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EPA Superfund .
. Record of Decision:
PB94-964135
EP A/ROD/R05-93/234
,February 1995
Hi-Mill Manufacturing Company,
Highland Township, MI
9/28/1993
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HazdrdoUf WQSteC'dtee+ioA ',,'
Information Resource Center
US EP A Region 3
Philadelphia, PA 19107
EP A Report Collection
Information Resource Center -
US EP A Region 3
Philadelphia, PA 19107
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50272-101
REPORT DOCUMENTATJON /1. REPORT NO.
PAGE EPA/ROD/R05-93/234
2.
3. Reclplenra Acc8aalon No.
4.
Title end Subtitle
SUPERFUND RECORD OF DECISION
Hi-Mill Manufacturing, MI
First Remedial Action - Final
Author(s)
5.
Report Dat,
09/28/93
6.
7.
8.
Performing Organization Rept. No.
9.
Performing Orgenlzatlon Name end Add,..
10 Project TaaklWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Add,...
U.S. Environmental Protection
401 M Street, s.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
Agency
800/800
14.
15. Supplementary Notes
PB94-964120
16. Abstract (Limit: 200 _rda)
The 4.5-acre Hi-Mill Manufacturing site is an active manufacturing plant located in
Highland Township, Oakland County, Michigan. The site contains a manufacturing
facility that makes aluminum, brass, and copper tubing parts and fittings and a paved
parking area. In addition, the site borders Highland Road and Highland State
Recreation Area, which includes Waterbury Lake approximately 1,000 feet to the south,
Target Pond (a 10-acre marsh land) to the east, and wetlands areas to the west and
south. Land use in the area is predominantly industrial, with the nearest residences
located approximately 2,000 feet from the site. The Hi-Mill operations began in 1946
and consisted of two main processes: anodizing and degreasing metals. As part of
plant operations, onsite tanks containing acids were used for metal baths.
Periodically, these tanks were emptied of the process wastewater, which contained
residues of acids and metals, including copper, aluminum, chromium, and zinc. From
1946 to 1979, this wastewater was discharged onsite into a clay-lined lagoon. In 1972,
site investigations documented elevated levels of metals in Target Pond and onsite
production wells. In 1976, Hi-Mill built a second, smaller lagoon to receive overflow
from the original lagoon. On two occasions, in 1976 and 1977, the larger lagoon
overflowed into the marsh bordering the site. As a result, the State required Hi-Mill
(See Attached Page)
17. Document Analyala .0 Descriptors
Record of Decision - Hi-Mill Manufacturing, MI
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (TCE, 1,2-DCE, vinyl chloride)
b.
IdentifiersiOpen-Ended Terms
c.
COSATI FleldIGroup
18. Availability Statement
18. Security CI... (This Report)
None
20. Security Class (This Page)
None
210 No. of Pag..
32
22. Price
(See ANSI.Z39.1 8)
SH InsfrucUons on RII"erse
OPTIONAL FOAM m (4-77)
(Fonnerty NTJS..35)
Department of Commerce
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EPA/ROD/R05-93/234
Hi-M~ll Manufacturing, MI
First Remedial Action - Final
Abstract (Continued)
to stop discharging untreated wastewater into the lagoon and requested that the company
design a wastewater recycling program, which was later implemented in 1981. Between 1978
and 1980, onsite construction activities resulted in damage to a solvent delivery line
between the storage tank and'degreaser. The major source of onsite contamination is
believed to be the result of this past accidental release of approximately 250 gallons of
chlorinated solvents from the underground piping on the north side of the facility. In
1983 under State supervision, Hi-Mill removed 142 yd3 of contaminated soil, 34,400 gallons
of contaminated sludge, and 63,300 gallons of contaminated wastewater offsite, and
backfilled the lagoon. In 1988, after State investigations concluded that the drinking
water was still contaminated, the two onsite production wells were abandoned, and bottled
water was provided to Hi-Mill employees. This ROD addresses the final remedy for
contaminated ground water. The primary contaminants of concern affecting the ground water
are VOCs, including TCE, l,2-DCE, and vinyl chloride.
The selected remedial action for this site includes monitoring ground water for 30 years;
re-evaluating the monitoring system, if results indicate that organic contamination is
migrating toward surface water at concentrations potentially exceeding the more stringent
of Federal and State standards; and implementing institutional controls, including deed
restrictions. The estimated present worth cost for this remedial action is $565,000, which
includes an annual O&M cost of $88,000 for years 0-3 and $23,000 for years 4-30.
PERFORMANCE STANDARDS OR GOALS:
Not provided.
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ill-MILL MANUFACTURING COMPANY
IDGHLAND TOWNSHIP, OAKLAND COUNTY, MICIDGAN
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
SEPTEMBER 1993
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RECORD OF DECISION
ffi-MILL MANUFACTURING SITE
HIGHLAND TOWNSHIP. OAKLAND COUNTY, MICIDGAN
"
b
TABLE OF CONTENTS
1. SITE DESCRIPTION
. . . . . . . . . '. . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . " 1
II. .SITE mSTQRY AND ENFORCEMENT ACTIVITIES
. . . . . . . '. : . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . . . . .... . . . . .. . . .. 1
m. mGHLIGHTS OF COMMUNITY PARTICIPATION
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
IV. SCOPE & ROLE OF RESPONSE ACTION
. . . . . . . . . . . . . ~ . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . . . . . . . . . . . .. 3
V. SITE CHARACTERISTICS
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . .. 4
VI. DESCRIPTION OF ALTERNATIVES
... .... ..... .... ........ ......... .......... .............9
vn. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIYES
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . .. 12
VllI. SELECTED. REMEDY
. . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . .. 15
IX. STATUTORY AU1HORITY FINDINGS
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 16
X. EXPLANATION OF SIGNIFICANT CHANGES
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 . . . . . . . . . . . . . . . . . . . . . .. 16
APPENDIX I: FIGURES
APPENDIX n: TABLES
APPENDIX ill: RESPONSIVENESS SUMMARY
APPENDIX IV: ADMINISTRATIVE RECORD INDEX
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCA 'nON,
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Hi-Mill Manufacturing Company, Highland Township, Oaldand County, Michigan.
STATEMENT OF BASIS
'Ibis decision documeDt presents the seJected remedial action for the Hi-Mill A-{anufacturing
Comp~y Superfund Site in HigJtland Township, ()aldand County, Micbi~n, which was
chosen in accordance with the Comprehensive Enviromnenta1 Response, Compenurion, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and is conn~ent with the Natioaal Oil and Hazardous
Substances Pollution Contingency Plan (NCP) to the extent practi~~le. 'Ibis decision is
based upon the contents of the Admini~trative Record for the site. The attached index
identifies the itemS which comprise the ,4tfminimative Record upon which the se1cction of
the remedial action is based. '
The State of lvfichi~n does not concur with this Record of Decision.
D
U.S. EPA bas selected a "No Action with Groundwater MODitoring and Institutional
Controls-. ' ' . , '
1bc remedy sdected for groundwater cont'nnnmnn iDclvdes ro,,':"UM monitmiDg of both
the sballow gmuDdwaIeI' uait aDd tile jJJteml"
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u.s. EPA has detennined that no remedial action is necessary at the site. As this is a
decision for "No Action", the stawtory requirements of CERCLA Section 121 for remedial
actions are not applicable and no stawtory five-year review will be undertaken.
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,~V aldas V. Adamkus! .' J
,~ Regional Adminis or -
U.S. Environmental Protection Agency
1/zS/~ 3
Date
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DECISION SUMMARY
I. SITE DESCRIYflON
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The Hi-Mill Manufacturing Company is located at 1704 Highland Road (M-59) in Highland
Township, Oakland County, Michigan (See Figure I). The site itself is approximately 4.5
acres in size and is dominated by the manufacturing facility and a paved parking area. The
site is bounded to the northwest by Highland Road (M-59) and, generally, on all other sides
by the Highland State Recreation Area, which is owned and operated by the Michigan
Department of Natural Resources (MDNR) (See Figure 2). Much of the Recreation Area is
, considered wetlands property. Target Pond, a marshy area of approximately lQ-acres,
borders the site-to the east, and Waterbury Lake lies about 1,000 feet to the south. The
immediate area around Hi-Mill is, sparsely populated and rural in nature. The nearest homes
are about 2,000 feet southeast of the site, along Waterbury Road.
II. SITE HISTORY ANi> ENFORCEMENT ACTIVITIES
The Hi-Mill Manufacturing Company began in 1946 as a partnership between Robert F.
Beard and Raymond Unroh~ Robert and Richard Beard bought out the business in 1957 and
remai~ the current owners. The Hi-Mill Manufacturing plant makes aluminum, brass, and
copper tublDg 'parts and finings.
Hi-Mill operations consisted of two main processes: (1) anodizing (or "pickling") to brighten
metals, and (2) degreasing to clean them. As part of plant operations, metals were bathed in
tanks containing acids. Hi-Mill employees periodically emptied these tanks of process
wastewater containing residues of acids and such heavy metals as copper, aluminum,
chromium and zinc. From 1946 until 1979, this wastewater was discharged into a clay-lined
, lagoon at ,the Hi-Mill site (See Figure 3). The lagoon was about 10 feet deep, 100 feet long,
and 100 feet wide.
Prompted by complaints from Hi-Mill employees to the MDNR, the two on-site production
wells and Target Pond were sampled in 1972 (See Figure 2). One well was found to contain
elevated levels of metals contamination. Target Pond was also found to be contaminated by
metals. In 1976, MDNR resampled the production well and Target Pond. Elevated levels of
metals previously detected in the production well were not evident. Elevated levels of
metals, however, were detected in Target Pond.
In the fall of 1976, Hi-Mill built a second, smaller lagoon south of the original one. This
second lagoon was designed to receive overflow from the original lagoon. On two separate
occasions in 1976 and 1977, the big lagoon overflowed into the marsh bordering the site.
The overflow came to the attention of the U.S EPA, and Hi-Mill applied for a special
NPDES pennit to authorize the discharges. The U.S. EPA did not concur with a pennit
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being issued by the state. MDNR ordered Hi-Mill to stop discharging untreated wastewater
into the lagoon, requesting that the company design a wastewater recycling" program. The
recycling system was implemented in 1981, but the already contaminated lagoons remained a
problem. Attempting to cleanup the big lagoon between 1981 and 1983, Hi-Mill evaporated
liquid in the lagoon using a spray technique. This technique involved spraying liquids from
the wastewater lagoons into the air. Spray nozzles were located on top of the production
facility and along ponions of the 8-foot high fence that surrounds the rear of the propeny.
MDNR ordered Hi-Mill to stop this practice in 1983.
In November of 1983, under MDNR supervision, Hi-Mill cleaned up the big lagoon by
removing 142 cubic yards of contaminated soil, 34,400 gallons of contaminated sludge, and
63,300 gallons of contaminated wastewater. The lagoon was then backfilled.
Following this Action, samples taken by the MDNR showed that removal of the water and.
sludge significantly reduced the levels of metals in on-site soils. However, other samples. .
showed elevated levels of toxic metals in sediment from Target Pond and Waterbury Lake.
Between 1978 and 1980 (exact date unknown), activities related to the construction of an
addition on the nonheast side of the building resulted in damage to the solvent delivery line
between a fonner 250 gallon aboveground storage tank and degreaser (See Figure 3). As a
result of the damage, up to 250 gallons of solvent leaked from the damaged underground
product line. The damaged. underground product line has since been replaCed with an
aboveground product line.
The two on-site production wells were resampled in 1988. Analytical results indicated that
the drinking water at Hi-Mill was contaminated with trichloroethylene (TCE) and 1,2-
dichloroethylene (DCE). A new well was installed in 1989 to provide Hi-Mill employees'
with safe drinking water. Before the new well was hooked up, bottled water was offered at
the facility. The two contaminated wells were eventually abandoned.
On June.24, 1988, the Hi-Mill site was propOsed to be placed on U.S. EPA's National .
Priorities List (NPL), a roster of hazardous waste Sites eligible for investigation and cleanup
under the Superfund Program, it became fmal on February 21, 1990 (55 FR 6160). On
October 5, 1988, an Administrative Order by Consent (U.S. EPA Docket #V-W-88-C-127)
was signed between Hi-Mill and the U.S. EPA authorizing Hi-Mill to conduct the RIlFS.
Community interest with the Hi-Mill site was minimal throughout the RIlFS process. On
October 23, 1989, a public meeting was held to answer questions about the site, the
upcoming RI, and the Superfund program. Prior to the meeting, a fact sheet was sent out
infonning the public about the Superfund process and describing the activities planned for the
RIlFS. In April 1990, an "Activities Update" was sent out infonning the public on the
progress of the RIlFS activities.
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In April 1993, a fact sheet was sent out infonning the public of the results of the Remedial
Investigation. A public meeting to present the findings of the Remedial Investigation was
held on April 13. 1993.' A notice infonning the public of the public meeting and the
availability of the RI Report in the Infonnation Repository, maintained at the U.S.EPA
Docket Room in Region V and at the Highland Township Library, was published in the
Oakland Press on March 25, 1993.
A fact sheet about the Feasibility Study and Proposed Plan was released to the public in
August 1993. The FS Report and Proposed Plan were made available to the public for
review and copying in the Infonnation Repository. The notice published on August 19, 1993
in the Milford Times announced the beginning of the 30-day public comment period. The
public comment ~riod ended Septen:tber ,17, 1993. A public meeting was held on August
23.' 1993. to present the proposed remedial alternative to the public and accept their oral and
wrinen comments.
The public panicipation requirements of CERCLA sections 113 (k) (2) (B) (i-v) and 117
have been met in the remedy selection process. This decision document presentS the selected
remedial action for the Hi-Mill Manufacturing Company Site, Highland Township, Oakland'
County, Michigan, chosen in accordance with CERCLA, as amended by SARA. The '
decision for this site is based on the Administrative Record maintained in the information
repo$itory located at,the Highland Township Library in Highland Township, Michigan.
IV. SCOPE & ROLE OF RESPONSE ACTION
This Record of Decision (ROD) addresses the fmal remedy for the Hi-Mill Manufacturing
Site. The U.S. EPA recommends that no further remedial action be taken at the site for the
following reasons:
(l) ,Although the shallow grou~dwater unit on-sit~ and off-site is contaminated with
relatively high levels of organics, this groundwater unit caDnotbe used as a drinking water
source now or in the 'future due to its low water yield. There are no beneficial uses for the
shallow groundwater unit.
(2) The intennediate aquifer, which is potable water source, showed no signs of
contamination.
(3) The only potential risks due to site contamination are found under the future residential
scenario and the likelihood of the Hi-Mill property, which has been industrial since the
1940's, being developed for residential purposes in the future is low.
(4) The complex geology of the shallow groundwater unit may make treatment of the
contaminated groundwater difficult.
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The main components of the preferred alternative are:
. Long-tenn (thirty years) monitoring of contaminated groundwater in the shallow
groundwater unit for volatile organic compounds (TCE, DCE, and VC).
. Long-tenn (thiny years) monitoring of the shallow groundwater unit near nearby surface
water bodies for TCE, DCE, and VC.
. Long-tenn (thirty years) monitoring of the intennediate aquifer.
. Implementation of in~titutional controls to restrict development of the Hi-Mill property for
residential use.
-"
Monitoring' of the shallow groundwater unit will .be implemented in order to monitor the
migration of contamination. The monitoring system will also be designed to detect adverse
impacts to the intennediate aquifer and potential impacts to nearby surface water. bodies, if
they should occur. The implementation of institutional controls will eliminate the potential
risk for direct contact under the future residential scenario because they will prohibit the
development of the Hi-Mill property for residential pUlpOses. If the U.S. EPA detennines
that there are unacceptable impacts, due to the 'results of the long-tenn monitoring progIaID,
a .treatment system will be evaluated. '. .
v. SITE CHARACTERISTICS
Pursuant to the authorities under CERCLA, as amended by SARA, and the National Oil and
Hazardous Substance Pollution Contingency Plan (NCP), an RI was conducted at the site.
The RI was conducted by the Potentially Responsible Party (PRP) between 1989 and 1992.
A Baseline Risk Assessment was prepared by the U.S. EPA to evaluate the level of risk to
. human health and the .environment. This ~on summarizes the analysis presented in the RI
Report (dated March 1993) and the Baseline Risk Assessment Reports (dated December
l~~. .
A) Site Topo~phy
The topogtaphy of the Hi-Mill Manufacturing site is gently sloping ranging in elevation from
approximately 999 ft above mean sea level (msl) at Waterbury Lake to 1,011 ft msl south of
the plant. There are several irregularly shaped ,upland areas ranging in elevation from 1,034
ft msl northeast of the site to 1,029 ft msl northwest of the site. Numerous sballow, closed
depressions exist within the area and during periods of high rainfall may contain water. .
Several water bodies are present in the area. These include Ta(get Pond, Waterbury Lake,
and Aldennan Lake. Target Pond is located approximately 100 to 200 ft east of Hi-Mill and
is a shallow surface water body and marshy area occupying a shallow depression in the
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ground surface. Waterbury Lake and the Nonh Ann of Waterbury Lake are separated by a
. smalJ levee and are located approximately 1.000 ft south of the plant building. Aldennan
Lake, located. approximately 1,000 ft nonhwest of the site. receives drainage from the stonn
sewer located in the M-59 median and roadway via ~ shallow creek which accepts outfall
from the stOnn sewer system.
D.
B) Site Geolog}'
There are seven distinct geologic units at the site: shallow soils and granular material,
brown periglacial andlor po$t periglacial lacustrine deposits. blue periglacial andlor post
periglacial lacustrine deposits, interglacial lacustrine deposits. glacial outwash deposits, and
post-glacial fluviQglacial outwash. .
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A thin veneer of sandy topsoil occurs as the uppennost unit that overlies a thin horizon of
fine sands. silts, and other various soil types. On the Hi-Mill property, this thin sandy soil
is generally absent and has been replaced by a clayey fill. material above an organically rich
topsoil or possibly peat.
A brown-gray variegated silty clay which underlies the topsoil and appears to be rather
unifonn in thickness, generally occurs between 1000 and 1010 ft msl and, except for the rear
of th~ .facility, is generally, continuous across the site.
The brown clay is'underlain by a stiff blue-gray clay that ~urs between approximately 955.
to 1000 ft msl except on the western edge of the study area. This" gray clay contains
numerous small sand and silt valves that are indicative of a lacustrine depositional
environment. The gray clay thins toward the west and south and pinches out southeast of
Target Pond.
Underlying the gray clay is a horizon of saturated outwash sands occurring from
approximately 897 to 972 ft msl in the;outhwest, and 948 to' 972 ft msl directly beneath the
site. Except toward the north and southwest, this intermediate sand is approximately 28 to
30 ft thick across the site. The intermediate sand generally consists of medium to coarse-
grained sand and fme gravel in the upper portions of the unit, and grades into a fine silty
sand toward the south and west and a medium sand beneath the Hi-Mill facility.
The intermediate sand is underlain by a lower blue-gray clay layer which is composed of
interglacial lacustrine clays similar to that of the upper gray clay horizon discussed
previously. The lower gray. clay pinches out toward the south and west and thickens to the
east. Where the lower gray clay pinches out, the intermediate and deep sands merge into a
single unit.
Below the lower gray clay horizon is a second layer of outwash sands similar to the
intermediate sand unit. This deep sand was likely deposited prior to the deposition of the
quiet, deep-water gray clay wedge. The deep sand unit merges with the intermediate sand to
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the southeast where the lower gray clay pinches out.
C) Site Hydrology
~
Subsurface groundwater flow at the site has been subdivided into five distinct
hydrostratigraphic units:
"
1. A shallow discontinuous groundwater unit within the brown clay.
2. An aquitard represented by the upper gray clay.
3. The intennediate flow system within the intennediate outwash sands.
4. A lower aquitard represented by the lower gray clay.
5. The deep flow system within the deep outwash sands.
" .
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Several dry locations in the" shallow groundwater unit indicate that it is discontinuous with
respect to the continuity in groundwater flow. It does not appear that the shallow
discontinuous groundwater unit and the intennediate flow system are hydraulically connected,
however, it should be noted that the lower aquitard (lower gray clay) does pinch out resulting
in the hydraulic interconnection of the intennediate and deep flow systems to the southeast of
the site.
D) Site Surface Water Hydrology
",: :'~:':A'-TI1e Hi-Mill site is situated among several water bodies. Target Pond is adjacent to the east,
Waterbury Lake and the North Ann to the south, and Aldennan Lake to the northwest across
M-59. The water bodies are surficially unconnected and lie within respective closed basins
that do not possess surface water drainage outlets. "
Target Pond is rimmed by adjoining wetland areas and generally possesses a surface water
area of between 8 to 10 acres, at present, and a maximum depth of approximately 10 ft. The
size of Target Pond changes substantially depending upon the surface water level of the"
pond~ " "
The surface area of Waterbury Lake ranges from 3S to 40 acres and is rimmed by wetland
areas. The maximum depth of the lake is unknown but is substantially greater than Target
Pond. The North Ann of Waterbury lake is generally isolated surticially from the main
portion of Waterbury Lake by a small levee. Surface water data suggest that the two water
bodies are hydraulically interconnected through the levee located between them.
Alderman Lake possesses approximately the same surface area as Waterbury Lake and is
adjoined by a wetland area. An arm of Alclennan Lake extends southeast of the lake to the
northwest side of M-59 across from the North Ann of Waterbury Lake. It is this arm that
accepts discharge via an outfall pipe from the sto~ sewer system located within M-S9. No
surficial connection between the North Ann and Aldennan Lake has been confinned, and no
surface water exit point for the water in the North Arm has been located southeast of M-S9.
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Another ann of the Aldennan wetland is located northeast of M-59 across from the north
~dge of Target Pond. Previous investigations have suggested that these water bodies may be
connected surticially during high water periods via a culvert beneath the M-59 roadway.
While a conduit is present near the northern edge of Target Pond, no outflow pipe has been
discovered on the nonheast site of M -59. It is possible that the conduit located near Target
Pond connects into the M-59 stonn sewer system.
Observations made during the remedial investigations indicate that Target Pond, Waterbury
Lake, the North Ann, and Aldennan Lake are generally groundwater discharge zones, and
that any limited hydraulic connection between the surface water bodies appears to be only
through the shallow groundwater unit.
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EXTENT OF CONTAMINATION
Between 1989 and 1992, the RIlFS was conducted by Hi-Mill under the guidance and
oversight of the U. S. EPA and MDNR. The RIlFS was conducted to identify the types,
quantities, and locations of contaminants at the site and to develop ways of addressing the
contamination problems. The key fmdings of the RI are as 'follows:
1) Hydroeeol~ic Investie:ation'
Results from groundwater sampling show that the shallow groundwater unit below the Hi-
Mill property and M-59 has been contaminated by on-site sources. Several volatile organic
compounds (VOCs) were detected in the shallow groundwater unit. The VOCs of primary
concern are trichloroethylene (TCE), 1,2 dichloroethylene (DCE), and vinyl chloride (VC);
maximum concentrations detected were 55ppm, 3.5ppm and 0.4ppm, respectively (See '
Figures 4, 5, & 6).
, ,
The primary source of contamination is believed to be the past accidental release of
approximately 250 gallons of chlorinated solvents from the underground piping associated
with the solvent storage tank located on the north side of the facility.
2) Site Soils Investigation
Results from the surface and subsurface soil sampling show that on-site soil near the facility
has been contamin2ted with organic' and inorganic chemicals. The primary sources of the
organic contamination are believed to be the accidental release of solvents from the delivery
line and the former and current solvent storage tanks located on the north and southwest
sides of the facility. The primary sources of the inorganics contamination are believed to
include the wastewater lagoons located at the rear of the facility and the abandoned
wastewater recycling system.
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3) Marsh Surface Waters and Sediment Investigation
Results of the sediment investigation show that although the sediments in Target Pond show
concentrations of inorganics apparently from the Hi-Mill facility; there does not appear to be
any adverse environmental effects associated with the inorganics concentrations. The surface
water in Target Pond and Waterbury Lake and the sediment in Waterbury Lake does not
appear to be severely impacted with inorganics. .
The ecological inventory included a survey of the plants and wildlife and an aquatic survey
of Target Pond. The survey results do not indicate any adverse impacts related to Hi-Mill
activities.
. .
BASEUNE RISK ASSESSMENT
During the RI, the U.S. EPA conducted a risk assessment which analyzed the health and
environmental problems that could result if site related contamination was not cleaned up.
That analysis, called a Baseline Risk Assessment (BRA), compared the contamination levels
at the site with Federal and State standards. It considered pathways by which people and
wildlife could be exposed to site-related contaminants and whether such exposure could
increase the incidence of ~inogenic (cancer-related) and noncarcinogenic (non-cancer
related) diseases beyond'the levels that normally occur in the study area.
The assessment assumed ,that people could come into contact with site related contaminants
by eating or drinking them (ingestion), breathing them (inhalation), or abSorbing them
through the skin (dermal contact). The contaminants of con~m are the VOCs (TCE, DCE,
VC) found in the shallow groundwater unit both on-site and off-site. There are no
unacceptable risks from inorganic chemicals associated with site activities.
The BRA evaluated ihe potenuaI health threats to current Hi-Mill workers expose4 to site .
soil and future residents exposed to site soil, groundwater, and Target Pond. The assessment
concluded that current Hi-Mill workers are not at an unacceptable carcinogenic risk due to
the soil at the site. Current worker expo$ure to site groundwater was not evaluated because
there is no indication that workers ,are exposed to this groundwater (the shallow groundwater
unit below the Hi-Mill propeny and M-59 is not used for drinking water by Hi-Mill or for
residential wells). If the site is developed for residential use in the future, adult and child
residents on-site will not be at an unacceptable risk due to site soil or Target Pond.
. However, future adult and child residents on-site who would regularly use water from the
shallow groundwater unit may be at a carcinogeDic risk by ingesting, inhali"g, or having skin
contact with the groundwater.
Table I lists all the pathways evaluated in the human health risk assessment and the potential
carcinogenic risks associated with each. Listed below are the pathways of greatest concern
showing risks in excess of U.S. EPA's acceptable risk range (1 X 1()'6 to I X 1()"4) and the
8
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~stimated upper limits of additional cancer cases that could occur as a result of repeated
~xposures in the future to site related contaminants (these risks were estimated by assuming a
person would be exposed to the contaminants of concern every day over a period of a
lifetime). The excess lifetime cancer risks should be regarded as conservative estimates on
the potential cancer risk rather that actual representations of true cancer risks:
. Future on-site residents inhaling, ingesting, or having direct contact with the
water from the shallow groundwater unit:
Adults: 4 additional cases per 1,000 people exposed (4 X 10-3).
Children: 3 additional cases per 1,000 people exposed (3 X 10-4).
-.
. .
Some site-related contaminants could also pose various noncarcinogenic health problems.
The measure of noncarcinogenic risk is termed a hazard index (H.I.). When the H.I.
exceeds I, there is a potential for adverse health effects. Table 2 lists all the pathways
evaluated in the human health risk assessment and the potential noncarcinogenic risks
associated with each of them. Of the exposure pathways evaluated, the H.I. is greater than 1
for future on-site adult residents ingesting or h~ving direct contact with water from the
shallow groundwater unit (H.I. = 37) and future on-site child residents ingesting water from
the shallow groundwater unit (H.I. = 20). .
10 addition to performing an assessment ot nsks to human health, an assessment of risks to
the environment was also performed. The results of the assessment show that there does not
appear to be any adverse impacts to the surface water and sediments of Target Pond or
Waterbury Lake as a result of site activities. There is also no indication of adverse impacts
to wetland vegetation or terrestrial animals or plants.
In summary, the risk assessment show$ there is no health risk to current workers from
exposure to site soils or groundwater and no health risk to future residents from e~sure to'
site soil. Also, there do not appear to be any risks to the environment. The risks apply only
to future residents on-site, if any, who ingest, inbale, or have direct skin contact with water
from the shallow groundwater unit at the site. Subsequent to the preparation of the risk
assessment, the U.S. EPA determined that based on the fact that the shallow groundwater
unit cannot be used as a drinking water source due to its low water yield and that the land
use has been industrial for nearly 50 years, the probability of a future residential scenario
occurring at this site is low. Therefore, the evaluation of a future residential scenario for the
Hi-Mill site is considered'to be too conservative and should not be considered in the
determination of risk for the site. .
VI. DESCRIPI'ION OF ALTERNATIVES
An array of alternatives for addressing groundwater and soil contamination at the Hi-Mill
9
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Manufacturing Site was developed. The remedial alternatives considered were evaluated
based on their ability to be protective of human health and the environment, attain
compliance with Federal and State environmental regulations, be cost effective. and use
pennanent solutions and alternative treatment technologies or resource recovery technologies
to the maximum extent practicable.
The alternatives analyzed at the Hi-Mill Manufacturing site are presented below. The
Feasibility Study analyzed three alternatives: No Action; Groundwater Monitoring and
Institutional Controls; and Active Treatment (On-site and Off-site), however, the U.S. EPA
has chosen to combine the No Action and Groundwater Monitoring and Institutional Controls
. alternatives. This is due to the fact that the U. S. EP A considers Groundwater Monitoring
and Institutional Controls a fonn of "No Action". The active treatment alternatives are
designed to remOOiate the soil and shallow groundwater unit on-site and/or off-site.
Alternative 1: No Action with Groundwater Monitoring and Institutional Controls
**Preferred Alternative**
Capital Costs:
Annual O&M Costs:
First 3 years: .
Next 27 years:
Total Present Worth Costs:
$ 36,000
$ 88,000
$ 23,000
$565,000
The statute requires that the "No Action" alternative be evaluated at every site to establish a
. baseline for comparison. Under this alternative, no action will be taken to prevent exposure
to. the shallow site soils or to prevent contaminants from leaching from the soil at the site. In
addition, no action will be taken to prevent the possible migration of the contaminated
groundwater further off-site or into deeper aquifers. This alternative does, however, involve
monitoring of the shallow groundwater unit ,and intennediate aquifer at the site and
implementation of institutional controls (i.e. deed restrictions).. ,..
Groundwater monitoring .would be utilized to monitor the migration of impacted groundwater
in the shallow groundwater unit. The monitoring network: would also be designed to detect
impacts to the intermediate aquifer and nearby surface water bodies if it should occur. Data
would be collected from the monitoring wells quarterly for the fust three years after which
consideration will be given to reducing sampling frequency to annually. If at any time U.S.
EP A detennines that contamirnation has adversely impacted nearby surface \Yater bodies
and/or the intermediate aquifer, a treatment alternative will be evaluated. .
Institutional controls (deed restrictions) would be used as a means to prevent the Hi-Mill
Manufacturing site from being developed for residential use. Such restrictions would
eliminate the need to consider exposure risks to future residents.
10
.
-------
Alternative 2A: Active Treatment (On-Site)
u
Capital Costs:
Annual O&M Costs
First 3 Years:
Next 27 years:
Total Present Wonh:
$ 452.000
$ 134,000
$ 73,000
$1,738..000
This alternative involves the use' of a vacuum enhailced recovery system designed to
remediate on-site soils and shallow groundwater that have been impacted by volatile organic
compounds. This alternative also involves the implementation of institutional controls on the
Hi-Mill propeny to prohibit development of the property for residential use.
-'
Vacuum enhanced recovery wells would be placed around the Hi-Mill ManufactUring
building in a pattern designed to capture shallow groundwater and air from suspected source
areas and also to prevent migration of on-site groundwater that exceeds the cleanup levels.
Once contaminated groundwater is captured. it would flow to a diffused aeration unit where
primary treatment of VOCs would occur. Discharge from the aeration unit would be
pumped to an activated carbon bed for fInal treatment. Treated water would be discharged to
a selected discharge point. Recovered air would be treated in an activated carbon unit and
discharged to the atmoSphere.
" ; .-' The complex hydrogeology of the shallow groundwater unit may make successful treatment
of the groundwater unit difficult. Pilot tests will need to be conducted in order to detennine
the effectiveness of this technology.
In addition to the vacuum enhanced recovery system, groundwater monitoring would be used
to provide data on the effectiveness and progress of remedial efforts.
Alternative.2B: Adive Treatment (On~ite & Off~site)
Capital Costs:
Annual O&M Costs
First 3 years:
Next 27 years:
Total Present Worth:
$ 564,000
, $ 136,000 .
$ 73,000
$1,857,000
This alternatives involves,the same components as Alternative 2A with the addition of an off-
site groundwater recovery component.
In order to capture off-site shallow groundwater, a single conventional groundwater well
would be placed off-site (in the median of M-59). Captured shallow groundwater and air
would undergo die same treatment process as described in Alternative 2A.
11
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VII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A. The Nine Evaluation Criteria
In selecting its preferred remedial alternative, U.S. EPA uses the following criteria to
evaluate each of the cleanup alternatives developed in the FS. The nine evaluation criteria
are summarized below:
1.
Overall Protection of Human Health and the Environment addresses whether a remedy
provides adequate protection of human health and the environment and describes how
risks posed through each exposure pathway are eliminated, reduced or controlled
through treatment, engineering controls or institutional controls.
-'
2.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) ..
addresses how the proposed alternatives complies with pertinent Federal and State
environmental laws and/or justifies a waiver.
3.
LomHerm Effectiveness and Permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time.
4.
Reduction of Toxicity. MobiJjty or Volume Through Treatment evaluates an
alternative's use of treatment to reduce the hannful nature of contaminants, the
. contaminants' ability to move in the environment, and the amount of contamination
present.
5.
Short-term Effectiveness addresses the ability of alternatives to manage risks during
construction and implementation phases, and reduce immediate risks posed by the
hazardous materials present. .
6.
Implementability is the technical administrative feasibility of a remedy , including the
availability of goodS and services needed to implement a particular option. .
7.
~ includes estimated capital and operation and maintenance costs.
8.
Suwort Agency Acceptance indicates whether, based on its review of the Feasibility
Study and Proposed Plan, the support agency. concurs, opposes, 9r has no comments
on the preferred alternative.
9.
. .
Community ACCej)tanCe summarizes the public's genel31 response to the alternatives
described in this Proposed Plan and in the Feasibility Study. Community acceptance
will be assessed at the end of the public comment period.
12
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B. Comparative Analysis
The following comparison of alternatives. considers the options ~or soil and groundwater.
1.
Overall Protection of Human Health and ihe Environment
Alternative I would promote the continued protection of human health and the environment
by controlling land and groundwater use, as described above. As a result of the monitoring
activities, appropriate remedial action could be taken, if necessary, to provide for the
continued protection of human health and the environment. in the even't of a significant plume
expansion.
Al~i11atives 2A and 2B would provide long-term protection of human health and the. .
environment by reducing the concentration of the constituents of concern in the groundwater
and soils.
2.
Compliance with Applicable and Relevant and Appropriate Requirements
(ARARs)
There are no ARARs' associated with Alternative I since there are no reasonable potential
risks due to site con~tion. Compliance with chemical-specific ARARs would be
anticipated over the long tenn for Alternatives 2A and 2B. Al,tematives 2A and 2B would.
also comply with their respective action-specIfic ARARs. Assuming that regulatory agencies
would approve the necessary site activities for the alternatives, Alternatives 2A and 2B would.
comply with the location-specific ARARs.
3.
Long-tenn Effectiveness and Pennanence
The institutio~ controls provided for in Alternative I would provide long-term effectiveness
. and permanence m promoting the continued protection of human health and the' enVironment
while monitoring the changes within the shallow groundwater plume. Monitoring would also
be a reliable means for detecting future. impacts, allowing for future implementation of
remedial controls if necessary. Deed restrictions would prevent direct contact with, or
ingestion of, impacted groundwater in the future, as described above.
Alternatives 2A and 2B will provide source control by controlling the flow of groundwater
from the site source areas. The additional benefits of accelerated aquifer restoration may be
limited due to complex hydrogeologic conditio":s. .
4.
Redudion of Toxicity, Mobility, or Volume Through Treatment
Alternative I does not inCOIpOIate active treatment and therefore would not reduce the
toxicity, mobility or volume of contamination through treatment.
13
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Alternatives 2A and 2B do provide for the reduction of toxicity, mobility, and volume of
the constituents of concern through the active treatment of impacted soils and groundwater.
5.
Short-tenn Effectiveness
Alternative I would provide a relatively high degree of short-tenn effectiveness because no
disturbance of the impacted soils or groundwater would occur during implementation of deed
restrictions. and the limited contact with potentially impacted soils and groundwater during
the installation of the additional groundwater monitoring wells.
Alternatives 2A and 2B would provide a relatively lower level of short-tenn effectiveness
because of the additional potential exposure risks that could occur during construction.
-"
6.
. .
Implementability
The institutional controls provided for Alternatives I, 2A and 2B could all be readily.
implemented. The additional components necessary for the implementation of Alternative 2A
could also be constructed rather easily. Alternatives 2A and 2B may be difficult to
implement due to the complex geology of the shallow groundwater unit. Alternative 2B
would be the most difficult to implement primarily because of the technical and
administrative difficulties due to the necessity to pipe extracted off-site groundwater. to an on-
site treatmerit system and the presence of the highway (M-59). . . .
.7.
Cost
The costs of the individual alternatives are detailed below.
Capital
~
Annual
O&M
$ 88,000 (3yrs)
$ 23,000 (27yrs)
Present
Worth
Alt I $ 36,000
$S65,OOO
Alt 2A $4S2,OOO
$134,000 (3yrs)
$ 73,000 (27yrs)
. $136,000 (3yrs)
$ 73,000 (27yrs)
$1,738,000
Alt 2B $S64,OOO
$1,857,000
All costs are estimates. The costs associated with Al~ves 2A and 2B may change based
on the results of pilot tests necessary to assess their effectiveness.
14
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8.
Support Agency Acceptance
o
- The State of Michigan does not concur with the preferred alternative (See attached
Responsiveness Summary).
o
9.
Community Acceptance
Community acceptance is assessed in the attached Responsiveness Summary. - The
Responsiveness Summary provided a thorough review of the public comments received on
the RIfFS and the Proposed Plan, and the U.S. EPA's responses to the comments received.
-"
VID. SELECTED REMEDY
The U.S. EPA has selected Alternative l.as the preferred remedy for the Hi-Mill
Manufacturing Site. Alternative I constitutes a "No Action with Groundwater Monitoring
and Institutional Controls". The costs associated with this remedy are related to the design
of an effective monitoring network, which will involve the installation of additional
monitoring wells, and long-tenn monitoring for thirty years.
This alteritative relies on the finding that: (I) the contaminated shallow groundwater unit is
not presently being used as a potable water source and can not be used as one in the future
due to its low water yield, therefore there are -no beneficial uses for-the shallOYI groundwater
unit; (2) the intennediate aquifer, which does supply potable water, showed no signs of
contamination; and (3) the only scenario under which unacceptable human health risks were
found (future residential) is not likely to be reali7.ed due to the fact that the Hi-Mill property
has been industrial for nearly fifty years and the possibility of it being developed for
residential purposes in the future is low; and (4) the active treatment alternative evaluated
may not be effective .in treating contam~ondue to the .complex geology of the .shallow
groundwater unit.
It is anticipated that no further action will be required to mitigate the migration of .
contaminants already present in the aquifer. Water quality monitoring will be conducted for
thirty years to monitOr contaminant migration in the. shallow groundwater unit and to assess
water quality in the intennediate aquifer. Total cost for insta1Jation of additional monitoring
wells and monitoring for the site is estimated to be $565,000.
Alternative I will establish a databue of groundwater analytical results which will be used in
the assessment of the site remedy. If monitoring results indicate that organic contamination
from the shallow groundwater unit appears to be migrating toward nearby surface water
bodies at concentrations that could potentially exceed the more. stringent of Federal and State
water quality standards, the monitoring system andlor treatment alternatives will be re-
evaluated. In addition, if monitoring results reveal organic contamination in the intermediate
15
-------
aquifer at levels which could pOtentially cause risks to human health. the treatment
alternatives will be re-evaluated.
Alternative I will also involve the implementation of i'1stitutional controls to prohibit the
development of the Hi-Mill property for residential use in the future. For nearly 50 years
the Hi-Mill property has been industrial. In addition, the property is surrounded on three
sides by the State owned and operated Highland Recreation Area and on the fourth side by a
highway (M-59), thereby further reducing the probability that the Hi-Mill property will be
developed for residential' use in the future. These facts eliminate the need to consider
potential risks under the future residential scenario which leads to the U.S. EPA
. detennination that there are no human health risks associated with the site contamination.
"
The U.S. EPA ,believes that the selected alternative provides the best balance of tradeoffs
among alternatives with respect to the criteria used to evaluate the remedies. The selected
alternative would be protective of human health and the environment and would utilize
pennanent solutions to the maximum extent practicable.
IX. STATUTORY AUTHORITY FINDINGS
The human health risk assessment indicates that risks associated with site contamination fall
within acceptable guideliites as long as the Hi-Mill property remains industrial and no potable
water wells are screened in the shallow groundwater unit. These conditions will be achieved,
through the selected remedy, by the implementation of deed restrictions on the Hi-Mill
property which will prohibit residential development. All potable water wells on-site and
off-site are screened in the intennediate aquifer and no contamination was found in this
aquifer. In addition, the monitoring network proposed in the selected remedy will be
designed to track the movement of the contaminant plume in the shallow groundwater unit
and detect adverse impacts to the intennediate aquifer and nearby surface water bodies, if
. . they should Occur. . This will allow the U.S.. EPA to continually monitor and evaluate
" .
groundwater quality and reassess the need for active treatment, if necessary. '
X. EXPLANATION OF SIGNIFICANT CHANGES
There are no significant changes from the recommended alternative described in the Proposed
Plan.
16
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-'
APPENDIX I .
FIGURES
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AWGERAGHn"
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ORiGiNAL
-------
HI-MILL MANUFACTURING
"Hightanci~~*'~
.:. ..:::ii;f?:
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2. Former Underground
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6. Former TCE Degreasing'
FIGURE
2
-------
DWG DATE: 02APR13
PRJCT NO.: WI't.Ga
ADDITION 3
STORAGE'
FilE NO. 9b
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.- _._L - ......
"
MAIN MANUFACTURING PLANT DIAGRAM
HI.Mlll MANLIFAC runlUG .
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AND
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. TWOfOHMER
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GROUNU
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FIGURE
3
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i
~PPROXIMA TE LATERAL EXTENT
OF VINYL CHLORIDE MIGRAtiON
!cl!i(!!!!.
<:> """0 "uGEII BOIIIIIG lOCAIION
. PtEZOIolE tEll
"....11' .1' I'v, ...~ &.0"'.....'.11.
h\-
111.U AI Q II.."'"
"8fOERAOUTY
"Fe MILI.ER . It-a'
.,.."..........,., i.f.....
MEDIAN INVESTIGATION
VINYL CHLORIDE DISTRI8UTlOli
FIGUI
6
HIIAILl MANII' At; 11.11111(;
HlGHL.ANO t.uc.c.G,Au
'.
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o
-'
APPENDIX II
TABLES
..
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o.
TABLE I
Summary Of Excess Cancer Risks For Populations At Hi-Mill
Exposed Exposure Exposure Medium Exposure Cancer Risk
Population Point Route
AVa RME
Current On-site Soil Oral 5E-Q7 2E-Q6
Worker -
Future On-site Groundwater Oral. 4E-04 2E-03
Resident. Dermal 6E-Q5 2E-04
Adult Indoor Air Inhalation 5E-04 2E-03
Soil Oral 7E-07 1 E-Q5
Ambient Air Inhalation 3E-09 lE-QS
Garden Vegetables Oral 4E-07 2E-Q6
Future On-site Groundwater . Oral SE-04 9E-04
: Resident, Dermal 7E-Q5 SE-QS
..-, Child Indoor Air Inhalation 2E-Q3 2E-Q3
Soil Oral 4E-Q6 SE-06
Ambient Air Inhalation lE-QS lE-QS
Garden Vegetables Oral 6E-Q7 lE-D6
Future . Target Surface Water Oral (a) . (a)
Resident, Pond Dermal (a) (a)
Youngster Sediment Oral 9E-oS . 5E-Q7
(a) No carcinogenic chemicals detected in surface water.
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TABLE :!
Summary Of Hazard Indices For Populations At Hi-Mill
, "
Exposed Exposure Exposure Medium Exposure Hazard Index (a)
Population Point Route
AVE RME
Current On-site Soil Oral 2E-02 4E-02
Worker .
Future On-site Groundwater Oral 2E+Ol 3E+Ol
Resident, Dermal 6E+OO 7E+OO
Adult Indoor Air Inhalation 2E-O 1 3E-OI
Soil Oral 2E-02 2E-0l
Ambient Air Inhalation 8E-06 8E-Q6
Garden Vegetables Oral 8E-02 1 E-Q 1
Future On-site . Groundwater Oral lE+Ol 2E+Ol
. Resid~t, Dermal 2E-O 1. 2E-O 1
Child Indoor Air Inhalation 4E-Ol 5E-Ol
Soil Oral 2E-O 1 4E-Q 1
Ambient Air Inhalation. lE-OS lE-05
Garden Vegetables Oral 2E-O 1 3E-Ol
Future Target Surface Water Oral 4E-04 2E-Q3
Resident, Pond Dermal lE-03 1 E-02
Youngster . Sediment Oral 1 E-02 . 6E-02
(a) Hazard Index is sub~hronic for ~hild resident and chronic for all other populations.
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"
-'
~
RESPONSIVENESS SUMMARY
-------
. lU-lWILL MANUF ACnJRING SITE
fUGIILAND TOWNSHIP. OAKLAND COVN1Y. MlCIUGA.V
RESPONSIVENESS SUMMARy
T
-'
A.
Overview
'" ""', '" ................................. ...........1
B.
Background on Commuaity Invo'VellleDt
... """"" ......... ......... ............ ......... ....1
c.
Summary of Commeats Received Duriac the Publie CO"'"!eat Periud and
Aleacy Respoases . . . .
. . . .' .
...............................~................... 2
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"
.
lU-MILL :\tANUFAC1t1RING SITE
HIGIILA.'ID TOWNSHIP. O~"" COUNI"Y. ~UCIIIG~'J
RESPONSIVE.~S SUMMARY
This Responsiveness Summary has been prepared to meet the requirementS of Sections t 13
, (k)(2)(B)(iv) and' 117 (b) of the Comprehensive Environmental Response. Compensation and
Liability Act o( 1980 (CERCLA). 'as amended by the Superfund Amendments and
ReauthoriZOltion Act of 1986 (SARA) which requires a response to each of the significant
~omments. criticisms. and new data submined in written or or3..1 presentations on the
proposed plan for a remedial action.
A. .
Overview
At the time of the public comment period. the U.S. EPA had selected a preferred alternative
for the Hi-Mill'Manufacturing' site loc:arcd in Highland Township,
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been mostly supponive of the selected remedy.
c. Summary of CommentS Received During the Public Comment Period and Ageacy
Responses
The public comment period on the Feasibility Study and the Proposed Plan for ttle Hi-Mill
ManufactUring site wu held from August 19. 1993 to Seprember 17, 1993. CommentS
received durmg this time an: summarized below. Copies of aU writteD commentS submitted
[0 the U.S. EPA are included in the Administrative Record for the site which is located in
the Highland Township Library. The AdmiDistmi~e Record also comains a copy of the
. public meeting tl3nSCript.. . .
Written Comments
Comment: A United States SenatOr expressed his confidence that the aJternative selected by
the U.S. EPA is the best plan. .
RaDOn.f~: 77u!. u.s. EPA. appf'tdtlla yo"" etinjitJma in 1M proptUed lliIunmi~ for rM
rDll6iiQl acrion Ql th4 Hi-MiU Maruifaaurinj Sire.
Commeat: A United States RepreR"'hlUve scad that he was pJeased that the apacy has
been able to deveJop a cost-effective r=MisJ pJaa whida will pnxect hUIDIII bf!:8Jt~ aod the
environment in the mOSt economica1ly feasible IIWIIIer aDd urged the implementation of the
proposed plan.
/luptma: 1M u.s. EPA tlppr«Uzta yo",. C01IrIIU!1Ia on . pl't1ptJS«J lliIunmiw 10,. 1M .
. rDnediiJl aaiDn fJltM Hi-MUI M~, SilL
Comment: !be CouIIIy Executive for o.ltI.~ CoUllI)' exp~ Ilia support of tile U.S.
EPA '$ colll!h.1iaas aad recommendations IDd his pleasure rhat tile Ageacy has deveJoped a
. COSI-effeaive - dJat is pmcective of bWIIIII heaJtb aDd 11 the same time DOC detrimeara1 to
the f2lllilies B II I wat on Ri-MiD for their livMihooct. . . .
RaD01l.f~: 77u! u.s. EPA appfW"iQra YOIII'Iuppon olitJ ~ tllIIJ ~
lor r~ Propostftlllilunmi", lor 1'tIMtliIll tlCIiJRI fJl * Hl-MUl MtIIIII/tIaurin, SilL
CO"'''''': A Stare Searor~ his CIIdoa:....1IId ~ of die Apacy's
COIIClusioas aDd recomml!ftlhri01lS IDd bis belief that die Pl~ akemarive will plOCa:t
public hea1tb UId die eavinmmeat in the IDOIC eIX)~nJJy (Mable IfttInner.
RaDD11f~:
77Ie u.s. EPA tlpptmtlla yor DlllDnDlll!lll fJIId IllpptJn 01 its C01IdusiD1u tIIIIi
2
-------
o.
, recOmmtnamzofU for the propostd aLremanrt for the remedial aCllon alrhe Hi-Mill
,Hanu,iactunn
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protecung the public health and environment and should be commended for effectively
bnnglng this issue to a conclusion. .
Re$Don.re: 77ze U.S. EPA appreciares .vour suppon ollhe proposed aileT1ll11lve for remedial
(JCIZOn QZ the Hi-Mill Manwaclunng Site.
Comment: Four commenu from locaJ residentS were received in the fonn of a joint letter.
The letter swed their dissatisfacUon with the proposed aJtema1ive ~U~ they feel that it
doesn't provide for the clean-up of conraminams on-site and off-site. They expressed a
preference for AJtemarive 2B beal'SC it provides for aCtive cleanup and they feel it decreases
the possibility of futUre comaminaUon. They also expressed a concem that the quality of
water in their residential wells must' not Pose a potential risk 10 their health. . .
- .
ResQon.rt: ~ re:uiu of 1M Rt/'MliiQi Invultgarion and Risk A.uUSl1lDU intiiCQle Ihtz: lile
uni.v IUl4CceplabLe risk 10 humtUJ htlJilh is lhizl ruuiling from direa COfUtlCl Wilh
,:OnllUlU1f/Jled shaJlow J1TJlIIIliwaler untiu the jiaun ruidmritzl scDllU'io. 71JU means Ihtz: if
III some rime in IM.fi.aun 1M Hi-MiU pl'fJfJUI'! is used for ruitJDuial tk~Jopmou {l!1/i -
cirinJeing MWU ~Ils are piDati in IhI! siuJJJDw -grollllliwaur unil. lite ruiderus using Ihtz: -
Waler would POltnriail.v be tZl rislc. 17Iir scDllUio is nollilWy for Sevel'tli TtIlSDn.r: J) il is
ImJilcdy rhtzt thl! pl'fJpury will be used for rr.rid.tnlitzi tk'ldoPIllDll sina iI hD.r been industritzi-
for ntDrly 50 YeJUS and: 2) the shtllJow Jrolllldwtuu unit-is nol CIII'mIIty bdng used tU a.
drinking walU source and could nol be used QS a drinking WtIlU source in the fun,ue d. 10
ilS /ow MaIU yield. BectlU.re 01 thae faa.r. il is nol MaDary 10 cJanup 1M colllDminDriDn
in 1M sb4lJow groundwtJur lIIIil. r~ is no humtJn haJIh or enviro1llM1lllll risIc.
AJIhough the aaiw l1YtI11Mnl a/ummiva do p1't1'tli8 for clan-up of.C01llllllliMriDn, the u.s.
EPA only con.rid4n clmninf up colllllllrinDriDn lhiII ptMa a thntJz 10 humtIn Jwzith or lhe
enviT01llllBll. ~ u.s. EPA is co1lCD'll«l Mth . poISibi/ily of co1lllllllinlZlio refldUng 1M
ilUentretIUzu fJJ[Ilifu. a drinJdnr MGI6 so",". tllfIt ,. MJUby siu/tltz MGlU bDdia. .
1buejore. Jonf-IDIIIlllllllilDrint (JO Y«JnJ of. grr1ll1ldWtlur will be ~flCted.. If fJ/f]
UIIIlI:C4pIllb14 imptJI:u-/ft ds«:Rd. an ~ lT8IIIMIIl alrmuJrlve will N e"."I'(tIltd.. In
n4diiiDn tD tMlIItfttoIiII,. ~ collllOll wiD be implanstJlllJ eiiltti1uJu 1M
ptmibilily 01. Hi-Mill propory bein, IUC fo,. ~ use and CDlUequauiy eJimiJuJu
lM risk follllli "".,. ,. /IIl1ln 1'tSiIJ4nritU sCftllitJ.
~ U.S. EPA --1' r"'" du:Il"", hIM CtJIIt:SftI ngtll'din, . ....,. qlllliity of JOur
ruiIJDuUU ~ 77Ie =1f1IIIIIJ of~ wdl MlIIIpIin,. CIJlIIIqCHd in Nt1WIIIbu 1989.
did nol dac fl1I1 CGrIIGIIIiIaior ~,.,1fIIIIIIlwtlur CIJIIIlJIIIinIlnfolllld tll *
sUe is lIDl iDClIII!tl in ,.. fJJ[Ilifu in wIIit:h ,.,. wdl.r are s~ FinIIIly, JO"" ruidatiJIl
wcJJs are w--fd upf1tl/JiDll 0/* CtIIIIII1IIi1tI
Comma: A 1eUer from the "Frieads of Rose ToWllSbip", aD eDVimmnema1 group active ill
the nearby Rose Township community, submiued a leaer saungly opposing EPA's pi"~
remedial altemalive for the Hi-Mill Mamaiaduring Site. They fee! that the proposed
4
-------
alternative does not satisfy the intent of CERCLA nor does It sawiy the nine criteria EP A
uses [0 ratc si[c cleanup proposais. They reel [hat Alternative 2B provides complete
remediation oi the site and thc~rore meetS ail critena ior. cleanup and protection of the
public's health. They urge EPA to reject aJternative J and adopt Alternative 2B.
ReSDOflse: 77le U.S. EPA Iw aelermzned rhaJ rhe proposed Alre17lQllVe J is prorective of
pubLic heauh and Ihe environmeIU and l~reJore sartsjies 1M inrou oj CERCZA.. which is ro
respond 10 releases or rhremened reimses rhal may endDnger public heaiJh. welfare. or r~
environmenr. In addirion. l~ proposed ailUl'llJlive does si1lUfJ r~ niM criteria U.S. EPA.
uses ro evatume ailemarives. Ailhough AllUl'llJlive 2B does proviiUjor compLete remediarion
ojrhe sire. rhe U.S. EPA beLieva rhtu tM proposed ailemarive providu prolecrion 0/ public
Izeauh and rheinvironmenr and r~refore compielt! remetiitllion is IIII,Mcessary. .
CommentS: The Michigan Department of Natura! Resources (MDNR) stated that it does not
agree with or supporr the EPA's Proposed Plan for RemediaJ ACtion at the Hi-Mill
ManufaCtUring Site for the foUowing reasons: I) AJtbough the groundwater conwnill2tion
off plant property has been verified. the extell1 of CODf2mi~tion has nOt been derIDed and
therefore a reasonable intonned decision on the appropriate remedy cannOt be made and; 2)
The proposed remedy does not comply with the Applicable or ReIevam and Appropriate .
Requm:mems (ARARs)of the Michigan &vinmmema1 Response Act 307, as amended. and
:.i admi.f1istialT.-e rules.
Rt!SDOn.rt!: ~ U.S. EPA. 1m tielentIiMd thDl: J). 1M rDuJu of. RmIediDl lnvesrigtllion
. give adeqllDU in/Dr",lItkJn regarding rhe urent of the plume 01/ plllnt property. 1M dIIr4
indiaues rhalrhe pil.uM is c01llllined in the shlllJow grollllliwaJu IIIIil only and does not pos~
a IhreaJ ro humtJn hetz/lh or 1M environmDU. The U.S. EPA m:ognizD Ibm c01lllllllinllrio
in 1M shllilDw grollllliwaJu unil couid. in * jimIre, pt1lDllillJly cause adwne imptIca 10 *
deep~r aqllifen t1IIIi netII'by sllJ'jtJa MaID' bodiG. which IIIIZ1 thntzun humDn Iu!tlilh or 1M .
env;ronillenl.' ~ U.s. EPA 1m. ~fo~.. i~uJ~d COIIIIngtneiain ~' Proposed
Aile17llllive IhDI wouid cIIlllor 1M ~W111H1ri0ll of till dCIiw trmI1IIDU GJunuzrlve shDuid
adwrse itnpfJl:a lD dupu lIIpIiftn anIi MIUby sU1/tl1% MaW bodia tJCCIII' thIIl couid mull in
. a pOlenrUU risk lD hIIIIIIIIJ ht!IIlIh or. enWrltullat. ~ u.s. EPA belUwu dull it 1m 1If/IM
an infOnneti. MdlifJIfJ.1xlmI on * ii(017lllllitm gtllMrtti 10' . Iil4 and: 2) A.et:DnJing 10
U.S. EPA. OSM:R Dint:riw #93SS.o-JO. -If- btl.rdiM risJc ~ tlII/J 1M comptZrisDn
of uposurc collalltl'tltiDn to cMmictzl speCific slll1llillrrb indiCtlla thIIllhen is 1I/J .
UllQCcqJltlb~ rUt to humtzn MtlJJh or 1M enWrltullat tl/IIJ thJlt lID ~ DCriDn is
M1tI1TtI1IU/J. then CElCId S«:tiDn 121 clawlp SIIJIIIiIlrtb for . s-l«Titm DIG SIIpDfund
rt!1Mdy, indIIding 1M ~ to "'"' fl/IPlit:tIb~ or ~iDtZnl tl1Id fl/JPropritlu
rtqllirDnaa (AlWf.JJ. tW 1IDt tl'iggum.. ~~. sUa it Mal ~ by. u.s.
EPA IhIIl ~ is no risJc GSSodllted with Hi-Mill siu C01IIllIIIintIt tlIIIl. suiMequDUly no
nud lor retII/!lJiQl llCIion, 1I/J A.1WfS apply. induding.Mlt:higtlll EnvirtJlUtIDIlIIl Response A.a
. 301, as ammded, 0IId Us administrtzriw ruJa. .
5
-------
()1"31 Comments Taken Durin2 The Public Meeting
Comment: One commentor stated that if the alternative proposed by the EPA is the best
[hat C:1n be done. then he is in favor of it.
ReSDon.fe: 77le U.S. EPA appreciaJes your commenlS on the U.S. EPA's preferred p/Qn for
remedial acnon aJ l~ Hi-Mill Marw]aaunng Sileo
Comment: A MDNR rePresentative stated that the shallow groundwater flows radially from
[he site. In addition. he sLUed that there is a possibility that the shallow and intennediaJe
. aquifers are ~orinected. FmaUy, he stated that there is some strange geology in the median
and that there is the possibility that the contamination either is or can get into the
intennediate aquifer. .
ReSDon.re: 71ze U.S. EPA agreu IhDl the s/uziJ.ow groundWDlu flows rDliiilii.v .from l~ sileo
77le U.S. EPA aJso acknow,"gu IhDl ailhough lMre is a possibiliry lha11~ shlli/ow
groll1lliWtllU unit DIIIi i1Uumedklu aquifer may be cOIIMcred, l~ resuJu from the remedial
invaliganon did nol indiaue IhlZll~ IWO flow sySIVIIS. are COIIMCled. FiMiiy, I~ resuJu 01
l~ remeditzJ invarigarion did nor indicQ/e 1M presen« 01 con.tal1li1uJlion in 1M inr~
al/llifer bUl, 1M li.S. EPA ag~u lhlllihue is SOIM.sl1'll1Ige geoiDgy in 1M 1MliiDn an4llun
is l~ possibility IhDl colll/11lUnQrion can gel into 1M int~ aqlliler. 17zuej'ore, we .
have propostd moni1oring OIIM inremreditJu aquifer. whiCh will'a/Dr us 10 tmy Ddvene
impacu to rhDl aquifer, if lh4y shDuJd occur.
Comment: One commeatOr Stated that they wouJd like to go on record to say that those who
have beea involved in the Jeuphy and costly paR inVf'!SOpaon appreciate theEPA's
involvement and the fact tbat me EPA is uyiDg to briDg this site to a safe conclusion .for the
community. . . ... .
RUDQn.re: 1M U.S. EPA flfJpmiDlG your COItllllSla on 1M U.S. EPA's aaiDns with regard
101M Hi-Mill MtIIIlljiIaluin, SilL
6
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-"
~
ADMINISTRATIVE RECORD INDEX
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U.S. EPA ADMINISTRATIVE RECORD
HI-MILL MANUFACTURING SITE
HIGHLAND, MICHIGAN '~II
ORIGINAL
07/30/93
:::. .~: 4~THQF, RECiPIENT TrTL,iDE3:RiFTiON P;~ES
--------- -----------------
---- ---- ------ --------- ----------------- -----
1 (,O/COi(JO ~DPH File . Co..unity F~blic Water 3uPQlies Su..ary ..
Report
. 2 00/00/00. ,,,"'..,.. U.S. EFA Hi-"ill "anatacturing ~o. 3-~ile R3di~s "ap
;.1::,,:, ,.;
3 OO/vOl~O ,,~ -~A File P~tential Ground Water Conta.ir.ation ~ource
Li.;:), ~:" J
- Identification and Preli.inary Assesslent
4 03/1a/i5 Leonard, J. and Bear~, R., Hi-~lll Letter re: Co.pliance 2
Salley. 6., ~DNR Plai1ufacturing
Co.pany
S l0/31IiS Turne~, W., "DNR "i-"ill ~anufacturl- cer.it To Discharge 's
n9 CQ.pany
6 12/06lib Sc~raEeck, ~., ~~NR 3@ard, R., Hi-"i1l Letter re: Status of Co.pliance 2
Planuficturing
Co.pany
i Ql/12iii ~andell. H., PlD~R 5chralect, R., PlDhR ~e.o re: water Guality of Waterbury Lake 1
8 ,)l/:SI7B Beard, R., H:-"ill 3et, :., PlDNR Letter re: Request f~r 30 Day Extension '
..
~anufacturinq
~o.pany
9 04/\J7I7S .3eard, ~., ~i-ftill ~chraleck, R., ftuNR letter re: final ~lans and Specifications for f
;o,anu~i\:tudng. the' Eli.inatian' !It Process ~ater D~~charges,
:o.pilly Mith Atta~hlents
10 08/14/79 Beard, R., Hi-ftill Dougherty, T., "DNR Litter re: July 18, 1~79 letter and Progress 2
,lIanufacturing ~epor~
to'pin, -
11 NI1Sf80 Beard, R., Hi-ftil! Daugherty, T., ~~NR ~~tter re: COIPleticn 01 Zero Jischarge .,
..
I!uufacturing ;,stet
Co.pmy
1.2 02iO./60 Beard, R., ni-ftill ~chra.ect, R., ~DNR ~etter re: Cancellations of All Nater 3
ftanl!facturing. Discharif Per.its (Unsigned) .. ".
Co.pan,
n 02/15i80 Schra.eck, R., I!DNR Beard, R., Hi-P-ill ~etter re: Plans for Zero Dischirge 1
ftanutacturing
Co.pany .
-------
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Livingston, ?., ~DNR File
Anders:n, P.,
Ecobgy anti
EnVlrJnment, r~c.
Fi~e
Narrative SU~;QrY
lliiNR
File
Generator Insoectlon Fer.
14
Frick. S.. uakland
County Health
Division
':.eard~ R., Hl-~il:
r!anufacturing
COlpany
Lette~ reI, June IE, 19S7-Site Ins~ection
i.
;;ottnkiss"H., iJakiand County
Hi-"iil ~anufacturi- Health Division
ng COlpany .
Letter reI Chroliul Waste
,3
Getty, K., Ecology' File
Environ.ent, Inc.
T21ephone Log reI Conver~ation With Judy
~cCuliy, Highla~d Recreation Office
.,
L
36 10/07/87 Spoler, "., "ichigan "i-"ill ~anufactari- Letter re:Acceptability ot Waste for
Disposal. . Treatlent
Lnc. og
37 06/26/89 Gade, ~.~ U.S. EPA' Beard, R.. "1-"ill S,ecial Notice ,of Potential liability,
"anuhcturin9
Co.pany
~8 OB!:)6/Sa Tec~na Corporation Hi-~ill Mar.ufactur~- ?r:~:sed ?emedial Inve5ti~ation Strategy
'9 i:o.pany
. 3
11
39 OBi22iB8 Parsons, J., "DSR Beard, R., Hi-"i:1 _etter re: Silpling Analysis Results,
/'!anufacturing
COlpany
40 OB/30;89 Shu.ate, J., Butzel Lingle, S., U.S. ErA ~l-~ill "cnufacturing Co.pany's Co..ents Con- :255
Lcng Sust Klein' c!rning and abjection to the Proposal of'
Van lile B:lilg Listed on the National Priorities List,
~i~~ Attach.ents
41 10/05/88 U.S. EPA Hi-"ill ~anufacturl- ~1.:ni~tratiye Grder 9y Consent Re: Reledial 63
ng Co.pan, ;r,estigat:~n and Fea~ibility Study
42 11/07/88 Holben, R., "DPH Beard, R., ,i~"lll ~~tter re: ~ater Supply. 3
"anufactunng
43 01/17/89 File ~ewspaper Article: 'Frustration for Hi ~
~:ll: ~a,p3ny Jfficials Co.plain About DNR,
E!'A Dealings'
,;.
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49
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50
11130/89
51
~tT~;jR
------
U.S. EPA
C'Riurdan, D., U.S.
E?A
5ustafsC1. M.E.~
U.S. EN
'i'" "'0"
'o,i.~. 1:: jot
Gustafson, '''E.,
U.S. EPA
Techna Cor~oration
Larsen, D., ~DNR
52
04 lOt' [QO
04/00/90 U.S. EPA
53
06i21iQO
54
07/17/90
5S
.; 7 120/90
56
07/23/90
57
07/31/90
~8
08/03/90
59' 09/17"0
RE:PIPH
---------
---------
Public
Pub1ic
File
File
File
U.S. EPA
Concer~ed Citizens
Public
Donohue & Associate- U.S. EFA
s, Inc.
Tecnna C~~pcration
Belt~an, D., U.S.
E?A
U.S. EPA
Wilko C., U.S. ErA
Var.der~ool, L., U.S. Wilk, C., U.S. E?A
~(A
Bryson, C., U.S. EPA Ullrich, D., U.S.
EPA
Larsen, D., U.S. EPA Wilk, C., U.S. EPA
Donohue' Associate- U.S. EPA
5, Inc./Life
SysteI5,Inc~.
Wilk, C.. U.S. EPA
Beard, R., Hi-"lll
ftanufacturing
CClilany
. Tr'LEiDE3CRiFi:G~
-----------------
-----------------
5~perfur.d Fact Sheet: "Hi
~111 ~anafacturing 5upe~tijnd Site"
I11ediate ~elease: "Note To ~orrespondents"
~e.o re: Techna's Perforiance
Sign-In She~t for October 23, 1969 RI
Kick-Off fte!ting
~e.o re: Techna As the PRP's Contractor
RliFS Nark Plan/Site Safety Plan, 9AFP,
Revision. .2
Letter re: Answers and/or Current Inforlation
Regarding . Issues Raised at the October 23,
1989 Public ~eeting
Activities Update
Final Co..uoity Relations PI~n
'; and Baseli~e Risk Assess.ent, Draft
Technical Support Unit's Review of the Draft
~Ii~ndanger.ent Assess.ent Repcrt
iechnical Support Unit's Geolo~ical Review of
.the Draft RI/Endangerlent'Assesslent Report
Water ~ivision's Review of ~he RI
~DNR's SO'lents on the Draft Rl
Dono~ue's Review of the Draft RI and Baseline
hSk As!:ess.ent
U.S. EFH's Disapproval of the RI Sub.i~ted By
1esoondents
4
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11/14/90
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05/06/91
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05/1i m
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65
06/03/91
66
07/00/91
67
07/24/91
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09/00/91
b9
09/24/91
70
10/24/91
i1
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72
02/06/92
i3
04/06/92
74
12/00/92
;'wj~CF.
------
Davis, R.C.. Butzel
~ong Gust Klein &
~an hie
Hct~hkiss, G" et
al.. Geraghty ~
"iller. Inc.
Davis. R.C., Butzel
Long
Gonzalez, ~., U.S.
EPA
Geraghty & "iJler,
Inc.
Davis, R.C., Sutzel
~ong
Bronson, N.,
3~onetics.Corporati-
on
Traub, J., U.S. EFA
Geraghty ~ "iller.
Inc.
Wilczynski, ". and
Wolia, K., 5e~aghty
& "iller, Inc.
Johnson, K., U.5.
~PA
"DPH
Johnson, K., U.5.
EP4
?E:r=rENT
---------
---------
Johnsen, Land
Scn:alez, ~., ~,S.
EPA
;~hn~an, K., U.S.
ErA
Sanzalez, ~., U.S.
EPA
Davis, R.C., Butze1
Long
~riLE;&E5CRrFTrQ~
-----------------
-----------------
Letter re: ~i-~ill ~anu~acturlng CCloany's I-
ntent t:l (cnhn!i! With Its Freparation ..nd
;ublittal at. the ~isk Assess.ent (.it~
Attac~ed Letters)
Garaghty & "iller's Points ~f Concero
;elating to the Phase II Hydrogeologic
Investigation
Letter ra: the Dis~ute Resolution Request
Regarding vertical Prof:ling
U.S. EPA's Written Response to t~e Forlal
Dispute re:. Vertical Sa.pIing
Hi-"ill ~anufacturi- Final Technical ~elorandu., Revision 13
ng COllpany
Gonzales, ~.. U.S.
EPA
U.S. EFA
Davis. R.C., Butzel
. long
Letter re: Hi-"ill's Good Faith Participatio-
n to the Dispute Resolution re: Vertical
Profiling
Site Analysis
U.S. EPA's Resolution OT the Dispute re:
Vertical Sa.pling
Hi-IHll lIanufacturi- Ecological.Inventory/Assesslent Work Plan,
19 Co.pany Revision 11(!ncludes !lodifications), Final
Johnson, (., U.S.
EPA
Wolta, K., Seraghty
. "iller, Inc.
U.S. EPA
Wolta, K., Geraghty
. !liller, Inc.
Hydrogeologic Investigation Work
Flan/Sa.pling Plan/QAPP, Phase II, Revision
14 (Includes "odifications), Final
U.S. EPA's Co..ents and Approval of the Phase
II Hydrogeologic Investigation Wort
PI~n/Sa.pling Plan/QHPP
P~elilinary Health Assesslent
Letter re: February 4, 1992 Discussion and
Issued Directives
!lateer, T., U.S. E~A Hi-llill !lanufacturi- Request for Infor.ation Letter (Unsigned)
ng Co.pany
SEe Donohue/Life
5ystels, Inc.
U.S. EPA
Final Baseline Risk Assess.ent/E~viron.ental
Evaluation
5
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-------
u.s. EPA ADMINISTRATIVE RECORD
HI-MILL MANUFACTURING SITE
HIGHLAND, MICHIGAN ,f~
UPDATE 4U
12/07/93
G
DO,Ct DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
--------- .----------------
---- ---- ------ --------- ----------------- -----
04/22/91 Clay, D., U.S. EPA U.S. EPA Guidance: .Role of the Baseline Risk 10
Assesslent in Superfund Reledy Selection
Decisions,. OSMER Directive '9355.0-30
2 08/19/93 Patterson, L., leveque, l., U.S. letter re: Public COllent on the Proposed 2
Oak1an~ County EPA Plan
3 08/19/93 Donovan, S., Notary U.S. EPA Public Notice Announcing the Proposed Plan 1
Public and COllent Period (Affidavit 01 Publication}
4 08/23/93 Po.ers, D., Oakland Leveque, L., U.S. Letter re: Public COllent on the Proposed 2
County Board of EPA Plan
COllissioners
5 08/25/93 Brian, W., Charter U.S. EPA Resolution re: Public COllent on the Proposed 1
To.nship of Highland Phn
6 08/26/93 .~e!~inger, B. and. Leveque, L., U.S. Letter re: Public COIItnt on the Proposed 1
Zeelinger, R.' EPA Plan
7 08/26/93 Shockey, 6. Leveque, L., U.S. Letter re: Public COllent on the Proposed 1
EPA Plan
8 08/26/93 lIasson, S. ,nd Leveque, L., U.S. Letter re: Public COIlent on the Proposed 1
W,sson, D. EPA Plan
9. 08/26/93 Pa.loski, it. ~eveque, L., U.S. .Letter re: Public COIIent on the Proposed 1
EPA Plan
10 08/31/93 Honiglill, D., Leveque, L., U.S. letter re: Public CoIItnt on the Proposed . 1
I!ichigill Stite EPA Plan
Senate
11 09/00/93.. Hi-ftill Klnuflcturi- U.5. EPA Letter re: Public COlllnt on the Proposed ..
I.
. ng EaploJIII Plan
12 09/00/93 Lendl. ling, .., Leveque, L., U.5. Letter re: Public COlllnt on the Proposed 1
Friends of Ros. EPA Pl,n
To.nship
13 09/01/93 Colasanti, R., leveque, L., U.S. Letter re: Public COIItRt on the Proposed 1
Colasanti's Farl EPA Phn
"arket
14 09/03/93 levin, C., United .leveque, L., U.S. letter re: Public CoIIent on the Proposed 1
States Senate EPA Plan
-------
DOCI DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
---- ------ -------- -----------------
---- -------- --------- -----
15 09/07193 Kranz, "., Notary U.S. EPA Transcript 01 the August 23, 1993 Public 51
Public "eeting reI the Proposed Plan
(j
16 09/09/93 lane, 8., Ollga leveque, L., U.S. Letter reI Public COllent on the Proposed 2
. Environ.ental . EPA Plan
Services
17 09/14/93 "iddleton, T., Leveque, L., U.S. Letter reI Public CO.lent on the Proposed
"ichigan House of EPA Plan
Representati ves
18 09115/93 Knollenberg, J., Leveque, L., U.S. Letter reI Public CO.lent on the Proposed
U.S. House 01 . EPA Plan
Representa ti yes
19 09/17/93 Ho.ard, A., ftDNR Leveque, L., U.S. . "DNR' s COI.en t on the Proposed P lin 3
EPA
20 09/28/93 Ada.kus, V., U.S. U.S. EPA Record 01 Decision 46
EPA
2
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