PB98-964106
                                 EPA 541-R98-093
                                 November 1998
EPA Superfund
      Record of Decision:
       Petoskey Municipal Well Field
       Petoskey, MI
       9/30/1998

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                                      DECLARATION

                          SELECTED REMEDIAL ALTERNATIVE
               TO ADDRESS SOIL AND GROUNDWATER CONTAMINATION
                                          AT THE
                        PETOSKEY MUNICffAL WELL FIELD SITE
                                  PETOSKEY, MICHIGAN
Statement of Basis and Purpose

This decision document presents the selected remedial action for the soil and groundwater contamination
at the Petoskey Municipal Well Field Site (Site), in Petoskey, Michigan. This remedial action was
chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act (SARA) of
1986, and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision is based on the administrative record for this Site.

The State of Michigan concurs with the selected remedies.  The Letter of Concurrence is attached to this
Record Of Decision.

Assessment of the Site

Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing
the response action in this Record of Decision (ROD), may present an imminent and substantial
endartgerment to public health, welfare, or the environment.

Description of the Selected Remedies

The selected remedial actions are  final remedies for the Site. This ROD selects Soil Alternative 3 and
Groundwater Alternative 2 to address soil and groundwater contamination at the Petoskey Municipal
Well Field  Site. The soil alternative includes the construction and operation of a Soil Vapor Extraction
(SVE) system to remove trichloroethene (TCE) from deep, unsaturated  soils.  In addition, the excavation
of the top 5 feet of soil from the property will remove organics and inorganics that pose a direct contact
threat for future residents (if the property is developed) and pose a threat of continued leaching to
groundwater. A deed restriction will be placed on the PMC property identifying the landowner's "due
care" responsibilities in accordance with provisions of Michigan Part 201  if the current structure is
partially or totally removed.

Once the PMC soils have been addressed by SVE and excavation, the residual contaminated groundwater
will be allowed to "naturally attenuate," with the remaining contamination diluting, dispersing, and
discharging into Lake Michigan.  No adverse environmental impacts are anticipated from the short-term
continued discharge of contaminated groundwater. Contaminated groundwater has been naturally
moving to and discharging into Lake Michigan for approximately twenty years. Groundwater
contaminant concentrations are expected to decrease dramatically once  the source area soils are
addressed.  An aggressive monitoring program will be implemented to establish a baseline of
contaminant concentrations in groundwater. Routine monitoring will be implemented to track
contaminant levels, consistent with anticipated decreases from natural attenuation. A Contingency Plan

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will be included with the "monitored natural attenuation" approach to evaluate when and how follow-up
actions will be implemented if decreases in contaminant concentrations do not occur as quickly as
anticipated.  Additional deed restrictions preventing exposure to the contaminated groundwater will be
implemented for the PMC property and all properties where the contaminated groundwater plume exists
and migrates. This remedy also assumes that the Ingalls municipal well will continue to remain unused
as a drinking water source.

Statutory Determinations

The selected remedies are protective of human health and the environment, comply with Federal and
State requirements that are legally applicable or relevant and appropriate to the remedial actions, and are
cost effective.  The remedies utilize permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable. The remedies do not  satisfy the statutory preference for
remedies that employ treatment that reduces the toxicity, mobility, or volume as a principal element.

A review of the soil and groundwater remedies selected in this ROD will be conducted five years after
commencement of the remedial actions to ensure that the remedies continue to provide adequate
protection of human health and the environment.
William E. Muno      7                            Date
Director, Superfund Division

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X-/EPA
            RECORD OF DECISION

                 FOR THE
     PETOSKEY MUNICIPAL WELL FIELD SITE
                   IN
            PETOSKEY, MICHIGAN
               September 1998

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1.0     SITE NAME, LOCATION, AND DESCRIPTION	 1

2.0     SITE HISTORY AND ENFORCEMENT ACTIVITIES	 1

3.0     HIGHLIGHTS OF COMMUNITY PARTICIPATION	:	 3

4.0     SCOPE AND ROLE OF RESPONSE ACTION  	 4

5.0     SUMMARY OF SITE CHARACTERISTICS	 5
       5.1     Site Geology 	 5
       5.2     Site Hydrogeology	 5

6.0     MAJOR FINDINGS OF THE REMEDIAL INVESTIGATION AND RISK ASSESSMENT . . 6
       6.1     Extent of Soil Contamination  	 6
              6.1.1          Soils - Exceedances of State Chemical-Specific ARARs	 7
              6.1.2          Soils - Exceedances of Federal Chemical-Specific ARARs	  10
       6.2     Extent of Groundwater Contamination	  10
              6.2.1          Groundwater - Exceedances of State Chemical-Specific ARARs  ...  11
              6.2.2          Groundwater-Exceedances of Federal Chemical-Specific ARARs  .  12

7.0     SUMMARY OF SITE RISKS 	  12
       7.1     Baseline Risk Assessment - Chemicals of Potential Concern	  13
       7.2     Baseline Risk Assessment - Exposure Assessment	  14
       7.3     Baseline Risk Assessment - Toxicity Assessment  . . .	  15
              7.3.1          Noncarcinogenic Effects	  15
              7.3.2          Carcinogenic Effects	  16
       7.4     Baseline Risk Assessment - Risk Characterization	  16
              7.4.1          Results - Current Land Use Scenarios	  16
              7.4.2          Results - Future Land Use Scenarios	  17
       7.5     Uncertainties 	  19
       7.6     Environmental Risks 	  19

8.0     DESCRIPTION OF ALTERNATIVES	  20
       8.1     Soil Alternative 1. No Action	  20
       8.2     Soil Alternative 2: Engineered Cap with Deed Restrictions  	  20
       8.3     Soil Alternative 3: Soil Vapor Extraction (SVE) with Excavation and Off-Site Disposal
              of Contaminated Soil	  21
       8.4     Groundwater Alternative 1: No Action  	  22
       8.5     Groundwater Alternative 2: Monitored Natural Attenuation of Groundwater
              Contamination 	  22
       8.6     Groundwater Alternative 3: Pump and Treat / Groundwater Monitoring 	  23

9.0     COMPARATIVE ANALYSIS OF ALTERNATIVES: THE NINE CRITERIA  	  24
       9.1     Overall Protection of Human Health  and the Environment 	  24
              9.1.1          Soil Alternatives  	  24

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              9.1.2          Groundwater Alternatives	  25
       9.2     Compliance with ARARs  	  26
              9.2.1          Soil Alternatives 	  26
              9.2.2          Groundwater Alternatives	  27
       9.3     Long-term Effectiveness and Permanence 	  27
              9.3.1          Soil Alternatives 	  27
              9.3.2          Groundwater Alternatives	  28
       9.4     Reduction of Contaminant Mobility, Toxicity and Volume Through Treatment	  28
              9.4.1          Soil Alternatives	  28
              9.4.2          Groundwater Alternatives	  29
       9.5     Short-term Effectiveness	  29
              9.5.1          Soil Alternatives 	  29
              9.5.2          Groundwater Alternatives	  30
       9.6     Implementability	  30
              9.6.1          Soil Alternatives	  30
              9.6.2          Groundwater Alternatives	  30
       9.7     Cost	  31
              9.7.1          Soil Alternatives 	'.	  31
              9.7.2          Groundwater Alternatives	  31
       9.8     State Acceptance	  31
              9.8.1          Soil Alternatives	  31
              9.8.2          Groundwater Alternatives      	  31
       9.9     Community Acceptance	'	  32
              9.9.1          Soil Alternatives 	  32
              9.9.2          Groundwater Alternatives	  32

10.0   THE SELECTED REMEDY	  32
       10.1    Additional Discussion of Selected Soil Remedy - Soil Alternative 3  	  33
       10.2    Additional Discussion of Groundwater Remedy - Groundwater Alternative 2 	  35
       10.3    Cleanup Levels  	  36
              10.3.1         Soil Cleanup Levels	  36
              10.3.2        Groundwater Cleanup Levels  	  37
       10.4    Environmental Monitoring / Contingency Plan  for Follow-Up Action  	  37
       10.5    Institutional Controls	  39
       10.6    Natural Attenuation	  39
       10.7    Five-Year Site Reviews	  40

11.0   STATUTORY DETERMINATIONS	  40
       11.1    Protection of Human Health and the Environment	  40
       11.2    Compliance with ARARs  	  40
                .2.1         Water Regulations	  41
                .2.2        Soil Regulations	  42
                .2.3        Air Regulations  	  42
                .2.4        Waste Management and Disposal Regulations	  42
                .2.5        Transportation ARARs 	  43
                .2.6        Construction ARARs	  43
       11.3    Cost Effectiveness	  43

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       11.4   Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
              Recovery Technologies to the Maximum Extent Practicable                     . .  44
       11.5   Preference for Treatment as a Principal Element  	  44

12.0   DOCUMENTATION OF SIGNIFICANT CHANGES 	  45
TABLES

Table 1:

Table 2:

Table 3:


FIGURES

Figure 1:

Figure 2:

Figure 3:

Figure 4:

Figure 5:

Figure 6:

Figure 7:

Figure 8:
Chemicals of Potential Concern in Soil and Groundwater

Quantitative Summary of Site Risks for Current and Future Risk Scenarios

Table of ARARs for Selected Alternatives (Soil Alternative 3, Groundwater Alternative
2)



Northwest Michigan Map - Showing General Site Location

General Site Map Showing Site Features and Location of Lake Michigan

Figure Showing Exceedances of Chemical-Specific Soil ARARs

Figure Showing Exceedances of Chemical-Specific Groundwater ARARs

Soil Alternative 2 - Figure Showing Proposed Response Area

Soil Alternative 3 - Figure Showing Proposed Response Area

Groundwater Alternative 2 - Figure Showing Proposed Response Area

Groundwater Alternative 3 - Figure Showing Proposed Response Area
APPENDICES

Appendix A:   Concurrence Letter from the State of Michigan

Appendix B:   Responsiveness Summary

Appendix C:   Index to Administrative Record

Appendix D:   City of Petoskey Ordinance No. 651
Appendix E:   Groundwater Surface Water Interface (GSI) Criteria /
              Generic Soil Criteria Protective of the GSI

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                            RECORD OF DECISION SUMMARY
                          For Soil and Groundwater Contamination
                                           at the
                                Petoskey Municipal Well Field
                                     Petoskey, Michigan
1.0     SITE NAME, LOCATION, AND DESCRIPTION

The Petoskey Municipal Well Field Site (the "Site") is located in Petoskey, Michigan.  The City of
Petoskey is located in the northwest corner of Michigan's lower peninsula (Figure 1). The Site includes
contaminated source area soils and the groundwater that has been affected by contaminants migrating
from the source area. Groundwater contamination has impacted the Ingalls Avenue Municipal Well
("Ingalls Well") which is located on the shore of Lake Michigan and, until recently, supplied water to
residents of the City  of Petoskey.

The Petoskey Manufacturing Company, Inc.  (PMC) is a small fabricating operation that was established
in 1946 as a die cast  manufacturer, continued with painting operations in the late 1960's, and remains in
operation today. Although PMC remains in operation at the site, the City of Petoskey has identified the
PMC property as "multi-family residential" in its Master Zoning Plan.  The Master Zoning Plan has not
yet been implemented for the PMC property.

PMC is located at  200 West Lake Street in Petoskey, Emmet County, Michigan.  PMC has been
identified by the U.S. EPA and the Michigan Department of Environmental Quality (MDEQ) as the
source of contamination at the Petoskey Municipal Well Field Site. Because of the connection between
PMC and the Superfund Site, the Site is also commonly known as the "PMC Site."  Disposal of spent
solvents and/or paint sludge on the ground surface outside the PMC building has contaminated soils and
groundwater in the vicinity of the source area.  Soils at the PMC facility are contaminated with volatile
organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and inorganic compounds.
Water downgradient from PMC contains VOCs, including trichloroethene (TCE), and low levels of
SVOCs and inorganic contaminants. Until late  1997, the nearby Ingalls Well was used to service the
population of Petoskey and supplied 60 to 70%  of the City's water needs.

The PMC  source area is located approximately 500 feet south of Little Traverse Bay (Figure 2).  In
general, groundwater from the PMC source area moves towards the bay and into Lake Michigan and also
moved toward the Ingalls Avenue Municipal Well when the well was pumping. The Bear River is
located approximately 500 feet east of the PMC Site.  Geology at the Site consists of a thin layer (1 to 30
foot thick) of sands and gravels overlying  the approximately 400 foot thick Devonian age Traverse
Group. The Traverse Group consists of fractured limestone with thin interbeds of shale.
2.0    SITE HISTORY AND ENFORCEMENT ACTIVITIES

In 1981, the Ingalls Well was found to be contaminated with VOCs. In 1982, the U.S. EPA and MDEQ
(formerly the Michigan Department of Natural Resources) identified PMC as a potentially responsible
party for the water supply contamination. Analysis of samples obtained from the area west of the PMC

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building indicated that elevated levels of VOCs were present in the soils.  In 1982, under the direction of
the MDEQ, PMC removed approximately 131 cubic yards of contaminated soil, backfilled the
excavation, and capped it with a polymembrane liner and a small amount of soil.  In addition, the MDEQ
installed several monitoring wells to try to determine the extent of groundwater contamination.

Prior to 1982, TCE concentrations of approximately 50 parts per billion (ppb) were found in the Ingalls
Well. Following the removal of the contaminated soil, TCE concentrations in the municipal well
decreased to approximately 4.0 ppb and have more recently remained relatively stable in the 1 to 3 ppb
range.  A MDEQ groundwater study conducted in 1982 and 1983 confirmed the presence of groundwater
contamination and found that the local groundwater flow from the PMC Site was toward the Ingalls Well
when the well was pumping.  The MDEQ also indicated that additional work was necessary to further
identify and characterize the source(s) of contamination.

In July 1983, the PMC Site was evaluated using the Hazard Ranking System. The PMC Site was
subsequently added to the National Priorities List on September 8,  1983.

In 1984, the U.S. EPA negotiated  an Administrative Order by Consent with PMC. This Order required
PMC to conduct further hydrogeological studies. PMC retained an environmental consultant and
completed the work under the direction of the U.S. EPA and MDEQ. Work included the installation of
four monitoring well clusters, groundwater and soil sampling, and groundwater flow analysis.

In 1987, PMC signed another Administrative Order by Consent with the U.S. EPA.  PMC agreed to
conduct a full Remedial Investigation/Feasibility Study (RI/FS) to determine the nature and extent of
contamination and investigate appropriate remedial alternatives to address the contamination.  PMC
started the work plan  phase of the Administrative Order, but in 1990 the U.S. EPA relieved PMC of
conducting further RI/FS work due to delays in developing the work plan and PMC's questionable
financial  ability to complete the work required by the Administrative Order.  The U.S. EPA entered into
a State Cooperative Agreement with the MDEQ in  1990, in which the MDEQ agreed to perform the
RI/FS and U.S. EPA agreed to fund the investigation.

In April 1989, the Agency for Toxic Substance and Disease Registry (ATSDR) prepared a Health
Assessment for the PMC Site. This assessment concluded that:

       The "site is of potential public health concern  because of the risk to human health that could
       result from possible exposure to hazardous substances at levels that may result in adverse health
       effects over time."

       "Human exposure to TCE and DCE [dichloroethene] has occurred via ingestion of contaminated
       water and inhalation of contaminated air."

In 1990, hydraulic fluid seeped through the compressor room wall (located on the northwest corner of the
building) and further contaminated site soils outside the building. MDEQ and the U.S. EPA Technical
Assistance Team (TAT) performed an inspection of the site and the spill area in June of 1990.  Both
MDEQ and U.S. EPA collected soil samples. See the  Phase II Remedial Investigation  (RI) report for
further discussion of the hydraulic fluid spill and sample results.

In 1992, MDEQ retained EDER Associates to develop a work plan and to implement the investigation of

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soil and groundwater contamination. RJ field activities were conducted from September 1992 through
March 1993. Data collected during these activities were used to complete a "Phase I" draft RJ report in
December 1993. Review of this report by EPA and MDEQ revealed data gaps and the need for additional
investigation. MDEQ retained Malcolm-Ptrnie, Inc. to conduct the follow-up "Phase II" investigation and
prepare a RI Report to address all of the relevant data collected to date.

Concurrent with the state-led RI, EPA began a focused FS to examine the impact of site-related
contamination on the Ingalls municipal well.  The focused FS concluded that VOC levels at the well at that
time were below the maximum contaminant levels (MCL) promulgated pursuant to the Safe Drinking
Water Act.  The focused FS also determined that risk levels calculated under present  industrial and future
residential land-use scenarios based on current levels of contamination are within the EPA's acceptable
risk range.  However, because of the uncertainty associated with future concentrations of VOCs in the
Ingalls municipal well, in 1993 EPA proposed the construction of an air stripper at the Ingalls well to
reduce existing  levels of VOCs, especially trichloroethene (TCE), in the well and to ensure that the city's
water supply is  not adversely impacted by VOC contamination detected in groundwater near the Ingalls
municipal well.  This action was proposed as an interim measure to fully ensure protection of the city's
water supply with regard to PMC site-related contamination.

In 1995, EPA signed a record of decision (ROD) for providing on-line treatment of groundwater at the
Ingalls municipal well.  Air stripping was identified as the appropriate treatment technology, with carbon
treatment as a contingent remedy.  The State of Michigan requested that the city's construction of a new
drinking water source be considered an enhancement of the selected remedy under 40 CFR 300.515(f)-
Because enhancement of the selected remedy was requested and specifically permitted under the ROD,
EPA agreed to contribute the capital cost of the  selected remedy to  be used by the state to partially defray
the city's cost of replacing the Ingalls well. Therefore, EPA's selected remedy of an  air-stripper on the
Ingalls Well was not and will not be implemented. In late 1997, the City of Petoskey completed the
construction of  its replacement municipal wells  and use of the Ingalls Well ceased.

In February 1998, the MDEQ released the Phase II RJ Report. The report summarizes soil results from
the Phase I  (Eder) and Phase II (Malcolm-Pirnie) site investigations and groundwater data from Phase II
sampling. Groundwater contaminant data from  the Phase I investigation were not included  in the Phase
II RJ report because the Phase II groundwater data is expected to better represent current conditions. The
Phase II RI report was sent to the site  repository in February 1998.  Another copy of the Phase II RJ
report was sent  to the site repository in July of 1998, as part of the administrative record for the Proposed
Plan for the Petoskey Municipal Well Field Superfund Site.

In January  1998, the U.S. EPA retained Tetra Tech EM, Inc. for preparation of a Feasibility Study (FS)
report. A draft  FS report was completed in July 1998 and was included in the site administrative record.
The Proposed Plan Fact Sheet invited  public comment on the draft FS, in addition to  the summary of
alternatives presented in the Fact Sheet itself. The MDEQ submitted comments on the draft FS during
the public comment period. The FS was finalized on September  18, 1998. The final  index to the
Administrative  Record is included in Appendix  C. There are no significant differences between the
alternatives proposed for public comment and the remedies selected in this ROD.
3.0    HIGHLIGHTS OF COMMUNITY PARTICIPATION

As part of its community relations program, MDEQ opened an information repository at the Petoskey

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Public Library, 451 East Mitchell Street, Petoskey.

The MDEQ handled community relations activities during the Phase I and Phase II site investigations.
During that time, the U.S. EPA also was involved with community relations activities in order to inform
the public about the availability of the Proposed Plan for the interim ROD, and to solicit public comment
on the proposed interim remedial alternatives.

Upon MDEQ's completion of the Remedial Investigation, the U.S. EPA took the lead in developing the
FS report and preparing the Proposed Plan Fact Sheet to support this ROD. The Administrative Record,
which contains the documents upon which this ROD is based, is available in the site repository. The
Administrative Record includes MDEQ's RI report, the draft and final FS reports, MDEQ regulations,
and other information critical to the informed selection of remedies.

U.S. EPA notified the local community, by way of the Proposed Plan Fact Sheet, of the Agency's
recommendation of remedial alternatives for the PMC Site.  To encourage public participation in the
selection of a remedial alternative, U.S. EPA scheduled a public comment period from July 20, 1998, to
August 18, 1998.

Additionally, on July 22, 1998, U.S. EPA held a public meeting at the Petoskey Municipal Building. At
the meeting U.S. EPA presented a summary of site  history, reviewed the remedial alternatives being
considered, and presented its recommended alternatives for soil and groundwater.  U.S. EPA offered
MDEQ the opportunity to participate and/or make a presentation.  The MDEQ elected not to formally
participate in the public meeting, but the MDEQ site project manager was in attendance at the meeting
and did participate in responding to questions'from the public. A transcript of this meeting is included as
part of the Administrative Record that supports this ROD.  U.S. EPA's responses to oral comments
received during this public meeting and to written comments received during the public comment period
are included in the Responsiveness Summary which is attached to this ROD.

News releases announcing the public comment period, the public meeting and the availability of the
Proposed Plan, were sent to the Petoskey News Review.  The information was also provided to local
media, including:

                      WPBN-TV (7) NBC, Traverse City;
                      WWTV-TV  (9) CBS,  Cadillac;
                      WWUP-TV (10) CBS, Sault St Marie;
                      WCMU-TV  (36) PBS, Mt  Pleasant;
                      WGTQ-TV (29) ABC, Traverse City;
                      WTDM-TV, Traverse City;
                      WCMV-TV, Cadillac;
                      WJML (AM & FM) Petoskey; and
                      WKHQ (FM), Charlevoix.
4.0     SCOPE AND ROLE OF RESPONSE ACTION

The selected remedies for Petoskey Municipal Well Field are intended to be the final response actions at
the Site. As outlined in the FS report, the purpose of the selected alternatives is to meet the following

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remedial goals identified for the site:

               Prevent direct contact with or ingestion of soil under current industrial and future
               residential land-use scenarios (to the extent necessary based on risk assessment results and
               chemical-specific applicable or relevant and appropriate requirements (ARARs)).

        •       Protect groundwater from being contaminated at levels exceeding MCLs by leaching of
               residual contamination from soil to groundwater.

        •       Prevent future exposure to groundwater containing site-related contamination at
               concentrations exceeding MCLs.

        •       Restore the aquifer to its highest beneficial use (i.e., drinking water).

               Protect surface water from site-related contaminants in groundwater in accordance with
               provisions set forth in Part 201 of the Michigan Natural Resources and Environmental
               Protection Act (NREPA), 1994 PA 451, as amended, and Part 31 and  associated rules.

The final remedies selected for the Petoskey Municipal Well Field Site include the excavation of 5 ft of
soil along the north site of the PMC building, the operation of a Soil Vapor Extraction (SVE) system at
the northwest corner of the building, and implementation of deed restrictions on the PMC property
identifying the "due care" responsibilities of the current and future owners of the property in accordance
with Michigan Part 201 requirements.  The remedial actions also include the construction of new
groundwater monitoring wells, the long-term monitoring of groundwater contaminant levels, and deed
restrictions to reliably prevent unacceptable exposure to contaminated groundwater.
5.0     SUMMARY OF SITE CHARACTERISTICS

5.1     Site Geology

        Site stratigraphy was interpreted from information obtained from borings drilled at the site and
        local water well logs.  Unconsolidated deposits at the site range in thickness from approximately
        5 to 45 feet. These deposits consist of up to 6 feet of sand overlying a layer of large limestone
        boulders and cobbles in a clayey, silty, and sandy matrix. The limestone fragments vary in
        diameter from a few inches to 15 feet. Immediately below this boulder and cobble layer is
        limestone bedrock that is part of the approximately 400-foot-thick Devonian-aged Traverse
        Group. The upper portion of the limestone bedrock is highly weathered. Interfaces between the
        limestone cobbles and weathered bedrock and between the weathered bedrock and competent
        bedrock are extremely variable along the shore  of Lake Michigan near the site and often difficult
        to determine.

5.2     Site Hydrogeology

        During preliminary investigations and the Rl, 31 groundwater monitoring wells were installed to
        investigate site hydrogeologic conditions. A single, shallow, unconfined aquifer corresponding to
        the boulder and cobble layer and limestone bedrock was discovered during the RI. Shallow

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       groundwater at the site is typically present at approximately 8 to 19 feet below ground surface
       (bgs). The hydraulic conductivity of the shallow aquifer calculated from slug test data collected at
       the site ranges from 7.67x10"4 centimeters per second (cm/sec) at well MW-105D to 2.11x10"3
       cm/sec at well MW-201S, which is typical of limestone, silty sand, and sand aquifers.

       Data collected from a pumping test conducted during the Rl indicates that the water level of Lake
       Michigan greatly influences water levels in the monitoring wells.  During the pumping test, water
       levels in monitoring wells located near the pumping well fluctuated even though a constant
       pumping rate of 35 gallons per minute (gpm) was maintained in the pumping well. A strong
       correlation was observed between fluctuations in lake water level and monitoring well water level,
       indicating that large-scale lake effects influence  static water levels in the wells more than the
       pumping.

       Local groundwater flow is also heavily influenced by changes in Lake Michigan water level. In
       general, groundwater flows from the highlands toward the lake, but in the beach shelf between the
       bluff and the lake where the site is located, water levels are approximately the same as the lake
       water level.  A lag time is associated with the aquifer response to changes in lake level, thus
       resulting in local reversals of groundwater flow direction.  When the lake is at low ebb,
       groundwater flow is toward the lake. As the lake level rises, the lake elevation becomes higher
       than the groundwater elevation in the aquifer and lake water flows into the  aquifer (away from the
       lake). Both previous and current water level measurements show  that the horizontal gradient
       across the site is essentially flat.

       As a result of these conditions, equilibrium conditions, which are  the basis  for static water level
       measurements, could not be depicted graphically based on RI data. Aquifer conditions are in a
       constant state of flux and undergo reversal on a frequent basis.

       Groundwater flow at the site is also  controlled by voids between limestone boulders and by
       fractures in the limestone bedrock.  Groundwater flow through fractures near the Ingalls municipal
       well appear to be more pronounced; however, the flow rate of groundwater near this well
       historically has been irregular due to periodic pumping of the Ingalls well.   .
6.0    MAJOR FINDINGS OF THE REMEDIAL INVESTIGATION AND RISK ASSESSMENT

6.1    Extent of Soil Contamination

       Surface and subsurface soil samples were collected from the site in 1992 and 1995 as part of the
       Remedial Investigation.  Surface soil samples were collected from 0 to 1 foot below ground
       surface (bgs), and subsurface soil samples were collected from 1 to 18 feet bgs. Soil
       contamination appears to be limited to the PMC facility.  Although contaminant concentrations
       in the PMC soils are generally low, soil contamination at some locations extends into the
       subsurface to the water table. The sampling results indicated the presence of several VOC's,
       semi volatile organic compounds, pesticides, and inorganic (metal) compounds. TCE is the
       primary VOC. The semivolatile organic compounds are likely from oils and lubricants which
       contain petroleum products.  Pesticide detections appear to be isolated and are most likely
       related to localized spraying for pest control. The inorganics appear to be related to PMC's
       manufacturing operations.  The  site investigation found that:

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       »•      TCE is in soils primarily at the northwest corner of the building (as far as 17 ft below the
              surface), and extends under the PMC building, which was constructed on a concrete slab.
              The highest TCE concentration (830 ppb) was found in a soil boring taken through the
              PMC floor. The  sample was from a depth of 12 to 14 feet.

       »•      The semivolatile organic compounds also appear to be primarily near the northwest  corner
              of the building, primarily in the shallow soils. The highest concentrations, found in a
              surface-soil sample near the northwest comer of the building, contained 23 parts per
              million (ppm) of benzo(a)anthracene, 18 ppm of benzo(a)pyrene, 31 ppm of
              benzo(b)fluoranthene, 50 ppm of fluoranthene, 6.6 ppm of acenapthene, 7.8 ppm of
              carbazole, 7.9 ppm of di benzo(a,h)anthracene, and 46 ppm of phenanthrene.

       »•      Inorganic contamination, primarily zinc, is most prevalent in the surface and top several
              feet of the soil. The maximum concentration of zinc was 19,700 ppm at the northeast
              corner of the building.

6.1.1          Soils - Exceedances of State Chemical-Specific ARARs

              As part of the Feasibility Study process, analytical data obtained from the RI were
              compared to generic soil clean-up criteria established by the  State of Michigan under Part
              201, "Environmental Remediation," of the  Michigan Natural Resources and
              Environmental Protection Act (NREPA), 1994 PA 451, as amended, and associated
              administrative rules. Although a comparison of site data to chemical-specific applicable
              or relevant and appropriate requirements (ARARs) had been performed in the  RI report,
              it was important to reevaluate the data with more specificity  before areas possibly
              requiring remedial action could be identified.  In the RI report, soil chemical-specific
              ARARs were combined (to simplify the evaluation of contaminant concentrations.) and
              exceedances of the most stringent ARAR led to the data point being identified as an area
              of chemical-specific ARAR exceedance. However, during preparation of the FS, the U.S.
              EPA and the MDEQ agreed that several of the Part 201 soil and groundwater criteria
              would not be appropriate for the Petoskey Site because there is an existing institutional
              control in place  to prohibit construction of private wells and  groundwater use (City  of
              Petoskey Ordinance No. 651 -  See Appendix D) and because of the proposed remedy's
              inclusion of deed restrictions which will reliably prevent exposure to contaminated
              groundwater. There is a municipal water supply available and the City of Petoskey
              ordinance requires that, "where City water service is available, no other methods of
              obtaining water service shall be utilized unless specifically permitted by the City or by the
              Michigan Department of Environmental Quality or any of its subsidiaries."  Although
              Part 201 is an ARAR for this site, the following chemical-specific criteria would not be
              appropriate for this site (i.e., used as chemical-specific cleanup standards) because the
              presence of an existing institutional control and the proposed deed restrictions render the
              Generic  Residential Drinking Water Criteria inappropriate.  Taken one step further, the
              Part 201 criteria developed from  the Generic Residential Drinking Water Criteria would
              also be inappropriate.

              Based on U.S. EPA and MDEQ discussions, the following Part 201 criteria were
              determined not to be appropriate for soil contamination at the Petoskey Municipal Well
              Field Site:

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                                 8

•      Generic Soil Criteria Protective of Residential Drinking Water; and
•      Generic Soil Criteria Protective of Industrial Drinking Water.

As a result, the following chemical-specific Part 201 cleanup criteria were used in the FS
to evaluate the extent .of soil contamination at the PMC property. These criteria represent
the appropriate Part 201 criteria for soils at the Petoskey Site:

•      Statewide Default Soil Background Levels;
•      Site-Specific Soil Background Levels;
•      Generic Soil Criteria Protective for Groundwater Contact
•      Generic Soil Criteria Protective of the Groundwater Surface Water Interface
       (GSI);
•      Generic Residential Direct Contact Criteria;
•      Generic Industrial Soil Direct Contact Criteria;
•      Generic Residential Infinite Volatile  Soil Inhalation Criteria (VSIC) for Ambient
       Air;
•      Generic Residential Finite Volatile Soil Inhalation Criteria (VSIC) for Ambient
       Air; and
•      Soil Saturation Concentration Screening Levels.

Based on the appropriate Part 201 criteria listed above and an evaluation of the RI data,
the U.S. EPA could identify no exceedances of relevant industrial soil criteria at the
PMC property. However, if the property were to be developed for residential use, there .
would be exceedances of relevant Part 201 generic residential criteria.  Specifically, two
locations on the property were found to have exceedances of the Generic Residential
Direct Contact Criteria (see Figure 3 of this ROD).  A surface soil sample (near the
northwest corner of the PMC building (near the location of the historical hydraulic fluid
spill) was found to have levels of SVOCs that exceed Part 201 Direct Contact Criteria.
This sample, SS-6, contained 23 parts per million (ppm) of benzo(a)anthracene, 18 ppm
of benzo(a)pyrene, 31 ppm of benzo(b)flouranthene, 50 ppm of fluoranthene, 6.6 ppm of
acenapthene, 7.8 ppm of carbazole, 7.9 ppm of di benzo(a,h)anthracene, and 46 ppm of
phenanthrene. In addition, another surface soil sample (SS-1) near the northwest corner
of the PMC building (where the hydraulic fluid seep occurred) was identified as having
contamination in excess of Generic Residential Direct Contact Criteria. The RI found
that  SS-1 had  12 ppm of arsenic. The volume of soil thought to be contaminated in
excess of Generic Residential Direct Contact Criteria was estimated during the FS to be
 15 cubic yards. Soil contamination was not found to be sufficiently high to pose a
problem based on volatilization and inhalation of organic contaminants.

In addition to the concern about direct contact and inhalation, contamination in the PMC
site soils continues to leach and acts as a source for the groundwater contaminant plume.
The  leaching from site soils is a problem independent of land use.  Of most concern is
the continued  leaching of TCE, the primary contaminant of concern for groundwater.
Although the Michigan Part 201 Generic Residential Soil Criteria Protective of Drinking
Water are not  ARARs for the Petoskey Municipal Well Field Site (see the discussion in
Section 6.1.1 on page 7), the Generic Soil Criteria Protective of the Groundwater Surface
Water Interface (GSI) are ARARs. These criteria identify soil contaminant

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concentrations which are not expected to leach and contaminate groundwater at levels
greater than the corresponding GSI criteria. The Generic Soil Criteria Protective of the
GSI do not necessarily require that soils exceeding these limits be addressed. Part 201
allows multiple methods for evaluating compliance:

•      The applicable generic soil criterion is the higher of the "20 times GSI Criterion"
       and the "GSI Soil-Water Partitioning Criterion." If site-specific GSI
       groundwater criteria are calculated, the soil values may be adjusted accordingly.

•      Leachate testing may be done to determine the site-specific leachate
       concentrations which may be compared to the GSI criteria.  If the site-specific
       soil leachate concentration is less than the GSI criterion, then the corresponding
       soil concentration may be used as the applicable soil criterion protective of GSI.

•      Site-specific and appropriately collected groundwater data may, in some cases,
       serve as an in-situ demonstration that the soil contaminants will not have an
       unacceptable impact on the venting groundwater.

•      Site-specific values for any of the following parameters may be substituted for
       the generic assumptions in the soil-water partitioning criteria and still allow for
       generic closures: soil dry bulk density, soil organic carbon content, and the
       chemical-specific temperature adjustment factor for the Henry's Law constant.

For purposes of the FS and the development of remedial alternatives, levels of soil
contamination were compared with draft Generic Soil Criteria Protective of the GSI. •
However, upon issuance of the ROD, U.S. EPA will obtain the final Generic Soil
Criteria Protective of the GSI used as a drinking water source (See Appendix E for
current partial list) and will work with MDEQ to develop site-specific GSI criteria.
Although the criteria to  be developed will be for groundwater, the revised groundwater
GSI values may be used to calculate site-specific soil criteria protective of the GSI. To
develop site-specific soil criteria for the protection of the GSI, the site-specific GSI
values for groundwater will be multiplied by twenty (20) to allow for dilution and
attenuation. Upon determination of the site-specific GSI criteria, the selected GSI
criteria will be placed in the site file and applied as ARARs for the site cleanup.

Also to be considered in the development of soil criteria protective of the GSI and the
evaluation of the extent of soil contamination, Part 201  allows the use of background
concentrations (either determined by the State of Michigan or site-specific) for selected
inorganic compounds if background concentrations are higher than general cleanup
criteria.  For many inorganics, including zinc, the determination of background
concentrations was not fully resolved in the RI report. The FS report revised
assumptions for the development of inorganic background concentrations in accordance
with MDEQ's "Guidance Document for Verification of Soil Remediation" (MDEQ
1994). However, additional discussion of appropriate background concentrations may
be necessary as site activities progress in order to more fully delineate areas where soil
contaminant concentrations exceed soil criteria protective of the GSI. This issue may
prove irrelevant if the development of site-specific groundwater criteria results in revised

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                                              10

               site-specific soil criteria that are not below State of Michigan or site-specific inorganic
               background concentrations.

6.1.2           Soils - Exceedances of Federal Chemical-Specific ARARs

               The U.S. EPA does not have generic soil cleanup numbers that can be applied to the
               PMC facility to determine what levels of soil contamination are or are not acceptable
               from a human health standpoint. Instead, the site-specific risk assessment is used to
               determine pathways with unacceptable risk and identify contaminants that require
               remediation. However, from the groundwater data it is clear that there is an exceedance
               of a chemical-specific ARAR at the site. Concentrations of TCE in the groundwater
               exceed the MCL of 5 ppb. Using the "20 times" rule of thumb and evaluating soil TCE
               concentrations, it is clear that TCE is present in site soils at levels leading to MCL
               exceedances in groundwater. An approximate  maximum soil concentration of TCE (in
               terms of a rough estimate of leaching potential) would therefore be 100 ppb; the
               maximum concentration seen in PMC soils was 830 ppb. Most of the TCE seen in site
               soils is in the northwest comer of the PMC building (both near the corner of the building
               and under the corner of the building).

6.2     Extent of Groundwater Contamination

        Groundwater samples were collected from the site in 1992 and 1995 as part of the RI.  As part of
        the investigation, groundwater samples were collected  from 31 monitoring wells.  Although
        groundwater samples were collected in 1992 and 1995, only the Phase II groundwater analytical
        data were evaluated in the RI report because they were representative of more current site
        conditions (see Figure 4 of this ROD).  Data from an additional groundwater monitoring round
        (March 1998) was collected after the finalization of the RI report. Although it is too late to
        include the data  in the RI report, the data has been included in the Administrative Record and
        carefully reviewed and considered prior to preparation  of this ROD.

        Based on data from all rounds of groundwater monitoring, TCE was the most commonly
        detected VOC and was present in a northwesterly trending plume from the PMC building toward
        the Ingalls municipal well. This plume probably resulted from past pumping that drew
        contaminants toward the Ingalls well.  Another VOC, vinyl chloride (a degradation product of
        TCE), has also been seen in monitoring wells near the building where soil TCE concentrations
        are highest.  Due to the relatively high toxicity of vinyl chloride, the presence of vinyl  chloride
        has a great impact on the development of risk assessments associated with the consumption of
        contaminated site groundwater. The only regularly detected SVOC was bis (2-ethylhexyl)
        phthalate.  This  compound is a common laboratory contaminant and was detected at various
        groundwater sampling locations away from the PMC building.  However, bis(2-ethylhexyl)
        phthalate was also found in some site soils at-depth, making it difficult to determine at  this point
        whether it is or is not site-related.

        The pesticide 4,4'-DDT was detected in a few samples from wells located northwest a few
        hundred feet of the PMC building in an area where non-site-related storage activities prior to
        1982 have been  reported.  No pesticides were detected in wells located next to the PMC building,
        which indicates  that PMC is probably not a source of pesticide contamination in groundwater.

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                                               11

       For inorganics, there does not yet seem to be a clear pattern of inorganic groundwater
       contamination. Levels of zinc in groundwater appear to be elevated in wells downgradient of the
       PMC property, likely due to leaching of zinc from site soils. The presence of iron may be
       attributable to site activities or natural conditions. Manganese contamination cannot
       conclusively be attributed to PMC. Thallium was present in several laboratory blanks at similar
       concentrations, suggesting that thallium is a laboratory contaminant. The sporadic detections
       and possibly elevated concentrations of other potentially site-related inorganic compounds are
       difficult to evaluate because site-specific background concentrations for groundwater were not
       determined during the RI because only three sampling events were performed at background
       wells and statistically valid background values could therefore not be developed.

6.2.1           Groundwater - Exceedances of State Chemical-Specific ARARs

               In the preparation of the Rl report, groundwater analytical data were compared to
               cleanup criteria established by the State of Michigan under Part 201, "Environmental
               Remediation," of the Natural Resources and Environmental Protection Act, 1994 PA
               451, as amended and associated administrative rules. Criteria used for comparison
               included the following:

               •      Generic Residential and Commercial I Drinking Water Criteria;
               •      Generic Groundwater Surface Water Interface (GSI) Criteria;
                      Generic Industrial /Commercial II, III, IV Drinking Water Cleanup Criteria;
               •      Generic Groundwater Contact Criteria;
               •      Residential Groundwater Volatilization to Indoor Air Inhalation Criteria;
                      Flammability and Exposivity Screening Levels; and
               •      Groundwater Acute Inhalation Screening Levels.

               However, as described in the soil discussion above (Section 6.1.1), it was necessary to
               reevaluate relevant State chemical-specific ARARs as part of the Feasibility Study in
               order to properly identify exceedances. Because there are municipal controls in place to
               prohibit the use of private wells in the area of groundwater contamination, there is a safe
               municipal water supply is available and in use, the current industrial use of the site and
               the remedy's deed  restrictions prevent consumption of contaminated groundwater, the
               Part 201 Generic Residential Drinking Water Criteria were determined not to be
               appropriate criteria for the site. Therefore, as part of the FS, the groundwater was
               reevaluated in terms of the remaining appropriate Part 201 chemical-specific ARAR,
               Generic GSI Criteria,  and the Michigan Safe Drinking Water Act (Michigan Act 399 of
                1976, as amended, and administrative rules) which would be relevant and appropriate for
               future consumptive use of the aquifer.

               TCE and vinyl chloride concentrations in groundwater exceed Michigan's Safe Drinking
               Water Act (Michigan  Act 399 of 1976, as amended, and administrative rules) limits. Act
               399 generally adopts the federal MCLs as acceptable concentrations for public drinking
               water supplies. Michigan's Safe  Drinking Water Act requirements are relevant for
               comparison with site contaminant concentrations because Act 399 requirements are the
               baseline minimum standards for a consumptive water supply, regardless of the existence
               of institutional controls barring the use of private wells.   Because MCLs were

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                                             12

              promulgated for municipal and community water supply systems, not individual wells or
              aquifers, the Safe Drinking Water Act limits are not applicable requirements. However,
              Act 399 is relevant and appropriate for usable aquifers and one of the goals for
              remediation is to return the groundwater to its most beneficial use.

              For purposes of the FS, the development of remedial alternatives and this ROD,
              groundwater contamination was compared with draft Generic GSI Criteria and the Act
              399 Safe Drinking Water Act limits. It is important to note, however, that upon issuance
              of the ROD, U.S. EPA will obtain the final Generic Soil Criteria Protective of the GSI
              used as a drinking water source (See Appendix E for current partial list) and will work
              with MDEQ to develop site-specific GSI criteria. Upon determination of the final site-
              specific GSI criteria, the selected GSI criteria will be placed in the site file and applied
              as ARARs for the site cleanup.

6.2.2          Groundwater - Exceedances of Federal Chemical-Specific ARARs

              The U.S. EPA has established the Maximum Contaminant Levels (MCLs) as its primary
              drinking water standards. MCLs are the maximum level of a specific contaminant,
              based on human health factors, allowed in water delivered to any user of a public water
              system. Michigan's Safe Drinking Water Act (Michigan Act 399 of 1976, as amended,
              and administrative rules) generally adopts the federal MCLs as acceptable concentrations
              for public drinking water supplies  so these two ARARs should be generally equivalent.
              Because contaminated groundwater is not currently being used as part of a drinking
              water supply, MCLs are not applicable requirements. However, MCLs are relevant and
              appropriate for usable aquifers and one of the goals for remediation  is to return the
              groundwater to its most beneficial use.

              TCE concentrations in the groundwater between PMC and Lake Michigan exceed the
              MCLofSppb.  Based on the most recent sampling (March 1998), the highest TCE
              detection seen was 60 ppb (with a duplicate sample result of 61 ppb) at well PS-CD.
              Monitoring well PS-203S, which was not sampled in March 1998, had a TCE detection
              of 82 ppb. In addition, vinyl chloride concentrations detected in groundwater appear to
              be increasing over time.  The most recent round of sampling (March, 1998) identified
              vinyl chloride in groundwater at well MW-201S, at the corner of the PMC facility, at a
              concentration of 27 ppb. Vinyl chloride is a degradation product of TCE and could be
              present elsewhere in portions of the aquifer which have lower flow and allow the solvent
              time to degrade before discharging into the lake. The MCL for vinyl chloride is 2 ppb.
7.0    SUMMARY OF SITE RISKS

As part of the Remedial Investigation, MDEQ conducted a site-specific Baseline Risk Assessment,
which evaluated potentially exposed populations and exposure pathways (ways in which people come
into contact with contaminants).  The Baseline Risk Assessment is presented in Chapter 6 of the Phase II
RI Report. The Baseline Risk Assessment was prepared in accordance with U.S. EPA's guidance,
including: "Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual (Part
A)" (U.S. EPA, 1991; 1989b).

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                                               13

MDEQ looked at the current light industrial land use, and, in addition, assumed that the PMC site
eventually will be developed for residential use. Although PMC remains in operation at the site, the City
of Petoskey has identified the PMC property as "multi-family residential" in its Master Zoning Plan.
The Master Zoning Plan has not yet been implemented for the PMC property.  The potentially exposed
populations and exposure pathways evaluated in the risk assessment include:

•      Current risk scenario -  Adolescent Trespasser
•      Current risk scenario -  PMC Worker;
•      Potential Future Land Use Risk Scenario -       "Generic Residential" -  Adult and child living
                                                    on-site, exposed to site soils and consuming
                                                    contaminated groundwater.
•      Potential Future Land Use Risk Scenario -      "Limited Residential Use" - Adult and child
                                                    living on-site, exposed to site surface soils.
                                                    This pathway was evaluated for a home both
                                                    with and without a basement.
•      Potential Future Land Use Risk Scenario -      Construction Worker - Earth mover / contractor
                                                    exposed to site soils.

7.1     Baseline Risk Assessment - Chemicals of Potential Concern

       The identification of the Chemicals of Potential Concern is based on the frequency, spatial
       distribution, and magnitude of contaminant detection in each medium of concern, and
       comparison of detected concentrations to appropriate health/risk-based federal and state criteria.
       The MDEQ used  three (3) criteria in its selection of chemicals of potential concern for the
       Petoskey Municipal Well Field Site:

       »•       Frequency of detection.  With sample sizes greater than 20, selection is based on
               detection in 5% or more of the samples in a medium. Chemicals  detected infrequently
               (i.e., in less than 5% of the samples) and at  low concentrations (i.e. in concentrations
               below the appropriate MDEQ generic residential cleanup criteria) are not selected as
               chemicals of potential concern. With sample sizes less than 20, selection is based on
               detection in at least one sample in medium.

       ••       For the inorganic chemicals, comparison to background.  For soils, selection is based on
               an arithmetic average concentration greater than two times the arithmetic average
               concentration in the background samples. For groundwater, selection is based on
               detection at a concentration greater than that in the one  background sample.

       *•       For the essential nutrients (i.e. calcium,  iron, magnesium, potassium, and sodium)
               comparison to reference concentrations derived from recommended daily allowances.
               Selection is based on concentrations greater than the appropriate reference
               concentrations.

       Table 1 of this ROD provides a summary of the chemicals of potential concern selected by the
       MDEQ and identifies the matrices in which they were found.

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                                               14

7.2    Baseline Risk Assessment - Exposure Assessment

       The purpose of the Exposure Assessment is to estimate the type and magnitude of potential
       exposure to the Contaminants of Potential Concern present in the PMC soils and the
       contaminated groundwater. Exposure is quantified by calculating exposure doses for each
       exposure scenario.  Exposure doses are calculated based on the exposed populations, exposure
       point concentrations, and exposure pathways using the equations and default values presented in
       U.S. EPA and state guidance.

       Currently, potentially exposed populations include adult PMC workers and adolescent
       trespassers. Both populations are assumed to reside in the vicinity of the PMC site. Adults were
       selected to represent the PMC worker population while adolescents, aged 12 to 15, have been
       selected to represent the trespasser population. Evaluation of adolescent trespassers should
       adequately characterize potential exposure and health risks to adults that might trespass on the
       site.

       Potentially exposed populations in the future may include adult and child residents and
       construction workers.  Adults were selected to represent the adult resident and construction
       worker populations. Children represent sensitive receptors as behavior patterns, body size, and
       exposure rates could lead to greater exposure to the chemicals of potential concern than would be
       experienced by adults; children, ages 0 to 6, were selected to  represent this population in the risk
       assessment. Sensitive receptors can  include any subpopulation that may be at increased risk
       from chemical exposures due to increased sensitivity, behavior patterns and/or current or past  •
       exposures from other sources.

       Shallow soil represents the medium of concern regarding the current potential for human
       exposure as PMC workers and trespassers could come into contact with chemicals of potential
       concern through inadvertent ingestion and dermal contact. As the municipal water supply
       provides potable water, there is little likelihood of human contact with groundwater under
       current conditions.

       Shallow soil, subsurface soil, and groundwater represent media of concern regarding the future
       potential for human exposure. Future residents may come into contact with chemicals of
       potential concern through inadvertent ingestion of and dermal contact with soil, inhalation of
       VOCs released from soil and groundwater and transported to indoor air (i.e., enclosed spaces)
       and ambient air, and potable use of the groundwater.  Future  construction workers may come
       into contact with chemicals of potential concern through dermal contact with  contaminated
       groundwater and in soils through inadvertent ingestion and dermal contact and inhalation of
       respirable particulates released from the soil.

       Direct contact exposure by residents was evaluated based on both shallow soil data ("limited
       residential use") and all soils data ("generic residential use")- Construction worker exposure is
       based on all soils data. It should be noticed that as of December 1997, the City of Petoskey's
       primary drinking water supply is groundwater from the new  Bay Harbor development. Specific
       assumptions concerning the ingestion of, dermal contact with, and inhalation  of site
       contaminants may be found in the RI report.

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                                               15

7.3    Baseline Risk Assessment - Toxicity Assessment

       The toxicity assessment, also termed the dose-response assessment, serves to characterize the
       relationship between the magnitude of exposure and the potential that an adverse effect will
       occur. It involves determining whether exposure to a chemical can cause an increase in the
       incidence of a particular adverse health effect, and characterizing the nature and strength of
       causation.  The toxicity information is then quantitatively evaluated and the relationship between
       the dose of the contaminant received and the incidence of adverse effects in the exposed
       population  is evaluated.

       The U.S. EPA and other regulatory agencies have performed toxicity assessments for numerous
       chemicals and the guidance they provide was used in the MDEQ risk assessment. These include
       verified reference doses, or RFDs, for the evaluation of noncarcinogenic effects from chronic
       exposure and cancer potency slope factors for the evaluation of cancer risk from  lifetime
       exposure. Sources of information used for the development of the MDEQ risk assessment
       included:

       *•       IRIS (Integrated Risk Information System), which is a U.S. EPA database containing
               current health risk and regulatory information for many chemicals;

       >       U.S. EPA Health Effects Assessment Summary Tables (HEAST), which are .tabular
               presentations of provisional toxicity data; and

       »•       U.S. EPA National Center for Environmental Assessment's (NCEA) Superfund
               Technical Support Center (formerly the Environmental Criteria and Assessment Office,
               ECAO).

7.3.1           Noncarcinogenic Effects

               Noncarcinogens are those compounds that cause an effect (e.g., liver damage) other than
               carcinogenicity. Noncarcinogenic compounds differ from carcinogens in that they are
               believed to have threshold dosage levels below which adverse health effects are not
               expected. U.S. EPA's preferred criterion for quantifying noncarcinogenic risk is the
               reference dose (RfD), which corresponds to U.S. EPA's identification of the threshold
               effects level with an added margin of safety.  The IRIS database maintains a current
               listing of all of the verified RfDs, which are reported in units of mg/kg-day. By
               definition, the RfD is an estimate of an average daily exposure level below which
               significant, adverse noncarcinogenic health effects are not expected. RfDs often have an
               uncertainty spanning perhaps an order of magnitude or greater.

               The hazard quotient for a contaminant is defined as the ratio of the estimate of chronic
               daily intake to the health-protective criterion for that contaminant. The hazard quotient
               assumes that there is a level of exposure (i.e., the RfD) below which it is unlikely for
               even sensitive subpopulations to experience adverse health effects. If the hazard
               quotient exceeds 1.0, there may be a concern for potential non-cancer effects. The
               greater the hazard quotient above 1.0, the greater the level of concern.

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                                               16

 7.3.2          Carcinogenic Effects

               The U.S. EPA has derived estimates of incremental excess cancer risk from lifetime
               exposure to potential carcinogens. This is accomplished by establishing the carcinogenic
               potency of the chemical substance through critical evaluation of the various test data and
               fitting dose-response data to a low-dose extrapolation model. Carcinogenicity is
               quantified by the cancer slope factor. The slope factor (which describes the dose-
               response relationship at low doses) is expressed as a function of intake.  The slope
               factors for the carcinogenic chemicals of concern are used to estimate finite, upper limits
               of risk as low dose levels administered over a lifetime.  For children, the estimated
               cancer risk reflects the potential risk over a lifetime due to childhood exposure.  Cancer
               slope factors are determined by U.S. EPA and published in IRIS and HEAST.

7.4     Baseline Risk Assessment - Risk Characterization

        The Risk Characterization integrates the quantitative exposure and toxicity values for each current
        and future exposure scenario. Table 2 of this ROD  presents a quantitative summary of site risks
        for each risk current and future risk scenario.

        Noncarcinogenic effects are quantified in terms of a Hazard Index (HI), which is calculated by
        dividing the exposure dose by the RfD:

               Hazard Index (HI) = Exposure Dose (mg/kg-day) / RfD (mg/kg-day)

        Noncarcinogenic risks are evaluated by dividing the exposure dose of each compound by its
        respective RfD and summing the resulting hazard index for each compound within each exposure
        scenario. The resulting cumulative noncarcinogenic risk for each exposure scenario was compared
        to the U.S. EPA target HI of 1.  If the HI is less than or equal to 1, the predicted exposure dose
        level could potentially cause adverse effects.

        Carcinogenic effects are evaluated by  multiplying the estimated exposure dose by the cancer slope
        factor (CSF) to obtain an estimate of incremental risk, as follows:

               Carcinogenic Risk = Exposure Dose (mg/kg-day) x CSF (mg/kg-day)"1

        The cancer risks of each compound are summed within each exposure scenario. U.S. EPA's
        guidelines state that the total incremental carcinogenic risk for an individual resulting from
        exposure at a hazardous waste site should not exceed a target risk range of 1x10"6 to  1x1 (TV In the
        Petoskey risk assessment, the estimated carcinogenic risk for each exposure scenario was
        compared to the target risk range.  Further actions are recommended for estimated risks exceeding
        the upper end of the target risk range (IxlO"4).

 7.4.1           Results - Current Land Use  Scenarios

               Based on assumptions in the risk assessment, none of the exposure pathways or routes
               under current industrial land-use  conditions results in carcinogenic (cancer-causing) or
               noncarcinogenic risks exceeding  EPA's acceptable levels. This means that the
               contaminant levels in soils are acceptable for the current operation of the PMC facility.

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                                               17

               The risk assessment found that:

               Adolescent Trespasser:

               For an adolescent exposed to contaminated on-site soils (i.e., trespassing), the total hazard
               index for adolescent trespasser exposure to chemicals of potential concern in subsurface
               soil from ingestion and dermal contact is 8xlO"2. This hazard index is less than the U.S.
               EPA acceptable level of 1.0, indicating that adverse noncarcinogenic health effects from
               such exposure are unlikely. The total estimated cancer risk is approximately 6xlO'7.  This
               risk is less than the U.S. EPA acceptable range of IxlO'6 to IxlO"4.

               PMC Worker:

               For a worker at the PMC facility, the total hazard index from industrial exposure to the
               chemicals of potential concern in surface soil from ingestion and dermal contact is 7xlO'2.
               This hazard index is less than the U.S. EPA acceptable level of 1.0, indicating that
               adverse, noncarcinogenic health effects from such exposure are unlikely. The total
               estimated cancer risk is approximately 5 x  10"6. This risk is within the U.S. EPA
               acceptable range of IxlO"6 to IxlO"4.

7.4.2           Results - Future Land Use Scenarios

               The MDEQ risk assessment also looked at possible future exposure scenarios.  If the PMC
               property were to be developed for residential use and a home were built  on site, there is a
               possibility that a resident could  come into contact with both surface and  subsurface soils
               via ingestion and dermal contact.  It is also possible that the City's current prohibition
               against the use of private wells could be eliminated or not enforced, thus allowing an
               individual to construct a private well and consume contaminated groundwater. The
               MDEQ's risk assessment looked at three variations of the future residential use scenario:
               "Generic Residential," "Limited Residential Use - Basement Construction," and "Limited
               Residential Use - Slab Construction."  Iri addition, the risk assessment evaluated
               exposures to construction workers who would be involved in the construction of a home at
               what is now the PMC property.

               "Generic Residential Use":

               If the PMC property were developed for residential use, an adult could be exposed to
               contaminated on-site surface and subsurface soils (ingestion and dermal contact) and to
               contaminated groundwater (ingestion, dermal contact and volatilized chemicals).  It is
               assumed that the construction process disturbs the soils at the site and that both surface
               and subsurface soils are made available for contact.  Because the surface soils generally
               have higher concentrations of contaminants (except for TCE) than the subsurface soils,
               this in fact is less conservative than assuming contact with surface soils. Under this
               scenario, the total hazard index  for exposure to the chemicals of potential concern is 1.0,
               equal to the U.S. EPA acceptable level of 1.0. The total estimated cancer risk is about
               SxlO"4.  This risk is greater than the U.S. EPA acceptable range of IxlO"6 to IxlO"4.
               Ingestion of vinyl chloride in groundwater is the primary contributor to the estimated
               cancer risk.

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                                18

For a child living on the property under this same scenario, exposed to contaminated on-
site surface and subsurface soils and to contaminated groundwater, the total hazard index
is 3. This hazard index is greater than the U.S. EPA acceptable level of 1.0, indicating a
potential for adverse, noncarcinogenic health effects. The hazard index for ingestion of
groundwater is 2; however, none of the hazard quotients for individual chemicals exceed
1.0.  The total  estimated cancer risk is approximately IxlO"4. This risk is within the U.S.
EPA acceptable range of 1 x 10"* to 1 x 10"4.

"Limited Residential Use" - Basement Construction:

This scenario assumes that the property would be developed for residential use, and that a
house with a basement would be constructed on site. Residents would receive water from
the new municipal supply and would not consume water from the contaminated
groundwater plume.

The total hazard index for resident adult exposure to the chemicals of potential concern  in
surface soil from ingestion and dermal contact and in indoor air from inhalation of
chemicals volatilized from subsurface soil and groundwater is 4x10''. This hazard index
is less than the U.S. EPA acceptable level of 1.0, indicating the noncarcinogenic health
effects from such exposure are unlikely.  The total estimated cancer risk is approximately
7xlO-s. This risk is within the U.S. EPA acceptable risk range of IxlO"6 to IxlO"4.

The total hazard index for resident child exposure to the chemicals of concern in surface
soil from ingestion and dermal contact and in indoor air from inhalation of chemicals
volatilized from subsurface soil  and groundwater is 2. This hazard index  is greater than
the U.S. EPA acceptable level of 1, indicating a potential for adverse, noncarcinogenic
health effects. None of the hazard indices for the individual exposure routes exceeds I,
although the hazard index for ingestion of surface soil is 1.  The total estimated cancer risk
is approximately 4xlO"5. This risk is within the  U.S. EPA acceptable range of IxlO"6 to
IxlO"4.

Construction Worker:

The total hazard index for construction worker exposure to the chemicals of potential
concern in surface and subsurface soils from ingestion, dermal contact and inhalation is
IxlO*1.  This hazard index is less than the U.S. EPA acceptable level of 1.0, indicating the
adverse noncarcinogenic health  effects from such exposure are unlikely. The total
estimated cancer risk is approximately 6xlO~7. This risk is less than the U.S. EPA
acceptable range of 1 x 10"* to 1 x 10"*.

Summary of Potential Future Risks:

In summary, based on the risk assessment's evaluation of possible future  use scenarios,
there is a potential for noncarcinogenic risk above U.S. EPA's general threshold of a
hazard index of 1.0.  Under all limited residential land use scenarios (both with a
basement and  with slab construction),  a child could be exposed unacceptable levels
contamination in site shallow soils. A child's incidental ingestion of shallow soils results
in a hazard index of 1.0.  Dermal contact results in a hazard index of 0.4.  For combined

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              contact with shallow soils (incidental ingestion and dermal contact), the hazard index of
              1.4 exceeds U.S. EPA's threshold of 1.0. MDEQ's risk assessment rounded this to a
              hazard index of 2.0.

              Groundwater consumption also increases the chance of noncarcinogenic risk.
              Consumption of contaminated site groundwater results in a hazard index of 2.0, based
              primarily on the ingestion of manganese, arsenic and TCE in groundwater. The arsenic
              and manganese.contribute the majority of the noncarcinogenic risk (0.5 each) and could be
              at background levels. Insufficient groundwater monitoring data is available to determine
              whether PMC is contributing to the arsenic and manganese levels or if these inorganics are
              present in groundwater at background levels. The hazard index solely from ingestion of
              the TCE in groundwater is 0.3. The presence of TCE in groundwater is clearly site-
              related.

              Future residential use of the property, if it is not remediated, could result in an increase in
              carcinogenic risks to the residents at the site. However, for all of the residential land use
              scenarios, the carcinogenic risk from exposure to site soils is within U.S. EPA's allowable
              risk range. Carcinogenic risk increases dramatically if contaminated site groundwater
              would be used by future residents of the property.

7.5    Uncertainties

       The Baseline Risk Assessment utilized the best available  site data.  Since the preparation of the
       Risk Assessment, additional groundwater sampling has been performed. Results from the most
       recent sampling event found vinyl chloride levels have risen at monitoring well MW-201S near
       the northwest corner of the PMC building.  If the contaminated site groundwater were consumed
       for long-term residential use, this higher  level of vinyl chloride seen at the site (27 ppb) would
       result in  risks in excess of those calculated in the Risk Assessment.

       The Baseline Risk Assessment could not quantify risks from those contaminants without known
       slope factors or reference factors. The slope factors calculated by the U.S. EPA for potential
       carcinogens have inherent uncertainty because they are calculations of lifetime cancer risks
       based on less-than-lifetime exposures and incorporate high-dose to low-dose extrapolations. In
       addition, methods to quantify risks and possible synergistic effects due to exposure to multiple
       contaminants or multiple pathways are very limited.  The use of risk additivity helps prevent the
       underestimation of cancer risks or potential  noncancer health effects.

7.6    Environmental Risks

       No ecological risk assessment was performed for the Petoskey Municipal Well Field Superfund
       Site.  The PMC facility is an operating industrial facility.  Soil contamination is minimal and is
       limited to the PMC property. The plume of contaminated groundwater discharges to Lake
       Michigan, but at levels not believed to pose any risk  to ecological habitats.  Michigan's
       Groundwater Surface Water Interface (GSI) criteria will be used, in part, as a tool to screen
       whether  the groundwater discharge could be impacting the lake.

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8.0     DESCRIPTION OF ALTERNATIVES

The Feasibility Study evaluated alternatives to address risks of possible residential exposure to site soils
and possible consumption of contaminated groundwater. In addition, soil alternatives were evaluated for
their ability to reduce current and future leaching of contaminants to groundwater. Reducing soil leaching
would slow the movement of contaminants into groundwater and reduce the groundwater concentrations.
In addition, this leaching reduction  would minimize the discharge of contaminants to Lake Michigan.

8.1     Soil Alternative 1:  No Action

               Time To Complete:            No action, thus requires no time to complete.
               Capital Cost:                  $         0
               Yearly O&M:                 $         0
               30-Year Present Worth Cost    $         0

        This alternative serves both as a possible course of action at the site and provides a reference
        against which other soil "action" alternatives are evaluated. Under this alternative, no action
        would be taken to remediate contaminated soil at the PMC site.  Only natural attenuation and
        degradation processes would affect changes in concentrations of contaminants in soil. This
        alternative is included in the alternatives in accordance with the NCP.

        No capital or O&M costs are associated with this alternative.  Capital and operating costs for  •
        Alternative 1 would be zero because no remedial action, institutional controls, or monitoring
        would  be  implemented.  Therefore, there is no net present value cost associated with
        implementation of Alternative 1.

' 8.2    Soil Alternative 2: Engineered Cap with Deed Restrictions

               Time To Complete:           Approximately 4 to 6 weeks.
               Capital Cost:                 $      43,900
               Yearly O&M:                 $        700
               30-Year Present Worth Cost    $      52,600

        This alternative involves placing an asphalt cap over the contaminated soil area near the PMC
        building.  The expected area of capping is  shown in Figure 5. The asphalt cap would consist of 4
        to 6 inches of gravel overlain by 2 to 4  inches of asphalt.  The asphalt would be seal-coated and
        pitched to promote drainage. Site preparation activities associated with this alternative may
        include grass, tree,  and shrub removal.  During implementation, surveying would be necessary to
        ensure that proper thicknesses and slopes are obtained.  Deed restrictions would be necessary
        after construction to ensure the integrity of the cap by prohibiting intrusive activities within the
        capped areas. O&M would  include periodic cap inspection and repair.

        This alternative has low capital and O&M costs. Approximately 4 to 6 weeks would be required
        to mobilize necessary equipment, grade, excavate, and transport material to an approved landfill;
        install  a cap; restore the site: and demobilize.

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8.3    Soil Alternative 3: Soil Vapor Extraction (SVE) with Excavation and Off-Site Disposal of
       Contaminated Soil

               Time To Complete:            4 to 6 weeks for SVE, followed by 3 to 5 weeks
               Capital Cost:                  $    145,200
               Yearly O&M:                 $          0
               30-Year Present Worth Cost    $          0

       Under this alternative, the existing Soil Vapor Extraction (SVE) wells (MW-201S, MW-203S,
       and MW-204S) from an earlier SVE pilot study (conducted during the Remedial Investigation)
       would be used to remove TCE in soil at depths greater than 5 feet below ground surface (bgs)
       near the northwest corner of the PMC building. A liner would be installed at the ground surface
       before SVE begins to prevent short-circuiting of ambient air into the SVE system.

       Upon completion of SVE, contaminated soil requiring remediation would be excavated and the
       area would be backfilled with clean soil. The area of SVE remediation and planned excavation
       is shown in Figure 6 of this ROD. Because there is no unacceptable risk under the current
       industrial land use and Part 201 chemical-speciftc ARARs are not exceeded for the current
       industrial land use, no soil is required to be excavated under the current industrial land-use
       scenario to protect human health and the environment from potential risks from dermal contact
       and ingestion of soil. Approximately 15 yd3 would require excavation to meet future .residential
       direct contact and ingestion criteria. To remove the potential source of groundwater
       contamination and meet MDEQ soil criteria for protection of groundwater "and surface water
       quality, soil would be excavated to a depth of about 5  feet below  ground surface (bgs), resulting
       in an excavated soil volume of 2,050 yd3.  The excavated soil would be transported off site for
       disposal at an appropriate facility. Based  on data presented in the Rl report, most of the
       excavated soil is expected to be disposed of at a sanitary landfill.  Waste characterization
       samples would be collected to verify the appropriate disposal facility to be selected.

       Site preparation activities associated with this alternative would include grass, tree, and shrub
       removal.  Site preparation would also include identifying and protecting monitoring wells
       located  in the area of excavation.  Temporary fencing would be constructed  before excavation
       begins to secure the work area and limit access in and out of the work zone.  During
       implementation, surveying would be necessary to ensure that backfill is placed to proper
       elevations. Air monitoring and dust suppression would also be necessary during
       implementation. After remedial activities are completed, the temporary fence would be taken
       down, grass areas seeded, and gravel placed in the parking areas north of the PMC building.

       Based on the data gathered during the RI,  this alternative would remove all soils that exceed
       Michigan's Generic Residential Direct Contact Criteria. Therefore, deed restrictions to limit
       land use and/or restrict development would not be required.  However, the landowner remains
       responsible to exercise "due care" in accordance with  provisions  of Michigan Part 201. This is
       especially a concern if the PMC facility is partially or totally demolished. Because of the
       presence of the PMC building, it was not possible for  investigators to completely characterize the
       soils below the foundation of the PMC facility. Therefore, if those soils are uncovered, the
       property owner would have a responsibility to determine if there  is a threat to human health and
       the environment and/or exceedances of Michigan's chemical-specific ARARs. The property

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       owner would be responsible for conducting any follow-up action (i.e., additional excavation and
       disposal) necessary for the development planned for the property. In order to address these
       requirements and concerns, this alternative will require that a deed restriction be placed on the
       PMC property. This deed restriction would identify the landowner's responsibility to exercise
       due care in accordance with Part 201 requirements and, in the event that the soils underneath
       PMC become uncovered, determine if there is a threat to human health and the environment
       and/or exceedances of Michigan's chemical-specific ARARs, to not exacerbate an existing
       condition, and to conduct any follow-up action (i.e., additional excavation and disposal)
       necessary for the development planned for the property.

       This alternative has-a moderate capital cost, but required no O&M.  SVE would have to be
       conducted before excavation could begin.  About 4 to 6 weeks would be required for SVE to be
       conducted. Approximately 3 to 5 weeks would be required to mobilize heavy equipment,
       excavate contaminated soil at the site, transport the soil to an approved landfill, restore the site
       and demobilize. The length of time required to excavate and remove contaminated soil may be
       affected by (1) the time required to analyze samples of contaminated soil to determine the extent
       of excavation, (2) the volume of contaminated  soil accepted at the landfill each day, and (3)
       unanticipated obstructions during excavation.

8.4    Groundwater Alternative 1:  No Action

               Time To Complete:            No action, thus requires no time to complete.
               Capital Cost:                  $        0
               Yearly O&M:                 $  .      0
               30-Year Present Worth Cost    $        0

       This alternative serves both as a possible course of action at the site and provides a reference
       against which other groundwater "action" alternatives are evaluated. Under this alternative, no
       action would be taken to remediate groundwater at the PMC site.  Only natural dilution and
       attenuation processes would affect changes in contaminant concentrations in groundwater. This
       alternative is included in the evaluation in accordance with the NCP.

       No capital or O&M costs are associated with this alternative. Capital and operating costs for
       Alternative 1 would be zero because no remedial action, institutional controls, or monitoring
       would be implemented.  Therefore, there is no net present value cost associated with
       implementation of Alternative 1.

8.5    Groundwater Alternative 2:  Monitored Natural Attenuation  of Groundwater
       Contamination

               Time To Complete:
               Capital Cost:                  $   40,600
               Yearly O&M:                 $    49,500 for years 1 to 3
                                            $     8,800 for years 4 to 30
               30-Year Present Worth Cost    $   250,700

       This alternative would allow groundwater contamination to naturally attenuate (disperse, dilute,

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       and degrade). A monitoring program would be implemented to track the decrease of
       contaminant concentrations. This alternative would also include supplemental deed restrictions
       to prevent installation of residential wells (on the PMC property and any other property where
       groundwater exceeds or approaches drinking water standards due to site-related contamination).

       As shown in Figure 7, approximately 11 additional monitoring wells would be installed to
       supplement the existing monitoring network. Additional wells would include one well paired
       with existing well PS-11 and five new monitoring well clusters. These locations are tentative
       due to a shift in plume direction or other activities that may impact the actual locations of the
       monitoring wells. Final locations would be determined by U.S. EPA, in consultation with the
       MDEQ. Groundwater would be monitored on a regular basis to establish baseline concentrations
       and to evaluate changes in contaminant concentrations over time.  The results of groundwater
       monitoring would also be used to determine compliance with GSI criteria.  This information
       would be used to either confirm that concentrations are decreasing over time by natural
       processes or, if levels fail to drop sufficiently rapidly, determine what additional remedial
       actions, if any, would be required. The monitored natural attenuation approach would include
       the development of a Contingency Plan to outline when and how follow-up actions would be
       implemented.

       This alternative has low capital and moderate O&M costs. Approximately 2 to 3 weeks would
       be necessary to mobilize equipment and install the additional monitoring wells. Another 1 to 2
       weeks would be needed to develop the new wells and perform  site restoration activities. It is not
       currently known how long it will take for natural attenuation to allow contaminant
       concentrations in the groundwater to meet cleanup standards.  For purposes of cost estimation,
       groundwater monitoring is assumed to continue for a period of 30 years. However, monitoring
       activities would cease once  it  is confirmed that cleanup standards have been met throughout the
       aquifer.

8.6    Groundwater Alternative 3:  Pump and Treat / Groundwater Monitoring

               Time To Complete:            6 months for construction, installation and  testing
               Capital Cost:                  $    253,400
               Yearly O&M:                 $     82,500 for years 1 to 3
                                            $     41,900 for years 4 to 30
               30-Year Present Worth Cost    $    874,500

       Under this alternative, groundwater would be removed from the aquifer by extraction wells,
       pumped through a treatment system, and discharged to either surface water or a publicly owned
       treatment works (POTW). Because data are limited regarding nature and extent of
       contamination and hydrogeologic characteristics, this alternative  is conceptual in nature and
       based on numerous assumptions. Predesign data would need to be collected to adequately
       identify the full extent of groundwater contamination and extraction well pumping rates. The
       assumptions used to develop this alternative are discussed below.

       It is assumed that three 6-inch-diameter extraction wells located as shown in Figure 8 would be
       adequate to extract contaminated groundwater.  It is also assumed that each extraction well
       would be screened from the water table (about 18 feet below ground surface (bgs)) to a depth of

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                                              24

        about 50 feet bgs.  Each extraction well would be fitted with a submersible pump capable of
        pumping at a rate of 75 gpm.  Extracted groundwater would be conveyed to the treatment
        building using buried PVC pipe. In addition, a total of 11 additional monitoring wells would be
        installed to supplement the existing monitoring well network.

        It is also assumed that groundwater would be adequately treated by air stripping. As a
        contingency, additional treatment using granular activated carbon (GAC) or ion exchange may
        be used as well.

        Treated water would either be collected in an effluent tank or passed directly to its final
        discharge location. Treated groundwater would ultimately be discharged to either a surface
        water body (Bear Creek or Lake Michigan) or to a POTW. Effluent sampling would be
        conducted on a periodic basis to ensure that appropriate discharge criteria are met.  If necessary,
        vapor phase carbon or an equivalent technology would be used to treat the air stripper off gas.

        The alternative has moderate capital and O&M costs.  Construction of extraction wells,
        additional monitoring wells, and associated piping is expected to last approximately 1 month.
        Installation and testing of the  groundwater treatment system and associated discharge piping is
        expected to last approximately 2 months.  Pump testing and system shakedown is anticipated to
        last an additional 3 months. For cost estimating purposes, ongoing pumping and treatment
        activities, including groundwater monitoring and O&M activities, are expected to last for 30
        years.  In actuality, extraction, treatment and monitoring activities would cease once it is
        confirmed that  cleanup standards have been met throughout the aquifer.
9.0     COMPARATIVE ANALYSIS OF ALTERNATIVES: THE NINE CRITERIA

The relative performance of each remedial alternative was evaluated in the FS Report using the nine
criteria set forth in the NCP at 40 CFR Section 300.430.  These following nine criteria were used to
select the most appropriate alternatives for addressing soil and groundwater contamination at the
Petoskey Municipal Well Field Site in a manner that is protective of human health and the environment,
attains applicable or relevant and appropriate requirements (ARARs), is cost-effective and represents the
best balance among the evaluating criteria.  An alternative providing the "best balance" of tradeoffs with
respect to the nine criteria is determined from this evaluation.

9.1     Overall Protection of Human Health and the Environment

        This evaluation criterion provides confirmation of the effectiveness of a remedial alternative in
        protection of human health and the environment. Evaluation of overall protectiveness of a
        remedial alternative focuses on whether the alternative achieves adequate protection and how
        risks posed by the site are minimized via remedial or institutional actions. This evaluation also
        allows for consideration of unacceptable short-term or cross-media impacts.

9.1.1           Soil Alternatives

               Soil Alternative 1 (No Action) would not be protective of human health.  While the No
               Action approach would provide overall protection of human health under the current

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               land use (industrial), possible risks posed by direct contact with contaminants at the site
               would remain if the site were to be developed for residential use.  PMC is an operating
               facility, but site conditions may be altered and the overall protectiveness (in terms of
               human health) of the No Action alternative under the future residential land-use scenario
               would need to be re-assessed during rezoning and land-use planning.  In addition to
               protectiveness concerns based on contact with site soils, the contaminated soils serve as
               a continuing source of ground water contamination and, thus, pose an indirect risk to
               human health via exposure to contaminated groundwater. Therefore, Soil Alternative 1
               may not be protective of human health if no action is taken to address groundwater
               contamination and contaminated groundwater is consumed for residential use.

               Soil Alternative 1  may not be protective of the environment.  The contaminated aquifer
               currently discharges into Lake Michigan. The exceedances of the Generic Soil Criteria
               Protective of the GSI lead to exceedances of the Generic Groundwater Criteria
               Protective of the GSI.  Impacts from  the current discharge of contaminated groundwater
               into Lake Michigan have not been  demonstrated and are unlikely, based on the  relatively
               low-levels of contaminants found in the aquifer.  Upon issuance of the ROD, U.S. EPA
               will obtain the final Generic Soil Criteria Protective of the GSI used as a drinking water
               source (See Appendix E for current partial list) and will work with MDEQ to develop
               site-specific GSI criteria. Although the criteria to be developed will be for groundwater,
               the revised groundwater GSI values may be used to  calculate site-specific soil criteria
               protective of the GSI.  To develop  site-specific soil criteria for the protection of the GSI,
               the site-specific GSI values for groundwater will be  multiplied by twenty (20) to allow
               for dilution and attenuation. Upon determination of the final generic GSI values and the
               site-specific GSI criteria, the selected GSI criteria will be placed in the site file  and
               applied as ARARs for the site cleanup. The determination of whether the No Action Soil
               Alternative would pose a risk to the environment (based on GSI criteria) could  be
               determined,  in part, based on these Generic Soil Criteria Protective of the GSI and the
               site-specific GSI criteria.

               Because contaminated soil at the PMC site would be either removed or covered with a
               cap under Soil Alternatives 2 and 3, these alternatives offer some degree of protection to
               human health and the environment. In addition, the proposed institutional controls
               would be necessary to protect human health  at the site during future residential land use
               and protect the environment under current industrial and future residential land-use
               conditions.

               Because Soil Alternative 3 involves remediation, it would provide better overall
               protection of human health and the environment than containment under Soil Alternative
               2.  Capping provides excellent short-term protection by minimizing direct contact with
               contaminated soil. However, capping most likely would not be consistent with future
               residential land use. Removal of soil under Soil Alternative 3 to satisfy Part 201 cleanup
               levels would be most protective of human health and the environment.

9.1.2           Groundwater Alternatives

               Groundwater Alternative 1 relies on existing institutional controls to be protective of

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              human health and the environment.  If the City's municipal regulation that requires use of
              the municipal water supply and prohibits the use of private wells (City Ordinance 651)
              were modified, rescinded or were otherwise not enforced, the No Action Alternative
              would not be protective.

              Groundwater Alternative 2 would be protective because supplemental deed restrictions
              would further minimize the potential for human consumption of contaminated
              groundwater. In addition, natural attenuation may be sufficient for remediating
              contaminated groundwater. Groundwater monitoring results would confirm the
              effectiveness of natural attenuation and allow the U.S. EPA and MDEQ to assess
              compliance with GSI criteria, which can be used  in conjunction with other information to
              determine if the natural discharge of the contaminant plume into the Lake is posing a
              threat to human health and the environment. Groundwater Alternative 2 is more
              protective than the No Action Alternative (Groundwater Alternative 1) because the
              monitoring will allow the U.S. EPA to track the attenuation of contaminant levels and
              would include the preparation of a Contingency Plan, which would be enacted if
              contaminant levels do not drop sufficiently or within the expected timeframe (currently
              estimated to be 5 years). This Contingency Plan would allow the Agency to be prepared
              to respond if the monitoring identifies an unacceptable risk to human health and the
              environment.

              Groundwater Alternative 3 would be protective because supplemental deed restrictions
              would be in place and contaminated groundwater would be extracted from the aquifer. .
              Groundwater Alternatives 2 and 3 would be equally protective as long as the
              contaminated groundwater is not used for consumptive purposes (deed restrictions are
              maintained) and the current discharge of the contaminated plume to the lake does not
              result in risks to human health and the environment.

9.2    Compliance with ARARs

       "Compliance with ARARs" addresses how the proposed alternative complies with all applicable
       or relevant and appropriate requirements of Federal and more stringent State environmental laws
       (ARARs), and also considers how the alternatives comply with advisories, criteria or other
       guidance to be considered (TBCs) that do not have the status of laws, but that the U.S. EPA and
       the State have agreed are appropriate for protectiveness or to carry out certain actions or
       requirements.  In some instances, rules cited contain both substantive and procedural or
       administrative requirements. Only the substantive requirements are ARARs for the purpose of
       on-site activities.  Examples of administrative or procedural requirements which are not
       considered ARARs include, but are not limited to, reporting requirements and permit application
       requirements.  A more detailed discussion of Site ARARs is provided in the FS.

9.2.1          Soil Alternatives

              Based on the current industrial land use, Soil Alternative 1 (No Action) would meet
              MDEQ industrial soil cleanup criteria for exposure from direct contact and ingestion of
              contaminants. However, Soil Alternative 1 (No Action) would not satisfy ARARs
              (Generic Residential Direct Contact Criteria) for future residential use of the property.
              The No Action alternative would also not meet MDEQ Generic Soil Criteria Protective of

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                                              27

              the Groundwater Surface Water Interface (GSI);

              Soil Alternative 2 would be effective in achieving site-specific cleanup levels that comply
              with Part 201 cleanup standards because (1) the risk assessment indicates that PMC site
              soil does not present unacceptable risks to human health under the current industrial
              exposure scenarios and (2) capping would reduce the mobility and amount of
              contaminants leaching to groundwater.  Soil Alternative 2 would only meet Generic
              Residential Direct Contact Criteria if the cap remained undisturbed and future
              development of the property were curtailed.

              Soil Alternative 3 would comply with ARARs under both the current industrial and future
              residential land-use scenarios through the removal of contaminated soil from the surface to
              5 feet below ground surface (bgs) and through the removal of TCE in soil from 5 to 18
              feet below ground surface (bgs);

              No action-specific ARARs were identified  for Soil Alternatives 1 and 2. Soil Alternative
              3 action-specific ARARs would be met by soil treatment before disposal in an off-site
              hazardous waste landfill (if the soil is determined to be hazardous) and by treatment of air
              emissions from the SVE system to meet MDEQ air regulations.  Finally, no location-
              specific ARARs were identified for the PMC site; therefore, this type of ARAR was not
              used to evaluate the alternatives.

9.2.2          Groundwater Alternatives

              Groundwater Alternative 1 would not comply with state or federal ARARs. Groundwater
              Alternative 2 may comply with drinking water ARARs (Michigan's Safe Drinking Water
              Act and MCLs) and MDEQ GSI values if natural attenuation occurs at a significant rate
              and soil does not leach contaminants to groundwater at levels that would adversely affect
              groundwater quality.  The ability of Groundwater Alternative 2 to meet ARARs would
              partly depend on the selection of a soil alternative that would sufficiently reduce leaching
              and cut-off the  continued contamination of the aquifer and would partly depend on the
              concentrations  in the aquifer compared to the forthcoming GSI criteria.  Initially,
              Groundwater Alternative 2 may not comply with GSI criteria; however, it is expected that
              GSI criteria will be met within a reasonable timeframe after the soil removal action has
              been completed. Groundwater Alternative 3 would comply with all cleanup, treatment,
              and discharge standards assuming aquifer restoration to meet Michigan Safe Drinking
              Water Act limits and MCLs is technically feasible.

9.3    Long-term Effectiveness and Permanence

       Long-term effectiveness and permanence evaluated the effectiveness of alternatives in protecting
       human health and the environment after response objectives have been met, in terms of the
       magnitude of residual risk and the adequacy and reliably of controls.

9.3.1          Soil Alternatives

              Soil Alternative 3 would provide the greatest long-term effectiveness and permanence
              because contaminated soil would be completely removed from the site or remediated to

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               levels protective of human health and the environment. Soil Alternative 2 would provide
               less long-term effectiveness and permanence because it relies on maintenance of the
               engineered cap and enforcement of deed restrictions. Soil Alternative 2 is not compatible
               with future residential use of the site. In addition, although the cap would slow leaching,
               the soil beneath the engineered cap will still have the potential to leach contaminants into
               the saturated zone. However, if Soil Alternative 2 is not effective, Soil Alternative 3 could
               be easily implemented.  Soil Alternative I would provide long-term effectiveness or
               permanence only under current industrial land use at the PMC site. Under Soil
               Alternative 1, potential  health risks may be posed under future residential land use.  In
               addition, contaminants in soil may leach to groundwater and surface water at
               concentrations that may cause risks to human health and the environment.

9.3.2           Groundwater Alternatives

               Groundwater Alternative 3 would have the lowest magnitude of residual risks because
               contaminated groundwater would be actively removed from the aquifer.  Under
               Groundwater Alternative 2, residual risks would remain but groundwater monitoring
               would be conducted to assess the magnitude of these risks.

               Groundwater Alternative 1 would have the greatest  magnitude of residual risks associated
               with it because no action would be taken and no monitoring would be implemented.

               Groundwater Alternatives 2 and 3 have similar controls in place,  including deed
               restrictions and  groundwater monitoring. Under Groundwater Alternative I, existing city
               and county administrative controls would be in place to help ensure the alternative's
               effectiveness and permanence; however, monitoring would not be implemented to ensure
               the effectiveness of natural attenuation of hazardous substances

9.4     Reduction of Contaminant Mobility, Toxicity and Volume Through Treatment

        Reduction in toxicity, mobility, or volume through treatment evaluated the treatment
        technologies by the degree of expected reduction in toxicity, mobility, or volume of hazardous
        material.  This criterion also evaluates the irreversibility of the treatment process and the type
        and quantity of residuals remaining after treatment.

9.4.1           Soil Alternatives

               Soil Alternative 3 would provide the greatest reduction of toxicity, mobility, and volume
               of contaminated materials. SVE treatment would remove VOCs from subsurface soil and
               capture the VOCs in carbon canisters, which would be sent off site for treatment and
               disposal. SVOC-  and metals-contaminated soil would be excavated and sent to an off-site
               landfill.  The amount of reduction in contaminant mobility depends on engineering
               controls at the off-site landfill.

               Under Soil Alternative  2, the toxicity and volume of contaminated soil would not be
               altered, but mobility would be reduced by capping contaminated soil. The effectiveness of
               the cap in reducing mobility is largely dependent on the maintenance and integrity of the
               cap. A small volume of contaminated soil would likely be hauled to an off-site landfill

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              during preparation of the site for the engineered cap. The amount of reduction in
              contaminant mobility depends on the engineering controls at the off-site landfill.

              Soil Alternative 1 would not reduce the toxicity, mobility, or volume of contaminants
              through treatment. The most mobile contaminant of concern, TCE, was detected in soil
              near and under the northwest portion of the PMC building; therefore, the PMC building
              provides some protection from precipitation infiltration.  Other contaminants of concern,
              including metals and SVOCs, are relatively immobile; under Soil Alternative 1, no action
              would be taken to reduce the long-term potential for the leaching of contaminants to
              groundwater.
9.4.2           Groundwater Alternatives

               Under Groundwater Alternative 3, destruction of toxic hazardous substances would occur
               through on-site groundwater treatment and possibly off-site treatment at the POTW.
               Under Groundwater Alternative 1, no cleanup standards are set and no reductions in
               toxicity, mobility, or volume of contaminants would be monitored.

               Under Groundwater Alternative 3, the total mass of toxic substances would also be
               reduced through groundwater extraction and treatment. Under Groundwater Alternative 2,
               the total mass of toxic substances would be reduced by natural dilution and attenuation.
               Under Groundwater Alternative 1, reduction in contamination would not be evaluated.

               Under Groundwater Alternative 3, groundwater extraction would help reduce the mobility
               of contaminated groundwater by minimizing off-site migration.  The mobility of
               groundwater contamination would not be reduced under Groundwater Alternatives 1 and
               2. Under Groundwater Alternative 2, groundwater monitoring would be conducted to
               assess the magnitude  of contaminant migration and its potential impact at the GSI.

               The volume of contaminated groundwater would be reduced under Groundwater
               Alternative 3 but would not be reduced under Groundwater Alternatives 1  and 2.

9.5     Short-term Effectiveness

        Short-term effectiveness addresses the period of time needed to achieve protection and any
        adverse impacts on human health and the environment that may be posed during the construction
        and implementation period, until the remedial action objectives are achieved.

9.5.1           Soil Alternatives

               All alternatives except Soil Alternative 1 would pose some degree of short-term risks
               during implementation. The significance of the risks depends on the nature and duration
               of remedial activities. For example, the remediation crew and nearby residents may face
               exposure to contaminated dust during remedial activities associated with Soil Alternatives
               2 or 3. Techniques, such as dust suppression, will be used to minimize these impacts.

               Short-term risks associated with Soil Alternative 2 are lower than under Soil Alternative 3
               because Soil Alternative 3 takes the longest time to implement.  Soil Alternative 3 is also

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               more intrusive and labor-intensive and thus requires more support equipment and on-site
               activities. Soil Alternative 2 can be constructed relatively quickly and does not involve
               intrusive activities.
9.5.2           Groundwater Alternatives

               Groundwater Alternatives 2 and 3 provide for deed restrictions that would protect future
               PMC property owners from ingestion of contaminated groundwater. Groundwater
               Alternative 3 would present the greatest short-term risks to the community and workers
               associated with construction, increased traffic, and potential exposure to contaminated
               groundwater.  None of the alternatives are expected to pose adverse environmental
               impacts during construction or implementation.

               Groundwater Alternative 1  would not involve any action; therefore, no time is required for
               implementation. Groundwater Alternative 2 would require about 3 to 5 weeks to
               implement and 30 years for groundwater monitoring.  The Feasibility Study estimated that
               Groundwater Alternative 3  would require about 26 weeks to implement and 30 years for
               groundwater extraction and monitoring.  The 30-year  timeframe was assumed for the
               development of alternative cost estimates. However,  it is very possible that monitoring
               (Groundwater Alternatives 2 and 3) and extraction (Groundwater Alternative  3) could be
               concluded well before the 30-year estimate.

9.6    Impiementability

       Implementability assesses the ability to construct and operate  the technology; the reliability of -
       the technology; the ease of undertaking additional remedial actions; and the ability to monitor
       the effectiveness of the remedy. Administrative feasibility is  addressed in terms of the ability to
       obtain approvals from other agencies.  This criterion also evaluates the availability of the
       required resources, such as equipment, facilities, specialists, and capacity.

9.6.1       .    Soil Alternatives

               Soil Alternative 1 would require no technical implementation and is therefore the easiest
               alternative to  implement.  Soil Alternative 2 would be easier to implement than Soil
               Alternative 3  because it includes asphalt capping, which is non-intrusive and  easily
               conducted. Soil Alternative 3 would be the most difficult alternative to implement
               because it requires  additional predesign soil sampling and analysis, waste characterization,
               and the most equipment mobilization. Soil Alternative 2 would be the most difficult
               alternative to  implement administratively because it requires deed restrictions and future
               maintenance and evaluation.

9.6.2           Groundwater Alternatives

               Groundwater Alternative 1 is the easiest to implement. Groundwater Alternative 2 is the
               next easiest to implement and may show that natural processes  are working to achieve
               cleanup standards.  Groundwater Alternative 3 would be the most difficult alternative to
               technically implement because of the additional data  needed to properly design a pump-
               and-treat  system. Site features, such as the fractured  nature of the bedrock aquifer and

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               large-scale lake effects from Lake Michigan, could make design of a pump-and-treat
               system difficult. Groundwater Alternative 3  is also more difficult to administratively
               implement because permits or their substantive requirements would have to be met for air
               emissions and ground water discharge.
9.7    Cost
       Cost evaluated the capita] and operation and maintenance costs of each alternative, and provides
       an estimate of the total present worth cost of each alternative.

9.7.1           Soil Alternatives

               The present worth costs for each alternative, from highest to lowest, are: (1) Soil
               Alternative 3 at $145,200;  (2) Soil Alternative 2 at $52,600; and (3) Soil Alternative 1 at
               $0. Soil Alternative 3  is expected to have only capital costs and does not require yearly
               O&M. Soil Alternative 2, which includes the construction of an asphalt cap at the PMC
               facility, has a lower capital cost, but would require yearly O&M to maintain the
               effectiveness of the remedy.

9.7.2           Groundwater Alternatives

               The present worth costs for each alternative, from highest to lowest, are: (1) Groundwater
               Alternative 3 at $874,500; (2) Groundwater Alternative 2 at $250,700; and (3)
               Groundwater Alternative 1 at $0.  Groundwater Alternative 3 is more expensive than
               Groundwater Alternative 2 because in addition to monitoring, the alternative includes
               significant capital costs for the construction of the extraction and treatment system.

9.8    State Acceptance

       State acceptance addresses whether, based on its review of the RI/FS and Proposed Plan, the
       state concurs with, opposes, or has no comment on the  proposed remedial alternative(s).

9.8.1           Soil Alternatives

               The State of Michigan conducted the investigation at the Petoskey  Municipal Well Field
               Site and prepared the RI Report. The MDEQ has provided comments on the draft FS
               Report prepared by the U.S. EPA. The State of Michigan has documented its
               concurrence with the proposed soil alternative, Soil Alternative 3, in its letter of
               concurrence (see Appendix A).

9.8.2           Groundwater Alternatives

               The State of Michigan conducted the investigation at the Petoskey  Municipal Well Field
               Site, prepared the RI Report, and, at the request of U.S. EPA, performed follow-up
               groundwater sampling to obtain a more recent profile of groundwater contaminant
               concentrations. In  addition, the MDEQ has provided comments on the draft FS Report
               prepared by the U.S. EPA. The State of Michigan has documented its concurrence with

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              the proposed groundwater alternative, Groundwater Alternative 2, in its letter of
              concurrence (see Appendix A). Note that the State of Michigan's concurrence requires
              that Groundwater Alternative 2 be implemented with Soil Alternative 3. Groundwater
              Alternative 2 would not be acceptable to the State of Michigan if significant source
              removal were not planned for the PMC property.

9.9    Community Acceptance

       Community acceptance addresses whether the public concurs with the Proposed Plan.
       Community acceptance of the Proposed Plan was evaluated based on comments received at the
       Public Meeting and during the public comment period.  This is documented in the
       Responsiveness Summary presented in Appendix B.

9.9.1          Soil Alternatives

              Community acceptance is assessed in the attached Responsiveness Summary. The
              Responsiveness Summary provides a thorough  review of the public comments received
              on the Proposed Plan, and the Agency's responses to those comments.

9.9.2          Groundwater Alternatives

              Community acceptance is assessed in the attached Responsiveness Summary. The  •
              Responsiveness Summary provides a thorough  review of the public comments received
              on the Proposed Plan, and the Agency's responses to those comments.
10.0   THE SELECTED REMEDY

Based upon consideration of the requirements of CERCLA, as amended by SARA, and the NCP, the
detailed analysis of alternatives and public comments, U.S. EPA and the State of Michigan have selected
Soil Alternative 3 and Groundwater Alternative 2 as final remedies for the Petoskey Municipal Well
Field Site.

The detailed evaluation of soil and groundwater alternatives, conducted as part of the preparation of the
FS Report and in preparation of this ROD, found that:

•       Excavation of soil exceeding Michigan's Generic Direct Contact Criteria for residential use will
        allow for unrestricted use and/development of the property. The volume of soil (approximately
        15  cubic yards) that would have to be excavated to eliminate the need for any land use
        restrictions is relatively small.

•       Excavation of soil exceeding Michigan's Generic Soil Criteria for the Protection of the GSI is a
        relatively inexpensive method of stopping the flow of contaminants to groundwater. While the
        excavation of the top five (5) feet shown in Figure 6 will not remove  all soils that exceed the
        Generic Soil Criteria for the Protection of the GSI, it will remove a large mass of contaminants
        that are leaching or have the potential to leach.

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•      Removal of TCE through SVE will be a relatively inexpensive method of reducing the flow of
       organic contaminants into groundwater.

•      Source control actions in soils are more direct and less expensive then active groundwater
       remediation.  It makes sense to remove contaminants that have the potential to leach to
       groundwater rather than trying to remove the contaminants once they have leached from the soil,
       entered the aquifer, dispersed and become diluted.

10.1   Additional Discussion or Selected Soil Remedy - Soil Alternative 3

       The selected soil remedy consists of excavating soil in the affected area (see Figure 6). RI data
       indicate that metal contamination extends from the  ground surface to approximately 5 feet bgs,
       SVOC contamination extends from the surface to approximately 7 feet bgs (with the exception of
       the northwest corner of the building where it extends to the water table), and TCE contamination
       extends from the ground surface to the top of the water table at approximately 18 feet bgs.
       Because it is impractical to excavate to 18  feet bgs near the PMC building, the selected remedy
       assumes that the existing on-site wells, MW-201S,  MW-203S, and MW-204S, would be used for
       SVE treatment to remove TCE from soil below 5 feet bgs  before excavation begins. A surface
       seal, such as a 40-mil liner or other suitable material, would be placed near MW-201S to reduce
       the potential for short-circuiting of ambient air into the SVE system.

       The RI report indicates that a small area near and below the northwest side of the PMC building
       contains TCE at concentrations exceeding  the target cleanup level of 0.1 milligram per kilogram.
       Pilot-scale  SVE testing was conducted in the area of TCE  contamination, and the pilot tests
       indicate that the TCE concentrations in the discharged soil vapors were relatively low, ranging
       from 2 to 9 parts per billion (ppb) in MW-203S to 2 to 3 ppb in MW-201S. The selected soil
       remedy assumes that the SVE wells would be sampled for organic vapors and that wells would be
       operated until no organic vapors are detected in the wells.  Confirmational soil samples would be
       collected as needed to document that TCE-contaminated soil has been remediated.

       After operation of the SVE system,  approximately  15 yd3  of contaminated soil would be removed
       to meet Michigan Generic Soil Direct Contact Criteria.  In addition, approximately 2,050 yd3 of
       contaminated soil would be removed under Soil Alternative 3 to remove the potential source of
       groundwater contamination and to meet MDEQ soil criteria for protection of groundwater and
       surface water quality. The remedial response area may need to be updated during remedial design
       to address the revised Generic Soil Criteria Protective of the GSI and/or site-specific Soil Criteria
       Protective of GSI that would be developed based on site-specific GSI criteria (assuming a mixing
       zone). Note that both Michigan's Generic Soil Criteria Protective of GSI and Michigan Generic
       GSI Criteria were in the process of being updated during the time that the FS Report and this ROD
       were in development. Therefore, the specific identification of exceedances of generic groundwater
       and soil criteria (related to the GSI) were not completed prior to the issuance of this ROD. The
       most recent list of available GSI criteria (for soils and groundwater) has been included in
       Appendix E of this ROD and is assumed to be the controlling GSI criteria until such time as the
       site-specific values can be calculated for the Petoskey site. These temporary criteria were based on
       discharge to a drinking water source, but the list does not contain criteria for all contaminants of
       concern at the Petoskey site.  The numbers to be provided by the MDEQ subsequent to the ROD
       signature date will  be based on GSI protective of a  drinking water source and will include the
       remainder of the necessary Generic GSI Criteria (to address all site contaminants of concern) and

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site-specific GS1 criteria. U.S. EPA will work with MDEQ to determine which criteria should be
applied to the Petoskey site. When available, these site-specific GSI criteria and "20 times" GSI
soil values protective of a drinking water source will be placed in the site file and applied as
ARARs for the site cleanup.

Excavation at the PMC property would involve preparing each excavation area, excavating
contaminated soil containing hazardous substances at concentrations that exceed cleanup
standards, sampling soil to confirm that cleanup standards are met, and backfilling and restoring
excavated areas with clean fill.  The excavation approach would be described in an approved
excavation plan that discusses excavation methods, health and safety monitoring, soil sampling
and analysis, and soil removal.  Because the PMC site is active, excavation work would be closely
coordinated with PMC to develop excavation methods and schedules. Excavation methods would
consider health and safety issues, including ambient air monitoring and physical hazards, and
contingency planning. General excavation methods are discussed below.

•       Excavation area preparation involves clearing and removing vegetation and providing
        utility clearance, constructing run-on and runoff controls for surface drainage control, and
        constructing decontamination facilities.  Site areas are vegetated with grasses, trees, or
        shrubs. Prior to excavation, mature trees will be cleared and removed as needed.
        However, U.S. EPA (in consultation with MDEQ) will attempt avoid disturbing trees
        when possible. Trees can be felled using chain saws, and the limbs can be collected and
        staged for off-site disposal or off-site municipal composting. Property boundaries and
        excavation areas will be field-staked based on certified land survey results. Clearance will
        be required for electrical,  gas, sanitary and storm sewer, and water lines.

•       A decontamination area will be constructed to capture all water used to decontaminate
        excavation equipment and vehicles. The decontamination area can be constructed of a
        HDPE liner and bermed.  The decontamination pad will be sized to easily accommodate
        either the largest equipment piece or two trucks used to transport excavated soil off site,
        whichever is larger. Decontamination water can be batch mixed in a 1,000-gallon,
        temporary storage tank. The decontamination water will be applied to all vehicles using
        hot water and a steam cleaner with pressure sprayer.

•       Contaminated soil will be excavated mechanically using standard construction equipment
        such as loaders, bulldozers, and backhoes. The excavation equipment will be equipped
        with 1- to 2-yd3 buckets.  Dust control will be accomplished by spraying contaminated soil
        with a mobile water source or water provided  by PMC during excavation, staging, and
        loading.  Excavated soil will be sampled and analyzed to determine the appropriate landfill
        for disposal. RI data indicate that most contaminants are present at relatively low
        concentrations; however,  zinc may be present at a concentration in toxicity characteristic
        leaching procedure (TCLP) leachate exceeding the MDEQ hazardous waste limit of 500
        mg/L. No TCLP analyses were conducted during the RI; therefore, the actual extent  of
        excavation will be based on soil analytical results obtained during excavation.  Samples of
        the excavation floor and walls will be analyzed with a 72-hour turnaround, if possible, to
        determine when a sufficient volume of soil has been removed to meet the cleanup levels.

*       Excavated materials will be staged as needed pripr to loading into dump trucks for
        transport to an approved off-site landfill. Once excavation activities are complete, the

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               excavated area will be surveyed, backfilled, compacted, graded, and in some cases, paved
               with asphalt or patched with concrete. The excavated area will be backfilled with
               imported, clean soil.  After remedial activities are completed, the temporary fence will be
               taken down, grass areas seeded, and gravel placed in the parking areas north of the PMC
               building.

       •       The excavated materials will be transported by covered trucks to a hazardous waste
               landfill or sanitary landfill for disposal.  Hazardous waste landfills accept hazardous
               wastes as defined by federal and State of Michigan Act 451, Part 111, regulations.
               Sanitary landfills accept nonhazardous, sanitary waste as defined by State of Michigan Act
               451, Part 115. Off-site commercial disposal capacity should be adequate to handle the
               volume of contaminated soil from the PMC site. One hazardous waste landfill that can
               treat and dispose of the contaminated soil  is located near Detroit, Michigan.

       Because of the presence of the PMC building, it was not possible for investigators to completely
       characterize the soils below the foundation of the PMC facility. As a result, there is the potential
       for exposure to or exacerbation of any contamination under the building. Therefore, Alternative
       3 requires that a deed restriction be placed on the PMC property.  This deed restriction will
       identify the landowner's responsibility to exercise due care in accordance with Part 201
       requirements, and, in the event that the soils underneath PMC are uncovered, determine if there
       is a threat to human health and the environment and/or exceedances of Michigan's chemical-
       specific ARARs, to not exacerbate an existing condition, and to conduct any follow-up action
       (i.e., additional excavation and disposal) necessary for the development of the property.

10.2   Additional Discussion of Groundwater Remedy - Groundwater Alternative 2

       This selected groundwater alternative, Groundwater Alternative 2, consists of implementing deed
       restrictions in combination with an increased level of groundwater monitoring and the natural
       attenuation of the existing groundwater contamination.  The major components of this alternative
       are as follows:

       •       In conjunction with the removal of source area contamination, residual groundwater
               contamination will be allowed to naturally attenuate. It is anticipated that the
               contamination will disperse, become diluted, and discharge  into  Lake Michigan.

       •       Deed restrictions will be instituted to prohibit future consumption of groundwater (for
               private property because the current municipal ordinance  may be insufficient to prohibit
               the construction and  use of groundwater).

       •       Additional monitoring wells will be installed; and

       •       Groundwater monitoring will be performed on a regular, periodic basis to track the
               decrease in contaminant concentrations (in comparison with the  predicted rate of natural
               attenuation) and to demonstrate compliance with GSI criteria.

       Approximately 11 additional monitoring wells will be installed to supplement the existing
       monitoring well  network installed during the RJ. At each of the five cluster locations, two
       monitoring wells will be installed, with one well screened from about 15 to 20 feet  bgs and one

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       well screened from about 35 to 40 feet bgs.  The other well will be paired with existing well PS-11
       and screened at about 15 to 20 feet bgs. The new monitoring network will be sufficient to evaluate
       both the areal and vertical extent of contaminated groundwater. For cost estimating purposes, it is
       assumed that all new monitoring wells will be air rotary drilled. It is also assumed that the wells
       will be constructed of 2-inch-diameter PVC screens and risers.  However, based on VOC
       contaminant concentrations observed in the most recent groundwater monitoring event, it may
       prove necessary to use galvanized/stainless steel materials in some or all of the monitoring wells.
       Final well construction details such as exact locations, depths, screen lengths, and materials will be
       specified in the remedial design.

       Groundwater monitoring will be conducted to evaluate changes in contaminant concentrations
       over time, determine whether exceedances of MCLs or GSI values still occur, and evaluate the
       potential impact of contaminated groundwater on the GSI. Groundwater monitoring will  also be
       used to evaluate whether natural attenuation processes are adequately restoring groundwater to its
       beneficial uses. General parameters for groundwater sample analysis include VOCs, SVOCs,
       inorganics, those parameters needed to determine whether or not natural attenuation is occurring,
       and those parameters needed to monitor the progress of natural attenuation. Field measurements
       will include static water level, pH, temperature, and specific conductivity. For cost estimating
       purposes, it is assumed that (1) 36 monitoring wells will be sampled annually for the first 3  years
       after implementation, (2) 12 monitoring wells will be sampled quarterly for the first 3 years, and
       (3) 12 monitoring wells will be sampled semiannually from years 4  through 30. The number of
       wells sampled and sampling frequency may change over the 30-year period or until monitoring is
       deemed no longer necessary.  If natural attenuation is not sufficiently restoring groundwater
       quality, other remedial actions may be implemented, as necessary.

10.3   Cleanup Levels

10.3.1          Soil Cleanup Levels

               For all soil at the PMC facility, regardless of depth,  the cleanup levels are set at
               Michigan's Part 201 Generic Residential Direct Contact Criteria.  For soils within the
               surface to 5 foot depth, removal of soils exceeding Generic  Residential Direct Contact
               Criteria is required. However, U.S. EPA, in consultation with MDEQ, may make risk
               management decisions during Remedial Design to determine the necessity of excavation
               of any soil at depth (below 5 ft) that exceeds the Generic Residential Direct Contact
               Criteria.  U.S. EPA's risk management decisions will be based on the approximate
               volume of soil in question, the degree to which the contaminant concentration(s) exceeds
               the Generic Residential Direct Contact Criteria, and practical considerations such ease of
               excavation and cost.

               In addition to Generic Residential Direct Contact Criteria, soils within the planned
               surface to 5 foot depth must meet Michigan's Generic Soil Criteria Protective of the GSI
               protective of drinking water or the soil criteria protective of the site-specific GSI criteria
               (both to be provided post-ROD).  The U.S. EPA will work with the MDEQ to develop
               site-specific GSI values for groundwater and the corresponding soil criteria protective of
               the site-specific GSI values.  U.S. EPA will work with MDEQ to determine which of
               these two sets of soil criteria (soils criteria protective of generic and site-specific GSI
               values) will be applied to the Petoskey site. Based on available site data, many of the

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              Generic Soil Criteria Protective of the GSI for inorganic contaminants default to
              background levels. However, background inorganic concentrations in the area of PMC
              have not been sufficiently established. Thus, depending on the stringency of the site-
              specific soil criteria protective of GSI in comparison to inorganic concentrations in soils,
              it may or may not be necessary to better define background.

              The cleanup goal for TCE in unsarurated soils, regardless of depth, will be the Generic
              (or site-specific) .Criteria for the Protection of GSI. However, a performance based
              approach will be used to determine when the operation of the SVE system should be
              discontinued so that excavation activities can proceed.  If the SVE system fails to
              sufficiently reduce the levels of TCE, U.S. EPA (in consultation with the MDEQ) may
              consider pulsing the SVE system (before or after excavation) and supplementing the
              SVE system with air sparging. Air sparging basically pumps air into the unsaturated
              zone, which could help volatilize contaminants (i.e., TCE) and allow more productive
              removal via SVE.

              U.S. EPA may also adjust the area of remediation to best use remedial  funds. Because
              the actual cost of excavation and disposal of site soils is so low, it may be more practical
              (from an economical and engineering perspective) to remove additional soil in lieu of
              confirmatory sampling. These types of decisions will be made (in consultation with the
              MDEQ) during remedial design, based on the estimated cost of sample analyses and the
              estimated cost of the time (equipment and personnel) in the field.

10.3.2         Groundwater Cleanup Levels

              MCLs, Michigan's Act 399 Safe Drinking Water Act standards and Michigan's GSI
              criteria (based on Parts 31 and 201 of NREPA, as amended, and their associated
              administrative rules) have been selected as cleanup levels for the Petoskey Municipal
              Well Field Site. The most stringent of the federal and state standards will apply. TCE,
              the primary contaminant present in groundwater, will have a cleanup standard of 5 ppb.
              For vinyl chloride, the cleanup standard will be 2 ppb.

              Because contaminated groundwater is not currently being used as part  of a drinking
              water supply, MCLs are not applicable  requirements.  However, MCLs are relevant and
              appropriate for usable aquifers and one of the goals for remediation is to return the
              groundwater to its most beneficial use.

10.4   Environmental Monitoring / Contingency Plan for Follow-Up Action

       Environmental monitoring will be used to evaluate: (1) the effectiveness of natural attenuation
       processes  in the groundwater contaminant plume, (2) compliance with appropriate MDEQ GSI
       criteria, (3) compliance with MCLs and Michigan Act 399 Safe Drinking Water Standards, and
       (4) the change in risks to human health and the environment over time. Environmental
       monitoring will consist of routine periodic sampling and analysis of groundwater. Since the
       Ingalls Well is no longer pumping, the current path of groundwater flow may be different than it
       was during the Remedial Investigation phase of the  site.  Therefore, more frequent sampling and
       analysis at site monitoring wells will need to be conducted in the first three years of remediation

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to establish a new baseline of groundwater flow and contaminant concentrations.

Contaminated groundwater discharging to Lake Michigan will be monitored at the Point of
Compliance (POC) and at sentinel wells within the groundwater plume.  The GSI protection
criteria for the POC will be either the final Generic GSI Criteria protective of a drinking water
source or the calculated site-specific mixing zone-based value.  POC wells will be installed in
the contaminated groundwater plume as close to Lake Michigan as possible where groundwater
gradients demonstrate movement toward Lake Michigan.

Sentinel wells are to be located in the groundwater contaminant plume between PMC and the
POC. Sentinel wells are used to predict or provide early warning of potential exceedances of
POC criteria and to monitor the effectiveness of the remedy in reducing the level of
contaminants within the plume.

The details of establishing progress toward restoration of the aquifer to beneficial use will be
developed in the Long-Term Monitoring Plan, which will be required in the Statement of Work
for Remedial Design/Remedial Action.  The Long-Term Monitoring Plan will utilize
mathematical projections showing the projected/actual change in the groundwater contaminant
concentrations over time. The individual contaminants, and the cumulative risk (to be roughly
estimated) posed by these contaminants, will be evaluated at each monitoring event to establish a
trend (improving or deteriorating) of the groundwater restoration and contaminant attenuation.
Least square fit and linear regression analysis are two mathematical approaches that can be used
to show these trends.

A Contingency Plan will be provided in the Long-Term Monitoring Plan and will be
implemented to protect human health and the environment if environmental monitoring predicts
or detects statistically-significant exceedances of POC criteria that demonstrate that natural
attenuation is not occurring sufficiently or at an acceptable rate. Because the groundwater
alternative relies on natural attenuation to disperse and dilute the contaminants remaining in the
groundwater after the  source area at PMC has been addressed, it is possible that initially there
will be exceedances at the POC as the contaminants in the groundwater disperse.  If this occurs,
the significance of the exceedance will be evaluated with regard to concentration, duration, and
the potential impact to human health and the environment. Where such evaluation identifies the
likelihood of on-going exceedences which impact human health and the environment, the
contingency plan will  be implemented.

If the implementation  of Soil Alternative 3 fails to result in sufficient reductions in groundwater
contaminant concentrations (in terms of actual concentrations and the rate or reduction), the
Contingency Plan will require an evaluation of the impacts of the exceedance, potentially leading
to increased monitoring, the implementation of active groundwater extraction/treatment, an
additional source control action, or other suitable methods, to prevent further release of
contaminants to the surface water body.  These measures may include: groundwater pump-and-
treat (either within the aquifer or localized at the PMC property); groundwater bioventing and/or
biosparging; enhanced biodegredation of contaminants in the plume; in-well stripping; a
combination of these procedures; or other technology approved by the U.S. EPA, in consultation
with MDEQ, as suitable for remediation.

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10.5   Institutional Controls

       Institutional controls in the form of deed and land use restrictions will be implemented to
       prohibit groundwater use associated with the contaminant plume where contaminant
       concentrations exceed (or approach) MCLs or Michigan Drinking Water Standards (Act 399).
       These deed and land use restrictions will be for both the PMC property and off-site properties
       where the U.S. EPA determines that the existing municipal ordinance restricting the use of
       private wells is insufficient.  Because the City's ordinance contains a variance provision whereby
       a resident can request that the City give permission for installation and use of a private well, the
       U.S. EPA and the MDEQ have determined that the City's ordinance is insufficient for privately-
       owned property. For City property, however, the ordinance appears sufficient because it is very
       unlikely that the City would install a well in the contaminated aquifer. The City is required to
       adhere to all state and federal regulations for municipal water supplies and to monitor the quality
       of the extracted groundwater to ensure that federal and state drinking water requirements are
       met.

       A deed restriction will also be placed on the PMC property indicating that, if the property is
       redeveloped and the building is removed (partially or totally), the landowner is responsible for
       implementing the "due care" provisions of Michigan Part 201. The deed restriction will also
       require (if soils under the building are uncovered) the property owner to determine if there is a
       threat to human health and the environment and/or exceedances of Michigan's chemical-specific
       ARARs, conduct any follow-up action (i.e., additional  investigation and disposal) necessary for
       any development of the property, and not exacerbate an existing condition.

10.6   Natural Attenuation

       The selected remedial alternative for groundwater includes natural attenuation for  resolution of
       site-related  VOCs in groundwater.  Based on historical experience at the site, contaminant
       concentrations  in the well field dropped significantly after the partial remediation of site soils
       from the early 1982 removal action. This drop in groundwater contaminant concentrations after
       the early removal action is discussed further in the 1998 Remedial Investigation Report, which
       can be found in the site repository as part of the Administrative Record for this ROD.
       Implemented in conjunction with Soil Alternative 3, U.S. EPA expects that groundwater
       monitoring  will show reductions in contaminant concentrations and that acceptable groundwater
       contaminant concentrations will be reached within a reasonable time.

       Natural attenuation is an appropriate remediation method only where it is fully protective of
       human health and the environment, and where it can be demonstrated capable of achieving site-
       specific remediation objections (e.g., MCLs, GSI criteria, and Michigan's Safe Drinking Water
       Standards) within a reasonable time frame. The NCP states that remediation time  frame for
       restoring groundwater to its beneficial use should be developed based on specific site conditions.
       Because groundwater contamination is relatively limited in terms of the length of the plume, the
       number of contaminants, and contaminant concentrations, U.S. EPA expects that drinking water
       standards should be reached in the aquifer within approximately five years after completion of
       the soil cleanup at the PMC facility. The remediation time frame will be further evaluated as
       part of the Long-Term Monitoring Plan.

-------
                                             40

10.7   Five-Year Site Reviews

       Under CERCLA Section 121(c), a remedial action that results in hazardous wastes, pollutants, or
       contaminants remaining on site should be reviewed every five years.  Data collected during the
       monitoring program will be used to assess potential impacts of contaminants, and evaluate
       whether human health and the environment continue to be protected by the alternatives.


11.0   STATUTORY DETERMINATIONS

The selected remedy must satisfy the requirements of Section 121 (a-e) of CERCLA, as amended by
SARA, to:

•             Protect human health and the environment;
•             Comply with ARARs (or justify a waiver);
•             Be cost effective;
•             Utilize permanent solutions and alternative treatment or resource recovery technologies
              to the maximum extent practicable; and,
•             Satisfy the preference for treatment as a principal element or provide an explanation as
              to why this preference is not satisfied.

The implementation of Soil Alternative 3 and Groundwater Alternative 2 satisfies the requirements of
CERCLA, as amended by SARA, as detailed below:

11.1   Protection of Human Health and the Environment

       The selected remedies will provide adequate protection of human health and the environment
       through removal of soils at PMC that pose a direct contact threat. The excavation of soils, in
       conjunction with the operation of the SVE system, will remove contaminants that are leaching,
       or have the potential to leach, to groundwater at levels in excess of chemical-specific ARARs.

       The implementation of supplemental deed restrictions (in addition to the existing municipal
       ordinance) to further reduce the likelihood of groundwater use, and the monitoring of
       contaminant concentrations in the plume, will allow the U.S. EPA to effectively restrict contact
       with and use of groundwater that could pose a health risk if used for consumptive purposes. The
       potential future risks associated with use of groundwater will decrease over time because natural
       attenuation is expected to reduce the concentration of contaminants to meet MCLs and Michigan
       Safe Drinking Water Standards.

11.2   Compliance with ARARs

       The selected remedies will comply with identified federal and state ARARs. The primary
       chemical-specific ARARs were discussed in Section 6 of this ROD in order to clarify how
       contaminant concentrations were evaluated (in conjunction  with the Baseline Risk Assessment
       process). A summary of chemical-specific,  location-specific and action-specific ARARs for the
       selected alternatives (and possible groundwater contingency plan actions) is provided in Table 3
       of this ROD.

-------
                                              41

       A brief narrative of significant chemical and action-specific ARARs, follows:

11.2.1         Water Regulations

              Chemical-specific ARARs for site groundwater include regulations and criteria
              promulgated under the Safe Drinking Water Act (SDWA), Clean Water Act, and State of
              Michigan statutes. In addition, certain other numerical goals will be attained.  The
              federal National Drinking Water Regulations consist of contaminant-specific standards
              known as MCLs and Maximum Contaminant Level Goals (MCLGs). MCLs are
              enforceable standards that are the maximum permissible level for specific contaminants
              in public water supplies.  MCLGs are non-enforceable health-based goals that establish
              levels at which no known or anticipated health effects occur. The NCP,
              300.430(eX2)(l)(B) and (C), requires that MCLGs above zero, and MCLs, be attained
              for groundwater sources that are current or potential sources of drinking water.

              Under the Michigan Safe Drinking Water Act and related administrative rules, the state
              has primarily adopted federal MCLs. Because groundwater associated with the Petoskey
              Site is potentially a drinking water source, MCLs are not applicable at the site, but they
              are relevant and appropriate.  As part of the FS and this ROD, the U.S. EPA has
              compared groundwater contaminant concentrations with MCLs and Michigan Safe
              Drinking Water Standards.

              Part 201 of the Michigan Natural Resources and Environmental Protection Act
              (NREPA), 1994 PA 451, as amended, and associated administrative rules, is also an
              ARAR for this site as discussed in Section 6.0.

              Under Part 201 and under Rule 323.1057 of Part 4 of Part 31 of the NREPA, 1994, as
              amended, Groundwater Surface Water Interface (GSI) criteria have been identified as
              goals for the selected remedy. Part 31 of NREPA and associated administrative rules (in
              particular, parts 4, 8 and section 9) provide GSI criteria and protection to the GSI. These
              GSI criteria identify the maximum groundwater contaminant discharge to surface water.
              Under the 1995 amendments to Part 31, mixing zones for groundwater venting to a
              surface water body are allowed. Mixing zone determinations and discharge criteria are
              developed on a case by case basis in accordance with Part 31.  U.S. EPA will work with
              MDEQ to determine the final Generic GSI Criteria and  to develop site-specific GSI
              criteria based on a mixing-zone determination for the Petoskey Municipal Well Field
              Superfund  Site. Upon determination of the final Generic GSI Criteria and the site-
              specific GSI criteria, the final Generic GSI Criteria and/or the site-specific GSI criteria
              will be placed in the site file and will be used as ARARs for the site cleanup.

              The Mineral Well Act (Act 315, PA 1969) contains rules describing requirements for
              drilling brine, storage, disposal and test wells, geophysical test holes, and foundation
              borings. Because the installation of monitoring wells in included as part of the selected
              groundwater remedy, the Mineral Well Act is an applicable ARAR. However, permits
              will not be required for activities conducted on-site, which includes the area of
              groundwater contamination.

-------
                                               42

11.2.2          Soil Regulations

               Part 201 of the Michigan NREPA, as amended, and associated administrative rules, is
               applicable for the soil cleanup at the Petoskey site.  The Following appropriate criteria
               ha\e been determined to be chemical-specific ARARs for the selected remedial action
               for soils.

                      •        Statewide Default Soil Background Levels,
                      •        Site-specific  Soil Background Levels;
                      «        Generic Soil  Criteria Protective of the Groundwater Surface Water
                              Interface (GSl);
                      •        Generic Residential Direct Contact Criteria;
                      •        Generic Industrial Soil Direct Contact Criteria;
                      «        Generic Residential Infinite Volatile Soil Inhalation Criteria (VS1C) for
                              Ambient Air;
                      •        Generic Residential finite Volatile Soil Inhalation Criteria (VS1C) for
                              Ambient Air;
                      »        Groundwater Contact Protection Criteria; and
                      •        Soil Saturation Concentration Screening Levels.

               As discussed earlier in Section 6.1.1; Michigan's Generic Soil Criteria Protective or"
               Drinking  Water arc considered inappropriate requirements because Michigan's Generic
               Residential Drinking Water Criteria were determined to be inappropriate (because there
               is an existing institutional control in place (Municipal Ordinance 65 H and the L;.S. EPA
               has proposed additional deed restrictions to restrict groundwater use)

11.2.3          Air Regulations

               The Clean Air  Act provides primary and secondary air quality standards to protect
               human health from known or anticipated adverse effects of pollutants.  The Michigan
               Air Pollution Control Act (Part 55 of the' Michigan Natural Resources and
               Environmental Protection Act, 1994 PA  451. &* amended, and associated administrative
               rules) contains contaminant-specific regulations that pertain to allowable emissions or"
               pollutants from various air containment source categories and processes. These
               requirements arc applicable to the selected remedy because the SVE treatment system
               that will be used for TCE removal in unsaturated soils will produce V'OC emissions.
               The SVE off-gas will be monitored on a monthly basis to ensure compliance with state
               and federal permitting and emission requirements.

11.2.4          Waste Mauagement and Disposal Regulations

               Part  115 of NREPA, 1994 PA 451. as amended, and its substantive administrative rules
               (formerly the Solid Waste Management Act) is an ARAR for the selected remedies for
               activities associated with the  disposal of solid waste (i.e.. nonhaiardous soils, air stripper
               materials). Part 111 of NREPA, as amended and its administrative rules (formerly  the
               Michigan Hazardous Waste Management Act) is an ARAR for the selected remedies for
               activities associated with the  disposal of hazardous waste (i.e., characteristically

-------
                                              43

               ha2ardous soils).

11.2.5          Transportation ARARs

               Michigan Compiled Laws Annotated, Section 257.722, contains the rules governing the
               rc-Juetion of maximum axle loads during the period of March, April and Ma> (i e frost
               laws). This is applicable for the soil and groundwater remedies due to the potential
               transport of heavy materials or equipment.

11.2.6          Construction ARARs

               Part 91  of NREPA, as amended, and associated administrative rules (formerly the Soil
               Erosion and Sedimentation Control Act) is also an  ARAR for the selected remedies lor
               any earth moving activities

11.3   Cost Effectiveness

       The selected remedies provide overall effectiveness proportionate to their costs. The estimated
       costs associated with the selected remedies are:

                                              Soil Alternative 3      ("Sroiindwatpr Alternative ?

       Capital Cost                                S 145,200             $  40,600
       O&M  Cost (Net Present Worth)            $	(L            S 2id. 100
       Total   Cost (Net Present Worth)            S 145,200             S 250,700

       Soil Alternative 3 is considered cost-effective because for a moderate cost, soil contamination i»
       removed from the property, resolving both direct contact and potential leaching issues.  The N\,
       Action Alternative, Soil Alternative 1, would have no cost  and be protective of human health
       based solely on contact with soils under the current industrial land use. If land use would
       change, the No  Action Alternative would not provide sufficient protection for possible future site
       residents. In addition, Soil Alternative !  would not stop the leaching of contaminants to
       groundwater and is therefore not a protective solution.  Soil Alternative 2 would be less costK
       than Soil Alternative 3. but Soil Alternative 2 relies on O£M to maintain the protcctivencss of
       the asphalt cap. The asphalt cap would also be less effective and less permanent than direct
       removal of soils, and could limit future uses of the property

       Groundwater Alternative 2 is considered  cost-effective because it relies on source-control to
       resolve the movement of contaminants into groundwater. Monitored natural attenuation will
       then be used to  v.atch tht residual contaminants disperse and  dilute.  Groundwater Alternative .
       has no cost, but without monitoring and a documented  natural attenuation approach (that
       includes contingency plans for follow-up action), there would be no way to determine if and
       when the groundwater would be restored  to its beneficial use  and when GSI criteria have been
       achieved. Groundwater Alternative 3 is more costly than Groundwater Alternative 2, and would
       actively clean the aquifer that is currently contaminated. This active groundwater remediation
       would allow chemical-specific A'RARs to be met sooner. However, the increased cos; of the
       extraction and treatment system would not be as cost-effective because of the  large amount of

-------
                                              44

       lake water that would likely be inadvertently pumped and the inherent difficulties associated
       with pumping from a fractured bedrock environment where the hydrogcologv is too complex cc
       model.

       The selected remedies for soil and grcundwater, Soil Alternative 3 and Groundwater Alternative
       2, afford overall effectiveness when measured against CERCLA Section 121 criteria and the
       NCP's nine criteria evaluation, and their costs are proportionate to the protection lhat will be
       achieved.

11.4    Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
       Recovery Technologies to the Maximum Extent Practicable

       The selected remedies represent the maximum extent to which permanent solutions and
       treatment technologies can be used in a cost-effective manner at the Petoskey Municipal VVeil
       Field Site. The remedies permanently remove contaminants from the natural environment in tr.e
       following manner:

       •      TCE will be extracted from unsaturated soils (at the northwest corner of the PMC
              facility) by the operation of a SVE system.  Extracted vapors will be treated using carbon
              adsorption.  Spent carbon would be sent for regeneration to destroy VOCs and allow
              repeated use of the carbon

       •      Natural attenuation of residual groundwater contamination (after removal of the
              contaminant source from site soils) is expected to involve dilution, dispersion, and (to a
              limited extent) microbial anaerobic and aerobic dechlorination. However, because of the
              proximity of the site to Lake Michigan, it is likely that little TCE fully degrades before
              discharge to surface water.
       Because of the relatively low concentrations of contaminants in site soils, treatment is not a c<.
       effective approach for addressing contamination at the Petoskey site  No principal threat wastes
       have been identified at the site  Because the soils represent a low-level threat, containment (in
       tins case, excavation with off-site disposal in a permitted landfill) is an appropriate response to
       the contaminant levels present at the site and is consistent with the recommendations of the NCR

       Natural attenuation of the contaminant plume, combined with the removal of the contamination
       at the PMC facility (by SVE and excavation), environmental monitoring, and institutional
       conn-ols (deed restrictions) to prohibit use of contaminated groundwater  will provide the mcs:
       permanent solution practicable, proportionate to cost.

11.5   Preference for Treatment as a Principal Element

       The selected alternative for PMC soils, Soil Alternative 3, utilizes SVE to remove TCE from
       deep, unsaturated soils. Extracted vapors will be treated using carbon adsorption, with spent
       carbon regenerated to destroy collected VOCs.

       Natural attenuation of residual groundwater contamination (after removal of the contaminant
       source from site soils) is expected to involve dilution, dispersion, and (to a limited extent)

-------
                                             45

       microbial anaerobic and aerobic dechlorination. However, because of the proximity of the site to
       Lake Michigan, it is likely that little TCE fully degrades before discharge to surface water.
12.0   DOCUMENTATION OF SIGNIFICANT CHANGES

U.S. EPA has reviewed all written and oral comments submitted during the public comment period.
Upon review of these comments, it was determined that no significant changes to the remedy, as it was
originally identified in the Proposed Plan, were necessary.

-------
                                                                   FIGURES
Figure 1:     Northwest Michigan Map - Showing General Site Location




Figure 2:     General Site Map Showing Site Features and Location of Lake Michigan




Figure 3:     Figure Showing Exceedances of Chemical-Specific Soil ARARs




Figure 4:     Figure Showing Exceedances of Chemical-Specific Groundwater ARARs




Figure 5:     Soil Alternative 2 - Figure Showing Proposed Response Area




Figure 6:     Soil Alternative 3 - Figure Showing Proposed Response Area




Figure 7:     Groundwater Alternative 2 - Figure Showing Proposed Response Area




Figure 8:     Groundwater Alternative 3 - Figure Showing Proposed Response Area

-------
        SITE LOCATION

                               1/2
SCALc  1:24000
      0
                                                                                      MILE
                    1000
                                  1000   ZOOO    300O    4000    5000    5000  7000 FEET
                                         SCALE: 1"  = 2.000'
SOURCE; MC3IREO FROM USCS.
      HA,
-------
SPCT-S1TELAYO.DWC - 09/21/98 - RAO - OAA-02113
                   LAKE MICHIGAN
                           Little Traverse Bay
            ~ INGAU.S
        I x—x  I,
      MUNICIPAL
(  )| JWELL AND
V^yU, WATER
  _  I PUMP
   1  IHOUSE
                                                                        PETOSKEY
                                                                      MANUFACTURING
                                                                        COMPANY
                                                                                                  PETOSKEY MANUFACTURING COMPANY SITE
                                                                                                            PETOSKEY, MICHIGAN
                           LEGEND

                               	 SHORELINE
                                                                                                        FIGURE 2
                                                                                                   SITE AREA LAYOUT
                                                               75'     0      75     150
                                                                   III       |
                                                                  SCALE:  1" =  150'
                                                                                                     Tetra  Tech  EM  Inc.
OURCE: MODIFIED FROM MALCOLM PRUNE 1998 AND WW ENGINEERING AND SCIENCE 1992

-------
  - 09/21/M - KAO .. OAA-MIUM
                                                                                                           LEGEND

                                                                                                         Concenlrotion Exceeds
                                                                                                         Resldenllol Drinking
                                                                                                         Water Protection Criterion

                                                                                                         Concentration Exceeds
                                                                                                         GSI Criterion

                                                                                                         Concentration Exceeds
                                                                                                         Residential Direct
                                                                                                         Contact Criterion

                                                                                                         Concentration Exceeds  '
                                                                                                         Both Residential Drinking
                                                                                                         Water Protection and
                                                                                                         GSI Criteria
SB-7
Zlne
2-6']
-"-96:6]
                          SS-
LEGEND
                         SB-3
    9  Phase II Soil Boring
SB-202S  _  Malcolm Pirnle (1995)

 SB-2® Phase 1 Soil Boring
        -  EDER  Associates (1992)

 ss-2» Phase I Surface soil
       sampling location
        -  EDER  Associates
       (Surface soil samples
       collected 0-1'  bgs)

    uoantD rnoM UALCOLU ftmif IMS
SB-202S
Chromium
Mercury
Silver
Zinc
0-2'
--. 6.0-
: 0.2.1.
.2.0 B:
1 i?.67H
                                                                                                                        Concenlrotion In mg/kg
                                                                                                                          9 » Analyte present In
                                                                                                                             m",nn ' tilank
                                                                                                                          J m t*'*'rtoted voltl*

                                                                                                                         nol^« conc*ntrn*lof»
                                                                                                                          '*f Ihwi rlo'Kiifp ct\\*r\w
                                                                                                                              itrollon imbnown
SB-204S
Chromium
TrichloroethBn*
1J-13'
~-Z^1-Z-
\'^ls.
                                  SS-2
                                  Chromium
                                  Prwoonlhr«B«
                                  Zinc
     PETOSKEY
MANUFACTURING
     COMPANY
                                                                                                         SS-4
                                                                                                               Leod
                                                                                                         Silver
                                                                                                         Zinc
	 ^^^-SO-j
ITITTniTnTrliT
                                                                                                                 .:•:.:..-.:- . v.:.0;31
                                  SB-3
                                  Chroffllum
                                  Zinc
                                                6-7'
                                              :TTr5.4-
                                                                                                                                ®ss-«
                                                  Lake Strett
                                                                                                            PETOSKEY MAHUFACTUPING COMPANY SITI
                                                                                                                   PETOSKEY, MICHIGAN
                                                                                                                       HQURE 3
                                                                                                                 SOIL  AMMYTICAL DATA
                                                                                                           EXCEEDING MDEO  CLEANUP CRITERIA
                                                                                                              Tetre  Tech  EM  inc.

-------
LAKE MICHIGAN
Little Traverse Bay 	 __ • • •
Ingalls Ingalls M
Well Well Dup CD7?"t
	 . • • bis N-X'.S'JQx —
-" Thollium (IIJttttBI
\
COP-1
Y

JThalium


I INGALLS
-v | 1 MUNICIPAL ^F
\l 11 »»Jt-t 1 A I lit '***•
^ \\ J WELL AND =-T
II r'uiA-rr-D "«Ol
	 / 1 — 1 i WA TtR 	
r—, 1 PUMP
| HOUSE JSP.
.y. _i 1 COP
COP— 2 t Chromium xv3S
j, ji ThaHlum i)}
"*"
C0P-; UW-2051
'•'."•^W^ Thallum HHB-Hltf



PS-CO PS-
TC£ llllllttLIJJJll
1 |Sllver F^^^F^'
| ^«-o
g PS-OO PS-00
bis X\s-».»s S\\\\>

West Lake Street
•^^••^••••M -I.P— 1 . 	 — 1 1 - - . 1
X
COP-4__^ —
-^ 	 * F
PS- 11
•'•M6-'


' — J 4 4
'S-1C6M. pS-106 iror
bis .\\-$-,5;' Mar
• 	
COP-J
Iron \x^\\">ftK''
ium &|4Bf VACANI Mongonese SSS'Wfc
3-11
-2
Thallium SN\V'P09'~

COP-5
SJj. Antimony -S.^^-'
JO Thollium ifrlft

Mtf-2050
!|)|(K^W PS-JOS
•^
PS-C-^.



CO Oup i 	

FRATERNA
ORDER OF
EAGLES
Dup
*:»
KCOP-5
PS-105S PS-105D
ron ^Y.V'SN'
Lead Illlllfn-!' ' —
Thallium — IIIIW)II$I

-, \
PC— 4/f/lJ
L TCE >^^Nft
ki. ' •.'•vSVlbSA'
wo , *\\ >'x\"
VACANT PS-4/
LOT 1 	 ~
UW 11
HI fw £,\
TCE Hill
	 JO£_
>v ™l"~
I ps~'2 ^><(
LEGEND
K MONITORING WELL
•$• MONITORING WELL CLUSTER
•L> PUMPING TEST WELL
® SURFACE WATER LEVEL
MEASUREMENT LOCATION
ffl ABANDONED MONITORING WELL
REPLACED BY PS-1R/13
	 SHORELINE
SOURCE: M^ftp FROM MALCOLM PIRNC 1998
CONCENTF
NXN;^X RESIDENT!
WATER CF
_:-...-_: CONCENTF
-•-'-" GSI CRITE
CONCENTF
Illllllll RESIDENT!
AND GSI
MW-204S
TCE 1 fi
ThalBum • J JE
NATION EXCEEDS
AL DRINKING
(ITERION
?ATION EXCEEDS
RION
NATION EXCEEDS BOTH
AL DRINKING WATER 60
CRITERIA b
COP -4
    PS-WA 35
 NOTES

 All concentrations shown in ju.g/L
 B -  Analyte present in method  blank
 J -  Estimated value
— = Anolyte  concentration is lower than
     cleanup criterion or concentration unknown
                            ABBREVIATIONS

                            COP = City of Petoskey
                            bis = bis (2-Ethylhexyl) phthalate
                            TCE = Trichloroethene
                            VC = Vinyl chloride
        PETOSKEY
      MANUFACTURING
        COMPANY
                 bis
                    PS-1R/1J
                             Lake Street
      120'
                                  PS-1P./13
                 PETOSKEY MANUFACTURING  COMPANY SITE
                          PETOSKEY. MICHIGAN
               FIGURE 4
  GROUNDWATER  ANALYTICAL  DATA
EXCEEDING  MDEQ  CLEANUP CRITERIA
QTetra  Tech  EM  Inc.

-------
Sm-SOlD»0 - QO/H/M - KAO -. OAA-021HW
                                                              Quintan Streit
                                •^?*-sv. ..;., •;;.-.-/.  ;/.•-. -:, ••:• "•>,x: v. •;•••..• ,-;..•   ,  •.,.->•. :•   .:- .;• ;. .•,:>.• •-.-•: -    . •

                    	#;^;>'^:'^

                    '••>••'• .•'; .-'•'.'•. '''•••'••','.• •'.•'JL,'- ''"• //'•'''.'''.  '.•; ''• '•'•• ••' ' , ''•'•'.•,- • >'/. '.'•'_• ;..'•• •  (ggs^-iv ,'.'//,.- /.''//.••, .•','/,'.•'AtSrA-.- '.kk-intk
                    &^e9 '•.-,-', •''••'• .'''/•?&'?\ f'^^s's^l:'' '•'  '•'''''/' ''•'""''• '•'  -."•'   '  , I	  —^"^,.-'vY
                    »'•;••>>,.••;'••;;.-;',. • •.'* 'ffifoft--<
-------
SPET-SOIL.OWC - 09/21/98 - RAO - OAA-OZ11202
                                                            Quintan Street
                                  SB-
                   SB-8®
                               ®S8-S
                                      00  1
                                                                             ass-3
                              SB-201S*
                       SB- 7
                              SB-2
       LEGEND

     «  Phase II Soil Boring     s^
 SB-202S  _ Malcolm Pirnie (1995)

  SB-Z®  Phase I Soil Boring
         - EDER  Associates (1992)

  ss-2®  Phase I Surface  soil
        sampling  location
         - EDER  Associates
T®
  SB-4
                                                                                                            SB-202S
                                              9SB-203D
                                                    SB-204S*
                                                                         PETOSKEY
                                                                     MANUFACTURING
                                                                          COMPANY
                                                                                                                            ®ss-*
 L      I  Area of 5- foot excavation and
          soil vapor extraction
 i - 1  Area to be excavated  5 feet
 L - '  below ground surface
SOURCE: MOOIFIEILfBpM MALCOIM PIRNIE 1098
      Lofce  Street
15'     0     15'     30'
               *~^—^am
               mum
    SCALE:  1" = 30'
                                                                                                          PETOSKEY MANUFACTURING COMPANY SITE
                                                                                                                 PETOSKEY, MICHIGAN
                                                                     FIGURE 6
                                                             APPROXIMATE EXTENT OF SOIL
                                                          EXCAVATION FOR SOIL ALTERNATIVE  3

-------
»fi-owATC».i)wa - 09/tt/»e - HAO - OAA-OJIH
         LAKE  MICHIGAN
          Little Traverse Bay
r~    _|INGALLS
I  .^-sl   MUNICIPAL
i(   ) JWELL AND
I \_y U | WATER
        I PUMP
        I HOUSE
10
                                        c0P-4
                               COP- 3
                                                                                    PS-10A
                                                 VACANT
                                                  LOT
   COP-/
    *
D
                               O»PS-n
                   COP-2
                                                                  CUT
                                                               RCOP-S
                                              PS-105
                                              FRATERNAL
                                              ORDER OF
                                              EAGLES
                                                                                        PS-t
                        PS-D

                         PS-DO PS-DD Dup
                                                      VACANT
                                                       LOT
                                                          PS-4/104*
                    Vest Lake Street
                                                 PS- 12
  LEGEND

      «  MONITORING  WELL

      •
J



UW-20JD
PETOSKEY
MANUFACTURING
COMPANY





                                                                                                                 (?uin/an Street
                                                                                                               Lake Street
                                                                                        PS- A
                                                                                                   PS-6
                                                                                                                   PS-IR/tJ
                                                                                                                          •
                                                             60"     0      60'     120'

                                                                 SCALE: 1" •= 1201
                                                                                                  PETOSKEY MANUFACTURING COMPANY SITE
                                                                                                           PETOSKEY,'MICHIGAN
                                                                                                               FIGURE 7
                                                                                                 LOCATIONS  OF ADDITIONAL  MONITORING
                                                                                                WELLS  FOR GROUNDWATER ALTERNATIVE 2
                                                                                                     Tetra  Tech  EM  Inc.

-------
SPET-CWATER.OWC - 09/21/98 - RAO - OAA-0211202
         LAKE MICHIGAN
         Little Traverse Bay
                                         cOP-4
                                                                                                                         \
                               COP-3
                                                     P5-W61&
           00
	j INGALLS
I  (I MUNICIPAL
   WELL AND
   WATER
   PUMP
  I HOUSE
                                                                                      PS- 10A &
                                                  VACANT
                                                   LOT
                               Q1& PS- 11
                   COP-2
               MW-20S 
-------
                                              TABLE 1
Chemicals of Potential Concern in Soil and Groundwater

-------
TABLE 1
CHEMICALS OF POTENTIAL CONCERN

CHEMICAL
INORGANICS
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
VIercury
Nickel
Selenium
Silver
Pha Ilium
Vanadium
Zinc
OTHER
Cvanide
PETOSKEY MANUFACTURING SITE
GROUNDWATER
ND
X
X
X
X
X
ND
X
X
ND
X
X
X
ND
X
X
'
ND
SHALLOW SOIL
X
X
•
X
X
•
X
X
•
X
X
X
X
X
•
X

x
SUBSURFACE
SOIL
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA '
NA
NA
NA
NA
NA
NA

NA
ALL SOILS
•
-X
«
X
X
•
X
. x

X
X
X
X
X
*
X

x
ND : Not Detected
• :  Detected hut not chosen as a chemical of potential concern
X : Selected as .1 chemical ot"potential concern
NA  Not Applicable

-------
TABLE 1
CHEMICALS OF POTENTIAL CONCERN

CHEMICAL

VOLATILE ORGANICS
Acetone
1,2-Dichioroethene (total)
ithylbenzene
vlethylene Chloride
retrachloroethene
Toluene
rrichloroethene
Vinyl Chloride
Xylenes (total)
SEMI-VOLATILE ORGANICS
Acenapthene
Anthracene
3enzo[a]anthracen<:
3enzo[a]pyrene
3enzo(b]tluorunthene
3enzo[g,h,i)perylene
bis(2-Ethylhexyl)phthalato
3utyl benzylphthalate
Carbazole
Chrysene
Di-a-butylphthalate
Di-n-ociyl phthalate
!>ibenz[a,h]amhracen<:
Dtbenzoluran
rluoranih<:ne
rluorenc
[ndeno[ 1 .2 , 3-oJ Jpyrene
Phenanthrene
Pyrene
PESTlCIDES/PCBs
Aldrin
4,4'-DDD
4.4'-DDE
•U'-DOT
indosutfun I
indosultjn 0
PCBs
PETOSKEY MANUFACTURING SITE
GROUNDWATER

ND
X
ND
*
• •
ND
X
X
ND

.
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
SHALLOW SOIL

X
X
" X
X
X
X
X
ND
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
SUBSURFACE
SOIL
X
X
X
X
X
X
X
ND
X

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA

ALL SOILS

X
X
X
X
X
X
X
ND
X

X
X
X
X
X
X
X
X
X
X
X
•
X
X
X
X
X
X
X

X
.
X
X
.
.
•

-------
                                             TABLE 2
Quantitative Summary of Site Risks for Current and
              Future Risk Scenarios

-------
TABLE 2
SUMMARY OF HAZARD INDICES AND CANCER
PETOSKEY MANUFACTURING SITE
EXPOSURE POPULATION
AND PATHWAY
CURRENT SCENARIO
ADOLESCENT TRESPASSER
Ingestion of Shallow Soil
Dermal Contact with Shallow Soil
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
PMC WORKER
Ingestion of Shallow Soil
Dermal Contact with Shallow Soil •
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
FUTURE SCENARIO
RESIDENT ADULT (GENERIC RESIDENTIAL USE)
Ingestion of All Soils
Dermal Contact with All Soils
Ingestion of Ground water
Dermal Contact with Groundwater
Inhalation of Chemicals Volatilized from Groundwater
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
RESIDENT CHILD (GENERIC RESIDENTIAL USE)
Ingestion of All Soils
Dermal Contact with All Soils
Ingestion of Groundwater
Dermal Contact with Groundwater
Inhalation of Chemicals Volatilized from Groundwater
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
RESIDENT ADULT (LIMITED RESIDENTIAL USE)
Ingestion of Shallow Soil
Dermal Contact with Shallow Soil
Inhalation of Chemicals Intruding through Basement
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
RESIDENT CHILD (LIMITED RESIDENTIAL USE)
Ingestion of Shallow Soil
Dermal Contact with Shallow Soil
Inhalation of Chemicals Intruding through Basement
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
RESIDENT ADULT (LIMITED RESIDENTIAL USE)
Ingestion of Shallow Soil
Dermal Contact with Shallow Soil
Inhalation of Chemicals Intruding through Foundation
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
RISKS
HAZARD
INDEX


3E-02
5E-02
8E-02

2E-02
5E-02
7E-02


8E-02
IE-01
8E-01
2E-02

1E+00

7E-01
IE-01
2E-KX)
JE-02

JE+00

IE-01
2E-01
3E-09
4E-
-------
                                   TABLE  2
            SUMMARY OF HAZARD INDICES AND CANCER RISKS
                    PETOSKEY MANUFACTURING SITE
EXPOSURE POPULATION
AND PATHWAY
RESIDENT CHILD (LIMITED RESIDENTIAL USE)
Ingestion of Shallow Soil
Dermal Contact with Shallow Soil
Inhalation of Chemicals Intruding through Foundation
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
CONSTRUCTION WORKER
Ingestion of All Soils
Dermal Contact with All Soils
Inhalation of Respirable Particulates
TOTAL PATHWAY HAZARD INDEX/CANCER RISK:
HAZARD
INDEX

lE-t-00
4E-OI
7E-09
2E+00

9E-02
2E-02
5E-03
1E-01
CANCER
RISK

4E-05
3E-06
2E-IO
4E-05

6E-07
5E-08
2E-08
6E-07
Based on 30 year exposure, 6 years child exposure plus 24 years adult exposure.

-------
                                                  TABLE 3
Table of ARARs for Selected Alternatives (Soil Alternative 3T
              Groundwater Alternative 2)

-------
                                                        TABLE 3-A

                                  SUMMARY OF CHEMICAL-SPECIFIC ARARs FOR SOIL
                                      PETOSKEY MANUFACTURING COMPANY SITE
Description
Prerequisite for ARAR
Requirement
Citation
Comments
State Requirement
Determination of cleanup criteria
Facility requiring remedial action
Cleanup category requirements and
remedial action criteria
Land-use requirements for facilities that
do not meet residential cleanup goals
NREPA, Part 201 (1994 PA
4 5 1, as amended).
Environmental Response,
Section 20 120a'
NREPA, Part 201 (1994 PA
51, as amended),
Environmental Response,
Section 201 20b'
Soil cleanup levels are applicable
(substantive requirements) to the
selected cleanup. Soil Alternative #3.
Notes:

ARAR   =
NREPA  =
PA
Applicable or relevant and appropriate requirement
Natural Resources and Environmental Protection Act
Public Act
(1)
Includes the substantive requirements of the associated administrative rules.
F:\USER\TVANDONS\PE'nNEWROD\AJ>P-A TV.WPD
                                            Table 3 - Page 1

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                                                TABLE 3-B
                               SUMMARY OF ACTION-SPECIFIC ARARs FOR SOIL
                                PETOSKEY MANUFACTURING COMPANY SITE
Description
Prerequisite for ARAR
Requirement
Citation
Comments
Federal Requirements
Excavation
New air emissions sources
Fugitive dust emissions from
excavation activities
On-site SVE or air stripper;
establishes air emissions limits based
on modeling
Control activity to minimize particular
matter emissions
NAAQS specify the maximum
concentrations of federally regulated
air pollutants (such as S02, paniculate
matter [PM10], N02, CO, ozone, and
lead) in an area resulting from all
sources of these pollutants; no new
construction or modification of facility
structure, or installation may emit an
amount of any criteria pollutant that
will interfere with the attainment or
maintenance of a NAAQS (see 40
CFR, Part 5 1.60)
40 CFR, Part 51
Federal Clean Air Act, 42
USC 1857, 40 CFR, Part 50;
^lAAQS regulations
Substantive requirements are applicable
to the selected soil alternative (Soil
Alternative #3).
Substantive requirements are applicable
to operation of SVE unit. However,
emissions are expected to be below
regulated levels.
State Requirements
Excavation
Maintenance or undertaking of a land
use or earth change
Excavation of contaminated soils
Excavation of contaminated soils
Excavation, or other activity which
disturbs site soils
Provide for control of soil erosion and
prevent sedimentation of surface watei
Provide for control of fugitive dust or
air emissions that would affect human
health and the environment
Requirements for characterization and
handling of hazardous waste
"Due care" and general remedial /
engineering practice requirements
Part 91 of the NREPA (1972
PA 347), Soil Erosion and
Sedimentation Control Act '
Part S 5 of the NREPA ( 1 965
PA 348), Air Pollution Act '
Part 111 of the NREPA (1 994
PA 451, as amended),
formerly 1979 PA 64,
Hazardous Waste
Management Act '
Part 20 1 of the NREPA, (1994
PA 451, as amended),
Environmental Response
Substantive requirements are applicable
to selected soil alternative, which •
includes excavation.
Substantive requirements are applicable
to selected soil alternative, which
includes excavation.
Substantive requirements are applicable
to selected soil alternative, which
includes excavation.

F:\USER\TVANDONS\PET\NEWROD\APP-A TV.WTD
Table 3 - Page 2

-------
                                            TABLE 3-B (Continued)
                               SUMMARY OF ACTION-SPECIFIC ARARs FOR SOIL
                                 PETOSKEY MANUFACTURING COMPANY SITE
Description
On-site waste piles storage
Off-site disposal of soil
Transport of heavy materials or
equipment
Sedimentation of surface waters
Prerequisite for ARAR
Storage of nonhazardous waste in on
site piles
Disposal of excavated soils at a
RCRA hazardous or nonhazardous
waste landfill
Disposal of excavated soils at a
ICRA hazardous or nonhazardous
waste landfill
Disposal of excavated soils at a
ICRA hazardous or nonhazardous
waste landfill
Transport of excavated soils and
equipment
Transport of excavated soils and
equipment
"ransport of excavated soils and
equipment
iarth changing activities more than 1
acre in area or within 500 feet of a
ake or stream
Requirement
Characterize nature of wastes to be
accumulated in piles
Requirements for relocation of
sxcavated soils
Requirements for disposal of excavate
soils
Requirements for disposal of excavate
soils
Requirements for maximum axle load;
during frost periods
General transportation requirements
General transportation requirements
mplement appropriate erosion and
edimentation control measures
Citation
Partll5oftheNR£PA(1994
'A 451, as amended),
formerly 1978 PA 641, Solid
Waste Management Act '
Part 201 oftheNREPA, (199'
PA 45 1 , as amended),
Environmental Response,
Section 20 120c'
Part 1 1 1 of the NREPA (1994
'A 451, as amended),
formerly 1979 PA 64,
lazardous Waste
Management Act '
Part 115 of the NREPA (1994
'A 45 1, as amended),
formerly 1978 PA 64 1, Solid
Waste Management Act '
Compiled Laws Annotated
Section 257.722 '
Part 111 of the NREPA ( 1994
'A 451, as amended),
ormerly 1979 PA 64,
Hazardous Waste
Management Act '
Part 115 of the NREPA (1994
'A 451, as amended),
ormerly 1978 PA 641, Solid
Waste Management Act '
Part 91 of the NREPA (1972
'A 347), Soil Erosion and
edimentation Control Act '
Comments
Substantive requirements are applicable
to selected soil alternative, which
includes excavation and could include
the temporary stockpile of soil.
Substantive requirements are applicable
(o selected soil alternative, which
includes excavation and off-site
disposal.
Substantive requirements are applicable
to selected soil alternative, which
includes excavation and off-site
disposal.
Substantive requirements are applicable
to selected soil alternative, which
includes excavation and off-site
disposal.
Substantive requirements are applicable
o transport of excavated soils and heav
equipment.
Substantive requirements are applicable
o transport of excavated soils and heav
equipment.
Substantive requirements are applicable
o transport of excavated soils and heav
equipment.
Substantive requirements are applicable
o selected soil alternative, which
ncludes excavation.
F:\USER\TVANDONS\PET\NEWROD\APP-A TV.WPD
Table 3 - Page 3

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                                                    TABLE 3-B (Continued)

                                     SUMMARY OF ACTION-SPECIFIC ARARs FOR SOIL
                                       PETOSKEY MANUFACTURING COMPANY SITE

Notes:

40 CFR      =  Title 40 of the Code of Federal Regulations
ARAR      =  Applicable or relevant and appropriate requirement
CO         =  Carbon monoxide
NAAQS     =  National Primary and Secondary Ambient Air Quality Standards
NO,        =  Nitrogen dioxide
S02         =  Sulfur dioxide
USC        =  United States Code

(})         Includes the substantive requirements of the associated administrative rules.
F:\USER\TVANDONS\PET\NEWROD\APP-A TV.WPD
                                                         Table 3 - Jjace 4

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                                              TAlME 3-C
                       SUMMARY OF CHEMICAL-SPECIFIC ARARs FOR GROUNDWATER
                               PETOSKEY MANUFACTURING COMPANY SITE
Description | Prerequisite for ARAR
Requirement
Citation
Comments
-ederaJ Requirements
MCLs
Water quality criteria
Actual or potential drinking water
source
Discharge to surface water used by
aquatic organisms and humans;
luman consumption of aquatic
organisms
insure that chemical constituents do no
exceed water quality standards
Surface water must not exceed
numerical criteria for certain indicator
chemicals and other water quality-
's lated standards
Safe Drinking Water Act (42
USC, 300); 40 CFR, Part 141
Clean Water Act (33 USC
1251)
tfCLs are relevant and appropriate if
groundwater around the facility is use<
or potentially used for drinking water
or designated for public or private
water use
Water quality criteria are relevant and
appropriate because contaminated
groundwater discharges to surface
water
State Requirements
linking water source
Groundwaler discharge to surface
water
Groundwater quality
Groundwater used or potentially
used for drinking water
Discharge to surface water used by
aquatic organisms and humans
Discharge to surface water used by
aquatic organisms and humans
Cleanup of contaminated
groundwater
Acceptable concentrations of chemical
constituents in groundwater must not
exceed water quality standards
Ensure that chemical constituents do no
exceed water quality standards
Ensure that chemical constituents do no
exceed water quality standards
Environmental response
Michigan Safe Drinking Wate
Act (Act 399)'
Part 31 of the NREPA (1994
PA 451, as amended),
formerly 1929 PA 245, Water
Resources Protection1
Part 201 of the NREPA (1994
PA 451, as amended),
Environmental Response'
Part 20 1 of the NREPA ( 1 994
?A 451, as amended),
Environmental Response1
Act 399 is relevant and appropriate if
promulgated water quality standards
are more stringent than federal MCLs
Substantive requirements are
applicable because contaminated
groundwater discharges to surface
water
Substantive requirements are
applicable because contaminated
groundwater discharges to surface
water
The substantive requirements of Part
201 are applicable requirements for lh<
selected groundwater alternative.
However, U.S. EPA and the MDEQ
lave determined that Michigan's
generic drinkine water criteria
(residential and industrial) are not
applicable ot relevant requirements for
the selected groundwater alternative.
F.\USER\TVANDONS\PET\NEWROO\APP-A TV.WPD
Table 3 - Page 5

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                                                  TABLE 3-C (Continued)

                            SUMMARY OF CHEMICAL-SPECIFIC ARARs FOR GROUNDWATER
                                        PETOSKEY MANUFACTURING COMPANY
Notes:
40CFR  =  Title 40 ofthe Code of Federal Regulations
ARAR  =  Applicable or relevant and appropriate requirement
MCL   =  Maximum Contaminant Level
DSC    =  United States Code

(1)        Includes the substantive requirements of the associated administrative rules.
F \USER\TVANDONS\PET\NEWROD\APP-A_TV.WPD                       Table 3 - Page 6

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                                                                       TABLE 3-D

                                      SUMMARY OF ACTION-SPECIFIC ARARs FOR GROUND WATER
                                                PETOSKEY MANUFACTURING COMPANY SITE
  Description
     Prerequisite for ARAR
           Requirement
         Citation
            Comments
  Federal Requirements
 New air emissions sources
On-site air stripper, or soil treatmentjNAAQS
units; establishes limits for air
emissions based on modeling
        specify the maximum
concentrations of federally regulated ai
pollutants (such as SO2, participate
matter [PM10], N02, CO, ozone, and
lead) in an area resulting from all
sources of these pollutants; no new
construction or modification of facility,
structure, or installation may emit an
amount of any criteria pollutant that wil
interfere with the attainment or
maintenance of a NAAQS (see 40 CFR,
Part 51.60)
Federal Clean Air Act, 42
USC 1857, 40 CFR, Part 50;
NAAQS regulations
 Substantive requirements are
 applicable to treatment units with
 regulated emission levels.  ARAR
 would be applicable if a follow-up
 groundwater treatment system is
 required (i.e., pump and treat with air
 itripping).
 Point-source discharge to surface
 water
Surface water discharge of treated
effluent
Applicable federal water quality criteria
for the protection of aquatic life must be
complied with when environmental
factors being considered

Applicable federally approved state
water quality standards must be
complied with; standards may be in
addition to or more stringent than other
federal standards under CWA
CWA, 40 CFR, Part 122.44
Substantive requirements are
applicable to discharge of treated
groundwater to surface water.  ARAF
would be applicable if a follow-up
groundwater treatment system is
required (i.e., pump and treat with air
Stripping).
                                                              Discharge must be consistent with the
                                                               equiremcnts of the state's Water
                                                              Quality Management Plan approved by
                                                              IEPA
                                                                CWA, Section 208(b)
                                                           Substantive requirements are
                                                            ipplicable to discharge of treated
                                                            ;roundwater to surface water.   ARAF
                                                           .vould be applicable if a follow-up
                                                           groundwater treatment system is
                                                            equired (i.e., pump and treat with air
                                                           stripping).
F:\USER\TVANDONSVPET\NEWROD\APP-A TV.WTD
                                     Table 3 - Page 7

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                                          TABLE 3-D (Continued)
                         SUMMARY OF ACTION-SPECIFIC ARARs FOR GROUND WATER
                               PETOSKEY MANUFACTURING COMPANY SITE
Description

Point-source discharge to surface
water (continued)
Prerequisite for ARAR

Surface water discharge affecting
waters outside of the state
Surface water discharge of treated
affluent
Requirement
Use of economically achievable BAT is
required to control toxic and
nonconventional pollutants; use of best
conventional pollutant control
technology is required to control
conventional pollutants; technology-
based limitations may be determined on
case-by-case basis
Discharge must conform to applicable
water quality requirements when
discharge affects state other than the
certifying state
Discharge limitations must be
established for all toxic pollutants that
are or may be discharged at levels
greater than those that can be achieved
by technology-based standards
Comply with additional substantive
requirements such as
• Duty to mitigate any adverse
effects on any discharge and
• Proper operation and maintenance
of treatment systems
Citation
40CFR,Partl22(a)
WCFR,Partl22.44(e)
40CFR,Partl22.44(e)
40 CFR, Part 122.41(1)
Comments
Substantive requirements are
applicable to discharge of treated
groundwater to surface water. ARAf
would be applicable if a follow-up
groundwater treatment system is
required (i.e., pump and treat with air
stripping).
Substantive requirements are
applicable to discharge of treated
groundwater to surface water. ARAf
would be applicable if a follow-up
groundwater treatment system is
required (i.e., pump and treat with air
stripping).
Substantive requirements are
applicable to discharge of treated
groundwater to surface water. ARAf
would be applicable if a follow-up
jroundwater treatment system is
^quired (i.e., pump and treat with air
stripping).
Substantive requirements are
applicable to the discharge of treated
jroundwater to surface water. ARAJ
would be applicable if a follow-up
groundwater treatment system is
required (i.e., pump and treat with air
stripping).
F \USER\TVANDONS\PET\NEWRODVAPP-A TV.WPD
Table 3 - Page 8

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                                            TABLE 3-D (Continued)
                          SUMMARY OF ACTION-SPECIFIC ARARs FOR GROUND WATER
                                 PETOSKEY MANUFACTURING COMPANY SITE
Description

On-site treatment
Prerequisite for ARAR
Surface water discharge
Waste treatment unit generating air
emissions
Requirement
Develop and implement a BMP prograti
and incorporate measures that prevent
the release of toxic constituents to
surface waters; BMP program must
• Establish specific procedures for
the control of toxic and hazardous
pollutant spills;
• Include a prediction of direction,
rate of flow, and total quantity of
toxic pollutants where experience
indicates a reasonable potential for
equipment failure; and
• Ensure proper management of soli
and hazardous waste in accordance
with RCRA regulations
Control of air emissions from the
treatment unit
Citation
40 CFR, Parts 125. 100 and
104
40 CFR, Part 61
Comments
Substantive requirements are
applicable to discharge of treated
groundwater to surface water. ARA
would be applicable if a follow-up
jroundwater treatment system is
required (i.e., pump and treat with air
stripping).
Substantive requirements would be
applicable if a follow-up groundwater
treatment system is required (i.e.,
jump and treat with air stripping).
Jote that air emissions would likely tx
>elow levels requiring treatment befor
discharge.
State Requirements
Point source discharge to surface
water
Discharge of treated effluent to
surface water
Comply with Act 245 requirements to
jrotect waters of the state and Great
Lakes
Part31oftheNREPA(l994
PA 451, as amended),
formerly 1929 PA 245, Water
Resources Protection
Substantive requirements would be
aplicable to discharge of treated
»round water to surface water. ARAF
would be applicable if a follow-up
jroundwater treatment system is
required (i.e., pump and.treat with air
stripping).
F:VUSER\TVANDONS\PET\NEWT«.OD\APP-A TV.WPD
Table 3 - Page 9

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                                                               TABLE 3-D (Continued)

                                     SUMMARY OF ACTION-SPECIFIC ARARs FOR GROUNDWATER
                                               PETOSKEY MANUFACTURING COMPANY SITE
 Description
     Prerequisite for ARAR
           Requirement
         Citation
            Comments
 On-site treatment
Operation of an air stripper as part o
the groundwater remedies
 ;omply with air emission standards
Part55oftheNREPA(1994
 A 451, as amended),
brmerly 1965 PA 348, Air
 'Dilution Act'
Substantive requirements are
applicable to selected alternative if
operation of an air stripper is
ultimately required.  ARAR would be
applicable if a follow-up groundwater
treatment system is required (i.e.,
jump and treat with  air stripping).
                               Groundwater remediation
                              Comply with "due care" and general
                              engineering / remedial requirements
                                  'art 201 of the NREPA (1994
                                  'A 451, as amended),
                                 Environmental Response'
 retaliation of monitoring wells
Installation of monitoring wells as
part of the groundwater remedy
Requirements for permitting of drilling
associated with monitoring well
installation
 'art 625 of the NREPA (1969 Substantive requirements are aplicable
                                                                                               'A 315), Mineral Well Act1
                          o installation of monitoring wells as
                         part of the selected groundwater
                         remedy.
 Pransport of heavy materials or
 equipment
Transport of heavy materials and
Equipment
Requirements for maximum axle loads
during frost periods
Compiled Laws Annotated
Section 257.722'
Substantive requirements are
applicable to transport of heavy
materials and equipment
 On-site treatment
Construction of groundwater
treatment system
mplement soil erosion and sediment
control procedures
 'art 91 of the NREPA (1972
PA 347), Soil Erosion and
sedimentation Control Act'
Substantive requirements are
applicable to construction of an on-siu
 ;roundwater treatment unit.  ARAR
would be applicable if a follow-up
groundwater treatment system is
required (i.e., pump and treat with air
stripping).
                                'onstruction and operation of
                               groundwater treatment system
                               Requirements for characterization and
                               landling of hazardous waste
                                 'art 111 of the NREPA (1994
                                 PA 451, as amended),
                                 ormerly 1979 PA 64,
                                 Hazardous Waste
                                 Management Act'
                          ubstantive requirements are
                         applicable to construction and
                         operation of an on-site treatment unit.
                         ARAR would be applicable if a
                         bllow-up groundwater treatment
                         system is required (i.e.. pump and treal
                         with air stripping).
F-\USER\TVANDONS\PET\NEWHOD\APP-A TV.WPD
                                                                   Table 3 -Page 10

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                                                                 TABLE 3-D (Continued)

                                      SUMMARY OF ACTION-SPECIFIC ARARs FOR GROUNDWATER
                                                PETOSKEY MANUFACTURING COMPANY SITE
  Description
     Prerequisite for ARAR
           Requirement
         Citation
                 Comments
 Point source discharge to surface
  water
Discharge of treated effluent to
surface water
Prohibits direct or indirect discharge to
ground or surface waters of the state thafPA 451
are or may become injurious to the
environment or public health
 1art31oftheNREPA(1994
      , as amended),
pormerly 1929 PA 245,
Resources Protection, Part 6a (would
      Substantive requirements are
      applicable to discharge of treated
Water groundwater to surface water.  ARA
            be applicable if a follow-up
      groundwater treatment system is
      required (i.e., pump and treat with air
      stripping).
 Unpalatable flavor to food or fish;
 interfere with surface water use
 Taste and odor tainting surface watei Prevent concentrations
                               of taste- and odor-producing substances
                    in surface water part 31 of the NREP A (1994
                                   A 451, as amended),
                                  formerly 1929 PA 245,
                                  Resources. Protection '
                                                                                                 'art 4,
                                                                                                 R 323.1041-323.1117;
                                                                                                 Michigan Water Quality
                                                                                                  tandards
                          Substantive requirements may be
                          applicable to discharge of treated
                    Water groundwater to surface water.   ARAI
                          may be applicable if a follow-up
                          groundwater treatment system is
                          required (i.e., pump and treat with air
                          stripping).
 Acute toxicity of discharges
Acutely toxic surface water
'revent acutely toxic substances from
entering surface water
 art31oftheNREPA(1994
 A 451, as amended),
ormerly 1929 PA 245, Water
Resources Protection'

'art 4, R323.1057; Acute
'oxicity
       ubstantive requirements are
      applicable to discharge of treated
      groundwater to surface water.  ARAI
      would be applicable if a follow-up
       roundwater treatment system is
      required (i.e., pump and treat with air
      dipping).
 Chronic toxicity of discharges
 Chronically toxic surface water
 revent chronically toxic substances
 rom entering surface water
>art31oftheNREPA(I994
'A 451, as amended),
ormerly 1929 PA 245, Water
lesources Protection'

 art 4, R323.1057; Chronic
 oxicity
     Substantive requirements are
     applicable to discharge of treated
     groundwater to surface water.  ARAF
     .vould be applicable if a follow-up
     p-oundwater treatment system is
     equired (i.e., pump and treat with air
     stripping).
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                                     Table 3 - Page 11

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                                                               TABLE 3-D (Continued)

                                     SUMMARY OF ACTION-SPECIFIC ARARs FOR GROUNDWATER
                                               PETOSKEY MANUFACTURING COMPANY SITE
 Description
     Prerequisite for ARAR
           Requirement
         Citation
                    Comments
 Genera! toxicity of discharges
Generally toxic surface water
Prevent generally toxic substances from
entering surface water
Part 31 of the NREPA (1994
PA 451, as amended),
formerly 1929 PA 245, Water jgroundwater to
Resources Protection' '
                                                                                               Part 4, R323.1057; General
                                                                                               Foxicity
         Substantive requirements are
         applicable to discharge of treated
                      surface water.   ARAF
         would be applicable if a follow-up
         groundwater treatment system is
         •equired (i.e., pump and treat with air
         stripping).
 Human toxicity of discharges
Surface water toxic to humans
Prevent substances toxic to humans
from entering surface water
Part 31 of the NREPA. (1994
PA 451, as amended),
formerly 1929 PA 245, Water |groundwater to
Resources Protection'
                                                                                               Part 4, R323.1057; Human
                                                                                               Toxicity
         Substantive requirements are
         applicable to discharge of treated
                      surface water.   ARAP
         would be applicable if a follow-up
         groundwater treatment system is
         required (i.e., pump and treat with air
         stripping).
 LC50 toxicity criteria of discharges
Exposure of aquatic organisms to
toxic concentrations at LC50 doses
Prevent toxic concentrations of
substances based on LC50 doses
Part 31 of the NREPA (1994
PA 451, as amended),
formerly 1929 PA 245,
Resources Protection'
                                                                                               Part 4, R323.1057;LC50
                                                                                               Toxicity Criteria
         Substantive requirements would be
         applicable to discharge of treated
   Water groundwater to surface water.  ARAF
         would be applicable if a follow-up
         groundwater treatment system is
         required (i.e., pump and treat with air
         stripping).
 Numeric criteria for toxics
Toxic materials and site indicator
chemicals with numeric criteria
discharges cannot exceed numeric
criteria
Part 31 of the NREPA (1994
PA 451, as amended),
formerly 1929 PA 245,
Resources Protection '

Part 4, R323.1057;
Criteria for Toxics
         Substantive requirements would be
         applicable to discharge of treated
   Water groundwater to surface water.  ARAf
         would be applicable if a follow-up
         groundwater treatment system is
Numerica required (i.e., pump and treat with air
         stripping).
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                                                                                   12

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                                                               TABLE 3-D (Continued)

                                     SUMMARY OF ACTION-SPECIFIC ARARs FOR GROUND WATER
                                               PETOSKEY MANUFACTURING COMPANY SITE
 Description
     Prerequisite for ARAR
           Requirement
         Citation
           Comments
 Antidegradation standard
Water quality of discharge must
water quality standards of receiving
water
  void degradation of waters with lower
water quality standards
Part 31 of the NREPA (1994
PA 451, as amended),
formerly 1929 PA 245, Water
Resources Protection l

Part 4, R323.1098,
Antidegradation
Applicable to discharge of treated
groundwater to surface water.   ARA1
would be applicable if a follow-up
groundwater treatment system is
required (i.e., pump and treat with air
stripping).  Note that there may be
technical impracticability concerns if
discharge requirements cannot be met
3y treatment system.
 Disposal of solid wastes from
 groundwater remedies
Groundwater remedies that generate
solid waste
Characterization and handling of wastesjParl
generated from groundwater treatment
    115 of the NREPA (1994 [Substantive requirements are
'A 451, as amended),
•ormerly 1978 PA 641, Solid
Waste Management Act'
applicable if groundwater treatment is
ultimately required.  ARAR would be
applicable if a follow-up groundwater
treatment system is constructed and
operated ((i.e., pump and treat with air
stripping).
                                Toundwater remedies that generate
                                tazardous waste
                               Characterization and handling of wastes
                               enerated from groundwater treatment
                                 Part 111
                                 JA451, as amended),
                                 formerly 1979 PA 64,
                                 Hazardous Waste
                                 Management Act'
       of the NREPA (1994 Substantive requirements are
                         applicable if groundwater treatment is
                         ultimately required.  ARAR would be
                         applicable if a follow-up groundwater
                         treatment system is constructed and
                         operated ((i.e., pump and treat with air
                         stripping).
 Site-specific designated uses and
 criteria
Wastewater discharge to surface
water
Designated uses of surface water must
>e provided
'art 31 of the NREPA (1994 [Substantive requirements are
'A 451, as amended),
rormerly 1929 PA 245, Water [groundwater
lesources Protection '
                                                                                               Part 4, R323.1100; Site-
                                                                                               Specific Designated Uses
applicable to discharge of treated
           to surface water.  ARAf
would be applicable if a follow-up
 ;roundwater treatment system is
•equired (i.e., pump and treat with air
stripping).
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                                    Table 3-Page 13

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                                                      TABLE 3-D (Continued)


                                SUMMARY OF ACTION-SPECIFIC ARARs FOR GROUNDWATER
                                        PETOSKEY MANUFACTURING COMPANY SITE

Notes:

40 CFR     =   Title 40 of the Code of Federal Regulations
ARAR      =   Applicable or relevant and appropriate requirement
BMP       =   Best management practice
CO         =   Carbon monoxide
CWA       =   Clean Water Act
EPA        =   U.S. Environmental Protection Agency
LC50       =   Lethal concentration to 50 percent of exposed organisms
NAAQS     =   Naitonal Primary and Secondary Ambient Air Quality Standards
NOj        =   Nitrogen dioxide
RCRA      =   Resource Conservation and Recovery Act
SOj         =   Sulrur dioxide
USC        =   United States Code


(1)         Includes the substantive  requirements of the associated administrative rules.
F:\USER\TVANDONS\PET\NEWROD\APP-A TV.WPO
                                                          Table 3-Page 14

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                                                         TABLE 3-E
                                        SUMMARY OF LOCATION-SPECIFIC ARARs
                                       PETOSKEY MANUFACTURING COMPANY SITE
Location
Prerequisite for ARAR
Requirement
Citation
Comments
Federal Requirements
Within flood plain
Critical habitat upon which
endangered or threatened species
depends
Within coastal zone
Action in lowlands, relatively flat
areas adjoining inland and coastal
waters, or other flood-prone areas
Determination of endangered or
threatened species
Conduct activities in manner
consistent with approved state
coastal zone management program
Avoid adverse effects, minimize
potential harm, and restore and preserve
natural and beneficial values
Conserve endangered or threatened
species in consultation with the U.S.
Department of the Interior
Activities affecting coastal zone,
including lands thereunder and adjacent
shorelands '
Executive Order on Floodplair
Management; Exec. Order No
11, 988; 40 CFR, Part
6.302(b), and Appendix A
Endangered Species Act ( 1 6
USC 153 let. seq.);50CFR,
Part 200; 50 CFR, Part 402
Coastal Zone Management Ac
(16 USC, Section 145 let.
seq.)
Substantive requirements are
applicable since selected remedial
actions planned within flood plain
Substantive requirements are
applicable if endangered or threatened
species exists on facility or within
treatment area.
Substantive requirements are
applicable if selected remedies
potentially impact coastal area
[because facility has direct access to
coastal management zone of Lake
Michigan).
State Requirement
Within a 1 00-year flood plain
Occupation, filling, or grading of
lands in a flood plain
ARAR requires submission of permit
application to MDEQ containing, if
requested, site development plan, river
cross section, and hydraulic report. For
on-site activities under Supertund, must
meet substantive requirements.
Administrative requirements are not
binding.O
Part 31 of the NREPA (1994
PA 451, as amended),
formerly 1929 PA 245, Water
Resources Protection '
Part 13 - Floodplains and
Floodways
Substantive requirements are
applicable since construction activities
for the selected remedies will be
conducted in 100-year flood plain
Notes:

50 CFR  =
ARAR  =
MDEQ  =
USC


(I)
Title 50 of the Code of Federal Regulations
Applicable or relevant and appropriate requirement
Michigan Department of Environmental Quality
United States Code


Includes the substantive requirements of the associated administrative rules.
F:\USERVrVANDONS\PETWEWROD\APP-A TV WPD
                                             Table 3-Page 15

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                                      APPENDIX A
Concurrence Letter from the State of Michigan

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                                           STATE OF MICHIGAN
                                         JOHN ENGLER, Governor

                          DEPARTMENT OF ENVIRONMENTAL QUALITY
                                     ~B»tter S«rvic» for e Botlar Environment'
                                HOI I IKT6R BUILDING, f O BOX 30473. LANSING Ml 46909-7973

                                         INTERNET: ww^.d.q .t«le.ml.Ufl
                                         AU3SCLL J. HARMMG, Dimator
                                              September 29,199&
        Mr. David LUIrich, Acting Regional Administrator
        United States Fnvironmental Protection Agency
        Region 5
        77 West Jaokeon Boulevard (R-19J)
        Chicago, IHinois 60604-3590

        Dear Mr. Ullrich:

        The Michigan Department of Environmental Quality (MQEQ.) has revievyed the; proposed Record
        of Decision the United States  Environmental Protection Agency's (EPA) proposed Soil
        Alternative 3 and Groundwater Alternative 2 outNned in tpe-ROD for the. site subject to the
        following .understandings: 1 ) deed restrictions for both the. soils and grcjundwaiet will be
        implombnted as described In *H» ROD; 2) »n adequate rjjrnundwater monitoring plan will be
        implemented; 3) art adequate  groundwater cortingency plan wW be developed jand
        implementwJ, If necessary; 4)  the IngaJIs municipal weW Mil be reliably reetnctBjd from residential
        consumption; and 5) a monitor well abandonment plan wiU be developed during remedial
        design.
        The selected remedies meet state cleanup requirements ana nave been deteMiin.ieu to be
        protective of human health and the environment, provided the ROD is implemented as written.

        if you have 'any questions, please. contact Ms. Claudia Kerbawy. Superfund Section,
        Environmental Response Division, at 517-335-3397, or you may contact me.

                                               Sincerely,
                                               Russell
                                               Director
                                               517.373-7917
        cc:    Ms Terese Van Donsel. U:S. EPA
              Mr. Brian Thc»rs*nn. MDEO
              Mr. Alan J. Howard, MDEO
              Ma. Claudia L.S Kerbawy, MDEQ
              Dr. George Carpenter, MDEQ
              Ms. Beth O'Brien, MDEQ/PMC File
EQPOlOCe
(Rav i/W)

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                            APPENDIX B
Responsiveness Summary

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                       PETOSKEY MUNICIPAL WELL FIELD
                           RESPONSIVENESS SUMMARY
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 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986, which requires the United States Environmental Protection Agency
(U.S. EPA) to respond "...to each of the significant comments, criticisms, and new data
submitted in written or oral presentations" on a proposed plan for remedial action. The
Responsiveness Summary addresses  concerns expressed by the public and potentially responsible
parties (PRPs) in the written and oral comments received by the U.S. EPA and the State
regarding the proposed remedy for the Petoskey Municipal Well Field Site.

A.    OVERVIEW

      I.     BACKGROUND/PROPOSED PLAN

      The Petoskey Manufacturing Company (PMC) has been identified as the source area for
      the volatile organic compound (VOC) contamination in the Ingalls Avenue Municipal
      Well in Petoskey, Michigan.  The PMC facility is a small fabricating operation that was
      established in 1946 as a die cast manufacturer and continued with painting operations in
      the late 1960's.  PMC is still in business at the site.

      The disposal of spent solvents and/or paint sludge on the ground surface outside the PMC
      building has contaminated soils and groundwater in the vicinity of the site. The soil
      contamination appears limited to the PMC facility. The groundwater contamination
      extends between the PMC facility and Lake Michigan. Groundwater contamination has
      affected the Ingalls municipal well, which until recently was a source of drinking water
      for the City of Petoskey.  In late 1997, the City of Petoskey discontinued use of the
      Ingalls well and replaced the well with a new source of drinking water. The primary
      contaminant of concern in soils and groundwater is trichlorethylene (TCE).

      In July of 1998, U.S. EPA proposed final cleanup alternatives for soil and groundwater at
      the Petoskey Municipal Well Field Superfund Site.  U.S. EPA recommended the
      operation of a Soil Vapor Extraction (S VE) system to remove volatile organic
      compounds (VOCs) from unsaturated soils on the northwest corner of the property and, to
      some extent, under the PMC  building. The  SVE wells are already in-place at the PMC
      property from earlier testing conducted as part  of the Remedial Investigation (RI).
      Following the operation of the SVE system, U.S. EPA would excavate (to approximately
      5 feet) soils that exceed Michigan Part 201 Residential Direct Contact Criteria and/or
      have the potential to leach to groundwater.  For groundwater, U.S. EPA recommended
      the construction of additional monitoring wells to track the contaminant plume, the long-
      term monitoring of groundwater contaminants, and the use of deed restrictions, where

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       necessary, to restrict the construction of private wells in the area of groundwater
       contamination.

 II.    PUBLIC COMMENT PERIOD

       A public comment period was held from July 15, 1998 to August 18, 1998 to allow
       interested parties to comment on the Proposed Plan in accordance with Section 117 of
       CERCLA. On July 22, 1998, a public meeting was held in Petoskey, Michigan at the city
       of Petoskey Municipal Building.  The U.S. EPA project manager presented the Proposed
       Plan, answered questions, and accepted comments from the public.  The MDEQ project
       manager was in attendance and assisted in responding to questions from the public.
       During the public meeting, two individuals made statements as part  of the oral comment
       portion of the meeting.  A hard copy of statements made by one commentor (representing
       the City of Petoskey) was presented to U.S. EPA for inclusion in the record. During the
       30-day public comment period, U.S. EPA received 2 additional written comments.

B.     COMMUNITY INVOLVEMENT

Recent public interest regarding the Site has been relatively low. Since the  City of Petoskey
replaced its water supply and no longer uses the Ingalls well, residents primarily appear to be
concerned about whether the City will be reimbursed for the funds expended to replace the
Ingalls Well.  As part of the 1995 Interim Record of Decision (ROD), the U.S. EPA
recommended that an air stripper be constructed at the Ingalls well to reduce VOC concentrations
in the City's drinking water. The City of Petoskey elected to replace the well and, as provided
for in the ROD, the U.S. EPA agreed to contribute the capital cost of the selected remedy
($1,238,000) to partially defray the cost of replacing the well.

C.     SUMMARY OF SIGNIFICANT COMMENTS FROM PUBLIC OFFICIALS AND
       GOVERNMENTAL UNITS

Comments from the City of Petoskey were presented, in writing and orally, at the public
meeting.  While the City's comments do  not directly address the alternatives presented in the
Proposed Plan, a summary of the City's comments is presented below with  U.S. EPA responses
to the issues raised by the city. The City's comments were submitted on behalf of the City of
Petoskey by Mr. George Korthauer, City Manager, and Mr. W. Richard Smith, City Attorney.

       Comment GOVERNMENT-1

       "The City of Petoskey strongly objects to the further expenditure of federal response
       dollars for new  remedial actions on this site when it claims that  it does not have
       funds to meet prior obligations to reimburse the city for its expenditures that
       virtually eliminated the most serious public health threat (i.e. drinking water
       contamination) posed by contaminant releases at this site/'

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Response to Comment GOVERNMENT-1

At the time of the Interim ROD, contaminant concentrations in the Ingalls Well were
below maximum contaminant levels (MCLs). Nonetheless, the ROD recommended
construction of an air stripper to further reduce VOC levels in the water supply and to
ensure that the higher levels of VOCs present in the aquifer did not result in MCL
exceedances at the Ingalls well.  Because the contamination at the well was below MCLs,
funding the Interim ROD was not given a high priority when sites "competed" for
cleanup funding. When limited cleanup dollars are available, it is appropriate to address
the worst sites first.  The funding has now been made available by U.S EPA headquarters
and the $1,238,000 will be provided to the State under a Cooperative Agreement.
Through a separate agreement with the City of Petoskey, the State will distribute the
funds to the City.

Comment GOVERNMENT-2

"Allowing the Petoskey Manufacturing Company to escape the costs it has imposed
on the public is unacceptable particularly in view of its continued demonstrated
failure to take reasonable and prudent steps to comply with environmental
requirements."

Response to Comment GOVERNMENT-2

Pursuant to Sections 113 (k)(2)(B) and 117(b) of CERCLA, the U.S. EPA is obligated to
respond to significant comments to its Proposed Plan for remedial action. Issues
involving the liability of potentially responsible parties (PRPs) at Superfund sites are
neither relevant to the Proposed Plan, nor properly within the scope of this
Responsiveness Summary. However, U.S. EPA notes that it has pursued recovery of
costs from PMC in pending bankruptcy proceedings.

Comment GOVERNMENT-3

"All the properties potentially impacted by the proposed deed restrictions
prohibiting the use of ground water need to be identified and the property owners
noticed and provided opportunity to comment prior to adoption of the proposed
remedy and preparation of the Record of Decision"

Response to Government-3

The public was provided with the  opportunity to  comment on U.S. EPA's proposed plan,
which discussed the possible use of deed restrictions.  The U.S. EPA will work with
property owners to coordinate the deed restrictions. The deed restrictions included as part
of the selected remedy are a measure of protection beyond the municipal ordinance

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currently in place, in order to make sure that property owners do not consume
groundwater contaminated above health-based standards.  The required restrictions would
remain on the deed only until the groundwater is sufficiently clean to reasonably ensure
that potable use of the water would not create unacceptable risks to the user.

Comment GOVERNMENT-4

"... the City of Petoskey opposes the recommend [sic] alternatives unless and until
the following steps are taken to resolve outstanding issues:

•     The EPA fulfillment of the commitment to the City of Petoskey to provide
      $1.2 million to partly defray the cost of replacing the city water supply

•     The EPA takes appropriate actions with respect to Petoskey Manufacturing
      Company that holds [sic] that firm accountable for its past actions and
      assures future compliance with federal, state and local environmental
      requirements

•     The EPA clearly identifies the present and future area encompassed by the
      plume of groundwater contamination, the properties impacted by the
      proposed restrictions  and the willingness of the owners affected to.
      voluntarily accept restrictions on their property."

Response to Comment GOVERNMENT-4

      The U.S. EPA notes the City's opposition to the remedy. Specific responses to
      the bulleted items can be found in the responses to comments GOVERNMENT-1
      through GOVERNMENT-3.

Comment GOVERNMENT-5

"The City of Petoskey and its residents have anxiously awaited a resolution to the
environmental contamination problems created by Petoskey Manufacturing
Company since the problem  was first discovered over 15 years ago. It is difficult for
people to understand that despite the fact that this site has been under study by
EPA as a National Priority List site since 1983 that the majority of costs to date for
removing the risk of human exposure have been borne by the residents of the areas
rather than either the responsible party or the EPA. The city and its residents also
find it difficult after all this time to accept a resolution that does not address past
city costs at this site, imposes additional future burdens on its residents through
deed restrictions, and allows the responsible party to continue to place the
community at risk through its operations. The issues considered in the Feasibility
Study and the alternative remedies recommended for inclusion in the Record of

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Decision appear to be an attempt to limit further EPA actions and costs on this
National Priority Site without finalizing payments committed to the city, and
completing effective enforcement actions, including cost recovery, against the
responsible party to assure the residents of the area that operations of this firm at
this site will not continue to place the environment and the community at risk."

Response to Comment GOVERNMENT-5

U.S. EPA agrees that the investigation at this site took too long to complete.  To
accelerate project completion, the project became an EPA-lead site in January of 1998.

U.S. EPA is in the process of providing the funds committed to in the 1995 Interim
Record of Decision. The City's decision to replace the Ingalls well went beyond what
was necessary to ensure that the water supply was protected (since contaminant levels
were below MCLs). It is clear that the Ingalls well had other problems (i.e., surface water
intrusion) that would have warranted either the replacement of the well or the
.implementation of very costly upgrades and filtration systems.  For that reason, the
Interim ROD allowed the contribution of the $1,238,000 cost of the air stripper remedy
toward the City's "enhancement" of the U.S. EPA's selected remedy. Costs borne by the
City in the replacement of the Ingalls well, while possibly mandated by the requirements
of the Safe Drinking Water Act, were not consistent with the cost-effectiveness
requirements of the National Contingency Plan's remedy selection process.

The deed restrictions to  restrict the use of contaminated groundwater are not burdensome.
Private wells are not currently used in the area of groundwater contamination, and a City
ordinance already requires residents to use City water when available.  The deed
restrictions are to be imposed to ensure that the  ordinance's variance provision is not used
without considering the existence of the groundwater contamination. The deed
restrictions would be temporary and would be in place until the aquifer is sufficiently
clean to ensure that potable water would  not exceed MCLs.

U.S. EPA is aware that the City of Petoskey is concerned with environmental problems
associated with the operation of the PMC facility. As part of its comment, the City stated
that PMC, in its failure to sufficiently pretreat its waste discharge to the POTW, is
causing the POTW to violate its NPDES sanitary waste water discharge permit limits on
zinc. Although the Petoskey Municipal Well Field Site is on the NPL, it is still the
responsibility of state and local authorities to enforce state and municipal requirements
relating to the operation of an active facility. If U.S. EPA determines that PMC is
contributing to the soil and groundwater  contamination at the property  or exacerbating the
problems at the site by increasing the likelihood of exposure, the U.S. EPA could
consider additional enforcement actions against PMC.

It is important to remember that the RI/FS found that soil contaminant  levels at the PMC

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      facility are acceptable for human exposure based on industrial use of the property (Part
      201 criteria). Therefore, the soils are not presenting an unacceptable level of risk to
      human health based on the current land use.  However, regardless of land use, the soil
      contaminants are leaching to groundwater and U.S. EPA feels that it is appropriate to
      address the contamination even if land use remains unchanged for the foreseeable future.

D.    SUMMARY OF SIGNIFICANT COMMENTS FROM THE PUBLIC

      Comment PUBLIC-1

      Comments were received from Ms. Ann Baughman, Water Resource Program
      Director for the Tip of the Mitt Watershed Council.

      "We support the U.S. EPA's recommendation to remediate the contaminated soil by
      excavating five feet of soils and constructing a soil vapor extraction system. We
      agree that this alternative would likely remove the major source of ground water
      contamination and would be the most effective at decreasing the level of
      contamination at this site.

      "We are also supportive of the recommendation for the ground water treatment,
      which would continue ground water monitoring. We suggest that if the
      contamination levels do not drop sufficiently to consumptive levels, soon after the
      soils have been removed, that plans should be in place to begin treating the ground
      water. We realize that the complexities with the ground water flow in this area
      make collection and treatment of the contaminated ground water difficult.
      However, the expense would be well spent if the contamination continues to flow
      towards Lake Michigan.

      "Lake Michigan is a national resource, making clean-up of significant sites of
      environmental contamination important for more than just the local environment
      and economy. Although the water quality of Lake Michigan, particularly in the
      northern portions is considered excellent based on low nutrient levels, toxic
      pollution continues to be a problem. The  continued fish advisories and recent
      discovery of problems with perch  populations, point  out the need to reduce and
      where possible eliminate all sources of toxic pollution to the lake.

      "We strongly support the U.S. EPA's plan for soil remediation. We encourage you
      to modify the ground water remediation plan of initial testing and attenuation, to
      include collection and treatment of the ground water, if contamination levels do not
      drop to consumptive levels soon after the soils are removed."

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Response to Comment PUBLIC-1

U.S. EPA appreciates the support expressed by the Top of the Mitt Watershed Council.
U.S. EPA agrees that natural attenuation (after soil remediation) is only acceptable if
contaminant levels in groundwater do in fact drop in response to the soil cleanup. The
selected groundwater remedy (Groundwater Alternative 2) includes the preparation of a
Contingency Plan and the Contingency Plan will be implemented if groundwater
contaminant levels do not drop relatively soon after remediation of the site soils. Follow-
up actions could include continued monitoring or the implementation of a supplemental
cleanup, such as a the operation of a localized low-flow extraction well close to the PMC
property, or a broader aquifer-wide groundwater extraction/treatment system (i.e.,
Groundwater Alternative 3).

Comment PUBL1C-2

Comments were received from Mr. John V. Byl of Warner, Norcross & Judd. The
comments were submitted on behalf of Petoskey Manufacturing Company.

"... The Plan sets forth U.S. EPA's recommended alternatives for cleanup of this
Site. Among other things, the Plan recommends that soil around PMC's facility be
excavated to five feet, and that a vapor extraction system be installed to remove
VOCs from deeper soil. The net present worth of the estimated cost for that
alternative $145,200.

"Another alternative that was considered for remediation of the soil involved
placement of an asphalt cover, which had a net present worth of $52,600. The
apparent basis for recommending the more expensive alternative is a statement in
the Plan that the property may be 'converted from industrial to residential [use]."
PMC, which is submitting these comments, is the owner of the property in question.
As reflected in the plan and other documents in the administrative record, the
property is presently used for industrial purposes by PMC and has been used for
such purposes for many years. PMC intends to continue using the property for
industrial purposes, and it is inappropriate for U.S. EPA to select a  more expensive
remedy based on possible future uses that are completely inconsistent with the
current use of the property and the property owner's intended future use of the
property. Moreover, it is not appropriate for U.S. EPA to base a decision on a
unilateral zoning decision by the City to change the zoning from industrial to
residential, or to rely on statements by City officials that the property may be
converted to residential in the future.  The City does not own or control the
property in question.  It is owned by PMC, and PMC intends to continue using the
property for industrial purposes.

"PMC is aware that the City has made certain comments in the record at the public

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      meeting concerning possible responsibility by PMC for costs incurred by the City
      relating to replacement of its water supply system. PMC strongly disagrees with
      any notion that it is responsible for replacement of the City's water supply. To the
      contrary, the City voluntarily chose to increase its water supply capacity for reasons
      unrelated to contamination at this Site. In fact, the City's municipal well did not
      have levels of contamination that exceeded the applicable (and conservative) clean-
      up criteria.  Nonetheless, despite the fact that the levels were well within acceptable
      risk ranges under applicable law, the City chose to spend money to expand its water
      supplies.  It is well documented in the administrative record that the City elected to
      replace and enhance its water supply for reasons unrelated to the contamination.
      Accordingly, it is disingenuous of the City to claim that PMC or the EPA has any
      obligation to reimburse the City for its voluntary expenditures relating to its water
      supply."

      Response to Comment PUBL1C-2

      When deciding on land use assumptions for the selection of remedies, the U.S. EPA must
      look at the character of the neighborhood and consider possible future uses. Although it
      is clear that the City does not own or control the PMC property, the U.S. EPA felt that it
      was appropriate to consider a future residential land use as part of its evaluation of the
      overall protectiveness of remedial alternatives on human health and the environment.

      The U.S. EPA would like to emphasize that cleanup of the property (regardless of land
      use) is necessary to reduce the continued leaching of contaminants to groundwater.
      While the asphalt cap would slow the movement of contaminants to groundwater from
      the unsaturated zone, the use of SVE and excavation would be more effective because the
      cleanup would remove contaminants before they have a chance to enter groundwater.
      U.S. EPA feels that it is a wise use of funds to aggressively address contamination is soils
      before it has a chance to enter groundwater. Once contamination is in the aquifer, the
      difficulty and cost of cleanup dramatically increase. If U.S. EPA had selected the asphalt
      cap alternative (Soil Alternative #2), it is doubtful that the Agency would have
      recommended the monitored natural attenuation approach and a more aggressive and
      costly groundwater option would have been pursued.

E.    SUMMARY OF SIGNIFICANT ORAL COMMENTS PRESENTED AT THE
      PUBLIC MEETING HELD ON JULY 22. 1998

             Comment ORAL-1

             The Petoskey City attorney, Mr. W. George Smith, read the City's comments
             into the record during the oral comment portion of the public meeting.

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Response to Comment ORAL-1

Please see the comments/responses to GOVERNMENT-1 to GOVERNMENT-5.

Comment QRAL-2

Mr. Brian McGillivary from U.S. Representative Bart Stupak's office,
attended the public meeting. He stated that he was in attendance to hear
what the community had to say regarding U.S. EPA proposed alternatives.
No specific comments were offered on the Proposed Plan.

Response to Comment ORAL-2

The comment was not specific to the Proposed Plan.  No response is required.

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                                 APPENDIX C
Index to the Administrative Record

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              U.S. ENVIRONMENTAL PROTECTION AGENCY
                         REMEDIAL ACTION


                      ADMINISTRATIVE RECORD
                               FOR
                PETOSKEY MUNICIPAL WELL FIELD  SITE
                PETOSKEY, EMMETT COUNTY, MICHIGAN
NO.  DATE
AUTHOR
    UPDATE  #1
SEPTEMBER 22, 1998


       RECIPIENT
 1   06/24/96  City of

               Petoskey
TITLE/DESCRIPTION
PAGES

Ordinance No. 651:

An Ordinance to
                                         Amend
                                              the  Petoskey City
                                              Code
                                              to Provide for the
                                              Establishment of
                                              Rates
                                              for  Water and Sewer
                                              Disposal Service by
                                              City Council
                                              Resolution,
                                              to Provide for
                                              Publication
                                              of Rate Schedules,
                                              and
                                              to Require Use of
                                              City
                                              Water Services by
                                              Property
                                              Owners within the
                                              Juris-
                                              diction of the City
                                              when-
                                              ever Such Services
                                              are
                                              Available
 2   07/22/9.8  Northwest

               Reporting
                U.S.  EPA
                     22,
                    49
                                         and
 Transcript of  July
i
 1998  Public  Meeting

 Public  Hearing re-.
 the
 Petoskey  Municipal
 Well

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07/22/98"  O'Brien, B.,    Van Donsel
               Groundwater     91
          MDEQ           U.S. EPA
07/31/98  O'Brien, B.,   Van Donsel
               Second Set      82
          MDEQ
               Field  Site

                   Letter re:

               Sample Results from
               Samples Collected
               May 26-
               28,  1998 from
               Monitoring
               Wells  at the
               Petoskey
               Manufacturing Site
               w/
               Attachments

              ,     Letter re:
U.S. EPA       of Groundwater
          Sample
               Results from Samples
               Collected May 26-28,
               1998 from Monitoring
               Wells at the
               Petoskey
               Manufacturing Site
 08/00/98   City of

           Petoskey
U.S. EPA
     5
                                    EPA'S
Attachments

City of Petoskey's

Response to U.S.
 08/04/98  O'Brien, B.,    Van Donsel,  T
                Comments    16
           MDEQ           U.S. EPA
               Feasibility Study
               and
               Proposed  Clean  Up
               Plan
               for the Petoskey
               Muni-
               cipal Well Field
               Site

                    Letter:  MDEQ's
                on  the  Draft
           Feasibility
                Study for  the
                Petoskey
                Municipal  Well  Field
                Site
                w/  Attachment

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                                           Petoskey Municipal
                                        Well Field AR
NO.
          AUTHOR
RECIPIENT
     08/10/98  Baughman, A.,  Van Donsel, T.
                    Council's        2
               Tip of the Mitt     U.S. EPA
                              Proposed
               Watershed
               Council



     08/18/98  Byl,  J.;

               Warner

               Norcross

               &  Judd,

               LLP

     08/31/98  Tetra Tech

               EM,. Inc.
                                         the
                                   Well
               Updat
               e #1

               Page
               2

TITLE/DESCRIPTION
PAGES

     Letter re:

     Comments on the

Clean-up Plan for

Petoskey Municipal

Field Site
 10
                         de Blasio,  D.,  Letter re: Petoskey
                         2
                         U.S. EPA       Manufacturing's
                              Comments
                                        on the Proposed Plan
                                   for
                                        the Petoskey
                                   Municipal
                                        Well Field Site

                              U.S. EPA       Feasibility
                         Study Report  167
                                         (Revised) for the
                                   Petoskey
                                        Municipal Well Field
                                        Site

09/19/98  Van Donsel, T.,     File           Memorandum re:
                         U.S. EPA's   1
          U.S. EPA                      Approval  of the
                                   Feasibility
                                        Study for the
                                        Petoskey
                                        Municipal Well Field
                                        Site

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               U.S.  ENVIRONMENTAL  PROTECTION AGENCY
                         REMEDIAL ACTION

                      ADMINISTRATIVE RECORD
                               FOR
                PETOSKEY MUNICIPAL WELL FIELD SITE
                PETOSKEY, EMMETT COUNTY, MICHIGAN

                             ORIGINAL
                          JULY 17, 1998

NO.  DATE      AUTHOR         RECIPIENT      TITLE/DESCRIPTION
                                             PAGES

 1   06/00/91  U.S.  EPA/  .    U.S. EPA       Site Analysis  for
                                   the     24
               ORD                           Petoskey
                                             Manufacturing
                                             Company

 2   1993-1995 U.S.  EPA       Public         U.S. EPA
                                   Administrative     8
                                             Record Index for  the
                                             Petoskey
                                             Manufacturing
                                             Company Site:
                                             Original
                                             and Updates #l-#4
                                             (DOCU-
                                             MENTS CONTAINED IN
                                             THE
                                             PETOSKEY
                                             MANUFACTURING
                                             AR ARE INCORPORATED
                                             BY
                                             REFERENCE INTO THE
                                             ADMIN-
                                             ISTRATIVE RECORD  FOR
                                             THE
                                             PETOSKEY MUNICIPAL
                                             WELL
                                             FIELD SITE)

 3   06/14/95  U.S.  EPA       Public         Interim Action
                                   Record      232
                                             of" Decision for the
                                             Petoskey Municipal
                                             Well
                                             Field Site

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    03/29/96
O'Brien,

MDEQ
B.,    Van Donsel,  T.,
 Results of        16
      U.S. EPA
    07/22/96
O'Brien,

MDEQ
B.,
 of
    11/04/96
Adamkus,

U.S. EPA
V.
    11/07/96
O'Brien,

MDEQ
B.
                        of
8   01/15/97
O'Brien,

MDEQ
B,
Chow,  E.,
    8
U.S. EPA
     Letter re:

MDEQ's October 1995
Groundwater Sampling
from the City of
Petoskey's Ingalls
Municipal Well

Letter re: Results

MDEQ's June 27, 1996
Sampling from the
City
of Petoskey's
Ingalls
Municipal Well

     Letters re:
Levin, C.,
Funding for
U.S. Senate
     Municipal
& B. Stupak,   Well Field Site
U.S Congress
                                                 the Petoskey
Chow,  E.,
    8
U.S. EPA
                                       1996
Chow, E.,
of       8
U.S. EPA
                                       1996
Letter re: Results

MDEQ's October 15,

Sampling from the
City
of Petoskey's
Ingalls
Municipal Well

Letter re: Results

MDEQ's December  16,

Sampling from the
City
of Petoskey's
Ingalls
Municipal Well
                                               Petoskey
                                            Municipal Well AR
                                                      Original

                                                      Page 2

-------
NO,
DATE
     04/15/97
AUTHOR



O'Brien, B.

MDEQ
RECIPIENT
                         Chow, E.,
                         of       8
                         U.S. EPA
                                        1997
10   07/24/97
          O'Brien, B.,

          MDEQ
               Van Donsel, T.,
          Results of         9
               U.S. EPA
11   09/00/97  U.S. EPA
12   01/00/98  MDEQ
13   02/00/98
          Malcolm

          Pirnie

          Engineers,

          LLP
14   02/17/98  MDEQ
                         Public
                         for
                                       68
TITLE/DESCRIPTION
PAGES

Letter re: Results

MDEQ's March 21,

Sampling from the
City
of Petoskey's
Ingalls
Municipal Well

     Letter re:

MDEQ's June 26, 1997
Sampling from the
City
of Petoskey's
Ingalls
Municipal Well

Record of Decision

the Bendix Supefund
Site
                         U.S. EPA       Training Manual  for
                              Part   453
                                         201  Cleanup Criteria
               U.S. EPA
               Inves-  337
                Phase  II  Remedial

                tigation  Report  for
                                         the
                                                   Petoskey
                                         Manufacturing
                                              Site
                         U.S.  EPA
                               Generic
                              Tables:  Part  201
                                3
                              Groundwater Surface
                              Water
                              Interface (GSI)
                              Criteria
                              and Soil Criteria
                              Protec-
                              tive of  GSI '
15   02/18/98  MDEQ
                         U.S.  EPA
                               Tables:  September

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16   02/18/98  MDEQ
17   03/30/98  Tetra Tech

               EM, Inc.
18   05/07/98  MDEQ
19   06/19/98  Tetra Tech

               EM,  Inc.




20   07/00/98  U.S. EPA
          1992    13
               and August 1995 Soil
               Sampling Anaytical
               Data
               for the Petoskey
               Manu-
               facturing Company
               Site

U.S. EPA       Tables: October 1995
          14
               Groundwater Sampling
               Analytical Data for
               the
               Petoskey
               Manufacturing
               Company Site

     U.S. EPA       Draft Health
and Safety    15
               Plan for  the RI/FS
          at the
               Petoskey Municipal
               Well
               Well Field Site
Van Donsel, T.,
     Forwarding
U.S. EPA;
et al.
          the
                    Letter
                       31
               Attached April 1998
               Updated Tables for

               Part 201 Cleanup
               Criteria
               Training Manual

     U.S.  EPA       Draft
Feasibility Study   166
               Report for the
          Petoskey
               Municipal Well Field
               Site
Public
Proposes
                                          14
               Fact Sheet: EPA

               Clean-Up Plan for
               the
               Petoskey Municipal
               Well
               Field Site

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                                 APPENDIX D
Citv of Petoskev Ordinance No, 651

-------
                              CITY OF PETOSKEY

                          ORDINANCE NO.     651

      AN ORDINANCE TO AMEND THE PETOSKEY CITY CODE TO PROVIDE FOR
THE ESTABLISHMENT OF RATES FOR WATER AND SEWER DISPOSAL SERVICE BY
CITY  COUNCIL  RESOLUTION,  TO PROVIDE  FOR  PUBLICATION  OF  RATE
SCHEDULES, AND  TO  REQUIRE USE OF CITY WATER SERVICES  BY PROPERTY
OWNERS WITHIN THE JURISDICTION OF THE CITY WHENEVER SUCH SERVICES
ARE AVAILABLE.

                        THE CITY OF PETOSKEY ORDAINS:

      Section 1. Section 22-68 of the Petoskey City Code is hereby repealed.

      Section 2. The rates to be charged for water and sewer disposal services furnished by
      the City Water and Sewer System shall be prescribed by the City Council from time to
      time by resolution.

      Section 3. Whenever the City Council determines to change the rates  to be charged for
      water and sewer disposal services, the City shall publish notice of the adoption of the.
      changed rates in a newspaper of .general circulation in the City together with a schedule
      of the current  water service or sewage  disposal rates as fixed  by the Council.  Rate
      schedules shall also be made available to the public  at City  offices  during normal
      business hours.

      Section 4. Charges for sewage disposal shall be based upon the consumption of water
      and water meter sizing or upon separately installed meters which measure sewage flow.
      Charges for sewage disposal shall be levied upon all property benefiting from an installed
      sanitary sewer and capable of connecting to an installed sanitary sewer even though a
      physical connection is not made. In the case of a newly installed sanitary sewer, monthly
      charges will be rendered six (6)  months  after the installation  is completed or upon
      physical connection, whichever occurs first. There shall be no distinction between classes
      of customers,  and rates shall apply equally to all  types of  users, public or  private.
      Sewage disposal charges shall be fixed by City Council from time to time as regards
      readiness-to-serve and minimum billing charges,  commodity charges,  individual cost
      recovery charges, surcharges and rate differentials for services both inside and outside
      the City limits.

      Section 5. Water and sewage disposal rates as fixed by City Council Resolution shall be
      such  as are estimated to be sufficient to provide for the payment  of any or  all
      indebtedness, to provide  for the expenses of administration and operation and such
      expenses of maintenance of such system as are necessary to preserve  the same in good
      repair and working order and to build up a reasonable reserve for equipment replacement
      thereof.  Such  rates shall be fixed and revised from time to time  as may be necessary to
      produce these amounts. An  annual audit shall be prepared. Rates for services shall be

-------
      reviewed annually and revised as necessary to determine that rates meet system expenses
      and  to  ensure  that all user classes pay their proportionate share of operation and
      maintenance and equipment replacement costs.  If any of the replacement funds are spent
      before a twenty-year period expires and where the replacement funds are based  on the
      sinking fund method, the annual cost must be reviewed to  compensate for the loss in
      principal.

      Section 6.  Where City water service is available, no other  methods of obtaining water
      service shall be utilized unless specifically permitted by the City or by the  Michigan
      Department of Environmental Quality or any of its subsidiaries.

      Section?.  This ordinance shall become effective fourteen (14) days after its publication,
      which publication shall be made within seven (7) days after its adoption in the Petoskey
      News Review, a newspaper of general  circulation within the City.

      Enacted and ordained by the common. Council of the City of Petoskey on the 24th day
of   June       , 1996.
                                             B. JEREMY WILLS, MAYOR
                                             ALAN TERRY, CITY CLERK
pet-l.ord.

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                                                APPENDIX E
Groundwater Surface Water Interface (GSI) Criteria / Generic Soil
                 Criteria Protective of the GSI

-------
                                                                          APPENDIX E
                     Groundwater/ Surface Water Interface Criteria
            Developed by the Michigan Department of Environmental Quality
For groundwater discharges to the Great Lakes and their connecting waters or discharges in close
proximity to water supply intake(s) in inland surface waters, the generic GSI criterion is the
Surface Water Drinking Water Value (SWDWV) listed in the table below except for those
SWDWV indicted with an asterisk. For SWDWV with an asterisk, the generic GSI criterion is
the lesser of the SWDWV, the wildlife value (WV) and the calculated Final Chronic Value
(FCV). Soil protection criteria based on the SWDWV are listed below except for those values
with an asterisk.

Note that this list does not include all contaminants of concern for the Petoskey Municipal Well
Field Site.  U.S. EPA may elect to work with MDEQ on the development of site-specific GSI
criteria which account for the mixing zone present at the point of groundwater discharge into
Lake Michigan.
Chemical

Acrylonitrile
Alachlor
Arsenic
Atrazine
Benzene
Cadmium
Carbon tetrachloride
Chloroform
Chromium (III)
Chemical
Abstract
Service
Number

107131
15972608
7440382
1912249
71432
7440439
56235
67663
16065831
Surface Water
Drinking Water
Values
(ug/L)
0.87
3.5
50
4.3
12
2.5*
5.6
77
120*
Soil Protection
Criteria for
Surface Water
Drinking Water
(ug/Kg)
17
70
16,000
86
240
if
110
1,500
*
 Appendix E - Page 1 of 2

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Cyanazine
3,3'-Dichlorobenzidine
1 ,2-Dichloroethane
1 , 1 -Dichloroethylene
1 ,2-Dichloropropane
N,N-Dimethylacetamide
Hexachloroethane
Lead
Methyl-tert-butyl ether (MTBE)
Methylene chloride
Molybdenum
Pentachlorophenol
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Thallium
1 , 1 ,2-Trichloroethane
Trichloroethylene
21725462
91941
107062
75354
78875
127195
67721
7439921
1634044
75092
7439987
87865
79345
127184
7440280
79005
79016
10 {M}
0.3 {M}
6
24
9.1
700
5.3
14*
120
47
120
1.8*
3.2
11
1.2
12
29
200
500
120
480
180
14,000
1,500
*
2,400
940
2,400
*
64
220
910
240
580
Appendix E - Page 2 of 2

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