the remedy may be regulated under
section 404 of the CWA; therefore, the substantive
requirements of section 404 would be relevant and appropriate
to the remedial action at the site.
state ARARs
Goemaere-Anderson Wetland Protection Act 203 of 1979 -- This
act regulates any activity which may take place within
wetlands in the State of Michigan. Act 203 is applicable at
this site; it may require the replacement of adversely
impacted wetlands with comparable resources.
Soil Erosion and Sedimentation Control Act, Act 347 of 1972 --
This act regulated earth changes, including cut and fill
activities, which may contribute to soil erosion and
'sedimentation of surface waters of the State. Act 347 would
apply to any such activity where more than 1 acre of land is
affected or the regulated action occurs within 500 feet of a
lake or stream. Act 347 would be applicable to the excavation
activities since these actions could impact the st. Marys
River, which is less than 500 feet from the area to be
excavated.
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Shoreline Protection and Management Act, Act 245 of 1970 --
This act regulates construction of permanent structures in
designated high risk erosion areas, designated flood risk
areas and designated environmental areas. Substantive
requirements will be met if permanent structures are
constructed in areas designated under the act.
3.
Action-specific ARARs
Action-specific ARARs are requirements that define acceptable
treatment and disposal procedures for hazardous substances.
Federal ARARs
Resource Conservation and Recovery Act -- Since tannery waste
is exempted as a listed waste and TCLP and other tests have
shown that the waste at the site is not characteristically
hazardous, only RCRA Subtitle 0 would be an ARAR at this site.
Since a new containment area is being constructed on-site
under this alternative, the substantive requirements under
Subtitle D would be met.
State ARARs
Michigan Solid Waste Management Act (Act 641) -- As mentioned
above, the substantive requirements under this act for
constructing and closing new solid waste containment areas
would be met, to the extent that they are more stringent than
the provisions of RCRA Subtitle D. Also, for the reasons
discussed above, the Michigan Hazardous Waste Management Act
64 of 1979, as amended, is not an ARAR at this site.
c.
Cost-effectiveness
A cost-effective remedy is one for which the
proportional to the remedy's overall effectiveness.
cost
is
The selected remedy, Alternative 7, affords a high degree of
overall effectiveness. It ls the least expensive alternative
being considered, with the exception of No Action. While
Alternative 7 has less stringent soil and sediment cleanup
standards than Alternatives 2, 3, 4, and 5, it is still
protective of human health and the environment by removing and
containing wastes and soils and sediments above health-based
criteria. It may also preserve some of the quality wetland
areas which currently exist at the site. Alternatives 4 and
5, which involve incineration, are the most expensive.
Incineration was evaluated primarily as a way of reducing the
volume of material so that disposal costs would be cheaper.
However, since the overall cost was higher than those
alternatives calling for disposal without treatment, the
incineration alternatives did not meet this objective. In
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general, alternatives with off-site disposal (3 "and 5) were
more expensive than those with on-site disposal (2, 4, 6 and
7), but eventually long-term operation and maintenance costs
would no longer exist for off-site options since waste would
not be left on site. When waste is left on-site, either in an
on-site landfill or in place, as in Alternatives 2, 4, 6 and
7, operation and maintenance, whi~h includes monitoring of the
site and maintenance of shoreline stabilization, would be on-
going. In spite of this, the 30-year net present worth cost
for on-site remedies remains below off-site remedies.
Alternative 7 is a cost-effective alternative which provides
overall effectiveness proportional to its cost.
d.
utilization of Permanent Solutions and Alternative Treatment
Technoloaies or Resource Recoverv Technoloaies to the Maximum
Extent Practicable
u.S. EPA believes the selected remedy represents the maximum
extent to which permanent solutions and alternative treatment
technologies can be utilized in a cost-effective manner for
the Cannelton Industries site. Of the alternatives that are
protective of human health and the environment and comply with
ARARs, u. s. EPA has determined that the selected remedy
provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence, reduction of toxicity, mobility
or volume' through treatment, short-term effectiveness,
implementability, cost and State and community acceptance.
The alternatives involving incineration were far more
expensive, didn't achieve their intended goal (i.e. to reduce
the volume of waste to dispose and thereby reduce the overall
cost), and could potentially increase the mobility of
inorganic contaminants by destroying the organic matter to
which the contaminants are currently bound. Other treatment
technologies which were tested in treatability studies were
found not to be effective.
Therefore, the selected remedy represents the maximum extent
to which permanent solutions and treatment can be practicably
utilized. The contamination in the waste, soils and
sediments, especially considering the low mobility this
contamination currently exhibits, can be reliably controlled
over time through engineering and institutional controls, and
treatment is therefore not practicable. "
e.
Preference for Treatment as a princiual Element
No principal threat which warrants treatment at the site has
been identified. While the waste at the site does not readily
fit the definition of a principal threat, it also cannot be
classified on the whole as a low level threat. Treatment
options were evaluated for the source material (soils, wastes
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and sediments), and treatment was found to be impracticable.
It was also determined that, given the waste characteristics,
chiefly the low mobility of the principal contaminants,
containment of the source material would be a safe and
reliable option when coupled with institutional controls and
monitoring. Based on the comparative analysis of
alternatives, it has been determined that treatment does not
provide a significant benefit proportional to its cost.
DOCUMENTATION OF SIGNIFICANT CHANGES
The selected remedy, Alternative 7, was modified based on comments
and additional information. The derivation of cleanup standards
for soils is no longer dependent on the groundwater model presented
in the FS Addendum which called for a standard set at "20 times"
the backcalculated groundwater concentration if the resulting
standard was more stringent that the Direct Human Contact number.
Eliminating this approach most significantly affects mercury, which
in this ROD has no numerical standard. Further assessment of the
site's contribution of mercury to the st. Marys River and the
ecosystem will be made. It will be the objective of the cleanup to
reduce the levels of mercury discharging from the site to health-
based or background levels, whichever is less stringent.
To confirm whether the concentrations of other contaminants of
concern, namely chromium, cadmium and lead, will ultimately be
protective of groundwater and surface water, leachate tests
pursuant to Act 307 R 299.5711(2) (b), or another appropriate method
developed by EPA will be performed. Short-term and long-term
effectiveness and cost-effectiveness will be taken into account
when applying the standards resulting from any of these tests.
It is also noted that, in the FS Addendum, where Alternative 7 was
developed, a portion of the wetland of Tannery Point containing a
higher concentration of chromium would not be remediated, based on
the belief that this was an anomalous area of contamination and the
high concentration detected was localized. Additional sampling
performed in July and August 1992 by the MDNR demonstrated that
this area of higher contaminant concentrations is more widespread
that originally thought, and will be remediated to the extent that
cleanup standards are exceeded in this area.
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