PB96-963110
EPA/AMD/R05-96/302
May 1997
EPA Superfund
Record of Decision Amendment:
Cannelton Industries Inc.*
Chippewa County, MI
9/27/1996
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DISCLAIMER
The policies and procedures set forth in this document are intended
solely for the guidance of government personnel, They are not intended,
nor can they be relied on, to create any rights, substantive or procedural,
enforceable by any party in litigation with the United States. The Agency
reserves the right to act at variance with these policies and procedures
and to change them at any time without public notice.
CAVEAT
The text of this document has been recreated by means of a scanned
copy of the original document. NTIS is not responsible for discrepancies
that may appear between this copy of the document and the original EPA
document.
NOTE
Some parts of this document may be illegible. This is the best copy of
the document currently available.
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DECLARATION OF AMENDED RECORD OF DECISION
Site Name and Location
Cannelton Industries, Inc. Site
Sault Ste. Marie
Chippewa County, Michigan
Statement of Basis and Purpose
This decision document amends the 1992 Record of Decision (ROD)
for remedial action at the Cannelton Industries, Inc. site, in
Sault Ste. Marie, Michigan. This decision document was developed
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, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
The information supporting this remedial action amendment decision
is contained in the administrative record for the Cannelton
Industries site. The attached index identifies the items that
comprise the administrative record.
The Michigan Department of Environmental Quality (MDEQ) agrees
with the approach taken in this selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of Remedy
This final remedy addresses remediation of soil and sediment
contamination by eliminating or reducing the principal threat
posed by contaminated tannery waste, contaminated soil and
sediment at the site, through containment and removal.
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The major components of the selected remedy include:
4 Excavation and removal of contaminated soil and tannery waste
down to clean sand from the Barren Zone (Zone B), tannery
waste from the southern shoreline of Tannery Bay and
surficial debris and waste materials from the western
shoreline of the site to an off-site facility for appropriate
disposal.
* Collection and treatment (if needed) of groundwater from
construction/dewatering activities and discharge to the
Publicly Owned Treatment Works (POTW). If applicable NPDES
standards are met, water can be discharged to the river.
4 Surface water, groundwater, sediment, wetland soils, and
biological monitoring, including bioavailability studies for
site specific metals (chromium, cadmium, mercury, arsenic and
lead). Action triggers will be determined and agreed upon,
by the U.S. Environmental Protection Agency (U.S. EPA) and
the MDEQ.
4 Appropriate regrading and landscaping of the western
shoreline; regrading and backfilling as necessary of the
excavated area in the barren zone to restore wetland.
4 Construction of surface drainage works and maintenance of
shoreline protection to prevent erosion.
4 Further evaluation of the stability of soils and sediments,
and monitoring study to evaluate the potential for future
releases or impacts of metal(s) to the environment;
evaluation of Tannery Bay using appropriate analysis to
determine if erosion of sediments and site materials are a
concern.
^ Construction of a sheet pile containment system or other
appropriate -remedy for the Tannery Bay area if it is
determined that erosion of sediment is a concern.
4 Modification of the amended remedy or the monitoring plan, if
indicated, following assessment(s) of the monitoring results.
Such revisions, if necessary, would be established through an
Explanation of Significant Difference (BSD) to be issued by
U.S. EPA, in consultation with the State.
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Site deed restrictions to limit future use to industrial or
recreational uses in specific areas (consistent with wetland
protection regulations), while permitting residential use of
other portions of the site.
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. The remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies, to the maximum extent practicable. However, because
treatment of the principal threats of the site was not found
practicable, this remedy does not satisfy the statutory preference
for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element.
Because this remedy will result in some levels of contaminants
remaining on-site, a review will be conducted every five years
after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
William E. Muno / Date
Superfund Division Director
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DECISION SUMMARY AMENDED REMEDIAL ALTERNATIVE
CANNELTON INDUSTRIES, INC. SITE
SAULT STE. MARIE, MICHIGAN
I. INTRODUCTION
The Cannelton Industries, Inc. (Cannelton) Site, a fenced 75-acre
site located on the shore of St. Marys River, approximately one mile
upstream of the Soo Locks in Sault Ste. Marie, Chippewa County,
Michigan was formerly a tannery which operated from 1900 to 1958.
Most of the north part of the site is wetland and is located in the
100-year floodplain, with an elevation of 3-5 feet above average
river level. The remaining areas of the site are not in the 100-
year floodplain. There are approximately 400 single-family
residences located within one-half mile of the site boundary, the
majority of which are south and west of the site. Primary land use
surrounding the site is residential and light industrial. The
tannery property is currently zoned for heavy industrial use. The
twenty-year City Master Plan (May 1995) designates the majority of
the property for general industry, with the exception of the area
from 4th Avenue to South Street and from 18th Street to 16th Street,
which has been projected as high density residential. There are no
known endangered species however, the wetlands and Tannery Bay are
currently used by wildlife as habitat.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
On September 30, 1992 EPA signed a Record of Decision (ROD) for the
final remedy at the Site. The ROD required: excavation of on-site
soil and sediments from Tannery Bay where levels of contamination
exceeded ROD cleanup standards; disposal in a cell to be constructed
on site; collection and treatment of groundwater from the
construction and dewatering activities; and groundwater monitoring
and land use restrictions for landfilled area. On April 12, 1993,
U.S. EPA and Cannelton, entered into an Administrative Order on
Consent (AOC) for Remedial Design.
III. REQUEST FOR REMEDY MODIFICATION
After completion of Pre-Design Studies and Preliminary Design,
pursuant to the AOC, Cannelton requested that U.S. EPA and MDEQ
consider and evaluate an alternate cleanup option for remediation of
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contaminated, soil and sediments in a document entitled "Alternative
Remedy Proposal" dated June 5, 1995 and revised on October 30, 1995.
In general, the alternate remediation proposal consisted of: (1)
excavation, dewatering and disposal of tannery waste and soils from
the area with highest contaminant concentrations, the Barren Zone
(Zone B), in an off-site landfill that meets Resource Conservation
and Recovery Act (RCRA) Subtitle D and Part 115 of the Michigan
Natural Resources and Environmental Protection Act (NREPA, formerly
641) solid waste landfill requirements; (2) excavation and off-site
disposal of surficial waste and debris from the western shoreline
(Zone A) and of tannery waste from the southern shoreline of Tannery
Bay (Zone D); (3) construction of a sheet pile containment system in
Tannery Bay to prevent off-site migration and erosion of sediments;
(4) appropriate regrading and landscaping of the western shoreline
and backfilling as necessary in the "barren zone" area to restore
wetland and allow for natural revegetation; (5) construction of
surface drainage system and maintenance of shoreline protection to
prevent erosion; (6) further evaluation of soil stability and
monitoring study to evaluate potential future release of metal(s)
into the environment; (7) development and implementation of a long-
term monitoring program for soils, surface water and sediments; and
(8) implementation of deed restrictions to limit land use to
industrial, recreational and residential in certain specific areas
of the site. As described in this amended ROD, U. S. EPA agreed
with the proposed changes to the 1992 selected remedy.
In addition, on June 5, 1995, the State of Michigan passed into law
Part 201 .of NREPA which changed the environmental cleanup
requirements and standards. Part 201 standards are based on
different land use scenarios and the potential exposure under each
scenario. These standards also allow for the use of engineering
(e.g. sheet piling) and institutional (e.g. deed restrictions)
controls to prevent adverse exposures. The amended remedy will be
consistent with future land use of the property. The cleanup
standards for each scenario are shown in Table 1.
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Table 1
Area Description
Remedy
Western Shoreline (Zone A)
Excavation and removal of an
estimated volume of 2,000 cubic yards
(cy) of surficial waste materials and
disposal in off-site landfill.
Regrading and landscaping of area as
appropriate for future land use.
Construction of surface drainage
works to prevent erosion.
Barren Zone (Zone B)
Excavation and removal of an
estimated volume of 35,000 cy of
soil and tannery waste down to clean
sand; dewatering of materials and
disposal in off-site landfill.
Backfilling of excavated area with
clean fill (from off-site sources) as
necessary to restore wetland habitat.
Wetland Area (Zone C)
Further evaluation of stability of
soils. Monitoring study to evaluate
the potential for future releases or
impacts of metals to the environment.
Deed restriction to limit future use
to industrial or recreational uses,
consistent with wetland protection
regulations.
Tannery Bay/Sediments (Zone D)
Further evaluation of stability of
sediments and the potential for
future releases or impacts of metals
on the environment. Evaluation of
Tannery Bay using appropriate
analysis to determine if erosion of
sediments is a concern. Construction
of a containment system or other EPA
approved remedy, for the area where
erosion of sediments is a concern (if
necessary). Removal of visible
tannery waste along the southern
shoreline of Tannery Bay (estimated
volume of 3,000 cy) and disposal in
off-site landfill.
Plant Area (Zone E)
No action required, deed restrictions
to limit future use to industrial
will apply.
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Under the amended remedy, tannery waste and soils from the barren
zone, western shoreline and southern shoreline of Tannery Bay will
be excavated and transported to an appropriate off-site facility for
disposal. Soils in the wetland (Zone C) and sediments (Zone D) will
be evaluated to determine any potential future release of metals
into groundwater and surface water. Upon review, it was determined
that further evaluation of the sediments in Tannery Bay was needed
to assess whether the area is subject to significant erosion. If
evaluation shows a concern for erosion and off-site migration of
sediments and site materials, a containment system to prevent off-
site migration, or other appropriate measure, will be constructed.
The results of studies performed will be used to better define the
long-term monitoring plan.
A requisite monitoring plan will also be designed and implemented as
part of the amended remedy to monitor the ongoing reduction of
groundwater and surface water contaminant concentrations at the
Site, and to determine the stability of soils in the wetland (Zone
C), and sediments in Tannery Bay. Biological monitoring will also
be included to ensure the protectiveness of benthic organisms and
wildlife. The requisite monitoring plan will specify the sampling
frequency, parameters, locations and protocols to be implemented and
include a contingency for further action if continued reduction of
contaminant concentrations are not observed or if site conditions
indicate that human health and the environment are not being
protected. The requisite monitoring plan will be assessed after
each sampling event to determine the ongoing site stability and
protectiveness and the need for future modification of the amended
remedy or the monitoring plan. At each monitoring event, the most
current and sensitive analytical methods will be used as they are
approved for use by the U.S. EPA.
IV. REASONS FOR AMENDING THE 1992 RECORD OF DECISION
Ground water, soil and sediment data, collected as part of the pre-
design investigations, along with major changes in Michigan's
environmental cleanup standards, present significant opportunities
for enhancement of the remedy with respect to future Site uses, and
cost-effectiveness.
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Ground Water
Based on testing conducted during pre-design investigations, the
quality of groundwater discharging from the site is protective of
St. Marys River. Only two groundwater sampling locations, bordering
the "barren zone", showed exceedances of the groundwater/surface
water interface surface water quality criteria (Interim
Environmental Response Division Operational Memorandum #8, Revision
4: "Generic Residential Cleanup Criteria" [June 5, 1995]). After
implementation of the amended remedy, the source will be eliminated
and groundwater discharging from the site is expected to remain
protective of surface water quality in the future.
Soils/Sediments
Much of the chromium and other metals are present in tannery wastes
and organic soils, which significantly reduces the mobility of
metals at the site. Previous analysis had indicated that the site
soils, wastes and sediments have low potential for leaching and are
not classified as RCRA characteristic hazardous waste with respect
to chromium or other metals. However, to confirm protectiveness of
levels left in place under the 1992 ROD, additional soil leaching
studies were performed under pre-design investigations. Based on
the results of these studies, there is minimal leaching and movement
of contaminants from site soils into groundwater and surface water.
Sediment toxicity and bioaccumulation studies performed during pre-
design investigations were in some cases inconclusive, but otherwise
indicated that the soils and sediments which are proposed to remain
on-site do not pose a significant threat to terrestrial and aquatic
organisms. Leaving the sediments in place will minimize impacts due
to sediment resuspension from dredging or excavation. If Tannery
Bay is determined to be consistently depositional, sedimentation of
clean sediments over contaminated sediments will serve as a natural
cover and as protection from erosion or migration. Aerial
photographs have shown that part of Tannery Bay is in a depositional
area but, concern remains with major storm and flood events and ice
scouring, which might cause significant erosion and off-site
migration of sediments and site materials into St. Marys River. An
evaluation of erosion/ deposition will be undertaken to evaluate the
potential for future off-site movement of site materials and
endangerment to human health and the environment.
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Based on testing conducted during the pre-design investigation, the
volume of soils/sediments requiring remediation has been more
accurately defined. The revised estimated volume of soils/sediments
which require removal is approximately 40,000 cy. This volume
represents a decrease of approximately 75 % from the 1992 ROD
estimate which was based on data collected during the Remedial
Investigation (RI) and the Feasibility Study (FS). For this reason,
short-term risks associated with transportation of excavated
materials off-site would be significantly reduced from the short-
term risks of the off-site disposal options considered as part of
the 1992 ROD. Additionally, Cannelton has proposed that on-site
excavated areas will be appropriately regraded to allow for
revegetation and formation of wetlands. The plant area, which under
the 1992 ROD would be the location for the on-site landfill, will
now be available for industrial land use and possibly other uses.
The excavation of soils followed by off-site disposal at a Subtitle
D landfill will eliminate the need for long-term deed and access
restrictions which could interfere with future use or development of
the Site. This approach also furthers U.S. EPA's policy of
attempting to return contaminated property to productive use where
feasible and appropriate.
The design and implementation of off-site disposal of soils in a
Subtitle D landfill could be completed within about 8-12 months,
whereas, the design and implementation of the on-site landfill would
require 24-36 months to complete.
V. COMPARATIVE ANALYSIS
The amended remedy will address all remaining principal threats at
the Site. These threats include: on-site tannery waste; debris and
contaminated soils in the "barren zone"; surficial waste and debris
in the western shoreline; tannery waste in the southern shoreline of
Tannery Bay; and sediments in Tannery Bay. Surface water and
groundwater will be addressed through the removal of the existing
sources.
The final remedy for the Site is intended to address the entire Site
with respect to the principal threats to human health and the
environment.
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A. The Nine Evaluation Criteria
Based on current information, the amended remedy provides an
improved balance of trade-offs with respect to the nine criteria
that EPA uses to evaluate alternatives when compared to the 1992
ROD. This section compares the performance of the amended remedy
and the 1992 ROD against the nine criteria and explains the
rationale for revising the 1992 selected remedy.
B. Comparative Analysis
Overall protection of human health and the environment. Both
alternatives provide protection of human health and the environment
by eliminating, reducing, or controlling risk through treatment,
engineering controls, institutional controls, or a combination of
these measures. Under the amended remedy, the principal criteria
for overall protection of human health and the environment were
based on the new Michigan soil, groundwater, and surface water
cleanup standards. At the present time, based on available data,
the quality of groundwater discharging from the site is protective
of the St. Marys River and is expected to remain protective of
surface water quality in the future. Localized groundwater quality
will further improve after the removal of soils and waste from the
barren zone. After implementation of the remedial actions described
in this amended remedy, the soil quality at the site will be
protective of human health and the environment under all reasonably
anticipated future land uses. Deed restrictions will be used to
ensure that future uses of the site remain consistent with the
remedial approach taken. The remedial actions described in this
amended remedy preserve a large area of wetland habitat which would
have been destroyed in completing the remedy specified in the 1992
ROD. The existing shoreline stabilization system will be maintained
over time in order to prevent erosion of shoreline. If found to be
necessary, sediments along the western side of Tannery Bay will be
contained. A monitoring study to be completed will evaluate the
long-term stability and bioavailability of contaminants in soils in
the wetland area and in sediments. The amended remedy provides the
same level of overall protection as the 1992 ROD.
Compliance with ARARs. Both remedies would be designed to meet all
current applicable or relevant and appropriate substantive
requirements (ARARs) of Federal and State environmental laws.
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Compliance with ARARs is applicable only to on-site activity.
Because disposal of contaminated soils and tannery waste and debris
will not occur* on site under the amended remedy, RCRA disposal
requirements (beyond certain on-site preparatory activities) are not
ARARs. Excavated material will be disposed of in an off-site Type
II landfill in accordance with the requirements of Michigan's solid
waste management rules and those of the landfill. Any groundwater
collected during excavation activities will be collected, treated if
necessary, and discharged to the City of Sault Ste. Marie POTW in
accordance with the requirements of the City and the MDEQ.
Cleanup standards for soil, sediments, and groundwater included in
the 1992 ROD were developed to meet requirements in the Michigan
Environmental Response Act (Act 307) administrative rules and
associated for soils, sediments, groundwater, and surface water.
The State of Michigan on June 5, 1995 enacted Part 201 of NREPA to
amend the cleanup standards and liability in Act 307. The amended
remedy will comply with Part 201 with respect to soil, groundwater,
and surface water at the site. At the present time there are no
chemical specific ARARs for sediment quality. The amended remedial
action for sediments is based on the results of the sediment
toxicity and bioaccumulation studies and further evaluation and
monitoring of the potential for migration of metals at the site.
Any remedial actions to address sediments will, be completed in
accordance with the State's action-specific and location-specific
ARARs.
Long-term effectiveness and permanence. Under the National
Contingency Plan (NCP), the analysis under this criterion focuses on
any residual risk remaining at the Site after completion of the
remedial action (55 FR 8720). The amended remedy will.be effective
over the long term through the removal and off-site disposal of
contaminated soil and tannery waste which pose a potential risk to
human health and the environment. If required, a containment system
will be constructed along the west side of Tannery Bay to prevent
migration of sediments in that area. On-going maintenance to
prevent erosion will be required.
The amended remedy for groundwater provides long-term effectiveness
and permanence by excavation and off-site disposal of contaminated
media. Long-term effectiveness for the disposed materials is
provided by the permit requirements of the disposal facility. The
amended remedy provides its effectiveness without the need to
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install, maintain and operate the on-site landfill. In addition,
the established wooded wetland areas will be preserved. Soil
remaining on-site will meet the Part 201 cleanup standards based on
expected future land use.
Reduction of contaminant toxicity, mobility, or volume through
treatment. The studies completed to date at the site have shown
that the contaminants are not mobile to a significant degree in
soils which are proposed to remain on site and that soils to be
excavated are classified as non-hazardous waste. The amended remedy
does not reduce contaminant mobility, toxicity, or volume through
treatment. Several studies have been conducted by U.S. EPA and
Cannelton to investigate possible treatment alternatives for the
materials present at the site. However, feasible volume reduction
techniques are not available for metals.
Short-term effectiveness. The amended remedy requires
transportation of excavated materials through local neighborhoods
and over public highways. The short-term risks related to these
activities can be controlled by establishing and following a project
specific safety plan in addition to strict adherence to all local,
State and federal regulations regarding the transportation of solid
waste. Because the volume of excavated material and the distance to
the off-site disposal facility are dramatically reduced under the
amended remedy, the scope of these short-term transportation risks
is much smaller than those evaluated in the prior remedy decision.
Exposure of the public and of the on-site workers to contaminated
materials during excavation and transportation off-site will be
minimized by implementation of appropriate management practices and
standard safety precautions to minimize potential short-term
impacts, including proper covering of trucks, dust control measures,
site access restrictions, air monitoring, and personal protective
equipment.
With respect to sediments, the amended remedy calls for a
containment approach (natural or engineered) as opposed to dredging,
dewatering, transport, and disposal of sediments. In the short-term,
this approach could reduce impacts to the St. Marys River associated
with dredging activities, which would include releases for suspended
solids, migration of impacted sediments, and destruction of existing
wetlands.
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The amended remedy can be accomplished within a relatively short
time frame (1 year). This time frame is significantly reduced from
the 1992 ROD, which would have taken 3-4 years to implement.
Implementability. The amended remedy uses common construction
equipment and technologies. The availability of off-site landfill
capacity was investigated during the preliminary design and it was
determined that adequate landfill volume is available and that the
ability of the receiving landfill to service the surrounding
community will not be adversely affected. Since waste disposal
would take place off-site, this alternative would not require new
construction activities. Thus, the amended remedy can be
implemented much more quickly than the 1992 ROD, which would require
significant on-site construction activity. Manifests would be
required for the trucks hauling the material. Implementability of
access restrictions and other institutional controls for both the
1992 ROD and the amended remedy would require the landowner to agree
to such controls.
Cost. Cost estimate of the amended remedy is shown in Table 2.
Costs are based on the revised volumes presented in the Alternative
Remedy Proposal. Given the reduced volumes of material which
require excavation and disposal under the revised remedy, the time
and cost required to implement the cleanup would be less than the
time and cost required to complete the 1992 ROD. In addition to the
$600,000 spent on construction of the shoreline stabilization, the
amended remedial activities are estimated to involve capital costs
of $4.6 million, and annual operation and maintenance costs of
$17,000, for a total present worth cost of approximately $5.2
million.
State acceptance: The Michigan Department of Environmental Quality
(MDEQ) agrees with the approach in this remedial action amendment.
Community acceptance. Community acceptance of the amended remedy has
been evaluated in. the Responsiveness Summary which is part of this
amended ROD. The members of the community who provided comments
generally favor the amended remedy over the previous ROD based on
the elimination of the on-site landfill. The City has informed
U.S.EPA of its support for the alternative remedy which eliminates
the need for an on-site landfill and facilitates the reuse and
development of the property. The amended remedy addresses the
City's and communities concerns regarding future land use and will
10
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Table 2
Cost Estimate1
Cannelton Industries, Inc. Site
Schedule
Description
Quantity Unit
Unit Cost
Cost
A GENERAL REQUIREMENTS
A. 1 Bonds
A.2 Insurance
A. 3 Permits
A.4 Deed Restrictions
A.5 Mobilization and Project Startup
B HEALTH AND SAFETY
B.I Development, implementation, and Maintenance of Site-specific Health and Safety Pla
C CONSTRUCTION FACILITIES & TEMPORARY CONTROLS
C.I Temporary Facilities and Utilities
C.2 Security
C.3 Equipment Decontamination Facilities
C.4 Wastewater Storage Tanks
C.5 Access Roadways
D CONTRACT CLOSEOUT, CLEANUP & RESTORATION
D.I Demobilization
D.2 South Street Repair
E SITE CLEARING
E. 1 Clearing and Grubbing
F MONITORING WELLS
F. 1 Monitoring Well Abondonment
G EXCAVATNG
G.I Excavation
G.2 Dust Control
H OFF-SITE DISPOSAL
H.I Transportation
H.2 Tipping Fees
I BACKFILLING
I.I Common Fill
1.2 Topsoil
1.3 Seeding
J SOIL COVER-WESTERN SHORELINE
J.I Base Preparation
J.2 Earth Fill
J.3 Topsoil
J.4 Seeding
J.S Erosion Control Works
K SHORELINE STABILIZATION
K.I Clearing
K.2 Access Roadways
K.3 Sheet Pile Wall
K..4 Fill Material (Aggregate)
K.5 G«ogrid
K.6 Drainage Outlet
L TEMPORARY EROSION & SEDIMENT CONTROL
L. 1 Temporary Erosion & sediemnt control - land based
L.S.
L.S.
L.S.
L.S.
L.S.
$140.000
$60,000
$17,000
$30,000
$100,000
$140.000
$60.000
$17.000
$30.000
$100.000
600
L.S.
$75,000
L.S.
L.S
40,000
1
40,000
40,000
19,000
2,200
3
15,000
10,000
2,500
3
1
1,300
I
900
1,600
1,500
1
c.y.
L.S.
c.y.
c.y.
c.y.
c.y.
acre
s.y.
c.y.
c.y.
acre
L.S.
L.F.
L.S.
L.F.
c.y.
s.y.
L.S.
$40,000
$30,000
$5,000
linear foot $25
L.S.
$3
$20,000
$15
$20
$14
$24
$3,500
$5
$14
$24
$3,500
$75,000
$16
$46,000
$250
$70
$10
$20,000
$15,000
$75.000
1
1
2
4
1
L.S.
L.S.
each
month
L.S.
J75.000
$20,000
$5,000
$1.000
$30,000
$75,000
$20,000
$10,000
$4,000
$30,000
$40,000
$30,000
$20.000
$15,000
$120.000
$20,000
$600,000
$800,000
$266,000
$52,800
$10,500
$75,000
$140,000
$60.000
$10,500
$75,000
$20,800
$46,000
$225,000
$112.000
$15.000
$20.000
$15.000
Final Costs in Remedial Design
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Schedule Description
Quantity Unit
Unit Cost
Cost
M WASTEWATER MANAGEMENT FACILITIES
M. 1 Excavation Dewatering
M.2 Water Treatment (Solids)
M.3 Sanitary Use Surcharge
N CHAIN LINK FENCES & GATES
N. 1 Temporary Fencing
O VERIFICATION SOIL SAMPLING
O.I Sampling & Analysis
Sub-Total Capital Cost
Design & Construction Management Cost (20%)
Total Estimated Capital Cost
Operation & Maintenance
Shoreline Stabilization - annual
Capped area - annual
Estimated Present Value Operation & Maintenance Cost (1=5%)
Engineering - annual
Total Present Worth Operation & Maintenance (1=5%)
TOTAL ESTIMATED COST
1 L.S.
1 L.S.
1.000.000 gallons
3,000 linear foot
1 L.S.
1 L.S. $10,000
1 L.S. $2,000
1 L.S. $5,000
S50.000 $50.000
S40.000 $40.000
$0.05 $50.000
$2 $6.000
SI 00.000 L100.000
3.595.600
719.120
$4,314,720
$10,000
$2,000
$5,000
$261,000
$4,575,720
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allow for future development of site consistent with the City's
long-term land use plans.
VI. THE AMENDED REMEDY
U.S. EPA believes that the amended remedy is the most appropriate
solution for the Site because of its performance against the nine
evaluation criteria previously discussed. The major components of
this combined remedial alternative include the following:
4 Excavation and removal of contaminated soil and tannery
waste down to clean sand from the Barren Zone (Zone B),
tannery waste from the southern shoreline of Tannery Bay
and surficial debris and waste materials from the western
shoreline of the site to an off-site facility for
appropriate disposal.
* Collection and treatment (if- needed) of groundwater from
construction/dewatering activities and discharge to the
Publicly Owned Treatment Works (POTW). If applicable
NPDES standards are met, water can be discharged to the
river.
^ Surface water, groundwater, sediment, wetland soils, and
biological monitoring, including bioavailability studies
for metals of concern (chromium, cadmium, mercury, arsenic
and lead). Action triggers will be determined and agreed
upon by the U.S. EPA and the MDEQ.
^ Appropriate regrading and landscaping of the western
shoreline; regrading and backfilling as necessary of the
excavated area in the barren zone to restore wetland.
4 Construction of surface drainage works and maintenance of
shoreline protection to prevent erosion.
+ Further evaluation of the stability of soils and
sediments, and monitoring study to evaluate the potential
for future releases or impacts of metal(s) to the
environment; evaluation of Tannery Bay using appropriate
analysis to determine if erosion of sediments and site
materials are a concern.
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4 Construction of a sheet pile containment system or other
appropriate remedy for the Tannery Bay area if it is
determined that erosion of sediment is a concern.
4 Modification of the amended remedy or the monitoring plan
if indicated following assessment of the monitoring
results. Such revisions, if necessary, would be
established through an ESD to be issued by U.S. EPA, in
consultation with the State.
4 Site deed restrictions to limit future use to industrial
or recreational uses in specific areas (consistent with
wetland protection regulations), while permitting
residential use of other portions of the site.
The goal of the soil and sediment element of this remedial action is
to dispose of those materials which pose unacceptable risks to human
health and the environment.
The estimated cost for the amended remedy is as follows:
Capital Costs: $4, 600,000
O&M (annual): $ 17,000
Net: $5, 200,000
VII. STATUTORY DETERMINATIONS SUMMARY
1. Protection of Human Health and the Environment
The amended remedy provides overall protection of human health and
the environment by removal, off-site disposal of contaminated soils,
tannery waste and materials from the site. Institutional controls
will be implemented following remediation to assure protection based
on future use of the site.
Any short term risks associated with excavation and transportation
of contaminated soils and sediments (dust generation) will be
minimized by the use of standard construction practices. Air
monitoring will be conducted to assess possible exposure during
remedial action.
No significant environmental impacts have been identified for the
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site, with the exception of the areas proposed for excavation. This
is largely due to the fact that impacts from the Site have been to
the soil and sediments in the site areas where disposal activities
took place. Studies have indicated that contaminants present in
soils and sediments proposed to remain undisturbed are not
bioavailable and therefore, do not pose a risk to the environment.
2. Compliance with ARARs
The amended remedy will be designed to meet all applicable or
relevant and appropriate requirements (ARARs) of Federal and more
stringent state environmental laws. The following discussion
highlights the ARARs that will be met by the amended alternative.
Action-Specific ARARs:
Clean Water Act (CWA) of 1977, as amended [33 U.S.C.1251]
40 CFR 122 and 40 CFR 125 - The National Pollutant Discharge
Elimination System (NPDES), which specifies the scope and
details of the NPDES permit applications, including
limitations, standards, and other permit conditions which are
applicable to all permits including specified categories of
NPDES permits. The regulations also specify schedules of
compliance and requirements for recording and reporting
monitoring results. They are administered by MDNR under Part
31 of NREPA (formerly, Michigan Public Act 245, Part 21). The
substantive requirements of these parts will apply to water
removed during excavation that- will be treated as necessary and
discharged on-site.
Part 55 of the Natural Resources and Environmental
Protection Act, 1994 PA 451 (formerly known as the Air
Pollution Act)
Emissions, which specifies emission limitations for
particulate, fugitive dust, VOCS, and or contaminants which may
be injurious to or adversely affect human health or welfare,
animal life, vegetation, or property, or interfere with normal
use and enjoyment. The substantive requirements of this
section will apply to excavation activity, and to operation of
any water treatment system that is necessary for on-site
treatment of water removed during excavation.
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Chemical-Specific ARARS:
Clean Water Act (CWA) of 1977, as amended [33 U.S.C.
12511
40 CFR 129 - Toxic Pollutant Effluent Standards, which
establish toxic pollutant effluent standards and prohibitions
of specific compounds for specified facilities discharging into
navigable waters. 40 CFR 129.104 sets the ambient water
criterion in navigable waters. These requirements may apply to
water removed during excavation that will be treated as
necessary and discharged on-site.
Part 31 of the Natural Resources and Environmental
Protection Act, 1994 PA 451 (formerly known as the
Water Resources Commission Act)
Rule 57 - Water Quality Standards (Surface Water Quality
Standards), which establishes limits for all waters of the
State for the following components: dissolved solids, pH, taste
and odor producing substances, toxic substances, total
phosphorous and other nutrients, and dissolved oxygen. These
requirements will apply to water removed during excavation
that will be treated as necessary and discharged on-site.
Part 55 of the Natural Resources and Environmental Protection
Act, 1994 PA 451 (formerly known as the Air Pollution Act)
Establishes standards for the density of emissions and emission
of particulate matter. The substantive requirements of this
section will apply to excavation activity, and to operation of
any water treatment system that is necessary for on-site
treatment of water removed during excavation.
Part 201 of the Natural Resources and Environmental Protection
Act, 1994 PA 451 (formerly known as the Michigan Environmental
Response Act) The rules promulgated pursuant to the Act set
requirements for evaluating remediation of hazardous waste
sites in Michigan. These rules establish cleanup criteria for
contaminated soil, groundwater and the groundwater/surface
water interface.
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Location-Specific ARARs
Executive Order 11988 - Protection of Flood plains. This
Executive Order is applicable at this site since a portion of
the site north of South Street lies within the 100-year
floodplain of the St. Marys River. It requires the
minimization of potential harm to or within floodplains and the
avoidance of long and short term adverse impacts associated
with the occupancy and modification of floodplains.
Executive Order 11990 - Wetlands Management. This Order is
applicable to the site. The Order requires federal agencies to
avoid, to the extent possible, the long and short term adverse
impacts associated with the destruction or modification of
wetlands.
Shoreline Protection and Management Act, Act 245 of 1970. This
Act regulates construction of permanent structures in
designated high risk erosion areas, designated flood risk areas
and designated environmental areas. Substantive requirements
will be met if permanent structures are constructed in areas
under the act.
Part 91 of the Natural Resources and Environmental Protection
Act, 1994 PA 451 (formerly known as the Soil and Sedimentation
Control Act) Establishes general soil erosion and sedimentation
control procedures and measures. Also, specifies earth change
requirements and soil conservation district standards and
specifications. These rules may apply to excavation and
grading activities.
Part 301 of the Natural Resources and Environmental Protection
Act, P.A. 451 of 1994 (NREPA). This part was formerly known as
the Inland Lakes and Streams Act.
Part 303 of the NREPA, formerly referred to as the Geomere-
Anderson Wetlands Protection Act.
Part 13 of the NREPA, formerly referred to as the Water
Resources Commission Act, regulating floodplains and floodways.
15
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3. Cost-Effectiveness
The amended remedy provides overall cost-effectiveness. A high
degree of permanence is achieved by excavation and off-site disposal
of the contaminated soil and tannery waste in a solid waste cell.
The amended remedy can be implemented at a cost which is
approximately 70 percent less than the on-site remedy selected in
the 1992 ROD.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
The amended remedy provides a better balance with respect to the
nine evaluation criteria than the remedy selected in the 1992 ROD.
Treatment technologies are utilized to the maximum extent
practicable by excavation, treatment (when required to meet
regulatory standards), and off-site disposal of the contaminated
soil and waste at an approved off-site facility. The amended remedy
represents the maximum extent to which permanent solutions and
treatment can be practicably utilized. The contamination in the
waste, soils and sediments, especially considering the low mobility
this contamination currently exhibits, can be reliably controlled
over time through engineering and institutional controls, and
treatment is therefore not practicable.
5. Preference for Treatment as a Principal Element
No principal threat which warrants treatment at the site has been
identified. While the waste at the site does not readily fit the
definition of a principal threat, it also can not be classified on
the whole as a low level threat. Given the wastes characteristics,
chiefly the low mobility of the principal contaminants, containment
of the source material would be a safe and reliable option when
coupled with institutional controls and monitoring. Therefore, by
treating the contaminated groundwater where required for off-site
disposal, the amended remedy satisfies the statutory preference for
remedies that employ treatment -of the principal threat which
permanently and significantly reduces toxicity, mobility, or volume
of hazardous substances as a.principal element.
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RESPONSIVENESS SUMMARY
AMENDED RECORD OF DECISION
CANNELTON INDUSTRIES INC, SITE
SAULT STE. MARIE, MICHIGAN
This Responsiveness Summary has been prepared to meet the
requirements of Sections 113 (k) (2) (B) (iv) and 117 (b) of the
Comprehensive Environmental Response, Compensation and Liability Act
of 1980, as amended by the Superfund Amendments and. Reauthorization
Act of 1986 (CERCLA) , which requires the United States Environmental
Protection Agency (EPA) to respond "...to each of the significant
comments, criticisms, and new data submitted in written or oral
presentations" on a proposed plan for a remedial action. The
Responsiveness Summary addresses concerns expressed by the public
and governmental bodies in written, and oral comments received by
EPA and the State regarding the proposed amended remedy for the
Cannelton Industries Site.
A. Overview
1 . Proposed Plan
On May 13, 1996, the U.S. EPA proposed an amendment to the September
30, 1992 Cannelton Industries Inc, Superfund Site Record of
Decision. The amended remedy proposes the off -site disposal of
contaminated soil and tannery waste rather than on- site containment
in a landfill cell. Continued monitoring of the site and
appropriate actions for development of site areas.
Estimated volume to be removed: 40,000 cubic yards
Time frame for remedial action: 1-2 years
Capital Costs: $4,600,000
O&M Costs: $ 17,000
Net Present Value: $5,200,000
2 . PMM^c Comment Period
A public comment period on the proposed plan was held from May 13,
1996 to June 12, 1996. In addition, a public meeting was held on
May 22, 1996. At this meeting, representatives from U.S. EPA and
the MDEQ presented the proposed changes to the remedy and answered
questions regarding these changes. Approximately 12 people attended
the meeting. Comments from the public were accepted at the meeting.
17
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During the comment period, U.S. EPA received 2 written submittals of
comments and 1 oral comment concerning the proposed plan.
B. Summary of Comments
The public comments regarding the Cannelton Industries Site are
organized into the following categories:
Summary of comments from local community
Summary of comments from MDEQ and other Agencies
COMMENTS FROM THE COMMUNITY
Two written comments were received from community residents and one
oral comment from the city manager of Sault Ste. Marie. These
comments have been summarized, please refer to the actual comment
letters and meeting transcript in the administrative record for a
more complete reading of the comments.
a) Comment: Commentor applauds the proposed changes made to the
remedy and believes that evaluating the needs of a cleanup should
be dealt with on a case by case basis.
Response: U.S. EPA appreciates the view of the commentor and
agrees with this comment.
b) Comment: Commentor believed that eliminating the on-site landfill
was a big step forward, since the key objection to previous remedy
selected was the on-site landfill that would ruin the key shoreline
of this area.
Response: U.S. EPA appreciates and acknowledges this comment.
c) Comment: Commentor stated support for the amended cleanup and
approach taken for this site since the City did not want a landfill
on site. Key elements of concern from the technical committee
[representing the City] were that the remedy allow for future
development of the site as envisioned in the City's Twenty-Year
Master Plan. For example, residential development across from the
McKinley School, north of 4th Avenue and from 16th Street to 18th
Street and the specific identification of industrial areas within
the former plant area and other areas of the site. Also of concern
18
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was the future stability of site materials and the continued
monitoring to assure protectiveness to human health and the
environment. Specific comments from the technical committee focused
on: a) the barren zone after excavation, should be filled back up to
existing grade; b) long-term assurance of wetland stability if left
in place; c) adequately analyze and evaluate the health and
environmental factors to determine stability of materials and
sediments in Tannery Bay so that no health or environmental problem
occurs in the future; d) concern that the final remedy for Tannery
Bay not preclude the future development of a deep water port
facility at some point in the future.
Response: U.S. EPA agrees with commentor's comments and
concerns with respect to future development and protectiveness
of human health and the environment. U.S. EPA has taken into
consideration the City's input when developing .the amended
cleanup and will work with the community to meet appropriate
goals. In regards to specific comments, U.S. EPA will take
appropriate measures when implementing remedy to regrade barren
zone area as necessary and establish adequate monitoring
plan(s) for maintenance of site stability and protectiveness.
COMMENTS FROM OTHER FEDERAL AND STATE AGENCIES
Responses to Michigan Department of Environmental Quality Comments:
These comments were presented in a letter from John M. Shauver and
Mitch Adelman of the MDEQ to Rosita Clarke-Moreno, U.S. EPA dated
July 1, 1996 and in a letter from Russell J. Harding, MDEQ to
William E. Muno, U.S. EPA dated July 12, 1996.
Comment: The MDEQ had several concerns and recommendations with
respect to the long-term monitoring and proposed changes to the
remedy.
Response: U.S. EPA has taken into consideration MDEQ's comments
and concerns. The recommendations made pertain to monitoring
issues which will be evaluated during remedial design and
incorporated as appropriate into the monitoring plan(s) for
this site. U.S. EPA considers the long-term monitoring of the
site to be of most importance and will take the necessary
measurements and actions as appropriate in consultation with
MDEQ.
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STATE OF MICHIGAN
JOHN ENGLER. Governo-
DEPARTMENT OF ENVIRONMENTAL QUALITY
hO.USTER BUILDING PO BOXSfcrT'JkNSING Ml 4MM.7873
RUSSEU. J. HAROMG. Dimctw
September 26,1996
Mr. William E. Muno, S-6J
Director, Superfund Division
US. Environmental Protection Agency, Region 5
77 West Jackson Boulevard
Chicago, Illinois 60604
Detti Mi. Muno:
«
On behalf of the State of Michigan, the Michigan Department of Environmental Quality (MDEQ) has
reviewed the September 19, 1996 Amended Record of Decision (ROD) with Declaration and
Responsiveness Summary, received September 19,1996, for the Cannelton Industries, Inc.
Superfund site located in the city of Sault Stc. Marie, Chippcwa County, Michigan. The MDF-Q is
pleased to inform you that the state concurs with the selected remedial alternative as outlined in the
amended ROD.
We look forward to working with you and your staff assisting in the development of remedial design'
and operation and maintenance documents, and in uvei seeing their implementation. If you have any
questions, please contact Mr. Bruce Van Otteren, MDEQ Project Manager, at 517-373-8427, or you
may contact me.
Sincerely,
Russell J. Harding
Director
517-373-7917
cc: Ms. Rosita Clarke-Moreno, EPA
Mr. Alan Howard, MDEQ
Mr. Bruce Van Otteren, MDEQ/Cannelton File (16)
S5P0130.
(1085)
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.3. EPA ADMINISTRATIVE =
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U.S. EPA ADMINISTRATIVE RECORD Afi
REMEDIAL. ACTION
CANNELTON INDUSTRIES
SAULT. STE. MARIE, MICHIGAN
UPDATE #7
05/16/95
DOCI DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PASES
1 04/08/93 Bayka, J. and Traub, J., U.S. EPA Heiorandui re: Execution of Attached 70
Peterson, L, U.S. Administrative Order on Consent for Reiedial
EPA Design (./Attached Statement of Hork for the
Reiedial Design
2 10/01/93 Clarke, R., U.S. EPA Kerrigan, J., At ax Letter re: U.S. EPA's Couents on the Pre &
Resource Conservati- Design StudiesWork Plan (2nd Revision)
on Coipany
3 12/12/94 Clarke, R., U-S. EPA Lie, P., Cyprus Aiax Letter re: U.S. EPA's Approval a/Attached 12
Minerals Coipany Modifications of the Revised Pre Design
Studies Report
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AR
-EMEDIAL
JPDATE *»S
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
CANNELTON INDUSTRIES SITE
SAULT STE. MARIE, MICHIGAN
UPDATE #9
09/18/96
AR
DOCI DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
==:::
1 07/01/96 Shauver, J. and H. Clarke-Moreno, R., Letter re: HDEQ's Recommendations Concerning
Adelman, HDEQ U.S. EPA Additional Studies to be Conducted by
Hichigan State University for the Cannelton
Site M/Attachients
2 07/12/96 Harding, R., HDEQ
Nuno, M., U.S. EPA Letter re: NDEQ's Review and Concurrence,
Kith Modifications, of the Proposed Plan for
Amending the Record of Decision
3 07/17/96 Schauver, J. and H. Clarke-Horeno, R., Letter re: Additional Studies Proposed in the 1
Adelian; HDEQ
4 07/24/96 Petito Boyce, C.,
PTI Environmental
Services
U.S. EPA '
Clarke-Horeno, R.,
U.S. EPA
Nay 1996 Revised Proposed Plan
Letter re: Suiiary of Assumptions Used in
Deriving Soil Screening Levels for Lead at
the Cannelton Industries Site
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
CANNELTON INDUSTRIES SITE
SAULT STE. MARIE, MICHIGAN
UPDATE #1O
09/20/96
AR
DOCI DATE
=r:= :===
AUTHOR
RECIPIENT
1 05/22/96 NorthNest Reporting U.S. EPft
2 06/05/96 Concerned Citizens U.S. EPA
TITLE/DESCRIPTION
Transcript of Hay 22, 1996 Public Meeting
THO Public Conent Letters re: the Revised
Proposed Plan Received Hay 14 and June 5,
1996 (PORTIONS OF THIS DOCUHENT HAVE BEEN
REDACTED)
PAGES
21
3 00/00/99 U.S. EPA
Record of Decision Aiendient (PENDING)
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