United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-93/236
September 1993
&EPA Superfund
Record of Decision:
Packaging Corporation of
America, Ml
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50272.101
REPORTDOCUMENTAnON 11. REPORT NO. 2. 3. Reclplant'a Acc8ulon No.
PAGE EPA/ROD/R05-93/236
4. Tltla and Subtitle 5. Raport Data
SUPERFUND RECORD OF DECISION 09/24/93
Packaging Corporation of America, MI 6.
First Remedial Action - Final
7. Author(_) 8. Performing Organization Rapt. NO'
9. Performing Organization Nama and Addr- 10 Project TaskIWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nama and Address 13. Type of Repor1 & Period Cover8d
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplemantary Notas
PB94-964118
16. Abstract (Limit: 200 words)
The 700-acre Packaging Corporation of America site is an inactive wastewater disposal
site located in Stronach Township, Manistee County, Michigan. Land use in the area is
predominantly mixed industrial and residential, with the Manistee National Forest
located to the east of the site. The primary surface water body near the site is
Manistee Lake, which borders the Packaging Corporation of America (PCA) site tb the
west. In addition, there is an unconfined upper aquifer that underlies approximately 5
miles of land under and surrounding the si:te. No residences exist within the area of
the contaminated ground water plume, and all drinking water wells within the boundary
of the plume have been replaced with an. alternate water supply. Site features include
eight seepage lagoons and four seepage areas. From 1949 to 1951, the American Box
Board Company (ABBCo) discharged spent cooking liquor, from a wood pulping process
called the neutral sulfite semichemical (NSSC) process, to Manistee Lake. The discharge
depressed the dissolved oxygen in the lake and, as a result, caused a fish kill in
1950. After the State held a public hearing, ABBCo was required to dispose of the
waste liquor on land in seepage lagoons. In response, ABBCo purchased 700 acres of
land, which make up the site, for the disposal of the NSSC waste. Subsequent to
purchasing the land, ABBCo merged with two companies to form PCA and continued to
(See Attached Page)
17. Documant Analy818 a. Descrlptora
Record of Dec'ision - Packaging Corporation of America, MI
First Remedial Action - Final
Contaminated Medium: None
Key Contaminants: None
b. IdantifieralOpen-Ended Terms
c. COSATI FleldlGroup
18. Availability Statamant 19. Security CIua (This Rapor1) 21. No. of Pag..
None 24
20. Security Class (This Page) 22. Price
None
(See ANSI.Z39.18)
See Instructions on RavafS8
OPTIONAL FORM 272 (4.77)
(Formerly NTlS-35)
Department of Commarce
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EPA/ROD/R05-93/236
Packaging Corporation of America, MI
First Remedial Action - Final
Abstract (Continued)
discharge over 7,000,000,000 gallons of spent cooking liquor, evaporator condensate, and
primary clarifier sludge into the onsite seepage lagoons. In 1972, PCA constructed a
secondary treatment plant and stopped disposing of the pulp to the lagoons. All of the
lagoons and seepage areas are currently empty with the exception of lagoon 3, which is a
company-owned solid waste landfill, and lagoon 2, which contains primary clarifier sludge.
From 1980 to 1983, PCA performed some hydrogeological investigations which ident.ified
heavy metals, including arsenic and chromium in the onsite. ground water. The site has
been divided into two OUs for remediation. This ROD addresses a final remedy for the
ground water at the site, as OU2. Studies indicate that private wells in East Lake and
Stronach are not currently contaminated, and since the source of the contamination has
been removed, and 95% of the plume has already vented into Manistee Lake, the wells are
not threatened with future contamination. The risks calculated using a reasonable exposure
scenario are within the acceptable risk range; therefore, there are no contaminants of
concern affecting this site.
The selected remedial action for this site is no further action with continued monitoring
of ground water, surface water, and residential wells. EPA has determined that exposure
to site related contaminants does not pose a current or potential risk to human health or
the environment, and that a remedial action is not warranted. .
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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.
.
. .
DECLARATION FOR THE RECORD OF DECISION
Packaging Corporation of America, Filer City, Michigan.
This decision document presents the selected remedial action for Ground Water Operable Unit
at the Packaging Corporation of America site, in 'Filer City, Michigan, which was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and Liability act
of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA) and to the extent practicable with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based upon the contents of the
Administrative Record for the site.
The State of Michigan does not concur with this Record of Decision.
U.S. EPA (EPA) has selected the 8No Remedial Action- Alternative, with groundwater and Jake
monitoring. -
~
EP A bas determined that conditions at the site pose no current or potential un~cceptable risk to
human health or the environmenL While the Packaging Corporation of America site does appear
to exhibit elevated levels of heavy metals and some organics, calculations of potential future risk
indicate that the contamination does not appear to pose an unacceptable risk to human health or
the envimnmenL Accordingly, no remedial action for the ground water operable unit is
Deces~ry to ensure protection of human health and the envimnmenL EPA will however,
continue to monitor Manistee Lake and the contaminants in the groundwater until the
contaminated plume bas fully discharged into the lake. '
EP A bas determined that no remedial action is necessary for the ground water operable unit at
this site. As this is a decision for 8No Action8, the requirements of CERCLA Section 121 for
remedial actions are not applicable and no statutory five year review will be undertaken.
However as deemed prudent by the U.S. Environmental Protection Agency, annual monitoring
will,;: ~~ me. :Mu/li ~~jL
~D~ ? Q~ v. Adamkus
~ Kegional Administrator
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} ,
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PACKAGING CORPORATION OF AMERICA
FILER CITY, MICHIGAN
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
GROUNDWATER OPERABLE UNIT
AUGUST 1993
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DECISION SUMMARY
L SITE NAME, LOCATION, AND DESCRIPTION
The Packaging Corporation of America Site (PCA) is located in Stronach Township, Manistee
County, Michigan. The site consists of approximately 700 acres of land in and adjoining Section
17 of Stronach Township (T21N, R16W). The site is bordered by the Village ofEast1ake to the
north, the Village of Stronach to the south, Manistee Lake to the west, and Manistee National
Forest to the east. The Site has eight seepage lagoons and four seepage areas. The seepage
lagoons, seepage areas, and the land between them comprise approximately 280 acres. The area
surrounding the site is mixed industrial and residential. The nearest resident is in the Village
of Stronach approximately 500 feet from the site. The Site is shown in Figure 1.
n. SITE HISTORY AND ENFORCEMENT ACTIVITIES
In July 1947, the American Box Board Company (ABBCo) bought a pulp and paper mUllocated
at F01ler City, Michigan. From 1947 to 1949 the mill used the wKraftw cooking process to
produce wood pulp. The wood pulp was used to make corrugating medium for corrugated
boxes. In late 1949, ABBCo changed their pulping process to the neutral sulfite semichemical
(NSSC) process. The NSSC process uses a solution of sodium sulfite and sodium carbonate to
cook wood. The cooking, or pulping process, dissolves the lignin in wood that binds the
cellulose fibers together; the fibers are then reformed into paper products.
From 1949 to 1951, the spent cooking liquor from the NSSC process was discharged to
Manistee Lake. The discharge depressed the dissolved oxygen in the lake and a fish kill
occuned in May of 1950. The Michigan Water Resources Commission held a public hearing
and ordered the company to dispose of the waste liquor on land in seepage lagoons. ABBCo
then purchased the 700 acres of Jand, which make up the Site, for the disposal of the NSSC
waste. The wasteWater lagoons were constructed from natural depressions in the land. A
pipeline was installed from the plant under Manistee Lake to the lagoons.. Spent pulping liquor
was discharged into the lagoons beginning February 15, 1951.
A new mill was constructed in 1956 which used the Kraft process to digest wood. In the Kraft
process, spent cooking liquor is evaporated and recovered. Evaporator con~~te, which is
very dilute liquor, was also discharged to the lagoons. Eight seepage lagoons were used for
disposal. .
A clarifier was installed in 1958 which removed cellulose fibers from the general mill
wasteWater. The fiber or primary clarifier sludge was also disposed of in the lagoons. In 1959,
ADBCo merged with Central FOlbre Products and Ohio Box Board Company to form Packaging
Corporation of America (PCA). PCA continued to discharge spent cooking liquor, evaporator
condensate, and primary c1arifier sludge into the seepage lagoons until 1972. In 1972, PCA
constrUcted a secondary treatment plant and lagooning of the pulping liquor stopped. In 1974
and 1975, clean water was pumped into the lagoons to keep the pipeline from freezing.
1
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. . .
. " .
. Figure 1
Site Location Map
Packaging corporation Of America
Lake
Michigan
MANISTEE
TOWNSHIP
FILER
TOWNSHIP
...PCA
.... . Lagoon
. Area
...
. North
Not to Scale
\
ManistBe
RJver
UIll8
Man1S188
IMw
STRONACH
TOWNSHIP
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.'
All of the lagoons and seepage areas are currently empty with the exception of lagoon 3 which
is a company owned solid waste landfill, and lagoon 2 which contains primary clarifier sludge.
Figure 2 shows the locations of the lagoons. .
PCA performed some hydrogeological investigations in 1980 through 1983. These studies
identified heavy metals, including arsenic and chromium in the groundwater. In August 1982,
the Site was ranked by U.S. EPA under the Hazard Ranking System. The Site was proposed
for placement on the National Priorities Ust (NPL) on December 19, 1982, and placed on the
NPL on September 8, 1983. A potentially responsible party search was completed on January
25, 1983 and PCA was identified as the only potentially responsible party.
On May 14, 1985, an Administrative Order on Consent for a Remedial Investigation and
FeaSibility Study (RI/FS), was executed between the sole PRP, PCA, and U.S. EPA. In April
1991, a final RI report was submitted to the U.S. EPA. On December 20, 1991, the U.S. EPA
informed PCA that the site would be divided into two operable units, Ground Water
Management and Source Control. PCA was directed to move forward with the Feasibility Study'
for the groundwater management operable unit, while the State of Michigan and PCA resolve
the issues associated with closure of the solid waste landfill. These two operable units together
will comprise the final remedy for the site. In June of 1992 a Feasibility Study for the
groundwater operable unit was concluded. In August of 1993 the State completed an additional
Jake study.
m. mGBLlGHTS OF COMMUNITY PARTICIPATION
The local residents of the Manistee Lake area, many of whom have resided in the area for years,
have been aware of pollution resulting from the PCA lagoons for 30 or more years. The
increased level of heavy industry in the Manistee Lake area has generated environmental
problems.
The announcement of the PCA site on the NPL was published in the Manistee News Advocate
on December 20, 1982, the Detroit Free Press on December 21, 1982, and by the MDNR
publication, Natural Resoun:es Register, also on December 21, 1982.
PCA held an informational meeting about its Superfund status on February 25, 1983. The
Manistee News-Advocate reported the events of that meeting OIl February 28, 1983. Community
relations efforts have been taken by other entities. The Martin Mariena Company had its wells
tested by the Michigan Department of Health, and informed employees of the water's safety a.fW
receiving the results. The City of Manistec also informed City water users of favorable results
fonowing extensive state testing of the city water in "1983.
U.S. EPA sponsored a publi~ meeting on October 25, 1985, in Stronach Township to discuss
the upcoming RVFS process and activities. On May 15 and 16, 1991, a U.S. EPA Community
Relations Coordinator conducted community interviews with public officials of~iu.ee County,
Manistee Township, Filer City Township, the Village of 1=~ct1~1ce, and residents.
On June 30, 1992 the U.S. EPA sponsored a public meeting to discuss the results of the RIIFS.
The Proposed Plan was released for public ~mment on July 21, 1993. The notice published
2
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&S9fcM
LEGEND
L-l = SEEPAGE LAGOON NUMBER
SA-A= SEEPAGE AREA LETTER
r.nnN
,
MAP
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on July 16,1993 in the Manistee News-Advocate and on July 22,1993 in the Manistee Observer
announced the beginning of the 30 day comment period. On August 10, 1993, the lake
Michigan Federation requested a 30 day extension to the comment period. The comment period
was extended for 14 days on August 20, 1993 to September 3, 1993. A Public Meeting to
discuss the preferred alternative was held in the Stronach Township Hall on August 10, 1993.
The public participation requirements of CERCLA sections 113 (k) (2) (B) (i-v) and 117 have
been met in the remedy selection process. This decision document represents the selected
remedial action for the PCA Site in Michigan, chosen in accordance with CERCLA, as amended
by SARA and, to the extent practicable, the NCP. This decision is based on the administrative
record.
IV. SCOPE & ROLE OF RESPONSE ACTION
This Record of Decision (ROD) addresses the final groundwater remedy for the site. U.S. EPA
recommends that no remedial action be taken for the groundwater operable unit, at the
Packaging Corporation of America Site for the following reasons. An action through CERCLA,
as amended by SARA, is not triggered because the risks calculated using a reasonable exposure
scenario are within the acceptable risk range. Institutional controls including a public health
moratorium prohibit the future drilling of wells into the contaminated groundwater. Should this
control fail, the groundwater itself is dark brown in color and has a strong odor and taste and
would preclude its use for human consumption. The property above the plume is zoned
industrial and demographic studies indicate that the population in the area is decreasing. All
indications are that the area will remain industrial. The source of the contamination has been
removed and 95% of the contaminated plume has already vented into Manistee Lake. Studies
indicate that the plume is actually shrinking and private wells in East Lake and Stronach are not
contaminated or threatened with contamination. The concentration of contaminants in the plume
are expected to reach MCLs in 60 years. Although some evidence suggests that the plume could
have an adverse impact on benthic organisms, the contaminants should not pose a long term
problem for the lake.
U.S. EPA has determined that exposure to site related contaminants does not pose an
unacceptable risk to human health or the environment and that a remedial action under Superfund
is not warranted. However the Site will continue to be monitored. The monitoring shall include
annual monitoring of residential wells in the area as well as monitoring of the plume itself.
Annual monitoring of the fish and sediments in Manistee Lake shall also be conducted. If review
of the Site information indicates that the No Action Alternative is no longer protective of human
health or the environment, the Agency will reevaluate this decision.
V. SITE CHARACTERISTICS
Pursuant to the authorities under CERCLA, as amended, and the National Oil and Hazardous
Substance Pollution Contingency Plan (NCP), an RI was conducted at the site. The RI began
in January 1985 and was completed in April 1991. The RI also included a Risk Assessment to
evaluate the level of risk to human health and the environment This section summarizes the
analysis presented in the RI report.
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A) Site Topography
The seepage lagoons are located in natural closed depressions or kettles located on the land
surface. Except for these kettles, the land surface on the site is nearly flat at an elevation of
approximately 670 feet mean sea level (msl). The topography drops near the shore of Manistee
T^ICP- to approximately 585 msl.
Bl Site Geology
The geology of the site consists of surficial unconsolidated glacial drift and underlying bedrock
formations. The glacial drift extends in depth from the surface to greater than 600 feet The
drift is composed of glacial outwash, clay-rich glacial till and lacustrine deposits. The surficial
deposits throughout most of the site consist of sand and gravel. These sediments were deposited
by the glacial melt water associated with the Michigan Ice Lobe.
The surficial and uppermost geologic unit on the site consists of a relatively permeable sand that
varies in thickness from 60 to greater than 250 feet. Although this unit primarily consists of
fine-to-medium-grained sand, it also contains interbedded lenses and layers of clay, gravel and
silt. These layers do not extend laterally for any significant distance.
The uppermost sand unit is underlain by a second and third unit, a lacustrine clay and a massive
clay-rich glacial till unit, respectively. The second and third units are of special interest because
they act as hydrological barriers that prevent downward migration of groundwater contamination.
O Site Surface Water Hydrology
The primary surface water body near the site is Manistee Lake. Manistee Lake is recharged by
two rivers, the Little Manistee River at the southern end and Manistee River at the
northeast end. Direct natural sources of water for the southern portion of Manistee Lake include
the Little Manistee River, direct precipitation, and groundwater discharge. Surface water runoff
into the lake is expected to be minimal given the flat lying porous nature of the soils surrounding
the lake. Surface water flow in Manistee Lake is from south to north, then exits west into the
Manistee River to Lake Michigan.
D) Site Hydrogeology
The upper aquifer is the primary recipient of the PCA effluent, and is unconfined throughout
the site with the exception of localized areas near the lakeshore where discontinuous clay layers
exist The upper aquifer underlies approximately five square miles of land bordered by Little
Manistee River to the south, Manistee Lake to the west, Manistee River to the north, and
Franklin Road and Manistee National Forest to the east. Groundwater flow direction is
generally west, horizontally towards Manistee Lake. Regional groundwater flow is radial,
south to the Little Manistee River, west toward Manistee Lake, and north toward Manistee
River.
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Both horizontal and vertical groundwater flow and transport models for the PCA site were
completed. The models indicate that the plume is expected to continue to migrate toward and
discharge into Manistee Lake. The concentrations of contaminants and their maximum flux into
the lake are also expected to decrease with time. The horizontal extent of the plume has reached
its maximum extent and should decrease with time. The maximum concentration of
nonattenuated solutes in the groundwater at the eastern edge of Manistee Lake is predicted to
decrease with time. The PeA plume, since it is slightly denser than the surrounding
uncontaminated groundwater, will tend to sink. The vertical model indicates that there is
sufficient vertical flow for the plume to discharge upward into Manistee Lake. Overall, the
plume is expected to reduce in both size and concentration and is not expected to flow
underneath Manistee Lake. Figure 3 shows a vertical profile of the contaminated groundwater
plume. . .
E) Extent of ContSimination
During the RI, several monitoring wells and residential wells were sampled. A sampling
summary is provided in Table 1 and monitoring well locations are provided in Figure 2. No
contamination was found in residential wells. The groundwater from the monitoring wells is
dark brown in color and bas a very strong odor and taste. Analytical results indicate the
presence of several organic and inorganic compounds listed in Table 2. The organic
contamination, including several tentatively identified compounds, is believed to be the
degradation products derived from wood lignin and the pulping process. The metals, with the
exception of the sodium and magnesium, are believed to be leaching from the background soils
as the contaminated groundwater moves through them. The sodium is from the cooking process
used in the PCA mill. The magnesium and chlorides are from a brine plume associated with
operations at Martin Marietta. Martin Marietta is located on the eastern shore of Manistee Lake.
A brine plume underneath the Martin Marietta Corporation mixes with a portion of the PCA
plume before the groundwater reaches Manistee Lake. Additional characteristics of the PCA
impacted groundwater include elevated total dissolved solids (TDS), and high biological oxygen
demand (BOD).
TABLE 1
SAMPLING SUMMARY
SAMPLE NUMBER OF
LOCATIONS SAMPLFS
Groundwater 50 61
Residential Water .. .
East Lake Village 2 2
StronaCh Township 2 2
Fder City 1 1
Martin Marietta 1 1
5
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TABLE 2
SUMMARY OF CHEMICALS IN THE GROUNDWATER*
Inorganic Chemicals Organic Chemicals ~
Arsenic**
Barium
Chromium**
Copper
Lead.*
Manganese
Nickel
Vanadium
2-Butanone
Benzoic Acid
2-Methylphenol
4-Methylphenol
Phenol
Butanoic Acid
Hexanoic Acid
. Other characteristics of the groundwater include high concentrations of sodium,
chlorides, and magnesium
** Concentration exceeds safe drinking-water standards
Groundwater flow direction is toward Manistee Lake. Before entering the lake the contaminated
groundwater mixes with a brine plume from Martin Marietta. Over 7 billion gallons of waste
Wele discharged to the lagoons from 1951 through 1976. Approximately 95" of the nonreactive
or nonattenuated constituents have already discharged to Manistee Lake. Figure 4 shows the
extent of contamination and monitoring well locations at the PCA site. Figures 5, 6, and 7,
show the arsenic, chromium, and lead concentrations in the groundwater, respectively.
Based on exceedences of Maximum Contaminant Levels for arsenic, chromium, and lead, a
Feasibility Study for the PCA site was developed. The Feasibility Study should be consulted
for an in depth discussion of the other remedial alternatives developed for the site.
VI. SUMMARY OF SITE RISKS
1be analytical data collected during the R1 indicated the presence of both organic and inorganic
contaminants in the groundwater. A baseline risk assessment was performed, pursuant to the
NCP, based upon present and potential future conditions at the site. 1be baseline risk
assessment determines actual'or potential risks or toxic effects the chemical contaminants at the
site pose under current and future land use assumptions. The risk assessment assumes no
corrective action will take place and that no site use restrictioos or institutional controls such as
fencing, groundwater use restrictions or construction restrictions will be imposed.
6
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FIGURE 5
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FIGURE 6
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1) ChemU:aJu!lPotential Concern
The groundwater data collected during the Rl for the PCA site was evaluated to identify which
chemicals detected at the site will be the focus of the risk assessment The finding of very few
target compound list organic constituents in the groundwater necessitated the inclusion of all but
one constituent in the quantitation of risk. Refer to Table 2 for a list of the chemicals of
potential concern in the groundwater. The maximum observed concentrations were used in the
risk assessment instead of the mean concentrations. This practice tends to overstate the chronic
toxicity health risks at the site.
2) ~osure Assessment
Exposure to the contaminated groundwater by daily ingestion over a long period of time is
improbable at the PCA site due to the discoloration of the water, the odor, and the unpleasant
taste. The area of the plume is zoned industrial and demographic studies indicate that the
population is decreasing. The source of the contamination has been removed, and 95 % of the'
contaminated plume has already vented into Manistee Lake. Studies indicate that the plume is
shrinking and private wells in East Lake and Stronach are not contaminated or threatened with
contamination. Groundwater encountered at the plume boundary is brown in color due to the
presence of the pulping liquor. The discoloration corresponds to color of approximately SO color
units. Correlation studies have shown that at less than SO color units, chromium and arsenic are
at background levels. In addition to the color and odor, the groundwater plume from the PCA
site mixes with a brine plume underneath the Martin Marietta Corporation before venting into
Manistee Lake. The increased levels of magnesium and chlorides associated with the brine
contamination causes the groundwater to have a strong unpleasant taste. Encountering
groundwater of this nature while drilling for a potable well supply would result in the rejection
of its use for that purpose.
There are no residential homes within the area of the plume. All drinking water wells within
the boundary of the plume have been replaced with an alternate water supply. Groundwater
north" of the plume in East Lake and south of the plume in Stronach is currently uncontarPinRted
and modeling and studies show that the plume is teeeding from these areas. Municipal wells
in Filer Township, located west of Manistee Lake, have not been and are not expected to be
affected. Modeling and sampling show that the plume has not migrated underneath ),fRnich¥
Lake and is not expected to in the future becav5e the groundwater flowing into the lalce from the
west side forms a hydraulic barrier "to underflow. The Michigan Department of Public Health
bas forbidden the drilling of any new wells on the contaminated property. All of the land above
the plume is zoned industrial. The VUlage of East Lake has park land above the plume; deed
restrictions limit the use of this property to park and recreational. It is unlikely that land use
patterns will change in the future; demographics show a declining population growth.
1be plume has been determin~ to be venting to Manistee Lake. For this reason, the exposure
pathways of fish ingestion, recreational use of the Jake, and aquatic toxicity impact were also
evaluated. These exposures were based on flux rates of the chemicals of concern into the Jake.
Actual Jake water sample results for arsenic, chromium and lead were used for quantification
of health risb associated with exposure to Jake water. Exposure to lagoon sediments and soils
by a hunter or trespasser was also evaluated. According to Agency guidance, actions at
superfund sites should be based on an esti~ of the reasonable maximum exposure (RMB)
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expected to occur under both the current and future land-use conditions. Consequendy the
Agency believes that a reasonable maximum exposure scenario' is a one day groundwater
ingestion scenario. This scenario assumes the receptor ingests two liters of contaminated
groundwater only once.
3) 7JIxkJty Assessment
For each exposure pathway evaluated, carcinogenic and noncarcinogenic health risks were
cbaracterized for each risk scenario.
Cancer potency factors (CPFs) have been developed by U.S. EPA's Carcinogenic Assessment
Group for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs, which are expressed in units of (mglkg-day)"l, are multiplied by
the estimated intake of a potential carcinogen, in mglkg-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 (e.g.
to account for the use of animal data to predict effects on humans).
Reference doses (RfDs) have been developed by U.S. EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting non-carcinogenic effects. RIDs,
which are expressed in units of mglkg-day, are estimates of lifetimecWIy exposure levels for
humans, including sensitive individuals. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemicals ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological studies or animal studies
to which uncertainty factors have been applied (e.g., to account for the use of animal data to
predict effects on humans). These uncertainty factors help ensure that the RfDs wDl not
underestimate the potential for adverse non-carcinogenic effects to occur.
Potential concern for non-carcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HQ) (the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a medium or across all
media to which a given population may reasonably be exposed, the Hazard Index (HI) can be
generated. The m provides a useful reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across media. Any Hazard Index
value greater than 1.0 suggests that a non-carcinogen potentially presents an vnACNTtable
health risk. .
1bere were only two suspect""carcinogens among the chemicals of concern, arsenic and' bis(2-
ehtylhexyl)phtha1ate. Arsenic is classified as a human carcinogen based on an
epidemiological study of ingestion of water containing high concentrations of arsenic. The
type of cancer linked with this contaminant is skin cancer. Skin cancers have a high cure
late in the United States because of ease of detection and efficacy of treatmenL Bis(2-
ethylhexyl)phtha1ate bas exhibited an increased incidence in dosed animals in toxicity studies.
1be endpoint health effect is liver cancer.
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. .
.. ...
All of the other constituents are systematic toxicants with threshold doses. Threshold doses
refer to a concentration at which no adverse health effects are observed. The major health
effects that established the reference doses for the site constituents were skin pigmentation
(arsenic), decreased fetal body weight (phenol), and decreased weight (cresols). At higher
concentrations the major. health effect was neurotoxicity and anemia.
4) Eeo1od011 Assessment
The effect of site contaminants on lake water was studied by performing a bioassay test on
lake water samples. The samples were collected from those areas of the' lake, both top and
bottom, that would likely be most severely impacted by the plume. No test stations exhibited
toxicity relative to the Little Manistee River which provides the majority of the influent water
for the lake, and represented background water quality.
The State did an additiona1lake study to assess the environmental impact the plume was
having on the lake, and although some evidence suggests the plume could have an adverse
impact on benthic organisms, the contaminants should not pose a long term problem for the
lake. The plume is dark brown in color and is contaminated with both organic and inorganic
contaminants. Since the color in the ground water is mainly due to lignin and other
recalcitrant organic compounds leached from wood, we do not expect these substances to
demonstrate the kind of bioaccumulative properties which can be a problem for higher
trophic level organisms, other than those which dwell in sediments. Since these types of
contaminants are not likely to be highly bioaccumulative, they therefore should not present a
biomagnification problem.
Manistee Lake has been surrounded by industry for the past 150 years. Over that time,
several industries and discharges have impacted the sediments in the lake. Studies of
Manistee Lake have been performed by the MDNR over the past several decades. These
studies indicate that the lake was seriously degraded prior to the time when the contaminated
groundwater from the PCA site reached the lake. Evidence suggests that over time the
conditions in the lake are improving. Since the majority of the contaminated plume bas
already vented into the lake, the U.S. EPA believes that this trend of improvement will
conu~. .
5)~
The aggregate chronic and acute health risks were calcu1at.ed for each of the complete
pathways. The complete pathways include contaminated groundwater ingestion, .
hunter/trespasSer exposure to lagoon solls and water, fish consumption from }.(~ni~ Lake,
and recreational use of Manistee Lake. No residential wells are currently being impacted by
the CODtami~ted plume, and no future development of the area is eApected. Exposure to the
contall'in~tM groundwater at the PCA site by daily ingestion over a long period of time is
improbable. In addition to the above factors, the nature of the contaminated groundwater, its
dark color, strong odor, and salt taste, should preclude human consumption. Accordingly
the most reasonable, yet conservative, future risk scenario is a one day exposure scenario
during which a person ingests two liters of contaminated water only once. The risks
associated with the one-day exposure scenario are summarized below.
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. .. ...
"
The risks associated with a potential lifetime exposure to the contaminated groundwater were
also calculated. Within this exposure scenario the estimated cancer risk level is 3 x 1()'4 and
the total noncaneer hazard index is 20. In this scenario, the cancer risk associated with the
PCA site is mainly attributable to exposure to arsenic in the groundwater by drinking two
liters of contaminated groundwater, containing arsenic at the reasonable maximum exposure
concentration for a period of thirty years. Arsenic and the phenols are also the major
contributors to the hazard index. Refer to the Baseline Risk Assessment for an in depth
discussion of the risk scenarios associated with the PCA site.
TABLE 3
SUMMARY OF CANCER RISKS AND HAZARD INDICES
FOR GROUNDWATER AND SURFACE WATER EXPOSURES
(POTENTIAL ONE DAY EXPOSURE)
EXPOSURE PATHWAY THI CRI
Residelltia1 Use of Groundwater
Drinking water .07 3 x 10"
Household Use 8 x lQ'4i -
TOTAL RESIDENTIAL .07 3 x 10"
Recreational Use of Lake (GW Disch)
Inadvertent Ingestion (boating) 9 x lQ'4i 1 x 10"10
Dermal Absorption (boating) 2 x 10"' -
Fish Ingestion 4 x 10"' 4 x 10"
TOTAL RECREATIONAL 4 X 10"' 4XIO"
TOTAL .07 7XIO"
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VB. STATUTORY AUTHORITY FINDING
EP A has determined that conditions at the site pose no current or potential threat to human
health or the environment. While the Packaging Corporation of America site does appear to
exhibit elevated levels of heavy metals and some organics, calculations of potential future
risk indicate that the contamination does not appear to pose an nnSicceptable risk to human
health or the environment. Accordingly, no remedial action for the groundwater operable
unit is necessary to ensure protection of human health or the environment. EP A will
however, continue to monitor Manistee Lake and contaminants in the groundwater.
EP A has determined that no remedial action is necessary for the groundwater operable unit at
this site. As this is a decision for 8No Action 8 , the requirements of CERCLA Section 121
for remedial actions are not applicable and no statutory five year review will be undertaken.
However as deemed prudent by the U.S. Environmental Protection Agency, annual.
monitoring will apply to this site.
..
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vm. EXPLANATION OF SIGNIFICANT CHANGES
There are no significant changes from the recommended alternative described in the proposed
pIan.
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