United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05.-89/113
September 1989
&EPA
Superfund
Record of Decision
Kysor Industrial, Ml
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50272-101
I REPQRT DOCUMENTATION i. REPORT Na 2.
PAGE EPA/ROD/R05-89/113
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
L Kysor Industrial, MI
••First Remedial Action - Final
MPT Author<«)
9. Performing Organization Nam* and Addreee
12. Sponsoring Organization Nam and Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
X Recipient-* Acceeeion No.
S. Report Oat*
09/29/89
8.
8. Performing Organization Rapt. No.
10. Pro|ectfTaak/Work Unit No.
11. Contract(C) or Grant(G) No.
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EPA/ROD/R05-89/113 .
Kysor Industrial, MI
16. Abstract (Continued)
latively localized and is from 6 to 25 feet in depth. The primary contaminants of
concern affecting the soil and ground water are VOCs including toluene, tee, PCE, and
xylenes; and metals including chromium.
The selected remedial action for this site includes a two-stage ground water pumping and
treatment system using carbon adsorption for the removal of chromium and air stripping
with vapor-phase carbon adsorption for the removal of VOCs and discharge to the Clam
River; in situ soil vacuum extraction with air pollution control equipment; ground water
monitoring; and institutional controls including site access and ground water and land
use restrictions. The estimated present worth cost for this remedial action is
$16,000,000, which includes present worth O&M costs of $5,000,000 over 60 years.
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DBCXARAZEGN FOR THE HUCUO) GP DEdSXCN
Site Name and
Kysor of Cadillac, Inc.
Cadillac, Michigan
of Tfagjg arri
IJiis decision document presents the United States Environmental Protection
Agency's (U.S. EPA's) selected remedial action for the Kysor of Cadillac,
Inc. , site located in CarilUac, Michigan. This decision document was
developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) , as amended by the Superfund
Amendments and Reauthorization Act (SARA) , and to the extent practicable, the
National Contingency Plan (NCP) . This decision is based on information and
documents contained in the administrative record for this site. The attached
index identifies the items that comprise the administrative record upon which
the selection of the remedial action is based.
The State of Michigan does not concur with the U.S. EPA's Record of Decision.
The Michigan Department of Natural Resources (MDNR) has indicated that they
agree with the remedial technology selected by U.S. EPA to remediate the
Kysor site. However, the State of Michigan does not concur with the cleanup
level for Trichloroethylene specified in the ROD summary.
Ass**=g=3nont of the Site
Actual or threatened releases of hazardous substances fron this site, if not
addressed by implementing the response action selected in this Record of
Decision (ROD) , may present an imninent and substantial endangerment to
public health, welfare, or the environment.
of the
This remedy is the first and final remedial action for the Kysor of
Cadillac, Inc., site. The combination of the soil cleanup alternative and
the groundwater extraction and treatment alternative for the Kysor site
chosen in the attached Record of Decision constitutes the final and overall
remedy for the site. The primary goals of the remedial actions at the Kysor
site are:
- to eliminate any human exposure to residual hazardous
waste dispofiffd of or contaminated materials at the site,
and;
to aridrp^s all potential risks to human health and/or impacts to
the environment.
The Cadillac Area Groundwater Ranpriial Investigation which included the
Kysor of Cadillac, Inc. , site identified areas of concern that include areas
of contaminated soils and groundwater.
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The potential risks associated with the site are posed by continued
contamination of the groundwater by the contaminated soils, and human
consumption of contaminated on -site groundwater. The selected remedy
addresses all site concerns by a combination of treatment, and site use
restrictions. Contaminated soils will be treated using a vacuum extraction
system removing the contamination from the soils, thus reducing the
likelihood of future ground water contamination. A groundwater extraction
and treatment system will be installed to eliminate groundwater
contamination. Additionally, the selected remedy will provide for long-term
monitoring of the groundwater. Corrective action measures will also be taken
should this monitoring indicate a failure of any component of the remedy.
Site use and access restrictions will be placed on the property to ensure the
integrity and performance of the remedy*
The major components of the selected remedy consist of the following:
o Install groundwater extraction and treatment system to remove
groundwater. contamination from area surrounding the site.
o Install vacuum extraction system to remove contamination -
from the soils. #
o Conduct groundwater monitoring to assess quality of area
groundwater.
o Impose access and use restrictions.
o Estimate Total Cost: $ 16,000,000.00
o F-gfrlTO^frgd tiTngj to complete: 64 years
Declaration of S
Ihe selected remedy is protective of human health and the environment,
attains Federal and State, requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost-effective. This
remedy utilizes permanent solutions and alternative treatment technologies to
the may-ill*™ extent practicable for this site. Treatment is a major component
of this remedy, as soil and groundwater contamination will be treated to
reduce the toxicity, mobility, and volume of the contaminants. The
combination of the soil and groundwater alternatives satisfy the statutory
preference for treatment as the principal element of the final remedy.
A reviey will be conducted within five years after commencement of remedial
action to ensure tha£ the remedy continues to provide adequate protection of
human pea 1th
_ 2 9 SEP
Valdas V.
U.S.
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EBdARMnEH FCR *IH|< M&LH) GP DBdSDQN
Site Kane and Location
Northernaire Plating Company
Cadillac, Michigan
This decision document presents the United States Environmental
Protection Agency's (U.S. EPA's) selected remedial action for the
Northernaire Plating Company site located in ft*H1g waste
disposed of or contaminated materials at the site, and;
to address all potential risks to human health and/or Impacts to
the environment.
The Cadillac Area Groundwater Pgmpriiai investigation which included the
Northernaire Plating Company site identified areas of concern that
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include areas of oontaminated groundwater.
The potential risks associated with the site are posed by human
consumption of oontaminated on-site groundwater. The selected remedy
addresses these site concerns by a combination of treatment, and site use
restrictions. A groundwater extraction and treatment system will be
installed to eliminate groundwater contamination, additionally, the
selected remedy will provide for long-term monitoring of the groundwater.
Corrective action measures will also be taken should this monitoring
indicate a failure of any component of the remedy. Site use and access
restrictions will be placed on the property to ensure the integrity and
performance of the remedy.
The major components of the selected remedy consist of the following:
o Xnstall groundwater extraction and treatanent system to remove
groundwater contamination from the area surrounding the site.
o Conduct groundwater monitoring to assess quality of area
groundwater. ' v
o Tmposft access and use restrictions.
o Estimated Total Cost: $ 16,000,000.00
to complete: 64 years
of S^ -^ 1TfrTV De^"***"1"'* ****"* Ons
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost-effective.
This remedy utilizes permanent solutions and alternative treatment
technologies to the ™pyi™im extent practicable for this site. Treatment
is a major component of this remedy, as groundwater contamination will be
treated to reduce the toxicity, mobility, and volume of the contaminants.
The groundwater alternative satisfies the statutory preference for
treatment as the principal element of the final remedy.
A review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
2 9 SEP 19891
Valdas V. Adamkus, /Regional Administrator
U.S. Environmental/Protection /Sgency, Region V
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RECORD OF DECISION
ROD Suaiaary
Northernaire Plating Company Site
Kysor of Cadillac, Inc., Site
Wexford County, Michigan
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1.0. SITE NAME, IOCAHCN, AND DESCKIPEIEN
The Cadillac industrial park encompasses an approximate 1-square-mile area
along the northern boundary of the city of Cadillac, Wexford County, Michigan
(Figure 1-1). The park is bounded by Thirteenth Street to the north,
Mitchell Drive (Route 131) to the east, Wright Street to the south, and
Leeson Avenue to the west. The city of Cadillac water supply well field is
located near the center of the industrial park. Several private residences,
including a trailer park, exist within the industrial park. Another
residential neighborhood, referred to as the North Park Subdivision, is
located adjacent to the northern boundary of the park, across Thirteenth
Street, in Haring Township. The dam River flows through the southeast
portion of the site and accepts run-off from the site.
Currently, approximately 40 industries operate in the industrial park, two of
which are Superfund sites; Northernaire Plating Company (Northernaire), and
Kysor of Cadillac, Incorporated (Kysor).
Northernaire is a former electroplating facility which operated from a 100-
foot by 50-foot prefabricated metal building on 12.75 acres of land at the
corner of Sixth Street and Eighth Avenue.
The Kysor facility, located on Wright Street on the southern edge of the
industrial park, is a large active manufacturer of truck parts. Use of
solvent cleaner and degreasers is common at this facility.
Site geology consists of five strata; three sand aquifers alternately
separated by two clay aquitards. The upper aquitard, ranging in thickness
from zero to about 20 feet, slopes upward from the southwest to the
northeast, until it pinches out along a northwest-southeast trending line
halfway across the industrial park. The lower aquitard appears to be a
clay-sand-clay sequence, which is thickest (i.e., 30 to 35 feet) in the
immediate vicinity of the city wellfield. This lower aquitard, previously
thought to be extensive and thick, was shown to be thick only below the
wellfield, becoming substantially thinner (i.e., 3 to 8 feet) short
distances in all directions away from the wellfield.
Groundwater must be considered separately in each of the three aquifers,
although there is vertical seepage downward between aquifers. The sand
above the upper aquitard defines the shallow aquifer, in which groundwater
flows north to northeast at 200 ft/yr. The intermediate aquifer is confined
in areas where the upper aquitard exists and is unconfined elsewhere; flow
direction is north-northwest. Where the shallow and intermediate aquifers
merge, the latter dominates and groundwater flow turns northwest. Average
groundwater flow in the intermediate aquifer is 80 ft/yr. The municipal
water supply aquifer lies below the lower aquitard. Only a few wells
penetrate this aquifer (3 monitoring wells and 7 city supply wells)
therefore, information concerning this aquifer is limited. The soils are
similar to those in the aquifers above, but may locally contain more gravel.
The flow direction east of the wellfield is westward toward the city wells
(probably under their pumping influence).
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The site, located in an area of both industrial and residential properties,
is a relatively flat glacio-lacustrine environment. The population of
Cadillac, Michigan, is approximately 10,000. This population has a potential
to be impacted by the site because they are served by area grcunduater.
2.0. SITE ulsiucf AND ENFORCEMENT ACTIVITIES
2.1. Northexnaire Plating Company
Northernaire, located at the northwestern corner of Sixth Street and Eighth
Avenue, operated from 1971 to 1981, providing custom chromium- and nickel-
plating finishes to automobile and other metal parts. Improper waste
handling and faulty sewer systems are believed responsible for releasing
toxic compounds (including hexavalent chromium, cadmium, and cyanide) to the
surrounding soils. As a result of leaching through soils to the
groundwater, the highly soluble hexavalent chromium was detected in private
wells downgradient of Northernaire in 1978. The city revoked Northernaire's
wastewater discharge permit and plugged their discharge pipe, forcing
Northernaire to seek other means of disposing their wastewater.
Also in 1978, MDNR ordered Nbrthernaire to conduct hydrogeologic studies of
the problem. In 1979, Northernaire submitted a plan for the requested
study, but later stated no funds were available for the investigation. A
1981 MDNR inspection of the site found the facility closed and apparently
out of business. Further inquiries revealed that Northernaire's assets had
been purchased by Top locker Enterprises of Florida, which had also ceased
operations. Two children playing in the area received chemical burns from
the hazardous wastes stored in containers outside the Northernaire building.
Emergency response measures were conducted by U.S. EPA and MCNR shortly
thereafter in 1983, including chemical testing; removal of waste drums and
liquids from process tanks, decontaminating tanks and building surfaces
(with hypochlorite for treatment of cyanide); and removal of a section of the
discharge sewer line.
On March 13, 1984, Region V referred an action to the Department of Justice
for the filing of a civil complaint for the recovery of all "response costs"
associated with the removal action. A complaint was filed in the District
Court for the Western District of Michigan, and on May 6, 1988, the Court
rendered a judgment granting the U.S. EPA all of its response costs,
including prejudgment interest and indirect costs. This judgement was for
$268,818.25. The Court instructed the Agency to file a statement of the
exact amount of its prejudgment interest. That was done, and on August 8,
1988 the Court made a second ruling granting the U.S. EPA $74,004.97 in
prejudgment interest. One defendant, R.W. Meyer, Inc., has appealed the case
to the 6th Circuit Court of Appeals. That case has been fully briefed and we
are presently awaiting a decision by that court.
The site was included on the National Priorities List (NPL) in July 1982
primarily based on concerns for the possible impact of wastes on the
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municipal wellfield (about a quarter-mile northeast and apparently
dcwngradient of Northernaire) and the potential for direct contact hazards.
A Remedial Action Master Plan (RAMP) was completed for Northernaire in 1983.
For the Northernaire RranRrlial Investigation (RI) (1984-1986) , a series of
borings and monitoring veils were installed by hollow-stem auger and screened
auger sampling techniques to determine site stratigraphy and the vertical and
horizontal distribution of site contaminants. The RI was a state-lead,
federally funded project. During the initial phase of the RI, groundwater
samples were analyzed for metals, cyanide, and VOCs. Cyanides were not
detected; the VOCs noted were not attributable to Northernaire. VOCs were
detected at similar concentrations in both upgradient and downgradient wells
at Northernaire. There were no historical records or indications of
significant solvent usage at Northernaire.
Elevated levels of sane metals were found in the groundwater; most were
believed to derive from salting of area roads (some unpaved) for dust
control in sunnier and ice control in winter. Hexavalent chromium,
attributed to Northernaire, was detected in two wells in the intermediate
aquifer, which led to a second phase of well installations to determine its
distribution. However, knowing that TOC contamination was the focus of the
future Cadillac Area RI, the screened auger groundwater samples were
analyzed for VCCs in addition to hexavalent chromium. The well screens for
the Northernaire study monitoring wells (identified by the designation "MW")
were placed in the zone of highest hexavalent chromium concentration, which
usually did not correspond to the zone of highest VCC contamination.
At that time it was decided to proceed with a source control operable unit in
order to expedite remediation of the soil contamination and continue
investigation of the groundwater contamination. A Focused Feasibility Study
(FFS) of proposed source control measures for the Northernaire site was
corpleted by MDNR in July 1985. Subsequently, with input from the public, a
remedy was selected for the soil cleanup. A Record of Decision was signed
for this source control operable unit (#1) remedy on September 11, 1985.
This included excavation of contaminated soil and sewerline sediments and
disposal at an off-site facility, limited modification of the building, and
restoration of the sewerline. A remedial design for this soil removal was
completed for MDNR in 1987. This action was implemented in 1988 and is
scheduled for completion in September of 1989.
2.2. Kysor of rariinar^ Ire.
The Kysor facility is a large manufacturer of truck parts located on Wright
Street at the southern edge of the industrial park. This facility commonly
uses solvent cleaner and degreasers. Past disposal, practices included
dumping barrels of spent solvent directly on the soils behind the plant.
The site was proposed for the NFL in September 1985.
A series of borings and wells were installed for the Kysor facility
hydrogeologic studies in 1980 and 1983. A total of 24 borings with
monitoring wells were widely distributed over the industrial park with
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several in the vicinity of the city wellfield. These wells (designated by
"K") Heritor both the shallow and intermediate aquifers. All of the K wells
were installed by Kysor. The well installations consisted principally of 4-
inch galvanized steel casings with 2- to 5-foot-long stainless steel
screens. Vertical screening for TOQs in the groundwater was r**** y-t-flrf during
installation. Analysis of groundwater samples frcn K-4 in 1983 found
elevated levels of TCA, TCE, tetrachloroethane (PCE), 1,1-dichloroethene
(DCS), 1,2,-dichloroetnane (DCA), xylene, toluene, ethylbenzene, and
chloroform. Specific details were not reported on the monitoring well
installation techniques. However, boring logs indicate that the borehole
annulus was not typically grouted after installation of the well. Without a
grout seal (usually powdered bentonite) in the annulus,. the effectiveness of
the upper clay aquitard to restrict downward groundwater flow is essentially
eliminated at the well point location. A conduit for contaminant migration
from the shallow to the intermediate aquifer exists under the impetus of
measured downward hydraulic gradients.
The 1983 hydrogeologic study for Kysor also included a 24-hour pump test of
City Hell Number 7. Water levels in the intermediate aquifer were monitored
in: nearby .K-24 . The report concluded that there was little or no apparent
influence of pumping in the municipal well aquifer on groundwater flow in the
intermediate aquifer. However, MENR and U.S. EPA are concerned that (1) the
test was inadequate because it was of limited duration; and (2) the apparent
effectiveness of the aquitard at the wellf ield might not extend throughout
the study area.
Partial remediation of the contaminated soils at the fHgpncai area was
conducted by Kysor in 1981. Excavation depth averaged approximately 6 feet
in two primary removal areas. Approximately 700 cubic yards of soil were
removed; MENR observers noted sticmj odors remaining in the completed
excavation pit. Samples taken by MEKR indicated greater than 100 parts per
million (ppm) of TCE, TCA, PCE, ethylbenzene, and xylenes remaining in soils.
The excavation was backfilled with clean
The PRPs were given the opportunity to perform the Cadillac area RI/FS but
declined to do so. This RI/FS was a state-lead, state-funded project. To
date there have been no significant enforcement efforts (apart from the
Northernaire cost recovery action described above) which address the combined
Cadillac area groundwater contamination problem. On May 20, 1988 a general
notice letter and information request was sent out to a number of potentially
responsible parties.
The Alternatives Array document reports that over 40 industrial facilities
are located within the Cadillac Industrial Park. Of that group, five are
likely sources of the contamination of the groundwater, according to the RI.
They are Kysor of Cadillac, Inc. , Northernaire Plating Co. , Four Wirms, Four
Starr, and Leo Ingraham. There are other facilities located in the area, but
present information does not indicate that they contributed to the
groundwater contamination associated with these two sites.
Other PRPs identified are landowners or somehow affiliated with the
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aforementioned five facilities. They are Willard S. Garwood (Northernaire),
R.w. Meyer Inc./Meyer Construction Company (Northernaire), Top Locker
Enterprises Inc. (Northernaire), and Jonar Company (Four Star).
A total of nine PRPs have been identified to date. They are:
Kysor of Cadillac, Inc. Northernaire Plating Company
Four Winns Ccnpany Top Locker Enterprises Inc.
Four Star Corporation R.W. Meyer Inc./Meyer Construction Co.
jonar Ccnpany ' Willard S. Garwood
Leo Ingraham
3.0. CCMMONHY RELATIONS
The MDNR and U.S. EPA conducted a community relations program to keep the
public informed of progress during the RI/FS for the Northernaire and Kysor
sites and to discuss upcoming events. The RI for the Cadillac area
groundwater study, including the Northernaire and Kysor sites, was released
to the public in August, 1988, and the F5 and Proposed Plan were released in
July, 1989. The MDNR and U.S. EPA provided the public with an opportunity to
comment on the U.S. EPA's preferred alternative and the other alternatives
presented in the Feasibility Study during a 30 day public eminent period from
July 27, to August. 28, 1989. During this fcjp** period, interested individuals
were encouraged to review the FS and Proposed Plan and send written comments
to the U.S. EPA. Individuals were also encouraged to review the
Administrative Record for the sites located at the Cadillac Wexford Library,
411 South Lake Street, Cadillac, Michigan.
Notification of the availability of the documents was published in the
Cadillac Evening News on July 27, 1989.
On August 7, 1989, the MCNR and U.S. EPA held a formal public meeting at the
Wexford County Courthouse in Cadillac, Michigan. During the meeting, the
MDNR made presentations to the community on topics such as: the results of
the RI; the remedial alternatives developed in the FS; and the U.S. EPA's
preferred alternative. Following the presentations, MDKR and U.S. EPA
answered questions from interested parties present at the meeting.
A transcript of the meeting is included as part of the Administrative Record
(see Administrative Record index, attached as Appendix A) for the
Northernaire and Kysor sites. The U.S. EPA's responses to comments received
during this public meeting and to written comments received during the public
comment period are included in the Responsiveness Summary attached to this
document.
This decision document presents the U.S. EPA's selected remedial action for
the Northernaire and Kysor sites located in Cadillac, Michigan. This
decision document was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERdA), as amended
by the Superfund Amendments and Reauthorization Act (SARA), and to the extent
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practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision is based on information and documents contained in
the administrative record for the sites.
4.0. SCOIC AM) ROLE OF RESPONSE ACTZCN
As with many Superfund sites, the problems at the Northernaire Plating
Company Site are complex. As a result, U.S. EPA organized the work into two
operable units (CUs). These are:
OU One: Contamination in the soils and sewer sediments.
CU Two: Contamination in the groundwater aquifers.
U.S. EPA has selected a remedy for OU One (contaminated soils and sewer
sediments). The BOO for this action was signed on September 11, 1985. This
action consisted of removal of contaminated soil and sewer sediments as well
as removal of parts of the sewer line and building at the Northernaire site.
The design for the action is complete and implementation is underway and is
scheduled for completion in September of 1989. The groundwater investigation
determined the groundwater contamination from the Northernaire Site had
mingled with the groundwater contamination emanating from the Kysor site.
Therefore, U.S. EPA decided to treat the groundwater, using a two-phased
approach, to remove the contaminants associated with both sites. Thus the
groundwater contamination from both sites are being rernpriiated with one
action. There are also other contributors to the groundwater contamination
but again the groundwater will be treated for all the contaminants using this
two-phased treatment process. There are contaminated soils at the Kysor Site
which will be addressed by this action as well. This action will be the
second and final action for the Northernaire Site and first and final action
for the Kysor Site.
The remedy for the Northernaire/Kysor sites was selected by combining
aspects of source control, treatment, site access restrictions, and long-term
monitoring. In summary, the selected remedy for the Northernaire/Kysor sites
includes a vacuum extraction technique for the soils at the Kysor site and a
two stage groundwater remediation process. The first stage will use carbon
absorption to remove the hexavalent chromium contamination, while the second
stage will be an air stripping process with vapor phase carbon to remove the
VOC contamination from the groundwater.
The principal threats posed at the Northerraire/Kysor sites are exposure to
contaminated groundwater, contamination of the city wellfield through
downward leaching of the contaminated groundwater, and continued
contamination of the groundwater by the contaminated soils at Kysor. The
selected remedy will address these threats by removal of the VOC
contamination in the soils using a vacuum extraction technique, limiting
access to the soil contaminated area at Kysor, limiting use of the currently
contaminated aquifers, and extraction and treatment of the contaminated
groundwater. The selected remedy will provide for long-term monitoring to
evaluate the effectiveness of the extraction and treatment system of the
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groundwater. Also, since the extraction and treatment system could take as
long as 64 years, the site will be re-evaluated each 5 years to determine the
effectiveness of the selected remedy.
5.0. SUB CHARACTERISTICS
The RI consisted of on site scientific studies and laboratory analyses to
determine the nature and extent of contamination at the sites and affected
areas. During'the RI samples were taken from surface and sub-surface soils,
grcundwater, and residential wells. The RI report for the Cadillac area
groundwater, including the Northernaire and Ifysor sites, was completed in
August 1988. Approximately sixteen (16) chemicals on the U.S. EPA's
Hazardous Substances List (K5L) were detected in the various media at the
site (Table 5-1). The substances were grouped into inorganics and VOCs.
These two groups were then divided into noncarcinogens or carcinogens. The
results of the RI are summarized below.
5.1. Groundwater
The nature and extent of groundwater contamination was defined at the site
(Figure 5-1). The study identified three aquifers beneath the site, a
shallow, intermediate, and deep aquifer, each separated by a clay aquitard.
The shallow aquifer is o.'miofied of mostly sand and fine gravel with
groundwater flow generally in a northeastern direction. The clay aquitard
separating the shallow and intermediate aquifers pinches out in the
northwestern half of the industrial park leaving the intermediate aquifer
unconfined to the surface. The intermediate aquifer is a much thicker sand
sequence with areas of coarse gravel. The groundwater flow in the
intermediate aquifer is in a north-northwest direction. The shallow and
intermediate aquifers appear to have good communication as there is evidence
of contaminant flow from the shallow aquifer to the intermediate aquifer.
The deep aquifer is similar geologically to the upper two aquifers, but
contains more gravel. Groundwater flow direction in the deep aquifer is in a
north-northwesterly direction. There is no evidence of communication between
the deep aquifer and the intermediate aquifer. The Cadillac city wellfield
is located in this deep aquifer.
Groundwater contamination was detected throughout the shallow and
intermediate aquifers (see Figure 5-1). This contamination consists of two
small hexavalent chromium plumes, emanating from the Northernaire facility,
one in the shallow aquifer and one in the intermediate aquifer. Commingled
with this hexavalent chromium contamination in the shallow aquifer is a large
VOC plume coming from the Kysor plant. This commingling occurs in the
intermediate aquifer as well, where a large VOC plume from Kysor has mingled
with the hexavalent chromium contamination. Other small VOC contamination
plumes originating on the property of Four Star Corporation and Four Winns
Company are commingled with these aforementioned hexavalent and VOC plumes
creating a collage of hexavalent chromium and VOC contamination in the
shallow and intermediate aquifers. At present the deep aquifer is not
affected by this contamination.
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5.2. Soil
The only soil contamination remaining at either of the sites is TOC
contaminated soil just north of the main tysor plant. The contaminated soils
and sediments at the Northernaire facility were removed through an earlier
source control remedy (first "operable unit").
The top 6 feet of contaminated soil was excavated at the Kysor site in 1981.
The remaining contamination, consisting of TOCs, is from 6 to 25 feet in
depth. The highest concentration of contaminants was found to be
approximately 150 feet north from the middle of the main tysor building at a
depth of 20 feet. The primary contaminants found included xylene, toluene,
ethylbenzene, TCE, and TCA. This contamination is relatively localized.
Numerous samples were taken to establish background levels and contaminant
migration. Results did not indicate that off-site soils have been affected
by site activity.
Table 5.2 shows indicator chemicals fOr groundwater and soil contaminants and
target cleanup levels (Ids).
5.3. Air
On-site air sampling and monitoring was conducted during the drilling of the
monitoring wells for the groundwater study. Interpretation of the results
indicated that en-site or of f-site air contamination would not occur unless
there is a substantial surface disturbance of the site, particularly in the
area of the soil contamination at Kysor. During the construction phase of
the remedy controls will be implemented to minimize exposure.
6.0. snta&y OF SITE RISKS
The MENR conducted a risk assessment to determine if the sites pose a
potential effect on public health and the environment. The study concluded
that the sites presently pose a significant risk to human health through
ingestion of contaminated groundwater and if untreated the contaminated
groundwater could continue to pose significant future risks. There are also
risks associated with possible contamination of the city wellfield, but due
to the difficulties in determining the migration of contaminants through the
lower aquitard these risks are not quantified.
6.1. Introduction
The risk assessment did use the indicator selection process in the Superfund
Public H^lth Evaluation Man*ml (SFHEH; U.S. EPA 1986g). The chemicals of
concern (Table 6-1) were as follows:
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VOIATHE CK5ANIC
1,1,l-Trichloroethane 1,1-Dichloroethene
Acetone 1,2-Dichloroethane
Toluene Methylene Chloride
Trans-1,2-dichloroethene Tetrachloroethane
Trichloroethene
INCBGANIC OCHPOUNDS
Chromium (Hexavalent)
Cyanide
Elevated levels of inorganics such as calcium, sodium, potassium, and
magnesium were also found in the shallow and intermediate aquifers. These
contaminants are believed to have been caused by salting of roads for ice and
dust control. Although they effect water quality, they are not believed to
be associated with any manufacturing facility.
Cyanide was not detected in the June and August 1987 sampling events.
However, this contaminant was of concern in the Northernaire study because of
its presence in plating baths. Lav levels of cyanide were detected in
Northernaire wells in 1985 (maximum concentration = 22 ppb), and it can be
assumed that the recent lower concentrations (ncn-detects) may be due to the
fact that we are now sampling a different portion of the Northernaire plume.
Therefore, the mayimm value of cyanide detected in 1985 was evaluated in
order to assess the potential for that chemical to pose a risk to public
health.
6.2. TSr^»»3ik»- ^
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-11-
shallow and Intermediate aquifers. The plumes of contaminated groundwater
addressed by this remedy are limited to the areas shown in Figure 5-1. The
groundwater associated with the Northernaire and tysor sites did contaminate
numerous private groundwater supplies. These private wells have since been
placed on city water, at the state's expense, to alleviate this initial
Groundwater in this area contains VOCs, hexavalent chromium, and
cyanide. Certain levels detected exceed the U.S. EPA's Maximum Contaminant
Levels (MCLs) and Maximum Contaminant Level Goals (MCLGs) for drinking water
(Table 6-2) . Therefore, consumption of the groundwater poses a risk to human
health.
The risk evaluation for present groundwater ingestion is summarized in Tables
6-3, 6-4, and 6-5. Groundwater in the shallow aquifer where carcinogens were
detected incurred excess lifetime cancer risks ranging from 4xlO~4 to 5xlO~2,
while in the intermediate aquifer the lifetime cancer risks incurred from
carcinogenic contaminants ranged from IxlO"5 to 4xlO~3. Non-carcinogenic
hazard indices ranged from less than 1 to 11 in the shallow aquifer and the
range in the intermediate aquifer was from less than 1 to 66.
Although the risks were not assessed quantitatively, the subsurface
contaminated soils at the Kysor site, until remediated, will be a continuing
source of groundwater contamination by VOCs. This would add to the actual
risk incurred by ingestion of this groundwater.
Another addition to actual risk incurred is the risk of contaminating the
city wellfield. This risk is not addressed quantitatively, but could be
significant in the years to come if no remediation is done at these sites.
Although these risks are significant, exposure is unlikely to occur at this
time. Groundwater en-site in the shallow and intermediate aquifers is
currently not used as a drinking water source and the contaminants will be
removed as part of the remedy for the site. Residents in the area are
connected to a municipal water supply and will not be impacted by the cleanup
activity. However, many residents who have been connected to the municipal
water supply have retained their old wells for non-consumptive uses.
6.3. Ttapcicity Assessment.
The assessment addrpsspri contaminants in terms of two categories of toxicity;
carcinogenic and noncarcinogenic health effects. Carcinogenic Patency
Factors (CPFs) and Reference Dose Factors (RfDs) for the chemicals detected
at the sites which- have these values are presented in Table 6-6.
6.4. Summary of Risk nv*rae^-o^ ***• * ™
The risk assessment for the Northernaire and Kysor sites arklrpsspd the most
critical risks to public health, however the risk characterization for some
compounds and pathways were not quantified. Standards or critical toxicity
values do not exist for every chemical detected at the site. Therefore, all
exposure pathways and their associated routes of exposure could not be
quantified.
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-12-
The adverse potential risks associated with the sites are summarized below.
Groundwater
There are no current exposures associated with groundwater, but if
residential wells were installed on-site,. residents would be exposed to an
excess lifetime cancer risk ranging from 4xlO~* to 5xlO~2 in the shallow
aquifer and a range of IxlO"5 to 4xlO~3 for the intermediate aquifer. The
residents would also be exposed to concentrations of noncarcinogens at levels
that exceed their respective RfOs.
The risk assessment assumed that a 70-kg adult would drink 2 liters of
groundwater per day over a 70-year lifetime, and a 35-kg child would drink l
liter of groundwater per day over a 10-year span. All toxiookinetic factors
were assumed to be 1.
and Assumptions
The risk assessment is based on a variety of factors including:
* Sampling and analysis
* Fate and transport estimation
* Exposure estimation
* Toxicological data
* Possible synergistdc/antagonistic effects
* Additional routes of exposure
Within the limits of these assumptions and factors this risk characterization
does present an accurate representation of the present and future potential
for risk to public health posed by the contaminated soils and groundwater in
the Cadillac area.
6.5. Analytical Methods
Cancer potency factors (CPFs) have been developed by U.S. EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. CFFs, which are expressed in
units of (mg/kg-day)'1, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level. The term
"upper bound" reflects the conservative estimate of the risks calculated from
the CPF. Use of this approach makes underestimation of the actual cancer
risk highly unlikely. Cancer potency factors are derived from the results of
human epidemiolcgical studies or chronic animal bioassays to which animal-to-
human extrapolation and uncertainty factors have been applied.
Excess lifetime cancer risks are determined by multiplying the intake level
with the cancer potency factor. These risks are probabilities that are
generally expressed in scientific notation (e.g., IxlO""6 or 1E-6). An excess
lifetime cancer risk of IxlCT6 indicates that, as a plausible upper bound,
-------
-13-
an individual has a one in one million chance of developing cancer as a
result of site-related exposure to a carcinogen over a 70-year lifetime under
the specific exposure conditions at a site.
Reference doses (RfDs) have been developed by U.S. EEA for indicating the
potential for adverse health effects from exposure to chemicals exhibiting
ncncarcinogenic effects. RfDs, which are expressed in units of mg/kg-day,
are estimates of lifetime daily •exposure levels for humans, including
sensitive individuals. RgMintyt^j intakes of chemicals ftTffi envi > »,j ^i»->n^ai
media (e.g., the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty factors have
been applied (e.g., to account for the use of animal data to predict effects
on humans). These uncertainty factors help ensure that the Rfds will not
underestimate the potential for adverse ncncarcinogenic effects to occur.
Potential concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as a hazard Quotient (HQ) (or the ratio of the
estimated intake derived from the contaminant concentration in a given medium
to the contaminant^ reference dose). By adding the HQs for all contaminants
within a medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The HI
provides a useful reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across media.
6.6. Potential Future Risks
The Northernaire site is no longer in operation and the soil contamination
has been remediated (first "operable unit") removing any further source of
groundwater contamination by hexavalent chromium and cyanide. The Kysor
facility is still in operation and current waste handling procedures should
prevent any new contamination from occurring at the facility. However soil
contamination still remains at the Kysor site and a major remedial action
objective for the Kysor site is to remove the continuing source of TOG
contamination of the groundwater. Although the groundwater is not being used
for drinking water purposes, there is still a potential threat of migration
of the contamination off-site to the north into residential areas or areas
which could be developed for residential use. There is also the significant
threat of contaminating the city wellfield.
To evaluate future risks posed at the sites from ingestion of contaminated
groundwater, contaminant concentrations were modeled to theoretical receptor
locations on the projected center line of the plumes at 13th street (see
Figure 6-1). Using various modeling techniques the arrival time of the plume
at its receptor well was estimated as well as the length of time the plume
would remain at its receptor well before migrating past the receptor
location. Maximum and average concentrations were calculated in order to
determine average and worst-case scenarios for future risk assessment
assuming no remediation would be performed at the sites. Using these methods
residents drinking the groundwater in the future would be exposed to excess
lifetime cancer risks ranging from TxlO"5 to lxlO~3 for the shallow aquifer
-------
-14-
and 6X10"5 to 5xlO~3 for the intermediate aquifer for at least another 10 to
15 years. Ncncarcinogenic hazard indices for future consumption of the
groundwater would range from less than 1 to 1.29 in the shallow aquifer and
in the intermediate aquifer the range is from less than 1 to 17.14,
indicating there would still be significant risks in the years to nrme if no
remediation is done at the sites. The risk evaluation for future groundwater
ingestlon is sumnarized in Tables 6-7 and 6-8.
Again the major concerns at the sites are the large groundwater contamination
plumes in the shallow and intermediate aquifers. These concerns shall be
addressed through implementation of the selected groundwater treatment
remedy.
7.0. DOOMEtnKIlCN OF SIGNIFICANT CHANGES
This Record of Decision selects an extraction, treatment and discharge system
for cleanup of the contaminated groundwater. Groundwater Alternative 3A
using Carbon Adsorption for treatment of the chromium and Soil Alternative 5,
as described in the Proposed Plan and later in this ROD, will be use to
remediate the Northernaire and Kysor sites. The U.S. EPA has reviewed and
responded to all relevant comments received from the interested parties,
including those from the State and community, during the public eminent
period. Comments were ™aA» on the selected alternatives as well as other
remedial alternatives. Based on the public comments, the U.S. EPA has
determined that there is no need for any significant changes to Groundwater
Alternative 3A with Carbon Adsorption, and Soil Alternative 5.
In the event that additional data or information during the design of the
remedy reveals the need for a modification, the U.S. EPA will notify the
public of any changes to the remedy presented here in this Record of
Decision in accordance with applicable law and Agency guidance.
8.0. DESCREFnCN OF AIHSaOTlVKS
Based on information gathered during the RI, MDNR in cooperation with U.S.
EPA occpleted a FS that involved reviewing all possible remedial methods,
and identifying and evaluating several remedial alternatives to address
concerns related to the Northernaire and Kysor sites.
The FS presented a detailed analysis of four alternatives for remediation of
the contaminated groundwater and six alternatives for the remediation of the
contaminated soils at Kysor. The evaluation considered the effectiveness of
each alternative in minimizing potential risks and future threats posed by
the sites. It also estimated the costs and implementation time associated
with each alternative. A brief summary of each alternative is presented
below.
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8.1. Groundwater Alternatr
-15-
Due to the commingling plumes of groundwater contamination, the groundwater
treatment would need to be in two stages. The VOC and hexavalent chromium
contaminants differ ocnsiderably and cannot be treated by the same process.
Therefore, the groundwater remediation would require one treatment for
hexavalent chromium and a separate treatment for the VOC contamination.
However, both of these treatments would be conducted in the same treatment
facility.
All of the alternatives considered for groundwater remediation, except the
"no action" alternative, would include the following:
Groundwater Extraction System: This would consist of a system of
pumping wells for extraction of groundwater in the shallow and
intermediate aquifers. These extraction wells would be strategically
located to intercept contaminated groundwater. An underground piping
system would interconnect the extraction wells and transport the
extracted groundwater to the TCC and hexavalent chromium .treatment
facility.
Hexavalent ChromiuB Treatment: There are two options which can be
utilized to treat the hexavalent chromium. One of these two options
would be included in all of the treatment alternatives. They are as
follows:
Option 1 - Ion Exchange
This treatment would require the extracted groundwater to be run
through a treatment process where toxic metals salts including
chromium, and ions are electrostatically bound to a solid resin
ma+wiai and removed from solution. The resulting residuals
include spent resins which would be regenerated on-site by
washing with caustic and acid solutions. This regeneration would
produce about 500 gallons of chromium waste per day requiring
off -site disposal.
Time to Implement: 18-21 months
Capital Cost: $ 271,000
Annual O & M Cost: $ 977,000
Total Present Worth Cost: $1,248,000
Option 2 - Carbon Adsorption
The hexavalent chromium-contaminated groundwater would be passed
through an activated carbon filtering system in this treatment
process. The activated carbon selectively adsorbs organics and
certain metals such as chromium by a surface attraction
phenomenon that binds organic molecules to available carbon
pores. This process would produce 15,000 pounds of spent carbon,
used in the filtering process, per year for disposal.
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-16-
Time to implement: 18-21 months
Capital Cost: $140,000
Annual O & M Cost: $364,000
Total Present Worth Cost: $504,000
Treated Groundwater Discharge: As a component of the groundwater
treatment alternatives, treated water would be discharged to the Clam
River. Discharge to the river would require construction of a force
main constructed of polyvinyl chloride (PVC) piping.
Groundwater Monitoring: Groundwater would be monitored from the
existing monitoring wells to determine effectiveness of the
extraction system and plume migration. This would include sampling of
the monitoring wells annually.
The major components of the groundwater alternatives are described below.
8.1.1. Groundwater Alternative 1 - No Action
The no-action alternative consists solely of groundwater monitoring and a
five-year review for the site. A monitoring program, inspection/
maintenance program, and contingency plan would be implemented. This
alternative would allow the groundwater plumes at the Cadillac Industrial
Park to disperse and dilute by natural mechanisms. A groundwater monitoring
plan would be necessary to periodically assess the fate and transport of the
contaminant plumes. A five-year review would be done to determine whether
public health and the environment are protected.
Time to Implement; None
Capital Cost: $ 0
Annual O & M Cost: $824,000
Total Present Worth Cost: $824,000
8.1.2. ^ __&ctracticn._Hexav;alent_Chromiu]n
UV/Oxiifeticn and
This alternative would include extraction, a treatment for the hexavalent
chromium contamination, and discharge as described previously.
Additionally, a ultraviolet (UV) light/oxidation treatment would be utilized
for treatment of the VOC contamination.
The UV/oxidation treatment would chemically oxidize the organic compounds in
the groundwater using a combination of UV light, ozone, and/or hydrogen
peroxide. Ozone and hydrogen peroxide are powerful oxidants of organic
compounds in water.
There are four main components of a UV/oxidation system: an air compressor,
an ozone generator, a reactor tank, and an electrical source for the UV lamp
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-17-
bulbs. The system would utilize a baffled UV/ozcne contactor, within
the UV tiii h« are mounted Inside quartz sheets. Ozcne is diffused into the
batten of the contactor, and allowed to sake contact with the contaminated
water in the presence of UV light. A manifold attached to the contactor
collects any residual ozone fron the procooo and catalytically converts it
back to molecular oxygen. Hydrogen peroxide may be added to the influent
stream prior to entering the contactor. Hydrogen peroxide and ozone are
oxidants that can be utilized separately or in combination to achieve maxim im
oxidation conditions. This system could be fully automatic, has no filtering
or adsorption medium to dtspnca of or regenerate, and treats groundwater
contaminated with VOCs without air emissions or generation of hazardous
wastes.
Time to Implement; 18-21 months
Using Ion Exchange for Hexavalent Chromium Treatment;
Capital Cost: $ 6, 115, OCX)
Annual O & M Cost: $32,358,000
Total Present Worth Cost; $38,473,000
Using Carbon Adsorption for Hexavalent Chromium Treatment;
Capital Cost: $ 5,935,000
Annual O & M Cost: $31,611,000
Total Present Worth Cost: $37,546,000
8.1.3. ^miprfcq^g'r' A^ ^'J5|rna^tve 3 —
Treat i*1* it. AIT fitiHrvin' and Digrfiaroe
This alternative would include extraction, a treatment for the hexavalent
gjvr*njim contamination, and discharge as described previously.
Additionally, an air stripping treatment would be utilized for treatment of
the VDC contamination.
The air stripping treatment is the mass transfer of TOCs from the liquid
(water) phase to the gas (air) phase. The liquid waste is descended through
a packed tower. Air is supplied by a blower or compressor that is introduced
to the bottom of the tower. The packing material functions to increase the
area of contact between the air and the descending liquid waste. As the
liquid waste descends through the packed tower the organics are transferred
from the liquid phase to the gas phase. Air stripping requires treatment of
gases generated during the process. There are two methods of air stripping
which could be implemented at these sites. They are as follows:
8. 1.3 (A).
TT* wh Vo— *=*»
This method of air stripping treats the off-gases with a vapor phase
carbon filtering system. This system would consist of two stripping
columns operating in series. The first air stripper would be designed
to remove 99 percent of the TOCs from the liquid phase. The second
air stripper would reduce VDC concentrations to meet the liquid-phase
effluent discharge requirements. The second stripper would provide a
50:1 air-to-water ratio which would not need treatment of the off-
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-18-
gases. However, vapor-phase treatment is required for the off-gases
from the first air stripper, which would be accomplished by a vapor-
phase carbon adsorption unit. This vapor-phase unit uses a carbon
filtering system which would be regenerated in-situ and avoids the
need for off-site disposal of spent carbon.
Time to Implement: 18-21 months
Using Ion Exchange for Hexavalent Chromium Treatment:
Capital Cost: $ 4,414,000
Annual O & M Cost: $11,637,000
Total Present Worth Cost: $16,051,000
Using Carbon Adsorption for Hexavalent chromium Treatment:
Capital Cost: $ 4,234,000
Annual O 6 M Cost: $10,890,000
Total Present Worth Cost: $15,124,000
8.1.3(B). A'*'1' Styi^flng With T.ir«iiri— pfra
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-19-
liguid stream that oust be treated and/or dlspofifld at an off-site permitted
facility. Approximately 231 gallons per hour of oonoentrated organics would
be produced for disposal at an off-site RCRA facility.
Time to Implement: 18-21 months
Using Ion Exchange for Hexavalent Chromium Treatment:
Capital Cost: $ 4,590,000
Annual O & M Cost:- $17,708,000
Total Present Worth Cost: $22,298,000
Using Carbon Adsorption for Hexavalent Chromium Treatment;
Capital Cost: $ 4,410,000
Annual O 4 M Cost: $16,961,000
Total Present Worth Cost: $21,371,000
8.2. Soil Alternatives
8.2.1. Soil Alternative 1 - Mb Action
This alternative consists of establishment of institutional controls,
development of a site inspection and maintenance plan, installation of a
perimeter surface barrier, and a five-year review for the site.
Institutional controls (e.g., deed and land restrictions) would be necessary
to restrict future site use for the protection of public health. These
controls would restrict site activities of the current site owners/operators,
as well as alert future owners to potential site-related risks. Additional
fencing would need to be installed at Kysor to restrict access. A five-year
review would be done to determine whether public health and the environment
are protected.
Time to Implement: None
Capital Cost: $ 24,500
Annual O & M Cost: $138,500
Total Present Worth Cost: $163,000
8.2.2 Soil Al^^TTErtiive 2 — &Trficial ft*pping and
This alternative consists of installation of a surf icial cap and a
subsurface slurry wall to contain contaminated soils at Kysor.
The slurry wall would be constructed in an excavated trench and would be tied
in to the low-permeable underlying clay layer about 90 feet below the ground.
It would completely surround the contaminated soils.
To prevent rainfall seepage into the contaminated soils a multilayer cap
would be constructed to cover the area encircled by the slurry wall. This
cap would consist of 24 inches of low-permeability clay, followed by a
synthetic liner. The liner would be covered with a m-ipi**™ 12-inch
permeable drainage layer and 24 inches of soil, which would support a
topsoiled vegetative layer to reduce the potential for soil erosion.
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Time to Implement: 24-30 months
Capital Oost: $1,050,000
Annual O & M Oost: $ 125,000
Total Present Worth Cost: $1,175,000
8.2.3. ft°n Al*'giT'na*"ive 3 — Rff '-jVdtion and rrfc*^P|j"t>'raf*^Tr
Stripping
This alternative would consist of excavation of contaminated soils and
treatment of these soils by low temperature thermal stripping.
Law tenperature thermal stripping is a treatment method that uses
temperatures typically 150 to 700 *F to remove adsorbed contaminants fron the
soils. The thermal stripping unit consists of a process feed system, large
rotating drum (kiln) , and a tenperatuie ocutrolled burner system. The
thermal stripping unit is operated under controlled conditions, and will
generate emissions such as particulates, water vapor, VOCs, and products of
incomplete combustion. To prevent these emissions from being released into
the environment, gaseous emission control equipment will be required.
Process emissions are typically controlled using an afterburner to thermally
destroy the contaminants, or vapor-phase carbon adsorption. If vapor-phase
activated charcoal canisters are employed in the emission control , the
canisters will be transported and treated off -site.
The contaminated soils at Kysor would be excavated and burned in a thermal
stripping unit to remove the VOC contamination. The clean soil would be
backfilled and disposed of onsite. Any emissions from this process would be
treated, either captured or burned, in an afterburner emission control unit.
Time to Implement: 24-27 months
Capital Cost: $8,600,000
Annual 0 & M Cost: $ 0
Total Present Worth Cost: $8,600,000
8.2.4. Soil Alternative 4 - In-situ Soil Flvy^iing
The contaminated soils would be flushed with water causing migration of the
VOC contamination from the soil into the groundwater where it would be
treated by one of the onsite groundwater treatments described earlier.
The soil-flushing system would consist of infiltration piping installed
above the zone of contaminated soils. A source of flushing water would be
provided at the Kysor site. The water would be flushed through the affected
soils and subsequently discharge to groundwater. The contaminated
groundwater would be collected using groundwater recovery wells and treated
at the onsite groundwater treatment facility proposed for groundwater
remediation.
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-21-
Tijne to Inplement: 21-27 months
capital Cost: $154,000
Annual O t M Cost: $ 71,000
Total Present Worth Cost: $225,000
8.2.5.
This alternative would entail vacuum extraction of the soil contaminants by
placing a series of wells to circulate soil gas Within the unsaturated zone
of the contaminated soil. A series of induction and extraction -wells would
be installed to the water table at the tysor site. A gas induction blower
system would force clean gases into the unsaturatad zone and soil pore
spaces. These purging gases volatilize the VDCs from the soil. At the same
time, the vacuum extraction system would be withdrawing the contaminated
gases from the unsaturated zone. These contaminated gases are treated by
emission control equipment before being released to the atmosphere.
Time to Implement: 21-27 months
Capital Cost: $925,000
Annual 6 & M Cost: $ 0
Total Present Worth Cost: $925,000
8.2.6. Soil Alternative 6 — fsoii 'fr*raiva*"Lon and Cnsite
This alternative would consist of excavating the contaminated soil and
incineration of this soil onsite.
Thermal destruction is a treatment method that uses high tenperature to
oxidize contaminants under controlled conditions, thereby degrading a
substance into products that generally include carbon dioxide, water vapor,
sulfur dioxide, hydrochloric acid gases, and process ash. The hazardous
products of the thermal destruction/incineration unit (e.g. , particulates,
sulfur dioxide, nitrogen oxide, hydrochloric acid, and products of inconplete
combustion) require air pollution control equipment to prevent release into
the environment. Thermal destruction methods can be used to destroy organic
contaminants in liquid, gaseous, and solid wastestreams.
The contaminated soils would be excavated and staged for onsite
incineration. A mobile incinerator would be installed at the Kysor site, and
all contaminated soils would be incinerated. If delisted and considered
unhazardous, the residual ash will be ^jgpniaari of at Kysor using backfilling
methods. If not delisted the residual ash would be rH^pncori of in a RCRA
landfill.
Time to Inplement: 25-27 months
Capital Cost: $14,300,000
Annual O & M Cost: $ 0
Total Present Worth Cost: $14,300,000
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-22-
9.0. SCM4ABY OP OCHPARAHVE ANALYSIS CF
The alternatives are evaluated by balancing technical considerations
(implementability) with the cost and protectiveness (effectiveness) of the
alternatives. This evaluation determines the most cost-effective
alternative that will meet the objectives of the feasibility study for
implementation at the Northerraire/Kysor sites. The alternatives are
evaluated against the nine criteria recommended by U.S. EPA (U.S. EPA,
1987). The criteria are as follows:
1) Overall protection of hunan health and trie environment. U.S.EPA
measures each alternative against how it protects human health and
the environment and describes how threats are eliminated, reduced,
or controlled through treatment, engineering methods (e.g., a soil
and clay cap), or institutional controls (e.g., deed restrictions).
2) Compliance with state and federal regulations. The alternatives
are evaluated for compliance with those environmental regulations
determined to be applicable, or relevant and appropriate to the
site.
3) Long-tern effectiveness. Long-term effectiveness relates to the
remedy's ability to maintain reliable protection of human health and
the environment over time once it has been implemented.
4) Reduction of contaminant tcocicity, Mobility, and volume. U.S. EPA
evaluates each alternative based on how it reduces (1) potential
threats to human health and the environment, (2) the contaminant^
ability to move, and (3) the anriunt of contamination.
5) Short-tern effectiveness. Implementing each alternative may take
varying lengths of time and present different risks to human health
and the environment during implementation (e.g., will contaminated
dust be produced during soil excavation?).
6) Implementability. U.S. EPA considers the technical (e.g., how
difficult is the alternative to construct and operate?) and
administrative (e.g., coordination with other government agencies)
feasibility of a remedy, including the availability of goods and
services.
7) Cost. The benefits realized by implementing a remedial alternative
are weighed against the cost of implementation.
8) State acceptance. After reviewing the Rpwriial Investigation and
Feasibility Study reports, the state may concur with, oppose, or
have no comment on U.S. EPA's proposed plan for cleaning up a site.
9) Community acceptance. U.S. EPA considers community response to the
proposed cleanup plan and the other remedial alternatives when
selecting the final remedial action.
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-23-
9.1. Overall protection of huaan health and the environment
9.1.1. Groundwater Alternativ
With the exception of the No-Action alternative (Groundwater Alternative
II), each alternative would protect human health and the environment.
Both technologies for treatment of the hexavalent chromium
contamination Option 1 (Ion Exchange)- and Option 2 (Carbon Adsorption)
would be protective by reducing the chromium ions to the levels required
by MDNR limitations for discharge to the Clam River. Because state
levels are below the MCLs and Ambient Water Quality Criteria (AWQC),
discharge concentrations would be considered protective of human health
and the environment.
Groundwater Alternative 3 (A) would protect human health by reduction of
the VOC contamination in the groundwater through treatment, to meet the
cleanup goals as outlined later in this section. This would minimize
potential risks from ingesting VDC contaminated groundwater through a
reduction of contaminant concentrations to acceptable levels. Because
the cleanup goals are set at levels protective of public health and the
environment, no adverse impacts would occur due to exposure to the
effluent.
Groundwater Alternatives 2, 3(B), and 4, would also be protective by
reducing VOC contamination to acceptable levels through treatment.
Under Groundwater Alternative 1, no remedial action would be conduct ed
at the site, and therefore risk to human health and the environment as
identified in the risk assessment would not be reduced. As this
alternative is judged to not be protective of human health, Groundwater
Alternative 1 will be dropped from further consideration or discussion.
The cleanup levels, which will be used to determine protectiveness, for
each of the groundwater treatment alternatives are outline for the
indicator contaminants as follows:
COMPOUND TARGET CLEANUP LEVELS
(ug/1)
1,1,1-Trichloroethane 200
Trans-l,2-dichloroethylene 70
1,1-Dichloroethylene 5
1,2-Dichloroethane 5
Methylene chloride 5
Tetrachloroethylene 1
Trichloroethylene 5
Chromium (Hexavalent) 50
Xylene 440
Toluene 40
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-24-
These levels were calculated so that the cleanup level for each
contaminant meets or exceeds Maximum Contaminant Levels (Ids) required
by the Safe Drinking Hater Act and the additive risk of all contaminants
falls within U.S. EPA's acceptable risk range of IxlO"4 to IxlO"7.
9.1.2. Soil Alternate
Soil Alternative 5 by reducing the VOC soil contamination through
treatment would provide adequate protection to human health and the
environment. Risks to public health would be reduced due to the
minimization of organic chemicals present in the soils, and therefore
eliminating the source for continuing groundwater contamination. This
alternative would result in an improvement in the environment over
current site conditions.
Soil Alternatives 3 and 6 would be very protective of human health and
the environment by completely eliminating the soil contamination
through excavation and incineration. Therefore these alternatives would
eliminate the source of groundwater contamination at the Kysor site,
reducing future site risks to public health.
Soil Alternative 4 would eliminate the risks associated with soil
contamination, but would flush the contaminants into the groundwater,
thus requiring groundwater treatment in order to be protective of human
health and the environment.
Soil Alternative 2 would reduce risks by capping and containing the soil
contaminants and would be more protective than current site conditions.
However, most of the risks incurred at this site from the soils are as a
source of groundwater contamination. Soil Alternative 2 would not
permanently remove the soil contamination and therefore is not as
protective as Soil Alternatives 3, 4, 5, or 6.
Under Soil Alternative 1, no remedial action would be conducted at the
site, and therefore risk to human health and the environment as
identified in the risk assessment would not be reduced. As this
alternative is judged to not be protective of human health, Groundwater
Alternative 1 will be dumped from further consideration or discussion.
The cleanup levels, which will be used to determine protectiveness, for
each of the soil treatment alternatives are outlined for the indicator
contaminants as follows:
CCMPOUND TARGET CLEANUP LEVELS
(mg/kg)
Trichloroethylene 0.07
Xylene 141.00
1,1,1-Trichloroethane 7.60
Toluene 724.00
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Soil cleanup levels were calculated so that residual contamination in
the soil will not result in a continuing source of contamination to the
groundwater above groundwater cleanup levels.
9.2. Compliance with Applicable or Relevant and Appropriate RequireBents
(ARARs)
9.2.1. Qnoundwater Alternatives
All groundwater treatment alternatives will meet MCL's under the Safe
Drinking Water Act (SENA). The SENA, is considered to be relevant and
appropriate to the treatment of groundwater. All alternatives will also
comply with construction and operating standards required by the
Michigan Safe Drinking Water Act and the mission standards of the Clean
Air Act and Michigan Air Pollution Control Act 348.
Both hexavalent chromium treatment options would create hazardous waste
for off-site disposal. This waste shall be handled, treated, and/or
Higpncorf as a RCRA hazardous waste pursuant to federal RCRA regulations
and the Michigan Hazardous Waste Management Act 64. Disposal shall
occur in a fully permitted RCRA facility and transported in accordance
with RCRA, Department of Transportation, and Michigan transportation
.regulations. Alternatives 3(B) and 4 would «!.«? produce hazardous waste
which shall be handled in compliance with these regulations.
Alternatives 2, 3(A), 3(B), and 4 shall meet all ARARS pertaining to
groundwater quality by collecting and treating the contaminated
groundwater. These alternatives shall incorporate a groundwater
treatment system which shall be designed to produce effluent that meets
the substantive requirements of a NPDfcS permit and Michigan Waste-water
Discharge Permit Rules.
The discharge limitations were developed by the State in order to be
protective of the Clam River. The discharge applicable to all of the
groundwater treatment alternatives shall be as follows:
•>
CCMPOUND DISCHARGE UMITATICN
Trichloroethylene 20 ug/1
1,1,1-tricnolorethane 10 ug/1
Total Benzene + Toluene + Xylene(s) 20 ug/1
Total chromium 52 ug/1
Hexavalent Chromium 6 ug/1
Other discharge limitations may be applicable depending on the treatment
technology. These limitations shall be part of mooting the substantive
requirements of a NPDES permit and the Michigan Waste-water Discharge
Permit Rules.
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Groundwater monitoring, extraction, and treatment under all alternatives
shall be consistent with RCRA Corrective Action Monitoring.
ARAR requirements are further dliqn insert in Sections 10 and 11.
9.2.2. Son Alternati\
All of the Soil Alternatives shall ocnply with RCRA and Michigan
facility design and operating standards, Michigan hazardous waste
monitoring regulations, and OSHA Standards for Harardnis Waste
Operations. Fugitive emissions from grading and excavation shall be
itrolled so that the CAA and Michigan Air Pollution Ccntrol Act 348
regulations are not exceeded.
Soil Alternatives 3, 4, 5, and 6 shall achieve the cleanup standards
established in Section 9.1 thus reducing the risks associated with
continuing groundwater contamination by reducing the amount of
contamination in the soil through treatment.
Soil Alternative 2 shall achieve the requirements of health based TBC
criteria for soil by using a cap and containment wall to prevent direct
contact with the contaminated materials. This cap and containment wall
shall also limit the migration of this soil contamination into the
groundwater, however, it would not eliminate it.
Soil Alternatives 3, 5, and 6 shall comply with the substantive
requirements of the CAA and Michigan Air Pollution Control Act 348
regulations to control emission rates, quantities of missions, fugitive
dust and particulates. These three alternatives would also generate
hazardous wastes and shall therefore ccnply with RCRA, Department of
Transportation, and Michigan generator and transporter regulations by
proper handling of the hazardous waste.
Soil Alternatives 3 and 6 shall excavate contaminated soils and would
therefore ccnply with RCRA Closure/Past Closure regulations and Michigan
Hayarrinig Waste Management Act 64. The cap design and construction of
the containment wall of Soil Alternative 2 shall comply with RCRA and
Michigan landfill regulations.
Soil Alternative 6 would use an incinerator and would cccply with RCRA
and Michigan requirements for incinerators.
Potential ARARs for all of the soil and groundwater alternatives are
sunmarized in Table 9-1, and further discussion is located in Section 10
and 11.
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9.3. l£ng-Tex» Effect!'
9.3.1. Grounduater Altemati
Both of the hexavalent chromium treatment options would equally provide
long-term effectiveness and permanence. Since these treatments would
only be necessary for approximately 4 years to reduce the hexavalent
chromium to acceptable levels they both provide the necessary
permanence.
All of the Grounduater Alternatives are permanent remedies and therefore
provide for long-term effectiveness. Grcundwater Alternative 3 (A) is
comparable to 2, 3(B), and 4 in the long-term effectiveness and
permanence it affords. These remedies involve long-term treatment of
groundwater in excess of 60 years. All of these grcundwater
alternatives would include an extraction, treatment, and discharge
system which would require long-term operation and maintenance.
Although it appears unlikely that the shallow or intermediate aquifer
grcundwaters would be used, all these alternatives would have to provide
for long-term restrictions of groundwater use of these two aquifers.
This would be done using institutional controls (i.e., dood
restrictions).
9.3.2. Soil Alternatives
A permanent remedy for the soils is feasible at the Kysor site. Soil
Alternative 5 affords comparable long-term effectiveness and permanence
to Soil Alternative 4. Both are permanent remedies for treatment of the
VOC soil contamination. No long-term maintenance would be required for
either alternative. Soil Alternative 4 would require limited monitoring
to verify the effectiveness of the treatment.
Soil Alternative 5 would exceed the long term effectiveness of Soil
Alternative 2. Soil Alternative 2 would minimize the amount of
contaminants leaching to the grcundwater; however, additional
degradation of grcundwater is possible. Also the surficial cap and
subsurface containment wall may require replacement after 20 to 30
years.
Soil Alternatives 3 and 6 provide very good long-term effectiveness and
permanence of the alternatives. Since excavation is being performed in
both of these alternatives the contaminants are being removed and no
long-term management would be required.
9.4. Reduction of Tenacity, Mobility, and Volume
9.4.1. Groundwater Alternatives
Carbon Adsorption would reduce the mobility of hexavalent chromium in
the extracted groundwater as would the Ion Exchange treatment. These
treatments would reduce the concentration of the chromium in the
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grcundwater to acceptable levels. The nobility of the chromium
contamination would be reduoed through the transfer of the contaminants
from the groundwater to the spent carbon and resin residuals. The Ion
Exchange treatment would produce approximately 200,750 gallons of
hazardous regeneration waste per year, while Carbon Adsorption would
produce about 15,000 pounds of spent carbon. Both of these residuals
would be disposed in offsite RCRA facilities and would not pose risks at
the site.
All of the treatment alternatives for groundwater, Groundwater
Alternatives 2, 3(A), 3(B), and 4, would reduce the mobility of VDC
contamination in the groundwater through treatment. The mobility of the
VOC contamination would be reduced through the transfer of the VOC
contaminants from the groundwater to the treatment residuals. The
differences lie in the amounts of residual hazardous waste created in
these treatment processes. Groundwater Alternative 3 (A) would avoid the
need for any off-site disposal of spent carbon consequent to thermal
regeneration of the carbon in-situ, while Groundwater Alternative 3(B)
would produce 225,000 pounds of spent carbon for off-site disposal.
Groundwater Alternative 2 would not produce a secondary wastestream or
air emissions requiring treatment. Steam stripping, Groundwater
Alternative 4, would produce approximately 84,000 gallons of
concentrated organic condensate per year requiring off-site disposal.
None of these residuals produced would pose risks at the site due to
regeneration onsite or offsite disposal.
9.4.2. Soil Alternatives
The mobility of the VOCs in the soils would be permanently reduced using
Soil Alternative 5. Through filtration of the off gases the
contamination would be transferred from the soils to residual carbon.
Comparably, Soil Alternative 4 would remove the VOCs from the soils and
transfer the contaminants to the groundwater, thus permanently reducing
the mobility of the contaminants in the soil. However, implementation
of Alternative 4 would increase the toxicity, mobility, and volume of
groundwater contaminants.
Through excavation the toxicity, mobility, and volume of the soil
contaminants would be permanently reduced in Soil Alternatives 3 and 6.
Soil Alternative 2 would not reduce the toxicity or volume of the
contaminants in the soils at Kysor. Soil Alternative 2 would however,
reduce the mobility of the contaminants through containment.
9.5. Short-Tterja Effectiveness
9.5.1. Groundwater Alternatives
The hexavalent chromium treatment options would reduce chromium to
acceptable level in 4 years. All of the groundwater alternatives would
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need an excess of 60 years to reduce VOC contamination in the
intermediate aquifer to acceptable levels.
The only short term hazards posed by the hexavalent chromium options
would be.minor construction hazards. For carbon adsorption slight risks
would be incurred when handling the spent carbon. Ion Exchange would
pose slightly greater risks during handling of the acid and caustic
solutions.
Alternative 3 (A) would provide no short-term community or worker health
impacts, again except for minor construction hazards. These hazards can
be effectively mitigated by careful construction techniques. The
workers on-site will also have appropriate personal protection.
Alternative 2 would be very comparable in short-term risks.
Alternatives 3(B) and 4 would include short-term risks associated with
the handling of hazardous waste materials. Proper safety techniques
can effectively reduce these risks.
9.5.2. Soil Alternatives
The alternative providing the best short-term effectiveness is
alternative 2. Protection provided by this alternative would be
achieved in one year. Alternative 3 could provide soil remedial
response objectives in approximately 14 months. Alternative 6 would
require about 22 months. Alternatives 4 and 5 would need approximately
2 years to reach soil remedial response objectives.
However, the alternatives which reach the soil cleanup goals the
soonest, alternatives 2, 3, and 6, also provide the greatest short-term
risks to workers through formal exposure to contaminated soils, or
inhalation of VOCs. These three alternatives also produce fugitive dust
and VOC emissions which could potentially effect workers or the general
public. Through the required proper monitoring and dust control
measures these risks can be mitigated.
Alternative 5 would also incur short-term risks to workers through
dermal contact or inhalation of dusts or vapors when drilling the
extraction wells. These risks can be eliminated through proper safety
procedures and equipment.
Soil Alternative 4 would incur the least risk of any of the soil
alternatives to on-site workers during implementation because it
involves no soil excavation and has limited potential for contact with
contaminated soils. It poses a high potential for risk to the
environment and groundwater receptors because the migration of
contaminants into groundwater is being promoted.
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9.6. I^eaentabJLlity
9.6.1. Groundwater Alternati
Both the Hexavalent Chromium Treatment options are readily implementable
at these sites and should require approximately equal *<«*« to
implement, 18-21 months. Most of this t^™* would be spent constructing
the groundwater extraction system with only a few days needed for
construction of the treatment facility. This treatment facility would
include the treatment for the VOC contamination.
All of the treatment alternatives for TOG groundwater contamination,
Groundwater Alternatives 2, 3(A), 3(B), and 4 are technically feasibly
for these sites and the equipment is readily available. Implementation
would consist of construction of a treatment facility in each case, and
would take approximately 18-21 months, again with most of the time spent
on constructing the extraction system.
Implementation of these treatment alternatives could be complicated by
the amount of piping necessary to connect all of the necessary
extraction wells to the treatment plant as well as the piping needed for
the discharge to the Clam River. The rights to place this piping across
private land mist be obtained.
9.6.2. Son Alternatives
Soil Alternative 5 would require construction of a soil gas collection
system. The hydrogeology of the Kysor site is well-suited to the vacuum
extraction of soil gas. The sandy soils present are highly permeable.
The relatively shallow water table limits the cost of well installation.
Site access would not restrict placement of wells. This implementation
would take approximately 21-27 months.
Soil Alternative 2 would require the installation of a surf icial cap and
slurry wall. A deep trench would need to be excavated to the clay
aquitard approximately 60-90 feet. Materials for construction are
readily available arid the land at Kysor is relatively flat and
accessible to construction equipment. Implementation is ^gt-iinafg«i at
24-30 months.
Soil Alternative 4 would be easily installed. A soil-flushing system is
readily available. This system would consist of a series of
infiltration pipes overlain by a coarse aggregate drainage layer, filter
fabric, and vegetated soil cover. It would require approximately 21-27
months to implement.
Soil Alternatives 3 and 6 would require excavation of all of the
contaminated soils at the Kysor site. Soil Alternative 3 would require
mobilization and installation of the thermal-stripping unit prior to
excavation. If a thermal afterburner is used some complications could
occur with the off-gas process systems. The equipment for this
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alternative is available and 24-27 months would be required for
implementation.
Soil Alternative 6 would require mobilization, construction, and
operation of the mobile on-site incinerator in addition to the
excavation of the soils. A test burn would be necessary during the
start-tf> phase to determine operational parameters. On-site
incineration often presents a material handling challenge. This
alternative would pose the greatest equipment problems, and would need
25-27 months to implement.
9.7. ODSt
9.7.1. Gzoundwater Alternatives
Cost is a major factor in deciding which of the Grcundwater Alternatives
to choose in remediation of these two sites. All of the alternatives
are protective, comply with ARARs, and provide a permanent remedy by
reduction of the contamination through treatment. There are tradeoffs
in short-term effectiveness and implementability but these differences
are not major.
Ion Exchange is slightly more costly than Carbon Adsorption for
treatment of the hexavalent chromium contamination due to the generation
of more hazardous waste for
Alternative 3 (A) is the least costly of the groundwater alternatives,
while 3(B) is slightly more costly due to generation of spent carbon for
Alternative 4 is just slightly more costly than alternative 3(B) due to
the generation of more volume of hazardous waste for off -site disposal.
Alternative 2 is the most costly of the groundwater alternatives due to
a more expensive treatment process.
9.7.2. Son Alternatives
Cost is not a determining factor in the Soil Alternatives since there is
considerable variance in the long-term effectiveness and permanence of
the soil remedies, as well as reduction of TMV, short-term
effectiveness, and implementability. However, all soil remedies are
protective and could comply with ARARs.
The least costly of the soil alternatives is Alternative 4, due to low
capital costs and maintenance. This remedy may cause the cost of the
Groundwater Alternative to increase due to a possible need for longer
operation of the chosen Groundwater Alternative.
Alternative 5 is slightly more costly due to higher capital costs, but
it has no major maintenance or operating costs.
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Alternative 2 has slightly higher capital and overall costs than 4 or 5,
and it does not provide a permanent remedy.
"Die two excavation rpmpdi.es, Alternatives 3 and 6 are by far the most
costly due to much higher capital costs. However, these two remedies
provide the most permanent remedies.
9.8. State Acceptance
The State of Michigan does not concur with the U.S. EPA's cleanup level for
Trichloroethylene (TCE) of 5 parts per billion (5 ppb). Instead, the State
would seek a TCE cleanup level of 1 ppb. U.S. EPA has examined the total
additive risk posed by the two different cleanup levels, and has found that
the additive risk level associated with the 5 ppb cleanup level is not
significantly different from the additive risk level associated with the 1
ppb cleanup level. The level proposed by U.S. EPA is within the Agency's
acceptable risk range.
However, the State does concur with the selection of Option 2, Carbon
Adsorption treatment for hexavalent.chromium with Groundwater Alternative
3 (A) for groundwater, and Soil Alternative 5 for soil as the preferred
remedial alternatives for the Nbrthernaire/Itysor sites. The Michigan
Department of Natural Resources has indicated their agreement with the U.S.
EPA's selected remedial alternatives for these two sites.
9.9. Commnity Acceptance
The U.S. EPA's preferred remedial alternative for the Nbrthemaire and Kysor
sites was presented at the start of the public g-iinipjit period through
distribution of a fact sheet and publication of a display advertisement in
the Cadillac Evening News on July 27, 1989. The advertisement informed the
public on the placement of the proposed plan and public comment FS in the
site information repository. A formal public meeting to ^craigg the proposed
plan was held in Cadillac, Michigan on August 7, 1989. Comments received
indicate that most residents are supportive of the U.S. EPA's preferred
alternative.
Several residents expressed support for the degeneration project proposed by
the Oogeneration Michigan Associates (CKA), pursuant to when the contaminated
groundwater would be treated and used in the Degeneration plant. The Agency
is keenly aware that the Cogeneration project holds strong possibilities for
supplementing or substituting for all or part of the Agency's proposed
cleanup activities at the Northernaire and Kysor sites. However, the
Agency's primary interest is in accomplishing a proper environmental cleanup,
and while the Oogeneration project has other important aspects (i.e. jobs,
economic benefits to the City), these aspects lie outside the scope of
CERdA. At this time it is too soon for the Agency to focus on Oogeneration
as a preferred remedial alternative. However, should the Cogeneration
project advocates demonstrate to the Agency's satisfaction that the
Oogeneration project will adequately treat the groundwater to meet the
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Agency's specifications, then the Agency would consider a proposal for the
Oogeneration project to work with the Agency to meet cur environmental goals.
At this t?me the Agency is not informed as to the actual details and
specifications of the Oogeneration project.
10.0. THE -«aa H
on the findings of the Rpmfvlial Investigation and the Feasibility
Study, and the evaluation of the nine criteria, U.S. EPA has identified
Groundwater Alternative 3 (A) as the selected remedial alternative for the
cleanup of the groundwater contamination at the Nbrthernaire and Kysor sites.
This alternative will include Option 2 (Carbon Adsorption) for treatment of
the hexavalent chromium contamination. Soil Alternative 5 has been
identified as the selected remedial alternative for cleanup of the
contaminated soils at the Kysor site. In the judgement of the U.S. EPA,
these alternatives, Groundwater Alternative 3 (A), Option 2, and Soil
Alternative 5 represent the best balance among the evaluation criteria and
satisfies the statutory requirements of protect iveness, compliance with
ARARs, cost-effectiveness, the utilization of permanent solutions and
treatment to maximm extent practicable.
The major components of the selected remedy consist of the following:
* Taking appropriate action to ensure that current or future
landowners do not use the contaminated groundwater aquifers as a
of drinking water. Activities at the Kysor site will be
itrolled to prevtait new contaminant releases from the site by
building on or excavating «nii froa tlie site.
* Constructing a fence around the Kysor site to prwtaiL trespassing.
* Construction of a groundwater extraction and treatment system.
This system shall consist of a number of extraction wells
*•*! r «*t***j i
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treatment. This treatment will meet the remediation goals for cleanup of the
groundwater (page 24) and soils (page 25) as outlined earlier in this
document.
These alternatives also address all remaining public health and environmental
threats posed by the contaminated soils and groundwater at the sites.
Based on the RI/FS U.S. EPA has concluded that Groundwater Alternative 3 (A)
with carbon adsorption treatment for the hexavalent chromium, is the best
choice for remediation of the groundwater at the Northernaire and Kysor
sites. However, all of the other treatment alternatives are permanent
alternatives, easily implemented treatment technologies, and would be
acceptable remedies but for their lack of cost effectiveness. U.S. EPA has
also concluded, based on the RI/FS that Soil Alternative 5 is the best
alternative for remediation of soils at the Kysor site.
10.1 Extraction, Treatment, and Discharge System
An extraction, treatment, and discharge system will be designed for the
Northernaire and Kysor sites to reduce groundwater contamination to
acceptable levels.
The extraction system will consist of approximately 10 pumping wells for
extraction in the shallow and intermediate aquifers. These extraction wells
would be strategically located to intercept contaminated groundwater (Figure
10.1). An underground piping system would interconnect the extraction wells
and transport the extracted groundwater to the hexavalent chromium and VOC
treatment facility. To install the collection piping, existing on-site
utilities would have to be considered. Water, sewer, storm, natural gas,
electrical, and telephone lines run underground throughout the sites. Exact
locations of these utilities would have to be identified before construction
activities. The collection piping would have to be located at least 10 feet
from existing water supply lines and en the opposite side of the street,
where possible. The existing roadways generally have a 66-foot right-of-way,
and several roads within the industrial park have a 10-foot utility right-of-
way on either side of the road. These areas should be utilized to lay the
piping. The appropriate rights-of-way would have to be attained prior to
construction activities. Installation of collection piping would take
approximately three months. Installation of the extraction wells would take
approximately two weeks per well, or 20 weeks for 10 wells. Approximately
8800 feet of pipe would be required to interconnect the system. Force mains
and gravity sewers would be used, depending on topography of the area where
piping is to be laid. Submersible pumps would pump groundwater from each
well into a manhole (when discharge fron well flows into a gravity sewer),
where it would then enter the collection piping. The system would be
designed to transport all flow to an enclosed wet well inside the treatment
facility, which would be situated east of Holman Street, north of its
intersection with Frisbee Street. The facility would house equipment for
both VDC and hexavalent-chrcmium treatment systems (Figure 10.1) Actual
specifications of the extraction, treatment, and discharge system will be
determined during the remedial design phase of the project.
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The Michigan Safe Drinking Water Act 399 shall be complied with during this
design phase and the Michigan Department of Public Health shall be consulted
before any final designs are implemented. Care shall be taken to see that
fugitive dust emissions do not exceed the FM10 standards under the OVA. -
NAAQS (40 era 50), during construction of the extraction, treatment and
discharge system.
As a component of the grcundwater treatment alternatives, treated water would
be discharged to the dam River. Discharge to the river shall require
construction of a force main constructed of polyvinyl chloride (FTC) piping.
Approximately 6000 feet of piping would be required to discharge the treated
water. The discharge point (Figure 10.2) would be located on the dam River
at its junction with River Street, on the northern side of River Street and
the western side of Mitchell Street.
Discharges to surface water shall comply with several federal and state
requirements. Michigan is authorized to administer the NPDES permit program
which governs discharges to surface waters. Under the Michigan Wastewater
Discharge Permit Rules (MWDPR), MDNR has established technology-based
discharge levels for total vOCs and hexavalent chromium to the dam River
(page 26). The proposed grcundwater treatment technology is expected to
reduce concentrations of VOCs and hexavalent chromium to the discharge levels
established by MCNR. Because discharge will occur on-site, a Michigan
Wastewater Discharge Permit is not required but the substantive requirements
of this permit will be met. In addition, routine completion of monitoring
records mist be performed in accordance with MWDPR 323, Part 21.
A grcundwater sampling and analysis program shall be developed to evaluate
the effectiveness of the remediation by grcundwater extraction. The purposes
of the monitoring program are to (1) assess the amount of contaminant
reduction near the center and at the edges of each identified plume by
sampling grcundwater from monitoring wells at these locations; and (2) ensure
that contamination is not migrating in the direction of regional grcundwater
flow. This would be accompli shad by obtaining water level measurements to
determine grcundwater flow directions in the plume areas toward the
extraction wells. Grcundwater sampling shall occur quarterly for the first
year, after which the sampling shall be reduced to an annual frequency.
Using periodic grcundwater monitoring and sampling, the effectiveness of the
designed system can be evaluated and pumping conditions changed as required.
This periodic sampling is a necessary phase of the remedial alternative to
evaluate progress toward reaching clean-up objectives. This grcundwater
monitoring would be consistent with RCRA Corrective Action Monitoring (40 CFR
264.100).
Grcundwater treatment will continue until the cleanup standards disnissad in
Section 9 are achieved.
All on-site remedial activities will be conducted in compliance with OSHA
Standards for the Hazardous Waste Operations (29 CFR 1910).
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10.2 Hexavalent ChromiuM Treetaent
The extracted groundwater would be treated to reduce the hexavalent chromium
contamination using a carbcn adsorption treatment. In this treatment the
activated carbcn matrix selectively adsorbs hazardous organic constituents
and certain metals such as chromium by a surface attraction phenomenon that
binds inorganic (or organic) molecules to available carbon sites (i.e.,
internal pores). Carbon adsorption with granular activated carbon is usually
accomplished in down-flew contactors, arranged in series to obtain high
levels of removal and to increase operating times. This carbon adsorption
system shall consist of two carbon adsorption beds operating in series
(Figure 10.3). It is estimated the hexavalent chromium contamination could
be reduced to acceptable levels in 4 years assuming 90% efficiency of the
treatment system.
Construction and operation of the proposed treatment system shall be in
compliance with RCRA regulations for Environmental Performance of
Miscellaneous Treatment Units (40 CFR 264, Subpart X). In general, these
requirements state that the proposed treatment system should be protective of
public health and the environment, and prevent releases and migration of
contaminants to environmental media; waste analyses and trial tests should be
performed; and all equipment and materials must be decontaminated prior to
closure.
This treatment will produce spent carbon which mist be handled as a hazardous
waste. The spent carbon will be transported, treated, and/or riigpng«r! of
properly according to RCRA regulations (40 CFR, 262 through 264) and the
Michigan Hazardous Waste Management Act 64 (R 299). Transportation will
occur via a licensed and permitted hagarHnig waste hauler and vehicle. Final
disposal will occur in a fully permitted RCRA facility operating in
compliance with 40 CFR 264.
10.3 VOC Treatment
The extracted groundwater shall be treated for VOC contamination using an air
stripping with vapor-phase carbon adsorption method. The air stripping
treatment is the ™«« transfer of VDCs from the liquid (water) phase to the
gas (air) phase. The liquid waste would be descended through a packed tower.
Air is supplied by a blower or compressor that is introduced to the bottom of
the tower. The packing ma-tw"i*i functions to increase the area of contact
between the air and the descending liquid waste. As the liquid waste
descends through the packed tower the organics would be transferred from the
liquid phase to the gas phase. This air stripping technique shall require
treatment of gases generated during the process. This method of air
stripping shall treat the off-gases with a vapor phase carbon filtering
system. This system shall consist of tub stripping columns operating in
series (Figure 10.4). The first air stripper shall be designed to remove 99
percent of the VDCs from the liquid phase. The second air stripper shall
reduce VDC concentrations to meet the liquid-phase effluent discharge
requirements. The second stripper shall provide a 50:1 air-to-water ratio
which shall not need treatment of the off-gases. However, vapor-phase
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treatnent is required for the off-gases from the first air stripper, viiich
shall be yxTT^llgh*** by a vapor-phase carbon adsorption unit. This vapor-
phase unit generally consists of two carbon vessels: one in operation and
the other in standby mode, ftoen the first vessel reaches exhaustion, the
system automatically switches to the second vessel. The exhausted bed is
nerated in-situ by a thermal oxidizer, tfiich obtains most of its heat
from the desorption of VOC compounds from the carbon during the oxidation
process. This regeneration process negates the need for rf|-«y>«^i of spent
carbon.
Assuming a 90% efficiency rate of this treatment system it would take
approximately 29 years to remediate the shallow aquifer to acceptable levels
and 64 years to have the intermediate aquifer cleaned up to acceptable
standards.
ARARs associated with the Air Stripping system shall include the federal CAA
regulations [40 CFR 129 and the Michigan Air Pollution Control Act 348
regulations (R336) ], and potential approvals required before locating the
system on state, city, or private property. Relevant CAA regulations include
the particulate matter standards (40 CFR 50). Under the Michigan Air
Pollution Control Act 348 regulations, the air stripping treatment system
shall be considered a source of air contamination and shall necessitate
compliance with the substantive requirements for installation and operation
of an air stripping unit (R336). Michigan regulations limit fugitive dust
(usually a problem during construction or excavation phases of remediation)
and establish the maximum allowable emission rate from new sources of VOCs
based on BACT (P336). BACT is determined on a case-by-case basis through
information submitted in the permit application. Furthermore, Michigan
regulations prohibit the emission of air contaminants in quantities that will
cause "injurious effects to human health or safety, animal life, plant life,
of significant economic value, or property," or "unreasonable interference
with the comfortable enjoyment of life and property" (R336.1901).
It is possible that radiation problems can originate with air stripping
systems because groundwater can contain concentrations of radioactive radon
(radon-222) and thoron (radon-220) gases. Operations at the site will be
monitored to ensure that "there are no exposures to radiation.
10.4 Vacuum Extraction of Soils
The vacuum extraction system is an in-situ soil treatment method that shall
use a series of wells to circulate soil gas within the unsaturated zone of
the contaminated soil. A series of induction and extraction wells shall be
installed to the water table at the Kysor site. A gas induction blower
system shall force clean gases into the unsaturated zone and soil pore
spaces. These purging gases volatilize the VOCs from the soil. At the same
time, the vacuum extraction system shall be withdrawing the contaminated
gases from the unsaturated zone. These contaminated gases are treated by
emission control equipment before being released to the atmosphere.
-------
-38-
At the Kysor site, this vacuum extraction system shall include installing a
series of induction and extraction wells, control trenches, header piping,
air-circulation equipment, and air pollution control equipment (Figure 10.5).
The likely place to install the vacuum extraction and emission control system
would be out from the northwestern corner of the Kysor building, and south of
the gravel access road leading form Leeson Avenue. Topography of this area
is relatively flat and open for the installation of concrete pads to support
the vacuum extraction and emission control equipment. These site areas shall
require improvements to support the vacuum extraction system, pumping, air
pollution control equipment, and ancillary activities. The proper spacing of
the wells shall be determined from pilot testing at the Kysor site; however,
a 5O-by-5O-foot horizontal grid is typical, considering the extent and depth
of contamination.
It is estimated in two years the soils at Kysor would be able to meet the
cleanup criteria specified in Section 9 in order to prevent continuing
contamination of the groundwater.
CAA ARABS include particulate matter standards (40 CFR 50), which must not be
exceeded during construction and operation of the treatment system. Under
Michigan Air Pollution Control Act 348 regulations, the in-situ vacuum
extraction system is considered a source of air contamination; therefore the
same requirements shall apply as in the Air Stripping technique (See section
10.3).
It is possible that radiation problems can originate with vacuum extraction
systems because soils can contain concentrations of radioactive radon (radon-
222) and thoron (radon-220) gases. Operations at the site will be monitored
to ensure that there are no exposures to radiation.
The PCRA and Michigan facility design and operating standards (40 CFR 264
and R 299.9604) apply to the temporary location of the treatment unit, as
well as any final cover systems.
Spent carbon from this treatment shall be considered hazardous waste. The
carbon shall either be regenerated on-site, or collected and regenerated off-
site by a licensed facility. If carbon is not regenerated onsite, it shall
be handled as a hazardous waste and transported via a Michigan-licensed
hazardous waste hauler and licensed vehicle to a permitted PCRA disposal
facility, in compliance with 40 CFR 264.
10.5 Gtoundwater and land use Restrictions
Restrictions on groundwater use for drinking water purposes in the shallow
and intermediate aquifers, shall be placed on the Northernaire and Kysor
sites where groundwater contamination is located. There are wells,
previously used for residential consumption which are currently contaminated.
These residents are now on city water, but a check shall be made to ensure
that none of these contaminated wells are still being used for consumption
purposes.
-------
-39-
Appropriate actions shall be taken to ensure that current or future
landowners do not use the contaminated grcundwater aquifers as a source of
drinking water. Activities at the Rysor site will be controlled to prevent
new contaminant releases from the site by building en or excavating soil frcm
the site.
10.6 Reduction of Site Risks
Stringent health and safety measures shall be taken due to the heavy
equipment and intense clean-up operations during construction of the remedial
alternatives. Measures shall be taken to ensure the health and safety of
workers en-site as well as the local residents near the site.
10.7 Cost
The total estimated present worth of the remedy is $16,000,000 which includes
an annual operation and maintenance present worth of approximately
$5,000,000. These costs are based on a present worth value of 60 years and
discount rate of 5%. The costs associated with the soil remediation at the
Kysor site would be about $925,000, while the grcundwater remediation would
be just over $15,000,000. It is difficult to break out costs associated with
the hexavalent chromium and TOC treatments, as each treatment would require
the extraction and discharge systems. Also the grcundwater is so
intermingled it will be very difficult to determine what volume is
contaminated with the different contaminants.
11.0. STATUKTCf LUilWONATICKS
11.1 The Selected Remedy is Protective of Human Health and the Environment
The remedial alternatives selected for the Northemaire and Kysor sites will
eliminate current and potential future risks to human health and the
environment by the following means:
»
* Reducing grcundwater contamination by extraction, treatment, and
discharge of the contaminated grcundwater.
* Reducing soil contamination at the Kysor site by using a vacuum
extraction treatment system to remove the contaminants.
* Preventing exposure to contaminated grcundwater and soils by
restricting grcundwater and land use.
11.2 The Selected Remedy Attains ARARs
The selected remedy will meet or attain all applicable or relevant and
appropriate federal and state requirements. These requirements are listed
below.
-------
-40-
Chemical Specific
* Safe Drinking Water Act (SDWA) - Mds and for non-carcinogens for
which no MCL has been pronulgated, MOfi's (40 CFR 141.11-141.16)
* dean Water Act Ambient Water Quality Criteria (AWQC).
* RCRA Corrective Action (Subpart F).
* Health advisories as described in Table 9-1, including RfDs and
CPFs, will be used in determining risk levels where no MCXs, etc.
exist.
All of these criteria were considered when determining target cleanup levels
for the groundwater and soils, and determining discharge limits for the
effluent from the groundwater treatment facility.
Action Specific
* The Michigan Safe Drinking Water Act 399 shall be ccnplied with
during the design of the groundwater treatment plant and the
Michigan Department of Public Health will be consulted before any
final designs are implemented.
* Care will be taken to see that fugitive dust emissions do not exceed
the PM10 standards under the CAA - NAAQS (40 CFR 50), during
construction of the extraction, treatment and discharge system, and
construction of the vacuum extraction system.
* Discharges to surface water shall comply with several federal and
state requirements. Michigan is authorized to AAnjnjgtw the NPDES
permit program which governs discharges to surface waters. Under
the Michigan Wastewater Discharge Permit Rules (MWDFR), MDNR has
established technology-based discharge levels for total VOCs and
hexavalent chromium to the Clam River (page 26). The proposed
groundwater treatment technology is expected to reduce
concentrations of VOCs and hexavalent chromium to the discharge
levels established by MDNR. Because discharge will occur on-site, a
Michigan Wastewater Discharge Permit is not required but the
substantive requirements of this permit will be met. In addition to
meeting the discharge limitations, routine completion of monitoring
records shall be performed in accordance with MWDFR 323, Part 21.
* Groundwater monitoring shall be consistent with RCRA Corrective
Action Monitoring (40 CFR 264.100).
* All on-site remedial activities shall be conducted in compliance
with OSHA Standards for the Hazardous Waste Operations (29 CFR
1910).
-------
-41-
* These treatments will produce spent carixn which shall be handled as
a hazardous waste. The spent carbon shall be transported, treated,
and/or disposed of properly according to RCRA regulations (40 CFR,
262 through 264) and the Michigan Hazardous Waste Management Act 64
regulations (R 299). Transportation shall occur via a licensed and
permitted hazardous waste hauler and vehicle. Final disposal shall
occur in a fully permitted RCRA facility operating in compliance
With 40 CFR 264.
* The Air Stripping and Vacuum Extraction systems shall comply with
the federal CAA regulations (40 CFR 129) and the Michigan Air
Pollution Control Act 348 regulations (R 336), and shall need
approvals required before locating the system on state, city, or
private property. Relevant CAA regulations include the particulate
matter standards. Under the Michigan Air Pollution Control
regulations, the air stripping treatment system shall be considered
a source of air contamination and shall necessitate compliance with
the substantive requirements for installation and operation of an
air stripping unit (R 336). Michigan regulations limit fugitive
dust (usually a problem during construction or excavation phases of
remediation) and establish the ™ayimmi allowable emission rate from
new sources of TOCs based on BftCT (R 336). Furthermore, Michigan
regulations prohibit the emission of air contaminants in quantities
that will cause "injurious effects to human health or safety, animal
life, plant life, of significant economic value, or property," or
"unreasonable interference with the comfortable enjoyment of life
and property" (R336.1901).
11.3 The Selected Remedy is Cost Effective
Alternative 3 (A) with Carbon Adsorption for groundwater, and Alternative 5
for soil represents a cost-effective remedy for the Northemaire and Kysor
sites. Carbon Adsorption for treatment of the hexavalent chromium
contamination will reduce the risks from ingestion of groundwater just as
well as the Ion Exchange which is a more costly remedy. Similarly the
groundwater alternative 3 (A) will reduce risks as effectively as any of the
other groundwater alternatives at a more cost-effective value. Groundwater
alternative 3 (A) and carbon adsorption for hexavalent chromium treatment also
provide as much long-term effectiveness as any of the other groundwater
alternatives.
Soil alternative 5 will reduce risks associated with the contaminated soils
as well as alternative 2 which is a more expensive remedy and not a permanent
remedy. Soil alternative 4 is a less costly remedy and will reduce the soil
contamination risks as well as alternative 5, but alternative 4 would
increase the already significant groundwater problem which U.S. EPA feels is
too big a risk, to justify the savings in cost. Soil Alternative 5 would also
provide an excellent degree of long-term protection, compared to alternatives
2 and 4. Although soil alternatives 3 and 6 may offer slightly increased
long-term reliability the relative cost increases outweigh the expected
-------
-42-
benefits. These additional oosts are not justified based en current site
conditions and contamination levels.
11.4 The Selected Remedy Utilizes Permanent Solutions and Alternate
Treatment Technologies or TVi.ri mm Recovery Technologies to the i
Extent Practicable
The remedial action selected for implementation at the Northernaire and
Kysor sites satisfies the statutory requirements of CERdA Section 121. The
selected remedy is consistent with the NCP, protects human health and the
environment, attains ARARs, and is cost-effective. The U.S. EPA has
determined that the selected remedy represents the maxim an extent to which
permanent solutions and treatment technologies can be utilized in a cost-
effective manner for the Northernaire and Kysor sites. Of those alternatives
that are protective of human health and the environment and comply with
ARARs, the U.S. EPA has determined that this selected remedy provides the
best balance of tradeoffs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility, or volume achieved through treatment, short-
term effectiveness, uplementability, cost, also considering the statutory
preference for treatment as a principal element and considering State and
ccranonity acceptance.
The selected remedy is judged to provide the same degree of protectiveness as
the other groundwater alternatives at a substantially lower cost, which is
more cost effective.
The selected remedy will provide long-term effectiveness Iron the risks
associated with the contaminated soils at a cost less than all of the soil
alternatives except one. The one less costly soil alternative will provide
adequate long-term effectiveness, but will also greatly increase risks
associated with the groundwater contamination.
The selected remedy is comparable in short-term effectiveness to any of the
other soil or groundwater alternatives. The selected remedy will also
utilize permanent treatment technologies to reduce not only the principal
risks, but all risks associated with contaminated groundwater and soil.
While the selected remedy does not offer as high a degree of long-term
reliability and permanence as the options which excavate and burn the
contaminated soils, it will significantly reduce the inherent hazards posed
by the contaminated soils through vacuum extraction treatment.
The selected remedy does satisfy the statutory preference for a permanent
solution, however since the selected remedy will take up to 64 years to
completely reduce groundwater contamination to acceptable levels, the
effectiveness of this remedial action must be reviewed at least once every 5
years.
-------
-43-
11.5 The Selected Remedy Reduces Itndcity, Mobility, or Voline of Haste
KateriaLs as a Principal
Groundwater alternative 3 (A) with carbon adsorption for the hexavalent
chromium treatment will reduce the nobility of the contaminants within the
groundwater at the Nbrthernaire and Kysor sites. This reduction will be
accomplished by extraction and treatment of the contaminated groundwater. By
treating this contaminated groundwater the remedy addresses the principal
threat posed at the Northernaire and Kysor sites through the use of treatment
technologies.
Soil Alternative 5 will reduce the mobility of the soil contaminants at the
Kysor through treatment of the soils by vacuum extraction. This treatment
will reduce the soil contamination to acceptable levels. Therefore^ all the
threats posed at the Northernaire and Kysor sites are being remedied through
treatment technologies.
-------
FIGURES AND TABLES
All figures and tables come directly from the Cadillac Area RI,
FS, or Proposed Plan or information contained within these
documents.
-------
I-I
.
I-'1
UnONtMNM
KYSOR OF CADILLAC, INC.:
NORTHERNAIRE PLATING
qOMPANY -^ . . ;. ,
SUPERFUND SITES • '.
CADILLAC, Ml. ,
.*
MICHIGAN
-------
• Kill- ..1.4 '
LOW AQUIFER AND TOTAL
TILE ORGANIC COMPOUND
JCENTflATIONS: JUNE 1987
CADILLAC AREA f S
CADILLAC, MICHIGAN
NOnTHERNAinE PLUMES ANO
HEX-OinOME CONCENTHATinriG
MAY/JUNI tori/
C A OIL I AC AHFA f S
• " ' •!(
"* • - ' I
^-,. r-^f"! . =
INTERMEDIATE AQUIFER ANO TOTAL
VOLATILE ORGANIC COMPOUND
CONCENTRATIONS: MAY/JUNE 1987
CADILLAC AREA FS
CADILLAC. MICHIGAN
LEGEND
• rout tun wuil
• o«* vuit
o nnoninu.1
• MW. WU1« (HONfMMAMf |
0 en? wui NOWUI
• •(WNCI UXUTKM Wtllt
• OfWJIAfcVIUI
MUDMMMIU
•no* tot. i
MUD NOUNV mtUt
JJJX-
*"
CMtOUN M
MTMrMIM f lit MI O»
urrtn AOUIIAMO
«OC CONCtNINAf MM M fr*
-------
MCI'HM IOCMVI
li
ivccrnm tocnoNi
CAMIAC **«• «
CMM.LM;. MOWAM
ECJORCANCQi
-------
I o-l
UCfMO
o
•
0 en* VIA* NOUNS
m BOUMnB ifWA,
» «««(M MM. I
«• MUBMIMV
'*'!A
COUflC
«l HI MMCMll nitavl
EXTRACTKM4 SVSf EM COU-ECTKJNIW4U
CAOLLAC AREA GHOUMMMATf N STUOV
CAOAXAC. MCMGAN
ECJOWWJOQ-
-------
LfCfNO
• HMN • !•• WlUt
• ••• WtUt
O «««ON W«tit
O C«l» «Ul KMWI
IOCAINM ««. .
• MUQ •OMNQB
•• «i*nr wtut
—4
M
INSCNARGC fO CLAM MIVCM MPMC SYSTEM
CADILLAC AREA GAOUNOWATEH STUDY
CAOK.LAC. M(CI«GAM
EC JOW3AN
-------
l-'i Win- 10- \
CARBON
ADSORPTION
VESSEL
CARBON
ADSORPTION
VESSEL
EFFLUENT
(DISCHARGE fO VOC
TREATMENT SYSTEM)
PUMP
PUMP
INFLUENT
iGf.652
AC-2 : HEXAVALENT CHROMIUM -
CARBON ADSORPTION
CADILLAC AREA GROUNDWATER STUDY
CADILLAC, MICHIGAN
-, — E.G. JORDAN-
-------
I1'i KNIT
VAPOR - PHASE CARBON
ADSORPTION UNITS
PACKING
MATERIAL
PACKING
MATERIAL
EFFLUENT
(DISCHARGE TO
CLAM RIVER)
,56 52
GW-3a : AIR STRIPPING WITH
VAPOR - PHASE CARBON ADSORPTION
CADILLAC AREA GROUNDWATER STUDY I
CADILLAC, MICHIGAN
— — FC.JORDAN
-------
|0-r,
CARBON ADSORBER
roOCED DRAFT
•tCC TUN MAMFCM O
I
MDUCEDfMAfTFAN
SAMH MQ AND 1
n
SAMPIM2 AND
1 EMIRACTtONMAMTOlO
1
1
1
1
\
\
\
f
I
_-_
_
>*.* ••-
}
1
1
_
•
f
t
III
1
I
— _— _
SC-9: IN SITU VACUUM EXTRACTION
CAD8LLAC AREA FEASIBILITY STUDY
CADILLAC, MICHIGAN
-------
TABLE 5-1
CADILLAC AREA GROUNDWATER CONTAMINATION
CONTAMINANTS DETECTED
ORGANICS
NONCARCINOGENS CARCINOGENS
Acetone Chloroform
Ethylbenzene 1,1-Dichloroethene
1,1-Dichloroethane 1,2-Dichloroethane
Toluene Methylene Chloride
1,1,1-Trichloroethane Tetrachloroethane
Trans-l,2-dichloroethene Trichloroethane
Xylenes Benzene
• INORGANICS
NONCARCINOGENS
Chromium (hexavalent)
Cyanide
-------
TABLE 52
CAOIUAC AREA III
GROUNOWAIER COMIANIMATIOM IVAlUAtlOM
NORTMERNAIRE/KYSOR SUES
EXISTING MAXIMUM CONCENTRATIONS (»fl/l)
CONFOUND
1.1,1-Trlchloroethane
irant-1,2-dlchloroethylene
1.1-Olchloroethylene
i.2-Dlchloroethane
.ethylene cMorfdt
etrachloroethylene
rlchtoroethylene
hroMlu* (Neievalent)
ylena
oluene
SHALLOW
AOUIfiR
32.00
1.00
2.00
0.69
0.72
78.00
1.70
1.20
IMTERNEOIA1E
AQUIFER
1.20
4.60
0.099
t
0.24
0.17
7.50
0.001
HORTHERHAIRE
PlUHf*
0.44
0.04
0.026
0.003
2.50
0.773
TARGET
CLEANUP
LEVELS
(•9/D
0.200
0.070
0.005
0.005
0.005
0.001
0.005
0.050
0.440
0.040
REFERENCE
NCI
HCIG
CROl
MCI
Calculated
Calculated
NCI
NCI
NCIG
SNCL
Iht VOCi prtltnt ullhln Iht boundarlt* ol lh« Northernalr* pliMe are not derived fro* Northernalre; the chrowliM
Iro* northernalre and VOCi fro* other toured have Mined In the aquifer.
Cl • Na«lawa Contaminant level; NCIG • NanlaMM Contanlaiant level Goal;
NCI • Secondary'NaRlaNM Contaminant level; CRDl • Contract Required Detection level
SOU CONTAMINATION EVALUATION
KTSOR SITE
NAXINUN
CONCENTRATION
COMPOUND
TARGET
CLEANUP
LEVEL
(ppm)
Trlchloroethylene
Xylene
1,1,1-TrIchloroethane
Toluene
74
520
24
95
0.07
141.00
7.60
724.00
All Ids for soils are 10 6 rick bated levels.
NOIE: tone of contaminated soil {depth below qr«<)<•) = 6 to 25 fret.
estimated volume of soil to be remediated = M,?00 cubic ynrds.
-------
Table 6-1
CHEMICALS OF CONCOU*
COILI^C AJLEA CROWWATER STODY
1A5ELJXE *ISJC ASSESSXErT
co«gopyps
l.l.l-Triehler»«th«nt
Actton*
Toluene
Tr«nj>1.2>diehlor*ebanc
Chloroferv
l.l«DiehlorotChtne
1,2-PIehloretthane
KtehyUn* Chlorld*
Tttr«chloro«ch«ne
7* iwLlorot th«n«
Chroalva
Cyanide
-------
CADII.I.Ai: ANKA CNOIINDWATKIt STUDY: GHOIINOWATKM
L'ONPt UNf)
1. 1, l-Tricliloroethane
Trans* 1 ,2-dirliloroelhylrne
1, l-Oirhloroethylene
1 ,2-Oirhloroethane
Methylene chloride
Tetrarhloroethylene
frirhloroethylene
hroMiu* (heiiavalent )
'ylene
oluene
I AD II I.AC AHKA KKASIDILITY
ARARS (»i5/f)
STUDY
1
MCI. nci.fi Awrjc'- HEXAIR
0.2 0.2 18.4 0
- 0.07*- - 0
0.007 0.007 0.00033
0.005 0 0.00094
0.00019 0
0"'* 0.0008
0.005 0 0.0028 153
0.05 0.12*-- 0.05
0.44**
2.0-'* .14.3 0
.017
.048
--
--
.078
--
.0
--
--
.042
Nf ISTINC MAXIMUM CONCtMTKATIOMS («g/l)
UPPER
DUIKER
J2.0
--
1.0
2.0
0.69
0.72
78.0
_ .
INTERNEOIATC 1
At/Ill FER
1.2
4.6
0.099
--
U.24
0 17
7.5
(ORTIIEKNAII
PLUMt1
0.44
0.04
0.026
—
--
O.OOJ
2.5
0.77J
1.7
0 0111
AWQC are adjusted for drinking water exposure only (IJSKI'A, I9H6) or talculdlcil for water and fUli infection If
drinking water exposure value iloi-s not exisi .
Proimsed levels.
.it- i/OCs present ujlliin ilie Ixiiniiljr ttm o| ilic Norlli.. rn.n n- (ilmm- are nol ilriivrd 1 1 urn NortlieriMi i «.-, tlie cliroaJun from
Vor'liernai re anil VOCs (rum ollirr sour««'i liavi- I»IN
-------
ROUNDVATCR INGEST ION
3HCARCINOCENIC EFFECTS
TABLE 6-1
RISK CALCULATION SUMMARY
NORIHERNAIAE/KYSOR SI US
SHALLOW PLUME
(PRESENT)
4NPOUNO
t.t-lrlchloroethane
luene
• ton*
wary of Naiard Indicts
HAZARD INDEX
MAXIMUM
CONCENTRATION
(ug/l)1
52000.0
3?00.0
920.0
AVERAGE
CONCENTRATION
*
1102.0
129.4
44.5
MOST PRO! All E
CHILD ADULT
1.01 1.01
0.01 0.01
0.01 0.01
WORST CASE
CHILD ADULT
10.41 10.61
0.10 0.10
0.26 0.26
1.06
1.06
11.20
11.20
RCINOCENIC EFFECTS
CANCER RISK
1POUNO
1-DlcMorotthtne
•rachlorotlh«nt
Uhlorotthtn*
oroforn
•Olchloro«lh*n«
hyltnt Chloride
««rx of Cancer Rltk
MAXIMUM
CONCENTRATION
(ug/l)
1000.0
720.0
78000.0
15.0
2000.0
890.0
AVERAGE
CONCENTRATION
(ug/l)
91.9
64.6
2879.4
0.4
104.4
11.9
MOST
CHILD
2.22n10-4
1.I4n10-S
1.29n10-4
1.12«10-7
3.88*10 5
1.04x10-6
MOIAILE
AOUL T
1.S6n10-l
9.41n10-l
9.05x10-4
9.26n10-7
2.71*10-4
7.26x10-6
WORST
CHILD
2.17*10-1
1.90*10-4
1.30*10-]
4.96*10-6
7.41*10-4
2.11*10-5
CASE
ADULT
1.66*10-2
1.05*10-1
2.45*10-2
1.47*10-5
9.20*10-1
1.48*10-4
4.05x10-4 2.81x10-1 6.79*10-1 4.75*10-2
E: MaxInuRi concentrations were used to calculate Moral case acenarios.
Average concentrations were used to calculate most probable scenarios.
-------
OUMDUAIII IHCfSTIOM
NCARCINOCENIC IMECTS
tABU 6-4
RISK CALCULATION SUMMARY
NORTHERNAIRE/KTSOR SITES
INTERMEDIATE PLUME
(PRESENT)
HAZARD INDEX
NPOUND
1,1-TrlcMorotthant
lu«n«
• ton*
an«-1,2-Olchlorotthtn*
M«ry of Natard Indict*
RCINOGENIC EFFECTS
IPOUNO
1-OlcMoroath«n«
iracMorotthtnt
Ichlorotlhanc
'. or«lora
,hyltn« Chtorldt
of C«nc«r Risk
MAX 1 NUN
CONCENfRAIION
(ug/l)1
1200.0
1.0
«20.0
4600.0
HA 11 MUM
CONCENTRATION
(ug/l)
99.0
17. 0
7500.0
4.0
240.0
AVERAGE
CONCENTRATION
(ug/l)2
185. 2
0.0
J5.9
419.0
AVERAGE
CONCENTRATION
(ug/l)
12.0
0.8
2251.7
0.2
15.1
NOST PROBABLE
CHILD ADULT
WORST CASE .
CHILD ADULT
0.06
0.00
0.01
5.99
6.06
0.06
0.00
0.01
5.99
6.06
0.40
0.00
0.04
65.71
66.15
0.40
0.00
0.04
65.71
66.15
CANCER RISK
WORST CASE
CHILD ADULT
NOST PROIAILE
CHILD ADULT
2.84x10-5 1.99n10-4
1.67i10-7 1.17*10-6
I.OlKlO 4 7.08x10-4
6.61x10-8 4.61x10
4.62x10-7 3.24x10-6
1.10x10-4 9.11x10-4 5.81x10-4 4.08x10-1
4
6
4
7
6
2.14x10 4
5.54x10-6
S.)7x10-4
1.12x10-6
7.15x10 6
1.64x10 1
2.48x10-1
2.16x10-]
9.26x10-6
5.14x10 5
IE: Maximum concentrations were used to c*lcul«te wont c«se scenarios.
Average concentrations were used to calculate most probable scenarios.
-------
TABIE 6-5
RISK CALCINATION SUMMARY
NORTHERNAIRE/KTSOR SUES
NORINERMAIRE PIUNE
(PRESENI)
OUNDUATER INCEST ION
NCARCINOCENIC EFFECTS
:IPOUND
MAMlNUN
CONCENfRAIION
(ug/l)1
AVERAGE
CONCENIRAIION
(ug/l)2
HAZARD INDEX
NOST PROBABLE
CHIIO ADUlf
WORST CASE
CHIIO ADULT
an I da
1,l-lrlchloroethane
ans-1,2-0tchloro«thtn«
771.0
22.0
4(0.0
40.0
101.9
0.0
44.6
2.4
0.59
0.00
0.01
0.03
0.59
0.00
0.01
0.01
4.42
0.02
0.15
0.57
4.42
0.02
0.15
0.57
•try of N«iard Indlcti
0.64
0.64
5.16
5.16
CINOCENIC EMCCTS
POUND
MAXIMUM
CONCENTRATION
(ug/l)
AVERAGE
CONCENTRATION
(ug/l)
CANCER RISK
NOST PROIAIIE
CHILD ADULT
WORST CASE
CHILD ADULT
-OlcMorotthtn*
rachlorotlhant
chlorotthtnt
26.0
1.0
2500.0
1.7
0.1
201.7
4.02x10-6 2.82x10-5
2.08x10-8 1.46x10-7
9.06x10 6 6.14x10 5
6.16x10 5 4.11x10-4
6.24x10-7 4.17x10-6
1.12x10-4 7.86x10-4
\»ry of Canctr Risk
1.11x10 5 9.T7x10-5 1.74x10-4 1.22x10-1
Neil
concentration* uere used to calculate wont case scenarios.
Average concentrations were used to calculate nost probable scenarios.
-------
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-------
OUMDUATEI IHCESTIOH
NCARCINOGENIC EFFECTS
TABLE 6-7
RISK CAICUIAIION SUMMARY
NORTHERNAIRl/KTSOR SUES
SHAILOU PLUME
(FUTURE)
IMPOUND
1. t-Trlchloro«thant
lutnt
•awry of Natard Indices
1.1-Trlchlorosthant'
ns-1.2-0lchloroeth«n«
Mary of Natard Indict*
MAXIMUM
CONCEN1RATION
(ug/l)1
1066.0
MO
2119.0
1792.0
5.0
AVERAGE
CONCENTRATION
-------
OUNOUATE* INCIIHOH
•CARCINOGENIC EMECTI
CINOCENIC EFFECTS
TABU 68
RISK CAICUIATION
NORINERNAIRE/KTSOR SUES
INIERNfDIAIC PlUMf
(FUfURE)
HAZARD INDEX
JPOUNO
1.1-f>lcMoro«th«n«'
:n»-1.2-0Iehloroethen*
MAXIMUM
CONCENtRATION
(ug/l)1
132.0
1700.0
600.0
AVERAGE
CONCENTRATION
.2
49.0
665.0
m.o
MOST PROSAllE
CHIID ADUIT
0.02
9.SO
1.69
0.01
WORST CASE
CHIID ADULT
0.04
0.04
9.50 17.14 17.U
0.70 1.4) J.4J
CANCER RISK
POUND
hyUnt CM or I da
chloroelhana
MAXIMUM
CONCENTRATION
(ug/l)
70.0
2140.0
AVERAGE
CONCENTRATION
(og/l)
sa.o
1200.0
MOST PROIAIIC
CHILD ADUIT
1.16x10-6 8.14*10 6
5.3fl«10 5 3.77N10-4
WORST CASE
CM 1 10 ADULT
2.14«10-A
9.61«10-5 6.73«10-4
of Cancer Risk
5.50x10-5 3.84x10 4 9.82x10-5 6.88x10-4
;hloro*lh«n«
1740.0
6730.0
585.0
2450.0
1.22x10-4 1.36x10-4
1.10x10-4 1.11x10-4
3.62x10-4 2.54x10 3
3.02x10-4 2.12x10-3
•ry of C«nc«r Rltk
2.32x10-4 2.48x10-4 6.64x10-4 4.65x10-3
Minimum concentr«»loni were u«cd to cclculate worst c**e scenarios.
Average toncenlrcl Ions were used lo calculate xiojl probable scennrioi.
3 these are risks associated with the four Star plume In the Inlcrmedinte aquifer.
4 Ihese are risks •ssoclnlfd with the chromium plume in the Inl ei mc
-------
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-------
Table 9-1 (continued)
to tin i u AnioN-irtciric AJUI*
CAD I LUC Mil II
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• ••I I* • fOTW. Ik* fOTV •uil k«»« *• «f»t«>*4 »«ll««ll»**t
Tk* c*llicll>« ifili* «il*r foilllf mil k* !•
lik lk« if*>«»t4 >f«|>i«. fcUf I* 4l*(k«f|U|t
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|i*««lflc ••*• »l M •<•/•' i«4 • <•*•!•««) lt-k*»r
C**C**ll«IU* *l tO •|7«> (>i|Mif *l**4*i4l).
Ik* t*w>*l *r
*l*fi|* !•••• v*nl4 t«l»U« Ikl*
• k* c***!4«f«4.
-------
T.ililr ''- I (« mil iiiiiifl)
nmnui •nimr-iriciric AJUIU
CADILLAC AW* •!
MUM
•>. Ml. ».«. Iftl
4fl,
Tfel*
lk*t fttk
•CTIOI TO N T/UU TO «n*lt MtMi
al!•••.
I*
f«r**MI**c* f»
l«f •l*tk*t|
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•I fOfVt
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Tkl*
f Ik*
MMI W
Ik*
far
Itltl
•Ilk
irlll k«
*
-------
APPENDIX A
-------
'/a
cm
MKIHISTSMIVS RECORD INDEX
n
SITE
Cf.DlLLf.C. KICHIMH
M1THOR
RECIPIENT
DOCUMT WE
2 89/08/07
Letter regarding
the cities' role
and position in
the clean up
D.Becker-Hayor
of Cadillac
US&PA
Correspondence
2 89/08/21
Letter concerning
questions about
cleanup and other'
related topics
K.Sttrk-CTH
u. O'Riordan Correspondence
I 89/08/24
Letter concerning
the responsible and
participating parties
in the cleanup
Satuel Bailor
D.Roycraft-HDNR Correspondence
I 8!/08/2S
Letter accoepanyitig
Kfsor Industrial
Corporation's contents
on tne Rl/FS and proposed
plan
J.Dunn .
•Harner, Horcross 4 Judd
D. Q'Riordan-USEPA Correspondence
J 89/03/20 Conents on Remedial R.Cooper & D.Skrocki
Investigation/Feasibility -ASI
Study on behalf of lour
Hians. Inc.- history,
perspective of proposed
soil and vater
reiediatioas
D. O'Riordao-USSPA Correspondence
2 81/09/05
Sunary of cements
frot public hearing
leeting on Kysor
Industrial and
Hortbernaire Plating
Superfund Sites
H.Shanks
-Black 4 Veatcb
S. Sanders-VSEPA Correspondence
5 89/09/15
Conents on the
relieved Record
of Decision draft
D.Roycraft-HDKR
S. Saoders-USSPl Correspondence
-------
:'. Ho. 2
:HS/?RAKS PAGES
rim
ADKIHISTRATIVE RECORD IKDEI
UP DATS t2
HORTHSRXAIRS SHE
CADILLAC. HICH1GAX
AUTHOR
RECIPIENT
rm
DOCHUKSBR
t 85/09/22
Cantata on the draft
Responsiveness Suiiary
tor the Ncrtheroaite/
Kysor Record of Decision
by HDHR
D.Roycraft-HDKR
S. Sanders-USEPA Correspondence.
2 SH09/2S
HOUR coteots
concerning Record
of Decision;
selection of reiedial
technology, cleanup
levels of TCS, rationale
used to support selected
reiedy, it description
of the site
D. Rector
HOUR
V.Adaikus-VSSPA Correspondence
8?/07/00 fact sheet describing:
background, results of
RI, goals of cleanup,
alternatives, and
schedule for public
conents
IISSPA
fact Sheet
2 SS/08/01
Stateient regarding
Cadillac groondttater
problem history and
proposed plan of
action
City of Cadillac
fact Sheet
(6 89/08/07
Transcript froi
Cadillac Area
Groundvater
Public Heeting
(vith HOUR, IISSPA
and S.C. Jordan)
Transcribed by
Hetvork Reporting
-A.Holtes
Heeting Rotes
375 89/06/08 feasibility Study on S.C. Jordan
Cadillac Area Groundvater
Contaiination
HDHR/USSPA
Reports/Studies
129 89/08/26
Kysor Industrial
Corporation's coiieots
Kysor Industries
Reports/Studies
-------
Ho.
3/89
s/mu PAGSS am
W RECORD IHOSI
mm 12
mmRHm sirs
CADILLAC. H1CHIGAH
Tins
CD the P.I/IS and proposed
plan for toe Cidiliic
Idustrial Park
RSCIPISM
im
DOCHMBSR
120 89/09/29
Record of Decision
'(ROD); docuieot
eipJainin? fiaai
USSfA
Reports/Studies
-------
Cf/
PIC-ES r/.rr
- umisTRims F.ECCF.L msi
SCRTESF.KIF.S SITE
c, sicsiem
F.SCIPIEK
ccmsT rr;? :::.v;
18/C4/M
1C&
1(1
J7C
Cidilhc Regional i:«i Kilcolt litli-VSEPt
Risk Issessses: F.eriev
Scrtbe-siire Site,
Cadillac, Kicbigaa.
'Cadillac Lrea
Sroaarfrater
Coatasiaatio* feasibility
Stzdr-ddillac, Kicbiqaa
Iztt'is Cslirerable fa.
1.'
Ttis Refer: p:esezis the
tesedial aczioa
obiectirts
is: tie Cadillac IS,
S.C.Jordaa Co.
target levels, and
treated jreaatater
discharge
'Cadillac Lrea
Grczadvater
Costasisatios Feasibility
Stzdf-Cadillac, Kicbigaa
later;! Celirerable Jfc. 2
42te*aat;res irrsy
S.C. Jcrc'aa Co.
c';i I
iRiR ladeatificatiaa
Checklists.'
'Cadillac irea
Srojzdrater
Coatstiaatioa Retedial
Izrestigatioa - Cadillac,
Kicbigaa. '
E.C.Jorias Cc.
E.C. Jordan Cc.
Erjce
P.efc:t$/Stydie<
«JfS
P.e?ort!/Stydies
urn
Repcrts/Stadies
Reftrts/Stydies
-------
Plft 10. 1
K/97/H
un Tint
item »miK/nn ueii
S1TI, US1LUC. I1CIKU
Siifliai/4ttt ioctitati inilitlt let rtntt it Kin
t. Chieiie.il.
UTIOI
locsniT TTPI
17/tt/tl Sieiti litat CLP Stiflt
fffljtl: SUflt It'I.
tit ii tt ii, its t its,
"11, US t 12f, 13 to It.
19 to 25, 25 111, 2( It
SI. (t IS t IS, 2, 3, (S.
HI, tt, 1, I, tS, St.
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II, 13, US, IS tt II,
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13 to il. II, t, (S. IS.
IS, 13, IS, 1(5, KB,
22, 23. If J« to 191.
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HP 1 to 7, j to 12.
17/97/13 Seceet tttai CLP Stiflt
Itialis. Stifle It's.
lt-997, J, It, 11, 13
. te It. 1-15, 11-19(7,
SUP (.
t7/97/Ol list tTtt t7/9l/CC.
Stcaii itted CLP Stiflt
Ittsltl. Stiflt It').
SLI-1 to SLI-S2.
17/97/99 Stetlt litet it CLP Siiflt
Itiilts. Siiflt It'i.
si is ti er 2t.
t7/9tf99 Stcaiil latsd it CLP Stiflt
lt$tlti. Siiflt le't.
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15, 1(, 22, 23. It 199 to
115. ISP 1 to t. Ill I to 3.
117, I to JJ, JJ to It.
tnrttt 1. tolt-tm
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trtrttt lolt-KDH
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trtrttt lilt-nil
tnrttt lolt-KSlK
Ktrj t. Castitsc-SSSPl
Sttf t. etstttitt-SHfA
Ktrj t. (utiliet-SStPH Sttflici.'ttit
far; t. tasttfiat-BSIPK Stipliai/tttt
17/11/lt Steiit lint it CLP Siiflt
tuiltt. Stiflt Stliitrj
fnif It. 32215 tut ftrni
tt I.C.JtTdti Co.
Cut fitter ril7jf.
trtrttt lilt-Ml*
fttf t. easttdaa-SStPl Sn?liai/Diti
19/99/99 leaner till i«fi.
I.C. Jiitia Ci.
Stifliai/Siti
-------
tlje It.
IS/97/1J
HTt TIKI
utitimuin ncoio swim/em im:
IQITItmilt SlTt, CUllllC, llClieil
Sttpliii/ittt ittiittti tttiltklt for ttiiti it UStf/l
l«fj«a r,
IICI/IMf
17/K/ff fine rooitf :i/ $ti?l<
rttilti. Sttflt fc'f.
ni 11« ;ii s;. si i to
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t» it tit 29. n i, 9
tt 11, 13 tt II. I 1,
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II 189 tt 114. W 1 tt
7, i tl 12. If «7,
005 C« til, 913 tt 911.
Irtrttt
itrj t. (titilioi-tStn
-------
Page No.
09/28/87
TITLE
NORTHERNSI RE
AUTHOR
DATE PAGES
Community Relations Responsive-
ness Summary
V. V. Adarnkus, USEPA
Appendix E to OSCR - Contract
Issued to Contractor
K. P. Banaszek, etc. , USEPA
11
3n-Scene Coordinator's Report
(OSCR)
K. Banasrek, USEPA
12
Summary of Remedial Alternative V. V. Adamkus, USEPA
selection
aroundwater Fact Sheet
MDNR
Appendix P to OSCR - S3
Dhotographs of Site
?ite Mgmt. Plan - Status
'eport
EPA
norganic Contaminant Analyses Michigan DNR
ab
c:S 4
etter to W.S.Garwood (NPC)
e Time Extension for PIPP
u brn i 11 a 1
D. W. Darnell, MDNR
ctice of Inoperative
crubbers
D. Darnell, MDNR
73/01/13 1
3mo to file - RE: Meeting
7 Cadillac Health Deot.
J. Heinrman, MDNR
.•tential Ground Water Con—
imination Source - Identifi—
79/11/OS
-------
Page No.
09/28/87
TITLE
NORTHERNSI RE
AUTHOR
0«TE
PGGE5
Site S*f«t_y Plan
D. Sewall, Ecol & Environment 82/05/06 5
Conversation record with
Ptty for Northernaire
B. Neuberger, USEPfl
aa/07/20 i
Site Inspection Report
P.O. Shea, Ecol & Environment 82/03/07 14
Notice Letters to Top Locker,
Northernaire and Meyer
B. Constantelos, USEPft
82/10/18 6
of Northernaire
Willard Garwood, Northernaire 82/1.1/02 1
=cterit:al Impact of Ground-
•»ater Contarn.
J. Lovato, MDPH
82/11/12 r
Bequest for Production of
Docs. Under FOIA
S. Danielson
82/12/06 1
Notice of Meeting for Response B. Neuberoer,USEPA
ions
82/12/12 1
Notice of Representation
J. Olson, Ptty for Meyer, Inc. 62/12/22 1
Appendix C to OSCR - Folio*-
Jp Letter to PRP for Verbal
•Jot i f icat ion
82/00/00 31
Appendix Q to OSCR - Sample
Appendix B to OSCR - Phone
1emos and Letters re
ificat ion
MDNR, Petrochem
82/00/00 32
Constantelos, Neuberger, USEPP. 83/00/00 8
Chronology
coo
-------
Page No.
O3/28/87
TITLE
NORTHERNAIRE
AUTHOR
DATE
PAGES
Response of R. N. Meyer to
Cleanup
James .Olson, fitty for Meyer,Ine 83/O1/12 2
Preliminary Assessment
A. Sause, Ecol & Environment 83/02/02 5
Notification of Plant
Inspect ion
B. Neuberger, USEPA
83/02/15 1
Permission to Inspect Plant
D. Sarnardich, Atty for Meyer 83/03/15 1
lite Inspection
Wester.
83/04/00 53
Decision Memo: Cooperative
agreement Proposal
V. Adamkus, USEPA
83/OS/02 1
Action Memo: Authorization
o Proceed with RI/FS
W. Hedernan, USEPA
82/06/20 2
•ppendix A to OSCR - 10 -
oint Document
W. H. Sanders, USEPA
83/06/22 8
mmediate Removal Request
ppendix D to OSCR
otice to Proceed
nort Form Contract
ppendix S to OSCR - Site
afety Plan
W.H. Sanders, USEPA
Ueston/Sper
83/06/23 9
83/07/05 11
83/07/05 8
spendix H to OSCR - Daily
jmmary CERCLA Cleanup Forms
Petrocherii
83/07/05 S£
spendix U to OSCR - Chronology
' Cleanup
83/07/O6 21
-------
3age No.
.19/88/87
•ITLE
TAT
NORTHERNAIRE
AUTHOR
DATE
PftGES
Bequest for Review of Records J. Niewiek, Hartford Ins Co. 82/07/13 2
iuthoriration for RI/FS Memo
Site Management Plan —
alender
:equest to Defend and. Provide
ove_rage
ommunity Relations Plan
I/FS Planning Meeting
rogress Report #2 and Agenda
or 3/22/84 CIC Meeting
.I.C. Meetings, Report and
ember List
afety Plan for RI/FS
ecommendation of Case to DQJ
ost Recovery
lanned Site Use by EPA
otice of Citizen Information
ornmittee Meeting
W. Hedeman, USEPA
EPA
82/08/54 7
83/12/16 1
G. Rentrop, Atty-Northernaire 84/01/23 1
EPA
E. C. Jordan, Co.
G. Simons,MDNR
84/01/25 le
84/01/21 5
84/02/12 4
G. Simons,MDNR
MDNR
V. Adarnkus, USEPA
G. Simons,MDNR
G. Sinions, MDNR
84/02/02 £
84/02/07 3£
84/02/12 4
84/02/21 1
84/04/25 1
eturn of Key to Site
G. Simons,MDNR
84/04/26 1
-------
Page No.
O9/28/87
TITLE
Citizen Info. Committee Member*
NORTHERNAIRE
AUTHOR
DATE
PfiGES
Commencement of Civil fiction
Under CERCLA by DOJ -
Recommended
C. Pr i ce
84/O6/25 1
Progress Report #3
Progress Report #3 Addendum
MDNR
MDNR
84/07/31 ei
84/08/03 1
2APP
E.C. Jordan
84/10/OO S9
3rovision of Docs.
J. Gross,DOJ
84/10/31 2
Notice of Counsel « Request for J. Kruis,Atty for Meyer, Inc. 84/11/35 1
Docs.
Denial of Production Request
J. Kruis, fitty for Meyer, Inc. 84/12/31 1
Dffer of General Business
Records of Northernaire
J. Gross, DOJ
85/OS/06 1
Completion of RI/FS
G. Simons,MDNR
85/03/20 -2
Jpdate on Project
G. Simons, MDNR
85/03/2-3 2
U Draft
E. C. Jordan Co,
B5/O4/00 121
notice of C. I.C. Meeting
G. Simons,MDNR
85/04/10 1
Schedule of Activities
M. Gust of son, USEPA
>ip Repor on RI/FS and Public M. Gustofson, USEPA
nfo. Meetings
85/04/2S 2
85/04/30 2
-------
3age No.
33/28/87
TJTLE
- Phase XI Vol. 1 and 2
Report on C. 1. C. Meeting
NORTHERNAI RE
AUTHOR
E. C. Jordan Co.
G. Simon*,MDNR
DOTE PfiGES
83/05/00 760
85/06/10 1
Request to Receive and Inspect J. Kruis, fltty for Meyer, Inc. 85/06/27 1
)ocs.
rocused FS Draft of Proposed
Source Control Measures
E. C. Jordan Co.
85/07/00 120
ion to Northernaire
May Be PRP
nnounceriient of Publ ic
eet ing
regress Report *4
genda of Public Meeting
espor.se of Cadillac to Source
ontrol Measures
B.C. Ccr.stantelos, USEPP
T. Stong,MDNR
MDNR
MDNR
85/07/C5
85/07/23 £
85/07/23 3
85/07/30 1
D. Rennie,Cadillac Uti 1 Dept. 85/08/06 2
equest to Proceed with
irk Plan
G. Simons, MDNR
85/OS/OS 1
rour.dwater Clean-Up Ouestior.s
on Public Meeting
eport on Citizen Info.
jmr.iittees (C. I.C. )
G. Simons, MDNR
G. Simons, MDNR
T. Stong,MDNR
85/08/15 1
85/08/15 2
85/03/03 £
equest for Site Access
G. Simons, MDNR
85/03/03 3
-------
Page No.
O9/28/S7
TITLE
NORTHERNAI RE
AUTHOR
DATE
PAGES
ROD
V. Adamkus, USEPA
85/03/11 2
Continued Investigation
G. Simons,MONR
85/10/18 1
Prelim. Design Docs, for
Source Control
R. Koster, E. C. Jordan
85/11/14 9
Request for Extension RI/FS
G. Simons,MDNR
85/12/02
R. W. Meyer, Inc. as Record
Owner of Property
D. Benson, Atty for Meyer, Inc 86/02/20 1
Grant Amendment Request
W. Marks, MDNR
8£/0£/27 4
ladillac's Recommendat ion For
Replacement of Sewer w/Map
B. DeUlitt, Cadillac City En=. 86/02/05 2
Outline for R. D. Specs
J. At we 11, E. C. Jordan Co.
86/03/17 6
Vogress Report *5
MDNR
86/04/15 2
Bequest for Docs.
J. Kruis, Atty for Meyer, Inc. 86/04/21 2
"DNR Request for bid for E. C. Jordan Co.
Remedial Action at Northerr.aire
• ite
86/05/00 213
:esponse to Request by
'ort hernia ire Atty's
G. Simons, MDNR
86/05/08 2
equest to Discharge Decon'd
aste into Cadillac Sewer
yst e«n
G. Simons,MDNR
86/05/29 2
-------
Page No.
09/28/87
TITLE
a
NORTHERNSIR£
AUTHOR
DATE
PfiGS:
Remedial Design Technical
Specs.
Report on Supplemental RI
Request for Time Extension
3ublic Notice - Progress
Report *6
. of Engineers - Army
:.eport or: Public Meeting
R. Koster, E.G. Jordan
G. Simons, MDNR
G. Simons, MDNR
MDNR
S. Carlock, U.S. Army COE
G. Simons,MDNR
86/06/2:5 33
86/07/11 1
86/07/21 1
86/08/11 2
as/os/:i s
86/08/20 1
ep. Subpoena to R. Bowden USEPA R. Trernp,Atty -Cty of Cadallic 86/08/27 £
'reduction of Docs.
".orps. of Engineers - Army
orn merit s
eceipt of Copy of 0. S. C. * s
ernoval Action
DNR Progress Report
ewer Replacement
tat us Questions
ite Mgrnt. Plan - Status
eport
onfirrnation of Filing —
upplenienta 1 Memorandum -
o be A1 * r.(«T»H ff.-»-' ••>
S. Carlock, U. S. Army COE
J. Malm, U.S. Army COE
MDNR
R. Hoster, E. C. Jordan Co.
86/09/04 4
86/10/07 i
86/10/23 3
86/11/05
J. Kruis,Atty for Meyer, Inc. 86/12/03 1
EPA
R. Oakley, U.S. DOJ
86/12/03 2
86/12/08 1
-------
Page No.
O9/28/87
TITLE
NORTHERNSIRE
AUTHOR
DATE PflGES
Response to Questions
Supplemental RI
G. Simons.MDNR
E. C. Jordan Co.
86/12/12 i
87/01/00 1 IS
Scheduling of Meeting to Set
Oep.
B. Neuberger, USEPA
87/04/0£ 1
Notice of Deps: Rennie,
Darnell and Bole M/Proofs
sf Ser.
Jo Kruis, Atty for Meyer, Inc. 87/04/07 5
3ep. Subpoenas to Darnell and
Boles - Copy
E. Bole, MDNR
87/04/14 2
J. S. Dist. Court - West Dist.
11 — So. Div. Opinion on
lotions
D. U. Hillman, Chief Judge 87/04/20 13
J. S. Dist. Court - West Dist. D. W. Hillman, Chief Judge
U — So. Div. Order on Motions
87/04/20 2;
Jork Plan for RI/FS
E. C. Jordan Co.
87/05/00 18£
isfication M/Named
s.
R. Trernp, fltty-Cty of Cadillac 87/02/01 1
)iscussion on FS
•nadequate Notice of Dep.
Cancel 1 at ion
M. Bustafson, USEP«
R. Oakley, DOJ
87/OS/20 1
87/05/20 1
• ite Mgmt. Plan
eport
- Status
EPA
87/06/01 3
Kttvr on FS
-------
Page No. 10
O9/28/87
NORTHERNSI RE
TITLE AUTHOR DATE PAGES
fc
Demand for Payment of Removal R. Oakley, DOJ 87/07/07 3
*osts --
Site Mgmt. Plan - Status EPA 87/07/16 3
Report
-------
10.
9J/12/U
fDiDAici oocmirs noa-svmmit to rat jo/misrmw
mow vmtt iiofi rot rat lommuii sin
CWUAC, HicaiGii. Docwiirs aw ior mi conto.iar MI
miimt rot mm M m VSIPA me.? orncis,caeo.,ii.
tmt unoi nil
Jaterii faidaace ta CoapJiaaee vita JppJieaaJe or feieraat tad 52 It J245J 37/U8
JppropiJti
luaraact fits for Super/and (Drift). 05m 11M.1-M
Sootrtoai ConooJtf ttlttioai ttlier. OSm J2JOJ-02
laterii Cairfiacc Oo CoipJiioee Vitt ^ppJieiiJe Or fcJeriot /lo^ppropijt« l!«fairei Mi. 1-12
CtKU Cttolittct nth Otter Lmi JTaoual Koluif III (Draft;. 05HJI J2J4J-DJ
Biaml ttr Suotrtuai Couaaitj ttlititas Caatnctot 5upporc (Draft). 05m 5242.5-01
Standard /i«Jd Opcntiaj Safttf 5uid< Kaoual, Kaouai /4 • Sit< tatrj, Kiaml II • 05m
Secoattaiaitioa at Itsooait ftisoaatl, Haanal
if • latl loan, tad liaaiJ n • Site Safetf tlta.
Saperfaod Public Sttlth Inlaatioa Kiautl. OSHt 5235.4-01
5nper/Bfl(J faftlic feiltt rnJuitioa Jraauii. 05m 52J5.4-01
leiltA lueiiieoti 6f Jf5D« ia /f-«J. 05VH 5245.4-OJ
(aidaace /or Coodoctio; leiediaJ Jureitijatioos Add /(aiibiJitf 05m 5JJ5J-01
Studiti Vaitr CliCU (Draft;.
»
(ai dance oo /repiriof Superfuad Deciiiao Oocuieoti: foe 05m 5JJ5.J-02
/ropoied fiio lad leeord of Decision (Draft).
/reparation of Decitioi Docoieoti for Approrio; raad-fiaaoced 05m 5J40.2-01
lad m feiedijj Jctioas ffader CIJCU.
Sgperfoad leiediaJ Deiija Jad leiediai Hctiaa Cuidaoce (JID/^;. 05m JJ55.J-04A
Coidiaee on /eaiioiJitf Stodiej (/S) Voder CMCLA. OSKI 5J55.MJ5C
Coidaice oa leiediaJ Iareiti;atioai («I) ffader CJJCIA. OSVfl 5355.0-0(8
Data ffoaJitf Oojectirei Dereiopaeat ffoidaoce for Xeaedial 05m 5355J-078
Ieipoa«e Jctioai.
-------
2
ti/n/ti '•
OOCMIITS iioii-so?niHiiT TO m mmsmmi
ncosa mm inn 101 rat lomimin sirt
c, HICSISH, Docmirs mi HOT tin conio.sur ui
mnmi rot iinir «r m asm m.r onicis,ca
-------
rm ISCQF.O mesa
UTi'M ISHSTRUS
CMlLlf.C. HICHKM
am
rim
P.SCIPISHT
DOCUHEXT r\'FS
DOCMKfa-
89/08/01
Letter
the cities' role
and position ia
the clean up
D.Secker-Kifer
of Cadillac
Correspondence
8J/08/2I
letter coocernioy
questions about
cleanup and other
related topics
K.StarJt-CfW
P. O'fliordan " Correspondence
83/08/24 tetter concerning
tbe responsible and
participating parties
in tbe cleanup
Saiuel faiior
D.Koyctatt-HDHR Correspondence
83/08/26 Letter accoipanping
K/sor Industrial
Corporation's coiaents
on tie Rl/fS and proposed
plan
J.flUfiD
-Earner, A'orcross S Judd
D.fl'fiiordan-BSSM Correspondence
83/08/30 Coneats on Seiedial fi.Cooper £
Inrestiffation/feasioilitf -A51
5tudf on benalf of four
Ifinnsjnc: history,
perspective of propose^
soil and vater
reiediations
D.O'Riordan-(/SfPA Correspondence
83/03/05 Sattatj of co«ients
froi public bearing
leeting on Kjsor
Industrial and
tfortfiernaire Plating
5uperfund Sites
/f.i'nanJts-
BJaci 4 Keatcc
S.Sanders-l/S!PA Correspondence
8J/OS/J5
Conents on tbe
rerietet Record
S.Saoders-QSSPA Correspondence
-------
?e #0. 2
•JJ/8?
m/nm PAGES DATE
run
of Decision draft
ADKIHISTRATIVE RECORD imx
UPDATE n
HSOR INDUSTRIES
CADILLAC, HICHIGAH
AUTHOR
RECIPIENT
DOCMSHT
DOCXUHHR
4 89/09/22
Contents on the draft
responsiveness Suiiaiy
for the Northeraiire/
Kysor Record of Decision
by HOUR
S.Szaders-USEPA Correspondence
2 S9/01/28
HOUR coteats
concerning Record
of Decisions
selection of reiednl
technology, cleanup
lerels of ICE, rationale
used to support selected
retedf, 4 description
of the site
D. Rector
HOUR
V. Adatkus-USSPA Correspondence
83/07/01) Fact sheet describing:
background, results ef
SI, goals of cleanup,
alternatives, evaluation,
and schedule for public
conents
USEPA
fact Sheet
2 M/OS/07
Stateient regarding
Cadillac groundvater
problei; history and
proposed plan of
action
City of Cadillac
fact Sieet
66 8S/08/07
Transcript froi
Cadillac Area
Groundvater
Public Heeting
(ifiti Km, tlSSPA
and E.C. Jordan)
Transcribed by
Xetvork Reporting
•A.Holies
Heeting Holes
\29 89/03/26
Industrial
Corporation's conent!
on the Rl/tS and proposed
plan tor the Cadillac
Industrial Park
Kjsor Industries
Report/Studies
-------
j?e Jo. 3
.V1J/8?
ICHS/FRAKS PAGES
AOHIHISTRATIVS RECORD IHOE1
atom a
Tins
CADILLAC. HICHICAX
WHOP.
RECIPIENT
DOCUHSHT TUPS
DOCHUHSSR
375 89/06/01 Feasibility Stair en S.C. Jordan
CadiJJac Area Grouadvater
CootatiaatioD
HDHR/USSPA
Reports/Studies
120 SS/09/2)
Record of Decision
(ROD); docaient
erplaioing final
reiedf
US&PA
Seports/Stadies
-------
?S/M!
nas urt
nni
uuiisntrin ttcoto 11011
ITSOt IWSTtltS
CUILUC. IJCflCJf
HTIOI
minm
KCOKIIT mt
S If/f5/2f letter
Stt ttrrice Jilt Ctmtt«a4tt:t
IJ U/91/99
21 IS/J4/JJ
n IS/H/CS
III II/J7/M
tt fotntitl
mi rffpfet t« tie
iJt«, rtcjpjdu jre
rcfifitftf t« rtifeti
to ttt riftrft for
Jiforijtjtfi tteltttd
it tiii Jcttfr.
11 tot
Ciiilltt Itfiitil Irti
lilt i5i«>5i«ic Itrur
Itnbtrttirt Silt,
Ctdilltc,
Iir(5tjfiti«e
ieport tor ton 5:ir
Carp.
Ctiilltc,
Se»riti
'Ctdillte irei
Crooarfrttfr
Cootiiipjtioa
fe.
i'j Ifpert prtjfocj
rcictfiiJ letiea
tbjtetirtt
tar ti<
tirfet
Jraee Stiei-OSlPK Seartetat
6«sliii CiaM ttstc., ?.C. fosr Sttr Carp. ttptrtt/Staiin
tcali
t.C.Jcrtit Co.
ItptttJ/Stiditi
:titi:t»ttt:.
"Ctiillie Atti
Snttiitttr
Cottniattiti fttiibilitj
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-------
RESPONSIVENESS SUMMARY
NORTHERNAIRE PLATING COMPANY &
KYSOR OF CADILLAC, INC.
CADILLAC, MICHIGAN
-------
HATING OGNPNff &
XZ9CR CP CAOniAC, DC.
CMHLUC, MICHIQUf
The Michigan Department of Natural Resources (MCNR) in cooperation with the
U.S. Environmental Protection Agency (U.S. EPA) has gathered information on
the types and extent of contamination, evaluated remedial measures, and
recommended remedial actions at the Nbrthernaire Plating Company
(Nbrthernaire) and Ifysor of Cadillac, Inc. (tysor) sites. Several public
meetings were held to explain the intent of the project, describe the results
of investigations, and to receive comments from the public. Opportunities
for public participation in Superfund projects is required by the
Comprehensive Environmental Response, Compensation and Liability Act
(CERCXA), as amended, and the National Oil and Hazardous Substances
Contingency Plan (NCP). Comments received from the public are considered in
the selection of the remedial action for the site. This document summarizes
the comments received regarding the proposed final remedy and describes how
they were incorporated into the decisionmaking process.
The community relations responsiveness summary has five sections:
* Overview discusses U.S. EPA's recommended alternatives for remedy
of exposure to contaminated material at the Nbrthernaire and Kysor
sites.
Background on Community Involvement and comerm provides a brief
history of community interest and concerns raised during remedial
planning activities at the site.
* Public o mm rf-g Received during Public Comment Period summarizes
both oral and written comments received from the community and U.S.
EPA's responses grouped by the following topics: general comments,
IHI * iiiiienrlpri alternative comments.
* Potential Responsible Party CuuuaiLs summarizes comments received
from the PRPs and U.S. EPA's responses.
•
Michigan CNR Comments summarizes comments received from Michigan
CNR and U.S. EPA responses.
In addition, Attachment A outlines community activities performed during the
remedial response activities conducted at Northernaire and Kysor Superfund
sites.
The detailed transcript of the Feasibility Study public meeting and the
written comments are not included, but they are available for public
inspection from U.S. EPA, Region V, in Chicago. Copies are »\*t* available in
the Administrative Record at the following repository:
CadHlac-Wexford County Library
411 South Lake Street
Cadillac, Michigan
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-2-
At the ti«*» of the public commit period, U.S. EPA had selected a preferred
alternative for the Northernaire and Kyaor sites in Cadillac, Michigan. U.S.
EPA' s m.»iiiiiHniV*i alternative addressed the soil contamination problems at
the Kjscac site and the groundwater contamination problems at both sites.
The preferred alternative specified in the pim-mnod plan involved vacuum
extraction to reduce soil contamination at tysor, and pumping and treating
the contaminated groundwater. Treatment of groundwater would involve air
stripping and carbon filtration. The treated groundwater would then be
discharged to the dam River.
Judging from the comments received during the public ouuutait period, the
residents and town council of Cadillac would like to see the use of a
proposed Cogeneration facility for cleanup of the groundwater. The proposal
for the construction of a large Cogeneration facility was brought forward by
an entity known as Cogeneration Michigan Associates (CMA) . This Cogeneration
facility would use large amounts of water in its operations and CMA has
proposed to extract and treat the contaminated groundwater for use in their
Cogeneration facility. CMA's proposed treatment method would involve the use
of air stripping to cleanup the groundwater. This proposal is also supported
by at least one of the PRPs. The community in general had no objections to
the alternative proposed by U.S. EPA, but some representatives of the
ocomanity were in favor of using the Cogeneration facility to implement the
cleanup.
Camunity interest in the area groundwater contamination began in 1978 when
contamination was discovered in private wells downgradient of the
Northernaire facility. In 1980 contamination of private wells was discovered
downgradient of the Kysor facility. The major concerns expressed during the
remedial planning activities at the Northernaire and Kysor sites focused on
possible health effects Hun the contamination at the sites and the apparent
delays in getting the sites cleaned up. These concerns and how U.S. EPA
addressed them are described below:
1. Local residents were concerned with the health effects of drinking
contaminated groundwater.
Response; All residents using private wells which were
contaminated were put on city water at the State's expense. A
health study was done to determine the actual health effects.
2. Cne of the major concerns expressed by local officials and
residents regarded the perceived delays in the cleanup schedule.
Response: MCNR and U.S. EPA distributed information describing the
remedial process and the time required for remedial activities.
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-3-
This responsiveness summary addresses both oral and written comments received
by the U.S. EPA concerning the RI/FS for the Northernaire and Kysor Sites.
The comment period was held from July 27 to August 28, 1989. A public
meeting was held on August 7, 1989 at the Wexford County Courthouse to allow
interested parties to present oral and written comments.
GENERAL COMMENTS
1. Mr. Darrell Becker, Mayor of r*H-niar», Mr. Donald Rennie, City of
raHi-n^ff Utilities Director, Mr. Keith Johnson, and Mr. Samuel
Bailor commented that U.S. EPA and Michigan DNR should consider
cogeneration as a cleanup alternative.
U.S. EPA's Response; The Agency is keenly aware that the
Cogeneration project holds strong possibilities for supplementing
or substituting for all or .part of the Agency's proposed cleanup
activities at the Northernaire and Kysor sites. However, the
Agency's primary interest is in accomplishing a proper
environmental cleanup, and while the Cogeneration project has other
important aspects (i.e. jobs, economic benefits to the City), these
aspects lie outside the scope of CERCLA. At this time it is too
soon for the Agency to focus on Cogeneration as a preferred
remedial alternative. However, should the Cogeneration project
advocates demonstrate to the Agency's satisfaction that the
Cogeneration project will adequately treat the groundwater to meet
the Agency's specifications, then the Agency would consider a
proposal for the Cogeneration project to work with the Agency to
meet our environmental goals. At this time the Agency is not
informed as to the actual details and specifications of the
Cogeneration project.
2. Mr. Samiel Bailor had questions on the acute and latent effects of
the existing site contaminants. Mr. Bailor also questioned the
ability of the area forests to g«*-Mr> a project such as
iration.
U.S. EPA's Response; Each of the contaminants discovered at the
Northernaire or Kysor sites may exhibit certain adverse effects on
humans under certain gTrrsnnghgnogg, The risks posed-by these
contaminants were thoroughly studied during the "risk assessment"
which was nnnrtiicteri as a part of the Remedial Investigation (RI).
The risk assessment itself contains specific information on the
actual assessment of the risk and the toxic effects of each
individual contaminant. Nevertheless, it is the Agency's
obligation to remedy these sites so that the public health and
welfare are protected from adverse risk, and the selected remedy is
designed to do exactly that.
Questions relating to the raw timber required to supply the
Cogeneration plant are beyond the scope of this remedial action,
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-4-
ard are not relevant to this remedial action proposed by the
Agency.
3. MB. Mary Stark, Supervisor, Qiarter Township of Baring, had
questions pertaining to the oogeneration project, in particular:
Would contaminated soils be remedied with oogeneration?
What effects would the oogeneration have on the local
aquifers?
What would happen to the discharge from the cogeneration
plant?
Will an environmental impact study be done on the oogeneration
facility and would it be available?
U.S. EPA Response: The Agency's selected remedy for these sites
provides for cleanup of the contaminated soils near the Kysor
plant. However, the Agency is unaware if the plans for the
(Degeneration plant would have any impact on the contaminated soils
problem at the Kysor plant.
The pumping rates projected by the Oogeneration plant have not been
projected to have any significant effects on the volume of water
available from the local aquifer.
The Agency has not been made aware of all the details of the
Cogeneration project, and as a result, is not aware of the plans
from any discharge from the plant.
Environmental Impact Studies under the National Environmental
Policy Act are required in certain situations where federal funds
are used for a project. While there may be other reasons for doing
such a study, the Agency is not aware that one is required for the
Cogeneration project.
4. There were other questions at the public meeting on August 7, 1989,
which were answered at the meeting (See copy of transcript of
meeting contained in the Administrative Record).
Rim -Tf?
CCMffiNT HJklOD AND U.S.
1. Kysor of Cadillac, Inc. (Kysor) submitted a ouuitaiL pertaining to
the Kysor site being listed on the National Priorities List (NPL).
U.S. EPA's Response; Kysor submitted a comment relating to the
legal aspects of the NFL listing for the Kysor site. This comment
is beyond the scope of the present public eminent period, and the
Agency will not now respond to it.
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Kysor comments that the pertbrnance of a portion of the RZ work was
applicative and not cost effective, Kysor states that even though
it had done a nydrogeological investigation of the area surrounding
the Kysor site, the State and U.S. EPA onrrtirfflrl another
hydrogeological investigation of such of the sane area.
U.S. EPA's Response: Although some hydrogeological work had been
done by Kysor at the Kysor site, the proper Quality Assurance/
Quality Control procedures were not in place in order to assure
that the data obtained was reliable and of high quality.
Therefore, much of the hydrogeological work done by the State,
although seeming duplicative in nature, was necessary in order to
validate the previous data and fill any data gaps with reliable
good quality data. Also a number of the monitoring wells installed
by Kysor may have been installed using improper installation
techniques, thereby providing a conduit for migration of
contaminants from the shallow aquifer to the intermediate aquifer
. (see section 2.2 of ROD Summary). This necessitated the need for
installation of new monitoring wells at the Kysor site.
3. Kysor comments that the baseline risk assessment uses erroneous
assumptions in the calculation of exposure risk. First, Kysor
comments that the exposure assessment's ™nA>i« used by U.S. EPA are
flawed, and secondly, that the exposure assessment uses implausible
duration assumptions.
U.S. EPA's Response: It is the U.S. EPA's position that the models
used for the calculation of risk is appropriate for these two
sites. The environmental factors taken into consideration by the
risk assessment models included natural recharge and dispersion,
biological and chemical ctegp^fa*'^rtn t adsorption, and
volatilization. In conducting risk assessments, the standard
length of exposure used is 70 years. Wiile Kysor states that this
grossly overstates the actual duration of exposure, 70 years is the
commonly used standard which complies with the Super fund Public
Health Evaluation Manual (SPHEM).
4. Kysor states that the RI report uses inconsistent and misleading
designations for the sources associated with Four Star and Joynts.
U.S. EPA's Response: The RI states that the Four Star and Joynts
facilities are separate sources of contamination. It is difficult
to determine what the extent of contribution to the overall
contamination that each of these facilities is responsible for due
to the commingling of contaminants within the plume. For that
reason both facilities were
-------
U.S. EPA's Response: The affected aquifers in the
industrial park can and have been used as drinking water
In fact, the same aquifers underlying the industrial park are
presently serving as drinking water aouiues in the North Park
Subdivision area. When establishing ARARs it is the Agency's
policy to maintain an aquifer's useability as a drinking water
source. In this manner the affected aquifers can be used for
drinking water sources after cleanup is complete.
6. Kysor comments that the FS report erroneously applies certain state
rules and policies as ARARs, in particular the Part 22 Rules of the
Michigan Water Resources Act (Act 245) and the 10*6 policy.
U.S. EPA's Response: For a response, please refer to the response
to Comment 1 from the State of Michigan as disrussed below.
7. Kysor comments that the FS errs in the calculation of residual
risk. In particular, flawed modeling assumptions and failure to
consider numerous environmental factors.
U.S. EPA's Response: It is U.S. EPA's position that the model
used for the calculation of risk is appropriate for these two
sites (see Comment 3).
8. Kysor comments that the FS errs in setting the final groundwater
and soil target cleanup levels for toluene, tetrachlorcethylene,
1,1-dichloroethylene, and trans-l,2-dichlorcethylene.
U.S. EPA's Response: It is the responsibility of U.S. EPA through
the Superfund piujidm to provide for protection of human health at
Superfund sites. The Agency has established numerous guidelines to
meet these responsibilities. One of these guidelines is the
establishment of a risk range for total additive risk associated
with all the contaminants of concern at a Superfund site. The goal
is for the total additive risk for all contaminants to fall within
the 10*"4 to 10~7 risk range. The target cleanup levels established
at the Northernaire and Kysor sites were established in order to
meet that goal.
9. Kysor comments that the FS overestimates the requirements for the
groundwater treatment system because of the use of unreasonably
high estimates for the purge water contaminant concentrations.
U.S. EPA's Response: The requirements for the groundwater
treatment system developed in the FS are only estimates. The
actual system will be designed during the remedial design phase of
the project. However, U.S. EPA feels that the estimates developed
for the treatment system are reasonable for the site conditions at
the Northernaire and Kysor sites.
10. Kysor comments that the FS underestimates the time required for
implementation of the groundwater remedy.
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-7-
U.S. EPA's Response; Again the timn required for implementation of
the groundwater remedy is only an estimate. U.S. EPA feels this is
an accurate estimate of the time required for implementation of
this type of remedy.
11. Kysor ocoments that the PS should evaluate the accelerated purge
rate that nay be associated with the oogeneration project.
U.S. ERA'S Response: The FS is used to help decide what remedy to
use to cleanup a Superfund site, not to determine the
specifications of the chosen remedy. During the RanRdial Design
phase of the project the actual purge rates will be analyzed and
decided upon.
12. Kysor comments that the FS uses misleading terminology to identify
the extraction veil systems.
U.S. EPA's Response: It is true that the extraction well systems
in the FS are referred to as "Kysor Shallow" and "Kysor
Intermediate1*. These designations, however, were not intended to
make any implication relative to the liabilities of any party.
The designation of the well system bears a rational relationship to
the name of the site.
13. Kysor comments that the Proposed Plan is inaccurate and misleading.
In particular three issues are raised: VJiy are Northernaire and
Kysor the only sites in the industrial park mentioned as having
contamination present? ttty is the remedy just for Northernaire and
Kysor? The portion of the costs attributable to the chromium is
understated.
U.S. EPA's Response: First, this is an action being taken under
the authority of the Comprehensive Environmental Response,
Compensation and Liability Act as amended by the Superfund
Amendments and Reauthorization Act, more commonly referred to as
Superfund. The'Superfund remedial prrxjram is designed to address
Superfund sites, therefore, to the extent practicable, only the
contamination at the Superfund sites shall be singled out in the
proposed plan. However other contamination located within the
industrial park not associated with these two Superfund sites can
and is being addressed by other means. This action will only
address the contamination associated with the two Superfund sites,
Northernaire and Kysor. The groundwater contamination plume
associated with these two sites is one indivisible plume with
multiple origins, some of which are not Superfund sites (Four
Winns, Four Star, Joynts). Since this contamination from multiple
origins is commingled, all of the contamination within the plume is
being addressed by this action. The one exception is the Rexair
contamination plume which can be identified as a separable plume.
The Rexair plume is not being addressed by this remedy.
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-8-
The proposed plan does not attempt to attribute costs to any one
facility so it is erroneous to say that costs are attributed
unfairly.
14. Kysor comma its that the scope of the groundwater remedy is
urily broad.
U.S. EPA's Response; The scope of the groundwater remedy Is to
remediate the contaminated groundwater associated with the two
Super fund sites, Northernaire and Kysor. As mentioned above, seme
other sources of VOC contamination have comingled with the VOC
contamination associated with the Kysor site. In this instance it
is impossible, to separate this VOC contamination into those
portions contributed by the several different sources. The Rexair
plume is the one exception.
15. Kysor comments that U.S. EPA should reconsider Soil Flushing and
other technologies as the remedy for the soil contamination at the
Kysor site.
U.S. EPA's Response; U.S. EPA did consider soil flushing as an
alternative for cleanup of the soils at the Kysor site and it was
rejected in favor of the vacuum extraction treatment. This
decision was made by balancing the nine criteria against all of
the alternatives and choosing the best remedy, based on site
conditions. Soil flushing would add to the already extensive
contamination of the groundwater, which would increase the amount
of time required to reach cleanup levels, which is not desirable.
In reference to Kysor comments about soil composting techniques,
if U.S. EPA determines during the Remedial Design stage that the
treatment for the contaminated soils at Kysor as outlined in the
ROD would not meet the requirements of the cleanup goals, including
cost effectiveness, other technologies (perhaps including soil
composting) may be considered.
16. Kysor comments that the soils remedy for the Kysor site does not
require the use of deed restrictions.
U.S. EPA's Response: U.S. EPA feels that deed restrictions are
necessary for implementation of the soils remedy at the Kysor site.
However, the deed restrictions would only be in effect for as long
as the soil remained contaminated.
17. Kysor comments that groundwater modeling is necessary prior to
design and implementation of the remedy.
U.S. EPA's Response; U.S. EPA concurs with this comment and the
modeling will be done as part of the Remedial Design.
18. Kysor comments that the oogeneration project provides the
appropriate remedy for the area groundwater contamination.
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U.S. EPA's Response: The U.S. EPA ayiooo that the Cogeneration
project presents possibilities for a remedy for the groundwater
contamination in the f^rf-m^ Area Industrial Park. However, prior
to endorsing such a remedy, there are nary issues that oust be
considered and resolved.
19. ASI Environmental Technologies ocnaents that the treatment proposed
for the groundwater cleanup appears to be technically feasible.
However, it is scaled to address the major contamination plumes and
is not practicably applicable to the contamination for which Four
Wirtns is responsible.
U.S. EPA's Response: Since the contamination for which Four winns
is potentially responsible is cqmingled with the other
contamination plumes, in effect making the contamination one bigger
plume, it is not practical to attempt to separately treat the
potential Four Winns contamination. Therefore, the potential Four
Winns contamination should and will be addressed as part of the
larger contamination plume.
MICHIGMf CMt CUmUIES U&X1V*1*) TTJKBiS H3BLIC
AND U.S.
1. The Michigan Department of Natural Resources (MENR) submitted
letters dated September 28, 1989, which stated that MENR concurs
with the remedial technology selected for the Kysor and
Northernaire sites, but does not concur with the target cleanup
level for Trichloroethene (TCE) .
U.S. EPA's Response: The U.S. EPA welcomes the State's
on the remedial technology proposed for the sites. However, the
MENR raises significant issues regarding compliance with State
laws. MENR specifically cites Act 245, and its rules. These rules
restrict degradation of waters of the State, and apply to indirect
or direct "addition of ™a+wiai« to groundwater from any facility
or operation which acts as a discrete or diffuse
R323.2202(j). The MDNR further asserts that, "The ROD states that
the target cleanup level for TCE is the Maximum Contaminant Level
(MCL), which is 5 parts per billion (5 ppb). MENR does not support
the use of MCL's as target cleanup levels; the Department supports
a target cleanup level of one part per billion (1 ppb)."
Section 121 (d) (2) (A) of the amended CERCLA states that remedies
must comply with "any promulgated standard, requirement, criteria,
or limitation under a State environmental or facility siting law
that is more stringent than any Federal standard, requirement, or
limitation1* if applicable or relevant and appropriate to the
haTarrtniitt substance or release in question. General State goals
that are contained in a rrr"*'1(y^t*yi statute and implemented via
specific requirements found in the statute or in other promulgated
regulations are potential ARARs. Vtoere such promulgated goals are
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-10-
general in scope, e.g. a general prohibition against discharges to
the waters of the State, compliance must be interpreted within the
contex of implementing regulations, the specific circumstances at
the site, and the remedial alternatives being considered.
The U.S. EPA accepts that a nondegradation law can be an ARAR.
However, the specific regulations which implement a general goal
are key in identifying what compliance with the goal means. If a
state has not promulgated implementing regulations, then the U.S.
EPA would have considerable latitude in determining how to comply
with the goal. The U.S. EPA may consider guidelines the state has
developed related to the provision, as well as state practices in
applying the goal, but such guidance would not be ARAR.
The State of Michigan contends that Act 245 is an ARAR for this
site. A literal reading of the Act and its Part 22 Grcundwater
Discharge regulations implementing the Act indicates that the law
is prospective and is intended to prevent degradation of ground
water quality. The remedy for the tysor/Nbrthernaire sites
consists of extracting contaminated ground water, treating
(removing) the contaminants, and discharging the treated water
into a surface water body. Therefore, the U.S. EPA does not find
Act 245 and its Part 22 Rules to be ARAR. However, U.S. EPA fully
supports the State's goal to ensure that the waters of the State
are protective of the public health and welfare.
The State asserts that its 1 ppb cleanup goal for. TCE is based en
Act 245, and Part 22. Unfortunately, neither Act 245, nor the
Part 22 Rules, provide specific remediation goals for the
contaminants of concern. We note that the only discussion
regarding specific concentration levels found in the Part 22 Rules
appears in 323.2205(3) which states: "Materials at concentrations
that exceed the «av-i™«i contaminant levels for inorganic and
organic chemicals.. .which are promulgated pursuant to the safe
drinking water act 42 U.S.C. 300f, shall not be discharged into
ground waters in usable aquifers..." Therefore, even if Act 245
and Part 22 Rules were considered to be ARAR, the rules do not
provide specific criteria or numerical standards which could be
applied in establishing remedial cleanup goals.
The U.S. EPA has developed a consistent policy regarding
remediation goals for ground water. This policy may be found in
the ncrenfror 21, 1988 proposed revisions to the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). The
U.S. EPA has stated its policy that for surface or ground water
that is or may be used for drinking, Mds are generally relevant
and appropriate as cleanup standards. The basis for this policy
was that Mds are protective of human health and represent the
level of water quality that U.S. EPA believes is acceptable for
over 200 million Americans to arvame every day from public
drinking water supplies. As the enforceable standard for public
water supplies, Mds are fully protective of human health and, for
carcinogens, fall within an acceptable lifetime risk range of 1£-04
-------
-11-
to 1E-07. Vben MCLs do not exist for contaminants IdenMfjad in
the ground water at a site, the Superfund piuuiam will use other
standards, advisories or criteria to determine if the rmprmr
action will achieve a level of protection within a range of LE-04
to 1Z-07 individual lifetime excess cancer risk.
The remedy proposed for the Jtyaor/Ncarthernaire sites establishes
cleanup goals for several contaminants. For example, the MCNR, as
the lead agency conducting the VI/FS, initially proposed to use
' MCLa as the target cleanup levels for Trichloroethene (5ppb), and
1,2-Oichlorcethane (5 ppb). In addition, the MEKR used a Contract
Required Detection Level of 5 ppb for 1,1-Dichlorcethylene, and a
carcinogenic risk derived level of 1 ppb for Perchloroethylene. If
one were to express the risks poood by these contaminants, at these
concentration levels, one would find that 5 ppb of TCE represents a
lifetime, risk of 1.5E-06, 1,1-DCE represents a 8.29E-05 risk, PCE
represents a 1.49E-06 risk, and 1,2HXA represents a 1.3E-05 risk.
The U.S. EPA accepted the cleanup goals proposed by the State
because the additive risk posed by these chemicals (9.9E-05)
remained within U.S. EPA's accepted risk range. Although the MEKR
letters state: "MCKR does not support the use of MCL's as target
cleanup levels..," there is no discussion regarding the cleanup
levels for contaminants other than TCE. The State simply argues
that the MCL for TCE is unacceptable, without providing any
supporting documentation, or evidence of an overarching rationale
for selecting more stringent cleanup goals for particular
contaminants. A 1 ppb concentration level for TCE represents a
3.14E-07 lifetime risk. This risk, rtnriimrt acceptable by the MEKR
for TCE, is an order of magnitude less than the risks deemed
acceptable for the other contaminants. The U.S. EPA recognizes
that there may be circumstances %4ven individual cleanup goals may
be adjusted to ensure that a remedy provides a level of
protectiveness within the U.S. EPA's accepted risk range. The
remedy selected for the I^sor/Northernaire sites does not exceed
the risk range, so adjustments to the cleanup goals are not
required. In fact, the additive risk calculated for the sites
using a 1 ppb cleanup level for TCE simply reduces the total risk
from 9.9E-05 to 9.77E-05. Given the inherent inconsistencies
presented by the State's insistence on a 1 ppb cleanup level for
TCE at these sites, the U.S. EPA maintains that MCLs are
protective, and declines to adopt a 1 ppb cleanup goal for TCE.
2. The State comments that the (Description of the "Site" needs to be
expanded to reflect additional known sources of contamination which
are not included within the Proposed Plan but have been addressed
in the RI/FS documents upon which the Proposed Plan is based.
Specifically, the Rexair TCE plume on the east side of the
municipal well field and the contaminated soils on the Four winns'
rty require mention as to their presence and why they are not
addressed within the Proposed Plan.
U.S. EPA's Response: The Agency does not agree that it is
necessary to describe or **>ern«« contamination which is not
-------
-12-
diractly relevant to the determination of a remedy for the
Noarthernaire and tysor sites. Vtiile there nay be additional areas
of oontamination in the vicinity of the industrial park, the scope
of the superfund activities is limited to those activities
necessary to remedy only the Northemaire and tysor oontamination.
U.S. EPA supports Michigan CNR efforts to bring facilities, outside
the scope of CERdA, into compliance with the State's environmental
statutes.
The State comments that although contaminated «*->tla on the Four
Winns property are not included in this Proposed Plan, it should be
stated that each of these soil alternatives have been evaluated for
Four Winns' soils. Remediation of soils on both the Kysor and Four
Winns properties is assumed in determining the length of *Hm» to
achieve cleanup goals in the groundwater cleanup alternatives.
U.S. EPA's Response; The U.S. EPA agrees that the Four Winns soil
oontamination was evaluated in the FS. However, the U.S. EPA does
not believe that an adequate characterization was done on the
oontamination of the Four Winns soils. Without adequate
characterization of the type and extent of the soil oontamination
at Four Winns it is impossible to adequately evaluate the
feasibility of any alternatives for cleanup. Again, U.S. EPA
supports Michigan CNR efforts to bring facilities, outside the
scope of CERdA, into compliance with the State's environmental
statutes.
-------
Attachment A
OdtfJNITY RELATICK5 ACTIVITIES OCNDUCTHD
AT THE NOR3HERNAIHE AND KXSCR SUES
Fact sheets were released on the following dates to keep the public informed
on the activities going on at the two sites:
October 1983
February 1984
July 1984
August 1984
July 1985
April 1986
August 1986
October 1986
August 1988
Fact sheet to inform public of upcoming RI/FS activity at
Northernaire site.
Fact sheet to inform public of ongoing RI/FS activity at
Northernaire site.
Fact sheet to inform public of RI/FS activity at
Northernaire site.
Fact sheet to inform public of RI/FS activity at
Northernaire site.
Fact sheet to inform public of FFS/Proposed Plan for
cleanup of soils at Northernaire site.
Fact sheet to inform public RI/FS activity (xncerning
area groundwater study.
Fact sheet to inform public of RI/FS activity concerning
area groundwater study.
Fact sheet to inform public of RI/FS activity concerning
area groundwater study.
Fact sheet on RI for area groundwater study.
July 1989
Fact sheet on FS/Proposed Plan for cleanup of the
contaminated soils at Kysor and contaminated groundwater
associated with Northernaire and Kysor.
Public meeting were held on the following dates to provide a forum for the
public input, and update the public on important milestones.
February 1984
August 1984
July 1985
Public meeting to determine public concern on
Northernaire RI/FS activity.
en on
Public meeting to determine public
Northernaire RI/FS activity.
Public meeting to provide forum for
FFS/Proposed Plan for soils remedy at Northernaire.
t on
-------
-2-
August 1986 Public meeting to determine public oonoern en Cadillac
area groundwater KE/FS activity.
August 1988 Public meeting to dinruss RI for the area groundwater
study.
August 1989 Public meeting to provide forum for comment on
FS/Proposed Plan of area groundwater study.
-------
p»1t It. I
9J/12/I9
Gamut Docwirs imi-sommir ro rst muismmt
ncono opom imi in m lotrmmn sin
CKDILLKC, HICBIGM. Docmirs mi for irn COFIID.BOT m
mums rot mm AT m ustPt MS.? opucts,caeo.,ii.
urn MTBOB DATS
lattrit Sttidtoct et Coipliasee vitb Applicable or JeJeraoc tad 52 !t 324H &l/Q3f
JppropiJte
Htattact flta far Supertaad (Drift). osm J2U0.1-OS
Suptrtuad Conuaitj Itlitioai taliej. OSHS J2JOJ-02
Jaterii Guidaacc Oa Coiplitoct tit a Applicable Or Relevant UndAppropitte Xejuireieati OSVSR
(UU).
Coiplitaet litb Othtr Livi * taut I Vtlait I (Iratt). OSm HU.l-tl
CHCU Coipliiact tita Other L»»i Kiaual Volute II (Draft). OSm 12H.1-02
CItCU Cotpliaace litb Otter Ltui Haaual Vohie III (Dralt). OSm 3234.1-11}
Procedures Xaaoaj /or Super/aid ConaaJtf Htlitioas Contracts: Support (Unit). QStlR
Sttadtrt litlt Optrttiag Safttj Guide Haeual, Haatttl H - Sitt lotrj, Kaaoal 17 • OSm S2SS.l-aiB,.2-tl,-92l-l}iS:-ll5
Steootniaatioa of Ketpoost Penoaatl, Xiaual
K • fart laflei, tad Xiautl 19 • Sitt Sttttj Pita.
Saptrlaad Public Setlta Srahatioa Htautl. OSm J2S5.<-01
Suptrtuad Public aetlta Ittluttioa Xtautl. OSm )2SS.t-Cl
letlth liseititatt bf USDX ia IT-iS. OSm J255.MJJ
(aidtact /or Coadactlaq Keitdiil laitttigatioas lad fnsibilitf 05KR 933S.3-01
Studies Osier CHCU (Drttt).
»
tuidaace on Prepariai Superhad Dtciiioa DocuieoCf: Tbt OSVHt JJJ5J-52
Proposed flu lad ttcord tl Secisioa (Draft).
Preparatioa of Dtciiioa Docuitati lor Approrio; fuad-liaaaced OSVIR 13W.2-Q1
lad PUP Ktitdial tctitai Under CHCU.
Suptrtoad ttiedial Dtiiga lad ttitdial Action Guidance (Win). OSm JJ55.0-OO
Saidaace oa leaiibilitj Studies (IS) Under CMCIL OSm 5J55.fl-05C
Saidaact oa ttiedial lamtijatioai (HI) Oadtr cmiK. OSHS
Pitt Qualitj Objtctires Dtrtltpitat Guidance tor Ktiedial OStlt J3S5. 0-078
feipooie Action.
-------
ttgi to. 2
97/12/19
DocottiTs urn-swumr ro m miiismmt
mow mm imi m m mrmimi sin
c, HCBIGH. oocmirs am tor m» copitojor m
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Caidtact /or Conducting SI/IS tladtt CIKCH (Vntt). OSfSK 9J55.J-01
5tjte trceartttat Vadtr Suftrfoad Rtitdial Cooftntirt Ayrttttoti. OSHR JJ75.1-JJ
-------
Rl'iVS -SCOP.D IMS!
uwf.iE n
HSOR ISHS1R1KS
CMILL?.C. XICH1MB
'/FP.f.HS FACES D.US
RECIPIENT
ooci'Hsur ri'
89/08/07
Letter regarding
the cities' role
and position io
the clean up
D.fleder-Haj'or
of Cadillac
met
Correspondence
2 89/08/21
Letter concerning
questions afcout
cleanup and otner
reJated topics
K.Stark-CTH
D. O'Riordan
Correspondence
I 89/08/24
Letter concerning
the responsible and
participating parties
in the cleanup
Satuel Bailor
D.Rofcraft-KDHR Correspondence
1 89/08/26
Letter accoapanping
^7sor Industrial
Corporation's co«ents
on toe RI/FS and proposed
plan
J.Dunn
-(farner,
0.0 'Riordan-USEPti Correspondence
Kcrcrcss 4 Jodd
j 89/08/30 Conents on Seiedial fi.Coopsr S
Inrestiyatiofl/feasifciJitf -A5J
Studf on oenaJf of four
tfinns,Inc: history,
perspective of proposed,
soil and vater
re«ediations
D.O'Riordan-USSPA Correspondence
2 89/09/OS
Suttary of cements
fro« punJic nearin?
leetiny on ffpsor
Industrial and
/fortnernaire Plating
5uperfund 5ites
K. Shanks-
Black 4 Feaccc
5. Sanders-ffSSPA Correspondence
5 8J/0S/J5
Conents on toe
mie»ed Record
D.Roycnit-Km
S.Saaders-USSPA Correspondence
-------
Ho.
J/8?
PAGES
TITLS
of Decision draft
ADKIHISTRATIVE RECORD INDEX
mm n
HSOR INDUSTRIES
CADILLAC, H1CHIGAH
AUTHOR
RECIPIENT
TUPS
4 89/09/22
Coiients on the draft
responsiveness Suiiary
for the Horthernaire/
Kysor Record of Decision
by KDHR
D.Roycraft-KDNR
S.Sandets-USEPA Correspondence
2 89/09/28
KDHR counts
concerning Record
of Decision!
selection of retedial
technology, cJeaoup
Jerels or JCE, rationale
used to support selected
retedj, & description
of the site
D. Rector
HDNR
V. Adaikus-USSPA Correspondence
8S/OJ/00 fact sheet describing:
background, results of
RI, goals of cleanup,
alternatives, eraJuatico,
and schedule for puoJic
conents
VSSPA
fact Sheet
2 89/08/07
Stateieot regarding
Cadillac grouodvater
problei: history and
proposed plan of
action
Citj of Cadillac
fact Sheet
66 89/08/07
Transcript froi
Cadillac Area
Groundvater
Public Heeting
(vitb HOUR, USSPA
and l.C. Jordan)
Transcribed by
Hetvork Reporting
-A.Hol»es
Keeting Holes
89/OS/26 Kysor Industrial
Corporation's conents
oo the Rl/fS and proposed
plan for the Cadillac
Industrial Park
Kysor Industries
Report/Studies
-------
e He.
1J/8?
PAWS
rmj
ADHIHISTRATIVE RECORD IHDE1
UFDf.TE l\
Kl'SQR IHM5TR1ES
CADILLAC. H1CH1GAX
All f HOP.
RECIPIENT
OOCVHSHT WPS DOCHUHSS.R
J75 89/06/OS feasibility Study en E.C. Jordan
Cadillac Area Groundvater
Cootatiaatioa
KBXR/USE?A
Reports/Studies
120 8i/09/29
Record ef Decision
(ROD); docuteot
explaining final
reiedf
USEPA
Reports/Studies
-------
»«A
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HCSKUT TTPt
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-------
Jjf Ko. 2
r/OJ/l!
S PAGES BATS
THIS
MKHISTMTIVE F.tCOF.D IKCSI
HSOfl IKMSTKltS
CMILUC, K1CHIGM
HI1TSOR
RSCIP1SXT
OOCtJKEtlT. TKS
1(8 8S/OJ/00
S.C.Jordaa Co.
ladeotificitioa
Checklists.'
110 '88/08/Ot 'Cadillac f.na
t.C. Jordan Co.
Coatatiaatioo Retedial
iBTtstiqatioc - Cadillac,
Kiekican. '
urn
Reports/Studies
Reports/Studies
-------
rut it.
H/87/11
nni
UTIOl
ItCOID SkMLlK/OkH
ITSQl 1WISTUSS. CU1UAC. IICIISU
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29. tt-97, 91, 19, 11,
13 tt II. II,.(, (I, 15,
It, 13, 15, US, ISO,
22, 23. SI 199 tt 197,
197-U, lit tt 1H.
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Itstlti. Stiplt It't.
tt 11 tt (I 28.
Stctti toned tt Cif Sttflt
ttsalti. Suplt It't.
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115. BU i tt t. in i tt 3.
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Ittf 1. euttlsiB-tlSlFt Sttplitj/Stti
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Stiplitl/Bitt
-------
tt-.t it.
M/'91/13
HTI TITlt
itcoto suruie/Dm inn
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-------
Page to. .
07/12/99
GaiDAtct oocmnTs jim-si/mm*r ro m
meow mti ton m nm imsmits sin,
CADILLAC, KICSIGAt. DOCHMHS ffW *OT mi COP.ItD.BVT AM
m nnn M m OSIPA MG.I orticss,cnGo.,iL.
TIM ' AUTHOR DATt
lattiii Gaidaact oa Coiplitact with Applicable or Keleraat tail 52 IR 3219S 87/01/27
Appropitte Regaireieats. :
gailitj iitartace PLia far Softrtaai (Drift). OS11R 1200. 1-(J5
Suptrloai Conoaltj Kelatioaa Pollcj. OSISK 1230. C-02
latttii Gaidtact OB Coiplitaet titb Applicable Or ttltnat AadAppropiatt ttquirtitati OSVSR
(Am).
CtSClA Coiplitaet lit a Otatt Lars Htanil Fojou I (Dnlt). OSISK
CUCLA Coiplliace titb Other Ini Xtaatl Joluit II (Drift). OSISK 9234.1-02
CISCIA Cotflittct ftth Other Law* Kaaoal John III (Draft). OSfSK S2H.1-S3
ttoettarti Kaaaal tor Saptrtoai Conoaitj Relations Coatractor Support (Draft). CSItR 92(2.5-01
Staaiart Htlt Operating Satttj Guide Kaaaal, Kaaual It - Site tatrf, Haaml 11 - OSm 9281. 1-01S,. 2-01, -02, -
-------
io.
enmict Mcnws itou-snmmiT to rsi
item inn /off rw row noasmis sin,
• cunuc, Kmi6M. oocmirs tun IOT Bin COPIID,W m
mumi M mm KT rag asm m.r onicts,csto.,n.
rim .
Inttitl Actiaa Coitiag ttotttttts Kttatl. OSttH WS.O-IS
Stttt Int Intiitl n«)eet Kiavtl. OSUK 93H.2-01
Seiitict tor deducting RI/IS Vattr CIKCU (Dtttt). OStSK 5J55J-01
Stttt frocuriteat Hattr Soptrloat Ktitditl Cooptntiit tqtttttati. OSUR WS.1-11
-------
RESPONSIVENESS SUMMARY
NORTHERNAIRE PLATING COMPANY &
KYSOR OF CADILLAC, INC.
CADILLAC, MICHIGAN
-------
PIAEDG COMCMff £
KXSOR OP craniAC, me.
CADXLUC, MKHH3W
The Michigan Department of Natural Resources (MONR) in oocperation with the
U.S. Environmental Protection Agency (U.S. EPA) has gathered information on
the types and extent of contamination, evaluated remedial measures, and
remedial actions at the Northernaire Plating Company
(Northernaire) and Kysor of Cadillac, Inc. (Kysor) sites. Several public
meetings were held to explain the intent of the project, describe the results
of investigations, and to receive ocmnents from the public. Opportunities
for public participation in Superfund projects is required by the
Comprehensive Environmental Response, Compensation and Liability Act
(CERdA) , as amended, and the National Oil and Hazardous Substances
Contingency Plan (NCP) . Conments received from the public are considered in
the selection of the remedial action for the site. This document summarizes
the comments received regarding the proposed final remedy and describes how
they were incorporated into the decisionmaking process.
The ccoRunity relations responsiveness summary has five sections:
* Overview discusses U.S. EPA's recanmended alternatives for remedy
of exposure to contaminated material at the Northernaire and Kysor
sites.
Background on Conmunity Involvement and Concerns provides a brief
history of ucuimnity interest and concerns raised during remedial
planning activities at the site.
Public Comments Received during Public Comment Period sunmarizes
both oral and written ocoments received from the comounity and U.S.
EPA's responses grouped by the following topics: general comments,
alternative conments.
Potential Responsible Party Ccnments sumnarizes conments received
from the PRPs and U.S. EPA's responses.
Michigan CNR Conments sunmarizes ocmnents received from Michigan
CNR and U.S. EPA responses.
In addition, Attachment A outlines conmunity activities performed during the
remedial response activities conducted at Northernaire and Kysor Superfund
sites.
The detailed transcript of the Feasibility Study public meeting and the
written conments are not included, but they are available for public
inspection from U.S. EPA, Region V, in Chicago. Copies are ai«n available in
the Administrative Record at the following repository:
Cadillac-Wexford County Library
411 South lake Street
Cadillac, Michigan
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-2-
At the time of the public comma it period, U.S. EPA had selected a preferred
alternative for the Northernaire and Kysor sites in Cadillac, Michigan. U.S.
EE&'s reocnmended alternative addressed the soil contamination problems at
the Kysor site and the groundwater contamination problems at both sites.
The preferred alternative specified in the proposed plan involved vacuum
extraction to reduce soil contamination at Kysor, and pumping and treating
the contaminated groundwater. Treatment of groundwater would involve air
stripping and carbon filtration. The treated groundwater would then be
discharged to the ^1*™ River.
Judging from the connents received during the public ooanent period, the
residents and town council of Cadillac would lite to see the use of a
proposed Cogeneration facility for cleanup of the groundwater. Ihe proposal
for the construction of a large Cogeneration facility was brought forward by
an entity known as Cogeneration Michigan Associates (CMA) . This Cogeneration
facility would use large amounts of water in its operations and CMA has
proposed to extract and treat the contaminated groundwater for use in their
Cogeneration facility. CMA's proposed treatment method would involve the use
of air stripping to cleanup the groundwater. This proposal is also supported
by at least one of the FRPs. The oonnunity in general had no objections to
the alternative proposed by U.S. EPA, but some representatives of the
oocDunity were in favor of using the Cogeneration facility to implement the
cleanup.
ON (Tf'MJ'CCnr
Community interest in the area groundwater contamination began in 1978 when
contamination was discovered in private wells downgradient of the
Northernaire facility. In 1980 contamination of private wells was discovered
downgradient of the Kysor facility. The major concerns expressed during the
remedial planning activities at the Northernaire and Kysor sites focused on
possible health effects from the contamination at the sites and the apparent
delays in getting the sites cleaned up. These concerns and how U.S. EPA
them are «^yiHh
-------
-3-
This responsiveness summary addresses both oral and written ocmnents received
by the U.S. ERA concerning the RI/FS for the Ncorthernaire and Kysor Sites.
The ocoment period was held from July 27 to August 28, 1989. A public
meeting was held on August 7, 1989 at the Wexford County Courthouse to allow
interested parties to present oral and written ocmnents.
GENERAL OGMOH5
1. Mr. Darrell Becker, Mayor of Cadillac, Mr. Donald Rennie, city of
Cadillac Utilities Director, Mr. Keith Johnson, and Mr. Samuel
Bailor ccranented that U.S. EPA and Michigan DNR should consider
cogeneration as a cleanup alternative.
U.S. EPA's Response: The Agency is keenly aware that the
Cogeneration project holds strong possibilities for supplementing
or substituting for all or .part of the Agency's proposed cleanup
activities at the Northernaire and Kysor sites. However, the
Agency's primary interest is in accomplishing a proper
environmental cleanup, and while the Cogeneration project has other
important aspects (i.e. jobs, economic benefits to the City), these
, aspects lie outside the scope of CERdA. At this *-imp it is too
soon for the Agency to focus on Cogeneration as a preferred
remedial alternative. However, should the Cogeneration project
advocates demonstrate to the Agency's satisfaction that the
Cogeneration project will adequately treat the groundwater to meet
the Agency's specifications, then the Agency would consider a
proposal for the Cogeneration project to work with the Agency to
meet cur environmental goals. At this time the Agency is not
informed as to the actual details and specifications of the
Cogeneration project.
2. Mr. Samuel Bailor had questions on the acute and latent effects of
the existing site contaminants. Mr. Bailor also questioned the
ability of the area forests to sustain a project such as
cogeneration.
U.S. EPA's Response; Each of the contaminants discovered at the
Northernaire or Kysor sites may exhibit certain adverse effects on
humans under certain circumstances. The risks posed by these
contaminants were thoroughly studied during the "risk assessment"
which was conducted as a part of the Remedial Investigation (RI).
The risk assessment itself contains specific Information on the
actual assessment of the risk and the toxic effects of each
individual contaminant. Nevertheless, it Is the Agency's
obligation to remedy these sites so that the public health and
welfare are protected from adverse risk, and the selected remedy is
designed to do exactly that.
Questions relating to the raw timber required to supply the
Cogeneration plant are beyond the scope of this remedial action,
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-4-
and are not relevant to this remedial action proposed by the
Agency.
3. Ms. Mary Stark, Supervisor, Charter Township of Hazing, had
questions pertaining to the cogeneration project, in particular:
Would contaminated soils be remedied with cogeneration?
What effects would the cogeneration have on the local
aquifers?
What would happen to the discharge from the cogeneration
plant?
Will an environmental impact study be done on the cogeneration
facility and would it be available?
U.S. EPA Response: The Agency's selected remedy for these sites
provides for cleanup of the contaminated soils near the Kysor
plant. However, the Agency is unaware if the plans for the
Cogeneration plant would have any impact on the contaminated soils
problem at the Kysor plant.
The pumping rates projected by the Cogeneration plant have not been
projected to have any significant effects on the volume of water
available from the local aquifer.
The Agency has not been made aware of all the details of the
Cogeneration project, and as a result, is not aware of the plans
from any discharge from the plant.
Environmental Impact Studies under the National Environmental
Policy Azt are required in certain situations where federal funds
are used for a project. While there may be other reasons for doing
such a study, the Agency is not aware that one is required for the
Cogeneration project.
4. There were other questions at the public meeting on August 7, 1989,
which were answered at the meeting (See copy of transcript of
meeting contained in the Administrative Record).
1&t v. I VFT^ DURj-NG PQnr.T
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2. Kysor comments that the performance of a portion of the RI work was
duplicative and not cost effective. Kysor states that even though
it had done a hydrogeological investigation of the area surrounding
the Kysor site, the State and U.S. EPA onfrtrtflrt another
hydrogeological investigation of much of the same area.
U.S. EPA's Response: Although some hydrogeological work had been
done by Kysor at the Kysor site, the proper Quality Assurance/
Quality Control procedures were not in place in order to assure
that the data obtained was reliable and of high quality.
Therefore, much of the hydrogeological work done by the State,
although seeming duplicative in nature, was necessary in order to
validate the previous data and fill any data gaps with reliable
good quality data. Also a number of the monitoring wells installed
by Kysor may have been installed using improper installation
techniques, thereby providing a conduit for migration of
contaminants from the shallow aquifer to the intermediate aquifer
. (see section 2.2 of ROD Summary). This necessitated the need for
installation of new monitoring wells at the Kysor site.
3. Kysor comments that the baseline risk assessment uses erroneous
assumptions in the calculation of exposure risk. First, Kysor
comments that the exposure assessment's models used by U.S. EPA are
flawed, and secondly, that the exposure assessment uses implausible
duration assumptions.
U.S. EPA's Response: It is the U.S. EPA's position that the models
used for the calculation of risk is appropriate for these two
sites. The environmental factors taken into consideration by the
risk assessment models included natural recharge and dispersion,
biological and chemical degradation, adsorption, and
volatilization. In conducting risk assessments, the standard
length of exposure used is 70 years, ttiile Kysor states that this
grossly overstates the actual duration of exposure, 70 years is the
commonly used standard which complies with the Superfund Public
Health Evaluation Manual (SPHEM).
4. Kysor states that the RI report uses inconsistent and misleading
designations for the sources associated with Four Star and Joynts.
U.S. EPA's Response; The RI states that the Four Star and Joynts
facilities are separate sources of contamination. It is difficult
to determine what the extent of contribution to the overall
contamination that each of these facilities is responsible for due
to the commingling of contaminants within the plume. For that
reason both facilities were »r**«-i«**F referred to jointly.
However, it is clear that Four Star and Joynts are separate
facilities and separate sources of contamination.
5. Kysor comments that the ARARs analysis is based on the erroneous
assumption that the affected aquifers are actual or potential
drinking water
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U.S. EPA's Response: The affected aquifers in the Cadillac
industrial park can and have been used as drinking water sources.
In fact, the same aquifers underlying the industrial park are
presently serving as drinking water sources in the North Park
Subdivision area, ttoen establishing ARARs it is the Agency's
policy to maintain an aquifer's useability as a drinking water
source. In this manner the affected aquifers can be used for
drinking water sources after cleanup is complete.
6. Kysor comments that the PS report erroneously applies certain state
rules and policies as ARARs, in particular the Part 22 Rules of the
Michigan Water Resources Act (Act 245) and the HOT6 policy.
U.S. EPA's Response: For a response, please refer to the response
to Garment 1 from the State of Michigan as discussed below.
7. Kysor comments that the FS errs in the calculation of residual
risk. In particular, flawed modeling assumptions and failure to
consider numerous environmental factors.
U.S. EPA's Response: It is U.S. EPA's position that the mnrlpl
used for the calculation of risk is appropriate for these two
sites (see Comment 3).
8. Kysor comments that the FS errs in setting the final groundwater
and soil target cleanup levels for toluene, tetrachloroethylene,
1,1-dichloroethylene, and trans-l,2-
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U.S. EPA's Response: Again the tine required for implementation of
the grounduater remedy is only an estimate. U.S. EPA feels this is
an accurate estimate of the tine required for implementation of
this type of remedy.
11. Kysor ocoments that the FS should evaluate the accelerated purge
rate that may be associated with the ccgeneration project.
U.S. EPA's Response: The FS is used to help decide what remedy to
use to cleanup a Superfund site, not to determine the
specifications of the chosen remedy. During the Remedial Design
phase of the project the actual purge rates will be analyzed and
decided upon.
12. Kysor ccranents that the FS uses misleading terminology to identify
the extraction well systems.
U.S. EPA's Response: It is true that the extraction well systems
in the FS are referred to as "Kysor Shallow1* and "Kysor
Intermediate1*. These designations, however/ were not intended to
make any implication relative to the liabilities of any party.
The designation of the well system bears a rational relationship to
the name of the site.
13. Kysor comments that the Proposed Plan is inaccurate and misleading.
In particular three issues are raised: Vfcy are Northernaire and
Kysor the only sites in the industrial park mentioned as having
contamination present? Why is the remedy just for Northernaire and
Kysor? The portion of the costs attributable to the chromium is
stated.
U.S. EPA's Response: First, this is an action being taken under
the authority of the Comprehensive Environmental Response,
Compensation and Liability Act as amended by the Superfund
Amendments and Reauthorization Act, more commonly referred to as
Superfund. The'Superfund remedial program is designed to address
Super fund sites, therefore, to the extent practicable, only the
contamination at the Superfund sites shall be singled out in the
pi'HJOuod plan. However other contamination located within the
industrial park not associated with these two Superfund sites can
and is being addressed by other means. This action will only
address the contamination associated with the two Superfund sites,
Northernaire and Kysor. The groundwater contamination plume
associated with these two sites is one indivisible plume with
multiple origins, seme of which are not Superfund sites (Four
Wirms, Four Star, Joynts). Since this contamination from multiple
origins is commingled, all of the contamination within the plume is
being addressed by this action. The one exception is the Rexair
contamination plume which can be identified as a separable plume.
The Rexair plume is not being arV*np«»Mri by this remedy.
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The proposed plan does not attempt to attribute costs to any one
facility so it is erroneous to say that costs are attributed
unfairly.
14. Kysor comments that the scope of the groundwater remedy is
unnecessarily broad.
U.S. EPA's Response; The scope of the groundwater remedy is to
the contaminated groundwater »»»>? iat1*^ with the two
Superfund sites, Nbrthernaire and Kysor. As mentioned above, some
other sources of VOC contamination have oomingled with the VCC
contamination associated with the Kysor site. In this instance it
is impossible, to separate this VOC contamination into those
portions contributed by the several different sources. The Rexair
plume is the one exception.
15. Kysor comments that U.S. EPA should reconsider Soil Flushing and
other technologies as the remedy for the soil contamination at the
Kysor site.
U.S. EPA's Response: U.S. EPA did consider soil flushing as an
alternative for cleanup of the soils at the Kysor site and it was
rejected in favor of the vacuum extraction treatment. This
decision was made by balancing the nine criteria against all of
tiie alternatives and choosing the best remedy, based on site
conditions. Soil flushing would add to the already extensive
contamination of the groundwater, which would increase the amount
of time required to reach cleanup levels, which is not desirable.
In reference to Kysor conraents about soil composting techniques,
if U.S. EPA determines during the Remedial Design stage that the
treatment for the contaminated soils at Kysor as outlined in the
ROD would not meet the requirements of the cleanup goals, including
cost effectiveness, other technologies (perhaps including soil
composting) may be considered.
16. Kysor conraents that the soils remedy for the Kysor site does not
require the use of deed restrictions.
U.S. EPA's Response: U.S. EPA feels that deed restrictions are
necessary for implementation of the soils remedy at the Kysor site.
However, the deed restrictions would only be in effect for as long
as the soil remained contaminated.
17. Kysor conraents that groundwater modeling is necessary prior to
design and implementation of the remedy.
U.S. EPA's Response: U.S. EPA concurs with this comment and the
modeling will be done as part of the Rpmfldial Design.
18. Kysor comments that the cogeneraticn project provides the
appropriate remedy for the area groundwater contamination.
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U.S. EPA's Response: The U.S. EPA agrees that the Oogeneration
project presents possibilities for a remedy for the groundwater
contamination in the OyJillar Area Industrial Park. However, prior
to endorsing such a remedy, there are many issues that oust be
considered and resolved.
19. ASI Envirormental Technologies commits that the treatment proposed
for the groundwater cleanup appears to be technically feasible.
However, it is scaled to address the major contamination plumes and
is not practicably applicable to the contamination for which Four
Winns is responsible.
U.S. EPA's Response: Since the contamination for which Four Winns
is potentially responsible is comingled with the other
contamination plumes, in effect making the contamination one bigger
plume, it is not practical to attempt to separately treat the
potential Four Winns contamination. Therefore, the potential Four
Winns contamination should and will be addressed as part of the
larger contamination plume.
MICHIGAN CNR OCmEMS HHCK1VED CURING HJBLIC
OCHMPFT HatlOD AND U.S. EE&
The Michigan Department of Natural Resources (MCNR) submitted
letters dated September 28, 1989, which stated that MCNR concurs
with the remedial technology selected for the Kysor and
Northernaire sites, but does not concur with the target cleanup
level for Trichloroethene (TCE) .
U.S. EPA's Response; The U.S. EPA welcomes the State's concurrence
on the remedial technology proposed for the sites. However, the
MCNR raises significant issues regarding compliance with State
laws. MCNR specifically cites Act 245, and its rules. These rules
restrict degradation of waters of the State, and apply to indirect
or direct "addition of materials to groundwater from any facility
or operation which acts as a discrete or diffuse source..."
R323.2202(j). The MCNR further asserts that, "The ROD states that
the target cleanup level for TCE is the Maximum Contaminant Level
(MCL), which is 5 parts per billion (5 ppb). MCNR does not support
the use of MCL's as target cleanup levels; the Department supports
a target cleanup level of one part per billion (1 ppb)."
Section 121 (d) (2) (A) of the amended OERCLA states that remedies
must comply with "any promulgated standard, requirement, criteria,
or limitation under a State environmental or facility siting law
that is more stringent than any Federal standard, requirement, or
limitation1* if applicable or relevant and appropriate to the
hazardous substance or release in question. General State goals
that are contained in a promulgated statute and implemented via
specific requirements found in the statute or in other promulgated
regulations are potential ARARs. Where such promulgated goals are
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-10-
general in scope, e.g. a general prohibition against discharges to
the waters of the State, compliance oust be interpreted within the
oontex of implementing regulations, the specific circumstances at
the site, and the remedial alternatives being considered.
Hie U.S. EPA accepts that a nondegradation law can be an ARAR.
However, the specific regulations which implement a general goal
are key in identifying what compliance with the goal means. If a
state has not promulgated implementing regulations, then the U.S.
EPA would have considerable latitude in determining how to comply
with the goal. Ihe U.S. EPA may consider guidelines the state has
developed related to the provision, as well as state practices in
applying the goal, but such guidance would not be ARAR.
Ihe State of Michigan contends that Act 245 is an ARAR for this
site. A literal reading of the Act and its Part 22 Groundwater
Discharge regulations implementing the Act indicates that the law
is prospective and is intended to prevent degradation of ground
water quality. The remedy for the Kysor/Northernaire sites
consists of extracting contaminated ground water, treating
(removing) the contaminants, and discharging the treated water
into a surface water body. Therefore, the U.S. EPA does not find
Act 245 and its Part 22 Rules to be ARAR. However, U.S. EPA fully
supports the State's goal to ensure that the waters of the State
are protective of the public health and welfare.
The State asserts that its 1 ppb cleanup goal for TCE is based on
Act 245, and Part 22. Unfortunately, neither Act 245, nor the
Part 22 Rules, provide specific remediation goals for the
contaminants of concern. We note that the only discussion
regarding specific concentration levels found in the Part 22 Rules
appears in 323.2205(3) which states: "Materials at concentrations
that exceed the TnaviMim contaminant levels for inorganic and
organic chemicals. . .which are promulgated pursuant to the safe
drinking water act 42 U.S.C. 300f, shall not be discharged into
ground waters in usable aquifers...1* Therefore, even if Act 245
and Part 22 Rules were considered to be ARAR, the rules do not
provide specific criteria or numerical standards which could be
applied in j^gfr^Ki ighing namarHai cleanup goals.
The U.S. EPA has developed a consistent policy regarding
remediation goals for ground water. This policy may be found in
the npramher 21, 1988 proposed revisions to the National Oil and
Hazaninas Substances Pollution Contingency Plan (NCP) . The
U.S. EPA has stated its policy that for surface or ground water
that is or may be used for drinking, MCLs are generally relevant
and appropriate as cleanup standards. The basis for this policy
was that Mds are protective of human health and represent the
level of water quality that U.S. EPA believes is acceptable for
over 200 million Americans to consume every day from public
drinking water supplies. As the enforceable standard for public
water supplies, MCLs are fully protective of human health and, for
carcinogens, fall within an acceptable lifetime risk range of 1E-04
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-11-
to 1E-07. fiien Mds do not exist for contaminants identified in
the ground water at a site, the Superfund piuuxvam will use other
standards, advisories or criteria to determine if the rosponoo
action will achieve a level of protection within a range of 1Z-O4
to 1E-07 individual lifetime excess cancer risk.
The remedy proposed for the Itysar/Northernaire sites establishes
cleanup goals for several contaminants. For example, the MCNR, as
the lead agency conducting the RI/FS, initially proposed to use
MCLs as the target cleanup levels for Trichloroethene (5ppb), and
1,2-Oichloroethane (5 ppb). In addition, the MCNR used a Contract
Required Detection Davel of 5 ppb for 1,1-Dichloroethylene, and a
carcinogenic risk derived level of 1 ppb for Perchlorcethylene. If
one were to express the risks posed by these contaminants, at these
ntration levels, one would find that 5 ppb of TCE represents a
lifetime, risk of 1.5E-06, 1,1-OCE represents a 8.29E-05 risk, PCS
represents a 1.49E-06 risk, and 1,2-OCA represents a 1.3E-05 risk.
The U.S. EPA accepted the cleanup goals proposed by the State
because the additive risk posed by these chemicals (9.9E-05)
remained within U.S. EPA's accepted risk range. Although the MCNR
letters state: "MCNR does not support the use of MCL's as target
cleanup levels..,1* there is no discussion regarding the cleanup
levels for contaminants other than TCE. The State simply argues
that the MCL for TCE is unacceptable, without providing any
supporting documentation, or evidence of an overarching rationale
for selecting more stringent cleanup goals for particular
contaminants. A 1 ppb concentration level for TCE represents a
3.14E-07 lifetime risk. This risk, dpfinpri acceptable by the MCNR
for TCE, is an order of magnitude less than the risks deemed
acceptable for the other contaminants. The U.S. EPA recognizes
that there may be circumstances when individual cleanup goals may
be adjusted to ensure that a remedy provides a level of
protectiveness within the U.S. EPA's accepted risk range. The
remedy selected for the Kysor/Northernaire sites does not exceed
the risk range, so adjustments to the cleanup goals are not
required. In fact, the additive risk calculated for the sites
using a 1 ppb cleanup level for TCE simply reduces the total risk
from 9.9E-05 to 9.77E-05. Given the inherent inconsistencies
presented by the State's insistence on a 1 ppb cleanup level for
TCE at these sites, the U.S. EPA maintains that MCTs are
protective, and declines to adopt a 1 ppb cleanup goal for TCE.
The State cannents that the description of the "Site" needs to be
expanded to reflect additional known sources of contamination which
are not included within the Proposed Plan but have been addressed
in the RI/FS documents upon which the Proposed Plan is based.
Specifically, the Rexair TCE plume on the east side of the
municipal well field and the contaminated soils on the Four Winns'
property require mention as to their presence and why they are not
addressed within the Proposed Plan.
U.S. EPA's Response: The Agency does not agree that it is
necessary to describe or Hjcraipg contamination which is not
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directly relevant to the extermination of a remedy for the
Nbrthernaire and Kysor sites. While there may be additional areas
of oontamination in the vicinity of the industrial park, the scope
of the Superfund activities is limited to those activities
necessary to remedy only the Nbrthernaire and Kysor contamination.
U.S. EPA supports Michigan CNR efforts to bring facilities, outside
the scope of CERCXA, into compliance with the State's environmental
statutes.
The State comments that although contaminated soils on the Four
Winns property are not included in this Proposed Plan, it should be
stated that each of these soil alternatives have been evaluated for
Four Winns' soils. Remediation of soils on both the Kysor and Four
Winns properties is assumed in determining the length of t--jjn» to
achieve cleanup goals in the groundwater cleanup alternatives.
U.S. EPA's Response: The U.S. EPA agrees that the Four Winns soil
contamination was evaluated in the FS. However, the U.S. EPA does
not believe that an adequate characterization was done on the
contamination of the Four Winns soils. Without adequate
characterization of the type and extent of the soil contamination
at Four Winns it is impossible to adequately evaluate the
feasibility of any alternatives for cleanup. Again, U.S. EPA
supports Michigan CNR efforts to bring facilities, outside the
scope of CERCLA, into compliance with the State's environmental
statutes.
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Attachment A
COfUNTIY FELATICN5 ACTIVITIES CONDUCTED
AT Uffi NUKiHiUNAIRE AND KYSOR SUES
Fact sheets were released on the following dates to keep the public informed
on the activities going on at the two sites:
October 1983
February 1984
July 1984
August 1984
July 1985
April 1986
August 1986
October 1986
August 1988
Fact sheet to inform public of upcoming RI/FS activity at
Northemaire site.
Fact sheet to inform public of ongoing RI/FS activity at
Northernaire site.
Fact sheet to inform public of RI/FS activity at
Northernaire site.
Fact sheet to inform public of RI/FS activity at
Northernaire site.
Fact sheet to inform public of FFS/Proposed Plan for
cleanup of soils at Northernaire site.
Fact sheet to inform public RI/FS activity concerning
area groundwater study.
Fact sheet to inform public of RI/FS activity concerning
area groundwater study.
Fact sheet to inform public of RI/FS activity concerning
area groundwater study.
Fact sheet on RI for area groundwater study.
July 1989
Fact sheet on FS/Proposed Plan for cleanup of the
contaminated soils at Kysor and contaminated groundwater
associated with Northernaire and Kysor.
Public meeting were held on the following dates to provide a forum for the
public input, and update the public on important milestones.
February 1984
August 1984
July 1985
Public meeting to determine public concern on
Northernaire RI/FS activity.
Public meeting to determine public concern on
Northernaire RI/FS activity.
Public meeting to provide forum for comment on
FFS/Proposed Plan for soils remedy at Northernaire.
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August 1986 Public meeting to determine public ccnoern on Cadillac
area groundwater KL/TS activity.
August 1988 Public meeting to discuss RI for the area groundwater
study.
August 1989 Public meeting to provide forum for cement on
PS/Prcpoeed Plan of area groundwater study.
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