united states
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA.ROD.R05-85 022
September 1985
Superfund
Record of Decision
Northernaire, Ml
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TECHNICAL REPORT DATA
(Please read Instructions on the'reverse before completing)
1. REf'ORT NO. 12. 3. RECIPIEN'''S ACCESSION NO,
EPA/ROD/R05-85/022
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 11, 1985
Northernaire, MI 6. PERFORMING ORGANIZATION COOE
-
7. AUTHORCS) 8. PERFORMING ORGANIZATION REPORT NO,
e. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency
401 M Street, S.W. 11. CONTRACT/GRANT NO.
Washington, D.C. 20460
12. SPONSORING AGENCV NAME AND ADDRESS 13. TVPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCV CODE
800/00
15. SUPPLEMENTARV NOTES
16. ABSTRACT
Northernaire Plating is the site of a former electroplating facility located at
1002 Sixth Street in Cadillac, wexford County, Michigan. Electroplating operations
were conducted at the 12.75 acre site from 1971 to 1981. Waste contaminants from electro
plating commonly include copper, nickel, chromium, zinc, lead, tin and cadmium, as well
as metal complexing agents. In 1978, two domestic wells were found to be contaminated
with hexavalent chromium. In addition, process waste waters containing cadmium and
chromium were discharged into the municipal sewer system. A private sewer line per-
mitted exfiltration of these waste waters through poorly sealed joints. A drywell in
the sewer line at the facility allowed plant effluent to be discharged directly to the
highly permeable unsaturated soil.
This ROD is a source control remedial action ,that includes: excavation of soils
and sewer line sediments to meet response objectives of 50 mg/kg chromium and 10 mg/kg
cadmium, and disposal offsite at a RCRA facility; cleaning the floor of the facility
of dust and residue; breaking-up a 30ft. X 10ft. area of the concrete floor and the
drywell in the building, sampling the soil for cadmium and chromium, and excavation and
disposal offsite at a ~CRA facility, if necessary: and backfilling with uncontaminated
soil. Any additional remedial actions will be addressed in a separate Record of De-
cision upon completion of the RI/FS. Total capital cost for the selected remedial
action is estimated to be $75,000.
17. KEV WORDS AND DOCUMENT ANALVSIS
a. DESCRIPTORS ., b.IDENTIFIERS/OPEN ENDED TERMS C. COSA T I 1-i~IJ Gr'."':'
_. _.
Record of Decision
Northernaire, MI
Contaminated Media: gw,soil,sewer sediments
Key contaminants: Hexavalent chromium,
cadmium, chromium
I
I
1B. DISTRIBUTION STATEMENT 19, SECURITY CLASS iTlII'S Rep
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INSTRUCTIONS
,.
REPORT NUMBER
Insert rhe J::PA reporr number as it appears on the cover of Ihe publil:alion.
2.
3.
LEAVE BLANK
RECIPIENTS ACCESSION NUMBER
Reserved for use by ~adl report redpienl.
" I. 1,..::-...1..'.: '
4.
TITLE AND SUBTITLE
Title should indicate dearly and briefly Ihe subje,.t l:ov.:ra~1: uf Iho: ro:porl. and b.: .li,phly,'.lI'r,uni,,,,nlly. S,'I suhtitk. ifu~,',1. 111 ~mali,'r
type or otherwise subordinate it to main title. Wh.:n a rcpOrl is pro:pared in muro: than '''I'' vLllum.:. r"I"',,1 Iho: .'rilll;IIY lillo:. ",1.1 v.,I:.Im,'
number and include sublitle fer the specific title.
. : ~ 1 ~,' 1 .'
5.
REPORT DATE
Each report shaD carry a date indicating at leasl monlh and yo:ar. Indil:al': tho: h.ISis un whkh if "'''' ""'1':\"1".1 (q:.. "al"'()lix.~i,c', .laIc; III
appro~al. Mlt 01 prtfHlrtllion, tIC.).
PERFORMING ORGANIZATION CODE
Leave blank.
8.
7.
AUTHORISI
Give name(s) in ,'»nvcnlional order (Joim R. DoC'. J. Robl'rt Doc'. 1'1<'.). List aUlhur's affiliallun if it ,liff,'r, frllm Ih,' l'o:rfLIIlllint: .."t:ani.
zation.
8.
PERFORMING ORGANIZATION REPORT NUMBER
Insert if performing organization wishes to assign Ihis numbcr.
9.
PERFORMING ORGANIZATION NAME AND ADDRESS
Give name, street, city, state, and ZIP code, Lisl no more Ihan two levels of an urt:anil.aliunal hir.:ardlY.
10. PROGRAM ELEMENT NUMBER
Use the program clement number under whil:h the reporl was pro:pared. Subur.linalo: nUIllb\'r, lII"r be indl""''' III p;I,,'n'.'l':!"'s..
.
11. CONTRACT/GRANT NUMBER
Insert contract or grant number under whkh report was prcparo:d.
12. SPONSORING AGENCY NAME AND ADDRESS
Indude ZIP code.
13. TYPE OF REPORT AND PERIOD COVERED
Indicate interim final, etr.. and if appli.:able, dales covered.
.' . f
:.,...l ., -
14. SPONSORING AG~NCYCODE
Insert appropriate code.
15. SUPPLEMENTARY NOTES
Enter information not included elsewhere but useful. such as:
To be published in, Supersedes, Supplements, etc.
'. :. . . ;
Prepared in .uopo:raliuo wllh. 1'"..,,101111111. III'. 1''''''11.1,',1 "I "\'11."'1\'11"" ....
, ). .:; : I..'.' '1 .:
18. ABSTRACT
. Include a brief (200 words or ftSSI factual summary of Ihe mo,r siJ!!nlfil:anl Infurmalilln ,'untaln"" III III,' 1\'1''''1. It II.." ;"il"~1 'liiil;lIit~ 01': .
significanl bibliography or literature survey. menrion illll~rc. J. ).1':;. ."
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS. Selcct from Ihe Thcsauru, uf 1'.ngInccrir.t' Jnd S,'iO:lltlli,' I ~rlll' th~ prup" auth..rl"'.J 1"1111' IhallLlo:nllfy Ihe maJllr
concepl of the research and are suffi.lenlly ,pc.:lfil: anLi pre.i.o: to bc u.~d a' Ind" o:nlric, I'm 'alalll~ln~,
(b) IDENTlI'IERS A"iD Opr".I:.NDED TlR~S . l'se Identifiers for proJcct nal11", .u.l.: nam." "4u1prm'nl .J"'I~natut'.III'" 1J,,' "I'cn- ..
ended terms I!illllen In do:scnpror form for tho\e subjecls for which no .I~,.-rlptur o:\ists, . '.' .'.: ': f "
(c; COSA TlIILLD GROl'P. held and j!roup h~ignmcnls .lre to be laken from th.: 11165 ('OS"'II Suhl,'~1 Calq!CIIY tist. Sinl:~' Ihe ma.
jority of documcnt; are multidis~iphnar) in nature. the Prim;!ry I ield/Croup a"ignm~1I1I ,j I/o III IJ~ ,p,', 111" ..II" Il'hnc, a"'a III' hUlllan
endeavor. or I)'pc of ph)'si.:al object. Th... appheatlonts) will be .ru)).r"'o:rcn,:~'d wl1h 'CL'IIndar)' 111'1.1.'( ;roul' a"I~"""'III' Ihal "1111..11..\\
the primary posling! 5).
18. DISTRIBUTION STATEMENT
Denole relcasabiht) to Ihe publ... IIr lII>nlalion for reaSon) olh.:r Ihan "..UIII) fur e\al11l'le "I{.kaw "11111'""'11." ( II~' an~ a~..il"llIh') '"
the publk. wllh addres) and pnCe.
19. II 20. SECURITY CLASSIFICATION
DO NOT submil classifio:d ro:porls to Ihe ~Jllonal T o:.hnt.allnformallon "(\'IIe.
21. NUMBER OF PAGES
Insert the tutal number uf paJ!!"'s. tnd"Jtn~ !h" 11m' Jnd unnumbered pJg~'. hut o:\duLl~ LI"trlbuliun 1t,1. II an)'.
22. PRICE
Insert the prke set by Iho: S;aliunal r~.hnl,..i If't"rrnall'..n S,rllll' ur t!;, C;"\,,rnm,,"t I'rtnllng Otfi",. II k"."ln.
E PA Fo,m 2220-1 IRn. 4-77) (Rue,se>
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C> .
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Northernaire Plating Company, Wexford County, Cadillac,
Michigan
Documents Reviewed
SITE:
I reviewed the following documents describing the analysis of cost-effective-
ness of rp.media1 alternatives for the Northcrnaire site:
- Focused Feasibility Study, Northernaire Plating, Cadillac, Michigan,
Michigan Department of Natural Resources, July 1985
- Public comments and recommendations
- Responsiveness summary.
".
Description of Selected Remedy
o Excavate soils and sewer line sediments contaminated with cadmium and
chromium to response objectives of 50 mg/kg chromium and 10 mg/kg
cadmium, and transport them to a privately owned off-site RCRA subtitle
C disposal facility.
o Clean the floor of the building of dust and residue which may contain
hazardous substances.
o Break-up a 30 ft. x 10 ft. area of the concrete floor and the drywell
in the building, sample the soil and if contaminated, excavate with a
backhoe and dispose of as above.
o Backfill the excavated areas with uncontaminated soil.
o Cost of the proposed alternative is approximately $75,000.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA). and the National Contingency Plan (40 CFR
Part 300). I have determined that the excavation and off-site disposal of
contaminated soils and sewer line sediments around and under the building
is a cost-effective remedy necessary to prevent or minimize the release of
hazardous substances so they do not migrate or cause harm to public health.
welfare and the environment. The State of Michigan has been consulted and
agrees with the approved remedy.
I have also determined that the action being taken is consistent with re-
medial goals at the site, and ;s appropriate when balanced against the
availability of monies for use at other sites. In addition, the off-
site transport is more cost-effective than other remedial actions. The
State is continuing its Remedial Investi9ation/Fea$ibi1ity .Study to
determine the extent of groundwater contamination and the hydraulic
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characteristics of the aquifers in order to eval~ate potential remedial
actions. If additional re;ned1Jl actions are determined to be necess3;Y.
a Recsord of Q'cls~n will be prepared for appr~~; .~ ~~e future action
Date ef II ., I ~ ~ ~ Vdh, 1/.
'.
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, .
Summary of Remedial Alternative Selection
Northernaire Plating Company
Cadillac, Michigan
Site Location and Description
Northernaire Plating is a former electroplating facility located at 1002
Sixth Street in Cadillac, Wexford County, Michigan (see Figure 1).
Operations were conducted in a 5000 sq. ft. building located on 12.75
acres.
.,.
Soils in the area are glacio-lacustrine in origin and have alternating
layers of highly permeable sands and gravels, and less permeable layers
of clayey and silty lacustrine deposits. T~ere are three aquifers.
The stratigraphy consists of three sand layers separated by two clay
layers. Little is known about the deep aquifer (300 ft.) where the
municipal well field located 1500 feet N.E, draws its water. The
intermediate aquifer flows in a northwest direction while the shallow
aquifer flows toward the northeast. The two upper aquifers merge north
of the site.
The site is located in an area of both industrial and residential properties
and is relatively flat with a relief of three feet across the 12.75 acres.
The population of Cadillac, Michigan, is approximately 10,000. This
population has a potential to be impacted by the site because t~ey are
served by area groundwater. The municipal we11field lies to the northeast
of the site and North Park subdivision lies directly to the north. This
subdivision draws its water from private wells. The wells are uncontaminated
at this time.
Site History
'In 1978 two domestic wells, two blocks from the Northernaire facility, were
found to contain hexavalent chromium in their water supply. This discov~ry
eventually led to the placement of the facility on the National Priorities
List (NPL) on July 23, 1982. The facility was in operation from 1971 to
1981. The property is owned by R.W. Meyer, Inc., and the facility was
owned and operated by Northernaire Plating Company, Inc., and Willard
Garwood. The assets were sold to Top Locker, Inc., in June, 1981.
Electroplating operations conducted at Northernaire included flash chrome,
hard chrome, bri~ht nickel, bright chrome, su1fo~ate nickel, black oxide,
e1ectroless nickel, and rack and barrel zinc. Waste contaminates from
such operations commonly include copper, nickel, chromium, zinc, lead, tin
and cadmium as well as metal complexing agents.
Process waste waters containing cadmium and chromium were discharged to
the r.!uni ci pa 1 c;ew~r systeln from 1971 to 1978. A private sewer 1 i ne per-
~itted exfiltration of these wastes waters through poorly sealed joi,ts.
A drywell in the sewer line at the facility allowed plant effluent to be
discharged directly to the highly permeable unsaturated soil. A floor
/
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I
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I Point
CHERRY GROVE
~~: . MITCHELL
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(
.::- - ~~:: :- J.:. .-==t ' i~d,~"< - r
'. 0- " -" "-\-'/ '. -. L\
2 - -:.. - _c ... 0 v- '- I
~.: "~<. ,- -;~~~:....~ ~~ -0' - I
Z"'-" -. -~ ~-=- ::1' -;j
-.co. . ".>=;, "" i.:'. '.4i' ;..::~ ;!t\
~-. -'1- r." II "fI:-=- :~.. 1 ...' :~~
DRAFT
~. .0..-
. .
L
12000
I 4000
FEET
,
~
"'fCM1GAN..t i
\ '"
. j
~,
Qu.oo-."G..E ..:COT:O"
FIGURE 1
SITE LOCATION MAP
NORTHERNAIRE PLATING CO.
CADILLAC. MICHIGAN
E.CJORDANCO
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, ,
-j-
/
drain, inside the building, is connected to a second dry well which allowed
direct discharge to the soil. Air quality control e~uipment. located on
the pad toward the northern end of the building, is connected to ductwork
from the chrome plating area inside the building. This ductwork is highly
corroded and stains o~ the pad and soil samples adjacent to the pad suggest
this was a pathway for environmental contamination along with the sewer
line and drywells at the Northernaire facility.
On July 5, 1983, the EPA initiated a removal action which lasted until
August 3, 1983. During that time, 3450 gallons of acids, 5402 gallons of
cyanide wastes, 160 drums of cyanide wastes and 5000 gallons of waste
hYPochlorite (used to decontaminate for cyanide during the cleanup) were
removed from the site. One hundred twenty feet of the private sewer line
were also removed and the building was steam cleaned. This action was
initiated as a result of the contaminated material entering the groundwater
and infiltrating two private wells near the site.
Current Site Status
'"
In 1978, hexavalent chromium in the groundwater, believed to have originated
at the Northernaire site, was detected by the Health Department District
No.1, in water supply wells of two homes near the site. The concentrations
were 2.8 and 3.8 mg/l (ppm) which were significantly higher than the drinking
water standard of 0.05 mg/l (ppm). The city of Cadillac extended city water
service to these homes. During this investigation, hexavalent chromium was
detected in the groundwater at a concentration of 0.93 mg/l (ppm) at a
depth of 150 ft. Phase II of the Remedial Investigation (RI) report,
published by E.C. Jordan Co., in May 1985 shows this contamination is about
1400 ft. north of the site. Additional investigation is necessary to deter-
mine the boundaries and implications of this plume.
The portions of the RI which address soil contamination include:
o sampling of surficial and near surficial soil
o sampling of sediments in manholes of sewers
o soil sampling from deep b1rings in the unsaturated zone.
Surface samples were take~ from the upper 6 inches of soil; shallow-samples
were taken from depths of less than 5 feet; intermediate samples were
collected between 5 and 15 feet; and deep samples were taken at depths greater
than 15 feet. .
The results of these samples showed surface and subsurface soil contamina-
tion is concentrated around the Duildin~ and in sewerline sediments along
the sewerline and in the area of t~e drywell.
Uf the 70 soil samples submitt~d fJr analysis 19 exhibited concentrations
above the selected screening levels for cadmuim and chromiu~. The screening
level for cadmium is 10 ~g/kg (drj weight), the federal limitation for
cadmium 1n land disposal of wastewater sludge. The screening level for
chromium is 50 mg/kg (dry weight) the conservative end of the suggested
range for land application of sludges contai.ling chromuim according
to Michigan guidelinas (See Table 1).
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Alia I Y ~ i!! ..
Total
I:...bo i 1181
III:/"g
(!'pm)
Total
1:1".1110 i "II
111:/"1:
(I'I'tII)
~I!~ !Y.~ ~ ~
"olal
Cillb. i UII
ag/"g
( ""18)
Tolal
Ch 1"1" i ...
IIg/"g
(1'1'01)
'l'AIII.~: I
Stili. SAtll'U: ANAI.Y'I'ICAI, IU:SIII:rS Al!oVE TilE St:KEENI NI;
I:K ITEICI A ANII AI'I'I.I CAli...: S'I'ANIJAIUlS
1...(.~l.i(I!I..1 ~il~ll!!t'~
S..r"an: S.. i 1 s
'l'c:;l I'i I:;
.- . n ... .. -- ~1' U L~l'~~_--.- .----
-,--,. Se,!~!~ed !-~_._----
.. ---. -- - -- .- --~
Saaille Total ~:.I'. S"lIllle Tolal ~:.\'. SOIaI'll' 'folal ILl'. Sa."le 'folal E.I'.
..!>'.!~ i&~...l}O"- ..__.~It:~d 1 ~ -- .. '!',-!j( ~~A1 - ~':::' i 1>"..1 ~ ",!, .. ~!:t..! ~ -- T'-!x.~~. ~ ~1- .o1O~_!a;lIaq,!.I!- -- t!el~ I~. -- !'!~!~!!I..- Des~K!!!!~!!.~_a IS__:!~~~!!I
-. .- . ._- - ._-
SS-OOI 10 *110/100 Mil 1~80 3600
S:;-002 10 140 "II-A 1930 3400
SS-OOI} 10 S 27~O 8400
SS-iJOJ 460 14110
S8-001 I~ <10/<10 ~-3 SJ 26 ~Wr-I-5 29 <10
SS-002 16 <10 ~-3A 37 13 81'1'-2-1 91 61
5S-003 Ibl <10 ~H~ II 47 SI''I'-2-10 'l7 28
SS-004 t:I <10 HH 2030 94
SS-005 J:I <10 ""-A 3210 <10
SS-008 ;n S 2190 224
SS - OU" 4'JIJ 1'110-3 14 210
SS-Ol:l II <10 PIIU-]5 2190 4:1160
8S-0 17 \U <10
SS-018 ]11 ~1
8S-11185 35 <10
8S-022 25 < 10
~'1' I i c~_I_,::!!~..!!,!~~~~~
Clean Waler Ad, Clean Water Act, Midaigdll MUllicipal
Waler Qual ity Crileria Waler Qual ily Criteria Sludgt" Mallageaeent
Safe lJrillking for Ihudall lIeallh, ~'ish IlIr 11111110111 lIealth a 1111 "rograa
.. . ----_._-~~~t.:~. !'~! -- -- .~!'~Jl1:il~~~I!IL\4~~_r__--__!l!.i~l~iU&._~~~.!..!!~~!L_- ___.!!ay-,- 1J8?__._-
Non- Slightly
Reslri~led Limited
0.01 .g/l
10 ~g/I
12 ~g/l
5 IIg/kg
~-2~ ag/kg
0.05 ag/I
50 \1&/1
50 ~g/l
50 lag/kg
~O-IOOO ..g/kg
Federal Limitation
Land Disposal of
Wastewater _Sl~~9.~-
10 mg/kg
.- .. ---.- -----.---------- -.-.-..- .--..-- .--..-... ~--_. - ._-.. -- ---.----------.. --.-.----------.---- --.----------.-- -------------
Nult's: J) -:. 110/100: Sa"llle value/,IIII,licitIC value.
2) 'J'ht~ sigllific;tllt:e nilc~ri" ulied was; 10 ..g/"g loli
4.K~,.;n
n,,,,I. n n
'ua or- tolal catll1lillll.
8\0 1\ CT
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Five of these samples showed concentrations of cadmium and chromium to
exceed the Extraction Procedure (EP) toxicity test. This is one test which
determines if a solid waste is considered a hazardous waste under the
Resource Conservation and Recovery Act (RCRA) (values greater than 1.0 mg/1
cadmium or 5.0 mg/1 chromium in the test extract under RCRA regulations
(40 CFR Part 261.24)). (See Figures 2 and 3 for soil sample locations and
Table 1 for a summary of soil sample results and applicable standards).
The elevated values of contamination occur primarily along the west side
of the building where the pad is located and in the vicinity of the former
drywell in the sewer line immediately to the north of the building.
Leachate concentrations from the EP toxicity test for cadmium range from
1.4 mg/1 to 8.4 mg/1. The leachate concentrations for chromium were
detected up to 43.76 mg/1.
In order to estimate the concentrations of chromium and cadmium that may
be left in the soil, a vertical and horizonta.1 spread (VMS) model was used.
The model uses the leaching potential of the metals as an indication of
their mobility through the soil as they enter the groundwater and predicts
their concentrations at the point of initial impact and at specific dis-
tances downgradient. The model has been used by EPA in evaluating the
possible impacts of wastes for land disposal [40 CFR Part 261 as explained
1n 50 Fed. Reg. 7882 (Feb. 26, 1985)]. The model incorporates several worst
case assumptions such as saturated soil conditions providing zero attenuation
and no precipitation for metals, continuous toxicant input to an underlying
aquifer at the maximum extract level, and a receptor well precisely in line
with the source and direction of groundwater flow. Using the response
objectives of 50 mg/kg chromium regaining in the soil, the model predicts
that the concentration of chromium in the groundwater 10 meters away from
the facility would be .02 mg/1 (primary drinking water standard is .05
mg/1). For cadmium, the model predicts a concentration of .01 mg/1 at a 10
meter distance with residual soil concentrations of 10 mg/kg. The primary
drinking water standard for cadmium is .01 mg/1.
Applying the model to the site, when the EP toxicity test concentrations
were used in relationship with existing concentrations of metals in the
soil, an estimated chromium concentration of .14 mg/1 resulted at a distance
of 10 meters (three times the standard). Similarly, cadmium remaining in
the soil predicted a concentration of 0.25 mg/1 at a distance of 10 meters
(twenty-five times the standard). These results support the need to undertake
a source control remedial action and similarly support the choice of the
response objectives. Although this model predicted groundwater contamination
based on no remediation it should be noted that no contaminants were found
at these levels in the groundwater at .this site. These model values represent
the worst case contamination of the groundwater under a No Action alternative.
Toxicity of Contaminants
Hexavalent chromium is manmade and toxic. It is used in various industrial
processes such as plating parts. Evidence has shown that large doses can
cause toxic reactions through ingestion and inhalation. Hexavalent chro.nv.ni
has been observed to cause lung cancer and a variety of respiratory compli-
cations in humans after it has been inhaled.
Cadmium is also used in the electroplating process. Long term effects of low
levels of cadmium can result in a total or partial loss of smell, couching,
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APPIIO.WAY! .CAll
r:--\....J:'I40 'UT
DRAFT
.A.I MAP PROVIDED ." KICII. CON8ULT'" UIIYICI8.IIIC."AMUAII". ....
6
6
6
o
IIOTI8:
I. CDNCIIITRATIOII8 AM .,. TOTAL Ct8Io.N. 88Iq""
I. MA."'" CONCIIITRATIO.. AT A lOCATION MGAIIOL." 01'
DIPTH. CONCENTRATION WITH DEPTH A T"PlCAllY HCIIIA.'"
'UNCTION. EITIMATED DEPTHI 0' COMCENUIATION IIANOEI .AIED
. ON DATA ARE:
100- ....
10-100 ..
0- I 'OOT
TO I PEn DEIP
10-10 -
1-10 -
TO 10 'EET HIP
TO la 'EET DEEP
I-a-
TO U fEET DEEP
llOEND
-I - CONCENTRATION CONTOUR 'OR CHIIO""U IN I'll-
6
'@
IUAfICIAl lOll IAMPLE lOCATIONS
'PUT "'OON IAUPlE lOCATIONS
f'ON:~ RECOMMENDED AREAS fOR EXCAVATION
NO' TO fIVE FEET AND DISPOSAL
FIGURE 2
IfTERPRETlYE CONTOURS OF CHROMIUM CONCBf'fRATIONSIN lOlLS
NORTHERNAIAE PLATINO CO.
CADILLAC. MICHIGAN
EC.oIDANCO-
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t. OOIlCIIITIIATIOIII AIIII Of' CADII.... .. ""1 ......
.0 IIAX'*III COIICIIITIIATIOIII AT A LOCATIOII I1I8AIIOL." Of' DEPTH.
COIICEIITIIATION WITH DE'TH A T,,"CALlY DECIIEAIINO 'UNCTION.
E8T1MATED DE,THS. FOIl CONCENTRATI01IIIANOE8 IAeED 011
.VALUATIOII OF DATA AilE:
---I
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t::. 6 6 --6 6 6 l\
@ 6
(j) 6
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6
IURFICIAL 10L IAMI'\.E LOCATIONS
6
I'LIT 8'0011 IAM'LE LOCATIONS
cD
~!~
~~
RECOMMENDED AREA FOA EXCAYATION TO TWO FEET AND DIS'OSAL
~
A'",OXIIiATE ICALE
~40FEET
FIGURE 3
..TEAPAETIVE CONTOURS OF CADMIUM CONCENTRATION. IN 8OL.
NOATHERNAIRE PLATING Co.
CADilLAC. MICHIGAN
E.CJaIDANCO-
DRAFT
8AI. IIA' ",OYIDID 8" !tICI! C0II8UU..G IIII.ICI.."'C~"AIIUAII". t881
-------
difficulty in breathing. loss of weight. yellowing of teeth. caries, gene-
ralized irritability. gastrointestinal upset, low level of blood he1noglobin
and proteinuria. Evidence has shown that large doses can cause toxic reac-
tions through ingestion and inhalation. Cadmium is a suspected carcinogen.
Threat to Public Health
Based on the above information, it is estimated that 230 cubic yards of
soil and 10 cubic yards of sewer line sediment are contaminated. An addi-
tional 15 cubic yards under the building may also be contaminated. (See
figure 4).
The potential receptors for the contaminants in the soil at the site are
local residents and animals and any living organism who might ingest the
contaminants in the soil. Toxic metals can be concentrated by biological
activity to lethal concentrations as they are passed up the food chain.
As such, the release of contaminants in the soils at the site, and the
threat of future releases, warrants this source control measure.
-
Enforcement
The U.S. EPA filed a CERCLA Section 107 cost recovery action against three
potentially responsible parties (PRPs), R.W. Meyer, Inc., Northernaire
Plating Company and Willard S. Garwood. to recover funds expended as a
result of the Immediate Removal Action. That action is currently pending.
Additional cost-re~overy action may be expected as future remedial work is
completed at the site. These PRPs were contacted regarding this operable
unit, and did not respond within the time limitations of the notice letter.
Alternative Evaluation
A Focused Feasibility Study (FFS) of proposed source control measures for
the Nort~ernaire site was completed by E. C. Jordon Company and submitted
for public review and comment on July 22, 1985. This project is a State
lead, being conducted through a cooperative agreement with the State of
,Michigan Department of Natural Resources. The following objectives were
developed as a result of the study.
o Prevent or minimize the source of groundwater contamination.
o Prevent or minimize direct contact hazards associated with
s~rface and subsurface soil and sewer line sediments.
o Select a final disposition for the building which is compat-
ible with the selection of the site remedy.
o Prevent future use of the floor drain and sewer line.
The FFS developed fifteen alternatives based on these objectives. Eleven,'
relate to soil and four relate to the ~uilding (See Table 2). Thase alter-
natives and objectives were developed in accordance with the National
Co~tingency Plan (NCP).
After the initial screening, five alternatives relating to soil and four
relating to the building were judged to meet the objectives of source
control and were assessed based 00 the following parameters:
-------
(
FOCUSED FEASIBILITY STUDY REPORT PROBLEMS DISCUSSED
230 CU YOS
FLOOR DRAIN JII
SEALED OFF
FLOOR DRAIN
o TO 8E
EXCAVATED
BLDG.
DUST RESIDUE
POSSIBLE
SOil CONTAMINATION
UNDER BLDG.
MANHOLE
o
SEWER LINE
!)
10 CU YOS
MANHOLE
o
SEWER LINE
MAMHOLE
o
Figure 4
-------
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-------
o .
-11-
1) level of protection; 2) reliability; 3) implementation; 4) cost;
5) constructability; 6) volume reduction; and 7) adverse environmental
impacts.
Table 3 su~narizes these alternatives.
TABLE 3
Contaminated Area
Remedial Action Alternative
Soil and Sewer line
Sediments
o No action
o Site capping
o On-site Subtitle C facility
o Oft-site disposal
o Solidification/fixation
Building
o No action
o Complete removal
o Limited Modification
o Containment
~
Soil and Sewer line Sediment
Alternative 1 - No Action
A No Action Alternative of fencing and posting signs would afford marginal
protection for direct contact but would not meet RCRA guidance. If this
alternative is selected. there will be no protection to public health and
the environment. In addition. danger exists of microorganisms or small
animals bioaccumulating the contaminants and introducing them into the f~od
cha(n. Site fencing and posting of signs are routinely implemented at
hazardous waste sites and the reliability is mOderately high. Installing a
fence around the entire site and posting signs will take about three to
four weeks.
Cost for Alternative 1 - No Action
Capital Costs
O&M
Present Worth
$64.000
N/A
64.000
Alternative 2 - Site Capping
Alternative 2 calls for a RCRA closure capping system to be placed over
approximately 920 sq. ft. of contaminated material on site. ihe site wo~ld
be revegetated. sloped and graded to promote and control surface runoff.
Technical compliance with RCRA would be met.
The technology for implementing RCRA caps is a co~non technical practice.
long term reliability of a closure cap is determined by the effectiveness
of the maintenance program. It is subject to loss of integrity due to
weathering. breaching by vegetation or deterioration through neglect. The
threat to groundwater would not be eliminated because of lateral migration.
The site lies on permeable sands and gravels which are not conducive to
capping. In addition. capping will cost approximately five or six times
more than some of the other alternatives. A RCRA cap may be constructed in
about 2 months.
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. r
-~~-
Cost for Alternative 2 - Site Capping
Capital Costs
Annual O&M
2-year Present Worth
30-year Present Worth
$129,000
19,700
163,199
314,712
~
Alternative 3 - On-Site RCRA Subtitle C Disposal Facility
Disposal of contaminants in an on-site land disposal facility complying
with applicable RCRA Subtitle C requirements is the most comprehensive of
the containment options. The facility would remove the hazardous material
from the environment at the site giving a very high level of protection to
people and animals, provided failure of the cap or liners does not occur.
Long term groundwater monitoring and inspection of leak detection systems
would be part of the operation and maintenance program. The fact that the
site lies on permeable sands and gravels must be considered when evaluating
this alternative. The cost is five or six times greater than some of the
other alternatives. Technology for RCRA landfills is commonly used by
contractors familiar with hazardous waste site cleanups and can be imple-
mented in approximately 2 months. Technical compliance with RCRA would be
met.
Cost for Alternative 3 - On-Site RCRA Subtitle C Disposal Facility
Capital Costs
Annual O&M
2-year Present Worth
30-year Present Worth
Alternative 4 - Off-site Disposal
$139,000
19,700
173,199
324,712
Off-site disposal would involve excavating contaminated soil and transport-
ing it to a privately owned off-site RCRA Subtitle C facility. This option
would eliminate the possibility of future environmental degradation from this
source at this site which makes it highly reliable. Two facilities have been
identified which are permitted to receive inorganic metal wastes. The first
is Wayne Disposal, Inc., # 2 Landfill, Belleville, Michigan, 200 miles from
the site. The other is Fondessy Enterprises, Inc., Oregon, Ohio, 230 miles
froln the site. Both facilities were found by the State regulatory agencies
to have no Class I RCRA violations and were inspected within the past six
months. This kind of work is commonly done and easily implemented. There
are no adverse impacts connected with this alternative; however, a possible
hazard would exist in the event of an accident during transportation.
Capital Costs
O&M
Present Worth
$53,000
N/A
53,000
Alternative 5 - Solidification/Fixation
Solidification/fixation will transform hazardous materidl into a non-leach-
able form or create a material which is easier to handle. The process
consists of soil excavation, mixing and curing to form the new material,
and placement and/or disposal. These processes are appropriate for hazardous
materials containing metals. Pilot tests must be performed in the field to
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. .
-13-
determine mix proportions. The technology is considered reliable provided
a site-specific mix design and quality control ~rogram is developed and
properly implemented. Treated materials will undergo RCRA hazardous wastes
testing to determine if the materials have been rendered non-hazardous.
If not and the material must be removed to a RCRA Subtitle C landfill,
additional costs will be incurred which are not included in the cost summary.
Capital Costs
O&M
Present Worth
$79,000
N/A
79,000
Building
Alternative 1 - No Action
'.
The No Action alternative for the building involves securing the building,
fencing and posting. This alternative provides a lower level of protection
than some of the other alternatives. Vandalism and forced entry is a
common problem of boarded-up buildings. In addition, there is no provision'
for securing the drywell and possibly contaminated soil beneath the building.
Some adverse impact may occur if metals leach out from this soil. The
technology is simple and may be implemented in one to two weeks.
Costs for Alternative - 1 No Action
Capital Costs
O&M
Present Worth
$6,000
N/A
6,000
Alternative 2 - Complete Removal of the Building
Complete removal of the building provides for demolition of the building
and disposal of demolition debris. This alternative allows the breaking up
of the floor and access to any contamination in the unsaturated zone that
may have seeped from the floor drain drywell, but does not allow for manage-
ment of this soil. If high concentrations of contaminants were found upon
testing the soil, excavation to an off-site Subtitle C facility or capping
would be appropriate. The technology is proven and reliable. The costs
are divided into two tables, on-site disposal and off-site disposal. Soil
disposal under the building was not costed out because the handling of this
material will depend on the alternative chosen for soil and sewer line
sediment.
Costs for Alternative 2 - Complete Removal of the Building
On-s ite Disposal
Off-site Disposal
Capital costs
Annual O&M
2-Year Present
Worth
30-Year Present
Worth
$ 44,000
19,700
78,199
Capital costs
O&r~
Present Worth
$40,000
N/A
40,OOJ
229,712
If this alternative is combined with on-site d's~o$al for 50,1 and sewer
line sediment, O&M costs will be incurred only once.
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-14-
Alternative 3 ~ limited Modification
limited Modification allows the dust and residue on the floor to be vacuumed
and if hazardous disposed of as a hazardous waste. A 30 ft. x 10 ft. portion
of the concrete floor and the dry well will be broken-up to expose the
possibly contaminated soil beneath the building. It is estimated about
15 cubic yards of soil may be contaminated in that area. If so, the wastes
would be disposed of in a Subtitle C landfill. If the capping alternative
is chosen for the soil and sewer line sediment, the soil under the building
would be included.
~
Fifteen cubic yards of clean soil will be removed to reach the subsurface
contaminated soil under the building. This clean soil, along with clean
fill, will replace the excavated soil, and the floor will be covered with
gravel at the completion of the operable unit and replaced with concrete
at the time of the final remedy. This alternative is consistent with the
final remedy and protects public health and the environment. The techno-
logies required for this alternative are established and reliable.
Cost for alternative 3 - limited Modification
Capital costs
O&M
Present Worth
$21,250
N/A
21,250
Alternative 4 - Containment
Renovating the building to be used as a containment structure for the soil
and sewer sediment would involve constructing a vault inside the building
with cemented cinder or concrete blocks. The technology is available and
easily implemented.
An assessment would be needed for the possible contamination under the
building. If the containment system failed, the contaminants inside the
vault would remain a threat to public health and the environment. About
two months would be needed to meet response objectives. Applicable require-
ments of RCRA would be met.
Costs for Alternative 4 - Containment
Capital Costs
Annual O&M
2-year Present Worth
30-year Present Worth
$ 97,000
18,300
128.769
269,514
Summary
The No Action Alternative for 50il and sewer line sediment does not prevent
continued leaching of contaminants into the groundwater. It wo~ld ta~e 475
years for chromium and 325 years for cadmuim, before the concentrations in
the surficial soil would reach the response objectives of 10 mg/kg dry
weight of cadmium and 50 mg/kg dry weight of chromium through natural
flushing. therefore this alternative will not remove the danger to pUblic
health and the environment. For these reasons the No Action Alternative
was eliminated.
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. .
-15-
In evaluating alternatives for a site closure cap and on-site disposal,
a consideration must be given to the fact that the site is located on highly
permeable sand and graye1s which could significantly reduce effectiveness
and protection. The cost of a site closure cap and on-site disposal for
soil are five and six times greater than those for the remaining alternatives
with no additional level of protection. These alternatives were eliminated
on these bases.
~
Alternatives 4 and 5. Off-site disposal and Solidification/fixation for
soil are technically feasible and relatively close in cost. Both are
equally protective of public health and the environment if the solidifi-
cation/fixation process is successful. Excavation for off-site disposal
will take about two weeks. but actual disposal time will depend on the
receiving facility. The amount of material needed to be moved to an off-
site facility is small. so Jt will not sign~ficant1y impact the capacity of
that RCRA receiving facility. The time involved for solidification/fixation
cannot be determined until pilot testing is completed. In addition. the
long term effectiveness of this alternative has not been proven. It is not.
likely vendors will bid on a job for solidification/fixation for the small
amount of materials to be treated at Northernaire. They have indicated
transportation costs and costs for setting up equipment will not be cost
effective. If this alternative is selected. delisting procedures must
be followed.
The No Action Alternative for the building does not provide for securing
the dry well and possibly contaminated soil under the building. This
alternative provides a marginal level of protection compared to the other
alternatives and on that basis was eliminated. The Containment Alterna-
tive provides limited protection from the soil under the building leaching
into the groundwater. The cost of containment is an order of magnitude
higher than some of the other alternatives for the building. For these
reasons it was eliminated. The remaining alternatives provide adequate
protection and are more cost effective. The Complete Removal and Limited
Modification Alternatives provide comparable levels of protection at similar
costs. If the Complete Removal Alternative is selected and the floor is
left intact. contaminants would have a potential to reach the groundwater
and microorganisms may continue to bioaccumulate the toxins into the food
chain.
Community Relations
Copies of the FFS were made available to the pUblic on July 22. 1985. The
Cadillac Municipal Complex and the Cadillac Wexford Library served as
repositories for this document. The MDNR issued a press release in the
Cadillac Evening News on July 15 announcing the commencement of the three
week comment period and schedule for a public meeting.
The meeting was held on July 30, 1985, at the Municipal Building in Cadillac,
MI. Approximately 25 residents attended the meeting. Representatives of
the EPA. MONR, MO?H. E.C. Jordan Company and the local government were
present.
-------
Table 4
Summary of Alternative Analysis
Annual
Screeni ng level of Adverse Environ- Capital Operation Present
Parameters lteliability Protection mental Impacts Costs Maintenance Worth 30 yrs.
5011
No Action Not Rel iable Prevents di rect Impacts to G.W. $ 64.000 0 $ 64.000
contact. Does and biota
not meet intent
of RCRA
Site Cap Moderate II II 129.000 19.700 314.712
On-Site
D1sposa 1 RI~liable Meets RCRA None 139.000 19.700 324.712
Guidance
Off-Site
Disposal Reliable It None 53.000 0 53.000
5011 d1fi cat ion To bl! deter- To be deter- None 79.000 0 79.000
mined by mined by
pilot test. pilot test.
Expect High Expected to
exceed ReRA
standards.
Bu11di n9
No Action Not Reliable Less than ReRA Possible impacts 6.000 0 6.000
protection. to G.W. and boita
Complete
l(emlJvdl lti9h Meets RCRA None
*44.0001 19.7001 229.7121
40.000 0 40.000
LiI.1ited
Modi ficdtion JI i.~h " None 21.250 0 21,7.')f)
Containment r.1od~r"te Exceer1 nCRA None 97,006 18,300 269,514
* ':.?/f) ff - Sit i~
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, 0
-17-
Questions from local citizens were addressed. These citizens were interested
in the progress that has been made and plans for the future. They asked
questions about implementation and cost recovery. The public comment
period ended August 12, 1985. Responses to written comments are in the
Responsiveness Summary, attached.
Consistency with Other Environmental Requirements
Off-site activities will be in accordance with the appropriate RCRA and
Department of Transportation (DOT) regulations for the transportation and
disposal of hazardous wastes. This will include manifesting of wastes and
shipment to a RCRA approved facility.
Recommended Alternative
~
The National Oil and Hazardous Substances Contingency Plan (NCP) [40 CFR
Part 300.68(j)] states that the appropriate extent of remedy shall be
determined by the lead agency's selection of the remedial measure which the'
agency determines is cost-effective (i.e., the lowest cost alternative that
is technologically feasible and reliable) and which effectively mitigates
and minimizes damage to and provides adequate protection of public health,
welfare, or the environment. Based on the evaluation of the cost and
effectiveness of each proposed alternative, the comments received from the
public and the MDNR, the following alternative has been determined to be
cost-effective as defined by the NCP:
o Excavate contaminated soil and sewer line sediments and dispose
of at an off-site facility
o Limited Modification of the Building
The recommended action is considered a source control operable unit remedial
measure as defined in section 300.68(e) of the proposed changes to the NCP.
The objective of the action is to remove the source of continued contaminant
migration from the site. This includes cadmium and chromium contaminated
soils, sewer sediments including the sewer line, and residuals in the
building. The RIfFS study is continuing and will determine if additional
remedial actions are needed to address the groundwater contamination and
develop the appropriate level of cleanup.
The evaluation of alternatives for source control measures determined that
off-site disposal of the hazardous wastes is more cost-effective than other
feasible on-site alternatives.. On-site disposal would require a RCRA cap
or RCRA landfill. Each of these is more costly than off-site disposal with
no additional protection.
The capital cost of this alternativp. is approximately S75,OOO. The State.
of Michigan agrees to contribute ten percent of the source control operaDle
unit costs. Long-term In~nitoring needs will be determined at tne compl~tio~
of the RIfFS.
Schedule
- Approve Remedial Action (Sig~ ROD) 9/6/85
- Award Cooperative A9reement ~DfRA (Advance Match) 9/6/85
- Start Design 9/85
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-id-
Complete Design
- Start Construction
- Complete Construction
Future Actions
3/86
6/86
8/86
Additional field work will be conducted during the continued RI to determine
the vertical and horizontal extent of contamination to the groundwater. .
The Feasibility Study should be completed by March 1986.
".
-.
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o .
I'
Community Relations Responsiveness Summary
Northernaire Plating Company
Cadillac. Michigan
INTRODUCTION
This "Community Relations Responsiveness Summary" documents citizen concerns
and issues raised duriny the planning and preparation of the Focused
Feasibility Study (FFS) for an operable unit remedial action at Nortnernaire
Plating Company, Cadillac, Michigan. It also documents, for the public
record, the U.S. Environmental Protection Agency's (USEPA) response to the
comments presented during the public cOlrnnent period on the Focused Feasibility
Study.
CONCERNS RAISED DURING COMMENT PERIOD
".
The FFS was completed on July 19, 1985. Copies of the FFS were made availab)e
.to the public on JuJy 22. 1985. A public meeting was held in the Cadillac
Municipal Complex Council Chambers. Approximately 25 residents attended
the meeting. Although the attendees had several questions and showed
interest, written comments were not submitted at the meeting. The comment
period closed on August 12, 1985.
The Agency subsequently received two written comments regarding the proposed
alternative for the building and disposition of the sewer line. The co~nents
were submitted by the City of Cadillac. These issues are addressed below.
ISSUE:
Recommended Alternative for the Building
COMMENT: The soil under the building cannot be properly evaluated and
excavated without total removal of the building and slab with off-site
disposal.
RESPONSE: Demolition of the building was considered as an alternative.
The EPA and the MDNR have the opinion that if the building is useable, it
can provide a source of income and should remain in place. There is no
certainty the soil under the building is contaminated. but if it is. we
are confi dent that the exca vat i on can be success fully accompli shed VJit~out
razing the building.
COMMENT: The sanitary sewer is serving Northernaire and an adjacent
building and if removed should be replaced with a1~ernative sewage.
RESPONSE: Northernaire is not currently connected to the sewer. It is
uncertain if the adjacent building is connected to this particular line and
in fact, if the sewer is in useab1e condition. The sewer is a private line
installed by the owner of the site property. It is assumed installation
occurred at the same time the se~'er line connection to the building was
installed. The sewer line conne~tion to the ~ortheraire building was
re,noved during the immediate re:noval conducted by the U.S. EPA because of
!Joor constructior'l. 1ea
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