United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-91/188
September 1991
Superfund
Record of Decision
Novaco Industries
(Amendment), Ml
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150272.101
\)
REPORT DOCUMENTATION 11. REPOATNO.
PAGE EPA/ROD/R05-91/188
I ~
I. AIdpIenI'. Acc:888Ion No.
. '"'118 and .......
'PERFUND RECORD OF DECISION
..ovaco Industries, MI
First Remedial Action (Amendment)
7. Aulhar(.)
I. A8port Data
09/05/91
- Final
I.
I. P8rfonnkIg Org8lllZ81l0n Rapt. No.
8. Pwformlng Org8lnlDton NIm8 ... AddIw8
10. 1'roJIc"T8III/WCIItI UnIt No.
11. ConIr8cI(C) or Gr8nt(G) No.
(C)
(0)
12. ~ OrganlZllllon NIm8 and AddIw8
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
11. Type of R8por1. P81tocl Covered
Agency
800/000
14.
11. SUppI8m8rII8ry No-
111. Ab81r8c1 (lJmI1: 2011_'*)
The 2.6-acre Novaco Industries site is a one building site in Temperance, Michigan.
Land use in the area is predominantly residential and agricultural. The estimated 85
residences located within 1/2 mile of the site use the underlying sand/gravel and
limestone aquifer as their drinking water supply. In 1979, a chromic acid leak
occurred from a 1,870 gallon underground storage tank at Novaco, which led to chromium
'ntamination of an onsite well. Subsequent sampling from 1979 to 1982 detected
.1romium in wells of properties adjacent to the site, and as a result new wells were
installed in the uncontaminated lower aquifer. Later in 1979, Novaco Industries began
pumping and treatment of 122,000 gallons of contaminated ground water, removing 400
pounds of hexavalent chromium. In 1983, the State sampled several residential wells,
and chromium was not detected above background levels. However, sampling of ground
water monitoring wells in 1984 and 1985 revealed chromium contamination levels in .
excess of the MCL. A 1986 Record of Decision (ROD) addressed a final remedy for ground
water contamination and provided for ground water pumping and treatment using
electrochemical reduction/ion exchange polishing, followed by onsite discharge to
surface water. This ROD amends the 1986 ROD. Pre-design studies during 1988 have
(See Attach~d Page)
17. DoCI8I8IIt An8Iy8I8 .. D88crIi*N8
Record of Decision - Novaco Industries, MI
First Remedial Action (Amendment) - F~nal
Contaminated Media: None
Key Contaminants: None ~
b. 1cI8ntIt*8I~ T8m18
Co COSA 11 f'I8IcLIQr1qI
-:- \1II8bII1y ~
11. S8a81ty CIM8 (1bIa A8por1)
None
20. S8a81ty CIM8 (1bIa P8g8)
Non""
21. No. of Page.
25
22. Prlee
(S88 ANSl-Z38.18
s.1n881td_on 1It-
'ff)
(Fonnerty NTI~I
Department 01 Conmeree
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EPA!ROD!R05-91!188
Novaco Industries, MI
First Remedial Action (Amendment) - Final
. /
Jtract (Continued)
determined that contaminant levels have continued to decrease over time, and there is no
longer any indication of a chromium contaminant plume. Therefore, based on these data,
there are no contaminants of concern affecting the site.
The amended remedial action for this site is no further action. Although no significant
contamination is present at the site, EPA recommends that nested wells be installed and
ground water monitoring be implemented to evaluate the attenuation process. However, if
contaminant levels for hexavalent chromium exceed 50 ug!l for two consecutive periods of
monitoring, the remedy from the 1986 ROD will be implemented. There are no costs
associated with this no action remedy. .
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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./
NOVACO INDUSTRIES RECORD OF DECISION AMENDMENT
PURPOSE
This decision document presents the amendment to the Record of
Decision for the Novaco Industries site, in Temperance, Michigan.
It was developed in accordance with CERCLA, as amended by SARA, and
to the extent practicable, the National Contingency Plan.
BASIS
The decision to amend the Record of Decision (ROD) is based upon
the administrative record. The index attached to the amended ROD
identifies the items that comprise the administrative record upon
which the selection of the remedial action is based.
DESCRIPTION OF THE AMENDMENT
The remedy selected in the ROD was a final remedial action. It
consisted of ground water extraction, on-site treatment of the
ground water, and discharge to Indian Creek. The amendment to the
ROD consists of no action with installation of additional
monitoring wells and ground water monitoring to verify that no
unacceptable exposures to risks posed by conditions at the site
will occur in the future.
DECLARATION
The conditions at the site pose no current or potential threat to
human health or the environment. Therefore, no action is
necessary, the statutory requirements of CERCLA section 121 for
remedial actions are not applicable. This remedy will not result
in hazardous substances remaining on site above health based
levels. However, as deemed prudent by the U. S. Environmental
Protection Agency, the 5 year review will apply to this action.
The State of Michigan concurs on the selected remedy.
rfra~
-,
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1
INTRODUCTION
Novaco Industries is located at 9411 Summerfield Road, at the
intersection of Summerfield and Piehl, Temperance, Michigan. The
site lies 50 miles south of Detroit and 5 miles north of Toledo,
Ohio (Figures 1 and 2). The facility occupies a 2.6 acre
rectangular parcel. The Novaco study area consists of Novaco
Industries, Veterans of Foreign Wars (VFW) Post 9656 and the Moyer
residential property (Figure 3).
The Record of Decision (ROD) for the site was signed on June 27,
1986 which addressed ground water. This document amends the ROD
and provides for implementation of a program to continue to monitor
for chromium in ground water for a period of time to ensure
protectiveness. This action is based on data from the United
States Army Corps of Engineers (USACE) pre-design study and
evaluation of scientific information regarding the fate of chromium
in ground-water systems which suggest that the concentration of
chromium in the aquifer at the site has been attenuated by means of
natural mechanisms. The data from the study indicates that a
chromium plume is no longer present in the aquifer.
The lead agency for the remedial action at this site is the United
States Environmental Protection Agency (U.S. EPA). The State of
Michigan Department of Natural Resources (MDNR) is the support
agency. This ROD amendment will become part of the Administrative
Record File.
SITE CHARACTERISTICS
The site geology consists of glacial outwash sands and gravel
overlying limestone bedrock at an approximate depth of 25 feet.
The weathered limestone zone is underlain by relatively competent
limestone. Ground water occurs in both the shallow sand and
gravel/weathered limestone aquifer and the deeper competent
limestone aquifer. There is a hydraulic potential for downward
movement into the limestone aquifer. The flow direction in both
aquifers is toward the north, northwest.
The site is bordered on the north, east a~d south by residential
and agricultural areas and on the west by the VFW Post. The study
area is relatively flat and grass covered.
There is no public sewer or water available within one mile of the
~ovaco Industries study area. Approximately 85 residences, located
w~thin 1/2 mile of the site, have private wells and septic tanks.
In the down gradient ground-water flow direction and within.:l,ooO
feet of Novaco Industries, there are eight homes and businesses
that have individual water supply wells located in the sand/gravel
aquifer or the limestone aquifer, or are screened across both
aquifers.
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Under CERCLA S 117 and Section 300.435(c) (2) (ii) of the National
Contingency Plan, the lead agency is required to propose an
amendment to the Record of Decision (ROD) if the differences in the
remedial action alter the basic features of the ROD and allow the
public the opportunity to comment on the .proposed changes. A
public mee~ing for the original ROD was held on May 13, 1986, with
approximately 30 residents in attendance. The amendment to the ROD
was made available to the public on July 15, 1991. The public
meeting was held on July 24, 1991, at the Bedford Township Hall in
Bedford, Michigan. .. .
8:ITB R:I8TORY
A chromic acid leak from a 1, 870-gallon tank buried 4 feet
underground was detected in.the sand and gravel aquifer on June 13,
1979, at Novaco. Shortly afterward, the 20-foot-deep Novaco water
well became contaminated with chromium. During sampling
investigations conducted over the next three years, chromium was
detected in the VFW Post well, the Moyers' residential well, and
observation well M5. All these wells showed contamination in
concentrations that exceeded U. S. EPA and State of Michigan
drinking water standards for total chromium, both set at 50 ~g/l.
New wells were installed into the uncontaminated lower aquifer at
all three of these locations.
Ground-water extraction and treatment measures were undertaken by
Novaco Industries from July 13 to November 30, 1979. These
measures included extracting and treating approximately 122,000
gallons of contaminated ground water and removing approximately 400
pounds of hexavalent chromium. This operation was discontinued
before all contamination at the site was removed.
The MDNR and the Monroe County Health Department conducted
investigation and monitoring programs at Novaco prior to the U.S.
EPA sponsored Remedial Investigation (RI) field work (1984). In
September 1983 the Monroe County Health Department sampled several
area residential wells. Chromium was not detected in any of the
residential wells sampled.
Novaco was placed on the National. Priori ties List in September
1983. The RI field work was conducted during 1984 and 1985. The
study included an electromagnetic survey, installation of 16
monitoring wells, analyses of soil samples from three soil borings,
and implementation of a ground-water sampling program using the
newly installed monitoring wells and existing residential wells.
The sampling programs were conducted in April 1984 (Phase I);
December 1984 (Phase II); June 1985 (Phase III); and Septembe~ 1985
(Phase IV). .
REMEDIAL INVESTIGATION RESULTS
The electromagnetic survey conducted in January and February
of
-------
5
1984 failed to identify a ground-water contaminant plume at Novaco
due to background disturbances such as well casings, overhead
powerlines, and fences which contributed to false above-ground
electromagnetic measurements. Measurements away from the
disturbances did not detect a plume moving off-site.
Surface water and sediment samples were taken during Phase I from
Fishers Pond and Hickey's Pond (see Figure 3). Sediment samples
were taken during Phase II from Indian Creek and Carter's Pond (see
Figure 3). Soil borings in and around the site were taken during
these same time periods. These samples were analyzed for
hexavalent and total chromium. No hexavalent chromium
concentrations were detected. Total chromium concentrations were
detected below the typical background level of most soils of 100
parts per million (ppm). .
During Phase I, ground-water samples were taken from the new Novaco
well and from monitoring wells MW-7 and MW-8. The samples were
analyzed for Target Compound List inorganic and organic chemicals.
No organic, pesticide, or PCB contamination was detected in the
U.S. EPA organic priority pollutant analyses. Iron, manganese, and
zinc were detected in all four ground-water samples, and the
secondary drinking water standards for these metals were exceeded.
However, because the secondary standards are based on non-health
criteria, these metals were not addressed further as an
endangerment. Although barium was detected at concentrations above
the Federal primary drinking water standard in one sample
collected, additional ground-water sampling of 13 monitoring wells
and 8 domestic wells conducted during phase II did not show barium
concentrations in excess of this standard.
During the RI, total chromium was detected at concentrations above
the federal drinking water standard (50 ~g/l) in three samples
collected in April 1984 (monitoring wells MW-4, MW-7, and MW-8), in
two samples collected in December 1984 (monitoring wells MW-4 and
MW-8), and in two samples collected in June and September 1985
(monitoring wells MW-4A and MW-8) (Figure 4).
The total chromium concentrations for samples collected in April
1984 from 20 domestic wells were below a detection limit of 0.5
~g/l. The total chromium concentrations for samples collected in
December 1984 from eight domestic wells were below a detection
limit of 8 ~g/l. Detection limits in April were lower than the
limits in December because different laboratory methods were used.
During the RI, an Endangerment Assessment (EA) was conducted to
determine the potential for adverse effects to public health.
Since there was an exceedance of the Safe Drinking water Act
Maximum Contaminant Limit (MCL) for chromium, the risk from
ingestion of the contaminated ground water was not quantified. The
EA concluded that the ingestion of the contaminated ground water
could pose a potential threat to human health and the environment
-------
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-------
. /
7
since MCLs are based on human health criteria. Because chromium
contamination levels are no longer present above MCLs, the u.s. EPA
believes that the site no longer presents a risk from ingestion of
chromium in ground water. .
REASONS POR.ISSUING THE ROD AMENDMENT
After the ROD was signed on June 27, 1986, USACE was tasked by u.s.
EPA to perform the Remedial Design at Novaco. As part of the
design effort, samples were taken in April 1988 to determine design
parameters. Only one monitoring well showed chromium above the
level of detection. Based on these results the USACE attempted to
determine the fate of the plume.
A pre-design site investigation was performed at Novaco between
April 17 and May 1, 1989 by the USACE in order to establish the
fate of the chromium plume. The investigation consisted of
resampling existing wells, installation and sampling of a bedrock
monitoring well, soil sampling from shallow borings, and collection
of ground-water samples using the HydroPunch ground-water sampling
device. The HydroPunch is a sampling device that allows collection
of ground-water samples without installation of a monitoring well.
It is constructed primarily of stainless steel but has some Teflon
parts. The principle components are an outer sleeve, a barbed
drive point, a perforated section of pipe for sample intake, a
sample chamber, and an adapter to attach the sampler to the drill
rods. .
Results from the investigation indicated chromium above the
detection limit in only one of the monitoring wells (MW-4A)
sampled, and no detectable levels were found in any of the
HydroPunch samples. Table 1 summarizes the reduction of chromium
in ground water over time.
Pump test data from 1988 determined transmissivity and hydraulic
conductivity parameters to be 10,300 gpd/ft and 600 gpd/ft2
respectively. The local hydraulic gradient based on water well
measurements from 1988 is 0.0022 ft/ft to the west-northwest,
resulting in a calculated flow rate for the ground water between
215 and 230 feet per year (Figures 5 and 6). The regional flow
direction appears to be generally to the east in the sand and
gravel aquifer.
Analytical results from periodic sampling of ground water have
shown a steady decrease in hexavalent and total chromium with time. .
The only sample with a concentration above detection limits in the
last round of well samples was in MW-4A which is located at the
center of the previously identified plume. Analyses of surrounding
wells confirmed that all chromium concentrations were below
detection limits. This indicates little advective movement of the
plume.
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TABLE 1
CHROMIUM CONCENTRATIONS
...nCIIIIG wELLI TOTAL. IlEXAVALEIIT
IfTDIIOIUICII JQ8ER alK.UiM (1IIIb) alRc.UiM (1IIIb)
..,-, BDLb
Merch 1984 41
Oeceneer 1984 BDL BDL
oIl6Ie 1985 BDL BDL
"'-2
Merch 1984 4 BDL
Oeceneer 1984 9 BDL
oIl6Ie 1985 BDL BDL
fll-28
oIl6Ie 1985 BDL BDL
Septeatler 1985 BDL BDL
"'-3
Aprf l 1984 3 BDL
Oeceneer 1984 BDL BDL
oIl6Ie 1985 BDL BDL
~
Apr il 1984 610 320
Oeceftt)er 1984 1,640 1 , 930c
oIl6Ie 1985 BDL SOL
Septeneer 1985 2.3 BDL
April 1989 BDL BDL
"'-48
oIl6Ie 1985 190 190
Septeftt)er 1985 430 420
Aprf l 1988 22 28
April 1989 16 18
..,-41)
June 1985 BDL BDL
Septeatler 1985 BDL BDL
""'-5
April 1984 SOL BDL
Oeceneer 1984 " BDL
oIl6Ie 1985 BDL BDL
"'-5.
-: oIl6Ie 1985 BDL SOL
Septeneer 1985 BDL BDL
fll-6
Aprt t 1984 BDL BDL
Oeceneer 1984 8 BDL
.lint 1985 . BDL BDL
""'-68
JI6Ie 1985 3.3 BDL
Septetrber 1985 BDL BDL
fll-7
Merch 1981 480 25
Aprf l 1984 91 BDL
Oeceftt)er 1984 8 BDL ..
JI6Ie 1985 BDL BDL
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TABLE 1 cont.
CHROMIUM CONCENTRATIONS
-ITCIIIIIG WELLI TOTAL IlEXAVALEIT
HTDROfUICH IU8ER CHROUt.M CIIDb) CHROUt.M CIIDb)
"'-8
M8i=Ch 1981 37,200 29,000
Aprf l 1984 1,680 1,500
Oeceaeer 1984 3,220 2,780
Jw. 1985 200 190
Septeaeer 1985 370 340
..,-,
Deceamer 1984 BDL BDL
Jw. 1985 BDL BDL
"'-10
Deceamer 1984 10 BDL
Jw. 1985 BDL BDL
..,- 1 1
Deceamer 1984 10 BDL
JI6Ie 1985 BDL BDL
"'-12
Decentler 1984 10 BDL
JI6Ie 1985 BDL BDL
"'-1]
Deced)er 1984 10 BDL
Jw. 1985 BDL BDL
MP-01 BDL BDL
~ BDL BDL
~ BDL BDL
"'-04 BDL BDL
NP-OS BDL BOL
~ BDL BDL
!!t:9l BDL BDL
~ BDL BDL
~ BDL BDL
!!f:B BDL BDL
IIP-" BDL BDL
-Resulu from Aprfl 1984 end prfor ere ~ffltered s~les. The results from Deced)er 1984 on ere for ffltered
samples end represent totel dissolved chromium.
baoL fndicates that c~ was analyzed for, but below the detectfon limft.
CTotal end hexavalent chromfum concentrations are accurate with limits of 90X to 1101.
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-------
12
Oxidation-reduction (redox) reactions have a major effect on the
fate of chromium in ground water. Hexavalent chromium is easily
reduced to its more stable trivalent state by organic materials in
soil or water. Most trivalent chromium in the aqueous environment
is in the fQrm of insoluble chromium (III) hydroxide. Analyses of
the site ground water have consistently indicated that the dominant
oxidation state of chromium in solution is hexavalent. Measurement
of the redox conditions in the aquifer at the site indicate that
hexavalent chromium will be quickly reduced to the trivalent
oxidation state when it contacts a reducing agent and then be
precipitated as chromium (III) hydroxide. Chromium (III) hydroxide
is insoluble at site ground-water conditions and will sorb to soil
particles and become part of the soil matrix.
Concentrations of chromium in soil samples near the Novaco site
were all less than 25 milligrams per kilogram (mgjkg) although
typical concentrations of chromium in soils can be as high as
100 mgjkg. Based on site soil conditions, 1 liter of contaminated
ground water would be in contact with 5 kilograms of soil. While
in contact with the soil, redox reactions taking place would reduce
chromium to the trivalent state. Based on the worst case chromium
concentrations of 37 milligrams per liter, depositing all of the
chromium into the soil would account for only a 7 mgjkg increase in
chromium soil concentrations. Further dilution of the plume before
reduction of the chromium would result in smaller increases in soil
chromium concentrations. On average, the chromium deposited from
ground water would account for only a 1 or 2 mgjkg increase in soil
chromium concentrations. Changes of this magnitude would be very
difficul t to detect quanti tati vely because an increase in the
concentration of chromium of this magnitude is within variations
observed naturally in the soil. .
Based on the results of the ground-water sampling and evaluation of
the potential for the reduction and precipitation of chromium under
the conditions present within the aquifer, the u.s. EPA believes
the ground-water plume has been attenuated by natural processes.
DESCRIPTION OF THE NEW ALTERNATIVE
To address the risks posed by the hazardous chemicals found at
Novaco, the ROD signed in 1986 detailed that the remedial action
would consist of ground-water extraction until total chromium
concentrations remaining in the aquifer were below the 1986
drinking water standard of 50 IJ.gjl. The on-site treatment of.
-ground water would have been accomplished by electrochemical
reduction/ion exchange polishing and then discharge of the treated
ground water to Indian Creek. . .
u.s. EPA has determined that "No Action" with ground-water
monitoring is the preferred alternative for the site. u.s. EPA
proposes to amend the 1986 ROD and to implement a program to
continue to monitor for chromium in ground water for a period of
-
-------
. /
13
time to ensure protectiveness. The amended alternative will
include the installation of three sets of nested wells. Each well
nest will consist of two wells placed next to each other: one well
will be screened in the shallow aquifer and the other well will be
screened in the deep aquifer. In addition to monitoring chromium
in ground water, these new wells will be used to ensure that the
current unBerstanding of the vertical and horizontal gradients and
velocities of the two aquifers is correct.
Ground water will be sampled from all the wells tested during the
RI and pre-design phases of this remedi~l action. Monitoring will
take place over a 5 year period. Monitoring to evaluate the
attenuation process will be conducted on a quarterly basis for a
period long enough to ensure accounting for seasonal fluctuations
and on a bi-annual basis for the remainder of the 5 year period.
Ground-water samples will be analyzed for hexavalent and total
chromium. If a statistically significant increase in hexavalent
chromium is detected, monitoring will be conducted on a quarterly
basis until a new baseline chromium concentration is established.
If the concentration of hexavalent chromium exceeds the 1986 health
based level of 50 ~g/l for two consecutive periods of monitoring,
then the selected alternative from the 1986 ROD will be
implemented. If the concentration of hexavalent chromium does not
exceed this level by the end of the 5 year monitoring period, then
the u.s. EPA will proceed with the 5 year review.
STATUTORY DETERMINATIONS
Analysis of ground water over the past four years has shown a
steady decrease in the concentration of hexavalent chromium.
Currently, there is no contamination remaining on site above health
based levels and treatment of the ground water in the shallow
aquifer as proposed in the original 1986 ROD is unnecessary.
Therefore, monitoring to ensure the permanence of natural
attenuation of the chromium contamination in ground water is
appropriate as a remedy to address the situation at this site.
This remedy will not result in hazardous substances remaining on
si te above health based levels. This remedy is protective of human
health and the environment. The 5 year review will apply to this
action to evaluate the permanence of the remedy. Because there is
no contamination remaining on site above health based levels, the
statutory requirements of CERCLA 121 for remedial actions are not
applicable.
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RESPONSIVENESS SUMMARY
NOVACO INDUSTRIES SITE
The United States Environmental Protection Agency (U.S. EPA) has
recently completed a study of groundwater contamination at the
Novaco Industries site in Temperance, Michigan. During the study,
groundwater samples were collected to verify that levels of
chromium in the groundwater had dropped to below maximum
contaminant levels (MCLs) set forth in the Federal Safe Drinking
Water Act. An amendment to the 1986 Record of Decision (ROD) was
proposed by U.S. EPA based on the findings of the 1989 groundwater
study. U. S. EPA held a public comment period from July 15 to
August 13, 1991 for interested parties to comment on the U.S. EPA's
Proposed ROD Amendment.
The purpose of this Responsiveness Summary is to document the
comments received during the public comment period and U.S. EPA's
responses to the comments. All of the comments summarized in this
document were considered prior to U.S. EPA's final decision.
I.
RESPONSIVENESS SUMMARY OVERVIEW
Based on the 1989 groundwater study, which confirmed that chromium
contamination at the Novaco Industries site had decreased to
acceptable levels, available information, and public comments, the
U.S. EPA has determined that amending the ROD to require no action
with groundwater monitoring is the most appropriate remedy for the
Novaco Industries site.
/ '\
,,~ --/
The major components of the selected remedy include:
Installation of three new well nests to verify the direction
and speed of groundwater movement and to sample the
groundwater for chromium.
A five year groundwater monitoring program which will be
conducted quarterly until the impact of seasonal climate
changes is accounted for. After that, the groundwater will be
monitored twice a year for the remainder of the five year
period.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT
Historically, public interest with the Novaco Industries site has
been minimal. Homeowners in the immediate area of the Novaco site
are primarily concerned with their property value being affected by
the presence of a Superfund site. Three private wells were
contaminated with chromium soon after the discovery of the chromium
leak in 1979. These three wells (Novaco, VFW Post and Moyer
Residence) were reinstalled into the deep aquifer and have shown no
contamination since the reinstallation. No other private wells
have shown any contamination.
1
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~ /
As part of the .community relations program, two information
repositories have been established near the site, one at the
Bedford Township Hall and the other at the Monroe County Library -
Bedford Branch. The administrative record has been placed in the
repositories for public review.
u.s. EPA notified the local community, by way of a fact sheet
announcing u.s. EPA's proposal to amend the 1986 ROD to require a
no action ROD. To encourage public participation in the selection
of a remedial alternative, u.s. EPA scheduled a public comment
period from July 15 to August 13,1991. In addition, u.s. EPA held
a public meeting on July 23, 1991,. to discuss the proposed
amendment to the 1986 ROD. Three people attended this meeting.
Comments received during the public meeting and the public comment
period are included in this Responsiveness Summary, along with u.s.
EPA's responses.
III. SUMMARY OF COMMENTS RECEIVED AND U.S. EPA's RESPONSE TO THE
COMMENTS
Comments raised during the Novaco Industries public comment period
are summarized below.
1.
COMMENT:
A local citizen requested that the monitoring wells which are
located on his property be modified to flush mounted types.
U.S. EPA's RESPONSE:
When u.S. EPA installs the three additional well nests we will have
our contractor evaluate the viability of modifying the existing
monitoring wells on this citizen's property and accommodate him if
it can be accomplished without destroying the well.
2.
COMMENT:
The Monroe County Health Department is concerned that if the
monitoring well casings are installed flush with the ground
surface, the potential for surface water contamination may exist.
U.S. EPA'. RESPONSE
Installation of flush-mounted monitoring wells is an accepted
practice, and precautions will be taken to ensure that surface
water cannot enter the wells (e.g.; water-tight caps).
3.
COMMENT:
The Monroe County Health Department is concerned that some of the
language used in the fact sheet presenting the proposed ROD
2
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, ,
Amendment do not indicate that the fate of the contamination has
been determined.
u.s. BPA's RESPONSB
u.s. EPA has not conclusively determined the. fate of the
contamination, and the language used reflects this uncertainty. We
do know that groundwater samples taken as of 1989 show chromium
levels at safe levels. U.S. EPA does not know conclusively why the
chromium levels decreased, but we believe it is due to a natural
reducing process which occurs when hexavalent chromium comes into
contact with organic material in the soils.
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Page No.
~0/91
FICHE/FRAME PAGES DATE
5
90/11/06
4
9O/1Z1Z1
15
DO/DO/DO
37
90/0Zl1Z
394
9O/0Zl1Z
NOVA CO
ADMINISTRATIVE RECORD INDEX
REMEDIAL ACTION
INDUSTRIES SUPERFUND SITE. UPDATE NO.1
TEMPERANCE, MICHIGAN
TITLE
.Letter re:
The Stete's
rec0nmend8ti- for
further I i.ited
studies to deter8ine
the nature end
extent of the groundwater
contamination at
the Novaco Site
Memorandull re:
Review of Comments
to EPA from MONR
Novaco Industries
Record of Decision
Amencbent
Plume Verification
S8q)1 ing Report
Novaco Industries
Superfund Site
Plume Verification
S8q)lfng Report
Appendices .
Novaco Industries
Superfllld Site
AUTHOR
Denise Gr~,
"'NR
Steve White,
Steve Pearson
Valdas V. Adamkus,
USEPA
U.S. Army Corps of
Engineers
u.s. Army Corps of
Engineers
RECIPIENT
Beth Reiner, USEPA
Tom Thiele
Vari ous
USEPA
USEPA
DOCUMENT TYPE
DOCNUMBER
Correspondence
Memorandun
Report/Studies
Report/Studies
Report/Studies
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.'
.'~q'? '1(.,
1.11/22/&1
'~:ovac,)
'hen 1 gan
;I!L:;
AUTHOR
DATE
P~5
~~lu~lon that ~OfRA De ~oncluded In D.8alJotti - E~~ ('1)/00/00
i1~ne of no I'esponse lIy ehe p~1 s
N.:.tJce of p'Jllhc llel!t!ng to III SCUSS H~ 00/00/00
oroposed clean-up actions
Delegation Briefing unknotm 00/00/00
tnfonlatlon Request EPA 00/00/00 4
Su..ary of Re8ealal AlternatIve unknown 00/00/00 19
Selecuon
~orrHquatlc Fate of ChI'08IU8 Yersar, Inc. 80/01/30 18
'Jhronology of significant events LotIlan - MDHR 80/05/08 3
~eferral for Enforcement Action R. Courdaine - IIDNR 80/05/16
Suaary of ChrOlliU8 nati Lohun&Sc:hrall!Ck - OR 80/05/21 2
letter requestin~ iRHfdiate clean 6renaMitzke-MonroeCo.HeaJthDep 80/07/24 2
up action
SIJllllary 0' Chrolll UI data LohHn&Schrall!Ck - MDNR 80/08/06 4
SWlllary of ChrOlllUi data LohIan&SchrlllCk-flDNR 80/09/09 2
Letter 1IIChcating pencllng legal J. Bails - IWHR 80/09/15
action against Novaco
~ - Necessity of I HydrogIologicll R.HlyII-EPA 81101/15
Study
SIte Inspection Report P. SlIM - EM 82/09/03 14
Prelillnary AsSKSllent D. SetN 11 - EIE 83/02/01 5
Site Safety P~an s.J. Shenlin - EIE 83/10/20 5
FInal Work Plan for IU/FS CH2N Hill 84/02/08 104
CIvil AdllnlstratlVf Warrant For unknoem 84/03/00 4
t:ntry And tnspection Pursuant To
Sectaon 104 of CERClA
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.
0
jJa~e No,. c:
~ / .\, /2"2/88
He.v aco
flltctll gan
j[iLt: MI(JR DATE PAGES
Lclnynlty Meeting ageroa EPA 8~/(I3i15
Affl~~vlt In Suocort uf Application D. Caplle! - EPA 84/03/~ 4
F.", ""r,'ant
RecN'd .)f CCCllfllunu:atlon - Cht"Olll! J. Tanaka - EPA 8~/04/25
waste dlsOo)sal
rlnal Comaunity Relations Plan CI0I Hi 11 8~/05/02 27
ReMedial Investigation Tecnnical CI0I Hi II 84/05/17 89
Plemral'lClul
Stat. of Michigan waste Disposal 6. Lytwnysnyn-WoodlNro-tlyde 84/06/04 2
~anlfest with cover letter
Draft Ho. IB - 6eohydrologlcal Woodward - Clyde 84/08/03 31
Technical "elorandul
Endangereent AssesS8ent and CheMical 001 Hill 84/09/14 32
- 'a -- Precision and Bias Asses5llent
uraft - OeveloD8ent of Alternatives ~ Hill 84110/26 29
Technical ~randul
Corps of Engineers 6uldance Packet S. L. Car 1 ock - CtE 84/11/02 46
Conversation Record - Liability if D. Capl ice - EPA 84/11/14
COOIpant PUI'Cf1.Sft Hovaea
Superfund Progrll Fact Sheet EPA 84/12/00 2
AnalysIs of well Miter supl.. for J. ROY - Toledo Testing Labs 84/12100 5
cnrolliUl
QAPP Phase I and Ph.se 11 AI', Del Hill 84/12/14 99
Unlforl HazardOUS Wast. "'"if.., JIIN 84/12/20 2
irlP Report - RI Phase II field D. Clp! ice - EPA 85/01/14 2
.)rk 12/5 to 12/19/84
A 115t of .acti~ Ite.s8 frol S. Hahn - 00 Hi 11 85/02/11 3
2/4/85 leeting between the EPA,
"lINR and CI0I Hill
"et's detailing r.esult5 of Niedergang - EPA 85/03/11 8
,ate well salpling sent to
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a ..
.j~q! '4':" :.
':1::°;:'2;88
~~:.v aco
Ihc:nlgan
it rU~ IIITHOR DATE PAGES
"!S 1 o!nt.
::.ooenl!IJI1 t" :'f"vac-o OOPP fr:or Phase I II CI0I Hi 11 85/05/13 3S
~e.edlal Investigation
!'4o:ot Ice latter that wa5 sent to the Constantelos - EPA 85/06/14 J
c'R';"s
'.,tlflcatlon of quantity arG contents &.lytwynysnyn-Wooowani Cl yde 85/09/24
9f ~rVlS on tne site,
511.01e Results P. Hess - CH2N Hill 85/10/31 31
~eMedlal Investigation Report CRI) OtlN Hill 86/01/01 "'420
"DNR COMI!nts on 12/6/85 Draft FS S. Ph ill ips - MDNR 86/02/04 3
Recc.uended Mater qual i ty based W. Cred - NOHR 86/04/03
effluent li.lts for Movaco
RevIsed PubJic: eo..ent Draft D0t Hi 11 86/04/11 189
Feasability StUdy Report
SaapJe Results P. Hess - CM2N HilJ 86/04/22 73
ReVleM of ChroalUM data froa eight J.Lybarger - DHHS 86/04/23
resident ill wells
Invitation for public: COMents on EPA 86/04/28
c: 1 ean-UD recOll8tlndati on
~evleM of PubliC: Co88ent Draft S. Phillips - "DNR 86/05/05 2
FeaSibility StUdy
--:-
F~asabllity StUdy Fact Sheet NDNR 86/05/07 5
(.=-ents II'1II r~nHhOlll CIIt thI No Horwi h-£PA. Off. ofGroundwate 86/05/08 l
i'$
Letters Informing resident. of no Gustafson - EM 86/05/08 9
nealt" danger froa "'II NIter
ArrangMents to test tap watt!" for Gustafson - EPA 86/05/27
throalU8 contilinahon
Requeat for aonitoring weJI N. E. 6ustafson - EPA 86/05/27
placement on adJoining property
Pf!1f4R concurrence wi th reccaendld 6. 6uyer - "DNR 86/06/18
clean-up approach
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t>
. iigr:! "":',
~
II:!:: 2.2/ ~e
~ ;'
Novaco
"hcnlgan
i i ::.:
AUTHOR
DATE
PAGES
;:.:.j ;.:H-',ILI t(o "!!'n~ (ot ClifFS l'eDOrt
~ i ;;:r'q II W'I '=~nt:erns (\ver lie ii s arid
~.'J'J If !!I"S
D. Keetft-MICh.Dept. Pub. Health 8b/(~/23
2
~ea~est for Corc~rrence on the ROD
f.:.r 3 ~elle
-------
':'!qe N.).
')1122/[\8
GUIdance In
-------
e .. .
\I /
"~ge N/).
1)1122/88
2
T i TU:
I:';J(CU~ UwSfR Dlr. ''3395. O-OSC
. C~RCLA (..:oCIDhartCe l4Ith lither
EnvlrQnlental Statutes. OWser Dir.
"~2j4. O-(~
DI sct'harge "t WasteMater' fro. CERClA
Slces t/) ~QTW's. OWSER [lir.t9J30.e~
GUlda~ Index
PIovat'O, Ihctngan
ilJTItJR
DATE
H'A
85/10i02
EM
80/04/15
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