PB95-964102
EPA/ROD/R05-95/274
February 1996
EPA Superfund
Record of Decision:
Petoskey Municipal Well Field
Superfund Site, Petoskey, MI
6/14/1995
-------
ACHON RECORD OF DECISION
FOR THE
PETOSKEY MUNICIPAL WELL FIELD SUPERFUND SITE
PETOSKEY, MICfflGAN
-------
1
2
3
4
5
6
7
8
9
10
11
.0
.0
.0 .
.0
.0
.0
.0
.0
.0
.0
.0
SITE NAME, LOCATION, AND DESCRIPTION ......
SITE HISTORY AND ENFORCEMENT ACTIVITIES .....
HIGHLIGHTS OF COMMUNITY PARTICIPATION
SCOPE AND ROLE OF RESPONSE ACTION ...
SUMMARY OF SITE CHARACTERISTICS ,
SUMMARY OF SITE RISKS
DESCRIPTION OF ALTERNATIVES
COMPARATIVE ANALYSIS OF ALTERNATIVES: THE NINE
CRITERIA
THE SELECTED REMEDY
STATUTORY DETERMINATIONS
DOCUMENTATION OF SIGNIFICANT CHANGES
. , 1
. . 1
. . 5
. . 6
7
12
. . 19
, . 28
, 35
, . 36
. 40
-------
NATURAL RCBOURCCS
COMMWWON
JOHN ANGLER Covtmer
DEPARTMENT OF NATURAL RESOURCES
HL sevens T MASON emiowfl. PO eox xxwa. IANS-NO m «woo •»»»•
ftOUMO HMMES CX«ch»
June 6, 1995
Mr. Valdas V. Adamkus, R-19J
Administrator, Region 5
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago, Illinois 60604-3590
Dear Mr. Adamkus:
The Michigan Department of Natural Resources (MDNR), on behalf of the State
of Michigan, has reviewed the Record of Decision (ROD) for the Petoskey
Manufacturing Superfund site interim action (IA) for the Ingalls Avenue Municipal
Well, and the proposed remedy contained in that ROD. Michigan concurs with
the IA remedy proposed in the ROD consisting of:
On-line treatment of groundwater from the Ingalls Avenue Municipal Well
through the use of air stripping with the use of carbon treatment as a
contingency in the event that, within 18 months of the signature of the
ROD, site-related semi-volatile contaminants exceed maximum
contaminant levels in the Ingalls well tap.
The state elects the cost-equivalency option as an alternative to the
implementation of the proposed remedy. The state will be entering into an
agreement with the City of Petoskey whereby they will agree to:
A. Design and implement the cost-equivalency option.
B. Pay all additional costs associated with the design, construction
and operation and maintenance of such an alternate water
treatment system beyond the $500,000 already allocated by the
MDNR to the City of Petoskey for development of an alternate
water supply.
C. Agree not to hold the State of Michigan responsible for payment of
any additional funds associated with the alternate water treatment
plant beyond the $500,000 already allocated.
• 10M
UVRM
-------
Mr. Valdas V. Adamkus
Page 2
June6, 1995
The EPA needs to provide the state of Michigan with an explanation of (he
appropriate mechanism to transfer funds from the EPA to the state of Michigan
and identify the responsibilities associated with". ..assuming] the lead for
supervising the design and construction of the new drinking water source
pursuant to the NCP at 40 § 300.515(f)(1)(ii)(B)."
We look forward to working together to accomplish this IA remedy at this site.
tf you have further questions, please contact Mr William Bradford, Chief.
Superfund Section, Environmental Response Division, at 517-373-8815, or you
may contact me.
Sincerely,
Russell J. Harding
Deputy Director
517-373-7917
cc: Mr. James Mayka, EPA
Ms. Karla Johnson, EPA
Ms Terese Van Donsel, EPA
Mr. Chad Mclntosh, Governor's Office
Mr. Jeremy Firestone, MDAG
Mr. Alan J. Howard, MDNR
Mr. William Bradford, MDNR
-------
DECLARATION
SELECTED REMEDIAL ALTERNATIVE
FOR INTERIM ACTION AT THE
PETOSKEY MUNICIPAL WELL FIELD SITE
PETOSXEY, MICHIGAN
Statement of Basis and Purpose
This decision document presents the selected remedial action for
interim action at the Petoskey Municipal Well Field Site (Site),
in Petoskey, Michigan. This remedial action was chosen in
accordance with the Comprehensive Environmental Response,
Compensation, arid Liability Act (CERCLA) of 1980, as amended by
the Superfund Amendments and Reauthorization Act (SARA) of 1986,
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision is
based on the administrative record for this Site.
The State of Michigan concurs with the selected remedy. The
Letter of Concurrence is attached to this Record Of Decision.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action in
this Record of Decision (.ROD) , may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
The selected remedial action is an interim remedy for the Site.
The purpose of this remedy is to ensure that individuals drinking
water from the Ingalls Avenue Municipal Well are not exposed to
unacceptable levels of contamination from the Petoskey
Manufacturing Company source area. Soil contamination at the
Petoskey Manufacturing Company source area and ground water
contamination in the well field will be addressed in a subsequent
Record of Decision.
The selected remedy includes on-line treatment of ground water
from the Ingalls Avenue Municipal Well. Air stripping has been
identified as the appropriate treatment technology to address the
levels and types of contamination seen to date in ground water at
and near the municipal well. To address State of Michigan
concerns that site-related semi-volatile contamination could
adversely impact the Ingalls Well in the near future, the Record
of Decision also includes carbon treatment as a contingent
treatment remedy. The U.S. EPA will coordinate quarterly
-------
sampling at the Ingalls Well tap for a period of eighteen months
from the date of this Record of Decision. If during this
eighteen-month period, two consecutive quarters of sampling at
the Ingalls Well tap reveal a site-related, semi-volatile
contaminant exceeding a Maximum Contaminant Level, the selected
remedy will utilize granular activated carbon, instead of air
stripping, for treatment of the water supply. If the Ingalls
Well is replaced and the replacement supply is in operation
within eighteen months of the signature of this ROD, the
contingent carbon treatment remedy would no longer be available
and quarterly sampling at the Ingalls Well would be discontinued.
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment or resource
recovery technologies to the maximum extent practicable. The
remedy does not satisfy the statutory preference for remedies
that employ treatment that reduces the toxicity, mobility, or
volume as a principal element. Because this interim remedy does
not directly address the ground water and soil contamination
problems identified at the Petoskey Municipal Well Field
Superfund Site and because the Site itself will be addressed in a
subsequent ROD, the five-year review will not apply to this
action.
Enhancement of Remedy Option
By selecting this remedy, the U.S. Environmental Protection
Agency is seeking to ensure that contamination from the Petoskey
Manufacturing Company property does not impact the Ingalls Avenue
Municipal Well at levels which are considered unsafe. The
selected alternative of air stripping will, if constructed,
reduce levels of volatile organic compounds that enter the
municipal water distribution system. If semi-volatile organic
contaminant treatment is found to be necessary, carbon treatment
will address both volatile and semi-volatile organic compounds.
Either of these actions, if found to be necessary, would be
adequate to achieve the requirements of CERCLA and the National
Contingency Plan. The U.S. EPA cannot justify expending
Superfund monies to replace the water system when more cost-
effective alternatives (air stripping and granular activated
carbon) are capable of providing an added.margin of safety to an
already safe drinking water supply. Therefore, the U.S. EPA will
allow the State of Michigan to request that the City's cost of
constructing a new drinking water source be considered an
"enhancement" of the remedy under 40 CFR §300.515 (f).
The U.S. EPA finds that such an "enhancement" of the U.S. EPA's
-------
selected remedy, while not necessary for the protection of human
health and the environment, would not conflict with or be
inconsistent with the U.S. EPA's selected remedy. If such
enhancement is requested by the State of Michigan, U.S. EPA would
contribute the capital cost of U.S. EPA's selected remedy, in the
amount of $1,238,000 for air stripping or $1,444,000 for carbon
treatment, to be used by the State to partially defray the City's
cost of replacing the Ingalls Avenue Well. In that case, the
U.S. EPA's selected remedy will not be implemented and the State
will agree to assume the lead for supervising the design and
construction of the new drinking water source, pursuant to the
NCP at 40 CFR § 300.515(f)(1)(ii)(B). U.S. EPA understands that
the City of Petoskey will be required to fund the entire
additional cost associated with the enhanced remedy.
Valdas V. Adamkus
Regional Administrator
Date
-------
RECORD OF DECISION SUMMARY
For Interim Action At The
Petoskey Municipal Nell Field
Petoskey, Michigan
1.0 SITE NAME, LOCATION, AND DESCRIPTION
The Petoskey Municipal Well Field Site (the "Site") is located in
Petoskey, Michigan. The City of Petoskey is located in the
northwest corner of Michigan's lower peninsula (Figure 1). The
Site includes contaminated source area soils and the ground water
that has been impacted by contaminants migrating from the source
area. Ground water contamination has impacted the Ingalls Avenue
Municipal Well ("Ingalls Well") which is located on the shore of
Lake Michigan and supplies water to residents of the City of
Petoskey.
The Petoskey Manufacturing Company (PMC) has been identified as
the source area for the volatile organic compound (VOC)
contamination in the Ingalls Avenue Municipal Well. PMC is a
small fabricating operation that was established in 1946 as a die
cast manufacturer, continued with painting operations in the late
1960's, and remains in operation today. PMC is located at 200
West Lake Street in Petoskey, Emmet County, Michigan. Because of
the connection between PMC and the Superfund Site, the Site is
also commonly known as the "PMC Site."
The PMC source area is located approximately 500 feet south of
Little Traverse Bay (Figure 2). In general, ground water from
the PMC source area moves towards the bay and into Lake Michigan
and also moves towards the Ingalls Avenue Municipal Well when the
well is pumping. The Bear River is located approximately 500
feet east of the PMC Site. Geology at the Site consists of a
thin layer (1 to 30 foot thick) of sands and gravels overlying
the approximately 400 foot thick Devonian age Traverse Group.
The Traverse Group consists of fractured limestone with thin
interbeds of shale.
Disposal of spent solvents and/or paint sludge on the ground
surface outside the PMC building has contaminated soils and
ground water in the vicinity of the source area. Water from the
City of Petoskey's Ingalls Well contains VOCs, including
trichloroethene (TCE), and low levels of semi-volatile organic
contaminants (SVOCs) and inorganic contaminants. The Ingalls
Well is still being used to service the population of Petoskey
and supplies 60 to 70% of the City's water needs.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1981, the Ingalls Well was found to be contaminated with VOCs.
In 1982, the U.S. EPA and MDNR identified PMC as a potentially
responsible party for the water supply contamination. Analysis
of samples obtained from the area west of the PMC building
indicated that elevated levels of VOCs were present in the soils.
-------
MANUFACTURING
Petoskey
Emmet County
o 1000 2000
Approximate Scale in Feet
• WW Engineering & Science*
Figure 1
SITE LOCATION MAP
Petoskey Manufacturing Company
Petoskey, Michigan
Mav t992
OAOU 01
-------
tder associates c
/'i /'//
^ PS-106
oR
.0
Water
Pump House
A PS-104
A PS-II
Petoikey
Manufacturing
Company
Lake St.
~9T
PS-A
• A
PS-6
9.
lo
fs-im
kPS-Iff
iPS-IJ
IPS S»> .1.
engineers. pc
Fiounc 3 >
1
LEGEND
4 Monitoring Well
1$) Monitoring Well Cluster
* Surface Water Static
Measurement Location
(\) Surface Water Sample
i ocotion
PS-1 ffl Abandoned Monitoring Well
Replaced by PS- Iff
ISO'
MONITORING WELL LOCATIONS
PETOSKEY MANUFACTURING COMPANY
PEIOSKEY. MICHIGAN
-------
In 1982, under the direction of the MDNR, PMC removed
approximately 131 cubic yards of contaminated soil, backfilled
the excavation, and capped it with a polymembrane liner.
Prior to 1982, TCE concentrations of approximately 50 parts per
billion (ppb) were found in the Ingalls Well. Following the
removal of the contaminated soil, TCE concentrations in the
municipal well decreased to approximately 4.0 ppb and have
remained relatively stable for the last five years. A MDNR
ground water study conducted in 1982 and 1983 confirmed the
presence of ground water contamination and found that the local
ground water flow from the.PMC Site was toward the Ingalls Well
when the well was pumping. The MDNR also indicated that
additional work was necessary to further identify and
characterize the source(s) of contamination.
In July 1983, the PMC Site was evaluated using the Hazard Ranking
System. The PMC Site was subsequently added to the National
Priorities List on September 8, 1983.
In 1984, the U.S. EPA negotiated an Administrative Order by
Consent with PMC. This Order required PMC to conduct further
hydrogeological studies. PMC retained an environmental
consultant and completed the work under the direction of the U.S.
EPA and MDNR. Work included the installation of four monitoring
well clusters, ground water and soil sampling, and ground water
flow analysis.
In 1987, PMC signed another Administrative Order by Consent with
the U.S. EPA. PMC agreed to conduct a full Remedial
Investigation/Feasibility Study {RI/FS) to determine the nature
and extent of contamination and investigate appropriate remedial
alternatives to address the contamination. PMC started the work
plan phase of the Administrative Order, but in 1990 the U.S. EPA
relieved PMC of conducting further RI/FS work due to delays in
developing the work plan and PMC's questionable financial ability
to complete the work required by the Administrative Order. The
U.S. EPA entered into a State Cooperative Agreement with the MDNR
in 1990, in which the MDNR agreed to perform the RI/FS.
In April 1989, the Agency for Toxic Substance and Disease
Registry (ATSDR) prepared a Health Assessment for the PMC Site.
This assessment concluded that:
The "site is of potential public health concern because of
the risk to human health that could result from possible
exposure to hazardous substances at levels that may result
in adverse health effects over time."
"Human exposure to TCE and DCE [dichloroethene] has occurred
via ingestion of contaminated water and inhalation of
contaminated air."
-------
Data from the Remedial Investigation conducted by the MDNR were
released to the public in January of 1994. A Phase I Remedial
Investigation Report is expected to be released by the MDNR in
late 1995. The MDNR will conduct additional field work during
the summer and fall of 1995 will release a Phase II Remedial
Investigation Report in 1996.
While the state-lead RI/FS was ongoing, the U.S. EPA in 1992
began a Focused Feasibility Study (FFS) to examine the impact of
the PMC contamination at the Ingalls Well. The FFS concluded
that current VOC levels at the well were below the Maximum
Contaminant Levels (MCLs) promulgated pursuant to the Safe
Drinking Water Act. The FFS also determined that risk levels
calculated for present and future scenarios based on current
levels of contamination are within the U.S. EPA's acceptable risk
range. However, because of the uncertainty associated with
future concentrations of VOCs in the Ingalls Well, the U.S. EPA
in 1993 proposed that an air-stripper be constructed at the
Ingalls Well to reduce existing levels of VOCs, especially TCE,
in the well and ensure that the City's water supply is not
adversely impacted by the higher levels of VOC contamination that
have been found in ground water near the Ingalls Well. This
action was proposed as an interim measure at the Ingalls Well to
fully ensure the protection of the City's water supply with
regards to the Superfund contamination emanating from the PMC
Site. This interim action does not address the source of the
ground water contamination.
3.0 HIGHLIGHTS OP COMMUNITY PARTICIPATION
A community relations plan was developed in 1992 by the MDNR to
document community concerns and to plan an information strategy
for the PMC Site. At the request of the City of Petoskey, the
MDNR has postponed holding any public meetings to discuss the
RI/FS until issues regarding the Ingalls Well are resolved.
As part of its community relations program, MDNR maintains an
information repository at the Petoskey Public Library. The
library is located at 451 East Mitchell Street in Petoskey. The
Administrative Record and all formal reports developed prior to
and during the RI are available at this location. As Site
activities progress, MDNR will add additional RI/FS information
to the repository.
U.S. EPA took the lead in developing the technical documents to
support the evaluation and selection of an interim action. These
documents, including the FFS, can also be found in the Site
repository.
U.S. EPA notified the local community, by way of the Proposed
Plan, of the recommendation of a interim remedial alternative for
the PMC Site. To encourage public participation in the selection
-------
of a remedial alternative, U.S. EPA scheduled a public comment
period from December 1, 1993, to January 29, 1994.
Additionally, on December 2, 1993, U.S. EPA held a public meeting
to discuss the recommended remedial alternative and the other
alternatives identified and evaluated in the FFS. The MDNR, the
Michigan Department of Public Health (MDPH) and the Agency for
Toxic Substances and Disease Registry also participated in the
meeting. A transcript of this meeting is included as part of the
Administrative Record for the Interim Action at the PMC Site.
U.S. EPA's responses to oral comments received during this public
meeting and to written comments received during the public
comment period are included in the Responsiveness Summary which
is attached to this ROD.
Press releases announcing the public comment period, the public
meeting and the availability of the Proposed Plan, were sent to
the Petoskey News Review, the Super Shopper and the Charlevpix
Courier. The information was also provided to local media,
including:
WPBN-TV (7) NBC, Traverse City;
WWTV-TV (9) CBS, Cadillac;
WWUP-TV (10) CBS, Sault St Marie;
WCMU-TV (36) PBS, Mt Pleasant;
WGTU-TV (29) ABC, Traverse City;
WJML (AM & FM) Petoskey;
WWPZ (AM), Petoskey; and
WKHQ (FM), Charlevoix.
4.0 SCOPE AMD ROLE OF RESPONSE ACTION
The selected remedy for interim action at the Ingalls Well is not
intended to be the final response action at the Site. The
purpose of the selected alternative for this interim action is to
protect the Petoskey Municipal Well Field from unsafe levels of
contamination from the PMC site. The interim remedy selected for
the Ingalls Well will include on-line treatment of ground water
by air stripping and routine, long-term monitoring of water
quality in the well. If, within eighteen months of the date of
this Record of Decision, two consecutive quarters of sampling at
the Ingalls Well tap reveal a site-related semi-volatile
contaminant exceeding a Maximum Contaminant Level, the selected
remedy would consist of carbon treatment instead of air
stripping. If the Ingalls Well is replaced and the replacement
supply is in operation within eighteen months of the signature of
this ROD, the contingency carbon treatment technology would no
longer be available. No principal threat for the PMC Site will
be addressed as part of this action.
-------
5.0 SUMMARY OF SITE CHARACTERISTICS
On September 1, 1981, Che Michigan Department of Public Health
notified the City of Petoskey that routine samples from the
Ingalls Well contained between 20 and 50 parts per billion (ppb)
of TCE. Subsequent testing of the well in 1982 found
concentrations of 50 ppb of TCE and 32 ppb of (DCE). Following
the 1982 excavation of contaminated soil from an area west of the
PMC facility, the reported concentrations of both contaminants in
the Ingalls Well decreased to below the U.S. EPA Maximum
Contaminant Level (MCL) for TCE of 5 ppb and below the non-zero
Maximum Contaminant Level Goal (MCLG) for DCE of 7 ppb.
MCLs and MCLGs are the Federal standards used to evaluate the
degree of chemical contamination in water supplies. MCLs are
enforceable standards that apply to specified contaminants which
U.S. EPA has determined to have an adverse effect on human health
above certain levels. MCLs are set as close as feasible to
MCLGs. Feasibility takes into account both technology and cost
considerations. MCLGs are non-enforceable health-based goals
that have been established at levels at which no known or
anticipated adverse effects on the health of persons occur and
which will allow an adequate margin of safety.
Because of the complexity of the ground water flow patterns, it
has not been possible to clearly establish ground water flow
direction in any of the remedial investigation studies conducted
to date. Ground water patterns are naturally variable due to the
site's proximity to Lake Michigan and Bear River. Ground water
flow patterns are also variable because of the intermittent
pumping at the Ingalls Well. However, in general it has been
noted that operation of the Ingalls Well changes the directional
pattern. Ground water flows towards the well when it is pumping.
The contaminant plume has moved approximately 600 feet to the
northwest of the PMC facility to the Ingalls Well, and is within
100 feet of the lake shore. It appears that the contaminated
ground water drawn into the Ingalls Well is diluted by surface
water infiltration from Lake Michigan. This dilution appears to
reduce the concentration of TCE in the well. Since the removal
action in 1982, the level of TCE contamination in the Ingalls
Well has dropped over time and has remained at 4 ppb for several
years.
From what is known of ground water flow at the Site, levels of
contamination should have continued to drop at all wells since
the removal action in 1982. However, at Monitoring Well PS-CD
and Monitoring Well PS-11, levels of TCE have remained relatively
high even though other wells closer to the source area have
experienced decreasing levels of TCE contamination. The most
likely reason for Monitoring Well PS-CD and Monitoring Well PS-11
retaining the higher levels of contamination is the possibility
-------
8
that TCE may have sunk into the fractured bedrock as a Dense Non-
Aqueous Phase Liquid (DNAPL). The pocket of contamination within
the bedrock could serve as a secondary source of contamination to
the ground water entering the Ingalls Well. The RI has not
confirmed the presence of a DNAPL; however, due to the complex
fractures of bedrock, any field program designed to find a DNAPL
would likely fail to locate the pocket.
Three residential wells are located within # mile of the Ingalls
Well. In 1991, two of the three residential wells were sampled
by the Michigan Department of Public Health for volatile organic
compounds (VOCs) at the request of the MDNR. No confirmed
contamination was found. The third private well was unable to be
sampled because the property was closed for the winter.
Table 1 provides detail concerning the frequency of detection and
range of detection for all VOCs and semi-volatile compounds
(SVOCs) seen in monitoring wells during the two most recent
rounds of comprehensive ground water sampling (December 1992,
March 1993) conducted as part of the Remedial Investigation.
Sampling conducted by the MDNR found levels of TCE as high as 78
ppb in monitoring wells downgradient of the site. Low levels of
SVOCs have also been seen in monitoring wells. The most
prevalent of SVOCs are bis(2-ethylhexyl)phthalate and di-n-octyl
phthalate, which were seen in monitoring wells at estimated
maximum concentrations of 7 ppb. Only trace levels (estimated at
0.5 ppb) of bis(2-ethylhexyl)phthalate have been seen in the
Ingalls Well due to the mixing of ground water and surface water
that occurs when the Ingalls Well is in operation. Di-n-octyl
phthalate has not been detected in the Ingalls Well.
The December 1992 and March 1993 sampling events also analyzed
ground water for the presence of pesticides. However, only the
March 1993 sampling event detected the presence of any pesticides
in ground water. See Table 1 for a list of identified pesticides
from the March 1993 sampling event. Of the eleven pesticides
identified, only one pesticide, dieldrin, was found at trace
levels at the Ingalls Well. Follow-up ground water sampling was
conducted in October of 1993 to provide additional information
concerning concentrations of pesticides in the well field.
Analyses identified very low levels of heptachlor epoxide, 4,4'-
DDE and endosulfan sulfate. No pesticides were found in the
ground water from the Ingalls Well. Of the pesticides seen in
ground water to date, only 4,4'-DDT and 4,4'-DDE have been found
in site soils.
Because the majority of pesticides seen in the ground water were
not seen in soil samples taken from the site, it is possible that
the presence of low-level pesticides in the ground water is an
area-wide problem. As in many communities in the country, the
past prevalent use of pesticides makes it unlikely that the PMC
Site is the sole source of the trace 4,4'.-DDT and 4,4'-DDE in
-------
TABLE 1
Data from 12/92 and 3/93 Groundwater Sampling Events
Volatile Organic Compounds
Vinyl Chloride
Methylene Chloride
Acetone
Carbon Bisulfide
Cis - 1 , 2 -dichloroethene
Trichloroethene (TCE)
Tetrachloroethene
Methyl -t -Butyl Ether
Toluene
Chloroform
Semi -Volatile Organic
Compounds
Di - n-butylphthalat e
Butylbenzylphthalate
3,3' -dichlorobenzidine
Bis (2-ethylhexyl) Phthalate
Di-n-octyl Phthalate
Frequency of
Detection
1/44
12/44
6/44
7/44
7/44
15/44
7/44
7/44
1/44
1/44
Frequency of
Detection
1/44
2/44
1/44
13/44
13/44
Range of
Detected
Concentrations*
2 ppb
0.5J - 3 ppb
0.9J-15J ppb
0.6J-3 ppb
0.4J-8 ppb
0.7J-78E ppb
0.9J-2
0.6J-8 ppb
0 . 6 J ppb
3J ppb
Range of
Detection
Concent ra t i ons *
0.6J ppb
0.6J-1J ppb
1J ppb
0.5J-7J ppb
0.5J-7J ppb
Note - Contaminant concentrations marked with a "J" are
estimated values.
Contaminant concentrations marked with an "E"
identifies concentrations that exceed the
calibration range of the GC/MS instrument for the
specific analysis.
-------
10
TABLE 1 - Continued
Data from 12/92 and 3/93 Groundwater Sampling Events
Semi -Volatile Organic
Compounds - Pesticides
Heptachlor
Aldrin
Endosulfan 1
Dieldrin
4, 4 '-DDE
4,4' -DDT
Alpha - Chlordane
Gamma - Chi or dane
Delta-BHC
Heptachlor Epoxide
Endrin Aldehyde
Frequency of
Detection
2/43
2/43
2/43
2/43
2/43
4/43
4/43
5/43
1/43
1/43
2/43
Range of
Detection
Concentrations*
0.006J - 0.028J
0.008JP - 0.026J
0.012JP -0.019JP
0.008JP -0.015JP
0.028JP -0.068JP
0.008JP-0.27J
0.013JP - 0.81PE
0.015JP - 1.2PE
0.034JP
0.007JP
0.15BP - 0.20B
Note - Contaminant concentrations marked with a "J" are
estimated values.
Contaminant concentrations marked with an "E"
identifies concentrations that exceed the
calibration range of the GC/MS instrument for the
specific analysis.
Contaminant concentrations marked with a "B"
identify sample results where the compound was
detected in the associated blank sample.
Contaminant concentrations marked with a "P"
identify sample results where there was a greater
than 25% difference for detected concentrations
between the two GC columns..
-------
11
ground water. The sporadic, low-level detection of 4,4'-DDE and
4,4'-DDT does not warrant treatment for semi-volatile
contaminants at the Ingalls Well.
While soils at the PMC facility are contaminated with metals,
very little inorganic contamination has been seen during ground
water monitoring conducted during the Remedial Investigation.
Zinc was seen at moderately elevated concentrations in several
monitoring wells and it is possible that the zinc in ground water
is due to a 1990 hydraulic fluid spill at the PMC facility.
During that period, some formulations of hydraulic fluid
contained zinc.
During December 1992 and March 1993 MDNR monitoring, arsenic was
detected only in well PS-A (located south of PMC). In April
1993, the City of Petoskey's contractor, McNamee Industrial
Services, Inc., (hereafter referred to as "McNamee"), took a
round of ground water samples from borings and wells north of the
Site near the Ingalls Well. Sample results showed low levels of
arsenic (maximum concentration 4 ppb). Although arsenic was seen
in Site soils, the distribution of arsenic detections in ground
water suggests that the low levels found may be background
concentrations or unrelated to movement of contaminants from the
PMC source area. All detections of arsenic in ground water are
far below the MCL of 50 ppb.
During the analysis of samples from the monitoring wells and the
Ingalls Well, volatile and semi-volatile Tentatively Identified
Compounds (TICs) were found. TICs are contaminants that are seen
during gas chromatography/mass spectrometry (GC/MS) analysis, but
cannot be clearly identified as specific chemicals. The most
significant levels of TICs are seen in Well PS-6. The location
of the TIC chemicals at Well PS-6 corresponds with the area of
the 1990 hydraulic fluid release at the PMC facility. During the
December 1992 sampling event, field personnel observed a floating
product on three ground water samples taken from wells taken near
the PMC facility. A sample of the floating product was analyzed
and found to contain approximately 2% oil and grease. The exact
extent of the floating product is not known.
Because of the complex fractured bedrock geology and the
possibility of DNAPLs at the Site, any future active restoration
of the well field would be difficult. However, the MDNR will
evaluate both source area and ground water technologies that have
the potential of remediating the contamination at the PMC
property and in the Petoskey well field. Until a final remedy at
the Site can be implemented, construction and operation of the
alternative selected in this interim action ROD will ensure that
the municipal water from the Ingalls Well does not have unsafe
levels of VOCs.
-------
12
6.0 SUMMARY OF SITE RISKS
The Baseline Risk Assessment for ground water that was released
in conjunction with the FFS for interim action at the Ingalls
Well followed the guidance provided in U.S. EPA's Risk Assessment
Guidance for Superfund (RAGs); Volume I. Human Health Evaluation
Manual.
The data used in the Baseline Risk Assessment for ground water
were from samples collected and analyzed by the Michigan
Department of Public Health and the Michigan Department of
Natural Resources between 1989 and March 1991. Data collected
prior to 1989 were excluded from these tables because the more
recent data were believed to be more representative of present
conditions. Data.from more recent sampling rounds were not
available for inclusion in the Baseline Risk Assessment.
However, a qualitative discussion has been added to account for
new information from the most recent sampling events.
6.1 BASELINE RISK ASSESSMENT - CHEMICALS OF POTENTIAL CONCERN
Chemicals considered in the Baseline Risk Assessment are those
which are present as a result of chemical releases which have
occurred at the Site and are termed "chemicals of potential
concern". To identify these, chemicals present in soil and
ground water samples are distinguished from those which may
naturally be present (Site background) and those which can be
unintentionally introduced into samples through sample collection
or laboratory analysis. Further, consideration is given to the
frequency of occurrence of the chemical at the Site. Those
infrequently identified may not be significant in view of overall
Site contamination. Chemicals considered to be of potential
concern are evaluated further in the Baseline Risk Assessment.
All of the chemicals that were detected in the ground water
between 1989 and 1991 were included as chemicals of potential
concern, with the exception of bromodichloromethane, bromoform,
chloroform, and dibromochloromethene, which are. trihalomethanes
associated with chlorination that were detected at the Ingalls
Well. For the purposes of the Baseline Risk Assessment, the
chemicals of potential concern at the site were:
Arsenic;
cis-1,2-Dichlbroethene;
trans-1,2-Dichloroethene ;
Methyl-t-butyl ether;
Tetrachloroethylene;
1,1,1-Trichloroethane;
Trichloroethylene; and
Zinc.
Although analysis of ground water from monitoring wells in the
-------
13
early 1980s detected SVOCs, the levels dropped off after
completion of the removal action. Therefore, until 1992 and
1993, the Remedial Investigation did not routinely analyze for
SVOCs at monitoring wells. For the timeframe evaluated in the
Baseline Risk Assessment there were no SVOC data to support
inclusion of chemicals that have been seen at low levels in the
1992 and 1993 sampling rounds. A qualitative discussion of the
impact of SVOCs in the ground water is presented below in Section
6.5.
In the data used for the Baseline Risk Assessment for ground
water, trihalomethanes were detected only in the Ingalls well,
which was sampled following chlorination of the well.
Trihalomethanes can form in water from chlorination so it can be
reasonably be assumed that the trihalomethanes, which were not
detected in the monitoring wells, are due solely to the
chlorination of the water supply and are not related to the PMC
site. More recent sampling has shown very low concentrations of
trihalomethanes in area monitoring wells. Therefore, it can be
argued that chlorination at the Ingalls Well is not the sole
source of the trihalomethane contamination. It is necessary to
emphasize that the concentrations of trihalomethanes in the well
field are low and would not cause the Ingalls Well to exceed the
MCL for total trihalomethanes.
6.2. BASELINE RISK ASSESSMENT - TOXICITY ASSESSMENT
The purpose of the toxicity assessment is to evaluate the
potential for chemicals of potential concern to cause adverse
effects in exposed individuals and to provide, where possible, an
estimate of the relationship between the extent of exposure to a
chemical and the increased likelihood and/or severity of adverse
effects.
Exposure to chemicals may elicit both carcinogenic and non-
carcinogenic responses. The carcinogenic response is assumed to
be a "non-threshold" effect; that is, any exposure, no matter how
small, is assumed to increase the potential for developing
cancer. For non-carcinogenic effects, protective mechanisms are
believed to exist that must be overcome before an adverse health
effect can be manifested in an exposed individual. As a result,
it is assumed that a range of exposures from zero to some finite
value exists that can be tolerated by an organism without
expression of adverse effects.
6.3 BASELINE RISK ASSESSMENT - EXPOSURE ASSESSMENT
The exposure assessment identifies actual and potential pathways
by which human exposure to contaminated Site media may occur.
The assessment considers factors such as the physical location of
contaminated areas, the type of contamination and the populations
which may come into contact with these areas. Exposure pathways
-------
14
are identified for two ground water use scenarios, a pathway
based on consumption of water from the Ingalls Well at current
levels of contamination and a pathway based on consumption of
ground water with contaminant levels consistent with levels found
in nearby monitoring wells. Both current and future pathways,
which represent possible exposures, are then quantified to
estimate the magnitude of daily contaminant exposure that a
population may incur. To accomplish this, assumptions pertaining
to the exposed population are made, such as the nature of the
individuals (e.g., child vs. adult), the rate of contact with the
contaminated medium (e.g., adult consumes 2 liters water daily)
and the length of time the exposure is likely to occur (e.g.,
years vs. lifetime). These population variables are then
combined with, chemical concentration data to calculate a level of
exposure.
The current exposed population consists of residents of the city
that use the municipal water supply with water from the Ingalls
Well. The potential future exposed population includes users of
a water supply well that could be installed near the site. The
exposure routes are, for purposes of this risk assessment,
ingestion of ground water, dermal absorption of chemicals in the
water during showering, and inhalation of chemicals that
volatilize from the water to air during showering.
Much of the population of the City of Petoskey is exposed to
water from the Ingalls Well. Therefore, subpopulations of
concern must be considered. These subpopulations include
children, pregnant and nursing mothers, ill persons, and elderly
persons. The toxicity values used in this Baseline Risk
Assessment were developed to be protective of these
subpopulations.
Estimated Intakes of Chemicals from Increstion
Adults were assumed to weigh 70 kg and children were assumed to
weigh 15 kg. An exposure duration of 30 years was used for
adults. This exposure period is based on the upper bound (90th
percentile) number of years spent by an individual at one
residence. Six years was selected as the exposure duration
period for children. The averaging time (the total number of
days over which intakes are averaged) for children was 2,190 days
(6 years times 365 days/year) for exposure to non-carcinogenic
chemicals and 25,550 days (70 years times 365 days/year) for
exposure to carcinogenic chemicals. The averaging times for
adults were 10,950 days (30 years times 365 days/year) for
exposure to non-carcinogenic chemicals and 25,550 days (70 years
times 365 days/year) for exposure to carcinogenic chemicals. For
carcinogenic effects, the total dose during the exposure period
was assumed to be cumulative and is averaged over a lifetime (70
years). Adults were assumed to ingest 2 liters of water a day;
children were assumed to ingest one liter of water a day. The
-------
15
exposure frequency was assumed to be 350 days per year.
Estimated Intakes of Chemicals by Dermal Absorption
In addition to evaluating the possible adverse effects from
drinking contaminated water, the Baseline Risk Assessment also
considered possible risks from' dermal absorption of chemicals
during showering. An exposure time of 0.17 hours/event (10
minutes) and an exposure frequency of 350 days/year were used to
estimate dermal exposure.
Estimated Intakes of Chemicals by Inhalation
Volatile chemicals such as TCE may volatilize from water to air
during showering. The contaminants may then be inhaled by the
bather. An exposure time of 0.34 hours/event (20 minutes) was
used for inhalation during showering to account for 10 minutes
spent in the shower and an additional 10 minutes spent in the
bathroom after showering during which inhalation of the chemicals
of potential concern present in air could occur. An exposure
frequency of 350 days/year and an inhalation rate of 0.6 m3/hour
were used for both adults and children. A respirable fraction of
100% was assumed.
Using these scenarios, risk numbers are calculated for each
contaminant. These calculations factor in the amount of exposure
assumed, the dose of the chemical received (based on the
available monitoring data), and a toxicity value for each
individual chemical which quantifies the toxicity of that
chemical. Different toxicity values are used based on whether or
not the chemical is carcinogenic. The toxicity value for a
carcinogenic chemical is called a slope factor, and the toxicity
value for a noncarcinogen is called a reference dose.
6.4 BASELINE RISK ASSESSMENT - RESULTS
The results of these calculations are estimates of cancer risk
for carcinogenic risks and estimates of Hazard Indices for
noncarcinogenic risks. The cancer risk number is expressed in
scientific notation and represents an estimate of an individual's
increased risk of getting cancer over a lifetime. The
carcinogenic risk estimate is generally a conservative estimate,
i.e., the risk may be less than predicted. For example, 1.0 x
lO'6 represents an increase in an individual's risk of cancer by l
chance in a million, under the exposure conditions assumed. U.S.
EPA considers this 1.0 x 10"6 number as a point of departure when
determining risk at a Site. Risks calculated to be less than
this value are considered protective of human health and the
environment, while risks between 1.0 x 10"* and 1.0 x 10"* are
within a range acceptable to U.S. EPA but may not be considered
protective due to site-specific.conditions. Risks greater than
-------
16
1.0 x 10"4 are generally unacceptable.
The Hazard Index (HI) represents the risk of adverse non-cancer
effects occurring due to exposure to the Site. The HI number
generated is interpreted differently from the cancer risk number.
To evaluate risk at a site due to noncarcinogenic contaminants,
U.S. EPA has determined that an HI less than or equal to l
estimates that no adverse effects are likely to occur due to the
hypothetical exposure, while a Hazard Index greater than l
estimates that adverse effects due to site exposure may occur and
signals that potential risks to human health must be carefully
evaluated.
In summary, the Baseline Risk Assessment calculated the following
risks from use of ground water at the Site:
• The carcinogenic risk to an adult resulting from 30 years of
residential use of ground water from the Ingalls Well is
2.8 x 10"6. The Hazard Index calculated for this scenario is
less than 1.
• The carcinogenic risk to a child resulting from 6 years of
residential use of ground water from the Ingalls Well is
1.3 x 10"6. The Hazard Index calculated for this scenario is
less than 1.
• The carcinogenic risk to an adult resulting from 30 years of
residential use of ground water from a contaminated private
well is 1.9 x 10"5. The Hazard Index calculated for this
scenario is less than 1.
• The carcinogenic risk to a child resulting from 6 years of
residential use of ground water from a contaminated private
well is 9.0 x 10"*. The Hazard Index calculated for this
scenario is less than l.
The current VOC contaminant levels present in the Ingalls Well are
below MCLs. Therefore, according to the chemical data gathered to
date from the Ingalls Well, the water is of acceptable quality
according to Federal chemical-specific standards. Because the
current risk from residential use of the water from the Ingalls
Well (2.8 x lO^6) is within the U.S. EPA's acceptable risk range of
IxlO"6 to 1x10"*, U.S. EPA has the discretion to decide whether site-
specific conditions warrant an action.
The risk posed by future consumption of ground water from a
contaminated private well (1.9 x 10'5) is also within the risk range
where U.S. EPA has discretion concerning the acceptability of a
risk and the need for remedial action.
U.S. EPA has determined that there is uncertainty associated with
-------
17
future concentrations of volatile chemicals in the Ingalls Well.
The risk estimates summarized above do not reflect the possibility
that site conditions could change and higher levels of contaminants
could enter the well at. levels which exceed health-based standards.
See Section 6.6 below. Therefore, notwithstanding these present
and future risk scenarios, the U.S. EPA finds that actual or
threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this ROD,
may present an imminent and substantial endangerment to public
health, welfare, or the environment.
6.5 BASELINE RISK ASSESSMENT - IMPLICATIONS OF MORE RECENT DATA
Results from the sampling round conducted in December of 1992 and
March of 1993 were not included in the Baseline Risk Assessment.
In general, the levels seen in monitoring wells were not
significantly different than those seen during earlier sampling
rounds. However, there was one additional contaminant found that
could have an impact on the future scenario for calculation of risk
to users of a private well. Vinyl chloride was seen at 2 ppb in
monitoring well PS-4. If the 2 ppb detection of vinyl chloride
were to be used in the risk calculations, the risk from consumption
of contaminated water from a private well would increase
significantly. However, inclusion of vinyl chloride at the 2 ppb .
level would be a very conservative assumption since other
monitoring wells have not detected the contaminant and a lifetime's
worth of ground water would, based on the monitoring results, not
be contaminated at that level. Vinyl chloride has not been seen in
the municipal well and, therefore, this detection would not have an
impact on the risk calculations for the current municipal ground
water use scenario.
As discussed above in Section 6.1, SVOCs were not considered in the
original calculation of risks. As seen in Table 1, the primary
SVOCs found in ground water were Di-n-octyl Phthalate and
bis(2-Ethylhexyl)Phthalate. Although no MCL is available for
Di-n-Octyl Phthalate, the estimated maximum concentration seen in
ground water, 7 ppb, is far below the MDNR Act 307 Type B Health
Based Drinking Water Value of 130 ppb which is used here solely as
a point of reference. It is interesting to note that no Di-n-octyl
Phthalate was detected in wells during the December 1992 round of
sampling. All detections noted in Table 1 are from March 1993
data. Future rounds of sampling will confirm the presence or
absence of this contaminant and assist in determining whether the
contaminant is site related or a laboratory contaminant. Because
the contaminant has not been seen in the Ingalls Well, inclusion of
Di-n-octyl Phthalate in the Baseline Risk Assessment would have no
effect on the risk from consumption of municipal water. Inclusion
of the chemical in the Baseline Risk Assessment would have a
negligible effect on the calculated risks for a private well.
The MCL for bis(2-Ethylhexyl)Phthalate is 6 ppb. The estimated
-------
18
maximum concentration of bis(2-Ethylhexyl)Phthalate seen in
monitoring wells, 7 ppb, exceeds the MCL. The chemical was not
detected in the Ingalls Well when sampled in December 1992. in
the March 1993 sampling round, 0.5 ppb of the contaminant was seen
in the Ingalls Well. Such a low level of this contaminant would
have very little effect on the level of risk calculated in the
Baseline Risk Assessment for consumption of ground water from the
Ingalls Well. Because of the dilution that occurs as the Ingalls
Well operates the presence of bis(2-Ethylhexyl)Phthalate is not
expected to cause the MCL to be exceeded at the Ingalls Well.
However, the estimated maximum concentration of bis(2-
.Ethylhexyl)Phthalate seen in monitoring wells would increase the
overall risk from consumption of ground water from a private well.
During the 1992 and 1993 sampling conducted by MDNR, arsenic was
not seen in monitoring wells or in Ingalls Well samples. Because
arsenic was previously seen in a single monitoring well south of
the PMC Site and not in the Ingalls Well, arsenic was included only
in the Risk Assessment calculations for private well users. In an
April 1993 sampling of City monitoring wells conducted by McNamee,
arsenic was found at very low levels in City monitoring wells.
However, the distribution of detections does not demonstrate that
PMC is the source of the low level arsenic seen periodically in
ground water. It is possible that the presence of arsenic could be
due to background conditions. If arsenic were determined to be
naturally occurring at levels seen during monitoring, it may be
appropriate to remove arsenic from consideration in the Baseline
Risk Assessment. Because arsenic was the primary source of risk in
the private well scenario, the removal of arsenic from the Baseline
Risk Assessment would, greatly decrease the estimated risk to users
of private contaminated wells. However, if arsenic were to be
removed from the risk calculations, the risk to private well users
would remain within U.S. EPA's discretionary risk range. All
arsenic detections in the well field are far below the MCL of 50
ppb.
Antimony was seen in several monitoring wells and in the Ingalls
Well during the December 1992 sampling event; the detection of
antimony at the Ingalls Well was estimated at 13.9 ppb and exceeded
the 6 ppb MCL. Follow-up sampling conducted in March of 1993 did
not detect the presence of antimony in the wells where antimony had
previously been seen or in any monitoring wells at the Site. In
addition, U.S. EPA sampled the Ingalls Well in January 1995 and
found no antimony in either well tap or well point samples.
Although recent sampling has not shown antimony to be a concern at
the Ingalls Well, the risk to users of the Ingalls Well and the
risk to users of potentially contaminated private wells would
increase if future sampling detects antimony in the Ingalls Well or
the well field.
-------
19
6.6 UNCERTAINTIES
The lack of analyses for many chemicals may mean that there are
chemicals present that were not evaluated in this risk assessment.
This will tend to underestimate the risks associated with the Site.
As an example, inorganic chemical data for the Ingalls Well were
not available for the timeframe evaluated in the Baseline Rislc
Assessment.
The Baseline Risk Assessment could not quantify risks from those
contaminants without known slope factors or reference factors. The
slope factors calculated by the U.S. EPA for potential carcinogens
have inherent uncertainty because they are calculations of lifetime
cancer risks based on less-than-lifetime 'exposures and incorporate
high-dose to low-dose extrapolations. In addition, methods to
quantify risks and possible synergistic effects due to exposure to
multiple contaminants or multiple pathways are very limited. The
use of risk additivity helps prevent the underestimation of cancer
risks or potential noncancer health effects.
The quantitation limits for some chemicals may be greater than
corresponding ground water standards, criteria, or other "toxicity
reference values." This could result in a chemical remaining
undetected even though it is actually present at a concentration
that could be of significance to the risk assessment.
The Baseline Risk Assessment cannot account for the possibility
that Site conditions could change and higher levels of contaminants
could enter the Ingalls Well in excess of health-based standards.
6.7 ENVIRONMENTAL RISKS
Because the alternatives proposed as part of the interim action
address the municipal water supply and possible residential use of
contaminated ground water from a private well, no formal
quantitative ecological assessment was necessary. There are no
known ecological risks from the residential use of contaminated
ground water.
At present, the plume of contaminated ground water discharges to
Lake Michigan, but at levels not believed to pose any risk to
ecological habitats. This topic will be discussed further in the
final Record of Decision for the Site.
7.0 DESCRIPTION OF ALTERNATIVES
Based on the results of the available ground water monitoring data,
the U.S. EPA prepared a Focused Feasibility Study (FFS) to identify
and evaluate remedial alternatives that would minimize or eliminate
the health risks caused by site-related contaminants. The goal for
remedy selection at the Ingalls Well is to select a remedial action
that would protect the municipal well supply from unacceptable
-------
20
levels of contamination from the PMC site. Five alternatives were
evaluated.
7.1 ALTERNATIVE ONE: NO ACTION
Alternative One is the No Action Alternative. The National
Contingency Plan (NCP) requires that the No Action Alternative be
carried through the detailed analysis of alternatives. Under this
alternative, no active remedial action or institutional controls
would be applied at the site."
If no interim action were taken to remediate the ground water at
the Ingalls Well or to develop another source, VOCs in the ground
water at the jlngalls Well would be expected to continue to be
present at current levels. In general, residual contamination in
the ground water aquifer would be expected to decline over time as
the organics are slowly diluted by natural recharge of the aquifer.
However, the possible presence of a DNAPL near the Ingalls Well
complicates any evaluation of future impacts of well field
contamination on the Ingalls Well. While recent levels of TCE
(estimated at 4 ppb) at the Ingalls Well have been below the MCL of
5 ppb, U.S. EPA cannot predict the future behavior of the DNAPL
that may be present in fractures in the bedrock. If no interim
action were taken, the high levels of TCE contamination at Well PS-
CD indicate that the Ingalls Well remains at risk for further
contamination. Under the No Action Alternative, contaminant
exposure pathways including ingestion, air emissions, and dermal
contact would remain and present risks.
Capital and operating costs for Alternative One would be zero
because no remedial action, institutional controls, or monitoring
would be implemented. Therefore, there is no net present value
cost associated with implementation of Alternative One.
7.2 ALTERNATIVE TWO: DEVELOPMENT OF A NEW GROUND WATER SOURCE
In 1987, a water supply study was performed for the City of
Petoskey by its contractor, McNamee, to evaluate the possibility of
developing a new ground water source. The water supply study was
revised by McNamee in 1990. The study identified Bear Creek/Bay
View area as a location that may be suitable for meeting the city's
present and future water supply needs.
At the Bear Creek site, three new wells would have to be installed
to replace the existing capacity of the Ingalls Well. Each well
would have a capacity of 600 gallons per minute (approximately 2.59
million gallons per day). Approximately six and a half miles of
new pipeline would be required to connect the new well field to the
existing City watermain system. In addition, improvements would
need to be made to the city watermain to connect both storage tanks
to the new water supply. The Ingalls Well is currently capable of
providing backup service to the lower pressure district, which is
-------
21
normally serviced by the L-ime Kiln Municipal Well. The estimated
2.59 million gallons per day (MGD) is below the current maximum
capacity of the Ingalls Well when the Lime Kiln Well is out of
service. If it is determined that the replacement water supply
discussed in this alternative should also be capable of supporting
the water supply needs of the lower pressure district,
consideration should be given to installing a fourth well to
increase capacity above the high pressure district's maximum day
demand. Construction and operation of an additional 600 gpm well
would increase capacity to approximately 3.45 million gallons per
day (MGD) and would exceed the City's current maximum day demand.
Development of a new, non-contaminated ground water source would
remove the contaminant exposure pathway to municipal water users in
the Petoskey community. Both direct human contact, and
environmental exposures due to volatilization and direct contact
will be eliminated. Initial placement of the replacement well(s)
would be important to ensure that it would not be affected by this
contaminant plume or other possible ground water contamination.
Alternative Two would have no effect on private well users if they
continue to utilize water from the contaminated aquifer.
Capital costs for Alternative Two were assumed to include: three
new supply wells, alternate power supplies for the well field and
booster station, a booster station, water mains, and improvements
to the present city system. Costs also include indirect capital
costs such as engineering, construction management, and a 20
percent contingency. The cost of the land necessary for this
alternative is not included as a capital cost. Capital costs for
Alternative Two with three 600 gpm wells are estimated to be
$6,128,000. If a fourth 600 gpm well is added, capital costs are
estimated to be $ 6,472,000.
Annual operating costs for Alternative Two are estimated to be
$440,275 for a three well system and $548,000 for a four well
system. Annual costs include estimated utilities, maintenance,
chemicals and supplies, and analytical expenses.
Based on a 30-year operating life, the net present value cost for
implementation of Alternative Two with the three well system is
estimated to be $11,591,111. The net present value of the four
well system is estimated to be $13,272,155. The net present value
is computed using a constant 7 percent discount rate for the life
of the project. For purposes of evaluation in the FFS, the capital
cost was amortized as a "one-time" cost at the beginning of the
remediation, and the annual costs were initiated in the first year.
7.3 ALTERNATIVE THREE: DEVELOPMENT OF A LAKE MICHIGAN SURFACE
WATER SUPPLY INTAKE AND TREATMENT SYSTEM
In addition to evaluating the possibility of developing a new
ground water source (Alternative Two), the McNamee water supply
-------
22
study also evaluated the possibility of constructing a new surface
water intake and treatment system. Four alternative sites for a
surface water supply intake and treatment system were investigated.
After review of the location options and selection procedures in
the McNamee study, Site Number 1 (Ingalls Avenue) appears to be the
preferred location for a water treatment plant and will therefore
be evaluated in this alternative. The open space for a surface
water treatment plant is available at the Ingalls site, and the
treatment plant's effluent could be tied into the existing
distribution system. The city currently owns approximately 2.25
acres at the Ingalls Avenue location and this would be adequate for
the plant, although it would not be of adequate size to allow for
any future expansion.
The Ingalls Well has capacity in excess of the current usage. The
design for this alternative is based upon the existing service area
average day demand of 1.60 MGD and the maximum day demand of 3.2
MGD placed on the Ingalls Well. These design criteria are . •
consistent with those calculated by McNamee.
Development of a new, surface-water source of drinking water would
remove the contaminant exposure pathway to municipal water users in
the Petoskey community. Both direct human contact, and
environmental exposures due to volatilization and direct contact
will be eliminated. Alternative Three would have no effect on
private well users if they continue to utilize water from the
contaminated aquifer.
Capital costs for Alternative Three were assumed to include the
intake structure and piping, low-service pump station, water
treatment plant, clear well, drying/seepage beds, water treatment
plant site improvement, water main and installation. Costs also
include indirect capital costs such as engineering, construction
management, and contingency calculated at 25% of the installed
cost. Capital costs for Alternative Three are estimated to be
$7,113,000 for a conventional treatment plant and $6,069,000 for a
direct filtration treatment plant.
Annual operating costs for Alternative Three are estimated to be
$225,000 for a conventional treatment plant and $195,000 for a
direct filtration treatment plant. Annual costs include estimated
utilities, estimated maintenance, chemicals and supplies, and
insurance and training.
Based on a 30-year operating life, the net present value cost for
implementation of Alternative Three is estimated to be $9,905,034
for the conventional treatment plant and $8,488,763 for direct
filtration treatment plant. The net present value is computed
using a constant 7 percent discount rate for the life of the
project. For purposes of evaluation in the FFS, the capital cost
was amortized as a "one-time" cost at the beginning of the
remediation, and the annual costs were initiated in the first year.
-------
23
7.4 ALTERNATIVE FOUR: TREATMENT OF GROUND WATER FROM THE INGALLS
WELL AQUIFER USING AIR STRIPPING
Alternative Four calls for the construction of an air stripping
system for the treatment of the volatile organic contaminants found
in the ground water at the Ingalls Well. Water recovered from the
Ingalls Well would be passed through a 14-foot diameter air
stripper before being directed into the City of Petoskey's drinking
water treatment system and supply network or discharged to nearby
surface water. In order to ensure constant operation of the air
stripping treatment system, two stripping towers and their
associated equipment would be required. One tower would operate at
all times, with the second acting as a backup. Maximum pumping
rate from the Ingalls Well when the Lime Kiln Well is out of
service is 2,200 gallons per minute (gpm); all hydraulic system
components would be designed to accommodate this maximum flow rate.
Water from the Ingalls Well would be initially pumped to the top of
the stripping column, distributed across the tower diameter, and
allowed to pass downward through 15 feet of random packing within
the tower. Concurrently, 8,500 cubic feet per minute (cfm) of air
is discharged upward through the packed section. Contact between
the air and ground water will be accentuated by the high surface
area of the packing material. The high contact efficiency and
physical properties of the volatile organic compounds would allow
the VOCs to transfer from the ground water into the vapor stream.
Sufficient contact time in the stripper would result in "clean"
water exiting the bottom of the tower. The treated water would be
collected in an effluent tank equipped with a recycle pump. The
recycle pump would be used to maintain a minimum constant flow of
water through the treatment system in the event of the loss of feed
water flow. After exiting the treatment system, the contents of
the effluent tank would be chlorinated by the existing addition
system and pumped to the City's drinking water treatment system or
surface discharged without chlorination, based on the demands of
the community.
If, based on a comparison with State and Federal standards,
treatment of the contaminant-laden vapor stream from the air
stripper would be found to be necessary, the off-gas would be
collected at the top of the stripping tower and directed into
vapor-phase carbon beds (CVA system).. As the air passes through
the carbon, the organic contaminants within the air stream would be
adsorbed onto the activated carbon. Air leaving the carbon filters
would then be expected to be below the limits set for emissions by
air permits (or substantive permit equivalent). Based on the use
of the dilution factor matrix for air dispersion and initial mass
balances it is unlikely that the use of vapor-phase adsorption
would be necessary. At 100 percent stripping efficiency, it is
estimated that the system would release a maximum of 140 pounds of
VOCs per year. Should vapor-phase carbon beds be used in
conjunction with air stripping, it would be necessary to determined
-------
24
if the spent carbon is hazardous under 40 CFR Part 261. If the
spent carbon would be determined to be hazardous, it would have to
be managed according to Federal and State hazardous waste
regulations.
The initial construction necessary for Alternative Four would be
the preparation of the site for the treatment system. The ground
water treatment system would be placed at the Ingalls Well site, in
conjunction with the existing water pretreatment equipment. The
air stripping system would require a reinforced concrete foundation
for the placement of the columns and associated piping. For ease
of operation during the winter months, a protective structure would
enclose the associated treatment system equipment. Valves,
controls and instrumentation would be installed within the climate-
controlled structure to facilitate maintenance during inclement
weather. Sufficient space would be allowed within the structure to
allow easy access when servicing.
The stripper would be fabricated off-site and shipped to the
Ingalls Well site from the manufacturers. Installation of the
equipment, connecting piping, and associated appurtenances would be
completed on site by construction contractors. Construction
activities would not require direct contact with the contaminated
ground water and would therefore be performed in Level D personal
protection equipment.
Institutional actions would be initiated during, construction to
prevent exposure of the general public to dangerous conditions.
This would include the fencing of the site prior to construction
activities to restrict access and the implementation of appropriate
security measures. The fencing of the site would be permanent
during operations to maintain an air dispersion area with limited
public access around the air stripper.
Following the start-up of the treatment system, a monitoring
schedule would be initiated at the Ingalls Well treatment system.
Regular monitoring would include a daily check of flow rates and
pressure drops through the operating system components. Frequent
monitoring of the quality of the influent and effluent liquid
streams from the air stripping system will confirm the operating
efficiency of the treatment system. Monitoring results and carbon
contaminant loading calculations will be used to determine the need
for carbon replacement. Routine sampling and chemical analysis of
ground water from nearby monitoring wells would be included to
track the levels and types of contamination in the aquifer.
The air stripper could be designed to either operate continuously
or on a demand basis. Continuous operation would optimize
performance of the stripper system and provide supplemental removal
of VOCs from the well field during periods when the municipal
supply does not require the Ingalls Well to pump. Continuous
operation would also require the surface water discharge of excess
-------
25
treated water to Lake Michigan.
Operation of the system on a demand basis would reduce utility
charges included as a part of O&M and eliminate the need for the
discharge of large amounts of excess water to Lake Michigan.
However, the operation of the system on a demand basis would also
require the provision of an approximately 200,000 gallon clear well
to serve as an intermediate storage point for water prior to
treatment. The capital cost of the clear well is included in the
cost estimate for this alternative.
Proper air-stripping of the drinking water supply at the Ingalls
Well would essentially remove the VOC contaminant exposure pathway
to municipal Water users in the Petoskey community. Both direct
human contact, and environmental exposures to VOCs due to
volatilization and direct contact will be virtually eliminated.
Alternative Four would have no effect on private well users if they
continue to utilize water from the contaminated aquifer.
Capital costs for Alternative Four are based on continuous
operation of the system and were assumed to include stripper
fabrication, associated equipment and controls, shipping ,site
preparation, installation, and institutional actions (site fence
and equipment structure). Costs also include indirect capital
costs such.as engineering, construction management, and a 15
percent contingency. Capital costs for Alternative Four are
estimated to be $1,238,000.
Annual operating costs for Alternative Four are estimated to be
$169,000 per year. Annual costs include estimated utilities,
sampling and analytical costs, and estimated maintenance.
Based on a 30 year operating life, the net present value cost for
implementation of Alternative Four is estimated to be $3,335,128.
The net present value is computed using a constant 7 percent
discount rate for the life of the project. For purposes of
evaluation in the FFS, the capital cost was amortized as a "one-
time" cost at the beginning of the remediation, and the annual
costs were initiated in the first year.
7.5 ALTERNATIVE FIVE: TREATMENT OF GROUND WATER FROM THE INGALLS
WELL AQUIFER USING GRANULAR ACTIVATED
CARBON
Alternative Five, carbon treatment, calls for the construction of a
granular activated carbon (GAC) adsorption system for the treatment
of volatile and semi-volatile organic contaminants at the Ingalls
Well. Water recovered from the Ingalls Well would be passed
through the GAC before being directed into the City of Petoskey's
drinking water treatment system and supply network or discharged to
nearby surface water. The maximum pumping rate from the Ingalls
Well when the Lime Kiln Well is out of service is 2,200 gallons per
-------
26
minute. All system components would be designed to accommodate
this maximum flow rate.
The ground water would initially be split into a five stream
manifold system before entering the activated carbon adsorption
system. The system would consist of five 10-foot diameter x 10-
foot high steel vessels, connected in parallel, containing
20,000 pounds of granular activated carbon each. Four of the
carbon vessels would be in service at all times, while the fifth
would act as a backup during carbon changes or system emergencies.
As the water passes downward through the activated carbon beds, the
organic contaminants would be adsorbed onto the carbon surface.
The treated water would be collected in ah effluent tank equipped
with a recycle pump. The recycle pump would be used to maintain a
minimum constant flow of water through the treatment system in the
event of the loss of feed water flow. Contents of the effluent
tank would be chlorinated by the existing addition system and
pumped to the City's drinking water treatment system or surface
discharged without chlorination, based on the demands of the
community. All system components would be automated to require as
little operator supervision as necessary.
The carbon in a vessel would become saturated with the contaminants
following a period of treatment, indicated by samples analyzed from
the stream following the carbon cell. The spent carbon would be
removed from the treatment vessel and analyzed to determine if it
would be a hazardous waste under 40 CFR Part 261. If the spent
carbon would be determined to be hazardous, it would be managed
according to Federal and State hazardous waste regulations. If the
spent carbon is determined to be non-hazardous and if it meets the
requirements of the manufacturer, it will be sent back to the
manufacturer for regeneration. A fresh volume of carbon would be
installed and that vessel put back in service. Removal and
replacement of carbon could be accomplished in a period of several
hours during non-peak use hours, resulting in minimal disruption of
the water supply. Based on the low contaminant loading rate,
however, carbon bed life would be anticipated to be approximately
three years as a worst-case and up to ten years as a best-case.
The initial construction necessary for Alternative Five would be
the preparation of the site for the treatment system. The ground
water treatment system would be placed at the Ingalls Well site, in
conjunction with the existing water pretreatment equipment. The
carbon adsorption system would require a reinforced concrete
foundation for the placement of the carbon cells and associated
piping. For ease of operation during the winter months, a
protective structure would enclose the entire treatment system.
Valves, controls and instrumentation would be installed within the
climate-controlled structure to facilitate maintenance during
inclement weather. Sufficient space would be allowed within the
structure to allow easy access when replacing GAC.
-------
27
The carbon vessels would be fabricated off-site and shipped to the
Ingalls Well site from the manufacturer. Installation of the
equipment, connecting piping, and associated appurtenances would be
completed on site by construction contractors. Construction
activities would not require direct contact with the contaminated
ground water and will therefore be performed in Level D personal
protection equipment. Institutional actions would be initiated
during construction to prevent exposure of the general public to
dangerous conditions. This would include the fencing of the site
prior to construction to restrict access and the implementation of
appropriate security measures.
Following the start-up of the treatment system, a monitoring
schedule would be initiated at the Ingalls Well treatment system.
Regular monitoring would include a daily check of flow rates and
pressure drops through the operating system components. Frequent
monitoring of volatile organic concentration in the streams
following the carbon vessels would indicate the need for the
replacement of carbon. Weekly monitoring of the influent and
effluent from the carbon adsorption system would confirm the
operating efficiency of the treatment system. Routine sampling and
chemical analysis of ground water from nearby monitoring wells
would be included to track the levels and types of contamination in
the aquifer.
Proper carbon treatment of the drinking water supply at the Ingalls
Well would essentially remove the VOC and SVOC contaminant exposure
pathways to municipal water users in the Petoskey community. Both
direct human contact, and environmental exposures to VOCs and SVOCs
due to volatilization and direct contact will be virtually
eliminated. Alternative Five would have no effect on private well
users if they continue to utilize water from the contaminated
aquifer.
Costs for the implementation of Alternative Five have been
estimated as part of the FFS. Capital costs for Alternative Five
were assumed to include carbon cell fabrication, initial GAC
loading, associated equipment and controls, shipping, site
preparation, installation, and institutional actions (site fence
and system structure). Costs also include indirect capital costs
such as engineering, construction management, and a 15 percent
contingency. Capital costs for Alternative Five are estimated to
be $1,444,000.
t
Annual operating costs for Alternative Five are estimated to be
$206,000 per year. Annual costs include estimated utilities,
carbon change out, sampling and analytical costs, and estimated
maintenance. Based on a 30 year operating life, the net present
value cost for implementation of Alternative Five is estimated to
be $4,000,262. The net present value is computed using a constant
7 percent discount rate for the life of the project. For purposes
of evaluation in the FFS, the capital cost was amortized as a "one-
-------
28
time" cost at the beginning of the remediation, and the annual
costs were initiated in the first year.
8.0 COMPARATIVE ANALYSIS OF ALTERNATIVES: TEE NINE CRITERIA
The following nine criteria, outlined in the NCP at Section
300.430(e) (9) (iii), were used to compare the alternatives and to
determine the most appropriate alternative for addressing the
Ingalls Well contamination in a manner that is protective of human
health and the environment, attains applicable or relevant and
appropriate requirements (ARARs), is cost-effective and represents
the best balance among the evaluating criteria. An alternative
providing the "best balance" of tradeoffs with respect to the nine
criteria is determined from this evaluation.
8.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This evaluation criterion provides confirmation of the
effectiveness of a remedial alternative in protection of human
health and the environment. Evaluation of overall protectiveness
of a remedial alternative focuses on whether the alternative
achieves adequate protection and how risks posed by the site are
minimized via remedial or institutional actions. This evaluation
also allows for consideration of unacceptable short-term or cross-
media impacts.
The current levels of contaminants present in the Ingalls Well are
below Maximum Contaminant Levels (MCLs). The present risk from
residential use of the water from the Ingalls Well (2.8 x 10"6) is
within the U.S. EPA's discretionary risk range. However, the
higher levels of TCE contamination seen in ground water at
monitoring wells near the Ingalls Well that have not yet dissipated
indicate that a DNAPL may be present in bedrock fractures. In
recent years, levels of TCE in the Ingalls Well have remained at
approximately 4 ppb, just below the MCL. This is likely due to the
dilution that occurs as the Ingalls Well pumps in both ground water
and, indirectly, surface water from Lake Michigan. Because the
location of the DNAPL, if present, is unknown and DNAPL behavior is
difficult to predict, the U.S. EPA cannot predict the future
concentrations of TCE in the Ingalls Well. During periods of peak
demand, such as when the Ingalls Well must supply water to the
lower pressure district, it is possible that levels of contaminants
in the Ingalls Well could rise above the MCLs. Therefore, while
the No Action Alternative is considered to be protective of human
health and the environment for residential use of water from the
Ingalls Well at current levels of contamination, site-specific
reasons justify an interim action to fully ensure the protection of
the City's water supply from Superfund contamination emanating from
the PMC Site.
Based on current levels of VOC contamination in the Ingalls Well,
-------
29
all alternatives, including No Action, would be expected to provide
long-term protection for human health. If VOC levels at the
Ingalls Well were to increase above current levels, all
alternatives, except possibly No Action, would be expected to
provide long-term protection for human health by reducing or
eliminating exposure pathways to receptors that utilize water from
the Ingalls Well. Alternatives Two and Three would accomplish this
by providing a new, non-affected source of water for the community.
Alternatives Four and Five would treat the minimally affected
ground water to even lower levels before exposure to the community.
The risk posed by future consumption of ground water from a private
well (1.9 x 10'5) is also within the U.S. EPA's discretionary risk
range. However, because of possibility that a well could be sited
in an area that could be impacted by high levels of residual ground
water contamination, the No Action Alternative is not considered to
be protective of human health and the environment for future
residential use of water from a private well. In fact, none of the
alternatives as presented in the FFS will reduce the risk to future
users of private wells.
Although no environmental threat has yet been identified with
regard to this Site, the alternatives evaluated for the interim
action would have slightly different impacts on the environment.
Alternatives One, Four and Five require continued use of the
Ingalls Well and therefore, indirectly, remove contaminants from
the aquifer which discharges into Lake Michigan. Alternatives Two
and Three replace the Ingalls Well, and would result in slightly
greater amounts of contaminants entering the lake. For all
alternatives, however, some contaminants would discharge to Lake
Michigan, and no adverse ecological impacts are anticipated.
8.2 COMPLIANCE WITH ARARS
"Compliance with ARARs" addresses how the proposed alternative
complies with all applicable or relevant and appropriate
requirements of Federal and more stringent State environmental laws
(ARARs), and also considers how the alternatives comply with
advisories, criteria or other guidance to be considered (TBCs) that
do not have the status of laws, but that the U.S. EPA and the State
have agreed are "appropriate" for protectiveness or to carry out
certain actions or requirements.
Because the universe of ARARs is so large, only ARARs necessary for
on-site remedial activities have been identified. In some
instances, rules cited contain both substantive and procedural or
administrative requirements. Only the substantive requirements are
ARARs for the purpose of on-site activities. Examples of
administrative or procedural requirements which are not considered
ARARs include, but are not limited to, reporting requirements and
permit application requirements. A more detailed discussion of
-------
30
Site ARARs is provided in the FFS.
The purpose of all of the alternatives is to ensure a source of
clean water to the city. All of the action alternatives are
capable of providing a water supply to the city that meets
chemical-specific ARARs. None of the alternatives directly
addresses cleanup of the ground water in the well field, although
the two ground water treatment alternatives indirectly will result
in some ground water remediation. ARARs do not apply to no action
alternatives and will not be discussed for Alternative One.
The primary chemical-specific ARARs for all action alternatives are
the Safe Drinking Water Act Maximum Contaminant Levels (MCLs) and
non-zero Maximum Contaminant Level Goals (MCLGs). The Federal
drinking water standards promulgated under the Safe Drinking Water
Act (SDWA),' 40 CFR 141, are applicable to municipal water supplies
servicing twenty-five or more people. MCLs are applicable to the
evaluation of the Ingalls Well. MCLGs are relevant and appropriate
for the evaluation of the Ingalls Well. MCLGs are never applicable
requirements at a CERCLA response action because they are not
enforceable "standards" or "levels of control.". Both MCLs and
MCLGs are relevant and appropriate for the consideration of
possible consumption of ground water from a private well.
Michigan Safe Drinking Water Act - Act 399, P.A. 1976, as amended
and administrative rules, provides regulations establishing MCLs
for certain contaminants in addition to Federal MCLs and would be
applicable for all action alternatives. The Michigan Safe Drinking
Water Act is also an action-specific ARAR as it also outlines
requirements for well construction and operation of a public water
supply. Authority under Superfund, however, does not extend to the
correction of existing deficiencies at the Ingalls Well and in the
Petoskey municipal water system that are not related to the
contamination at the Site.
The MDNR has promulgated administrative rules governing
"Environmental Response Activity" pursuant to the Michigan
Environmental Response Act, 1982 PA 307, M.A.C. 299.605 ("Act 307
Rules"). These Act 307 Rules, codified at M.A.C. Rule 299.5101 et
seq.. contain provisions establishing procedures for response
activities (M.A.C. Rules 299.5501-5519), selection of remedial
action (M.A.C. Rules 299.5601-5607), and cleanup criteria (M.A.C.
Rules 299.5701-5727) at sites of environmental contamination where
response activities are taken pursuant to Act 307. Because this
Interim Action is not meant to remediate the Site, but is instead
an Interim Action meant to ensure that the water supply of the City
of Petoskey meets Federal water supply standards for contaminants
related to the PMC Site, Act 307 and the Act 307 Rules are not
ARARs. Act 307 and the Act 307 Rules would be potential ARARs for
the final remedial action at the Site.
Federal Water Pollution Control Act (Clean Water Act) Section 304
-------
31
provides for the development and publication of water quality
criteria for human health and aquatic life. Water quality criteria
are not legally enforceable standards and are therefore not
applicable. However, a modified water quality criterion for TCE
for drinking water consumption would be relevant and appropriate
for all action alternatives.
Michigan Water Resources Commission Act 245, P.A. 1929 contains
State water quality standards, treatment plant operator
requirements, and wastewater reporting requirements. The rules
also implement a waste effluent discharge system compatible with
NPDES requirements and provide for the non-degradation of ground
water. Because NPDES requirements regulate discharge, these water
quality standards are applicable to action alternatives that may
discharge water to surface water bodies. U.S. EPA has made the
determination that since the selected alternative does not require
discharge to ground water, Act 245 Part 22 Rules, as interpreted by
the State, are not an ARAR for the PMC Site.
40 CFR Part 264, Subpart AA, under the authority of the Resource
Conservation and Recovery Act (RCRA), requires that the total
organic emissions from air strippers be reduced to less than 1.4
kilograms per hour (kg/hr) and 2.8 megagrams per year (Mg/yr; 3
Ibs/hr. and 3.1 tons/year); or that the total organic emissions be
reduced by 95 percent by weight. No organic compound is excluded
under this regulation due to its photochemical reactivity or
nonreactivity. Region 5 has supported the use of this regulation
as an ARAR at sites where air strippers have been used for ground
water remediation, and the U.S. EPA's authority under RCRA to
regulate air stripper emissions was reinforced in the promulgating
notice of 40 CFR 264, AA (55 FR 25468; June 21, 1990). For
Alternative Four, the maximum emissions from an air stripper at the
PMC site is estimated to be 140 pounds of total VOCs per year, well
below these limits. Portions of certain State air regulations may
also be ARARS for this action. The Michigan Air Pollution Act
(including MAC Rules 336.1702, 336.1901, 336.1371-1373, and
336.1201-336.1285) is applicable since emissions from the treatment
system would be subject to State and Federal standards for VOCs.
Alternative Four could be planned and implemented to comply with
action- and location-specific ARARs. Alternative Four must comply
with the substantive requirements of an Air Permit. Because the
action is considered to be "on site", the permit itself would not
be required. Compliance with the substantive requirements of an
air permit would not be triggered by the other action alternatives.
RCRA Land Disposal Restrictions (LDRs), 40 CFR Part 268, are
applicable for Alternative Five and Alternative Four (if vapor-
phase carbon treatment of the off-gas from the air-stripper is
necessary). Spent carbon has the potential of becoming
characteristically hazardous, and therefore, LDRs are applicable
prior to disposal of spent carbon. If characteristic spent carbon
is to be land disposed, it must be placed into a Subtitle C
-------
32
landfill or treated to Toxicity Characteristic (TC) treatment
standards prior to disposal into a Subtitle D landfill. Portions
of the Michigan Hazardous Waste Management Act, 1979 PA 64, as
amended, and administrative rules are also ARARs for the management
of spent carbon.
Location-specific ARARs for Alternatives Two and Three depend on
the particular location selected for the new ground water source or
the new Surface Water intake and Treatment Facility. Assuming that
a new Surface Water Intake and Treatment Facility would be placed
adjacent to Lake Michigan, the Clean Water Act dredge and fill
regulations, the Michigan Great Lakes Submerged Lands Act, the
Coastal Zone Management Act, and other ARARs described in the FFS
are location-specific ARARs for this alternative.
8.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
The residual risk to users of the Ingalls Well and users of
contaminated private wells would be reduced by the No Action
Alternative as the natural recharge of the aquifer dilutes
contaminants present in the well field. However, if a DNAPL is
present, natural attenuation could take a very long time.
Alternatives Two, Three, Four, and Five would all be effective in .
the long-term, depending on the proper design and operation of the
remedial systems.
8.4 REDUCTION OF CONTAMINANT MOBILITY, TOXICITY AND VOLUME THROUGH
TREATMENT
No treatment of the ground water will occur in the No Action
Alternative and Alternatives Two and Three. Therefore, there will
be no reduction in toxicity, mobility, or volume (TMV) through the
actions taken. Dilution of the contaminants due to the natural
recharge of the aquifer will slowly reduce the contaminant
toxicity.
Although the use of Air Stripping and Granular Activated Carbon
(GAC) only transfer contaminants from ground water to another media
(and thus do not reduce TMV), the regeneration of the filter carbon
used in the processes would reduce the TMV through treatment.
Alternative Five would therefore reduce the TMV of VOCs found in
ground water. Alternative Four would reduce the TMV of VOCs in
ground water if levels of contaminants justify the treatment of the
system off-gases. Because only low levels of VOCs are present at
the Ingalls Well, treatment at the well is not expected to remove
large volumes of contaminants; therefore, the amount of TMV
reduction for Alternatives Four and Five would be minimal.
8.5 SHORT-TERM EFFECTIVENESS
The potential for exposures to humans and the environment would not
-------
33
be restricted by the No Action Alternative because no action would
occur through treatment.
Alternatives Two, Three, Four, and Five are all expected to be
effective in the short-term in reducing or eliminating the
potential exposure pathways for human contact. Alternatives Four
and Five may require more rigorous monitoring and the use of
personal protective equipment to ensure that no contaminant
exposures to the workers or the community are caused due to the
remedial efforts.
8.6 IMPLEMENTABILITY
All of the alternatives can be readily implemented. Each
alternative utilizes conventional technologies and readily
available materials to complete the necessary objectives.
Alternatives Two, Three, Four, and Five would all require lead time
to acquire the equipment necessary to initiate the remedial
alternative.
Alternatives Two and Three would take longer to physically
implement than Alternatives Four and Five, due to the necessary
modifications of the existing city water system. Alternative Two
would require the installation of new transmission piping and
storage capacity to get water from a new well field. Alternative
Three would require the upgrading of the watermain system in place
for the Ingalls Well site.
Alternatives Two, Three, Four and Five would require a permitting
period with State and local agencies before implementation. For
Alternatives Four and Five this period would be used to identify
the substantive requirements of permits since the actions are
considered to be "on site" and no permits would be required to be
issued.
Because of concerns regarding existing construction deficiencies at
the Ingalls Well, the implementability of Alternatives Four and
Five would be dependant on the approval of the State of Michigan
prior to construction.
8.7 COST
Initial capital and annual operating costs were estimated for each
of the remedial alternatives under consideration. Capital and
operating costs were assumed to include all costs associated with
site management.
Capital and operating costs for Alternative One would be zero
because no remedial action, institutional controls, or monitoring
would be implemented. Therefore, there is no net present value
cost associated with implementation of Alternative One.
-------
34
The costs for initiating Alternatives Two and Three, both of which
require the installation of extensive new water supply and
treatment systems, are high. Capital equipment outlays range from
approximately $6,000,000 to $7,000,000, and high operating costs
result in 30-year net present value costs greater than $9,500,000'
for both alternatives.
Costs for Alternatives Four and Five, which utilize systems to
treat the contaminated Ingalls Well water before use, are
significantly lower. The 30-year net present value costs are on
the order of $3,000,000 to $4,000,000 for these two alternatives.
Alternative Four, treatment of the contaminated Ingalls Well water
with air stripping, is the most economical with a 30-year net
present value cost estimated to be $3,335,138. This cost should
also be more stable than the slightly higher cost for the activated
carbon treatment option (Alternative Five) since the operating
costs for electricity with air stripping should fluctuate less than
the costs of activated carbon over the life of the treatment
system..
COST SUMMARY
Alternative One
No Action
Alternative Two
Replacement Wells
- 1800 gpm capacity
- 2400 gpm capacity
Alternative Three
Surface Water Plant
- Conventional
- Direct Filtration
Alternative Four
Air Stripping
Alternative Five
Carbon Treatment
Capital Cost
$ o
$ 6,128,000
$ 6,472,000
$ 7,113,000
$ 6,069,000
$ 1,238,000
$ 1,444,000
O&M
$ 0
$ 440,275
$ 548,000
$ 225,000
$ 195,000
$ 169,000
$ 206,000
NPV
$ 0
$ 11,591,111
$ 13,272,155
$ 9,905,034
$ 8,488,763
$ 3,335,128
$ 4,000,262
8.8 STATE ACCEPTANCE
MDNR concurs with the selected alternative.
8.9 COMMUNITY ACCEPTANCE
Community acceptance is assessed in the attached Responsiveness
Summary. The Responsiveness Summary provides a thorough review of
the public comments received on the.Proposed Plan, and the Agency's
-------
35
responses to those comments.
9.0 TEE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, as amended
by SARA., and the NCP, the detailed analysis of alternatives and
public comments, U.S. EPA and the State of Michigan have selected
Alternative Four as an interim remedy at the Petoskey Municipal
Well Field Site. Alternative Five is also selected as a contingent
remedy under this ROD should a site-related SVOC exceed an MCL at
the Ingalls Well tap within either eighteen months of the date of
this Record of Decision or before a replacement water supply
becomes operational, whichever comes first. This eighteen month
timeframe isiconsistent with the timeframe.requiring the upgrade or
replacement of the water supply due to existing engineering
deficiencies and the infiltration of surface water at the Ingalls
Well. To confirm the need for carbon treatment, the site-related
SVOC MCL exceedance must be detected in two quarters of sampling at
the Ingalls Well tap.
The detailed evaluation of ground water alternatives found that:
• Based on current levels of contamination in the Ingalls Well,
Alternative One is protective of human health and the
environment. However, because of the uncertainty associated with
higher levels of ground water contamination present in the well
field, Alternative One would not ensure the protection of the
City's water supply from the contamination emanating from the PMC
Site;
• While Alternatives Two and Three may satisfy non-Superfund
related concerns of the City of Petoskey, Alternatives Four and
Five provide protection from unsafe levels of VOCs at
significantly less cost;
• In comparison with Alternative Four, Alternative Five does not
increase VOC removal effectiveness in proportion to its higher
cost;
• Alternative Five provides treatment of semi-volatile contaminants
that the State of Michigan believes could threaten the Ingalls
Well in the near future; and
• None of the alternatives as presented in the FFS protects a
future user of contaminated water from a private well.
Based on the information available at this time, the U.S. EPA and
the State of Michigan believe that the selected alternative,
Alternative Four, and the contingent alternative, Alternative Five,
will reduce the risks to human health and the environment by
removing and treating solvent contamination in the ground water at
the Ingalls Well. If U.S. EPA finds that it is necessary to
-------
36
address site-related SVOC contamination at the Ingalls Well tap,
carbon treatment will be used to address both VOC and SVOC
contaminants. Alternatives Four and Five will also be cost-
effective, attain ARARs, and use permanent solutions to the maximum
extent practicable.
10.0 STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of Section 121
(a-e) of CERCLA, as amended by SARA, to:
a. Protect human health and the environment;
b. Comply with ARARs (or justify a waiver);
c. Be cost effective;
d. Utilize permanent solutions and alternative treatment or
resource recovery technologies to the maximum extent
practicable; and,
e. Satisfy the preference for treatment as a principal element
or provide an explanation as to why this preference is not
satisfied.
The implementation of Alternative Four or Alternative Five
satisfies the requirements of CERCLA, as amended by SARA, as
detailed below:
a. Protection of Human Health and the Environment
Alternative Four is expected to be protective of human health and
the environment at the Ingalls Well by minimizing or eliminating
the contaminant exposure potential. If SVOC treatment is found to
be necessary, Alternative Five will minimize or eliminate both VOC
and SVOC exposure potential. The long-term effectiveness of either
alternative depends on the design and operation of the on-site
treatment system.
The treatment method (air stripping) transfers contaminants from
the liquid phase (water) into the vapor phase. Therefore, there is
the possibility of exposure to the contaminants in the air.
Rigorous control measures and the low initial contaminant
concentration will minimize or eliminate the airborne contaminant
possibility. The contingent treatment method (carbon treatment)
transfers contaminants from the water to the granular activated
carbon. Control measures will be used to reduce the possibility of
contaminant exposure during regeneration or disposal of the spent
carbon.
The removal of VOCs by air stripping at the Ingalls Well will
eliminate the contaminant exposure pathway to municipal water users
in the community. If U.S. EPA finds SVOC treatment to be
necessary, carbon treatment will also eliminate the contaminant
exposure pathway. However, because this interim action does not
directly address contamination in the well field, future users of
-------
37
private contaminated wells will derive little benefit from
continued operation of the Ingalls Well with treatment for VOCs
and/or SVOCs. However, to reduce the possibility that private well
contamination will be a problem, District Health Department #3,
which serves Emmet county, has the authority to restrict the
installation of private wells in areas known to be contaminated.
The District Health Department's well permit program can serve as
an institutional control to deter the placement of wells in areas
that are or could be impacted by contamination-from the PMC Site.
No confirmed contamination has been detected in the three existing
residential wells near the Site. However, it is anticipated that,
as part of the continuing RI/FS, existing private residential wells
in the area will be monitored as necessary to ensure protection of
human health.
The interim action at the PMC Site was initiated to evaluate risks
resulting from residential consumption of impacted ground water.
Environmental risks from the contaminated well field are beyond the
scope of this action. If Alternative Four or Alternative Five is
implemented, the continued extraction of contaminated ground water
at the Ingalls Well will reduce the amount of contaminated ground
water that would naturally discharge to Lake Michigan. However, as
noted above, low-level VOC contamination will be released into the
air with the implementation of Alternative Four. VOCs and SVOCs
that will be removed from the water supply with Alternative Five
will be transferred to the granular activated carbon, which will
require off-site disposal or regeneration.
Short-term risks resulting from the construction of an air
stripping or carbon treatment system would be minimal and could be
controlled with the use of standard safety measures, such as
fencing, use of protective equipment, and air monitoring.
b. Compliance with ARARs
The remedy selected will meet or attain the applicable or relevant
and appropriate Federal and State requirements, and will be
implemented in a manner consistent with these laws. •
The primary chemical-specific ARARs for Alternatives Four and Five
are the Safe Drinking Water Act Maximum Contaminant Levels (MCLs)
and non-zero Maximum Contaminant Level Goals (MCLGs). The Federal
drinking water standards promulgated under the Safe Drinking Water
Act (SDWA), 40 CFR 141, are applicable to municipal water supplies
servicing twenty-five or. more people. The remedy will attain
chemical-specific ARARs for contaminants related to the PMC Site.
The Michigan Safe Drinking Water Act provides regulations
establishing MCLs for certain contaminants in addition to Federal
MCLs and would be applicable for Alternatives Four and Five. The
Michigan Safe Drinking Water Act is also an action-specific ARAR as
it also outlines requirements for well construction and operation
-------
38
of a public water supply. However, Superfund authorities do not
allow U.S. EPA to correct existing deficiencies at the Ingalls Well
and in the Petoskey municipal water system that are not related to
the contamination at the Site. Superfund authorities also do not
extend to construction and operational requirements unrelated to
the contamination from the PMC Site.
Michigan Water Resources Commission Act 245, P.A. 1929 implements a
waste effluent discharge system compatible with NPDES requirements
and provides for the non-degradation of ground water. Because the
Air Stripper in Alternative Four may be designed to operate
continuously with the excess treated water to be discharged to Lake
Michigan, Alternative Four must comply with the substantive
requirements jof an NPDES permit. Since the discharge would be
considered to be "on site" for purposes of this CERCLA action, no
actual permit would be required.
40 CFR 264, AA, under the authority of the Resource Conservation
and Recovery Act (RCRA), requires that the total organic emissions
from air strippers be reduced .to less than 1.4 kilograms per hour
(kg/hr) and 2.8 megagrams per year (Mg/yr; 3 Ibs/hr. and 3.1
tons/year); or that the total organic emissions be reduced by 95
percent by weight. The maximum emissions from an air stripper at
the PMC site is estimated to be 140 pounds of total VOCs per year,
well below these limits. Alternative Four must comply with the
Michigan Air Pollution Act, 1965 PA 348, as amended and associated
rules, and the substantive requirements of an air permit.
If Alternative Five is implemented, the granular activated carbon
will eventually become saturated with contaminants. The spent
carbon will removed from the treatment vessel and analyzed to
determine if it is be a hazardous waste under 40 CFR Part 261. If
the spent carbon is determined to be hazardous, it will be managed
according to Federal and State hazardous waste regulations. If the
spent carbon is determined to be non-hazardous, and, if it meets
the requirements of the manufacturer, it will be sent back to the
manufacturer for regeneration.
The Federal Coastal Zone Management Act and Michigan's Shorelands
Protection and Management Act are location specific ARARs for this
alternative.
Alternative Four or Alternative Five can be constructed and
operated in a manner that would allow the remedy to comply with all
chemical, action and location-specific requirements.
Cleanup standards for the municipal water under Alternative Four or
Alternative Five will be MCLs and applicable non-zero MCLGs for
VOCs. Since current levels of VOCs in the ground water at the
Ingalls Well already meet the cleanup standards, the construction
and operation of Alternative Four or Alternative Five would further
reduce existing VOC levels and address any higher levels of VOC
-------
39
contamination that may enter the well. Alternative Five would also
address SVOC contamination. The point of compliance will be at the
point of entry into the distribution system. For surface water
discharge of treated water, treatment of VOCs in ground water must
meet the approved discharge standards.
Operation of the air-stripping (or carbon) treatment system at the
Ingalls Well may be discontinued when the U.S. EPA determines that
levels of VOCs (and SVOCs) in the well field no longer impact or
threaten the water supply from the Ingalls Well. Treatment at the
well may also be discontinued if the Ingalls Well is replaced as a
source of drinking water for the City of Petoskey.
c. Cost Effectiveness
A cost-effective remedy is one for which the cost is proportional
to the remedy's overall effectiveness. The detailed costs
associated with the implementation of ground water alternatives can
be found in Section 7, with costs summarized in Section 8.
Alternative Four and Alternative Five are each protective of .human
health and the environment and will ensure that unacceptable levels
of VOC contamination do not impact the users of the Ingalls Well.
Alternative Five would also address SVOC contamination that the
State of Michigan believes may impact the Ingalls Well within the
near future. Alternatives Four and Five can each be implemented
utilizing the existing municipal distribution system. Alternative
Four is selected over Alternative Five as the treatment technology
because the use of carbon treatment, and its associated higher
cost, cannot be justified based on the results of non-VOC chemical
monitoring performed to date. However, this contingency ROD allows
the implementation of Alternative Five if site-related SVOC
contamination above an MCL is confirmed at the Ingalls Well tap.
Alternatives Two and Three are not cost effective because
Alternative Four and Alternative Five can treat the water at the
Ingalls Well with significantly less cost than replacing the water
supply.
The increased cost of Alternative Four over Alternative One is
justified because Alternative Four ensures that the Ingalls Well
will be protective of human health even if the possible DNAPL of
TCE causes levels in the Ingalls Well to rise. In selecting
Alternative Four, the U.S. EPA recognizes its responsibility to
ensure that contamination from the PMC property will continue to
have no impact on the Ingalls Well at levels which are considered
unsafe. The selected alternative will, if constructed, reduce
levels of volatile organic compounds that enter the municipal water
distribution system. Because of State of Michigan concerns
regarding the possibility that SVOCs may cause a future MCL
exceedance at the Ingalls Well tap, the increased cost of
Alternative Five would be justified if future sampling at the
Ingalls Well tap reveals the need for. SVOC treatment in order to
-------
40
ensure the safety of the water supply from site-related
contamination.
d. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
U.S. EPA, with the State of Michigan's concurrence, has determined
that the selected and contingent remedies meet the statutory
requirement to utilize permanent solutions and alternative
treatment technologies to the maximum extent practicable for the
Petoskey Municipal Well Field Site. Of the alternatives that are
protective of human health and the environment and comply with
ARARs, U.S. EPA has determined that the selected and contingent
interim ground water remedies provide the best balance of tradeoffs
in terms of long-term effectiveness and permanence, reduction of
TMV through treatment, short-term effectiveness, implementability,
cost and State and community acceptance.
The selected and contingent remedies represent the maximum extent
to which permanent solutions and treatment can be practicably
utilized for this interim action.
e. Preference for Treatment as a Principal Element
The selected alternative, Alternative Four, will utilize air
stripping to remove contaminants from the ground water. Air
stripping transfers contaminants from ground water to air. Current
levels of ground water contamination do not indicate that treatment
of the off-gases from the air stripper will be necessary. However,
if significant levels of VOC contamination are encountered in the
ground water, filter carbon will be used to treat the off-gases
prior to release to the air. Any regeneration of the filter carbon
would reduce the TMV through treatment.
The contingent alternative, Alternative Five, will transfer
contaminants from the ground water to the granular activated
carbon. Regeneration of the spent carbon would reduce the TMV
through treatment.
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
U.S. EPA reviewed all written and oral comments submitted during
the public comment period. Upon review of these comments, it was
determined that no significant changes to the remedy as it was
originally identified in the Proposed Plan were necessary.
However, several minor changes were made in the alternatives
presented in the FFS and Proposed Plan.
Cost estimates were revised for Alternatives Four and Five based on
comments from the Michigan Department of Public Health (MDPH) and
the City of Petoskey. Because U.S. EPA has determined that it is
-------
41
inappropriate to include the capital cost of purchasing property,
the cost for land was removed from the cost estimate for
Alternative Two. The net present value cost estimates for all
alternatives were recalculated based on a 7% discount rate. These
revisions of costs did not change the relative costs of the
alternatives and thus were not significant changes.
The U.S. EPA's position regarding MERA Act 307 and the Act 307
Rules has changed since issuance of the FFS. In the FFS, Act 307
and the 307 Rules were noted as ARARs for all action alternatives.
It was also stated that the ARARs would be waived because: l) the
remedial action is only a part of a total remedial action and the
final remedial action will attain ARARs for ground water upon its
completion; and 2) compliance with the ARARs "would not provide a
balance between protecting human health and the environment and the
availability of Superfund money for response at other facilities.
Based upon a reevaluation of the Interim Action and potential
ARARs, U.S. EPA has determined that MERA Act 307 and the Act 307
Rules are not ARARs. The Interim Action is not a remedial cleanup,
but is instead intended to ensure that the Petoskey Municipal Water
Supply is not impacted by unsafe levels of contamination from the
PMC Site. MERA Act 307 and the Act 307 Rules would be potential
ARARs for the final remedial action at the Site. This modification
of the Agency's position on the potential ARAR does not constitute
a significant change in the alternatives and does not impact the
choice of the remedy selected in the Record of Decision.
The FFS stated that NPDES and Air permits would be required for the
implementation of Alternative Four at the Ingalls Well. U.S. EPA
has reviewed its position and determined that NPDES and Air permits
would not be required. Since ground water contamination has
impacted the Ingalls Well, the location is clearly part of the
Superfund Site and the action can be considered "on site."
Therefore, Alternative Four must comply with the substantive
requirements of Air and NPDES permits, but the permits themselves
would be not be necessary.
-------
PETOSKEY MUNICIPAL WELL FIELD
RESPONSIVENESS SUMMARY
This Responsiveness Summary has been prepared to meet the
requirements of Sections 113(k)(2)(B)(iv) and 117(b) of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986, which requires the United States
Environmental Protection Agency (U.S. EPA) to respond "...to each
of the significant comments, criticisms, and new data submitted
in written or oral presentations" on a proposed plan for remedial
action. The Responsiveness Summary addresses concerns expressed
by the public and potentially responsible parties (PRPs) in the
written and oral comments received by the U.S. EPA and the State
regarding the proposed remedy for the Petoskey Municipal Well
Field Site.
A. OVERVIEW
I. BACKGROUND/PROPOSED PLAN
The Petoskey Manufacturing Company (PMC) has been identified
as the source area for the volatile organic compound (VOC)
contamination in the Ingalls Avenue Municipal Well in
Petoskey, Michigan. The PMC facility is a small fabricating
operation that was established in 1946 as a die cast
manufacturer and continued with painting operations in the
late 1960's. PMC is still in business at the site.
The disposal of spent solvents and/or paint sludge on the
ground surface outside the PMC building has contaminated soils
and ground water in the vicinity of the site. Water from the
City of Petoskey's Ingalls Avenue Municipal Well (Ingalls
Well), located along the shore of Lake Michigan and
downgradient of the PMC facility, contains trichloroethene
(TCE), and possibly several other VOCs from the PMC site. A
ground water contaminant plume has migrated to the well, where
it is being drawn into the city's water supply system. The
Ingalls Well is still being used to service the population of
Petoskey and supplies 60 to 70% of the City's water needs.
In 1993, U.S. EPA proposed that an air-stripper be constructed
at the Ingalls Well to reduce existing levels of VOCs,
especially TCE, in the well and address higher levels of VOCs
that may enter the well. Because the Michigan Department of
Natural Resources (MDNR) has not yet completed the RI/FS for
the PMC Site, this action was proposed as an interim measure
to protect the water supply of the City of Petoskey.
-------
II. PUBLIC COMMENT PERIOD
•
A public comment period was held from December l, 1993 to
January 29, 1994 to allow interested parties to comment on the
Proposed Plan in accordance with Section 117 of CERCLA. On
December 2, 1993, a public meeting was held in Petoskey,
Michigan at the Petoskey High School. U.S. EPA and Michigan
MDNR presented the Proposed Plan, answered questions, and
accepted comments from the public. During the 60-day public
comment period, U.S. EPA received approximately six sets of
written comments and a significant number of oral comments
• concerning the proposed plan.
B. COMMUNITY INVOLVEMENT
i
Public interest regarding the Site has been moderate.
Petoskey residents are concerned about the presence of
contaminants in their drinking water. Various state and local
political bodies have expressed concern that the proposed
treatment alternative will not be capable of treating all
contaminants that have been seen in the groundwater and in the
soils at the Site. Some, therefore, feel that the U.S. EPA
should fund and/or construct a Surface Water Intake and
Treatment Plant to replace the substandard Ingalls Well.
There is an apparent expectation that Petoskey should be given
the same interim remedy as the City of Charlevoix, where the
U.S. EPA funded the construction of a Surface Water Intake and
Treatment Plant due to VOC contamination in the Charlevoix
well field. It should be noted that since the Charlevoix
Interim Action Record of Decision was signed in 1984 and the
subsequent final Record of Decision was signed in 1985,
treatment technologies have advanced. On-line treatment
systems, such as air-strippers, are no longer considered
experimental. Such technologies are now considered to be
reliable means of addressing the type of contamination found
in the Ingalls Well. Other considerations, such as the long-
existing noncompliance of the Ingalls Well with Michigan
Department of Public Health (MDPH) regulations, are outside
the scope of CERCLA and remain the City of Petoskey's
responsibility to address.
C. SUMMARY OF SIGNIFICANT COMMENTS FROM PUBLIC OFFICIALS AND
GOVERNMENTAL UNITS
I. Comments were provided by Michigan Governor John Engler.
Comment GOVERNMENT-1
Governor John Engler commented that the contamination of
the well field is more extensive than previously thought
-------
due to the presence of additional hazardous substances.
Governor Engler's comment letter states that U.S. EPA's
proposed air stripping remedy will not remove all organic
contaminants of concern at the site and is not protective
of public health.
Response GOVERNMENT-1
U.S. EPA agrees that 1992 and 1993 MDNR Remedial
Investigation sampling has identified additional law-
level organic contaminants in the Petoskey Well Field.
Based on the factors discussed below, U.S. EPA believes
that the levels do not pose a threat to the Ingalls Well.
See Table 1 of the ROD for a summary of detections of
organic contaminants, found in groundwater.
When MCLs are not available for a contaminant, Michigan
Act 307 Type B health-based levels are provided in
Responsiveness Summary responses solely as points of
comparison. Type B criteria are risk-based numbers and
will frequently be below method detection limits. In
these cases, Michigan generally establishes the cleanup
level at method detection limits. This corresponds to
Type A criteria, which require cleanup to either
background levels or method detection limits.
Of the organic contaminants that would not be addressed
by air stripping, only one organic contaminant has been
found in the well field that exceeds MCLs in the recent
data from the Petoskey Municipal Well Field groundwater.
That one contaminant, bis(2-ethylhexyl)Phthalate was
found at an estimated concentration of 7 parts per
billion (ppb) and is unlikely to cause an exceedance of
the 6 ppb MCL at the Ingalls Well tap. However, should
site-related SVOCs become a problem in the water supply
in the near future, the ROD allows for the implementation
of carbon treatment instead of air stripping.
For a thorough discussion of ground water quality, SVOCs
in the well field that approach or exceed Type B levels
are discussed below. Although Type B levels, and
sometimes Type A method detection limit levels, are used
as points of comparison, it is important to note that Act
307 is not an ARAR for this interim action.
a. 3,3'-dichlorobenzidine was detected in only l of 44
samples taken in the December 1992 and March 1993
sampling events. It was detected at an estimated
level of l ppb. Although the detection was
positive, the quantitation was estimated, and thus
"J" qualified, because the contaminant was seen
below the method quantitation limit. Although the
-------
Act 307 Type B level for 3,3'-dichlorobenzidine is
0.077 ppb, the Type A method detection limit is 20
ppb. The detection of 3,3'-dichlorobenzidine at one
location in the well field does not justify the
selection of an alternative to address semi-volatile
contaminants at the Ingalls Well.
b. Bis(2-ethylhexyl)Phthalate was detected in 13 of 44
samples taken in the December 1992 and March 1993
sampling event. The contaminant is also present in
the soils at the PMC facility. The maximum
concentration detected in the well .field was
estimated at 7 ppb and was seen at two sampling
points. The detections were estimated, and thus "J"
qualified, because it was seen below the method
quantitation limit. The MCL for Bis(2-
ethylhexyDphthalate is 6 ppb. Although the Act 307
Type B level for Bis(2-ethylhexyl)Phthalate is 2.5
ppb, the Type A method detection limit is 5 ppb.
Bis(2-ethylhexyl)Phthalate has been seen in the
Ingalls Well at very low levels (maximum
concentration of 0.5J ppb), but is not expected to
exceed the 6 ppb MCL at the Ingalls Well due to the
dilution resulting from pumping at the well.
Therefore, the presence of bis(2-
ethylhexyl)Phthalate at the levels seen to date does
not justify the selection of a remedy to address
semi-volatile contaminants.
c. Aldrin was seen in 2 of 43 samples taken in December
of 1992 and March of 1993 that were analyzed for
pesticides. The estimated maximum concentration
seen exceeds Type B levels. The Type B level for
Aldrin is 0.0021 ppb with an acceptable method
detection limit of 0.01 ppb. Aldrin was not
detected in the soils at the PMC facility and is not
believed to be site related. The detection of
Aldrin does not justify the selection of an
alternative to address pesticides.
d. Dieldrin was seen in 2 of 43 samples taken in
December of 1992 and March of 1993 that were
analyzed for pesticides. It was detected at an
estimated level of 0.015 ppb. Although the
detection was positive, the quantitation was
estimated, and thus "J" qualified, because the
contaminant was seen below the method quantitation
limit. In addition, because there was greater than
25% difference between the two GC columns, the
concentration was also "P" qualified. Although the
Act 307 Type B level for Dieldrin is 0.0022 ppb, the
Type A method detection limit is 0.02 ppb. The
-------
estimated maximum concentration of 0.015 ppb is
below 0.02 ppb, which is the method detection limit
based Act 307 Type A standard. In addition,
Dieldrin has not been found in the soils at the PMC
facility and is not believed to be site related.
The detection of Dieldrin does not justify the
selection of an alternative to address pesticides.
e. 4.4'-DDT was seen in 4 of 43 samples taken in
December of 1992 and March of 1993 that were
analyzed for pesticides. No 4,4'-DDT was found in
the samples taken in December of 1992; all 4
detections were from the March 1993 sampling event.
4,4'-DDT was detected at a maximum concentration of
0.027 ppb. The maximum detection seen at the Site
does not exceed the Act 307 Type B level of 0.1 ppb.
4,4'.-DDT was not seen in the Ingalls Well during the
1992 or 1993 sampling events. It is unlikely that
the Act 307 Type B level for 4,4'-DDT would be
exceeded at the Ingalls Well. The detection of
4,4'-DDT in the well field does not justify the
selection of an alternative to address pesticides.
It is an extremely conservative approach to use maximum
concentrations seen in groundwater as a basis for
comparison to drinking water standards. Maximum
concentrations are not necessarily representative of
water quality that would be entering the Ingalls Well on
a continuing basis. Even assuming that the maximum
concentration is valid for this comparison, the
contaminant-specific discussions presented above
demonstrate that low-level semi-volatile and pesticide
contamination in the well field does not warrant
treatment.
In the Governor's comment, he mentions additional
hazardous substances that have been found in the well
field. The Governor may also be referring to the 1990
hydraulic fluid spill that occurred at the PMC facility.
MDNR personnel who conducted ground water sampling in
December 1992 observed a "floating product" in several
ground water samples taken from near the PMC building.
Results of analyses conducted on a sample of the floating
product showed 2% oil and grease and low levels of three
routine SVOCs. However, the MDNR believes that more
specialized analyses may be necessary to provide
additional information concerning the composition of the
"floating product." The RI has not yet determined the
extent of the "floating product" and whether it could
have an impact on ground water quality.
-------
II. Extensive written comments were provided by the City of
Petoskey through the City's environmental contractor
McNamee Industrial Services, Inc. (McNamee).
The submittal from McNamee consisted of a main document
entitled "Interim Response Comments For The Petoskey
Municipal Wellfield Site On Behalf of The City of
Petoskey". The submittal also included the following
appendices:
Appendix I - Cost Evaluation
Appendix II - Correspondence Record
Appendix III - Summary Data
Appendix IV - Data From Eder RI Report
Appendix V - Figures from Eder RI Report
Note that the above list of appendices accurately
represents the documents submitted. The Table of
Contents from the main McNamee submittal omitted listing
the appendix which contained the data from the Eder RI
report.
Comment GOVERNMENT-2 (McNamee Main. Document - January 26,
1994 letter from Mr. Michael Italiano of Bell, Boyd &
Lloyd to Mr. Dave Novak of U.S. EPA. Mr. Italiano is
Special Environmental Counsel for the City of Petoskey) .
Mr. Italiano's letter states that the U.S. EPA has
"ignored the public health problem even though Region V
has direct and primary jurisdiction and responsibility
for the wellfield pursuant to Superfund." Mr. Italiano's
letter quotes the transcript from the December 2, 1993
public meeting in which a representative from the MDPH
discussed the inclusion of the Michigan Safe Drinking
Water Act and the Michigan Air Pollution Act as ARARs for
Alternatives Four and Five.
Response GOVERNMENT-2 U.S. EPA disagrees with Mr.
Italiano's assertion that the Agency has ignored public
health issues relating to the Site. When exceedances at
the Ingalls Well were identified in 1982, emergency
action was taken by the MDNR to excavate much of the
source of the contamination at the PMC property. This
action caused levels of contamination to significantly
drop at the Ingalls -Well.
As a follow-up to the MDNR removal action, U.S. EPA
required PMC to conduct groundwater studies at the site
and to conduct a Remedial Investigation/Feasibility Study
(RI/FS). U.S. EPA directed PMC to cease work on the
RI/FS because of unacceptable delays in the development
of the work plan and PMC's subsequent filing for
bankruptcy and the company's questionable financial
-------
ability to [Complete the work required by the
Administrative Order. The U.S. EPA entered into a State
Cooperative Agreement with the MDNR in 1990, in which the
U.S. EPA funded the MDNR to perform the RI/FS. MDNR's
work on the RI/FS is ongoing.
Because of the U.S. EPA's concern with the potential
quality of water entering the Ingalls Well, the U.S. EPA
proposed to construct an air stripper at the well as an
interim measure to protect the water supply.
Construction of an air stripper at the Ingalls Well would
.treat the volatile organic contaminants (VOCs), including
TCE which in the past had exceeded the Maximum
Contaminant Level (MCL) of 5 ppb. Since 1990, levels of
TCE in the Ingalls Well have been relatively stable at
apprqximately 4 ppb, just below the MCL-. With an
operational air stripper, TCE and other VOCs would be
reduced far below drinking water standards.
The Michigan Safe Drinking Water Act is an ARAR for
Alternatives Four and Five. U.S. EPA is not, however,
responsible for correcting existing deficiencies at the
Ingalls Well and in the Petoskey municipal water system
that are not related to the presence of hazardous
substances at the PMC Site.
The Michigan Air Pollution Act is an ARAR for
Alternatives Four and Five only.
Comment GOVERNMENT-3 (McNamee Main Document - January 26,
1994 letter from Mr. Michael Italiano of Bell, Boyd &
Lloyd to Mr. Dave Novak of U.S. EPA) Mr. Italiano
paraphrased past correspondence from the State of
Michigan to U.S. EPA. He referenced documents which
discuss contaminants present in the well field and claims
that U.S. EPA ignored these additional contaminants (cis-
1,2-dichloroethene, trans-1,2-dichloroethene, methyl-
tert-butyl ether, tetrachloroethylene,...1,1,1
trichloroethane, and possibly arsenic and zinc). Mr.
Italiano's letter states that the proposed alternative
will not address all contaminants in the well field and
at the site.
Response GOVERNMENT-3 The Baseline Risk Assessment
prepared by U.S. EPA for the interim action looked at
data from 1989 to 1991. Data collected prior to 1989
were excluded from these tables because the more recent
data were believed to be more representative of present
conditions. Data from more recent sampling rounds were
not available for inclusion in the Risk Assessment.
However, a qualitative discussion has been added to the
Record of Decision Summary to account for new information
-------
from the most recent sampling events.
Mr. Italiano is correct in that an air stripper will not
address all contaminants in the well field and at the
Site. Contaminants require treatment only if levels at
the Ingalls Well are expected to exceed drinking water
standards. Based on levels of contaminants seen in the
well field, only VOCs require treatment to ensure that
TCE levels in the Ingalls remain below the MCL. Based on
current data, SVOCs and inorganics are not expected to
enter the Ingalls Well in concentrations exceeding MCLs.
Should site-related SVOCs become a problem in the water •
supply in the near future, carbon treatment 'may be
implemented in lieu of air stripping.
Comment GOVERNMENT-4 (McNamee Main Document - January 26,
1994 letter from Mr. Michael Italiano of Bell, Boyd &
Lloyd to Mr. Dave Novak of U.S. EPA) Mr. Italiano states
that the air stripper will not address VOCs present as
DNAPLS in the well field.
Response GOVERNMENT-4 The air stripper will address VOCs
that enter the Ingalls Well and should be capable of
handling TCE contaminant levels as high as 100 ppb while
assuring that the water entering the municipal supply
meets the TCE MCL. Even if contaminant levels at the
Ingalls Well increase because of DNAPL movement, the size
of the treatment system is adequate. The main purpose of
the interim action is not to remediate the aquifer, but
to protect the water supply. Therefore, the interim
action will not attempt to locate and directly remediate
DNAPLs.
Comment GOVERNMENT-5 (McNamee Main Document - January 26,
1994 letter from Mr. Michael Italiano of Bell, Boyd &
Lloyd to Mr. .Dave Novak of U.S. EPA) Mr. Italiano claims
that Region V's lack of action and recommendation of a
remedy that will not address all contaminants in the well
field is a knowing endangerment of public health.
Response Government-5 U.S. EPA disagrees with Mr.
Italiano. U.S. EPA has recommended a remedy to address
contaminants that, based on existing ground water data,
have the potential of exceeding MCLs at the Ingalls Well.
Because the interim action is meant to protect a water
supply, the cleanup standards for any treatment system to
be installed at the Ingalls Well would be MCLs.
Therefore, it would not be a prudent use of public funds
to install a treatment system to address contaminants
that are not expected to exceed the MCLs.
8
-------
Comment GOVERNMENT-6 (McNamee Main Document - January
26, 1994 letter from Mr. Michael Italiano of Bell, Boyd &
Lloyd to Mr. Dave Novak of U.S. EPA) Mr. Italiano again
quotes from the public meeting transcript. He references
remarks made by Representative Pat Gagliardi who stated
that, "The agency knows that there are non-volatile
organic compounds at the site that will not be removed by
air stripping. The agency knows that because it has been
told so repeatedly by Department of Natural Resources and
the Public Health Department. Yet it continues to hide
behind its bureaucratic shield, and persistently insists
that its propo'sed remedy will work."
Response GOVERNMENT-6 As stated in previous responses to
comments, U.S. EPA acknowledges that semi-volatile
organic compounds are present in the well field.
However, the levels that have been seen to date in ground
water do not justify treatment at the Ingalls Well. Some
of Representative Gagliardi's concern may stem from the
fact that the Michigan Department of Public Health does
not accept MCLs as drinking water standards for the
Petoskey water supply system. The Department of Public
Health would like the U.S. EPA to eliminate all
carcinogens from the Ingalls Well. However, the National
Contingency Plan states that U.S. EPA is to use MCLs or
non-zero MCLGs as ARARs. MCLGs of zero'are not
enforceable and not considered to be ARARs by U.S. EPA.
It is difficult for many individuals to accept the fact
that federal standards allow the presence of low-level
carcinogens in their water.
[Federal Register/Vol.55, No.46/
March 8, 1990, §300.430 (e)(2)(i)(B),(C)]
"(B) Maximum contaminant level
goals[MCLGs], established under the Safe
Drinking Water Act, that are set at levels
above zero, shall be attained by remedial
actions for ground or surface waters that
are current or potential sources of
drinking water, where the MCLGs are
relevant and appropriate under the
circumstances of the release based on the
factors in §300.400(g)(2). If an MCLG is
determined not to be relevant and
appropriate, the corresponding maximum
contaminant level (MCL) shall be attained
where relevant and appropriate to the
circumstances of the release.
"(C) Where the MCLG for a contaminant has
been set at a level of zero, the MCL
promulgated for that contaminant under the
-------
Safe Drinking Water Act shall be attained
by remedial actions to ground or surface
waters that are current or potential
sources of drinking water, where the MCL is
relevant and appropriate under the
circumstances of the release based on the
factors in §300.400(g)(2)."
The Department of Public Health's goal to eliminate
carcinogens from water supplies is laudable.
Unfortunately, U.S. EPA cannot .enforce MCLGs of zero and
cannot use the presence of semi-volatile organic
contamination below MCLs as a justification for a more
aggressive treatment approach. U.S. EPA is not "hiding
behind its bureaucratic shield." The Agency is following
established regulations and is judiciously managing fund
dollars to ensure that resources are spent where they are
most needed.
The carbon treatment contingency portion of the Record of
Decision addresses the State's concern that SVOCs may
impact the well at some time in the future. The carbon
treatment contingency is available for eighteen months
from the date of the ROD signature or until a replacement
supply is in operation, whichever comes first. The
timeframe is consistent with other timeframes requiring
the upgrade or replacement of the water supply due to
existing engineering deficiencies at the Ingalls Well and
the infiltration of surface water.
Comment GOVERNMENT-7 (McNamee Main Document - January
26, 1994 letter from Mr. Michael Italiano of Bell, Boyd &
Lloyd to Mr. Dave Novak of U.S. EPA) Mr. Italiano quotes
a MDPH official who stated at the Public Meeting that
Alternatives Four and Five cannot meet the Michigan Safe
Drinking Water Act. Since Alternatives Four and Five do
not meet the requirements of the Safe Drinking Water Act,
they cannot be implemented because permits for their
installation cannot be issued.
Response GOVERNMENT-7 Alternatives Four and Five can
meet the chemical-specific requirements of the Michigan
Safe Drinking Water Act that relate to contamination from
the PMC facility. Alternatives Four and Five will not
address the existing construction deficiencies and the
fact that the Ingalls Well does not satisfy the location-
specific requirements of the Act.
Construction of an on-line treatment system would not
correct the existing problems with the well, but
treatment of the contamination would certainly improve
the overall water quality situation. If the State of
10
-------
Michigan makes the determination that the levels of
contamination in the Ingalls Well are not acceptable for
the period that it will take for the City to proceed with
its plans to replace the water supply and construct a
Surface Water Intake/Treatment Plant, the State of
Michigan could allow the air stripper to be constructed
as an interim measure.
The State of Michigan may make the determination that the
levels of contamination are acceptable for the period
until the City replaces its water supply. If the State
of Michigan concurs with the remedy but believes that the
money would be better spent replacing the water supply,
the capital cost of the selected remedy may be used by
the City to "enhance" the selected remedy and partially
fund a Surface Water Intake/Treatment Plant. Therefore,
the actual implementation of Alternatives Four or Five
. (as opposed to the cash equivalent option) is dependant
on the State of Michigan.
Comment GOVERNMENT-8 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "The Wellfield has contained elevated
levels of TCE for over 11 years."
Response GOVERNMENT-8 U.S. EPA agrees. Levels of TCE in
the well field are "elevated". Samples taken from
monitoring well PS-C-Deep in March, 1993, showed
approximately 78 ppb of TCE. The duplicate sample taken
from the same location showed approximately 83 ppb of
TCE. PS-C-Deep is located approximately 300 feet south
east of the Ingalls Well. As part of its RI/FS, the MDNR
will evaluate remedial alternatives for addressing the
contamination in the well field.
Comment GOVERNMENT-9 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "The wellfield site includes both the
wellfield area and Petoskey Manufacturing Co- (PMC)."
Response GOVERNMENT-9 U.S. EPA agrees. The Site
includes both the PMC source area and the contaminated
well field. However, the purpose of the interim action
is not to address the entire Site. The purpose is to
ensure that the Citizens of Petoskey are not exposed to
unsafe levels of contaminants in their drinking water.
The RI/FS for the entire Site is being conducted by the
MDNR, under a Cooperative Agreement with the U.S. EPA.
11
-------
Comment GOVERNMENT-10 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "Contaminants in the entire wellfield must
be addressed."
Response GOVERNMENT-10 As discussed previously, it is
not necessary to treat for contaminants that are not
expected to exceed MCLs" at the Ingalls Well.
Comment GOVERNMENT-11 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "Additional carcinogens were discovered in
the wellfield last December."
Response GOVERNMENT-11 See Comment/Response GOVERNMENT-
1, Comment/Response GOVERNMENT-6, and Comment/Response
PUBLIC-1.
Comment GOVERNMENT-12 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "Both the MDNR and MDPH maintain that this
site poses an unacceptable risk to the health and
residents of Petoskey" [Letter from Russell Harding, MDNR
to V. Adamkus, EPA, January 20, 1994]
Response GOVERNMENT-12 Based on current levels of
contamination in the Ingalls Well, residential use of
water from the Ingalls Well does not pose an unacceptable
health risk because the water meets MCLs. However,
because of the uncertainty regarding TCE levels in
groundwater and the possible presence of DNAPLs very near
the well, U.S. EPA cannot be sure that, if no action is
taken, levels of TCE in the Ingalls Well would remain
below MCLs.
Although the risk to private well users is within the
U.S. EPA acceptable risk range, U.S. EPA has made the
determination that, if no action is taken, the
residential use of a private well could pose an
unacceptable risk. This is because of the possibility
that an individual would site a well in an area with high
residual contamination. In addition, users of private
wells constructed in contaminated portions of the well
field may not see the same dilution effect from
infiltration of surface water that are reducing
contaminant levels at the Ingalls Well.
Comment GOVERNMENT-13 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
12
-------
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "MDNR and MDPH believe that EPA cost
estimates for air" stripping and carbon adsorption are
significantly understated."
Response GOVERNMENT-13 U.S. EPA has revised cost
estimates for Alternatives Four and Five based on
comments from MDNR and MDPH. The revision of cost
estimates does not alter the relative cost of the
Alternatives.
Comment GOVERNMENT-14 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "We believe this site should proceed
immediately to remedy selection under the format of a
presumptive remedy such as at other sites where there is
clearly only one viable option to address the situation."
[Letter from Russell Harding, MDNR to V. Adamkus, EPA,
January 20, 1994]
Response GOVERNMENT-14 U.S. EPA disagrees. Although a
U.S. EPA-funded replacement of the water supply is surely
the option most preferred by the State and the City,
other alternatives can effectively and reliably address
the VOC contamination at the Ingalls Well.
Comment GOVERNMENT-15 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "Monitoring data indicate that contaminants
may be moving toward the well."
Response GOVERNMENT-15 U.S. EPA agrees that contaminants
in the well field do tend to move toward the Ingalls Well
when the well is pumping. At the Ingalls Well, the
contaminated water is then diluted from the influence of
surface water and the intake of uncontaminated ground
water.
Comment GOVERNMENT-16 (McNamee Main Document - One-Page
Summary Sheet from January 26, 1994 letter from Mr.
Michael Italiano of Bell, Boyd & Lloyd to Mr. Dave Novak
of U.S. EPA) "A solution to the water supply
contamination will also allow the City to raze the PMC
building, help move PMC, and create a park near the
waterfront."
Response GOVERNMENT-16 The interim remedy will not
address contamination at the PMC source area. MDNR is
continuing its investigation at the Site and will
evaluate alternatives to address contamination in 'Site
13
-------
soils and in the well field.
Comment GOVERNMENT-17 (McNamee Main Document, Section
1.0, Page 2) McNamee states that Alternative One (No
Action) is not an acceptable remedial alternative to
reduce risks to citizens of Petoskey or reduce
groundwater contamination.
Response GOVERNMENT-17 See Comment/Response GOVERNMENT-
12.
Comment GOVERNMENT-18 (McNamee Main Document, Section
1.1, Page 2) Based on McNamee evaluation of alternatives
(excluding air stripping), construction of a Direct
Filtration Water Treatment Plant would allow U.S. EPA to
issue a follow-up no action ROD for ground water based on
OSWER Directive 9283.1-06 (05-27-92) which allows
evaluation of the technical impracticality from an
engineering evaluation and determination of alternative
remedial action objectives.
Response GOVERNMENT-18 Until MDNR's investigation is
complete and alternatives for soil and well field cleanup
have been evaluated, it is premature to assume that a No
Action ROD could be issued if a Surface Water Treatment
Plant were constructed. However, the on-line treatment
alternatives, Alternatives Four and Five, would provide a
slightly greater basis for a follow-up No Action ROD
because the Ingalls Well would act indirectly as a pump
and treat well to address a portion of the contaminated
aquifer.
Comment GOVERNMENT-19 (McNamee Main Document, Section
3.0, Page 3) Sample results from MDNR activities in 1992
indicate that hazardous substances above Type B levels
are still present in the property soils and are
contributing to ground water contamination.
Response GOVERNMENT-19 U.S. EPA agrees. However, the
interim remedy will not address contamination at the PMC
source area. MDNR is continuing its investigation at the
Site and will evaluate alternatives to address
contamination in Site soils and in the well field.-
Comment GOVERNMENT-20 (McNamee Main Document, Section
3.0, Page 4) In 1982, 51 ppb of TCE were found in the
Ingalls Well. A high probability exists that for 20 to
30 years, the population of Petoskey has been exposed to
TCE in concentrations as high as 50 ppb. Concentrations
of TCE have been above MERA 307 ground water cleanup
criteria, which are ARARs, since 1981. OSWER Dir.
9355.3-03 includes state standards and MCLGs as relevant
14
-------
and appropriate for the provision of alternate water
supplies.
Response GOVERNMENT-20 U.S. EPA agrees that the Ingalls
well had likely been contaminated for many years.
However, U.S. EPA disagrees that MERA 307 is an ARAR for
the Ingalls Well and the Petoskey municipal water system.
MCLs are the standards that are applied for water system
quality and have been adopted by the State of Michigan
under the Michigan Safe Drinking Water Act. MCLGs are
non-enforceable goals and, according to the National
Contingency Plan (NCP), only non-zero MCLGs may be
relevant and appropriate for Superfund Remedial Actions.
MERA 307 standards are not standards for the evaluation
of water supply quality.
Comment GOVERNMENT-21 (McNamee Main Document, Section
3.0, Page 4) "In 1984, U.S. EPA issued an administrative
order directing PMC to conduct further hydrogeological
studies. PMC retained an environmental consultant and
conducted work under the direction of U.S. EPA and MDNR.
In 1987 the U.S. EPA issued its second administrative
order to PMC. Under this order, PMC was to conduct a
full RI/FS to determine the nature and extent of
contamination and appropriate remedial alternatives to
address the contamination. PMC started the work plan
phase of this administrative order; but the U.S. EPA
relieved PMC of conducting further RI/FS work and
negotiated a settlement prior to recognition of the risk
to the citizens of Petoskey. Prior violations of the
NPDES permit and RCRA were ignored. The U.S. EPA entered
into a State Cooperative Agreement with MDNR in 1990, in
which the MDNR agreed to perform the RI/FS which was
completed in draft form in 1994."
Response GOVERNMENT-21 From the language of the comment,
it sounds as if the commentor believes that U.S. EPA
settled with PMC so as not to disclose the site risks.
If this is what the commentor meant to imply, U.S. EPA
disagrees. U.S. EPA directed PMC to stop work because of
the company's unacceptable performance in preparing the
RI/FS Work Plan. In addition, because PMC had filed for
bankruptcy after it agreed to conduct the RI/FS, there
was information to indicate that PMC would have been
unable to fully fund the work it had agreed to perform.
The commentor states that U.S. EPA ignored prior
violations of NPDES and RCRA. Both the NPDES and RCRA
programs are delegated to the State of Michigan and the
State has the authority to impose penalties for
violations. The fact that there were historical
violations did not and would not change the fact that PMC
15
-------
failed to perform as required by the Order and that the
company was not able to fully fund the work it had
committed to perform.
The commentor states that the MDNR completed the draft
RI/FS in 1994. In fact, the MDNR provided the U.S. EPA
with a draft RI Report in December of 1993. U.S. EPA
made the determination that the document was incomplete
and unacceptable and did not approve the RI Report.
However, to provide as much information as possible to
the community, the data from the investigation was ..
released to the public in January of 199.4. U.S. EPA is
now working with the State of Michigan to complete
limited additional field work during the spring of 1995.
MDNR has deferred completion of the FS until results of
the 1995 field work are available.
Comment GOVERNMENT-22 (McNamee Main Document, Section
3.0, Page 5) Contaminated ground water is drawn into the
Ingalls Well when the pump is operational and is
apparently diluted by surface and groundwater
.infiltration.
Response GOVERNMENT-22 U.S. EPA agrees. See
Comment/Response GOVERNMENT-15.
Comment GOVERNMENT-23 (McNamee Main Document, Section
3.0, page 5) McNamee states that other hazardous
substances known to be in the well field were not
included in the Agency For Toxic Substances and Disease
Registry (ATSDR) health assessment or in the Baseline
Risk Assessment prepared for the interim action.
Response GOVERNMENT-23 Because the more recent data was
not available, the ATSDR health assessment and the U.S.
EPA Baseline Risk Assessment for Ground Water did not
include the 1992 and 1993 sampling results. The Record
of Decision Summary and this Responsiveness Summary
qualitatively discuss the presence of other contaminants
seen in the more recent sampling events.
Comment GOVERNMENT-24 (McNamee Main Document, Section
3.0, page 5) McNamee states that State correspondence to
U.S. EPA documents that the Ingalls Well exceeds the MCLG
of zero.and the Type B 3 ug/1 TCE cleanup level.
Response GOVERNMENT-24 See Comment/Response GOVERNMENT-6
and Comment/Response GOVERNMENT-20.
Comment GOVERNMENT-25 (McNamee Main Document, Section
3.0, page 5) McNamee references a comment letter from A
MDNR toxicologist who states that "it would be prudent to
16
-------
discontinue use of the groundwater at this site for
residential consumption. Groundwater at this site
contains concentrations of contaminants which exceed Type
B criteria; there is a high level of uncertainty
associated with the analytical data and the risk
assessment for this site; and there is potential that the
risks associated with this site were significantly
underestimated in the risk assessment."
Response GOVERNMENT-25 Although U.S. EPA agrees that
there is uncertainty associated with the Baseline Risk
Assessment for the Interim Action, sampling results show
that the water in the Ingalls Well currently meets MCLs.
MCLs are nationally accepted standards for water supply
quality. U.S. EPA maintains that on-line treatment of
the well would be as effective as replacing the water
supply.
Comment GOVERNMENT-26 (McNamee Main Document, Section
3.0, page 5) Information from the RI completed by MDNR
in January of 1994 must be included in any evaluation of
risk to the citizens drinking groundwater from the
Ingalls Well.
Response GOVERNMENT-26 The MDNR has not yet completed
the RI. However, the Record of Decision Summary and this
Responsiveness Summary include discussions of recent RI
ground water monitoring results.
Comment GOVERNMENT-27 (McNamee Main Document, Section
4.0, page 6) The commentor notes that the Baseline Risk
Assessment for the Interim Action was performed with the
knowledge that there was a "high degree of uncertainty
associated with the use of the data". He further notes
factors that may have led to an underestimation of the
potential risks: insufficient identification of the
chemicals present, reliance upon data gathered during a
limited period of time, and not evaluating all of the
potential exposure pathways.
Response GOVERNMENT-27 U.S. EPA agrees that there are
certain uncertainties associated with the data. See the
"Uncertainties" discussion in Section 6.6 of the Record
of Decision Summary for further discussion.
Comment GOVERNMENT-28 (McNamee Main Document, Section
4.0, page 6) The Baseline Risk Assessment was based on
limited data. "Analytical tests performed do not appear
to have considered a number of hazardous substances
present in the soil, nor does it appear to have
considered the potential degradation by-products of these
substances." Results of tests conducted in 1992 and 1993
17
-------
identified cancer-causing chemicals that were identified
for the first time, including: vinyl chloride, methylene
chloride and bis(2-ethylhexyl)phthalate.
Response GOVERNMENT-28 The Baseline Risk Assessment
included only contaminants that had been seen in ground
water and could be related to the Site. As part of
evaluating ground water scenarios, it is not appropriate
to include contaminants that have been found only in
soils. The fact that a substance is present in soils
does not necessarily mean that it will migrate to ground .
water and become a problem. The Baseline Risk Assessment
also did not evaluate the presence of potential
degradation by-products since these contaminants had not
yet been detected. The Baseline Risk Assessment did not
include vinyl chloride, methylene chloride and bis (2-
ethylhexyDphthalate since the recent data was not
available for inclusion into the document. However, a
qualitative discussion of the recent data has been
included in the Record of Decision Summary and in this
Responsiveness Summary.
Comment GOVERNMENT-29 (McNamee Main Document, Section
4.0, pages 6,7) The commentor discusses the
characteristics of vinyl chloride, including its
solubility, volatility, mobility and toxicity. The
commentor also discusses vinyl chloride as a degradation
product of trichloroethylene and dichloroethylene in
anaerobic soils and notes that the risk assessment did
not consider by-product formation from the degradation of
soil contaminants.
Response GOVERNMENT-29 See also Comment/Response
GOVERNMENT-28. U.S. EPA agrees that degradation of some
chemicals in the soil could create vinyl chloride. Vinyl
chloride was analyzed for, but was never detected in the
analytical data used for the risk assessment. However,
vinyl chloride was detected in only 1 of 64 ground water
samples collected during the RI. This is still a
concern, but it is not evidence of substantial production
of vinyl chloride by degradation of other chemicals.
Vinyl chloride can be addressed by air-stripping. In
fact, under the Michigan Safe Drinking Water Act, packed
tower aeration (air stripping) is considered to be the
Best Available Technology (BAT) for vinyl chloride.
If U.S. EPA determines that future detections of site-
related SVOCs at the Ingalls Well tap warrant the
implementation of carbon treatment instead of air
stripping, it will be important to carefully review
future monitoring data for the presence of vinyl
18
-------
chloride. Carbon treatment is not effective in the
removal of vinyl chloride.
Comment GOVERNMENT-30 (McNamee Main Document, Section
4.0, page 7) The commentor discusses the characteristics
of methylene chloride, including mobility and toxicity.
The commentor states that, according to EPA's Office of
Drinking Water, a concentration of 0.5 ppb is associated
with a 1 x 10"6 risk. This contaminant should be
considered in any recalculation of risk.
Response GOVERNMENT-.30 Comment noted.- See also
Comment/Response GOVERNMENT-28. Methylene chloride can
be addressed by air-stripping.
Comment GOVERNMENT-31 (McNamee Main Document, Section
4.0, page 7) The Baseline Risk Assessment did not
consider the potential for other contaminants (PNAs,
Dibenzofurans, Phthalates) to migrate from the soil to
the ground water or to the Ingalls Well. TCE and/or
Dichloroethylene act as a "carrier" vehicle and can
enhance contaminant migration.
Response GOVERNMENT-31 Solvents can act as "carrier
vehicles" to enhance the migration of other contaminants.
However, it is not reasonable to assume that contaminants
will suddenly begin to migrate when, to date, we have
seen little semi-volatile migration into groundwater even
though the PMC soils have been contaminated for well over
twelve years. See also Comment/Response GOVERNMENT-28.
Comment GOVERNMENT-32 (McNamee Main Document, Section
4.0, page 7) Benzo(a)pyrene has been designated by the
EPA as a "Probable Human Carcinogen" and is associated
with a 1 x 10"6 risk level at a concentration of 0.003
ppb in drinking water.
Response GOVERNMENT-32 To date, benzo(a)pyrene has not
been found in ground water in the well field.
Comment GOVERNMENT-33 (McNamee Main Document, Section
4.0, pages 7,8) Dibenzofurans have been observed in the
site soils. The Baseline Risk Assessment did not include
chlorinated dibenzo-p-dioxin and chlorinated
dibenzofurans.
Response GOVERNMENT-33 To date, dibenzofurans have not
been found in ground water in the well field.
Comments GOVERNMENT-34 (McNamee Main Document, Section
4.0, pages 8) High levels of phthalates have been seen
in site soils, yet were not included in the risk
19
-------
assessment.
Response GOVERNMENT-34 Phthalates were not identified
during the previous sampling rounds evaluated as part of
the Baseline Risk Assessment. Phthalates are
qualitatively evaluated in the Record of Decision Summary
and in this Responsiveness Summary (see Comment/Response
GOVERNMENT-1) only to the extent that they were seen in
ground water.
Comment GOVERNMENT-35 (McNamee Main Document, Section
4.0, pages 8) The Baseline Risk Assessment.excluded
trihalomethanes, even though significant amounts of
trihalomethanes have been identified in monitoring wells
at the site. The presence of trihalomethanes may not be
exclusively from chlorination but from actual
contamination (or degradation of contaminants) at the
site.
Response GOVERNMENT-35 U.S. EPA agrees that recent
monitoring data suggest that the presence of
trihalomethanes may not be due solely to chlorination.
However, levels seen in the well field are very low. To
demonstrate this using an extremely conservative
comparison, assume that the maximum concentration of each
trihalomethane compound found in the well field would
impact the Ingalls Well. Even by summing these maximum
concentrations of trihalomethane compounds, the total
would be far below the 80 ppb MCL for total
trihalomethanes.
Comment GOVERNMENT-36 (McNamee Main Document, Section
4.1, pages 8-10) The commentor disagrees with the areas
of concern identified in the Baseline Risk Assessment.
Data from monitoring wells and data from the Ingalls Well
were considered independently in order to evaluate the
risks to private well users and risks to individuals who
consume water from the Ingalls Well. The commentor
believes that the entire well field should be considered
when looking at risks to the Ingalls Well. The commentor
provided an extensive list of contaminants that should be
included as Chemicals of Potential Concern. The
commentor further states that a reevaluation of risks
with the additional Chemicals of Potential Concern will
effect the current evaluation of the risk.
Response GOVERNMENT-36 It is widely known that the
Ingalls Well is under the influence of surface water from
Lake Michigan. Just how much surface water is drawn in
as the Ingalls Well pumps is not known. Because the
hydrogeology in the area is so complex, the Ingalls
Well's zone of capture is also uncertain. In any event,
20
-------
it is clear that contaminated ground water entering the
Ingalls Well is diluted by clean ground water and surface
water. It is therefore not appropriate to assume that
levels of contamination in the well field can be directly
compared to the levels that would be seen in the Ingalls
Well. Therefore, it is appropriate to independently
evaluate use of ground water from the Ingalls Well and
use of ground water from a private well in the well
field.
The results of a qualitative reevaluation of risks based
on 1992 and 19'93 data have not shown the need to modify
U.S. EPA's proposed alternative.
Comment GOVERNMENT-36 (McNamee Main Document, Section
4.2, page 10) The commentor states that the Baseline
Risk Assessment "intentionally did not address potential
exposures resulting from recreational and residential
activities such as swimming (air, dermal), home gardening
(food), or just living in close proximity to the site
(vapors, dusts). The justification for excluding these
potential pathways was the opinion that they contributed
little to the final risk calculations." The commentor
states that this is not a valid approach when one
considers individual risks and when one looks at the
worst-case exposed population (those residents near the
current PMC site).
Response GOVERNMENT-36 U.S. EPA is unsure whether the
commentor is referring to risks from use of water or from
exposure to site soils. Risks from exposure to site
soils for individuals in close proximity to the site are
not included in the Baseline Risk Assessment for the
Interim Action and will be evaluated by the MDNR as part
of the overall RI/FS. Risks from use of municipally
supplied ground water (or ground water from a private
well) for swimming and watering a garden are expected to
be minimal. If these activities were included, the risk
would still be within the U.S. EPA acceptable risk range.
In response to the commentor's assertion that the
approach does not consider individual risks, U.S. EPA
disagrees. The entire approach put forward in U.S. EPA
Risk Assessment Guidance, and followed in preparation of
the Baseline Risk Assessment for the Interim Action, is
based on evaluating risks to individuals. The Agency, is
conservative in its assumptions and considers the
reasonably maximally exposed individual and sensitive
populations.
The commentor's statement concerning the worst case
exposure of individuals near the Site again misses the
21
-------
point of th,e entire interim action. Risks for the
overall site will be evaluated by the MDNR. The Baseline
Risk Assessment for the Interim Action was meant to
evaluate the need for an action to ensure a safe drinking
water source. Individuals who are exposed to site soils
in addition to their use of municipal water would
certainly experience a greater risk; however, this fact
does not mean that the water that those hypothetical
individuals receive from the municipal supply should be
of any different quality than the water that would be
received by municipal water users who -are not exposed to
Site soils.
Comment GOVERNMENT-37 (McNamee Main Document, Section
4.2, page 10) The Baseline Risk Assessment
underestimated exposure to volatile contaminants because
it did not consider activities such as dish washing,
laundering, etc.
Response GOVERNMENT-37 Risks from use of municipally
supplied ground water (or ground water from a private
well) for swimming and watering a garden are expected to
be minimal. The risks associated with showering are 1 to
4 orders of magnitude less than the risks associated with
ingestion of the water (see Table 5-1 in the Baseline
Risk Assessment for Ground Water). Risks associated with
washing will be even less. If these activities were
included, the risk from residential use of contaminated
water would still be within the U.S. EPA acceptable risk
range.
Comment GOVERNMENT-38 (McNamee Main Document, Section
4.2, page 11) The Baseline Risk Assessment did not
consider the synergistic effect of exposure to multiple
contaminants.
Response GOVERNMENT-38 . U.S. EPA agrees with the comment.
However, synergistic interactions of chemicals are very
poorly known, and there is no technical basis for
estimating risks except for a very few chemical
combinations. Antagonistic interactions are also
possible, but are also poorly known. See the
"Uncertainties" discussion in Section 6.6 of the Record
of Decision Summary for further discussion.
Comment GOVERNMENT-39 (McNamee Main Document, Section
4.2, page 11) The Baseline Risk Assessment did not
consider the past exposure to users of the municipal
water supply.
Response GOVERNMENT-39 U.S. EPA acknowledges that
residents of Petoskey were exposed to unacceptable levels
22
-------
of TCE in their municipal well water prior to 1982 when
the contamination was identified. However, it is not
practical to consider past exposure to contaminants when
attempting to quantify site risks at Superfund Sites.
Superfund was established to remediate those sites that
are of greatest risk to human health and the environment.
Funds should be directed to those sites where an action
can reduce exposure to acceptable levels. No action by
the U.S. EPA can mitigate past exposure. The decision of
whether or not to take an action to remediate a site
depends on the current levels of contamination (and risk)
present at the site.
Comment GOVERNMENT-40 (McNamee Main Document, Section
4.3, pages 11,12) The commentor lists objectives of
risks assessments and states that U.S. EPA's Baseline
Risk Assessment for an interim action failed to meet the
objectives. No justification was provided.
Response GOVERNMENT-40 The Baseline Risk Assessment
prepared by U.S. EPA for the Interim Action met its
objectives. The Baseline Risk Assessment was never
intended to evaluate overall site risks and develop site
cleanup standards. The assessment was conducted to
determine if sufficient risk is present to justify taking
an interim action at the Ingalls Well to ensure that the
municipal water supply is not impacted by unsafe levels
of contamination.
Comment GOVERNMENT-41 (McNamee Main Document, Section
4.4, page 12) When discussing the conceptual model of
the Site, the commentor states that PNAs cannot be
disregarded due to their limited mobility since the
presence of solvents can increase mobility.
Response GOVERNMENT-41 See discussion above in
Comment/Response GOVERNMENT-28 and Comment/Response
GOVERNMENT-31.
Comment GOVERNMENT-42 (McNamee Main Document, Section
4.4, page 13) The McNamee commentor states that the Site
should have two Operable Units. The First would be an
interim response to provide a new drinking water source
for the Ingalls Well. The Final Response would include a
Risk Assessment for soil at the PMC source area and an
evaluation of ground water in the well field.
Response GOVERNMENT-42 The Record of Decision for the
Ingalls Well is an Interim Action for the Petoskey
Municipal Well Field Site. It is not meant to resolve
all ground water issues at the Site. An evaluation of
both soil and ground water remediation alternatives will
23
-------
be included in the RI/FS to be prepared by the MDNR.
Comment GOVERNMENT-43 (McNamee Main Document, Section
4.5, page 13) The coramentor notes a 1990 release of oils
into the soil. This was not included in the Baseline
Risk Assessment.
Response GOVERNMENT-43 The Baseline Risk Assessment was
based on chemical monitoring data. Although there was an
observed "floating product" at three wells at the PMC
facility, chemical monitoring has not provided much
information concerning the possible impact of the
observed substance. The "floating product" was analyzed
and found to contain approximately 2% oil and grease and
low-level SVOCs. The MDNR believes that specialized
analyses may be necessary to obtain a better
understanding of the problem. The MDNR will be
conducting additional field work to determine the extent
of the floating product. It is interesting to note that
the presence of zinc in the Baseline Risk Assessment may
be partly due to the 1990 release of hydraulic fluids.
During that period of time some formulations of hydraulic
fluids did contain zinc. The floating product itself is
believed to be localized and will be investigated in the
field work planned for 1995.
Comment GOVERNMENT-44 (McNamee Main Document, Section
4.5, page 13) The commentor states that since the
historical data was excluded, synergistic and cumulative
effects were not analyzed.
Response GOVERNMENT-44 See Section 6.6 of the Record of
Decision Summary for further discussion of Baseline Risk
Assessment uncertainties. In addition, see
Comment/Response GOVERNMENT-39 for a discussion of the
consideration of past exposures.
Comment GOVERNMENT-45 (McNamee Main Document, Section
4.6, page 14) The McNamee commentor claims that the
chemicals of potential concern were "preselected to
preclude an accurate risk." The limited nature of ground
water data increased uncertainty and caused the Baseline
Risk Assessment to underestimate risk.
Response GOVERNMENT-45 U.S. EPA acknowledges that the
ground water data is limited and agrees that this could
cause risks to be underestimated. It is important to
note, however, that the use of limited data could also
lead to the overestimation of risk. The impact of
additional data on site risk calculations would depend on
the level and types of contaminants detected.
24
-------
U.S. EPA strongly disagrees with the commentor's
assertion that chemicals were "preselected to preclude an
accurate risk." Chemicals were selected using best
professional judgment, U.S. EPA guidance, and the most
reliable data available at the time. It is U.S. EPA's
belief that the commentor has failed to recognize the
point of the entire Interim Action. Major areas of
technical disagreement include the fact that McNamee
appears to believe that it is appropriate to utilize
historical data that is not representative of current
conditions, that the Baseline Risk Assessment should
simulate the presence of contaminants that have not
migrated to ground water after being present in site
soils for over twelve years, that evaluation of the risks
from use of water from the Ingalls Well should be based
on levels in the well field that do not acknowledge the
dilution that undeniably occurs at the well, and that the
evaluation of the risk from residential use of ground
water should consider the possibility of exposure to
contaminants at the PMC Site itself.
Comment GOVERNMENT-46 {McNamee Main Document, Section
4.6, page 14) The site sampling plan has not been
thorough and consistent. Chemicals may be present for
which analyses have not been run.
Response GOVERNMENT-46 Deficiencies of the data base
were noted in the Baseline Risk Assessment. The sampling
program was designed by the MDNR for the RI/FS. Although
sampling events have not routinely analyzed all ground
water samples for VOCs, SVOCs, and inorganics, enough
sampling has been conducted by MDNR to provide an overall
picture of contaminants present in ground water. MDNR
will conduct additional analyses during the spring of
1995.
Comment GOVERNMENT-47 (McNamee Main Document, Section
4.6, page 14) Analytical detection limits for some
contaminants are above ground water standards, criteria,
or other "toxicity reference values". The methods used
to calculate Preliminary Remediation Goals (PRGs) were
not shown.
Response GOVERNMENT-47 The U.S. EPA guidance document
used to calculate PRGs was referenced and the chemicals
with sample quantitation limits above the PRGs were
identified in Appendix A.
Comment GOVERNMENT-48 (McNamee Main Document, Section
4.6, page 14) Use of more recent RI data coupled with
prolonged exposure and synergistic effects substantially
increases the risk above the level identified in the
25
-------
Baseline Risk Assessment. The use of MCLGs is "relevant
and appropriate".
Response GOVERNMENT-48 Limitations of the data were
clearly noted in the Baseline Risk Assessment. With only
a few exceptions, there is no technical basis for
evaluating synergistic or antagonistic effect in any risk
assessment. The chemicals identified in ground water
collected during the RI are not known to have any
synergistic effects (Casarett and Doull's Toxicology. .
1980). The recent data generated by the RI could result
in lower as well as higher estimated risk. .See the
discussion of MCLGs in Comment/Response GOVERNMENT-6 and
Comment/Response-20.
Comment GOVERNMENT-49 (McNamee Main Document, Section
4.6, page 14) CERCLA Section 121(d) states that U.S.
EPA's remedy should "at a minimum protect public health
and the environment." The commentor maintains that U.S.
EPA's proposed remedy does not protect public health.
Response GOVERNMENT-49 U.S. EPA disagrees. Construction
and operation of an on-line air-stripper will address the
presence of VOCs'that could exceed MCLs at the Ingalls
Well.
Comment GOVERNMENT-50 (McNamee Main Document, Section
5.2, page 15) The commentor notes that TCE, DCE and
various phthalates are present in the well field. The
commentor further notes that prior to the removal action,
monitoring wells, the Ingalls Well and Site soils showed
high concentrations of TCE and DCE and that wells near
the source area showed high concentrations of phthalates.
The mobility of phthalates is increased by.the presence
of solvents such as TCE and DCE.
Response GOVERNMENT-50 U.S. EPA agrees that contaminant
concentrations were significantly higher prior to the
excavation of highly contaminated soils from the PMC
facility. However, U.S. EPA notes that current levels of
phthalates in the well field and in the Ingalls Well are
relatively low.
Considering the December 1992 and March 1993 sampling
events, the maximum phthalate concentration at the
Ingalls Well was the estimated 0.5 ppb seen of bis(2-
ethylhexyl)phthalate. The MCL for bis(2-
ethylhexyl)phthalate is 6 ppb.
The maximum phthalate concentrations seen in the well
field were an estimated 7 ppb of bis (2-
ethylhexyl)phthalate and an estimated 7 ppb of Di-n-
26
-------
Octylphthalate. There is no MCL for Di-n-Octylphthalate.
However, the Act 307 Type B criteria is 130 ppb.
Comment GOVERNMENT-51 (McNamee Main Document, Section
5.2, pages 15,16) The commentor noted that TCE
concentrations in monitoring well PS-11 have increased
from 28 ppb in December of 1992 to 40 ppb in March of
1993. In the same period, TCE concentrations in
Monitoring Well PS-C-Deep (300' from the Ingalls Well)
have increased from 65 ppb to 83 ppb. The commentor-
maintains that this is evidence of a DNAPL pool. The
commentor further notes that as early as 1983, MDNR noted
an increase in 1,2 DCE, a degradation product of TCE.
Response GOVERNMENT-51 From the information gathered to
date, it is difficult to determine whether or not a DNAPL
is present and causing the variations seen in monitoring
wells PS-11 and PS-C-Deep. The increases in TCE and DCE
could be the result of normal fluctuations in ground
water quality or analytical methods. If a DNAPL were to
exist at the Site, the concentrations of dissolved
constituents would be anticipated to be three to four
orders of magnitude higher based on the solubility of the
chemicals.
On the other hand, U.S. EPA agrees that it is curious
that concentrations in PS-11 and C-Deep have not yet
dropped off. This could indicate the presence of a DNAPL
in bedrock fractures.
Although the question of whether of not there is a DNAPL
in close proximity to the Ingalls Well has not yet been
answered, the alternative selected by U.S. EPA in the
Record of Decision will address any TCE and DCE present
in ground water at the Ingalls Well.
Comment GOVERNMENT-52 (McNamee Main Document, Section
5.2, page 16) The commentor expressed concern over the
presence of vinyl chloride in ground water at the Site
and expects concentrations to increase as TCE and DCE
degrade.
Response GOVERNMENT-52 Vinyl chloride has been detected
only once. The contaminant was seen in monitoring well
PS-4 during the December 1992 sampling event. However,
it is possible that levels of vinyl chloride may increase
over time as other chemicals degrade. The remedy
selected by the U.S. EPA will effectively remove vinyl
chloride from the Ingalls Well. In fact, according to
the Michigan Safe Drinking Water Act, packed tower
aeration (air stripping) is considered to be the Best
Available Technology (BAT) for the presence of vinyl
27
-------
chloride in ground water. Granular activated carbon is
not a BAT treatment for vinyl chloride in ground water.
Comment GOVERNMENT-53 (McNamee Main Document, Sections
6.0-6.1, pages 16,17) The commentor states that MERA Act
307 regulations are ARARs. He also states that MERA 307
criteria must be applied at the well f.ield in the ground
water rather than at the Ingalls Well or at the drinking
water tap.
Response GOVERNMENT-53 Act 307 Rules, contain provisions
establishing procedures for response activities,
selection of remedial action, and cleanup criteria at
sites of environmental contamination where response
activities are taken pursuant to Ac.t 307. Because this
Interim Action is not meant to remediate the Site, but is
instead an Interim Action meant to ensure that the water
supply of the City of Petoskey meets federal standards
for contaminants related to the PMC Site, Act 307 and the
Act 307 Rules are not ARARs. Act 307 and the Act 307
Rules would be potential ARARs for the final remedial
action at the Site.
Comment GOVERNMENT-54 (McNamee Main Document, Section
7.0, pages 17-19) McNamee presented its own evaluation
of alternatives for interim action at the Ingalls Well.
This evaluation did not include an alternative for air
stripping contaminated ground water. McNamee's
alternatives were:
• Alternative One: No Action
• Alternative Two: Development of New Groundwater Source
• Alternative Three development of A Lake Michigan
Surface Water Supply Intake and
Treatment System
• Alternative Four: Treatment of Groundwater From the
Ingall's Shore Well Aquifer With
Granular Activated Carbon Contactors
Response GOVERNMENT-54 U.S. EPA reviewed this portion of
McNamee's comments and identified statements which could
be considered as comments which warrant responses. Note
also that U.S. EPA does not agree with McNamee's decision
to exclude air stripping treatment as an applicable
remedial alternative for the ground water from the
Ingalls Well. Air stripping is an appropriate technology
for treating the contaminants which are present in the
well field and could cause an MCL exceedance at the
Ingalls Well.
28
-------
Comment GOVERNMENT-55 (McNamee Main Document, Section
7.4.1, page 19) McNamee discussed the implementability
of an activated carbon system.
Response GOVERNMENT-55 All technologies reviewed in
McNamee's document are technically feasible. McNamee has
focused on the alternative specifying carbon adsorption
for remediation of the ground water. The description of
the operations of such a system are adequate and reflect
the description given in "Alternative Five: Treatment of
Ground Water Using GAC Adsorption" from the initial FFS.
Comment GOVERNMENT-56 (McNamee Main Document, Section
7.4.1, page 19) McNamee provided its cost estimate for
construction and operation of an activated carbon system.
Response GOVERNMENT-56 The costs given for the
construction and operation of an activated carbon
treatment system are significantly higher than the costs
developed by U.S. EPA for a similar system. It is U.S.
EPA's opinion that an adequate system to treat the
contaminated well water, but not replace any existing
water department facilities, could be constructed for
significantly less capital expense. In addition, U.S.
EPA does not see the need for a full-time superintendent
and operators at a new treatment facility, since it.
assumed that the City of Petoskey currently employs such
personnel.
According to the National Contingency Plan (NCP), the
State has the responsibility for O&M of alternate water
supplies constructed with Superfund monies. If
Alternative Four or Five were to be built, the State and
the City would have to work out an arrangement for O&M.
Comment GOVERNMENT-57 (McNamee Main Document, Section
8.0, pages 20,21) McNamee conducted its own evaluation
of the nine criteria.
Responses GOVERNMENT-57 U.S. EPA disagrees with many
points made in the McNamee evaluation. Rather than
restate the Agency's position with respect to the
alternatives and the nine criteria, the reader is
directed to the Record of Decision Summary for a
discussion alternatives and U.S. EPA's evaluation of
alternatives with respect to the nine criteria.
Comment GOVERNMENT-58 (McNamee Appendix I - Cost
Evaluation) McNamee submitted its costs for alternatives
it believes should be considered for use at the Site.
Cost estimates for air stripping were not provided.
McNamee calculations indicate that construction and
29
-------
operation of. a Direct Filtration Water Treatment Plant
(NPV of $9,067,618) will be the least expensive
alternative when compared to the development of a new
ground water source, construction and operation of a
conventional surface water1 treatment plant, and treatment
of ground water using GAG contactors. McNamee
calculations also show that the Direct Filtration Water
Treatment Plant is the least expensive in terms of the
capital investment required ($6,070,000) and the annual
operating expenses ($225,000)..
Response GOVERNMENT-58 McNamee cost estimates have been
reviewed. U.S. EPA maintains that cost estimates
presented in this Record of Decision are accurate for
purposes of evaluating and comparing alternatives. U.S.
EPA dpes not agree with many assumptions made by McNamee,
such as the cost of the structure necessary for carbon
treatment and the cost of the carbon treatment equipment,
and maintains that the relative costs of alternatives
under consideration for the Interim Action are not
accurately represented by the McNamee estimates.
Comment GOVERNMENT-59 (McNamee Appendix II -
Correspondence Record) McNamee submitted a file of
correspondence relating to issues at the PMC Site and a
copy of the transcript from the public comment period.
McNamee also included a written statement (typed, with
hand written notes) presented by Mr. Gary Molchan at the
December 2, 1993 public meeting.
Response GOVERNMENT-59 Copies of correspondence are
noted. Responses to comments made during the public
meeting are presented in Section E below. U.S. EPA has
reviewed Mr. Molchan's written statement and determined
that the substantive issues raised are identical to those
presented as oral comments at the meeting.
Comment GOVERNMENT-60 (McNamee Appendix III -
Groundwater Summary Data) McNamee submitted a summary of
ground water and soil data collected from the PMC Site.
Response Government-60 While the summary of data is
useful for the review of site data, U.S. EPA must note a
few of its observations concerning the information
presented.
McNamee's table failed to include the 6 ppb MCL for
bis(2-ethylhexyl)phthalate. Readers should note that in
the Drinking Water Regulations and Health Advisories
published by the U.S. EPA Office of Water, standards and
advisories for this compound are provided under the
synonym "diethylhexyl phthalate."
30
-------
U.S. EPA also notes that information concerning McNamee
sample points- (MWB-1, MWB-2, MWB-3, MW-1, MW-2) was not
included in the comment package. At the request of U.S.
EPA, McNamee submitted boring logs and a map of sample
locations. Note also that the McNamee table contains a
typographical error and lists sample point MW-2 twice
without listing MW-1. U.S. EPA confirmed with McNamee
that the first listing of MW-2 should have been labeled
as "MW-l." In addition, the MDNR later informed U.S. EPA
that McNamee did not perform a complete inorganic
analysis of the samples as is suggested by the data
.table.
Comment GOVERNMENT-61 (McNamee Appendix IV - Data from
Eder Report) McNamee submitted an appendix which
included copies of the Remedial Investigation sampling
data.
Response GOVERNMENT-61 Submittal noted.
III. Mr. Ira Gabin and Mr. Brad Brogren of the MDPH provided
oral comments at the December 2, 1993, public meeting.
The oral comments noted that the on-line treatment
technologies proposed by U.S. EPA would not meet the
requirements of the Michigan Safe Drinking Water Act.
Because the comments were not sufficiently specific as to
allow an adequate response to the comment to be prepared,
the U.S. EPA Remedial Project Manager, Ms. Terese Van
Donsel, requested that MDPH prepare additional written
comments to specifically address this issue. Follow-up
written comments were submitted by MDPH during the
comment period and are addressed below.
Comment GOVERNMENT-62 Mr. Gabin noted the areas of major
deficiencies in the design outline provided for
Alternative Four. These included:
• Failure to meet the requirements of Part 12 of Act 399
Administrative Rules regarding reliability;
• Failure to meet the requirements of Part 10 of Act 399
Administrative Rules regarding treatment systems and
pumping facilities; and
• Failure to meet the requirements of Section 4 of Act
399 and Part 13 of the Administrative Rules which
state that plans and specifications for alteration of
a waterworks system shall not be approved unless they
are protective of the public health.
Response GOVERNMENT-62 Comments noted. In a conference
call with the commentor, the U.S. EPA Remedial Project
Manager confirmed that the above general areas of major
deficiencies noted by Mr. Gabin are detailed in the
31
-------
actual list of deficiencies provided in the comment
letter. Responses are provided for each noted
deficiency.
Comment GOVERNMENT-63 Mr. Cabin commented that firm
pumping capacity as required by Part 10 is not provided.
Maximum demands must be met with the largest pumping unit
out of service. Since this design utilizes only one high
service pump, when it fails, the City's upper pressure
district would be without water.
Response GOVERNMENT-63 The initial conceptual design of •
the air stripping and activated carbon systems included a
single new pump to deliver water from the well to the
treatment system. Existing pumps were intended to be
utilized to move the treated ground water into the City's
distribution system. After receiving additional input .on
the existing equipment, the design for both the air
stripping and carbon adsorption systems will utilize two
new pumps (one as a backup) to deliver water from the
well to the treatment system. New pumps have been
specified for water distribution to the high pressure
district while the existing pumps would be utilized for
distribution to the low pressure district.
Comment GOVERNMENT-64 Mr. Gabin noted that when the Lime
Kiln Well is out of service, the Ingalls low pressure
pump station is placed into service. Treatment for this
pressure district is not provided. When in use, it will
continue to pump contaminated water into the lower
pressure district. This is not protective of public
health as required by Section 4 of the Act and Part 13 of
the Rules.
Response GOVERNMENT-64 Based on new information, U.S.
EPA understands that the Ingalls Well is utilized for the
City's entire demand (2,200 gpm) in the event that the
Lime Kiln Well is out of service. The two new well
pumps, stripping columns, carbon vessels, and
distribution pumps have been redesigned accordingly.
In the original conceptual design, the 50 horsepower pump
was intended to deliver water from the Ingalls Well to
the top of the air stripper only while the existing pumps
were to be utilized for treated distribution. As
previously noted in Comment/Response GOVERNMENT-63, a
second well pump was added to provide backup and new
pumps will be utilized for the distribution system.
Comment GOVERNMENT-65 Mr. Gabin commented that the
capability to meet maximum day water demands as required
by the reliability provisions of Part 12 is not provided.
32
-------
The 1600 gpm high service capacity is less than the
City's maximum day demand of 2200 gpm. When the Lime
Kiln Well is out of service, the Ingalls Well must
provide all 2200 gpm. In addition, the specified 50
horsepower capacity of the high service pump is much too
small to pump 1600 gpm to the upper pressure district.
Response GOVERNMENT-65 See Comment/Response GOVERNMENT-
64.
Comment GOVERNMENT-66 Mr. Gabin noted that stand-by
power is required by Part 12 to provide a continuous
supply of water when normal electrical service is
interrupted. No provisions are made for a generator to
operate the pumps and blowers when the power supply is
disrupted.
Response GOVERNMENT-66 A generator has been added to
both the air stripping and carbon adsorption treatment
scenarios, to provide power when primary electrical
service is disrupted. In the air stripping system, the
generator will be of sufficient size to operate one
blower, one well pump, one high pressure district pump,
one low pressure district pump, and the necessary
controls, valves, etc. on one stripping column. In the
carbon system, the generator will be of sufficient size
to operate one well pump, one high pressure district
pump, one low pressure district pump, and the necessary
controls, valves, etc. on the carbon vessels.
Comment GOVERNMENT-67 Mr. Gabin observed that the design
outline did not specify low service pumps and stated that
he assumed that the existing high service pumps are to be
utilized as low service pumps. Pumps designed to operate
at a discharge head of 220 psi cannot be used to operate
at a discharge head of 15 psi without extensive
modifications, or more likely replacement. He further
commented that the 3000 gallon effluent tank is much too
small to provide the storage volume needed to equalize
low service pumping rates with high service demands. It
is unlikely that the system could pump water with a tank
this size because the high service pump(s) would
continuously break suction.
Response GOVERNMENT-67 Based on information received
during the public comment period, new pumps have been
specified for the high pressure district while the
existing low pressure district pumps will be utilized.
The suction tank, from which the distribution pumps will
feed, has been increased in capacity to 5,000 gallons in
the revised design. The 5,000 gallon tank acts only as a
33
-------
wet well from which the distribution pumps can pump! It
is not intended to be utilized as a storage tank. In the
event of the loss of the primary well pump, the
distribution pumps would also go off-line while the
backup well pump comes on-line. Storage capacity in the
City's water distribution network is sufficient to
provide an adequate supply for the few minutes required
to switch to the auxiliary well pump.
Comment GOVERNMENT-68 Mr. Cabin notes that no provision
was made for capture of treated VOCs for the air-
stripping alternative. Carbon units are. not provided and
no mention is made of carbon replacement or regeneration.
Response GOVERNMENT-68 U.S. EPA has determined that the
potential maximum release to the atmosphere from the air
stripping system would be less than 200 pounds of VOCs
per year. This is well below the maximum limit of 3.1
tons per year regulated by 40 CFR 264 AA under the
authority of RCRA. The air strippers would need to meet
the substantive requirements of the Clean Air Act for
operations, but no system to capture or destroy air
emissions would be required. Since the Interim Action is
"on site", an air permit would not be required but the
system must satisfy the substantive requirements of
Michigan Air Pollution Act permit.
Comment GOVERNMENT-69 Mr. Cabin commented that the
structure provided is too small to enclose the required
facilities. The severe winter climate will require
enclosure of treatment components to ensure continuous
operation and facilitate maintenance.
Response GOVERNMENT-69 The buildings originally
specified for the treatment systems were designed to
house just the support equipment for the air strippers
(blowers, controls, electrical) and both the vessels and
support equipment for the activated carbon system. The
air strippers themselves were to be insulated and located
outside the building. The existing pump house was
anticipated to continue to be utilized for distribution
pumps.
To accommodate the MDPH's concern regarding access to
treatment components, the conceptual design has extended
the piping in Alternatives Four and Five to allow the
system electrical equipment and controls to be placed
within the building.
Please note that the structures in question are
anticipated to be insulated Morton buildings or the
equivalent. No provision has been made to replace
34
-------
existing Water Department facilities such as offices,
locker rooms/ etc.
Comment GOVERNMENT-70 Mr. Cabin observed that laboratory
facilities were not included in the design outline and
cost estimates. He states that a gas chromatograph would
be required to monitor treatment efficiency.
Response GOVERNMENT-70 The cost estimates presented in
the FFS, and revised for the Record of Decision, included
laboratory costs as a part of yearly operation and
maintenance. Because purchasing laboratory equipment
would likely lead to issues about equipment upkeep,
training of operators, repair of faulty equipment,
purchase of auxiliary supplies, and certification that
QA/QCj! procedures are being followed, U.S. EPA prefers
that- monitoring samples be submitted to a qualified
laboratory for chemical analysis related to Superfund
contamination.
Comment GOVERNMENT-71 Mr. Gabin stated that cost
estimates for Alternative Four controls, valving, piping
and other appurtenances seem to be for non-potable
applications. He states that costs for these items would
be higher for municipal applications.
Response GOVERNMENT-71 The costs for controls, valving,
and other appurtenances for both the air stripping and
carbon treatment systems were based on utilizing existing
piping wherever possible. Additional costs have been
included for new piping runs between the well and the
treatment system. The components are intended to be
constructed of standard engineering materials, e.g.
general purpose controls/electrical, carbon steel valves,
ductile iron pipe, etc. No special requirements are
known to U.S. EPA requiring stainless steel or other
specialized materials of construction for potable water
systems.
The stripping columns are designed to be constructed of
UV-stabilized fiberglass reinforced plastic (FRP), which
can be obtained in a sufficiently high grade to provide a
30-year operating life. The carbon adsorption vessels
are to be constructed of carbon steel.
Comment GOVERNMENT-72 Mr. Gabin stated that the selected
alternative must be capable of removing the wide variety
of contaminants found at the Site. He further commented
that granular activated carbon is the only acceptable
alternative for removing organic contaminants from the
Ingalls Well.
35
-------
Response GOVERNMENT-72 As stated in many earlier
comments, U.S. EPA has determined that, .based on the
existing ground water data, only VOCs require treatment
at the Ingalls Well. Air stripping is an appropriate
technology for treatment of VOCs.
Comment GOVERNMENT-73 Mr. Gabin states that Alternative
Five of the FFS includes design flaws similar to those of
Alternative Four.
Response GOVERNMENT-73 The conceptual design and cost . .
estimate of Alternative Five were reviewed and revised iri
light of MDPH comments.
Comment GOVERNMENT-74 Mr. Gabin notes that the City's
consultant has proposed a carbon treatment system which
would meet with MDPH approval. Mr. Gabin recommends that
U.S. EPA utilize the McNamee carbon treatment system for
the cost determination.
Response GOVERNMENT-74 U.S. EPA has had extensive
discussions with MDPH regarding the required components
for on-line treatment at the Ingalls Well. It is U.S.
EPA's opinion that MDPH technical comments have been
resolved and that the conceptual designs used for the
evaluation of alternatives and preparation of cost
estimates would meet the requirements of the MDPH.
IV. Mr. William Bradford, Chief of the MDNR Superfund
Section, provided written comments during the public
comment period.
Comment GOVERNMENT-75 Mr. Bradford stated that the
Michigan Safe Drinking Water Act is an ARAR for the
Interim Action. Mr. Bradford noted that it was
identified^as an ARAR in the FFS, yet not mentioned in
the Proposed Plan or at the public meeting.
Response GOVERNMENT-75 Comment noted. Please see the
discussion of ARARs in Section 8.2 and 10(b) of the
Record of Decision Summary.
Comment GOVERNMENT-76 Mr. Bradford supplemented the list
of potential ARARs in the FFS with the following list of
potential ARARs:
• The Air Pollution Act, 1965 PA348, as amended and
associated rules;
• The Michigan Water Resources Commission Act, 1929 PA
245, as amended, and associated rules. A portion of
this has been identified as an ARAR. The portions
36
-------
of Act 245 relating to antidegradation and
maintaining ground water quality (including part 22
rules) still apply;
• The Liquid Industrial Waste Removal Act, 1969 PA
136, as amended, and associated rules (requires use
of licensed liquid industrial waste hauler);
• The Soil Erosion and Sedimentation Control Act, 1972
PA347, as amended and associated rules (regulations
prescribing the requirements for earth changes);
• The Shorelands Protection and Management Act, 1970
PA 245, as amended, (construction of permanent
structures in erosion, environmental and flood risk
areas);
• The Mineral Well Act, 1969 PA 315 (rules describing
permitting requirements for test wells and
geophysical holes);
• The Solid Waste Management Act, 1978 PA 641
(Licensing and disposal of solid waste-i.e.,
carbon); and
• The Michigan Compiled Laws Annotated- Section
257.722 (frost laws).
Response GOVERNMENT-76 Comments noted. Whether or not
the above State regulations are ARARs depends, in large
part, on what activities will be required for
implementation of the selected alternative. For example,
the Mineral Well Act may be an ARAR for activities
requiring the installation of new wells. However, since
no new wells are expected to be necessary in order to
construct an air stripper at the Ingalls Well, it is not
an ARAR for Alternative Four. Also, Act 245 would not be
an ARAR for treatment of the water supply at the Ingalls
Well. For a brief discussion of major ARARs, see
Sections 8.2 and 10(b) of the Record of Decision Summary
for a brief discussion of major ARARs.
Comment GOVERNMENT-77 Mr. Bradford stated that the MDNR
cannot support any alternative that does not meet
appropriate Michigan environmental statues which are
ARARs. Mr. Bradford also stated that the proposed
alternative does not meet MDPH requirements under the
Michigan Safe Drinking Water Act.
Response GOVERNMENT-77 Comment concerning State
concurrence is noted. Alternative Four can meet the
requirements of the Michigan Safe Drinking Water Act
37
-------
relating to contaminant treatment. The alternative will
not correct the existing construction and location
deficiencies currently present in the Ingalls Well. See
Section 8.2 and 10(b) in the Record of Decision Summary
for additional discussion of Site ARARs.
Comment GOVERNMENT-78 Mr. Bradford notes that compounds
are present in ground water that cannot be treated by air
stripping. Semi-volatile organic contaminants, including
MTBE, pesticides and metals have been seen in ground
water. The extent of a 1990 hydraulic fluid release has
not yet been determined. Mr. Bradford states that
Alternative Five should be selected to address current
and potential future contaminants in the Ingalls Well.
Response GOVERNMENT-78 Based on the monitoring data
collected to date, U.S. EPA does not agree that
contaminants other than volatile organic compounds
currently require treatment at the Ingalls Well. See
Comment/Response GOVERNMENT-1 and Comment/Response
GOVERNMENT-43 above and Comment/Response PUBLIC-1 below.
Comment GOVERNMENT-79 Mr. Bradford notes that there is
an error in Table 2-2 of the FFS. Table 2-2 discusses
Michigan Act 307 Type A and B Surface Water Criteria.
Act 307 does not regulate surface water criteria; the
Michigan Water Resources Commission Act does.
Response GOVERNMENT-79 The commentor is correct. Error
noted.
Comment GOVERNMENT-80 Mr. Bradford noted that FFS Table
2-9 discusses "cleanup" criteria. Mr. Bradford questions
why cleanup criteria are discussed in the FFS when the
purpose of the Interim Action is to.treat contaminated
municipal water.
Response GOVERNMENT-80 Comment noted. Mr. Bradford is
correct; the Interim Action is meant to treat municipal
water to ensure that the water meets MCLs.
D. SUMMARY OF SIGNIFICANT COMMENTS FROM THE PUBLIC
Comment PUBLIC-1
The Tip of the Mitt Watershed Council submitted comments
supporting the development of an alternate drinking water
supply. The Watershed council expressed concern that the
proposed alternative will not effectively remove semi-
volatile organic and inorganic contaminants. The
Watershed Council states that installation of an air-
38
-------
stripper at the Ingalls Well is not cost-effective due
to the vulnerability of the Ingalls Well and encouraged
U.S. EPA to work with the City of Petoskey, the MDNR and
the MDPH to obtain a safe drinking water supply for the
City.
Response PUBLIC-1
U.S. EPA agrees that air stripping will not effectively
remove semi-volatile and inorganic contaminants.
However, U.S. EPA's review of the groundwater data has
not identified' a need to treat the groundwater for semi-
volatile and inorganic contaminants. Please see the
response to the comment from Governor Engler (GOVERNMENT-
1) for a discussion of semi-volatile contamination in the
well field.
Although the soils at the PMC facility are contaminated
with metals, very little inorganic contamination has been
seen during ground water monitoring conducted during the
Remedial Investigation. Exceedances of MCLs have not
.demonstrated the need for treatment of inorganics at the
Ingalls Well:
a. Zinc was seen at elevated concentrations in several
monitoring wells. No MCL exists for zinc; therefore,
the Act 307 Type B level will be used solely as a
point of comparison. During the December 1992 and
March 1993 sampling events, zinc exceeded the Act 307
Type B Level (2300 ppb) in three samples. In December
of 1992, well PS-AS was found to have a concentration
of 2850 ppb and well PS-6 was found to have a
concentration of 8510 ppb of zinc. Subsequent
sampling in March of 1993 showed that the zinc level
in well PS-AS had dropped to 584 ppb, well below the
Type B level. The March 1993 zinc level for well PS-6
also dropped, but at 4380 ppb, remained above the Act
307 Type B Level. Both PS-AS and PS-6 are shallow
wells located on the other side of Lake Street south
of the PMC facility. While the zinc in groundwater
may be site related, the distribution of elevated zinc
levels in groundwater does not demonstrate a threat to
the Ingalls Well.
b. Arsenic was detected only in well PS-AD (located south
of PMC) during the March 1991 sampling. It was not
detected in any site wells during the December 1992
sampling event. Arsenic was detected in monitoring
well PS- 106 at 2.5 ppb in March of 1993. All
detections of arsenic in groundwater were far below
the MCL of 50 ppb.
39
-------
Arsenic (was found at low levels (maximum 4 ppb) in
MWB-3 during sampling conducted for the City of
Petoskey by McNamee in April of 1993. All arsenic
detections were far below the MCL of 50 ppb.
Antimony was seen in several monitoring wells and in
the Ingalls Well during the December 1992 sampling
event. The detection of antimony in the Ingalls Well
was estimated at 13.9 ppb and exceeded the 6 ppb MCL.
Follow-up sampling conducted in March of 1993 did not
identify antimony above the Contract Required
Detection Limit (CRDL) in the wells where antimony had
previously been seen or in any monitoring wells at the
Site.
Wqll December 1992 March 1993
PS-10A 22.4 ppb ND (CRDL=18.4 ppb)
PS-AS 25.5 ppb (B) ND (CRDL=19.0 ppb)
PS-6 23.5 ppb (B) ND (CRDL=19.0 ppb)
PS-4 14.3 ppb (B) ND (CRDL=18.4 ppb)
Ingalls 13.9 ppb (B) ND (CRDL=18.4 ppb)
*(B) Data point qualified because the reported value
was less than the contract required detection
limit, but greater than or equal to the
instrument detection limit.
The December 1992 and March 1993 sampling rounds do
not provide definitive information concerning the
presence or absence of antimony. Sampling conducted
by McNamee in the vicinity of the Ingalls Well in
April of 1993 also did not detect the presence of
antimony.
U.S. EPA samples taken from the Ingalls Well in
September 1994 and January 1995 did not detect the
presence of antimony. In the September 1994 sampling
event, antimony was not detected in either the well
tap or the well point at a detection level of 100 ppb.
Lower detection levels were requested for the January
1995 sampling event. In that sampling event, no
antimony was seen in either the wall tap or well point
samples at a detection level of 2 ppb.
Antimony had previously been seen in source area soils
and in background soil samples Bl and B3. It is not
known if the presence of antimony in soils is
naturally occurring or related to Site contamination.
If future sampling demonstrates that antimony is
indeed present in ground water and is determined to be
due to contamination from the PMC source area, the
40
-------
risk to users of the Ingalls Well and the risk to
users of contaminated private wells could increase.
The possible presence of antimony warrants continued
monitoring of inorganics in the well field.
If antimony enters the well in concentrations
exceeding the MCL, a determination will need to be
made as to whether the antimony is related to the PMC
Site. If antimony is found to be site-related, the
need for treatment and possible treatment alternatives
will be evaluated as part of the final remedy
selection process for the Site.
d. Manganese was elevated in one monitoring well at the
Site. There is no MCL for manganese, so the Act 307
Type B level will be used solely as a point of
comparison. The Act 307 Type-B health-based drinking
water value for manganese is 170 ppb. The MDNR has
determined that Type B local background level for
manganese is 285.5 ppb (based on two rounds of
sampling from monitoring well PS-13).
During December 1992 and March 1993, manganese levels
in monitoring well PS-10A were found to be 465 ppb and
452 ppb, respectively.
From data collected during the December 1992 and March
1993 sampling events, levels of manganese in the
Ingalls Well appear to .be below 5 ppb. The presence
of manganese does not demonstrate a need for treatment
for inorganics at the Ingalls Weil.
e. Lead was not seen in monitoring wells above the 15 ppb
action level (40 CFR 141.80). The highest
concentration seen during the December 1992 and March
1993 sampling events was 6.6 ppb at monitoring well
PS-6 south of the source area. The sporadic presence
of low-level lead in the well field does not
demonstrate a need for treatment for inorganics at the
Ingalls Well.
f. Mercury was not seen in monitoring wells during the
December 1992 and March 1993 sampling events. Mercury
was seen at very low levels (0.2 ppb) at McNamee
sample points MWB-1 and MWB-2 near the Ingalls Well
during McNamee's April 1993 sampling event. The MCL
for mercury is 2 ppb. Monitoring data do not
demonstrate that the PMC source area is the cause of
the low-level detection of mercury by McNamee or
support the conclusion that mercury is a problem in
the well field.
41
-------
Comment PUBLIC-2 Mr. William La Cross commented on the
Proposed Plan. He expressed his concern that the
proposed alternative of air stripping would remove only
one of the many contaminants. In addition, he stated
that the remediation technique would not be acceptable to
State and City Agencies. He requested that U.S. EPA
construct a water system that would work so that the
people of Petoskey can be protected.
Response PUBLIC-2 The air stripping technique selected
by U.S. EPA will remove a family of chemicals known as .
volatile organic compounds (VOCs) from water. It is
these VOCs that most threaten the water supply of the
City of Petoskey. While other contaminants are present
in the well field and in the water supply, the levels of
contamination seen to date do not warrant treatment.
Because U.S. EPA has determined that treatment at the
Ingalls Well is not necessary for these other
contaminants, it does not mean that the agency is
ignoring their presence. A careful evaluation was •
.conducted of contaminants in ground water that would not
be remediated with an air stripper. U.S. EPA found that
the levels of these other contaminants are not likely to
cause any exceedances of MCLs.
Air stripping is a proven technique for remediation of
VOCs in water. According to the Michigan Safe Drinking
Water Act, air stripping (also known as packed tower
aeration) is one of the two Best Available Technologies
(BAT) options for treatment of VOCs in ground water and
is the sole BAT option for treatment of vinyl chloride
should that contaminant become a concern as TCE degrades.
U.S. EPA understands that the City of Petoskey and the
State of Michigan would prefer to see an alternative
chosen that would replace the substandard Ingalls Well.
However, U.S. EPA must evaluate all alternatives based on
the nine criteria and select an alternative that is
appropriate for the level and type of contamination
present at a site. Because federal and state standards
exist which permit "safe" levels of contaminants in water
supplies, U.S. EPA cannot justify selecting a more costly
remedy to address contaminants that are already at levels
which are considered to be safe.
Comment PUBLIC-3 Ms. Rebecca Drake commented on the
Proposed Plan. 'Ms. Drake noted that all levels of
government should work together to arrive at a
comprehensive solution to the contamination problem of
the City's water supply. She stated that the solution
should include replacement of the Ingalls Well with a
42
-------
surface water supply that would be free from all toxins.
She also noted that care should be taken to ensure that
any surface water supply is not impacted by radioactive
particles from the Big Rock Nuclear Plant.
Response PUBLIC-3 U.S. EPA agrees that all levels of
government need to work together on projects such as
this. Governmental units must recognize the needs and
limitations of other levels of government. However, any
action to be taken by U.S. EPA must be supported by sound
technical data and is limited by the authorities under
which the Agency acts. .
City and State officials would clearly prefer replacement
of the Ingalls Well over any type of on-line treatment.
Replacement of the water supply would not only eliminate
exposure to contaminated ground water, but it would also
eliminate the need for the City to address the existing
construction and location deficiencies at the Ingalls
Well. U.S. EPA is responsible for assuring that unsafe
levels of contamination from the PMC source area do not
impact the Ingalls Well and has proposed and selected an
alternative to do just that. However, the State should
not expect the U.S. EPA to "better" the remedy in order
to address problems that are unrelated to the Superfurid
contamination.
Because U.S. EPA recognizes the fact that the City has
concerns other than just the well field contamination,
U.S. EPA has offered to make the capital cost of the
selected remedy available to the City (through the State
of Michigan) for use in replacing its water supply. The
State and the City could then choose whether it is more
beneficial to install treatment at the Ingalls Well or
put the funds toward the construction of the Surface
Water Intake/Treatment Plant that it has expressed an
interest in building. This would not be inconsistent
with the selected remedy, but would allow the State to
"enhance" the Interim Action.
Comment PUBLIC-4 Mr. George Kurburski submitted comments
on U.S. EPA's Proposed Plan. Mr. Kurburski felt that
Alternative Two should be selected because it would
address the fact that the existing Ingalls Well is
vulnerable to contamination from other industries in the
area. He stated that it would be inappropriate to use
water from Lake Michigan since effluent from the sewer
plant is discharge into the Lake within a quarter mile of
where the surface water intake would be located.
Response PUBLIC-4 U.S. EPA agrees that the Ingalls Well
is vulnerable to contamination from other area
43
-------
industries. However, it is the responsibility of U.S.
EPA's Superfund program to address contamination that is
already released into the environment. Replacement of
the Ingalls Well with another well (Alternative Two) or a
Surface Water Intake/Treatment Plant (Alternative 3)
cannot be justified simply because the Ingalls Well is
vulnerable to future contamination from other sources.
However, U.S. EPA recognizes that the City of Petoskey
may elect to replace the Ingalls Well because of existing
Michigan Safe Drinking Water Act construction and
location deficiencies which allow the infiltration of
surface water and render the well vulnerable to future
contamination.
E. SUMMARY OF SIGNIF]
PUBLIC MEETING HELD ON DECEMBER 2.
I. Mr. Ira Cabin of the Michigan Department of Public Health
Division of Water Supply presented extensive oral
comments at the public meeting:
Comment MEETING-1 Mr. Gabin stated that the proposed
cleanup plan was flawed because it would not meet the
requirements of the Michigan Safe Drinking Water Act.
Alternative Four, air stripping, will not provide system
reliability and would not function hydraulically.
Response MEETING-1 U.S. EPA has worked with the MDPH to
arrive at a conceptual design for air-stripping that
would meet the requirements of the Safe Drinking Water
Act without correcting the existing deficiencies of the
Ingalls Well. The description and costs presented in the
Record of Decision Summary reflect the changes made based
on MDPH comments.
Comment MEETING-2 Mr. Gabin stated that Alternative Four
contained no mention of off-gas treatment or capture of
the aerated TCE. Mr. David Linnear of the U.S. EPA
stated at the meeting that off-gas treatment would be a
component of the remedy.
Response MEETING-2 Based on a conservative evaluation of
the levels of contamination that would be present in the
treatment system influent, it is not likely that an off-
gas treatment system would be needed. The maximum
emissions from an air stripper at the PMC Site is
estimated to be 140 pounds of total VOCs per year, well
below the limits that warrant treatment. However, if
operation of the air stripper demonstrates that treatment
of the off gas is needed, it will be implemented.
44
-------
Comment MEETING-3 Mr. Cabin stated that the Proposed
Plan does not delineate the boundaries of the site. He
stated that the Petoskey Manufacturing Company property,
the Ingalls Well and the regional aquifer should be
included as part of the site.
Response MEETING-3 The "boundaries" of the Site are not
relevant to the Proposed Plan that was issued for the
Interim Action. The Interim Action is meant to ensure
that the City's water supply is not impacted by unsafe
levels of contamination from the PMC Site. The Site
itself is being addressed as part of a RI/FS being
conducted by the State of Michigan. The "boundaries" of
the overall RI/FS investigation have not been established
as a line on a map, but are instead defined as including
the qxtent of soil and ground water contamination from
the PMC facility-
Comment MEETING-4 Mr. Gabin questioned how the U.S. EPA
could move ahead with the Proposed Plan when the Remedial
Investigation is not yet complete.
Response MEETING-4 The purpose of the Interim Action is
to ensure that the City's water supply is not impacted by
unsafe levels of contamination. While the Remedial
Investigation Report is not yet complete, significant
ground water sampling data has been collected and is
available for public review. Based on the data collected
to date, U.S. EPA believes that an interim action is
appropriate at this time to address the VOCs that are
known to exist in the ground water and are currently
impacting the Ingalls Well.
To specifically address Mr. Cabin's concern about the
timing of the Interim Action, the U.S. EPA Remedial
Project Manager, Ms. Terese Van Donsel, spoke with Mr.
Gabin during a meeting held in Lansing, Michigan, on May
31, 1994. Ms. Van Donsel asked Mr. Gabin whether the
MDPH would prefer that the U.S. EPA not issue a Record of
Decision until the Site investigation is complete. Mr.
Gabin declined and stated that U.S. EPA should proceed
with an Interim Action as planned.
It would of course be preferable to have all field work
complete and the Remedial Investigation Report finalized
and available to the public before taking any remedial
action. However, to wait may risk allowing higher levels
of contamination to enter the Ingalls Well.
Comment MEETING-5 Mr. Gabin stated that Alternatives Two
and Three are clearly superior to alternatives Four and
Five in terms of overall protection of human health and
45
-------
the environment because they eliminate exposure of the
water supply source to the contaminants on the site.
Response MEETING-5 The No Action Alternative is
considered to be protective of human health and the
environment based on an evaluation of the current levels
of contamination in the Ingalls Well and a comparison
with MCLs. U.S. EPA feels that Alternatives Four and
Five would also be protective of human health and the
environment when properly constructed and operated.
Comment MEETING-6 Mr. Gabin stated that, only
Alternatives Two and Three comply with ARARs,
specifically the Michigan Safe Drinking Water Act.
Response MEETING-6 Because of existing construction
deficiencies unrelated to the contamination from the PMC
Site, the Ingalls Well does not comply with the Michigan
Safe Drinking Water Act. Correction of these
deficiencies is not within the authority of U.S. EPA's
Superfund regulations. Alternatives Three and Four can
be designed and constructed so that the on-line treatment
system portion of the water system meets State ARARs.
Comment MEETING-7 Mr. Gabin stated that Alternatives Two
and Three are superior to Alternatives Five and Four in
terms of long-term effectiveness and permanence.
Response MEETING-7 U.S. EPA believes that Alternatives
Two, Three, Four, and Five would all be effective in the
long-term, depending on the proper design and operation
of the remedial systems.
Comment MEETING-8 Mr. Gabin stated that none of the
alternatives address reduction of contaminant toxicity,
mobility and volume through treatment.
Response MEETING-8 Alternative Five, and potentially
Alternative Four, would indirectly and slightly address
the reduction of contaminant toxicity, mobility and
volume. Although the use of Air Stripping and GAC only
transfer contaminants from ground water to another media
(and thus do not reduce TMV), the regeneration of the
filter carbon used in the processes would reduce the TMV
through treatment. Alternative Five would therefore
slightly reduce the TMV of VOCs found in ground water.
Alternative Four would reduce the TMV of VOCs in ground
water if levels of contaminants justify the treatment of
the system off-gases.
Comment MEETING-9 Mr. Gabin stated that Alternatives Two
arid Three are superior in terms of short-term
46 .
-------
effectiveness.
Response MEETING-9 The potential for exposures to humans
and the environment would not be restricted by the No
Action Alternative because no action would occur through
treatment.
Alternatives Two, Three, Four, and Five are all expected
to be effective in the short-term in reducing or
eliminating the potential exposure pathways for human
contact. Alternatives Four and Five may require the use
of personal protective equipment (PPE) by workers and
more rigorous monitoring to ensure that no contaminant
exposures to the workers or the community are caused due
to the remedial efforts.
Comment MEETING-10 Mr. Gabin takes issue, with U.S. EPA's
statement in the FFS that all alternatives can be
implemented. Mr. Gabin stated that no alternative can be
implemented without the approval and issuance of permits
from the Department of Public Health. Mr. Gabin stated
that because Alternatives Four and Five do not meet Safe
Drinking Water Act requirements, permits cannot be
issued.
Response MEETING-10 According to the MDPH, the City of
Petoskey has the option of either finding a new water
supply to replace the Ingalls Well or of installing
treatment at the Ingalls Well to address the infiltration
of surface water. U.S. EPA recognizes that continued
operation of the Ingalls Well is dependent upon the
City's future actions with respect to the Well's existing
construction deficiencies. Correction of these
deficiencies is not within the authority of the U.S. EPA
Superfund program.
Alternatives Four and Five can be designed and
constructed in such a manner that they meet the State
ARARs. Installation of either treatment system would do
nothing to correct existing deficiencies. Because
Alternatives Four and Five would be implemented on-site,
U.S. EPA would not be required to obtain permits for the
construction and operation of the treatment systems.
However, the Alternatives would have to comply with the
substantive requirements of permits.
Comment MEETING-11 Mr. Gabin stated that Alternatives
Four and Five are less expensive than Alternatives Two
and Three, but Alternatives Four and Five are based on
designs that do not meet Safe Drinking Water Act
requirements.
47
-------
Response MEETING-11 The conceptual designs and cost
estimates for Alternatives Four and Five have been
reevaluated in light of comments made by the MDPH.
Subsequent follow-up conference calls with the MDPH have
clarified State concerns. 'U.S. EPA believes that
Alternatives Four and Five satisfy MDPH concerns with
respect to Safe Drinking Water Act requirements relating
to contaminant treatment.
Comment MEETING-12 Mr. Gabin stated that Alternatives
Two and Three are superior in terms of state and
community acceptance.
Response MEETING-12 Comment noted. The State would
prefer that U.S. EPA replace the water supply. By
replacing the Ingalls Well with another well or with a
surface water intake/treatment plant, Alternatives Two
and Three eliminate the need for the City to address the
existing construction deficiencies at the Ingalls Well.
This would save the City of Petoskey a large amount of
money and eliminate any rate increase to Petoskey
consumers that may be necessary to fund the correction of
problems that are unrelated to the contamination from the
PMC source area. However, the Superfund cannot be used
in this way.
The remedy selected must be appropriate for addressing
the Ingalls Well contamination in a manner that is
protective of human health and the environment, attains
applicable or relevant and appropriate requirements
(ARARs), is cost-effective and represents the best
balance among the evaluating criteria. Alternative Four,
Air Stripping, provides the "best balance" of tradeoffs
with respect to the nine criteria.
Comment MEETING-13 Mr. Gabin concludes that Alternatives
Two and Three provide the best balance of trade-offs with
respect to the nine criteria. The Michigan Department of
Public Health has gone on record that Alternative Three,
the surface water treatment plant, is the best long-term
solution for the City of Petoskey.
Response MEETING-13 U.S. EPA disagrees. Based on the
U.S. EPA's evaluation of the nine criteria, Alternative
Four provides the best balance of trade-offs with respect
to the nine criteria. However, U.S. EPA recognizes that
the City of Petoskey has other concerns besides the
Superfund Site and acknowledges that the surface water
treatment plant may remain the City's preferred option.
Therefore, if the State of Michigan concurs with the
remedy selected in this Record of Decision, the capital
cost of the selected remedy could be made available to
48
-------
the State so that the remedy can be "enhanced."
Comment MEETING-14 Mr. Gabin stated that the solution
must address the presence of all contaminants at the site
and not just TCE.
Response MEETING-14 U.S. EPA disagrees. See
Comment/Response GOVERNMENT-1, Comment/Response
GOVERNMENT-6 and Comment/Response PUBLIC-1
Comment MEETING-15 Mr. Gabin stated that the solution
must also address the existing construction deficiencies
of the Ingalls Well.
Response MEETING-15 U.S. EPA disagrees. The City of
Petoskey responsible for the existing construction
deficiencies at the Ingalls Well.
II. Mr. Brad Brogren, also of the MDPH Division of Water
Supply, spoke after Mr. Gabin and presented excerpts from
correspondence concerning the site. Elements of the
correspondence quoted by Mr. Brogren that are relevant to
the evaluation of alternatives are presented below.
Comment MEETING-16 Mr. Brogren quoted from
correspondence that states that it is the MDPH's position
that the current 5 ppb Maximum Contaminant Level for TCE
is based primarily on the laboratory practical
quantification level, and thus a public health basis
exists to reduce exposure below the MCL. MDPH has taken
the position that water supplies should meet the Maximum
Contaminant Level Goal of zero for known or suspected
carcinogens.
Response MEETING-16 See Comment/Response GOVERNMENT-6
Comment MEETING-17 Mr. Brogren references correspondence
from a MDNR geologist who concludes that there are four
different sources of contamination within 1000 feet of
the Ingalls Well.
Response MEETING-17 The Interim Action is evaluating the
need for action at the Ingalls Well based on
contamination seen at the Ingalls Well and in the well
field. Other sources of contamination will be discussed
during the RI/FS. At this point in time, the PMC
facility is the sole source area being investigated under
the Superfund program.
Comment MEETING-18 Mr. Brogren stated that MDPH is
concerned with past exposure levels that were higher than
today's.
49
-------
Response MEETING-18 Comment noted. See also
Comment/Response GOVERNMENT-39.
Comment MEETING-19 Mr. Brogren stated that the Petoskey
Municipal System is unable to blend the Ingalls Well
water with the contaminant-free water from the Lime Kiln
Well.
Response MEETING-19 Comment noted.
Comment MEETING-20 Mr. Brogren stated that if Lime Kiln
were to go down for repair, the Ingalls Well would have
to pump at a high capacity, He expressed concern that
this higher pumping rate could cause additional
contaminants to enter the Ingalls Well.
I
Response MEETING-20 Comment noted. U.S. EPA agrees that
a higher pumping rate could cause levels of TCE in the
Ingalls Well to increase. However, based on a
conservative evaluation of the maximum levels of SVOC and
inorganic contamination detected in the well field, U.S.
EPA believes that it is unlikely that an increased
pumping rate would cause MCL exceedances at the Ingalls
Well for non-VOC contaminants. However, the carbon
treatment contingency portion of the ROD addresses the
State's concern that SVOCs could cause future MCL
exceedances.
Comment MEETING-21 Mr. Brogren referenced a letter from
MDPH Director Vernice Davis Anthony in which MDPH stated
that U.S. EPA believes TCE to be the only hazardous
substance associated with the Petoskey Site. Any
proposed treatment of the Ingalls Well must address all
area groundwater contaminants.
Response MEETING-21 U.S. EPA does not believe that TCE
is the only hazardous substance associated with the
Petoskey Site. However, based on ground water monitoring
data and a comparison with MCLs, TCE is the only
contaminant which seems to warrant treatment in ground
water at the Ingalls Well.
Comment MEETING-22 Mr. Brogren stated that health risk
assessments are not an exact science and that he does not
want the Citizens of Petoskey to be used as guinea pigs
for this type of study.
Response MEETING-22 U.S. EPA acknowledges that health
risk assessments are not an exact science. U.S. EPA
assumes that in mentioning a "study", Mr. Brogren is
referring to the selection, construction and operation of
an air stripper which would not address low level semi-
50
-------
volatile and inorganic contamination. U.S. EPA strongly
disagrees with Mr. Brogren's assertion .that selection,
construction and"operation of an air stripper to ensure
that the water from the Ingalls Well would meet MCLs
could somehow be considered a study which would use the
citizens of Petoskey as "guinea pigs." Selection of an
air stripper remedy is appropriate based on a careful
review of the ground water monitoring data and an
evaluation of the nine criteria. In fact, based on
current levels of contamination at the Ingalls Well, the
No Action Alternative is also considered to be protective
of human health and the environment.
In evaluating the contamination in the well field, U.S.
EPA is using MCLs as a basis for determining the
acceptability of water for the Petoskey municipal water
supply. MCLs are standards that are consistently applied
to all drinking water nation-wide; drinking water that
meets the MCLs set forth in the National Primary Drinking
Water Standards is associated with little or no risk of
adverse health effects and is considered safe for
. drinking purposes.
U.S. EPA supports the MDPH's goal to work towards
achieving MCLGs in all water supplies. However, U.S. EPA
cannot require or fund water supply treatment to achieve
non-enforceable goals.
U.S. EPA notes that since the promulgation of the Surface
Water Treatment Requirements of the Safe Drinking Water
Act on June 29, 1989, the State of Michigan had until
June 29, 1994, to notify each community where the water
supply was under the direct influence of surface water.
MDPH failed to issue its notification to the City of
Petoskey by the June 29, 1994, deadline. In fact, no
notification had been made as of the signature date of
this Record of Decision.
The Ingalls Well is a shallow well dug in the shoreline
of Lake Michigan. All parties agree that the well draws
in surface water as it pumps, yet the MDPH has failed to
provide timely notification to the City of the well's
deficiency. Formal recognition of the fact that the well
is under the influence of surface water would have
allowed U.S. EPA to properly evaluate the need for an
action at the Ingalls Well based on solid information
concerning the future use of the well.
III. Mr. Bill Bradford presented verbal comments on behalf of
the MDNR.
51
-------
Comment MEETING-23 Mr. Bradford stated that the Michigan
Safe Drinking Water Act and the Michigan Air Pollution
Act are ARARs for Alternatives Four and Five.
Response MEETING-23 As discussed before, The Michigan
Safe Drinking Water Act and the Michigan Air Pollution
Act are ARARs; however, U.S. EPA is not required to
correct existing deficiencies or "better" the well and
water distribution system. U.S. EPA's authority under
Superfund would also not extend to operational and
monitoring requirements unrelated to the air stripping
treatment process and to contaminants from the PMC Site.
The Michigan Air Pollution Act is an ARAR for operation
of the air stripper.
IV. Mr. Scott Schloegel spoke on behalf of- Congressman Bart
Stupak.
Comment MEETING-24 Mr. Schoegel stated that the U.S. EPA
has not done all it can and that the Agency has been slow
to incorporate state standards into consideration. He
also stated that Senator Levin and Senator Riegle share
Congressman Stupak's concern regarding the site.
Response MEETING-24 The State of Michigan has expressed
repeated concern that U.S. EPA is using MCLs as a point
of comparison for water quality at the Ingalls Well.
However, use of MCLs is consistent with Michigan's Safe
Drinking Water Act, which adopted MCLs. U.S. EPA has no
authority to enforce MCLGs of zero and does not believe
that MDPH policy is an appropriate justification for such
an action.
In addition, U.S. EPA's responsibility is limited to
those regulations that apply to the alternative selected.
For example, the Michigan Safe Drinking Water Act
outlines monitoring requirements for coliform bacteria.
This is an issue clearly unrelated to the remediation of
VOCs at the Ingalls Well and would not be the
responsibility of Superfund.
V. Mr. Gary Molchan of McNamee Environmental Consultants,
Inc. (McNamee) presented verbal comments. McNamee is the
City of Petoskey's environmental consultant engineer.
Comment MEETING-25 Mr. Molchan stated that the U.S. EPA
has disregarded" correspondence concerning the nature of
contamination in the well field. He also stated that
U.S. EPA actions have not been "reflective of the
positive environmental and social ethics" which he's
accustomed to seeing in government.
52
-------
Response MEETING-25 U.S. EPA has not disregarded
correspondence concerning the nature of contamination in
the well field. U.S. EPA has reviewed submitted
information and has made the determination that levels of
inorganic and semi-volatile organic contamination in the
well field do not warrant treatment at the Ingalls Well.
However, the carbon treatment contingency in the ROD
addresses the State's concern that SVOCs could threaten
the water supply of the City of Petoskey.
Comment MEETING-26 Mr. Molchan provided a brief history
of the RI/FS work at the site. He discussed the original
Scope of Work to be completed by PMC and questions why,
"six years later, this report, the responsibility of EPA,
is not completed and available to the public." He also
stated that the presence of hazardous substances in the
ground water and at the PMC is "contrary to the 1987
Order".
.Response MEETING-26 U.S. EPA notes that the RI/FS is
currently being conducted by the MDNR. In September of
1990, the MDNR requested to take the lead on the project
and U.S. EPA has provided the funding necessary to
perform the work. In December of 1993, U.S. EPA received
a draft RI that was not of acceptable quality. U.S. EPA
therefore chose not to finalize the document and instead
allowed the data to be released. U.S. EPA is working
with the MDNR to revise the draft RI so that it will be
acceptable for release.
U.S. EPA is unsure how the presence of hazardous
substances in ground water at the PMC Site is "contrary
to the 1987 Order." The 1987 Order with PMC required the
company to investigate Site contamination and evaluate
cleanup options. When it became clear that PMC was not
able to fulfill its responsibilities under the Order,
U.S. EPA funded the MDNR to conduct the RI/FS. That work
is still ongoing. Following the process outlined in the
National Contingency Plan, a Record of Decision will be
prepared to select cleanup alternatives for soil and
ground water. At that point in time, Remedial Design and
Remedial Action will proceed.
Comment MEETING-27 Mr. Molchan stated that EPA is
withholding data and refuses to acknowledge information
that "would alter the course of this remedy". He stated
that the substances in groundwater present an
unacceptable risk to the public. Mr. Molchan further
stated that the MDNR and the MDPH consider the current
and future risk to the public to be unacceptable.
53
-------
Response MEETING-27 U.S. EPA is not withholding data.
Even though the Remedial Investigation Report is not
final, RI/FS sampling and monitoring data has been made
public.
Comment MEETING-28 Mr. Molchan stated that key
information was omitted from the Risk Assessment prepared
as part of the Focused Feasibility Study. EPA has
ignored synergistic effects of multi-contaminant exposure
for the last 12 years and has failed to project possible
health effects for residents that have been or will be . .
drinking the water for periods greater than 30 years!
EPA has therefore underestimated the risk present at the
site.
Response MEETING-28 See Section 6.6 in the Record of
Decision Summary for a discussion of uncertainties. See
also Comment/Response GOVERNMENT-39.
Comment MEETING-29 Mr. Molchan stated that the proposed
system will not treat all ground water in the well field.
There are hazardous substances in the well field.
Therefore, the proposed action is inconsistent with the
NCP.
Response MEETING-29 The logic put forward by the
commentor is not supported by the NCP. The Interim
Action is meant to ensure that water from the Ingalls
Well meets MCLs, which are the chemical-specific ARARs
applicable for municipal water supplies. This Interim
Action is in no way inconsistent with the NCP.
Comment MEETING-30 Mr. Molchan stated that levels of TCE
and other compounds are increasing. TCE is transforming
into DCE.
Response MEETING-30 It is misleading to say that levels
of TCE and other compounds are increasing without
relating that information to specific monitoring wells.
Levels of TCE are fluctuating in monitoring wells as the
contaminants travel through the well field.
Comment MEETING-31 Mr. Molchan stated that EPA is
selectively monitoring and analyzing for hazardous
substances. He claimed that "EPA data is consistent in
recognizing TCE. But not on DCE and vinyl chloride as
hazardous substances that exist on the Petoskey
Manufacturing Site, and in the groundwater in the well
field."
Response MEETING-31 U.S. EPA did not establish the
ground water sampling program at the Site. The data used
54
-------
in the Baseline Risk Assessment for Ground Water were
from samples collected and analyzed by the Michigan
Department of Public Health and the Michigan Department
of Natural Resources between 1989 and March 1991.
The recent ground water monitoring (December 1992, March
1993) that was conducted at the Site was performed by the
MDNR and its contractor. This information has been
qualitatively discussed in the Record of Decision summary
and in this Responsiveness Summary. U.S. EPA also
qualitatively considered the April 1993 sampling data
submitted by McNamee, although QA/QC information has not
been provided.
Therefore, the fact that additional DCE and vinyl
chloride detections were not found does not mean that EPA
is selectively monitoring and analyzing for hazardous
substances.
Comment MEETING-32 Mr. Molchan stated that the City has
reduced pumping rates at the Ingalls Well to reduce the
quantity of ground water drawn into the system.
Response MEETING-32 Comment noted.
Comment MEETING-33 Mr. Molchan stated that, "EPA is
ignoring the MCL requirements that clean-up levels and
proposed remedy must address all hazardous substances
throughout the well field. These levels in the well
field have exceeded the MCL and Act 307 ARAR requirements
continuously since 1984. These are the requirements
addressing drinking water quality, which is the basis of
EPA's interim response.
Response MEETING-33 MCLs are the chemical-specific ARARs
applicable for drinking water quality in the municipal
system. The Interim Action is not meant to directly
remediate ground water in the well field.
Comment MEETING-34 Mr. Molchan stated that the
"deliberate misrepresentation of facts by the EPA and
deceitful action by EPA will result in the knowing
endangerment of public health if this proposed interim
remedy option is implemented."
Response MEETING-34 U.S. EPA strongly disagrees with the
statement made by Mr. Molchan. U.S. EPA has selected an
Interim Action to ensure that contaminant levels in the
Ingalls Well meet MCLs. It is U.S. EPA's opinion that
Mr. Molchan has failed to recognize that this is an
Interim Action that is not meant to address soil
contamination at the Site or remediate the well field.
55
-------
VI. Mr. Dean Mikulski (Director of Environmental Health,
District Health Department Number 3, representing Antrim,
Charlevoix, Emmet", Otsego Counties) presented verbal
comments.
Comment MEETING-35 Mr. Mikulski stated that the proposed
alternative is irresponsible and does not do anything to
protect the public health and the future of the citizens
of the City of Petoskey. He expressed concern with the
presence of carcinogenic contaminants within the plume.
Response MEETING-35 The water in the Ingalls Well
currently meets MCLs and is, therefore, acceptable in
terms of State and Federal chemical-specific standards.
The MDPH, however, has a stated policy of attempting to
eliminate all chemical contamination from water supplies
in the State of Michigan. U.S. EPA cannot enforce these
goals for total elimination of contamination and must
rely on enforceable standards to evaluate drinking water
quality.
The VOC contamination in the well field has the potential
of causing an MCL exceedance at the Ingalls Well. The
selected alternative will address the presence of VOCs in
the Ingalls Well. Based on the ground water quality data
collected to date, it is unlikely that semi-volatile
organic contaminants and inorganic' contaminants will
require treatment in order to satisfy MCL requirements.
However, the carbon treatment contingency in the ROD
addresses any site-related SVOC exceedances that may
occur in the near future.
Comment MEETING-36 Mr. Mikulski said that it was
unacceptable for EPA to not look at the vulnerability of
the well. He stated that the Ingalls Well "merely is a
dug well of 20 feet deep. That is getting, you're
getting the water, a shallow source. Some bay water,
depending upon the demands of that supply." He further
stated that the Safe Drinking Water Act would not let a
restaurant serving 25 people today use that supply. Even
with air stripping or carbon treatment, the supply would
be unacceptable.
Response MEETING-36 U.S. EPA agrees that the Ingalls
Well is not an ideal supply for the City of Petoskey and
that the well is indeed vulnerable to future
contamination. U.S. EPA also agrees with the MDPH's
conclusion that the Ingalls Well does not satisfy the
requirements of the Safe Drinking Water Act. However,
these concerns stem from existing construction
deficiencies at the Ingalls Well. The issues are not the
result of contamination from the PMC source area and are
56
-------
not the responsibility of Superfund. The City of
Petoskey is responsible for correcting the deficiencies
of the well that are unrelated to contamination from the
Superfund Site.
Comment MEETING-37 Mr. Mikulski stated that EPA has not
attempted to address the multiple contaminants within the
ground water. He said that the ground water is moving
and the other contaminants would find their way into the
water supply. EPA's proposal is "antiquated and
obsolete."
Response MEETING-37 The Interim Action is not meant to
remediate the well field. It will ensure that unsafe
levels of VOCs will not enter the municipal water supply.
U.S. EPA agrees with the commentor's statement that
ground water is moving. Therefore, current levels of .
contamination in the Ingalls Well may not be
representative of future contaminant levels. In an
attempt to conservatively predict contaminant levels at
the Ingalls Well, U.S. EPA has reviewed contaminant
levels throughout the well field and carefully considered
the fact that dilution would occur at the Ingalls Well as
it operates. From this evaluation, U.S. EPA has made the
determination that air stripping for VOC contamination at
the Ingalls Well is the appropriate technology to ensure
MCLs are maintained for the water supply.
Comment MEETING-38 Mr. Mikulski stated that the Health
Department wants to reduce cancer risk to the lowest
possible level. Therefore, there should be no TCE in the
drinking water supply.
Response MEETING-38 See Comment/Response GOVERNMENT-6,
Comment/Response GOVERNMENT-20, Comment/Response MEETING-
22, Comment/Response MEETING-24, and Comment/Response
Meeting 35.
VII. Mr. George Korthauer, the Petoskey City Manager,
presented oral comments which included a brief history of
the City's search for a reliable water supply and a brief
history of the City's dealings with EPA.
Comment MEETING-39 Mr. Korthauer stated that there are
people drinking contaminated water and instead of taking
action the Agency is studying the problem to death. He
further stated that "we can't convince the agency that's
responsible for' that solution to solve the problem."
Response MEETING-39 U.S. EPA is sympathetic to Mr.
Korthauer's concern that the Agency is "studying the
problem to death." The RI/FS technical process is long
57
-------
and involved but is necessary to gain a complete
understanding of the extent of contamination. MDNR is
continuing its evaluation of ground water and soil
contamination.
Because U.S. EPA recognizes the City's concerns with
regard to chemical contamination of the water supply, the
Agency proposed and selected the Interim Action to ensure
that water from the Ingalls Well will continue to meet
MCLs. U.S. EPA does not have the authority to require or
fund a cleanup to eliminate all carcinogenic
contamination.
VIII. State Representative .Pat Gagliardi, representing the 107th
House District, presented oral comments at the public
meeting. Because he could not remain for the public
comment portion of the meeting, his comments were taken
after the introduction to the meeting.
Comment MEETING-40 Representative Gagliardi stated that
PMC was required to prepare a sampling plan, quality
assurance project plan, a data management plan, a
hydrogeological study, a surface water investigation
study, and a site map (showing wetlands, floodplains,
water, future drainage patterns, above- and below-ground
utilities). Mr, Gagliargi stated that U.S. EPA was not
holding itself to the same standards that it required of
PMC when PMC was conducting RI/FS.
Response MEETING-40 When PMC demonstrated that it was
not capable of properly conducting the RI/FS, U.S. EPA
relieved PMC of conducting further RI/FS work. The U.S.
EPA then entered into a State Cooperative Agreement with
the MDNR in 1990, in which the MDNR agreed to perform the
RI/FS.
The Focused Feasibility Study (FFS) and Baseline Risk
Assessment for Ground Water prepared by the U.S. EPA were
solely meant to evaluate the need for an interim action
at the Ingalls Well. Basically, is the quality of water
in the Ingalls Well acceptable? If it isn't, what should
be done? The documents referenced by Representative
Gagliardi were not necessary for this interim evaluation.
The MDNR has already prepared many of the documents
outlined by Representative Gagliardi (i.e., sampling
plan, quality assurance project plan). The MDNR will
continue its work on the RI/FS and prepare the additional
documents/studies as needed to move the project forward.
Comment MEETING-41 Representative Gagliardi stated that
U.S. EPA withheld data and has refused "to acknowledge
58
-------
information provided by the City/ the Government, the
Department of Public Health, the Department of Natural
Resources."
Response MEETING-41 The U.S. EPA has not withheld data.
In fact, the U.S. EPA authorized the MDNR to release RI
sampling data (ground water results from samples taken in
December 1992, March .1993) even though the RI itself was
not approved. The U.S. EPA has evaluated information
submitted by the City, the MDPH and the MDNR. However,
U.S. EPA would like to note that Superfund authority
extends only so far, and the U.S. EPA cannot correct
problems unrelated to contamination from the PMC Site.
It also cannot eliminate all trace contaminants from
ground water that are below federal allowable levels.
Comment MEETING-42 Representative Gagliardi stated that
U.S. EPA is trying to "force a cheap, unworkable remedy
down the throats of the people of the community."
Response Meetina-42 U.S. EPA disagrees. If properly
constructed and operated, Alternative Four will work to
reduce the levels of VOCs in water.supplied by the
Ingalls. Well. If U.S. EPA finds SVOC treatment to be
necessary, Alternative Five will reduce the levels of
VOCs and SVOCs in the water supplied by'the Ingalls Well.
Comment MEETING-43 Representative Gagliardi stated that,
"the agency knows that there are non-volatile organic
compounds at the site that will not be removed by air
stripping. The agency knows that because it has been
told so repeatedly by Department of Natural Resources and
the Public Health Department. Yet it continues to hide
behind its bureaucratic shield, and persistently insists
that its proposed remedy will work."
Response MEETING-43 Representative Gagliardi's statement
was quoted by Mr. Michael Italiano in a previous comment
and responded to above. See Comment/Response GOVERNMENT-
6.
Comment MEETING-44 Representative Gagliardi stated that
the U.S. EPA treated both the City of Petoskey and the
State of Michigan with disdain during all the discussions
concerning the Ingalls Well.
Response MEETING-44 U.S. EPA staff tried their best to
explain that much of what was asked of the Agency was
beyond the scope of the Agency's Superfund authorities.
As discussed above in Comment/Response MEETING-43, U.S.
EPA cannot eliminate all low-level contamination from the
City of Petoskey's drinking water supply. In addition,
59
-------
the U.S. EPA cannot correct existing construction
deficiencies at the Ingalls Well that are unrelated to
the Superfund Site. U.S. EPA hopes that, in the future,
all governmental units will be better able to understand
each other's authorities and limitations.
60
-------
U.S. EPA ADMINISTRATIVE RECORD
PETOSKEY MANUFACTURING COMPANY SITE
PETOSKEY, MICHIGAN
ORIGINAL
11/24/93
DOCI DATE AUTHOR
RECIPIENT
SiSSSSSSS
TITLE/DESCRIPTION
S3SSSSSSSSSSSSSSS
PAGES
1 09/00/91 Eder Associates . U.S. EPA
Consulting
Engineers, P.C.
2 10/00/92 KM Engineering I U.S. EPA
Science
3 08/00/93 HH Engineering i U.S. EPA
Science
Remedial Investigation/Feasibility Study 54
Horkplan
Baseline Risk Assessment for Ground Hater, . ' 117
Revised
Focused Feasibility Study
111
-------
GUIDANCE ADDENDUM TO THE U.S. EPA ADMINISTRATIVE RECORD
PETOSKEY MANUFACTURING COMPANY SITE
PETOSKEY, MICHIGAN
(Available for Review at U.S. EPA, Region V)
11/24/93
DOCI DATE AUTHOR
== = === =====
RECIPIENT
=========
TITLE/DESCRIPTION
================
PAGES
=====
1 00/00/00 OHEA
. U.S. EPA
2 06/16/86 Dept. of Health and U.S. EPA
Hutan Services/ATSDR
3 09/24/86 U.S. EPA
4 09/24/86 U.S. EPA
5 10/01/86 OSHER/QERR
6 10/01/88 OSHER/OERR
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
Integrated Risk Information System (IRIS) (A 0
Computer-Based Health Risk Intonation Syste-
i Available Through EHUil), Final
ATSDR Health Assessments on NPL Sites, Draft 14
Guidelines for Carcinogen Risk Assessment 13
(Federal Register, September 24, 1986, p.
33992), Final
Guidelines for the Health Risk Assessment of 13
Chemical Mixtures (Federal Register,
September 24, 1986, p. 34014), Final
Superfund Public Health Evaluation Manual, 500
Final,USHER Directive 19285.4-1
Guidance for Conducting Remedial . 390
Investigations and Feasibility Studies Under
CERCLA, Final, OSHER Directive 19355.3-01
-------
U.S. EPA ADMINISTRATIVE RECORD
PETOSKEY MANUFACTURING COMPANY SITE
PETOSKEY, MICHIGAN
UPDATE #1
O1/11/94
DOCI DflTE AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PACES
1 12/02/93 Constantine, S., U.S. EPA
Constantine
Reporting
Transcript of the December 2, 1993 Public
fleeting I Public Coiients Regarding the
Petoskey Municipal Hell Field Site
109
-------
U.S. EPA ADMINISTRATIVE RECORD
PETOSKEY MANUFACTURING COMPANY
PETOSKEY, MICHIGAN
UPDATE *2
08/25/94
Aft
DOCI DATE AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PA6ES
ssass
1 00/00/00 HcNaiee Industrial U.S. EPA
Services, Inc.
2 06/12/84 Adaikus, V., U.S. U.S. EPA
EPA
3 09/30/85 Adaikus, V.. U.S. U.S. EPA
EPA
4 06/29/89 Federal Reaister
5 12/00/90 U.S. EPA Public
6 07/00/91 U.S. EPA Public
7 09/16/93 State of Hichigan
8 01/00/94 City of Petoskey U.S. EPA
9 01/00/94 City of Petoskey U.S. EPA
10 01/00/94 City of Petoskey U.S. EPA
11 01/00/94 City of Petoskey U.S. EPA
12 01/00/94 City of Petoskey U.S. EPA
13 01/00/94 City of Petoskey U.S. EPA
14 01/00/94 NcNaiee Industrial U.S. EPA
Services, Inc.
City of Petoskey Mater Supply Study (Update) 123
Charlevoix Municipal Hell (HI) Record of 23
Decision for the Initial Reiedial Alternative
Selection
Charlevoix (HI) Record of Decision (Second 23
Reiedial Action)
Surface Hater Treatment Rule (40 CFR Parts 58
141 and 142)
Fact Sheet: Drinking Hater Regulations under 48
the Safe Drinking Hater Act
Quick Reference Fact Sheet: ARAR's Q's and 6
A's. Compliance nith Hen SDHA National
Priiary Drinking Hater Regulations (Phase II)
Safe Drinking Hater Act (Act 399, P.A. 1976 116
as Aiended)
Interii Response Couents 33
Interii Response Couents, Appendix I: Cost 40
Evaluation
Interii Response Couents, Appendix II: 121
Correspondence Record
Interii Response CoMents, Appendix III: 21
6roundnater Suitary Data
Interii Response Cements, Appendix IV: Data 133
froi Eder RI Report
Interii Response Couents, Appendix V:
Figures froi Eder RI Report
Miscellaneous Table: SuMary of Contaiinants
Detected in the firoundnater in the Aquifer
(1992-1993)
11
-------
DOCI DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
==== !=== ====== ========= ================ =====
IS 01/00/94 nDNR U.S. EPA RI Data (See: Interii Response Comments, 133
Appendix IV)
16 01/14/94 O'Brien, 8., NDNR Killer, R., Petoskey Letter Forwarding RI Data to be Placed in the IS
Public Library in.fonation Repository w/Attachients
17 01/26/94 Gabin, I., Michigan Van Donsel,. T., U.S. Letter re: HDPH's Couents on the RI Data and 8
Department of Public EPA the Proposed Air Stripping Design
Health w/fittachments
18 01/27/94 Holchan. 6., NcNaiee Novak, 0., U.S. EPA FAX Transiittal Forwarding Public Comments on 4
Industrial Services, the Interim Response '
Inc.
19 01/28/94 Holchan, 6., HcNamee Novak, D., U.S. EPA Letter Forwarding Additional Letters to be 7
Industrial Services. Added to the Public Record (Gabin Letter of
Inc. 01/26/94: Engler Letter of 01/28/94)
20 01/28/94 Baugnian, A., Tip of Novak, D., U.S. EPA Letter re: Couents on the Proposed Cleanup 3
the Hitt Watershed Plan
Council
21 01/28/94 Engler, J., Office Adaikus, V., U.S. Letter re: Deceiber 1993 Proposed Plan and 2
of the Governor EPA - : Requesting U.S. EPA Meet with HDNR and HDPH
to Develop a Reiedy and a Record of Decision
22 01/28/94 Bradford, H., HDNR Novak, D., U.S. EPA Letter re: HDNR's Comments on the Proposed 3
Interim Remedy
23 02/02/94 Gabin, I., Hichigan Van Donsel, T., U.S. Fax Transiittal re: Hater Supply Evaluation 5
Department of Public EPA w/Attachients
Health
24 02/04/94 U.S. EPA U.S. EPA . NERA Operational Memorandum 18, Revision 3 IB
25 02/08/94 O'Brien, B.. HDNR Van Donsel, T., U.S. .fAI Transiittal re: Suuary Sheet of the 2
EPA . October 1993 Groundwater Pesticide Data
: : : Detected in the Monitor Hells
26 02/16/94 Adamkus, V., U.S. Engler, J., Office Letter re: Proposed Interii Reiedial Action 2
EPA of the Governor
27 03/14/94 Engler, J., Office Adaikus, V., U.S. Response to U.S. EPA's February 16, 1994 2
of the Governor EPA Letter re: Proposed Reiedial Action
28 03/15/94 Washington, T., Adaikus, V., U.S. Letter re: Site Cleanup and Public Disclosure 1
Hichigan United EPA of Information
Conservation Clubs
-------
DOCI DATE AUTHOR .. RECIPIEKf TITLE/DESCRIPTION PASES
29 03/22/94 Sruennald, 6., Tip . Adamkus, V., U.S. Position Statement re: Proposed Cleanup of 6
of the Mitt EPA the Contaminated Drinking Hater Hell a/Cover
Watershed Council Letter and Attachient
30 04/29/94 Van Donsel, T., U.S. Hashington, T., Letter Responding to March 15, 1994 Letter 3
EPA Michigan United re: Site Cleanup and Public Disclosure of
Conservation Clubs Intonation
31 05/00/94 U.S. EPA Drinking Hater Regulations and Health 13
Advisories
32 06/15/94 Nolchan, 6., HcNaiee Van Donsel, T., U.S. FAK Transiittal re: Boring Logs . 5
industrial Services, EPA
Inc.
33 06/15/94 Engler. Jj., Office Bronner, C., U.S. Letter re: Request for U.S. EPA's Approval of 2
of the Governor EPA Michigan's Application to Redesignate the
Southeastern Region as an Attainment Area for
Federal Ozone Standards (Includes Discussion
of Petoskey Municipal Hell Field)
34 08/09/94 Deny*. C. Cleland, J., Letter re: NDPH's Issuance of a Ground Hater 1
Michigan Department Under the Influence of Surface Hater
: . . of Public Health Determination (UNSIGNED)
35 OB/24/94 Earth Tech U.S. EPA Revised Cost Estimates for FFS Alternatives 13
-------
U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
PETOSKEY MUNICIPAL WELL FIELD SITE
PETOSKEY, MICHIGAN
. UPDATE t3
03/24/93
DOCI DATE
AUTHOR
sssssa
RECIPIENT
ssssmass:
TITLE/DESCRIPTION
PAKS
1 10/03/94
Ende, L. and Kouris,
T., Ecology and
Environment, Inc.
Nabasny, 6., U.S.
EPA
Litttr rt: Colliction of Thrtt Hunicipal toll
Hater Saiplit and Oni Blank Hater Saiple froi
the Ingalls Road toll n/Attachtd Analytical
Data .
2 03/03/95
Graczyk, L., Ecology
and Environient,
Inc.
3 03/13/95 Hatt, F., HOPH
4 03/31/95
Engler, J., State of
Michigan/Office of
the Governor ; .
Nabasny, 6., U.S.
EPA
Harding, R., HDHR
Browner, C., U.S.
EPA
5 04/21/95 Earth Tec
U.S. EPA
b 05/04/95 Browner, C., U.S.
EPA
.Engler, J., State of
Michigan/Office of
the Governor
Letter re: Collection of Six Hunicipal toll
Hater Staples froi the logalls Road toll
N/Attached Analytical Data
Heeorandui re: HOPH'i Cotstntf on the U.S.
EPA Draft Record of Decition
Letter ret Cleanip of Hanittique River and
Harbor Site and the City of Petnkey Hater
Supply a/Attached Governor's Letter of
February 10, 1999 Concerning Status of
Cleanup Activities
Capital Costs, Annual Operating Costs, and
NPV Calculation for Alternative Four
(Treatment of Grounduter Using Air
Stripping) and Alternative Five (Treatment of
Groundnater Using 6AC Adsorption)
Letter res Cleanup of Nanistique River and
Harbor Sitt and Drinking toter at the
Petoskey toll Field Site ii/Attached Detailed
Discussion of Points Raised in the Governor's
March 31, 1993 Letter to U.S. EPA
47
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE: August 8, 1995
SUBJECT: Petoskey Municipal Well Field
Misplaced Comment on Interim Action RQ
PROM: Terese A. Van Donsel
OSF, Section 4
VX ,
, RPM .^-^1/1 \/
' I js^^T^ y*
TO: James Morris, Attorney
SWERB, Section 4
On the morning of Friday, August 4, 1995, I was
reviewing and sorting my Petoskey file, document by
document. My goal was to reorganize the site file
and remove draft ROD documents that are no longer
necessary now that the interim action ROD has been
signed. During the review of the documents in the
site file, I found a one-page public comment form
submitted by Mr. Michael Olson of the Petoskey
Manufacturing Company. The comment form was found in
a file containing inter-agency correspondence.
The comment form is not dated, but was stamped by the
post office on December 3, 1993. The document
appears to be a copy of an original. The comment was
addressed to Mr. Dave Novak in the Office of Public
Affairs.
I was provided the files of Mr. David Linnear when I
took over the project in early 1994. When I took the
site file, the public comments were grouped together.
I do not recall seeing the comment from Mr. Olson. I
believe that I would have remembered seeing the
comment since it was submitted by the President of
the Petoskey Manufacturing Company, the facility that
has been identified as being the source of the well
field contamination.
When I was preparing the Responsiveness Summary I
looked through the file to verify that I had all
comments. Unfortunately, I did not find the comment
page submitted by Mr. Olson. When and how the
comment ended up in an inter-agency correspondence
file is unknown.
Mr. Olson's comments and agency responses are
presented in the attached comment/response document.
Mr. Olson's comments do not present any information
-------
that would require modification of the Agency's
selected remedy. If you need any additional
information, please contact me at 3-6564.
Attachment
cc: Administrative Record
Site Pile
-------
Use This Space to Write Your Comments
Your input on the proposed plan for the Petoskey Municipal Well Field Superfund Site is important to
U.S. EPA. Comments provided by the public are valuable in helping us select a cleanup plan for the
site.
You may use the space below to write your comments. When finished, please fold, stamp, and mail
this page. Comments must be postmarked by January 29, 1994. If you have questions about the
comments period, please contact Dave Novak at (312) 886-9840 or through U.S. EPA's toll free
number: 1-800-621-8431 (M-F 9:00 a.m. to 4:30 p.m.).
To whom this may concern: I an the President of Petoskey Mfg. Co. I attended
vour December 2, 1993 Public Hearing at the Petoskey High School. I was not
impressed with the solution to use an air stripper. I feel Petoskey Mfg. Co.
has gone beyond the limit of what is normal clean-up. Before any further clean-up
procedures should be adopted I feel we should move in an easiest to hardest direction.
Currently, the city well is not.a health hazard to the People of Petoskey. Why
wouldn't, it be prudent to continue monitoring the levels. Until such time
that it would be necessary to begin a new direction, the monitoring levels
should be over the E.P.A. limi t. I doubt that they would ever get over the E.P.A.
limit. I feel Petoskey Mfg. CO. is being made the SCAPEGOAT with this matter.
The city well is outdated and under capacity. I don't feel that it is the E.P.A. 's
responsibility to buy Petoskey a Surface Water Treatment Plant. Petoskey is looking
at the E.P.A. as the one with deep pockets to fill their needs that they shou Id
have been planning for for several years. He are a small company trying to survive
In a very political fish bowl.. I urge E.P.A. NOT to succomb to the political
pressures and proceed in a responsible manner and move in an easiest to hardest
process.
I have no comment, but Name: Michael E. Olson
please add me to your
mailing list for the Affiliation (if any): Petoskey Mfg. Co.
Petoskey Municipal Well _ . _ _
Field Superfimd Site. Address: P.O. Box G.
City: Petoskey, MI.
State: Michigan Zip: 49770
-------
PUBLIC COMMENTS
FROM
MR. MICHAEL E. OLSON
PETOSKEY MANUFACTURING COMPANY
Comment
Mr. Olson stated that the Environmental Protection Agency
(EPA) should continue to monitor contaminant levels in the
Ingalls Well instead of undertaking a clean-up. He
further states that he doubts contaminant levels would
exceed EPA limits.
Response
Chemical contaminants found in water from the Ingalls Well
tap are below EPA's Maximum Contaminant Levels (MCLs) .
The contaminant of greatest concern, Trichloroethylene
(TCE), has been found in the Ingalls Well tap at between 2
to 4 parts per billion (ppb) , below the MCL of 5 ppb.
However, relatively high concentrations of TCE have been
seen in wells near the Ingalls Well (see Comment/Response
GOVERNMENT-8 in the Responsiveness Summary). Because of
the uncertainties associated with environmental monitoring
and groundwater behavior, EPA has determined that
contaminants could exceed MCLs (see Comment/Response
GOVERNMENT-5 and Comment /Response GOVERNMENT-12 in the
Responsiveness Summary). EPA has therefore determined
that treatment at the Ingalls Well is necessary.
Comment
Mr. Olson states that the City's well is outdated and
under capacity. He notes that the City of Petoskey "is
looking at the EPA as the one with deep pockets to fill
their needs that they should have been planning for
several years."
Response
EPA agrees that the Ingalls Well is outdated and that the
City of Petoskey is likely in need of additional capacity.
EPA also agrees that it cannot use federal funds to
correct existing deficiencies at the Ingalls Well.
However, EPA has determined that there is a need to treat
the water at the Ingalls Well to ensure that contaminant
concentrations remain below MCLs. EPA has further
determined that the State may elect to "enhance" EPA's
selected remedy and use the funds towards replacing the
Ingalls Well. See also Comment/Response GOVERNMENT-?,
PUBLIC-3, MEETING-13).
Page 1 of 1
-------
COMMIftttON
JOHN ENGIER Covtmor
DEPARTMENT OF NATURAL RESOURCES
JAWS PHI STEVENS T MASON BWIWWJ. PO BOX S«M. lANWHO Ml « W09 >»«
- nouwo HAXMES
June 6. 1995
Mr. Valdas V Adamkus, R-19J
Administrator, Region 5
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago, Illinois 60604-3590
Dear Mr. Adamkus:
The Michigan Department of Natural Resources (MDNR). on behalf of the State
of Michigan, has reviewed the Record of Decision (ROD) for the Petoskey
Manufacturing Supertund site interim action (IA) for the Ingalls Avenue Municipal
Wall, and the proposed remedy contained in that ROD. Michigan concurs with
the IA remedy proposed in the ROD consisting of:
On-line treatment of groundwater from the Ingalls Avenue Municipal Well
through the use of air stripping with the use of carbon treatment as a
contingency in the event that, within 18 months of the signature of the
ROD, site-related semi-volatile contaminants exceed maximum
contaminant levels in the Ingalls well tap.
The state elects the cost-equivalency option as an alternative to the
implementation of the proposed remedy. The state will be entering into an
agreement with the City of Petoskey whereby they will agree to:
A. Design and implement the cost-equivalency option.
B Pay all additional costs associated with the design, construction
and operation and maintenance of such an alternate water
treatment system beyond the $500,000 already allocated by the
MDNR to the City of Petoskey for development of an alternate
water supply.
C. Agree not to hold the State of Michigan responsible for payment of
any additional funds associated with the alternate water treatment
plant beyond the $500,000 already allocated.
• 10M
UV02W
-------
Mr. Valdas V. Adamkus
Page 2
June 6, 1995
The EPA needs to provide the state of Michigan with an explanation of the
appropriate mechanism to transfer funds from the EPA to the state of Michigan
and identify the responsibilities associated with "...assuming] the lead for
supervising the design and construction of the new drinking water source
pursuant to the NCP at 40 § 300.515(f)(1)(ii)(B).M
We look forward to working together to accomplish this IA remedy at this site.
If you have further questions, please contact Mr. William Bradford, Chief,
Superfuhd Section, Environmental Response Division, at 517-373-8815. or you
may contact me.
Sincerely,
Russell J. Harding
Deputy Director
517-373-7917
cc: Mr. James Mayka, EPA
Ms. Karla Johnson, EPA
Ms. Terese Van Donsel, EPA
Mr. Chad Mclntosh, Governor's Office
Mr. Jeremy Firestone, MDAG
Mr. Alan J. Howard, MDNR
Mr. William Bradford, MONR
------- |