United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-92/207
September 1992
Superfund
Record of Decision:
Peerless Plating, Ml
-------
NOTICE.
The appendices listed in the index that are not found in this doCument have been removed at the request of
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All supptemental material is, however. contained in the administrative record
for this site. .
-------
50272.1 01
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R05-92/207
I 2.
3. Reclplenfs Acce8810n No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Peerless plating, MI
First Remedial Action - Final
7. Aulhor(s)
5. Report Date
09/21/92
6.
8. Performing Organization RepL No.
9. Performing OrgIInlzatlon Name and Addrea
10. ProjectfTaskJWork Unit No.
11. Contracl(C) or Gr..t(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, s.w.
washington, D.C. 20460
13. Type 01 Report & Perfod Covencf
800/000
14.
15. Supplernenl8ry Noles
PB93-964114
16. Ab8tract (Umlt 200 WOI'da)
The 1-acre Peerless Plating site is a former electroplating facility in Muskegon
Township, Michigan, and is located northwest of Little Black Creek and 1 mile north of
Mona Lake. Land use in the area is mixed use with urban, light industrial, and
residential. Lake Michigan supplies drinking water for residential and commercial
businesses within a 3-mile radius of the site. From 1937 to 1983, onsite
electroplating operations and processes included copper, nickel, chromium, cadmium, and
zinc plating, in addition to burnishing, polishing, pickling, oiling, passivating,
stress relieving, and dichromate dipping. The processes required the use of toxic,
reactive, corrosive and flammable chemicals. Over the years, Peerless Plating
discharged process waste with pH extremes and high heavy metal concentrations into
seepage lagoons at the rear of the facility. In the 1970s, the state directed Peerless
plating to monitor waste discharge daily and to install a treatment system to meet
reduced effluent limitations. The site violated the requirements and was charged by
the state. In 1980, the seepage lagoon sludge was removed and disposed of, and the
excavated lagoon area was backfilled and capped. In 1983, subsequent investigations
concluded that treatment facilities had not been upgraded adequately and discharge
(See Attached Page)
17. Document Analysis a. DMcrfptora
Peerless plating, MI
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (toluene, benzene, xylenes, TCE) ,
chromium, lead), organics (cyanide)
b. Identif/enlOpeD-Ended Tenna
metals (arsenic,
c. COSATI FleldfGloup
18. Availability Stalltmenl
19. Security Class (This Report)
None
20. SecurIty Class (ThIs Page)
Nnnp
21. No.olPages
64
I
22. . PrIce
See ANSI-Z39.18)
SeelnstructJons on Reveru
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-35)
Department of Comm-
-------
EPA/ROD/R05-92/207
Peerless Plating, MI
First Remedial Action - Final
Abstract (Continued)
limitations were still being exceeded for chromium, cyanide, cadmium, and zinc. As a
result, Peerless Plating closed in June 1983, and the owners abandoned the plant. In
1983, after the state and local government detected hydrocyanic acid gas within the
facility atmosphere, EPA carried out an Emergency Response Action onsite, which involved
removing 37,000 gallons of hazardous liquids, draining the lagoons, excavating lagoon
soil and sludge, sealing sewer lines, and neutralizing onsite the cyanides and
nitricacid. In 1984, EPA investigations revealed that ground water was contaminated with
VOCs and chloroform. Additionally, surface water and sediment in Little Black Creek were
contaminated with heavy metals. In March 1990, EPA conducted a second removal action to
remove and dispose of liquids and sludge contained in above-ground tanks onsite,
encapsulate an asbestos oven, and install a fence around the facility. This ROD
addresses the onsite contaminated soil and ground water as a final remedy. The primary
contaminants of concern are VOCs, including benzene, TCE, toluene, and xylenes; metals,
including arsenic, chromium, and lead; and inorganics, including cyanide.
The selected remedial action for the site includes demolishing Peerless Plating to
facilitate additional soil sampling underneath the building and disposing of debris; and
treating contaminated soil with in-situ vapor extraction (ISVE) with carbon filtration
for air emissions, followed by onsite stabilization of excavated soil. Stabilized soil
will be tested to ensure treatment standards are met and disposed of offsite at a RCRA
facility. Ground water treatment includes air stripping and precipitation, which
involves pumping ground water from an extraction well system, stripping VOCs using a
counter-current air flow in a packed tower or column, filtering the air stream with a
carbon filter to meet air emission limits of federal and state regulations; followed by
precipitation to remove inorganics, reducing the solubility of inorganic contaminants by
adjusting the pH of the water, adding chemical coagulants in a rapid mix tank,
precipitating the organic sludge out of the water, and treating it to meet LDR treatment
standards prior to disposal at the RCRA Subtitle C facility. Treated ground water will
meet discharge limitations prior to being discharged onsite to Little Black Creek. Spent
carbon from the ISVE emissions and the air stripper units will be handled as a hazardous
waste (if it is characteristic) and regenerated at an offsite thermal treatment facility.
A ground water monitoring program will be implemented during RD/RA. The estimated
present worth cost for this remedial action is $7,971,000, which includes an annual O&M
cost of $323,000.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up goals are based
on SWDA MCLs and State standards and include benzene 1 ug/l, arsenic 0.2 ug/1, cadmium
4.0 ug/1, and lead 5 ug/1. Chemical-specific soil clean-up goals are based on RCRA LDRs
and health-based levels and include benzene 0.02 mg/kg, arsenic 1.7 mg/kg, cadmium
0.8 mg/kg, and barium 40 mg/kg.
-------
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Peerless Plating
Muskegon Township, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Peerless Plating site developed in accordance with the
comprehensive Environmental Response, compensation, and Liability
Act of 1980, 42 U.S.C. 9601, as amended by the Superfund Amendments
and Reauthorization Act of 1986 and consistent with the National
oil and Hazardous Substances Pollution contingency Plan to the
extent practicable.
This decision is based upon. the contents of the administrative
record for the Peerless Plating Site.
The State of Michigan has verbally concurred with the u.S. EPA's
Record of Decision even though a concurrence letter has not yet
been received.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision, may present a current or potential
threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy is the final remedy for the site. The remedy
eliminates unacceptable threats to public health and the
environment by treatment and removal of the contaminated soils. and
treatment of groundwater at the site. This action addresses the
principal threat at the site by treating the contaminated soils.
The major components of the selected remedy include the following:
*
Demolition and disposal of the Peerless Plating buildinq
in order to facilitate additional soil samplinq
underneath the building and around the perimeter durinq
the remedial design phase. Disposal of the buildinq
debris will depend on whether or not it is contaminated.
If it is not contaminated, the debris will be disposed at
a solid waste landfill. If it is contaminated and can
not be cleaned to acceptable levels, the debris will be
disposed at a licensed RCRA hazardous waste facility.
-------
2
*
Air stripping and treatment of the volatile organic
compounds in the groundwater, followed by precipitation
of inorganic compounds. The treated groundwater will be
discharged into Little Black Creek in compliance with
effluent limitations, i.e., the substantive National
Pollution Discharge Elimination System (NPDES)
requirements. Inorganic sludges and spent carbon will be
handled and disposed of in compliance with Land Dispo~al
Restrictions (LDRs).
*
In-situ Vapor Extraction of the organic compounds and
stabilization of the inorganic compounds in the soil.
The treated soils will be disposed off-site in a licensed
hazardous waste facility in accordance with applicable
requirements, in particular LDRs.
DECLARAIJ.' ION
The selected remedy is protective of human health and the
environment, complies with Federal and State applicable or relevant
and appropriate requirements, and is cost-effective. This remedy
utilizes permanent solutions and al ternati ve treatment to the
maximum extent practicable, and satisfies the statutory preference
for remedies that employ treatment that reduce toxicity, mobility,
or volume as a principal element. Because this remedy will not
result in hazardous substances remaining on-site above health based
levels,. the 5-year review will not apply to this action.
ffe.~tu.if I I?ft
-------
c-
C,EPA
RECORD OF DECISION
DECISION SUMMARY
PEERLESS PLATING SITE
MUSKEGON TOWNSIDP, MICmGAN
Prepared by:
u . s. Environmental Protection Agency
Region V
Chicago, Illinois
September 1.992
-------
II.
DECISION SUMMARY
Peerless Platinq site
I.
SITE NAME. LOCATION. AND DESCRIPTION
The Peerless Plating site is an abandoned electroplating
facility located at 2554 Getty Avenue, Muskegon Township,
Muskegon, Michigan (Figure 1). The property covers
approximately 1 acre in the southwest 1/4 of Section 33, T.10
N., R. 16 W., Muskegon Township. The vicinity of the site is
urban, light industrial., and residential. Lake Michigan
supplies the drinking water for residences and' businesses
within a three mile radius of the site. There are no known
private wells being used for drinking water in the area.
The Peerless Plating Site is located northwest of Little Black
Creek and 1 mile north of Mona Lake, and slopes less than 1
percent in the southwest direction.
The groundwater occurs between approximately 5 and 13 feet
beneath the site within lacustrine sands. The lacustrine
sands comprise the primary aquifer beneath the site. This
unconfined aquifer is separated from the Marshall Sandstone
Aquifer System by the fine-grained deep water lacustrine clay
aquitard and presumably the underlying sil~y clay glacial till
aquitard. Shallow groundwater flow is primarily horizontal to
the southeast, toward Little Black Creek. The calculated
average linear flow velocity is 55 feet/year. The groundwater'
appears to discharge to Little Black Creek.
The soils at the site are classified as the Rubicon, Grayling,
and Kerston Soil Series. Natural soils. appear to have been
disturbed, replaced, or covered with varying thicknesses of
dark brown gravelly sand fill. Sediment near the bank cf
Little Black Creek were also covered with 5 to 9 feet of
gravelly, sandy fill material.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A) Industrial History
Electroplating operations were conducted at Peerless Plating
from 1937 to 1983. The facility was constructed in 1937 and
established as a platinq operation by Harvey Kroeze and John
Niemeyer. In 1952, the business was acquired by John Gifford
who operated it for 25 years, then sold the plating operation
and later the land and building to Scott Musselman. Mr.
Musselman operated the facility until its closure in 1983.
Electroplating operations and processes conducted at Peerless
Plating included copper, nickel, chromium, cadmium, and zinc
plating, as well as associated activities such as burnishing,
-------
FIGURE 1 - SI~E LOCA~ION
C~EI<
APPLE AVE.
-
.fBR(
(j!J
MUSKEGON
COUNTY
AJRPQRT
SQ.RCE: USGS
o
112
SCALE .
I
2 MILE
-------
2
pOlishing, pickling, oiling, passivating, stress relieving,
and dichromate dipping. These processes required the use. of
toxic, reactive, corrosive, and flammable chemicals.
Throughout Peerless Plating's history, process wastes with pH
extremes and high heavy metal concentrations were discharged
into seepage lagoons at the rear of the facility.
B) state Enforcement Actions
In 1972, a Stipulation was signed by the Michigan Water
Quality Commission (MWQC) , requiring Peerless Plating to
monitor its waste discharge daily.and to establish a schedule
for insta.llation of a treatment system to meet specific
effluent guidelines. In 1975., the owner was issued a "Notice
of Noncompliance and Order to Comply," indicating violation of
all aspects of the 1972 Stipulation.
In 1976, the Stipulation was superseded when the MWQC issued
a State Permit to discharge, requiring Peerless Plating to
meet reduced effluent limitations and to construct appropriate
treatment facilities. Peerless Plating violated this Permit
by failing to meet effluent. guidelines, by failing to
construct appropriate treatment facilities, and by failing to
maintain a daily sampling and analysis program.
Subsequently, a suit was filed by the Michigan Department of
Natural Resources (MDNR) and the MWQC, enjoining Peerless
Plating from further discharges and requiring compliance with
the MWQC permit.
In 1976, MDNR reported high cyanide concentrations in Little
Black Creek sediments adj acent to the seepage lagoons. A
Water Quality and Biological Survey of Little Black Creek was
conducted in 1977 by the MDNR Water Quality Division.
Extremely high concentrations of heavy metals in stream
sediments and surface water were attributed to seepage from
Peerless Plating waste disposal and to several known off-site
sources.
In 1978, the MDNR and the Michigan Attorney General's office
filed suit against Peerless Plating for environmental
contamination.
In 1979, a hydrogeological study was conducted to define the
extent of groundwater and surface wa~er contamination. This
study resulted in the installation of 7 monitoring wells
(Figure 2). Cadmium and cyanide were detected in groundwater
samples taken from the monitoring wells. In 1980, the seepage
lagoon sludges were removed and disposed of, and the excavated
lagoon area was backfilled and capped.
-------
.-.
)-
LEGEND
.. MW-3
MW-5
FXGURE 2 - HYDROGEOLOGXCAL STUDY MONITORING WELLS
..
I
I!IID .
I
DYMACO :
BUILDING I
?~._._-_.-
PLATING I
(U'LO'iG I :
. I .
. +- .. ~W-2
L 4W-6 )
W-3
HARDW ARE MW-4t
BUILDING ..
aLACK
I-
LU
I.U
a::
l-
I/)
)0-
l-
t-
LU
(j
/r-
SHERMAN STREET / / / .
~lBOX
.
I
~
I
-.
CREEK
(
I
CULVERT I
-+-...
MEINERT STUDY MONITORING WELL O' SO'
SCALE ~
100'
N
200'
\
-------
"
3
In 1982, the MDNR Water Quality Division conducted a second
study of sediment, surface water, and biota in Little Black
Creek in the vicinity of Peerless Plating. The resampling was
conducted to determine if removal of contaminated sediments
was necessary. Cadmium concentrations in both water and
sediments remained high, although substantial reductions
occurred since 1977. Except for cadmium, heavy metals in
sediments near Peerless Plating were not markedly different
from concentrations upstream or downstream. Leaching of
plating waste contaminqnt~ from the seepage lagoons was
concluded to be greatly reduced. Improvement in stream
quali ty was indicated by the increased number of general biota
categories. The report recommended that discharge of cadmium
to Little Black Creek from Peerless Plating via groundwater
should be reduced to permissible levels of 0.32 ug/l or less.
Sediment removal from Little Black Creek was not recommended
because upstream sources and urban runoff continued as
significant heavy metal sources, and sediment removal would
eliminate most available animal habitat.
In 1983, the MDNR conducted an investigation into the
operating practices at Pee.less Plating and sampled materials
in and around the plant. The MDNR found that treatment
facilities still had not been upgraded adequately, and
discharge limitations were still being exceeded for chromium,
cyanide, cadmium, and zinc. The MDNR determined that manholes
inside the building did not connect to the sanitary sewer or
plant treatment system, so wastes were discharged directly to
the ground. MDNR files indicated that drummed wastes had not
been removed from the building since 1980, and that materials
on the ground outside the building or ground surface material
contained high levels of heavy metals.
-
In 1983, the MDNR and the Michigan Attorney General again
filed joint suit against Peerless Plating. The County of
Muskegon Waste Water Management System blocked Peerless
Plating's discharge due to failure to meet County ordinance
discharge limitations.
In June 1983, Peerless Plating closed as a result of
regulatory actions, labor problems, and financial
difficu .=ies. The owner declared bankruptcy. The plant was
abandoned with plating solution, raw materials, and drummed
wastes staged throughout the building. The building was not
. well maintained, and access was generally unrestricted.
Subsequently, personnel from Muskegon County Civil Defense and
Michigan Department of Public Health, Division of Occupational
Health detected hydrocyanic acid gas in the facility
atmosphere. Additional site investigations by the Muskegon
County Health Department and the MDNR verified the presence of
cyanide gas.
-------
4
C) Federal Enforcement Actions
state agencies contacted the u.s. EPA Region V Spill Response
Section, requesting that the site be considered for emergency
action under the Comprehensive Environmental Response,
compensation, and Liability Act (CERCLA). In fall 1983, a
Site Assessment was conducted, and the On-Scene Coordinator
determined the Peerless Plating facility to be an immediate
threat to human health and the environment.
From September 6 until October 7, 1983, the U.S. EPA carried
out an Emergency Response Action at the site. Objectives of
the emergency response action included the removal and
disposal of hazardous waste and decontamination of the
facility. This action resu.l ted in the removal of 37,000
gallons of hazardous liquids including: sulfuric acid, nitric
acid, hydrochloric acid, chromic acid, cyanide plating
solution, . chromium plating solution, and trichloroethylene
(TCE). Lagoons were drained; soil was removed from lagoon
areas; soils and sludges were removed from the building
interior; vats, lines, tanks, sumps, debris, floorboards, and
walls were decontaminated; sewer lines were sealed; virgin and
proprietary chemicals were removed; and on-site neutralization
of cyanides and nitric acid occurred.
In 1984, the U.s. EPA conducted a Preliminary Assessment and
reported that groundwater was contaminated with TCE,
tetrachloroethylene (PCE), and chloroform, and that surface
water and sediment in Little Black Creek were contaminated
with heavy metals. The building structure was reported to be
unsound, and site access restriction was inadequate.
Recommendations included performing a site inspection to
confirm whether all on-site liquids and containers had been
removed during the 1983 emergency response action and to
assess groundwater, soil, and surface water contamination.
The Peerless Plating Site was identified for U.s. EPA Remedial
Planning/Field Investigation Team (REM/FIT) attention by a
Preliminary Assessment Form submitted by the MDNR. A site
Inspection was conducted in 1985 by Ecology & Environment,
Inc. The report mentioned the following potential hazardous
conditions: a high probability for a release of contaminants
to the groundwater, contaminated sediment and surface water in
Little Black Creek, cyanide gas release from on-site sludge,
fire/explosive conditions from incompatibility of constituents
remaining on-site, and private well contamination.
Also during 1985, a hydrogeologic study was conducted under
the direction of FIT personnel. This involved the
installation of 7 monitoring wells and soil borings on the
Peerless Plating property and testing the hydraulic parameters
of the aquifer. The monitoring well system and the faucet on
-------
5
an adjacent property were sampled for priority pollutants in
1985. Results indicated contamination of groundwater by
cadmium, chromium, copper, nickel, cyanide, TCE, and trans-
1,2-dichloroethylene (trans-1,2-DCE). Metals were found in
all wells including upgradient wells. Benzene, ethylbenzene,
xylenes, and naphthalene were found in wells around the center
of the site. Cyanide was found in all samples except that
from the off-site faucet. The distribution of the data with
respect to the hydraulic gradient was concluded to confirm
groundwater contamination as a direct result of methods and
processes employed at Peerless Plating.
In 1986, the site was scored according to the Hazard Ranking
System. The Peerless Plating site was proposed for inclusion
on the National Priorities List (NPL) in 1988.
In May 1989, U.S. EPA issued a work assignment to Donohue &
Associates, Inc. to initiate a Remedial Investigationl
Feasibility Study (RI/FS) to investigate the nature and extent
of contamination at the Peerless Plating Site.
In August 1990, Peerless Plating was listed on the NPL.
On March 13, 1990, U. S. EPA conducted another emergency
removal action to remove and dispose of the liquids and
sludges contained in an enclosed above-ground tank on the
site. Approximately 2,500 gallons of liquids with elevated
levels of heavy metals and cyanide were removed. A portion of
this removal action was performed by a Potentially Responsible
Party (PRP) and involved encapsulation of an asbestos oven in
the Peerless Plating building and installation of a fence for
site security.
The RI w.as conducted from October 1990 to September 1991. The
characterization of the nature and extent of contamination
posed by hazardous wastes at the site was performed through
sampling and analysis of the soil, the groundwater from
existing and newly installed monitoring wells, and the surface
water and the sediment from Little Black Creek. The results
indicate organic and inorganic contamination of the soils and
groundwater.
The FS, which developed and evaluated the remedial action
alternatives for the.site, was completed in June 1992. Three
groundwater alternatives and five soil alternatives we:-e
evaluated.
-------
6
III. COMMUNITY RELATIONS
u.s. EPA held a kick-off meeting on August 15, 1990 for the
Peerless Plating site. A dozen people attended the meeting.
People were primarily interested in the following: when the
site would be cleaned up so that it could be used for
expanding businesses, how the Peerless Plating property
affects the neighboring properties, and the affect of Peerless
Plating on Little Black Creek and Mona Lake (into which Little
Black Creek flows). The citizens were informed of what u.s.
EPA would be doing during the RIfFS and that many of their
questions would be answered by the study.
As part of the community relations program, an information
repository was established near the site at the Norton Shores
Branch Library.
u.s. EPA held another public meeting on December 10, 1991 to
discuss the results of the RI. Eighteen people attended the
meeting to learn about the organic and inorganic contamination
of the soil and groundwater at Peerless Plating.
u.s. EPA notified the local community, by way of the Proposed
Plan, of the preferred remedial alternative for the Peerless
Plating si te.' To encourage public participation in the
selection of the remedial alternative, u.s. EPA scheduled a
public comment period from July 10, 1992 to August 10, 1992.
In addition, u.s. EPA held a public meeting on July 22, 1992
to discuss the Proposed Plan. U. S. EPA . s responses to
comments received during the public meeting and to written
comments received during the public comment period are
included in the Responsiveness Summary.
The public participation requirements of CERC~ Sections ~17
and 113(k} (2) (B) (i-v) have been satisfied.
IV.
SCOPE OF RESPONSE ACTION
This ROD addresses the final remedy for the site. The threats
posed by this site to human health and the environment are
contaminated soil and groundwater. The contaminated soils,
which are the principal threat at Peerless Plating, will be
treated and disposed in an off-site licensed hazardous waste
facility. The contaminated groundwater, which is a primary
risk at the site, will also be treated. The treated water, .
which will meet the substantive National Pollution Discharge
Elimination System (NPDES) discharge requirements, will be
discharged to Little Black Creek.
-------
7
v.
SITE CHARACTERISTICS
The RI, consisting of on-site scientific studies and
laboratory analyses to deterinine the nature and extent of
contamination at the site, has been completed. RI activities
were conducted from October 1990 to July 1991. The field
activities included soil sampling and analysis, soil gas
investigation, hydrogeologic investigation, installation of
monitoring wells, groundwater sampling and analysis, and
surface water. and sediment sampling and analysis. Lake
Michigan supplies the drinking water for, residences and
businesses within a three mile radius of the site via two
municipal off-shore surface water intakes. There are no
private wells that supply drinking water within a one mile
radius of the site. The results of the RI are summarized
below.
A) Nature and Extent of contamination
Surface Soils
A total of 31 surface soil samples were collected from the 0
to 6 inch depth (Figure 3). This includes 12 samples around
the building perimeter, 6 samples from the parking lot, and 13
samples from the vegetated areas of the site. The samples
were analyzed for inorganic parameters only.
Ten inorganic compounds were detected above the local
background level in the soil samples including: arsenic (0.68
- 14 mg/kg), antimony (5.9 - 15 mg/kg), beryllium (0.25 - 1.50
mg/kg), cadmium (0.69 - 11,400 mg/kg), chromium (20.0 - 1,480
mg/kg), copper (20.3 - 22,300 mg/kg), lead (9.9 - 817 mg/kg),
nickel (20.3 - 7,240 mg/kg), zinc (28.1 - 10,100 mg/kg), and
cyanide (2.0 - 418 mg/kg).' Background levels are presented
in Table 1. A comparison to background levels indicates that
the detected inorganic compounds exceed levels considered
naturally occurring. Other inorganic analytes were detected;
however, they are either considered essential nutrients or
were not found at levels significantly above background.
cadmium, nickel, and zinc concentrations were found to be
significantly higher than the background levels. These three
compounds were selected as indica tor parameters to assess
potential contaminant sources and to delineate contaminant
migration pathways at the site. Figure 4 presents the surface
soil concentrations for these compounds. Inorganic
contamination of the surface soil appears widespread
throughout the site. Elevated concentrations around the
building perimeter, within the former seepage lagoons, and
along the southern edge of the property may be indicative of
-------
FI:GURE 3 - SURFACE SOJ:L SAMPLI:NG LOCATIONS
.
I
.
I
'"
,
.-.
.-- I
GS-I
DYMACO
BUILDING GS-7-, :-
~
~
~
c,:)
1-
(
I
/...../
/
SHERMAN' STREET / / V /
~ Laox
....
CULVERT +-
N
LEGEND
. SURFICIAL <0-6-) SOIL SAMPLING LOCATION
CS-25
O' SO'
SCALE ~
100'
200'
Ii
-------
"
TABLE 1 - BACKGROUND INORGANIC COMPOUND CONCENTRAT~ONS.
COMPOUND
CONCENTRAT~ON (mq/kq)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
3770.00
7.00 u
1.70 j
12.60 j
0.29 u
0.84 u
109.00 j
2.20
2.20 j
0.94 u
0.51 u
2650.00
3.20
302.00 j
17.30
0.09 u
1.80 u
86.40 j
0.31 u
1.20 u
22.90 u
0.43 u
4.80 j
12.40
Notes:
Background .data from the Bofors Superfund site RI, which is in the same
area as Peerless Plating.
j = Valu.e reported represents an estimate as the value is above
instrument detection limit, but below contract required
detection limit.
u = The compound was analyzed but not detected. The associated
numerical value is the samplE quantification limit.
-------
1000 N
...
I
1500 N
GS-19
GS-2J - .
GS-24 -
t- ,
W
W
0:
t-
1/1
>-
t-
...
W
U
HARDWARE
BU I LI)I NG
- -I -._- -HO-
SHERMAN STREET
1-
,
C
GS-26
- GS-21
/ /
//
/t
L-/
BOX
CULVERT
...
I
'"
--r~ "
LEGEND
.S5"2
.
&5-6
c=' ':J
LACOON BORINC
SURF ICIAI. SOli. AND
SOIL GAS ::iAMPLING
LOCATION
APPROXIMAll lXllNI
OF FORIA£II :>E[I'A(;[
LACOON
CONCENTRA T 'ON C Mg~f!lLl!!NCE
C"""" NIa1001
CREEK t
D
I!
II
.
.
o
~
II
.
.
<>
~
~
.
.
NotES.
I. FOR A COI.IPlEtE LIStiNG Of
CONTAMINANTS AND CONCENTRAtiON
LEVEL". REfER TO APt'EI«JIJI C.
tABLE C-I.
2. COlleENiliA liON IfANI;t ~ IIII'I( IlU
ARE REPRESlNI AliVE 01 till
o TO i-INCH SAMPLING INtERVAL.
~'JO'
SCALE r-.-
1000 N
60'
120'
I
<;>
hJ
H
Ci1
~
toJ
olio
m
5
o
toJ
m
o
H
tot
o
o
~
I
~
H
o
~
D1
N
-------
8
several source areas of inorganic contamination. The most
likely sources are the building and materials beneath the
building, areas in the vicinity of the building, and areas in
and around the former seepage lagoons.
Subsurface Soils .
A total of 32 subsurface soil samples were collected from six
locations within the former seepage lagoons and were analyzed
for inorganic parameters. Samples were collected at intervals
above (0 to 4 feet), at (5 to 6.5 feet), and below (6.5 to
13.5 feet) the water table. Figure 5 presents the sampling
locations.
The inorganic compounds detected in the subsurface soils
included: arsenic (0.44 - 2.2 mg/kg), antimony (5.9 mg/kg),
beryllium (0.24 mg/kg), cadmium (0.92 - 1,300 mgjkg) , chromium
(2.0 - 1,280 mg/kg), copper (0.92 - 44.8 mg/kg), lead (0.53 -
76.1 mg/kg), nickel (1.2 - 16.5 mg/kg), and cyanide (0.78 -
788 mg/kg). These compounds were also detected in the surface
soil samples. The subsurface soil concentration ranges for
cadmium, nickel, and zinc are presented in Figure 6, above the
water table, Figure 7, at the water table, and Figure 8, below
the water table. As for the surface soils, these three
compounds were selected as indicator parameters to assess
potential contamination sources and to delineate the migration
pathway of potential contaminants at Peerless Plating. It can
be seen that inorganic contamination above background levels
exists within the lagoon areas and is persistent both above
and below the water table. In addition, inorganic
concentration ranges appear to be highest below the water
table and the lowest at the water table. However, the
concentration ranges of inorganic compounds in lagoon samples
were less than those of surficial samples.
Soil Gas survey .
A shallow soil gas survey, 3 to 4 feet deep was conducted at
the same locations as the surficial soil sample collection.
Gas chromatographic analysis of collected soil gas samples
detected benzene (1.8 parts per billion (ppb», 1,2-DCE (1.7 -
10.7 ppb) , ethylbenzene (203.3 - 5,828 ppb), and TCE (1.0 -
717.10 ppb). . Ethylbenzene was frequently encountered in
ambient air blanks at concentrations similar to soil gas
samples. Therefore, the results for this analyte are suspect.
In general, volatile organic compounds (VOCs) were detected
along the south and east walls of the building and along the
southern end of the property. This contaminant distribution
-------
/ 7
/
SHERMAN STREET / /
0Leox CULVERT I
-t--.
FLGURE 5 - SUBSURFACE SOLL SAMPLING LOCATLONS
-
I
,,.. ,
g~~LAD~~GpE~RLES:~\ l~_2- . ~ -<
PLA T ING '-~'-\--.----~~-3
I e~s'~~G Ii. ...---:!
If-\-ii--..~~~-~----------' !
.------.- I
.
I
I
I
I-
LU
LU
c::
l-
V)
>-
l-
I-
LU
<.:)
(
I
.-.
]-
LEGEND
. . LAGOON SOIL BORING
ss-~
,-------.-
. 0
. .
--------.'
REPORTED EXTENT OF
FORMER SEEPAGE LAGOONS
O' 50.
SCALE ~
.
J
~
I"
aLAC" I
CREEK
N
100'
I
200.
I
-------
1000 N
+
1500 N
...
I
I
DYMACO
BUILDING
SS-I- 1-SS-2
~E~~T~~~-._.- -'-- ~._-~-'I 55-4
JBUILDING"' ( f -~SS-]
~ l II~~!
5S-6 --ID it -.. - -~ I
~ - r-SS-5 !
L- -'I) I
i i
.
I
.
I
.
I
I
I
"
t-
lLI
lLI
0:
t-
V)
>-
t-
t-
W
CI
HARDWARE
BUIU11NG
l...
SHERMAN S IREET
// /
/~
L-/
BOX
CULVERT
c
...
~
~l"" "_lEGEND
. 55-2 LAGOON BORING
~
CREEK
--1
'=-==1
APPROXIMATE EXTENT
OF FORMER SEEPAGE
LACOON
CONCENIRA nON U.lgLtaLIlANGE
C_ILII NIall 1,';;;-
I-50
51-100
.101-500
501-1000
)1001
o
~
It
II
.
o
~
~
.
.
D
I!J
II
.
.
NOI ESI
I. fOR A COUPLE IE LIST tNG OF
~~~~~~I~~\~ 'TN~ CppONCENTHA liON
taBLE C-2. A EI«)III C.
2.~~~~~~~:;1~: r::.~~SSIOEPIC'EO.
WITHIN T~ 0 LEVELS
INtERvAL -4.0 FOOT S'''''L ING
0' 30' 60'
SCALE ~
120'
,
1000 N
~
H
Q
~
t'!t
0\
m
:iJ
(II
J
o
t'J
m
o
H
ti
o
o
I
H
o
~
m
N
t
~
=
toil
f3
~
~
ti
toJ
-------
1000 N
1-
1500 N
.SS-2
S~I~_{: jfF::::
--
l-
I-
W
l.)
~HERMAN STREET
C
I
/ /
//
/t
L-./
BOX
...
~
'"
I"". LEGEND
.SS-2
LAGOON BORING
C =- -=J
APPROXIMATE EXTENt
OF FOR~ER SEEPAGE
LAGOON
CONCENTRATION IMgLfgtEANgL
CAOWIW HICI<£l IINC
I-50
51-100
101-500
501-1000
)1001
o
(!
CI
.
.
o
~
~
.
.
D
IS
II
.
.
NOlES.
I. FOR A COIolPlHE LIStiNG OF
CONJAIoIINAIES AND CONCENIRA liON
LEVELS, R£FER 10 AI'PENDlk C.
TABLE C-2.
CREEK
2.CONCENTRAIION RANGES DEPICTED
REPRESENT THE HICHES. LEVELS
W"HIN TI£ 5.0-10 6.5-F001
SAIAPLING INTERVAL.
.- --.---
CULVERT
~. 30' 60'
SCALE ~
1000 N
120'
I
hj
H
Q
~
t'Ii
~
(/1
:;)
fn
~
=
n
t'Ii
fn
o
H
t4
n
o
tIS
I
H
o
tIS
m
N
»I
t-:)
~
t3
t-:)
~
t4
t'Ii
-------
1000 N
!-
1500 H-
t-
W
W
a:
t-
VI
>-
t-
t-
W
U
SS-2
SS~I~\l( -~i:jffJ; ::::
I (l-~--- I
SS-6 - - . i
~=~SS-5 !
I
.
I
.
I
.
I
I
I
.
...
I
DYMACO
BUILDING
PEERLES
PLATING
BUILDING
SHERMAN STREET
C
I
/ /
/ /
/t=
L-/
BOX CULVERT
...
I
lit
["... LEGEND
.SS-2
lAGOON BORING
C :. :'1
APPROXIMATE EXTENT
OF FORMER SEEPAGE
LAGOON.
CONCENTRATION IMQ/!;gl HANGE
C-'" HICIEL ZINC
I-50
51-100
101-500
501-1000
)1001
o
~
.
.
.
o
I!
II
.
.
o
~
()
.
.
NOTES.
I. FOR A COMPLETE LISTING OF
CONTAt.AINATES AND CONCENTRAlION
LEVELS. MFER TO APPENUIX C.
TABLE C-2.
CREEK
2. CONCENTRATION RANGES DEPICTEO
REPRESEHT TtE HIGHESI LEVEtS
Ir"HIN THE 6.5 TO 13.5 FOOT
SALIPLING INTERVAL.
~. 30' 60'
SCALE ~
1000 N
120'
I
hj
H
iii
~
t'!I
CD
fa
:;)
m
~
o
t'!I
m
o
H
~
n
o
~
I
.H
o
~
m
N
b2
tIJ
~
o
a1
~
~
tIJ
Sd
8
t
t4
t'!I
-------
9
generally correlates to the inorganic contamination found in
surf icial soils and provides supporting evidence that the
building and the former lagoon areas are potential sources of
contamination at the Peerless Plating Superfund site.
Groundwater
Groundwater samples from monitoring wells were analyzed for
VOCs and inorganic analytes on the CLF Target Compound List
(TCL) and TAL lists, respectively. In addition, groundwater
samples were analyzed for water quality chemistry including
chemical oxygen demand (COD), total suspended solids (TSS),
total dissolved solids (TDS), alkalinity, chloride, sulfate,
and nitrate plus nitrite.
Inorganic Analysis:
A total of ~8 monitoring wells were sampled, including two
background wells hydraulically upgradient to the site. . Figure
9 presents the monitoring well locations. Inorganic compounds
detected in groundwater samples were generally the same as the
inorganics detected in surficial soil samples. Several
compounds detected above the corresponding background levels
include: arsenic (4.6 ug/l) , cadmium (5.1 - 5,460 ug/l),
chromium (8.4 - 29.~ ug/l), copper (0.92 - 44.8 ug/l) , lead
(1. 1 6.4 ug/ 1), and nickel (9.4 598 ug/l). other
inorganic contaminants detected in groundwater include cyanide
(10 - 22 ug/l) and barium (7.9 - 71 ug/l). However, cyanide
was also found in one of the b~ckqround wells at 1~ ug /1.
When on-site levels were compared to the background levels, it
appears that the on-site groundwater cyanide concentrations
may be from off-site sources. Barium was detected in all
samples at relatively consistent concentrations. However,
barium was also detected in the background wells at 49 ug/l
and 32 ug/l. These background levels, coupled with barium
detected in surficial soil, indicate that barium in
groundwater at the site is naturally occurring.
Figures 10, 11, and 12 present groundwater concentration
contours for cadmium, nickel, and zinc, respectively. As
described for surficial soils, these compounds were selected
as indicator parameters. The figures suggest that inorganic
groundwater contamination is prevalent throughout the southern
half of the site with the highest concentrations near the
former seepage lagoons. The contaminants persist with
decreasing concentrations in a southeast direction toward
Little Black Creek. Cadmium, nickel, and zinc contamination
was not detected southeast of Little Black Creek. contaminant
flow is parallel to groundwater flow. Comparison between
contaminant levels in shallow water table wells and deeper
piezometers indicates that contaminant levels are consistently
higher in the water table wells, suggesting that contamination
decreases with depth. Sources of contamination exist in the
-------
,ofT-O I A-$-,
::1Z-0IB '
-.
.')
r
LEGEND
-$-wr-02A
PZ-028
-+M-1401-3
-+ MW-3
. SG-I
FrGURE 9 - MONITORING WELL LOCATIONS
.
I
.
I
or
3C8 .
1_. ,
r M-140I-2..."
, \ r"-'40'-1
---~-_.,..-.--
... ... I ,
.~%z:84~
.!
~-1401-5
~ ~W-2
~L "-MW-6 1114,1401-4
-1401-3 I
, W-3
MW-~
PZ-OSA .-
PZ-oSS"-
PZ-OSC .
// ../
STREET / (
'---/
BOX
DYMACO
BUILDING
MW-S
-1<401 -
I-
UJ
UJ
a:
I-
'\11
>-
l-
I-
UJ
<.:)
SHERMAN
(
I
CULVERT +-.
..
N
RI MONITORING WELL NEST
REM/FIT MONITORING WELL
MEINERT STUDY MONITORING WELL O. SO.
STAFF GAUGE SCALE~
100.
I
200.
] .
-------
WT -OIA .
PI-OIB
.",=+
1500 N-
M-1401-7
WT-02A
PZ-02B -
12231
1.4-1401-6
IIUOI
...
I
~
od
---~-"" "
LEGEND
---.-
---
1.4-1401-2 -
'\.-- j-- "- "'., -, ""
~ ~Em~~r------~~-: i 50"
" '-7": - - .......--,- PZ-O~
J~ ~-,,~ . ,54601 ,
-- E--....-< ---, I I ,
--....... ,..:::-..J..- \,. I / . ,
/",- ." "-_J 7" /! . \
I . ,. '.....-. 0"""/ '" 11.4-1401-5 I
': I '",-- - L - _)00 t,1 !\ It'
\' -1.4-401-4 I
\ " I I/fl80 1 /
\ "--1.4-1401-3 I I //
, ',2g001 ,,0/ I I
..... ~v I
\ ,~~~~~~~:--[-=~/// ~
..... -\- .\000....
~=--=-=- - - ;Z-05A ob "oJ .
~ . PZ-06A
PZ-058 PZ-06B
PZ-OSC u-- el:QIi~---
------------- ... -- ._------------'85JII /
/ /
~lBOX CUlVERT---
t-
W
W
0:
t-
111
>-
t-
t-
W
l:)
C
1
DYMACO
BU1LDING
.../
CREEK
SHE RMAN S 1 REE T
...
. WT-OU
+PZ-02A
"""-140117
RI WAIER TAU! E WEt L
RI PIEZOME TER
REMIF IT
MONI TORING WELL
ISOCONCENlIIA T ION LINE
lua/ll
-- -1000 --
112301
CONCENTRATION IUc;j/11
C-:-:I
APPROXIMATE EXTENT
OF FORMER SEEPAGE
LAGOON
NOTES.
I. CONTOURED CONCENIRATION LEVEI.~
REFLECT DATA COlLECTED
FROM WAtER TABLE WELLS
AND 5HAllOYI PIElOMETER~
SCREENED NEAR THE WATER IAIILE.
o' 30'
SCALE ........
60'
1000 N
120'
I
I>j
H
G1
~
tIJ
...
o
Q
:d
o
I
.:J
tIJ
:d
(')
o
tIS
(')
!
H
o
tIS
o
o
~
o
~
m
I>j
o
N :d
o
~
~
-H
~
-------
WT-OIA $
PZ-OIB
ISoo N
III
I
M-I<401-2
1101
DYMACO
BUILDING
M-I<401-7- ~
WT -02A
PZ-02B -- -------
'571 ._~
1000 N
+
t,A-1<401-6
II/51
I-
W
W
a:
I-
VI
>-
l-
I-
W
C)
c-
I
"'-1401-'
PEERLES~~----/~:
PLATING I ---------- I
BU I L D I NG~. f - - -..=--=::: -'- t -;';:0'4~
100 -\~::;-- - -...' t- Pl-04B'
.- - '" 0"'" "'~'" --- \\. 159111 '
---- ;-~~~~O'" ....pO /11 ~ \
- -- --;.:':J- l......._......e-:/" \
r.... - ..00 -" - - / .
, - - ':--...:---- -]0"'-":-- ""M-1401-S I
----- -100- . ,
I I
. I
M-\<401-4 /
'1'5111. //
I .,-
. /
I /
. /
/
/
/
/
....
....
00-
__...1
I
\
\
\
,
,
,
,
,
'HARDWARE
Buil"btNG.-
-l__-
M-1401-]
1t9JI
.$
P2-06A
PZ-068
___fl:2i'
PZ-OSA .
PZ-OSB
pz-osc
-----;iiI/ /
/ /
/t
L-/ .
BOX
SHERMAN STREET
CULVERT
III
I
lit
1'--
LEGEND
. WT-02A
. PZ-02A
+"':,'461-7
RI WATER TABLE WEll
R' P,EZOMEIER
REMIf IT
MONITORING WE.ll
ISOCOtlCENTHATION LINE
lug/II
.... -.00--
1/58'
CONCEN! RA TlON C ug/l )
c.-: -='1
APPROXIMATE EXTENT
OF FORMER SEEPAGE
LAGOON
CREEK
NOTES.
t. CONTOURED CONCENTRATION LEVELS
REFLECT DATA COLLECTED
FROM WATER TABLE WELLS
AND SHAllOW PIEZOMETERS
SCREENED HEAR THE WATER !ABLE.
~. 30' 60'
SCALE ~
1000 N
120'
I
hj
....
ca
~
t'!J
I-A
I-A
I
Ii)
:d
o
~
e
f3
N
n
o
tz:
n
.~
e
H
o
~
n
o
~
o
~
(II
bj
o
:d
tz:
H
n
~
tIJ
tt
-------
WI-OIA.
PI-OIB
1000 N
~
1500 N
1.1-1401-1'
WI -02A
Pl-028 -
"460'
"'-1401-6
IItSI
III
I
1.4-1401-2-
156 ,
DYMAC~I
BUILD~
I-
W
W
a:
I-
VI
>-
l-
I--
W
t.:)
- "'-1401-1
"\ PEERLES -----I-~"
PL A T I NG - - - .:- = .=::. - .t
B 0 NG (- - - - - -,- ,.. - ~oo
- = = - - U I L I - f:; - ;; -:. -::::. :: {"W""'~A
..... -..... :: -- - 100 100- ...."" ""''''''...- "" .:1.
\( \ -- -- - ------ ...~.o;..-7-~ ,P2- 8
\ ~ -- - - - - ::: iiioo: ~Ol- - - - - ... -:...... / , I . 'I J75 ~
'ib .... .:::- - - - [ 1/ / . I I I ,
" '':::::::::--- ----- -2000-t.~000'''' ~/I i' \
-. -..... - ~ - - - - - L - -"J ,,'I " " \
" .... - -::::: -, ... '" " M-1401-!i
0{ ... "",'..... .......... - JOOO'" "" / I
I '" ""","'" -.. ..M'IO'" " /'
, " , -. ~- /' II I
" \" ~ - 1000 - I 'I I
'-0. , q, M- 401-4 I
i'J ~ " IP16'
~ " ,
\ 1.t-14tU;- ~ - "" " I
\ ItUOI I I
\ ' I
\ / BLAC\(
HARDWARL' /
BUI~DING ' / '-J
- \ / ....
l__- "Pl-OSA. / 'oJ .
" Dl-OSS " Pl-OG.
""...." Pl-OG8
Pl-~ -------. fl:Qit
I I /
/ / ,00
I
o Laox
CULVERT
SHERMAN STREET
c
,
CREEK\-
11.1
~
...
-1500 N
LEGEND
-$ WT -02A
+Pl-02A
.1-.4-1401-1
... ~IOO- -
/61
C :. :'1
RI WA TER TABLE WELL
RI PIEZOMETER
REM/FIT
MONITORING WELL
ISOCONCENTRATION liNE
Cugll ,
CONCENIlIA liON 11J11/11
APPROXIMATE EXTENT
OF FORMER SEEPAGE
LAGOON
HOTES.
I. CONTOURED CONCENTRATION LEVELS
REflECT DATA CDLLECIEO
FROM WAIER TABLE WELLS
AND SHALLOY! PIEZO!.E IERS
SCREENED NEAR THE WATER TAIILE.
120'
I
hj
H
Q
~
t'.i
~
N
I
G')
Sd
o
~
=
~
tJ
N
o
o
I
H
o
!2:
o
o
~
o
~
m
hj
o
~
~. JO' 60'
SCALE ~
1000 N
N
H
~
o
-------
10
vadose zone and near the water table in and around the
Peerless Plating building and the former seepage lagoon areas.
Infiltration is the primary mechanism for the release of
contaminants into the groundwater. Little Black Creek is a
discharge zone for the site shallow groundwater and acts as a
hydraulic barrier preventing further southerly migration of
the site contaminants.
Volatile organic Analysis:
A total of 18 monitoring wells were sampled, including two
background wells. The monitoring well locations are presented
in Figure 9. VOCs detected in the groundwater include:
acetone (7 ug/l), benzene (3 ug/l), chloroform (1 - 4 ug/l),
1,1-DCE (3 ug/l), 1,2-DCE (total) (2 160 ug/l), ethyl
benzene (10 - 88 ug/ l), methylene chloride (1 - 3 ug/l),
toluene (1 ug/l), 1,1,1-tricholroethane (TCA) (3 ug/l), TCE (2
- 1900 ugfl), vinyl chloride (VC) (16 ugfl), and xylenes
(total) (160 ug/l) . ..
TCE, 1,2-DCE (total), and VC were found above their
corresponding maximum contaminant levels (MCLs) in the
groundwater samples. Concentration levels for these compounds
are presented in Figure 13. TCE was detected at significant
levels in two wells, WT-02A and M-1401-3, at 140 ug/l and
1,900 ug/l, respectively. TCE was detected in a number of
other wells at concentrations ranging from 3 ug/l to 25 ug/l.
However, TCE was also detected in field blanks a 7 ug/l and 3
ugfl. This sugges..',:3 that the lower TCE concentrations may be
the result of laboratory contamination. 1,2-DCE was found at
significant levels in wells M-1401-3 and WT-02A, at 160 ug/l
and 37 ug/l, respectively. vinyl chloride was found at one
location, M-1401-3, at 16 ug/l.
The locations of elevated levels of contaminants indicate that
sources of contamination exist in the vadose zone and near the
water table in, unl~ :~r and around the Peerless plating building
and the former seepage lagoons.
Surface Water and Sediment
Seven surface water and seven sediment samples "ere collected
from Little Black Creek and analyzed for 'l~~s and VOCs.
Sampling locations were chosen coincident with previous MDNR
sample locat:':>ns as shown in Figure 14. The results of the
inorganic anc:Jrganic analyses are summarized in Tables 2 and
3, respectiv;;;.l.y. The data suggests that the site is a
potential contributor of zinc, lead, copper, cadmium and
chromiu~, as these contaminants were found in Little Black
-------
WT -OIA .
PI-OIB
DYMAC~
BUILDI~I
""-1101-1
f ,TC£ 5'
PEERLESSJ------ ----- .--:
PLATING I ------, I
BUILDING -, ( J !
----.J - - - - _7- t- WT -01A
~ . nl:E31
1--1 !
L__J !
tt.A-1401-5
. ITcr..,
I
.
t.A-\101- 4
'fCf JI
I
I
...
I
.500 N
t.4-1101-1 "\
01-0" - ~ I
(rce '''0\ ~
It .R-OCE J1) -----.
t.4-I"OI-~
r TeE 11
\!.2-DCE 2
1000 H
~
t.4-1101-2
trCE 25'
t-
W
w
0:
t-
1/1
>-
....
t-
W
C)
C
1
HARDWARE
BUIJ-DING
--1_-
SHERMAN STREET
- 1,.4-1401-3
/TCE '" I /
//
I
0L.o.
CUL VER T
.PZ-06A
...
~
...
1-"" :EGEND
.WT-02A
+PZ-02A
..t.4-1101-7
+t.A-1101-1
(TeE IJ5 \
\! .I-OCE J7)
RI WAlEH TABLE WEU.
RI PIEIOME TER
REt.tlF I T
MONITORING WELL
TRIClILOII9E 1 HENE 11 CE)
conc luO II
1.2 DICHlOROETHYLENE
11,2 OCEI conc. IIJO/II
VINYL CltLORIDE
conc. luglll
c. -=. -=.'
APPROXIt.4ATE EXTENI
OF FORMER SEEPAGE
LAGOON
CREEK t
NOTES.
I. FIELO BLANK SHOWED 7uO/l TCE
~O' 30'
SCALE f--
- 1000 N
120'
I
60'
hj
H
Q
fa
tIj
....
W
o
:d
t
H
o
o
o
t2S
o
B
e
H
o
t2S
tIJ
H
-t2S
Q
:d
o
~
N =
t-i
tIj
:d
-------
FIGURE 14 - LITTLE BLACK CREEK SAMPLING LOCATIONS
...
~
<.
5HSIUH BlV1).
flJttJJOIIIttt It ~
-
N
~
9
I N.I
.
-------
TABLE 2 - INORGANIC ANALYSIS OF LITTLE BLACK CREER
Concencracion In Surface water (1.12:/1)
Sampiine: Locacion+: ---L- ...-L ~ .-!:- .-i..- -L.. ~
Compound
Barium 48.9 46.4 36.1 37.5 46.7 37.8 34.9
~ickel ND ND NO NO ND ND ND
Zinc 20.2 i5..8 31.9 18.0 30.5 12.8 16.5
Cadmium ND 4.0 6.4 ND ND ND ND
Lead 2.1 1.1 5.3 2.6 9.4 2.4 1.0
Chromium 7.2 10.2 4.0 5.3 8.9 3.7 12.0
Copper 7.5 7.3 NO 4.9 7.1 3.7 5.5
-
Cyanide 2.0 ND NO ND 2.0 ~D ND
Concencracion In Sedimenc (me:/ke:)
Samoline: LocacionT: ---L- ~ ~ .-!:- .-i..- -L.. -1-
Coamound
5a~ium 26.4 51.6 19.3 . 7.7 53 12.7 8.7
Arsenic 1.0 6.3 1.1 0.67 2.2 0.63 1.2
Nickel 13.2 35 20.7 57 41. 2 ND ND
Zinc 4.4.3 258 61.6 37.7 108 21.8 17.7
Cadmium NO 8.2 9.7 230. ND NO NO
Lead 30.3 1270.0 126.0 22.7 155.0 13.3 7.9
Chromium 20.8 52.5 25.1 172 21.2 5.9 10.7
Copper 15.2 196 36.5 45.9 20.1 2.7 1.3
Cyanide NO ND 0.90 1.8 ND ND ND
--
+ Sampling locacion numbers correspond to Figure 14
ND - Not detected
-------
TABLE 3 - ORGANIC ANaLYSIS OF LITTLE BLACK CREEK
Concent:rat:ion In Surface Wat:er (ue:/l)
SamDlin£ Locat:ion+: .-l.. -L- ~ t. --2- -L -2-
-
COlJIt)ound
Acet:one 3 3 5 3 3 3 5
1.2-Dichloroet:hene
(Total) 5 6 7 7 ND 17 19
1.2-Dichloroechane 8 12 16 16 12 ND ND
l,l,l-Trichloroet:hene 6 9 13 13 9 ND ND
Trichloroet:hene 3 4 5 5 3 9 10
. .
Concencracion In Sediment: (ml!:/kl!:)
Samolin£ Locacion+: .-l.. -L- 3 ---L- 5 -L -2-
COlJIt)ound
A.cetone ND ND ND ND ND ND NO
l,2-Dichloroechene
(Total) 1 27 0.6 ND ND ND 1
l,l,l-Trichloroechane ND 1 0.7 2 ND ND NO
Trichloroechene 1 0.6 2 2 ND 0.7 NO
Tetracnloroechene 4 ND ND ND ND 4 NO
2-Bucane 7 ND ND ND ND 6 7
Toluene ND ND ND ND ND 0.6 NO
Carbon Disulfide ND ND ND ND 11 ND NO
Vinyl Chloride ND 21 ND ND ND ND NO
-
-
+ Sampling location numbers correspond to Figurel4
NO - Not Detected
-------
VI.
11
Creek. However, other contaminant sources exist upstream from
the site and appear to have contributed to this contamination
found in Little Black Creek near the site, as well as
downstream from the site.
SUMMARY OF SITE RXSK
As part of the RI/FS, a baseline risk assessment was conducted
to address the potential adverse impacts to human health and
the environment associated with the Peerless Plating Site in
the absence of remedial action. This assessment follows u.S.
EPA guidance for risk assessment as presented in Risk
Assessment Guidance for Superfund. Volume 1. Human Health
Evaluation Manual (Part A). Interim Final, EPA/540/l-89/002.
By definition, a baseline risk assessment is limited to
conditions assuming no corrective action will take place and
no site-use restrictions or institutional controls will be
imposed. The risk assessment determines actual or potential
risks or toxic effects posed by the chemical contaminants' at
the site under current and future use assumptions.
A) Identification of Chemica1s of Potentia1 Concern
The environmental monitoring data collected at Peerless
Plating during the RI were evaluated to identify which
chemicals detected at the site will be the focus of the risk
assessment. Some chemicals detected at the site are
considered essential nutrients to humans, e.g., calcium,
copper, iron, magnesium, manganese, potassium, selenium,
sodium, and zinc. Essential nutrients m~ not be of concern
to human health. If the estimated intake of an essential
nutrient did not exceed the Recommended Daily Intake for an
adult, the chemical was eliminated as a chemical of potential
concern.
The 25 chemicals of potential concern
groundwater are presented in Table 4.
in
soil
or
the
B) Exposure Assessment
Current PODulations
There is minimal current population exposure to contaminants
on or off the site. The impact of nearby workers due to
inhalation of fugitive dust is minimal. Lake Michigan
supplies the drinking water for residences and businesses
wi thin a three mile radius of the site via two municipal
offshore surface water intakes. The municipal water system
serves all residences and industries within a one mile radius
-------
TABLE 4 - CBEHICALS OF POTENTIAL CONCERN
Inoraanic comDounds
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Lead
Mercury
Nickel
Silver
Thallium
Vanadium
cyanide
Volatile oraanic ComDounds
Benzene
Chloroform
1,1-dichloroethene
1,1-dichloroethene (total)
Ethylbenzene
Toluene
1, 1, l-trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes . (total)
-------
12
of the site. There are no known private wells being used for
drinking water in the area.
Future PODulations
Currently, the site is an industrial property in an industrial
area. Although the area is presently zoned light industrial,
it is possible a residence could be built on the site in the
future. It is also assumed under this future scenario, that
a drinking water well would be installed into the. aquifer
beneath the site. Residents, adults and children, would be
exposed to the chemicals of potential concern in the drinking
water and in the soil.
Considering the current land use surrounding the site, it is
more likely that a potential future use scenario would be
construction of an industrial facility, with a drinking wa~er
well, instead of a residence. Occupational workers would be
exposed to the chemicals of potential concern via drinking
water and in the soils.
EXDosure Routes
The primary routes for exposures to contaminants from the
Peerless Plating site include the following:
* Ingestion of and dermal contact with contaminated soils
* Ingestion of and dermal contact with contaminated
groundwater
* Inhalation of VOCs from contaminated groundwater
only pathways that were considered complete were quantified in
the risk assessment. Some complete .pathways were .not
quantified because the exposure potential was considered to be
low. Dermal exposure to soil is not quantified because the
inorganic chemicals found in the soils generally have a very
low dermal absorption. Dermal exposure to groundwater is also
not quantified because exposure is limited to a very short
time period, e.g., while bathing, showering, and it is likely
that the dermal dose would be significantly smaller than the
oral or inhalation dose.
Risk Characterization .
Carcinogenic and non-carcinogenic health risks have been
estimated for the Peerless Plating site. The risks have been
evaluated for future residents and future workers with respect
to ingestion of contaminated soil, ingestion of contaminated
groundwater, and inhalation of contaminated groundwater.
-------
13
carcinogenic Risk:
carcinogenic risks from a site chemical are described in terms
of the probability that an individual exposed for his/her
lifetime will develop cancer due to that exposure. U. 5. EPA IS
Carcinogenic Assessment Group has developed cancer pqtency
factors (CPFs) for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of
(mg/kq-day) -1, are multiplied by the estimated intake of. a
potential carcinogen, in mqlkg-day, to provide an upper bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes underestimation of
the actual cancer risk highly unlikely. Cancer potency
factors are derived from the results of human epidemiological
studies or chronic animal bioassays to which animal to human
extrapolation and uncertainty factors have been applied to
account for the use of animal data to predict effects on
humans.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor for each
contaminant of concern. These risks are probabilities that
are generally expressed in scientific notation. For example,
an excess cancer risk of 1 x 10-6 indicates that an individual
has a one in one million chance of developing cancer as a
result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at the site.
The National Oil and Hazardous Substances Contingency Plan
(NCP) established acceptable levels of risk for Superfund
sites ranging from 1 in 10,000 (1 x 10-4) .t:o 1 in one r-' llion
(1 x 10-6) excess cancer cases. U.5. EPA generally emp... 3izes
the 1 x 10-6 risk level as a point of departure for dete:r.-,ining
remediation goals for remedial alternatives.
The excess lifetime
presented in Table 5.
cancer
risk for Peerless Plating
is
-------
14
TABLE 5 - EXCESS LIFETIME CANCER RISK
Population
Excess Cancer Risk
Future Adult Resident:
Groundwater Ingestion
Groundwater Inhalation
Soil Ingestion
Total
3 x 10-4
2 x 10-4
2 X 10-5
5 X 10-4
Future Worker:
Groundwater Ingestion
Soil Ingestion
Total
8 X 10-5
2 x 10-6
8 X 10-5
The excess lifetime cancer risk based on reasonable maximum
exposure in the future resident scenario exceeds the
acceptable risk range of 1 x 10-4 to 1 X 10-6. Thus, there is
an unacceptable carcinogenic risk at the Peerless Plating
site.
Non-carcinogenic Risks:
The potential for non-carcinogenic effects is evaluated by
comparing an. intake over a specified time period with the
reference dose (RfD), which indicate the potential for adverse
health effects from exposure to a chemical eXhibiting non-
carcinogenic effects. RfDs are conservative estimates of the
daily intake of a chemical, expressed in ~nits of mg/kg-day,
that is without risk of any adverse health effects in humans,
including sensitive individuals. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied to account for the use of animal
data to predict effects on humans. These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse non-carcinogenic health effects to occur.
Non-carcinogenic effects of a single contaminant in a single
medium is expressed as the hazard quotient (HQ), which is the
ratio of estimated intake derived from the contaminant
concentration to the contaminant's reference dose. By adding
the HQs for all contaminants within a medium or across all
media to which a population may reasonably be exposed, the
Hazard Index (HI) is generated. The HI provides a useful
reference point for gauging the potential signif icance of
multiple contaminant exposures within a single medium or
-------
15
across all media. Any Hazard Index values greater than 1.0
indicates the possibility that non-carcinogenic health effects
may occur.
The non-carcinogenic risks for Peerless Plating are presented
in Table 6.
TABLE ~ - NON-CARCINOGENIC RISKS
. .
poculation
Non-Cancer Risk
Future Adult Resident:
Groundwater Ingestion
Groundwater Inhalation
Soil Ingestion
Total (Hazard Index)
200
0.05
4
204.05
Future Worker:
Groundwater Ingestion
Soil Ingestion
Total (Hazard Index)
40
Jl.J..
40.7
Future Child Resident:
Groundwater Ingestion
Groundwater Inhalation
Soil Ingestion
Total (Hazard Index)
1
0.08
.L-
2.08
The Hazard Indices exceeds the value of 1.0 for all of the
future scenarios. Thus, the non-carcinogenic compounds at the
Peerless Plating site pose an unacceptable health risk.
Environmental Risks
In addition to human health risks at the site, the risks to
the environment were also considered. The impacts to the
environment result from the contaminated groundwater and its
discharge to Little Black Creek. If no action is taken at the
site, it will take many years for the contamination in the
groundwater to naturally attenuate (estimated at 21 to 63
years) . The groundwater discharge to Little Black Creek
contributes some contamination to the creek. However, because
of upstream sources, Little Black Creek is already
contaminated once it reaches the Peerless Plating site. This
makes any contaminant contribution from Peerless Plating
minimal.
-------
16
VII. CLEANUP STANDARDS
The u.s. EPA's program goal has been set forth in the NCP, 40
CFR section 300.430 (a) (1) (i), as follows: "The national goal
of the remedy selection process is to select remedies that are
protective of human health and the envi~onment, that maintain
protection over time, and that minimize untreated waste."
The contaminated media at the Peerless Plating site that will
be addressed by the remedial action are the soils and the
groundwater.
U.S. EPA' s groundwater cleanup policy is to return usable
qroundwaters to their beneficial uses wherever practicable,
within a reasonable timetable~ Under this policy, water that
is currently or potentially a drinking water source will be
remediated to contaminant levels appropriate to drinking water
use, generally Maximum Contaminant Levels (MCLs) established
under the Federal Safe Drinking Water Act. However, if, due
to the presence of multiple contaminants or multiple exposure
pathways, reduction of individual contaminants to MCLs would
not reduce the cumulative residual risk from groundwater
exposure to within the 1 x 10-4 to 1 X 10-6 acceptable risk
range, more stringent risk-based cleanup standards would be
required to ensure that the groundwater remedy is protective.
In such a case, the NCP provides that the 1 x 10-6 risk level
shall be used as the point of departure for determining
cleanup levels, unless site-specific circumstances warrant
other cleanup levels.
Similarly, with respect to soils, remedial action should
achieve acceptable exposure levels that are protective of
human heal th. For carcinogens, the ac;:ceptable range of
cumulative excess lifetime cancer risk is 1 X 10-4 to 1 x 10-6;
for non-carcinogens, a cumulative hazard index less than 1.
Under CERCLA, all remedial actions must at least achieve
cleanup levels required under "applicable or relevant and
appropriate requirements" (ARARs). MCLs and non-zero Maximum
contaminant Level Goals (MCLGs) under the Federal Safe
Drinking Water Act are ARARs for groundwater cleanup at this
site. With respect to the soil cleanup alternatives, Resource
Conservation and Recovery. Act (RCRA) Land Disposal
Restrictions (LDRs), including treatment standards, are
applicable to alternatives involving excavation and land
disposal of soils or treatment residuals containing RCRA
listed or characteristic wastes.
Michigan Act 307 Rules address the types of cleanup at sites.
The three types are Type A, Type B, and Type C. The
methodology for a Type A cleanup is based on background levels
or method detection limits for chemicals of concern. The
-------
17
methodology for a Type B cleanup is based on standardized
exposure assumptions and acceptable risk to determine cleanup
levels that do not pose an unacceptable risk to human health
and the environment. The methodology for a Type C clean~p
reviews the actual site conditions, e.g., the present and
future uses of the site, a site specific risk assessment, and
a cost effectiveness analysis.
Michigan Act 307, Type B cleanup criteria provide for the
calculation of risk-based cleanup standards at the 1 x: 10-6
excess lifetime cancer risk level for each carcinogenic
compound. The U.S. EPA has determined that because there are
multiple contaminants present at this site, the Michigan Act
307 Type B criteria, which are more stingent than MCLs, are
necessary to be protective and are, therefore, applicable or
relevant and appropriate to the Peerless Plating site.
The remedial alternatives considered for the Peerless Plating
site, and the selected remedy as described in Section X of
this Record of Decision, will achieve the groundwater and soil
cleanup standards set forth in the following Table 7. These
cleanup standards are based on Michigan Act 307 criteria. The
point of compliance for groundwater cleanup purposes shall be
throughout the contaminated groundwater plume. Final effluent
limitations from the groundwater treatment process are
presented in Table 8.
VXX~.DESCRIPTXON OF ALTERNATIVES
The alternatives for Peerless Plating are presented below.
The alternatives are separated into two groups: Groundwater
Alternatives and Soil Alternatives. One alternative is
selected from each group to address the groundwater and the
soil contamination at the site.
General elements that are common to all of the alternatives
include:
A) Demolition and disposal of the Peerless Plating building
during the Remedial Design. The RI data indicates that
there may be sources of contamination underneath the
Peerless Plating building. The building is in poor
physical condition, which prohibited sampling the soils
underneath during the RI. As part of the pre-design
phase of the Remedial Design, the building will be
demolished to facilitate the soil sampling. The
demolition debris will be tested to determine if it needs
to be handled as a hazardous waste. If the debris is
found to be a hazardous waste, then it will be
cleaned/treated to meet the alternate standards under a
variance for debris from the Land Disposal Restriction
-------
TABLE 7 - PEERLESS PLATING CLEANUP STANDARDS
(Based on Act 307 Type B)
contaminant of Concern
Groundwater (ua/l)
soil (ma/ka)
Inoraanic
Arsenic
Cadmium
Aluminum
Antimony
Barium
Chromium III
Chromium VI
Lead
Mercury
Nickel
silver
Thallium
Cyanide
0.2
4.0
50.0
3.0
2,000.0
7,000.0
2.0
5.0
2.0
57.0
0.1
0.5
4.0
1. 7 *
0.8 *
3770.0 *
7.0 *
40.0
100.0
0.04
5.0
0.04
1.8 *
1.2 *
0.43 *
0.08
oraanic
Benzene
1,1-Dichloroethane
Chloroform .
Trichloroethene
Vinyl Chloride
1,2-Dichloroethane
Ethylbenzene
Toluene
1, 1, 1-Trichloroethane
Xylenes (total)
1.0
700.0
6.0
3.0
0.2
0.4
30.0
100.0
117.0
59.0
0.02
10.0
0.1
0.06
0.0004
0.008
0.6
2.0
2.0
1.0
Notes:
* - Background values are used because they are higher than the Type B
cleanup levels.
Where the cleanup standard established for a contaminant is lower than the
method detection limit for that contaminant, the method detection limit
will be used as the cleanup standard for the site.
-------
TABLE 8 - FINAL PEERLESS PLATING EFFLUENT LIMITATIONS
contaminant of Concern
BETX
Benzene
1,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Total Cadmium
Chromium VI
Total cyanide (amenable)
Total Lead
Total Nickel
Total Zinc
Total Phosphorus
Dissolved Oxygen
pH (Standard Units)
Discharae Limitations
1h/dav other Limitations
Daily Monthly Daily
Maximum Averaae Maximum
20 ug/l
5 ug/l
5 ug/l
5 ug/l
3 ug/l
0.0013 0.72 ug/l
0.009 5 ugll 30 ug/l
0.OG9 5 ug/l 47 ug/l
0.02 11 ug/l
0.12 67 ug/l
0.17 95 ug/l 430 ug/l
0.9 0.5 mg/l
Daily Daily
Minimum Maximum
4.0 mg/l
6.5 9.0
Analvtical Testina: Purqeable halocarbons shall be analyzed usinq U.S.
EPA Test Methods 8010 or 601. Purgeable aromatics shall be analyzed using
u.s. EPA Test Methods 8020 or 602. Total Cadmium shall be analyzed using
u. s. EPA Test Method 213.2. Total and Hexavalent Chromium shall be
analyzed using u.s. EPA Test Methods 218.2 and 218.4, respectively. Total
Copper shall be analyzed using u.s. EPA Test Mathod 220.2. Total cyanide
shall be analyzed using u.s. EPA Test Method 335.1. Total.Lead shall be
analyzed using U. S. EPA Test Method 239.2. Total Nickel shall be analyzed
using u.s. EPA Test Method 249.2. Total Zinc shall be analyzed using u.s.
EPA Test Method 289.2. Total Phosphorus shall be analyzed using U.s. EPA
Test Method 365.2. BETX is defined as the arithmetic sum of the
concentrations of benzene, ethylbenzene, toluena, and xylene(s).
-------
18
(LDR) treatment standards. according to RCRA, 40 CFR
section 268.44. The variance would be granted because
the LDR treatment standards are based on treating less
complex matrices of industrial process wastes.
B) Pre-design sampling of the soil to better define the
, extent of contamination, especially under the building,
north of the building, and in the subsurface away from
the former lagoon areas. The pre-design studies will
also determine if semi-volatile soil contamination exists
and any necessa~y treatability studies will be conducted.
C) Groundwater monitoring to check the progress of the
groundwater cleanup.
Groundwater Alternatives
Alternative 1 - No Action
Under this alternative, no action would be taken at the
Peerless Plating site to reduce risks. ,The NCP requires that
U.s. EPA evaluate the No Action Alternative to provide a
baseline for comparison of the effectiveness of the remedial
alternatives. No reduction of risks would result from this
alternative. The No Action Alternative is not protective of
human health and the environment.
The only costs involved with this alternative are those
associated with groundwater monitoring that would be required
since contaminants would be left on the site. Alternative 1
has no capital costs. The estimated annual operation and
maintenance costs for the groundwater monitoring are $3,000.
The present worth is estimated at $41,000.
Alternative 2 - Air strippinq and precipitation
Under this alternative, the groundwater would be pumped out of
the aquifer from an extraction well system. The VOCs would be
stripped from the groundwater using a counter-current flow of
air in a packed column or tower. The packed column or tower
allows for high air-to-water contact time to achieve high
removal efficiencies. The air stream containing the
contaminants would be filtered with a carbon filter in order
to meet air emission limits of the Clean Air Act, RCRA Subpart
AA (for process vents), and Michigan's Air Pollution Control
Act prior to discharging. The spent carbon could become a
characteristic hazardous waste if enough contaminants are
collected. If the spent carbon is characteristic, it would be
handled as a hazardous waste. The spent carbon would be
regenerated by thermal treatment at an appropriate facility.
-------
19
The second part of this groundwater alternative would remove
inorganics, such as soluble cadmium, through precipitation.
The chemical equilibrium of the water would be altered to
reduce the solubility of inorganic contaminants. This would
be done by adjusting the pH of the water and by adding
chemical coagulants to aid in the formation of precipitates.
The chemical coagulants would be added in a rapid mix tank and
would be followed by gentle mixing or flocculation, which
causes interlattice bridging and formation of floes which
settle rapidly. The inorganics precipitate out as a solid
phase and would be taken out of the solution by settling and
filtration equipment. The inorganic sludge that precipitates
out of the water would be treated to meet LDR treatment
standards prior to disposal at a RCRA subtitle C facility.
The treated groundwater would meet the substanti ve NPDES
requirements prior to discharge to Little Black Creek. This
groundwater treatment process would continue until cleanup
standards are met.
Alternative 2 has an estimated capital cost of $720,000 and an
estimated annual operation and maintenance cost of $320,000.
The estimated present worth cost is $2,531,000.
Alternative 3 - Air strippinq and Ion Exchange
This alternative is similar to Groundwater Alternative 2 in
that the groundwater would be pumped from the aquifer from an
extraction well system and the VOCs would be removed by air
stripping. The two alternatives differ in the treatment of
inorganic contaminants. Whereas Groundwater Alternative 2
would use precipitation, Alternative 3 would remove inorganics
by ion exchange. Ion exchange is a separation process in
which contaminants that are present in the form of ions in the
groundwater are removed by transferring them to a solid
material called an ion exchange resin. The ion exchanger
accepts the contaminants and gives back an equivalent number
of ionic species stored on the ion exchanger skeleton. The
exchanger is usually made up of an organic resin, typically in
the form of beads. The resin is placed in a column and the
water is passed though the resin bed. The resin has a limited
capacity for storing ions on its skeleton. Once the ion
exchanger becomes saturated with contaminant ions, the resin
would be washed with a strong regenerating solution containinq
the desirable substitute ions. The contaminant ions are
replaced and the resin is useable again. The regeneratinq
solution contains the concentrated inorganics, which would be
precipitated through pH adjustment and chemical addition. The
inorganic sludges would be treated to meet LDR treatment
standards prior to disposal at a RCRA subtitle C facility.
-------
20
As with Groundwater Alternative 2, the treated groundwater
would meet effluent limitations required under the Clean Water
Act and Michigan Act 245 prior to discharge to Little Black
Creek. This groundwater treatment process would continue
until the cleanup standards are met.
Alternative 3 has an estimated capital cost of $1,002,000 and
an estimated annual operation and maintenance cost of
$384,000. The estimated present worth cost is $3,170,000.
soil Alternatives
Alternative 1 - No Action
The no action alternative involves no treatment or containment
of the contaminated soil. As with the groundwater no action
alternative, the NCP requires that u.s. EPA evaluate the No
Action Alternative to provide a baseline for comparison of the
effectiveness of the remedial alternatives. No reduction of
risks would be result from this alternative. The No Action
Alternative is not protective of human health and the
environment.
The only costs involved with this alternative are those
associated with groundwater monitoring that would be required
since contaminants would be left on the site. Alternative 1
has no capital costs. The estimated annual operation and
maintenance costs for the groundwater monitoring are $3,000.
The present worth cost is estimated at $41,000.
Alternative 2 - RCRA Cap
This alternative would contain the contaminated soils
(approximately 8,800 yd3) by means of a RCRA hazardous waste
cap. The cap would be used to prevent contact and reduce the
potential infiltration and migration of contaminants from the
soil into the groundwater. A RCRA minimum technology cap
would include a 24-inch soil cap, a 12-inch sand drainage
layer, a flexible membrane liner, a 24-inch clay layer, and a
12-inch soil cover. A monitoring program would be established
to evaluate the physical integrity and effectiveness of the
cap. Institutional controls would be implemented to limit
future land use activities on and adjacent to the capped area.
A five year review of the site would be required because
contaminants are left on-site.
Alternative 2 has an estimated capital cost of $484,000 and an
estimated annual operation and maintenance cost of $17,000.
The estimated present worth cost is $718,000.
-------
21
Alternative 3 - RCRA Cap and ISVE
This alternative would use in-situ vapor extraction (ISVE) to
remove VOCs from the soil contaminated with organics
(approximately 6,500 yd3). The system operates by applying a
vacuum through six production wells that are drilled through
the contaminated soil zone to just above the groundwater
table. Because of the pressure gradient created by the vacuum
pumps, VOCs in the soil percolate and diffuse through the air
spaces between the soil particles to the production wells at
a rate of 100 ft3 per minute. The vacuum established in the
soil continuously draws VOC-contaminated air from the soil
pores and draws fresh air from the soil surface dQwn through
the soil. The extracted gas flows through the collection
manifold and would be filtered with a carbon filter in order
to meet air emission limits of the Clean Air Act and
Michigan's Air Pollution Control Act prior to discharging.
The spent carbon could become a characteristic hazardous waste
if enough contaminants are collected. If the spent carbon is
characteristic , it would be handled as a hazardous waste. The
spent carbon would be regenerated by incineration at an
appropriate facility.
After the soil organic cleanup levels (listed previously) are
met, the soil contaminated with inorganics (approximately
8,800 yd3) would be covered with a RCRA cap to contain the
inorganic contaminants. The specif ics of the RCRA cap are the
same as that described in Soil Alternative 2.
Alternative 3 has an estimated capit~l cost of $711,000 and an
estimated annual operation and ma~. -:enance cost of $17,000.
The estimated present worth cost is $945,000.
Alternative 4 - ISVE and On-site stabilization
As with Soil Alternative 3, the VOC contaminated soils would
be treated through ISVE. Once the organic cleanup standards
are met, the soil contaminated wi th inorqanics above the
cleanup levels would be excavated, stabilized on-site and
disposed off-site in a licensed RCRA subtitle C facility.
Stabilization immobilizes contaminants, minimizes leaching
potential, and improves the waste handling characteristics.
The contaminated soil would be excavated and mixed with
treatment reagents that combine physically and/or chemically
with the inorganic contaminants to decrease their mObility.
The stabilized soil would be tested to ensure 'that alternate
treatment standards under a treatability variance for soil and
debris from LDR treatment standards are met prior to disposal
at a hazardous waste facility.
Alternative 4 has an estimated capital cost of $5,399,000 and
an estimated annual operation and maintenance cost of $3,000..
The estimated present worth cost is $5,440,000.
-------
IX.
22
Alternative $ - XSVE and In-situ stabilization
Alternative 5 is similar to Soil Alternative 4. The organic
contamination is treated through ISVE and the inorganic
contamination is stabilized. However, in Alternative 5, the
stabilization is done in-place rather than above-ground.
Injectors or tillers would simultaneously inject and mix:
stabilization reagents with the soil in the ground. After
solidification, samples of the cores of stabilized material
would be collected for Toxicity Characteristic Leaching
Procedure (TCLP) analysis to determine the. success of the
treatment process. The treated soil would remain in-place
with institutional controls implemented to prevent the soil
from being disturbed. Since contaminants are left on-site, a
five year review of the site.would be required.
Alternative 5 has an estimated capital cost of $1,112,000 and
an estimated annual operation and maintenance cost of $5,000.
The estimated present worth cost is $1,181,000.
COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, the relative performance of eacn
alternative is evaluated using the nine criteria, 40 CFR
Section 300.430(e)(9) (iii), as a basis for comparison. An
alternative providing the "best balance" of tradeoffs witn
respect to the nine criteria is determined from this
evaluation.
A detailed analysis was performed on the eight alternatives
using the nine evaluation criteria in order to select a site
remedy. The following is a summary of tha comparison of eacn
alternative's strength and weakness with respect to the nine
evaluation criteria. These nine criteria are: 1) overall
protection of human health and the environment, 2) compliance
with applicable or relevant and appropriate requirements
(ARARs), 3) short-term effectiveness, 4) long-term
effectiveness and permanence, 5) cost, 6) reduction of
toxicity, mobility, and volume, 7) implementability, 8) state
acceptance, and 9) community acceptance.
Overall Protection of Human Health and the Environment
This criterion 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.
-------
23
Alternative 1 for both the groundwater and the soil, No
Action, . does not satisfy the requirement for overall
protection of human health and the environment. The risks
associated with the site are not changed by the no action
alternatives.
Groundwater Alternatives 2 and 3, in conjunction with any of
the Soil Alternatives 2 through 5, are protective of human
health and the environment. Both of these groundwater
alternatives utilize treatment to reduce the risks associated
with ingestion and inhalation of contaminated groundwater to
acceptable health based levels. Also, both alternatives are
capable of treating groundwater to levels required by
substantive NPDES requirements.
Soil Alternatives 2, 3, 4, and 5, in conjunction with
Groundwater Alternatives 2 or 3, are protective since each
includes treatment and/or containment of the contaminated
soils, and thus eliminate the potential exposure pathways and
the associated risk. Alternatives 4 and 5 protect human
health and the environment as they treat both the organic and
inorganic soil contamination. Alternative 3 is protective as
it treats the organic soil contamination and contains the
inorganic contamination. Alternative 2 is also protective as
it contains all of the contamination without any treatment.
Al ternati ves 2 and 3 require institutional controls to be
implemented in order to remain protective so that the cap is
not breached.
Compliance with Applicable
Reauirements lARARs)
or
Relevant
and
Appropriate
This criterion evaluates whether a remedy meets applicable or
relevant and appropriate requirements set forth in Federal and
State environmental laws pertaining to the site or proposed
actions or if a waiver is justified. ARARs are discussed in
more detail in statutory Determinations.
All of the groundwater and soil alternatives, with the
exception of the no action alternatives, comply with Federal
and State ARARs.
The major ARARs that Groundwater Alternatives 2 and 3 will
comply with include: the Clean Air Act, RCRA Subpart AA (for
process vents), and Hichiqan's Air Pollution Control Act (Act
348), which address air emissions from the air stripping
process; the Clean Water Act and the Kichiqan Water Resources
Act (Act 245), which address the discharge of treated water
into Little Black Creek; the Federal Safe Drinkinq Water Act,
which addresses contaminant levels in the groundwater;
Kichiqan Environmental Response Act. (Act 307) I which addresses
-------
24
cleanup type; and, RCRA (in particular LDRs) and Michigan
Hazardous Waste Management Act (Act 64), which address the
handling of hazardous materials, such as, the inorganic
sludges and the spent carbon filters.
The major ARARs that Soil Alternatives 2 through 5 will comply
wi th include: the Clean Air Act, RCRA Subpart AA (for process
vents), and Michigan's Air Pollution control Act (Act 348),
which address the air emissions from the ISVE process; RCRA
(in particular LDRs) and Michigan Hazardous Waste Management
Act (Act 64), which address the treatment, storage, and
disposal of hazardous wastes, like the soil which is
contaminated with inorganic contaminants from listed waste,
i.e., electroplating wastes - F006, F007, FOOS, and F009}; and
Michigan Environmental Response Act (Act 307) (Rules 705(2)
and (3), 707 - 715, 717(2), 719(1), and 723 of the Act 307
Rules), which addresses cleanup type.
Lona-term Effectiveness and Permanence
This criterion refers to expected. residual risk and the
ability of a remedy to maintain reliable protection of human
health and the environment over time, once cleanup goals have
been met.
Neither of the no action alternatives satisfy this criterion
because neither reduces risk at the site.
Groundwater Alternatives 2 and 3 are effective. in t,he long
term as minimal risks remain from any residual contaminants
remaining after the alternatives are implemented. They both
utilize treatment to permanently reduce risk from groundwater
contaminants as cleanup standards are met. Residuals from the
treatment processes include spent carbon, which will be
regenerated through thermal treatment, and sludges, which will
be treated prior to disposal at an off-site RCRA subtitle C
facility in order to meet LDRs.
All of the soil alternatives are also effective in the long
term. Soil Alternative 4 is the most effective and permanent
as both organic and inorganic contaminants in the soil are
treated and then the soil is disposed of off-site, leaving no
on-site residuals. Soil Alternative 5 treats the organic and
inorganic contaminants, but the soil is left on-site. The
inorganic contaminants are. immobilized and remain in the
ground, so a five year review would be required. Soil
Alternative 3 treats the organic contaminants with ISVE and
contains the untreated inorganic contaminants with a RCRA cap.
While this is a lesser degree of effectiveness and permanence
than Alternatives 4 and 5, the residual risk from the
-------
25
untreated waste left on-site is reduced because the
containment reduces potential exposures. Soil Alternative 2
is least effective and permanent as both the untreated organic
and inorganic contaminants are contained on-site. Again, as
with Alternative 3, the RCRA cap reduces the residual risk by
reducing the potential exposures to contaminants. Soil
Alternatives 2,3, and 5 require long-term monitoring because
contaminants are left on-site.
Reduction of Toxicitv. Mobilitv. or Volume Throuqh Treatment
This criterion addresses the statutory preference for
selecting remedial actions that employ treatment technologies
that permanently and significantly reduce toxicity, mobility,
or volume of the hazardous substances as their principal
element.
Neither no action alternatives satisfy this criterion because
neither involve any type of treatment. .
Groundwater Alternatives 2 and 3 reduce toxicity, mobility,
and volume though treatment of the groundwater. Both
alternatives use air stripping to physically remove the
organic contaminants from the groundwater so cleanup levels
are met. The contaminants in the air stream are filtered with
activated carbon and are ultimately destroyed when the spent
carbon is regenerated through thermal treatment. Groundwater
Alternative 2 uses precipitation to treat inorganic
contaminants, while Groundwater Alternative 3 uses ion
exchange.
Soil Alternatives 4 and 5 reduce toxic.ity, mobility, and
volume through treatment of the soil. Both use ISVE to reduce
the toxicity and volume of organic contaminants. The
contaminants in the vapor phase of the ISVE system are
filtered with activated carbon and destroyed when the spent
carbon is regenerated through incineration. Also, Soil
Alternatives 4 and 5 use stabilization to reduce the mobility
of the inorganic contaminants. Soil Alternative 3 partially
satisfies the criteria for reduction of toxicity, mObility, or
volume through treatment. The organic contaminants are
treated using ISVE to reduce the toxicity and volume.
However, the inorganic contaminants are contained and not
treated. Soil Al ternati ve 2 does not reduce toxici ty ,
mobility, or volume through treatment. The mobility of the
contaminants may be reduced through containment. However,
since containment is not treatment, Soil Alternative 2 does
not satisfy this criterion.
All of the soil alternatives, except for Soil Alternatives 1
and 2, satisfy the statutory preference for treatment as a
-------
26
principal element as they all treat the contaminated soil.
Soil Alternatives 4 and 5 use treatment to a greater extent
than Soil Alternative 3, which only partially treats the soil.
Short-term Effectiveness
This criterion addresses the risks the remedy may pose to site
workers, the community, and the environment during the
construction and implementation phase until cleanup goals are
achieved and the time it takes to achieve these cleanup goals.
Neither of the no action alternatives involve any construction
nor implementation. Therefore, this short-term effectiveness
criterion does not apply to the no action alternatives. All
of the other groundwater and soil alternatives are effective
as there are no unacceptable short-term risks caused by the
implementation of any of the alternatives.
Groundwater Alternatives 2 and 3 utilize air stripping to
remove organic. contaminants from the water. This could
possibly release VOCs into the air. The risk to residents and
workers from this is minimal as the discharged air will be
filtered ~nd monitored to ensure discharge requirements are
met.
All of the soil alternatives involve construction, which could
cause dust, noise, and traffic problems. Also, there is the
threat to site workers of direct contact with contaminated
soils and inhalation of airborne emissions. The risks from
these issues will be minimized by using dust, noise, and
traffic controls; fOllowing safe working practices; and,
implementation of a site health and safetv plan.
The estimated time until the groundwater is cleaned up for
either Groundwater Alternative 2 or 3 is 7 years. The
estimated cleanup time for the soils range from 1 month (for
Soil Alternative 2) to s.lightly over 2 years (for Soil
Alternatives 3, 4, or 5).
ImDlementabilitv
This criterion addresses the technical and administrative
feasibili ty of implementing a remedy, including the
availability of materials and services needed.
There is nothing to implement with the two no action
alternatives. All of the other alternatives are technically
and administratively implementable and can be readily
constructed from. available materials.
-------
27
The groundwater alternatives, which include
carbon filtering, precipitation, and ion
available from multiple vendors and pose no
concerns.
air stripping,
exchange, are
implementation
The soil alternatives, which include capping, ISVE, and
stabilization, are also readily available. The only concern
with the soil alternatives that could impact implementability
may be the small size of the site. The placement of equipment
and treatment processes may be hampered by the lack of space
at the site. Any impact caused by. site logistics can be
minimized in the design.
Cost
This criterion compares the capital,
maintenance, and present worth costs
alternatives at the site.
annual operation and
of implementing the
The following
alternatives.
are
the
cost
estimates
for
each
of
the
Capita.l Cost Annual Cost Present Worth
Groundwater Alternative
1 $0 $3,000 $41,000
2 $720,000 $320,000 $2,531,000
3 $1,002,000 $384,000 $3,170,000
Soil Alternative
1 $0 $3,000 $41,000
2 $484,000 $17,000 $718,000
3 $711,000 $17~ 000 $945,000
4 $5,399,000 $3,000 $5,440,000
5 $1,112,000 $5,000 $1,181,000
The calculation of present worth is an estimate of the value
of money used to pay future costs in "today's" dollars. The
calculation is based on the assumption that an existing dollar
will earn interest and therefore has a greater value than a
future dollar.
state Acceptance
The state of Michigan has verbally concurred with u.s. EPA's
selection of Groundwater Alternative 2 and Soil Alternative 4
as the preferred remedial alternative as presented in the next
section. A letter of concurrence has not yet been received.
-------
28
Communitv Acceptance
Based on comments received by u.s.
alternative appears to be acceptable
Community concerns are addressed
Responsiveness Summary.
EPA, the selected
to the community.
in the attached
x.
SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, as
amended by SARA, and the NCP, the detailed analysis of the
alternatives, and public comment, u.S. EPA has determined that
Groundwater Alternative 2 (Air stripping and Precipitation)
and 80il Alternative 4 (ISVE and On-site Stabilization) is the
most appropriate remedy for the Peerless plating Site. This
selection was made keeping in mind the fact that the site is
in an urban, light industrial and residential area and that
there is interest in future use of the property.
The components of the selected remedy are as follows:
A)
Demolition of Peerless plating Building
The Peerless Plating building shall be demolished and
disposed in order to facilitate additional soil sampling
underneath the building during the design. Disposal of
the building debris will depend on whether or not it is
contaminated with a hazardous waste. If it is not
contaminated with a hazardous waste, the debris shall be
disposed at a solid waste landfill. If it is
contaminated with a hazardous waste, cleaning of the
debris shall be attempted. If the building debris can
not be cleaned to acceptable levels, it shall be disposed
at a licensed hazardous waste facility.
B)
pre-Design study
The pre-design phase shall include but is not limited to:
(1) sampling and analyses to define the nature and extent
of organic and inorganic soil contamination that exists
under the. building and around the perimeter, (2) sampling
and analyses to further define the organic and inorganic
contamination in the subsurface soil, (3) any necessary
treatability studies to determine the effectiveness of
the air stripping process (including vapor phase carbon
adsorption), the precipitation process, the ISVE process
(including vapor phase carbon adsorption), and the
stabilization process.
-------
29
C)
Air stripping and Precipitation
The groundwater shall be. pumped out of the aquifer from
a extraction well system. The VOCs shall be stripped
from the groundwater using a counter-current flow of air
in a packed column or tower. The packed column or tower
allows for high air-to-water contact time to achieve high
removal efficiencies. The air stream containing the
contaminants shall be filtered with a carbon filter in
order to meet air emission limits of the Clean Air Act
and Michigan's Air Pollution Control Act prior to
discharging. The spent carbon could become a
characteristic hazardous waste if enough contaminants are
collected. If the spent carbon is characteristic, it
shall be handled as a hazardous waste. The spent carbon
shall be regenerated by incineration at , an appropriate
facility.
The second part of this groundwater remediation shall
remove inorganics, such as soluble cadmium, through
precipitation. The chemical equilibrium of the water
shall be altered to reduce the solubility of inorganic
contaminants. This shall be done by adjusting the pH of
the water and by adding chemical coagulants to aid in the
formation of precipitates. The chemical coagulants shall
be added in a rapid mix tank and shall be followed by
gentle mixing or flocculation, which causes inter lattice
bridging and formation of floes which settle rapidly.
The inorganics precipitate out as a solid phase and shall
be taken out of the solution by settling and filtration
equipment. The inorganic sludge that precipitates out of
the water shall be treated to meet LDR treatment
standards prior to disposal at a RCRA subtitle C
facility.
The treated groundwater shall meet the substantive NPDES
requirements prior to discharge to Little Black Creek.
This groundwater treatment process shall continue until
cleanup standards are met.
D)
Groundwater KODi~oriDq proqram
A groundwater monitoring program shall be implemented to
monitor contaminant concentrations during the Remedial
Des~qn/Remedial Action (RDfRA). The laboratory analyses
shall include U. s. EPA I S Target Analyte List (TAL)
inorganics and U. s. EPA' s Target Compound List (TCL)
organics.
-------
30
E)
In-situ vapor Extraction and on-site stabilization
In-situ vapor extraction (rSVE) shall be used to remove
VOCs from the soil contaminated with organics
(approximately 6,500 yd3). The system operates by
applying a vacuum through production wells that are
drilled through the contaminated soil zone to just above
the groundwater table. Because of the pressure gradient
created by the vacuum pumps, VOCs in the soil percolate
and diffuse through the air spaces between the soil
particles to the production wells. The vacuum
established in the soil continuously draws VQC-
contaminated air from the soil pores and draws fresh air
from the soil surface - down through the soil. The
extracted gas flows through the collection manifold and
shall be filtered with a carbon filter in order to meet
air emission limits of the Clean Air Act and Michigan's
Air Pollution Control Act prior. to discharg ing. The
spent carbon could become a characteristic hazardous
waste if enough contaminants are collected. If the spent
carbon is characteristic, it shall be handled as a
hazardous waste, which includes meeting LDRs. The spent
carbon shall be regenerated by thermal treatment at an
appropriate facility.
Once the orqanic cleanup standards are met, the soil
contaminated with inorqanics above the cleanup levels
shall be excavated, stabilized on-site and disposed off-
site in a licensed RCRA subtitle C facility.
Stabilization immobilizes contaminants, minimizes
leaching potential, and improves the waste handlinq
characteristics. The contaminated soil shall be
excavated and mixed with treatment reagents that combine
physically and/or chemically with the inorganic
contaminants to decrease their mobility. The off-site
disposal of the soil shall comply with LDRs through a
treatability variance for the soils that can not be
treated to meet the LDR treatment standards as provided
for under 40 CFR section 268.44. The stabilized soil
shall be tested to ensure that alternate treatment
standards are met prior to disposal at a hazardous waste
facility.
Remediation Goals
The purpose of this response action is to control risks posed
by ingestion of and dermal contact with contaminated
groundwater and soils and to treat the principal threat (the
contaminated soils). The future use scenarios indicate
unacceptable risks to human health as the carcinogenic risk is
-------
31
5 X 10.4 for future adult residents and 8 x 10~5 for future
workers. The non-carcinogenic hazard index is 204.05 for
future adult residents, 40.7 for future workers, and 2.08 for
future child residents. These risks are outside of U. s. EPA IS
acceptable risk ranges. The cleanup levels presented in
section VII, CleanuD Standards, shall be achieved for the soil
and groundwater. Because the remedy selected will not result
in hazardous substances remaining at the site above levels
that allow for unlimited use and unrestricted exposure once
these cleanup standards are met, a. five year review of the
remedy is not required.
Estimated Costs
The fOllowing is the estimated cost summary for the selected
remedy.
Groundwater Alternative 2
Air stripping and precipitation
CAPITAL COSTS:
Groundwater Extraction Well
Air stripping and Carbon Adsorption
Precipitation and Filtration'
Building and Auxiliary Equipment
Engineering
Construction oversight
contingencies
$8,000
$92,000
$183,000
$239,000
$52,200
$15,660
$130,000
TOTAL CAPITAL COSTS
$720,.000
ANNUAL O&M COSTS:
Groundwater Extraction Well
Air stripping and Carbon Adsorption
Precipitation and Filtration
Building and Auxiliary Equipment
Groundwater Monitoring
$4,000
$75,000
$112,000
$126,000
$3,000
PRESENT WORTH COSTS
$2,531,000
-------
32
soil Alternative 4
ISVE and on-site staDilization
CAPITAL COSTS:
Excavation
On-Site Stabilization &
Off-Site Disposal
$121,000
ISVE
Building Demolition
Pre-Design Soil Sampling
Engineering
Construction Oversight
Contingencies
$3,401,000
$164,000
$171,000
$55,000
$391,200
$117,360
$978.000
TOTAL CAPITAL COSTS
$5,399,000
ANNUAL O&M COSTS:
Groundwater Monitoring
$3,000
PRESENT WORTH COSTS
$5,440,000
TOTAL PRESENT WORTH COSTS.......... ..............$7.970.000
XI.
STATUTORY DETERMINATIONS
u.S. EPA's primary responsibility at Superfund sites is to
select remedial actions that are protective of human health
and the environment. In addition, Section 121 of CERCLA
establishes several statutory requirements and preferences.
These require that the selected remedial action for the site
comply with applicable. or relevant and appropriate
requirements established under Federal and State environmental
laws, unless a waiver is granted. The selected remedy must
also be cost-effective and utilize permanent treatment
technologies or resource recovery technologies to the maximum
-------
33
extent practicable. Finally, the statue includes a preference
for remedies that include treatment as a principle element.
The following sections discuss how the selected remedy for the
Peerless Plating Site meets these statutory requirements.
A}
Protection of Human Health and the Environment
The selected remedy for the Peerless Plating site
protects human health and the environment through the
treatment of the principal threat, i.e. the contaminated
soil, which is a continuing source of groundwater
contamination, and treatment of the contaminated
groundwater.
. The organic contamination in the soil shall be treated
through ISVE to reduce the contaminant levels to cleanup
standards, reducing the risk at the site. The extracted
organics in the exhaust gas of the ISVE process is
filtered with activated carbon. The contaminants are
ultimately destroyed when the spent carbon is regenerated
through incineration. 50 even though the contaminants
are transferred from one media (soil) to another (air),
the contaminants are not released into the environment.
The inorganic contamination in the soil shall be treated
through stabilization and disposed off-site at a licensed
hazardous waste facility. This eliminates the ingestion
and direct contact exposure pathways for the contaminants
in the soil.
The groundwater shall be treated through air stripping
and precipitation to meet cleanup standards, reducing the
risk posed by ingestion of and dermal contact with
groundwater. The air stripping transfers the organic
contaminants from one media' (water) to another (air), but
the contaminants in the vapor phase are ultimately
destroyed when the carbon filters that collect the
organics are regenerated through incineration.
No unacceptable short-term risks shall be caused by the
implementation of the remedy. Carbon filtering of the
air stripping and ISVE exhaust gas prevents the release
of organic contaminants into the air and possible
exposure by residents. The residents and site workers
may be exposed to dust, noise, and traff ic nuisanc~s
during the implementation of the remedy. Monitoring and
standard controls shall minimize any short-term impacts.
-------
34
B)
Compliance with ARARs
The selected remedy shall comply with Federal or more
stringent state applicable or relevant and appropriate
requirements (ARARs) listed below:
1) Chemical-Specific ARARs
Chemical-specific ARARs regulate the release to the
environment of specific substances having certain
chemical characteristics. Chemical-specific ARARs
typically determine the extent of cleanup at a site.
a) Groundwater
Federal ARARs
At the Peerless Plating site, MCLs and MCLGs are
not applicable because the site is not a municipal
water supply servicing 25 or more people. MCLs are
relevant and appropriate since the aquifer in the
area of contamination is suitable for use as a
source of drinking water in the future. MCLGs are
also relevant and appropriate when the standard is
set at a level greater than zero (for non-
carcinogens). The point of compliance for
groundwater cleanup' purposes shall be throughout
the contaminated groundwater plume.
state ARARs
The u.s. EPA has determined that Rules 705(2) and
(3), 707 - 715, 717 (2), 719 (1.), and 723 of the
Michigan Environmental Response Regulations are
relevant and appropriate to the Peerless Plating
site in compliance with section 121(d) (2) of
CERCLA. The cleanup standards presented in Table
7, which shall be attained by the selected remedy,
were calculated pursuant to Act 307 Type B
criteria.
b) Surface Water
Federal ARARs
Surface water quality standards for the protection
of. human health and aquatic life were developed
under section 304 of the Clean Water Act (CWA).
The Federal Ambient Water Quality criteria (AWQC)
are non-enforceable guidelines that set pollutant
concentration limits to protect surface waters.
-------
35
Pursuant to Section 121 Cd) of CERCLA, the Federal
AWQC may be relevant and appropriate under the
circumstances or a release or threatened release,
depending on the designated or potential uses of
the surface water, the environmental media affected
by the releases or potential releases, and the
latest information available. Since the treated
groundwater will be discharged to Little Black
Creek, designated as a coldwater fishery, the AWQC
for protection of. freshwater aquatic organisms are
relevant and appropriate.
State ARARs
Part 4 of the Water Resources Commission Act (Act
245) establishes rules for water quality standards
for surface water in the state of Michigan based on
the Federal AWQC. The substantive requirements of
Part 4 are applicable to Little Black Creek.
2) Location-SDecific ARARs
Location-specific ARARs are those requirements
relate to the geographical position of a site.
that
Federal ARARs
Executive Order 11988 and 40 CFR section 264.18,
Protection of Flood Plains, are relevant and appropriate
for this site. The Order and regulation requires that
the groundwater treatm~nt system be located above the
100-year flood plain t:'. .evation and- be protected from
erosional damage. Any portion of the remedy that is
constructed in the 100-year flood plain must be
adequately protected against a 100-year flood event
(e.g., qeotextiles should be used to secure topsoil,
ate. )
Section 404 of the CWA regulates the discharge of dredged
or fill material to waters of the United states.
Construction of a surfa~e water discharge point may be
regulated under Section 404 of the CWA; therefore, the
substantive requirements of Section 404 ar,.. applicable to
the remedial action at the site.
State ARARs
The Inland Lakes and Streams Act (Act 346) regulates
inland lakes and streams in the State. Act 346 would be
applicable to any dredging or filling activity on Little
Black Creek bottomlands.
-------
36
The Soil Erosion and Sedimentation Control Act (Act 347)
regulates earth changes which involves more than 1 acre
or is within 500 feet of a lake or stream. Act 347 would
be applicable to the soil excavation activities as the
site is within 500 feet of Little Black Creek.
Appropriate erosion and sedimentation control measures
shall be planned. .
3) Action-Specific ARARs
Action-specific. ARARs
acceptable treatment
hazardous substances.
are
and
requirements that define
disposal procedures for
Federal ARARs
RCRA Subti tIe C requirements regulate the treatment,
storage, and disposal of hazardous waste. Because the
inorganic contaminants in the soils and sludges are from
a listed waste, RCRA Subtitle C requirements are
applicable to the treatment, storage, or disposal of.
these soils and sludges. In addition, the groundwater
contains organic contaminants. If, due to the filtering
of the organic contaminants in the air stripping and ISVE
processes, the spent carbon contains organic contaminants
exceeding RCRA toxicity characteristic levels, RCRA
Subtitle C requirements are applicable to the treatment
or disposal of this material.
RCRA Land Disposal Restrictions (LDRs), 40 CFR Part 268,
place restrictions on the land disposal of RCRA hazardous
waste. LDRs are applicable to the storage/disposal of
the stabilized soil, inorganic sludges from the
groundwater precipitation, and possibly the building
debris, which are to be disposed at an off-site RCRA
Subtitle C facility. The soil, which is contaminated
with inorganic contaminants from listed waste
(electroplating wastes - F006, F007, FOOS, and F009),
shall comply with LDRs through a treatability variance to
the extent that such soils can not be treated to meet the
LDR treatment standards. A treatablilty variance is
justified because the LDR treatment standards are based
on treating less complex matrices of industrial process
wastes, as provided for under 40 CFR Section 268.44. The
stabilized soil shall be tested to ensure that alternate
treatment standards are met prior to disposal at a RCRA
subtitle C facility. The inorganic sludges, which are.
contaminants from listed waste, shall be treated to meet
LDR treatment standards prior to disposal at a RCRA
Subti tIe C facility. Th~ building debris shall be tested
to determine if it is contaminated with a listed waste or
-------
37
is characteristic. If it is determined to be a hazardous
wast9, it shall be handled as a hazardous waste.and shall
comy with LDRs through a treatability variance for the
debr1s that can not be treated to meet the LDR treatment
standards, as provided for under 40 CFR Section 268.44.
The treated debris shall meet alternate treatment
standards prior to disposal at a RCRA Subtitle C
facility.
RCRA, Guideline for the Land Disposal of Solid Wastes, 40
CFR Part 241 is applicable to the disposal of the
building debris, if it is determined not to be a
hazardous waste through TCLP tests.
The following RCRA requirements are also ARARs:
40 CFR Part 260 - Hazardous Waste Manaqement System:
General;
40 CFR Part 261 - Identification and Listinq of Hazardous
Waste;
40 CFR Part 263 - Standards Applicable to Transporters of
Hazardous Waste; and,
40 CFR Part 264 - Standards for Owners and Operators of
Hazardous Waste Treatment. Storaqe. and
Disposal (TDS) Facilities.
The Clean Water Act Section 402 is applicable to the
remedial action at this site. The National Pollution
Discharge Elimination System (NPDES) program is the
national program for issuing, monitoring, and enforcing
permits for direct discharges to surface water bodies.
The NPDES program is implemented under 40 CFR Parts 122 -
125. The discharge of treated groundwater to Little
Black Creek shall comply with the substantive
requirements of the NPDES program.
The Clean Air Act protects and enhances the quality of
the nation's air resources by regulating emissions into
the air. Pursuant to Section 109 of the Clean Air Act,
National Ambient Air Quality Standards have been
promulgated in 40 CFR Part 50. These requireme:-
include standards for particulate matter equal or le_',
than 10 microns which is relevant and appropriate to the
excavation of the soils at Peerless Plating.
RCRA Subpart AA restablishes air emission standards for
process vents ion 40 CFR Section 264.1030 - 264.1036.
These requirements limit organic emissions and are
applicable to the air stripping process.
-------
38
state ARARs
The state of Michigan administers RCRA within the state.
Under the Hazardous Waste Management Act (Act 64), the
state regulates the generation, transport, treatment,
storage, and disposal of hazardous waste. As with RCRA
subtitle C, above, Act 64 is applicable at the site.
The Michigan Solid Waste Management Act (Act 641)
regulates the disposal of non-hazardous solid waste. Act
641. is applicable to the removal and disposal of non-
hazardous treatment residue and non-hazardous debris from
the site.
Parts 4, 9, and 21 of the Water Resources Commission Act
(Act 245) establishes rules for water quality and
administers discharge standards as promulgated by the
Federal NPDES program. These parts are applicable to
discharges of treated groundwater to Little Black Creek.
Because the discharge shall occur on-site, a permit is
not required, but the discharge must meet the substantive
requirements of an NPDES permit.
Michigan's Air Pollution Control Act (Act 348) regulates
air quality and is relevant and appropriate at the site.
The Michigan Environmental Response Act (Act 307)
provides for the identification,' risk assessment, and
evaluation of contaminated sites within the state. The
U.s. EPA has determined that Rules 705(2) and (3)., 707 -
715, 717(2), 719(1), and 723 are applicable to the
Peerless Plating site in compliance with section
121 (d) (2) of CERCLA. The Act 307 rules require that
remedial actions shall be protective of human health,
safety, the environment, and the natural resources of the
state. To achieve this standard of protectiveness, the
Act 307 rules require that a remedial action achieve a
degree of cleanup under either Type A (cleanup to
background levels), Type B (cleanup to risk-based
levels), or Type C (cleanup to risk-based levels under
site-specific considerations) criteria. u.s. EPA has
determined that the Type B criteria are necessary to be
protective and are, therefore, applicable to the Peerless
Plating site.
4) To Be Considered
In implementing the selected remedy, u.s. EPA considers
the CERCLA Off-site Policy. This directive, which is not
legally binding, establishes CERCLA' s policy for off-site
-------
39.
legally binding, establishes CERCLA' s policy for off-site
disposal of CERCLA-related wastes. u.s. EPA will follow
the CERCLA Off-Site Policy.
The promulgating notice for process vents (40 CFR Part
264 Subpart AA, 55 FR 25454 - June 20, 1990) states that
appropriate controls should be applied to in-situ
treatment if necessary. Therefore, the emission
standards of RCRA subpart AA are to be considered for the
emissions res~lting from the ISVE process.
C)
Cost Effectiveness
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional
to its cost . With respect to groundwater, Al ternati ve 1
is less expensive than the selected alternative
(Alternative 2), but does not provide any protection of
human heal th and the environment. Groundwater
Alternative 3 is more expensive than Alternative 2 and
provides the same protection.
Comparing the soil alternatives, all of the other
alternatives were less expensive than the selected soil
remedy (AI ternati ve 4). However, none of the other
alternatives are as effective. Also, they do not allow
for the site to be returned to unrestricted use once the
remediation is completed. Furthermore, the other
alternatives require long-term monitoring.
Thus, the combination of Groundwater Alternative 2 and
Soil Alternative 4 is the most cost effective remedy with
a present worth cost of $7.97 million.
D)
utilization of Permanent Solutions and Alternative
Treatment Technoloaies or Resource Recover Technoloaies
to the Maximum Extent Practicable
The selected remedy represents the maximum extent to
which permanent solutions and treatment technologies can
be utilized in a cost-effective manner for the Peerless
Plating site. Of those alternatives that are protective
of 1:.. -,an health and the environment and comply with
ARARs, Groundwater Alternative 2 and Soil Alternative 4
provide the best balance of tradeoffs in terms of long-
term effectiveness and permanence, reduction of toxicity,
mobility, or volume through treatment, short-term
effectiveness, implementability, and cost, and
considering state and community acceptance.
-------
40
The selected remedy provides the greatest degree of long-
term effectiveness and permanence because both the
groundwater and the soil are fully treated and no
residuals are left on-site. It reduces toxicity,
mObility, and volume through treatment as much, if not
more than any of the other alternatives. Short-term
effectiveness and implementability are similar for all of
the alternatives evaluated. While there are combinations
of groundwater and soil alternatives which would be less
expensive, none are as cost effective as Groundwater
Alternative 2 and soil Alternative 4.
E)
Preference for Treatment as a Principal Element
By utilizing ISVE and on-site stabilization to treat the
contaminated soil, which is suspected as a continuing
source of groundwater contamination, the selected remedy
addresses the principal threat posed by the site through
the use of treatment technologies. Therefore, the
statutory preference for remedies that employ treatment
as . a principal element is satisfied by the selected
remedy.
------- |