United States
Environmental Proection
Agency
Share your opinions
EPA invites you to participate in the
cleanup process at the Former Scott
Fetzer Facility, North Bronson site.
Your input helps EPA determine
the best course of action. Please
attend a public meeting at 6:30 p.m.,
Tuesday, July 21, at the Bronson
City Offices, 141 S. Matteson St.
A comment period has been set
up to provide you an opportunity
to share your comments on the
site cleanup. Comments should be
submitted from July 9 to Aug. 10,
2009:
• Orally at the public meeting or
in writing.
• Via the web at www.epa.
gov/region5/publiccomment/
bronson-pubcomment.htm.
• Fax to James Hahnenberg at
312-385-5476.
Contact EPA
James Hahnenberg
EPA Remedial Project Manager
312-353-4213
hahnenberg.james@epa.gov
Dave Novak
EPA Community Involvement
Coordinator
312-886-7478
novak.dave@epa.gov
Call EPA Region 5 toll-free
800-621-8431
9:30 a.m. to 5:30 p.m., weekdays
Review site documents
EPA's proposed cleanup plan along
with other documents about this
site can be reviewed at the Bronson
Branch Public Library, 207 N.
Matteson St.
Cleanup Plan Proposed For
Soil and Underground Water
Former Scott Fetzer Facility, North Bronson Superfund Site
Bronson, Michigan July 2009
In order to clean up the former Scott Fetzer section of the North Bronson
Former Facilities Superfund site, U.S. Environmental Protection Agency
is proposing digging up some of the contaminated soil and subsurface
structures along with constructing a treatment system to remove
contaminants remaining in the soil and underground water supplies.
Additionally, if the proposed cleanup plan is approved, an extraction system
will pump and treat contaminated underground water (called ground water in
environmental terms).
Complex cleanup sites such as North Bronson are divided into smaller parts
called "operable units" or OUs. The Scott Fetzer properties are known as
Operable Unit 3. The proposed cleanup plan is designed to reduce pollutant
levels at two properties at the site: Former Plant #1, consisting of 21A
acres, where the proposal calls for cleanup of pollutant levels to industrial
standards; and the second property, known as the former Annex/CDF, just
south of Plant #1 covering .8 acres, where contamination levels would be
cleaned up using residential standards. The two properties at the site are
currently vacant and surrounded by fences.
The contaminants of chief concern on both properties are a class of chemicals
known as volatile organic compounds or VOCs. VOCs dissolve in water
and may release harmful vapors. The main VOCs at this site are hazardous
substances called trichloroethylene or trichloroethene, also known as TCE;
cis-l-2-DCE; and PCE. During more than seven decades of industrial
activities VOCs and metals contaminated nearly 6,000 cubic yards of soil on
the site at concentrations requiring cleanup. In addition, the pollutants soaked
into the earth and contaminated the ground water. The TCE and VOC levels
in ground water near the site make it unsafe for drinking.
Responsibility for cleanup
Even though the site is now owned by the state of Michigan, EPA considers
the Scott Fetzer Co. legally responsible for the cleanup. The company paid
for an environmental consultant to conduct a major pollution investigation
on the property. The consultant issued two reports to summarize the work.
The "remedial investigation" details the types, quantities and hazards of the
pollutants on the site, while the "feasibility study" identifies and evaluates
possible cleanup options for the property. Both reports are available for
review at the Bronson Branch Public Library.'
The Scott Fetzer consultant came up with five options for reducing the
amount of contaminated soil on the site and six alternatives for cleaning up
1 Section 117 (a) of the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA, known as the Superfund law) and Section 300.430(0 (2) of the National Oil and
Hazardous Substances Pollution Contingency Plan require the public be given an opportunity
to participate in the process of approving a proposed cleanup plan. This fact sheet summarizes
technical documents about the soil and ground -water cleanup that are available for viewing at
the official site repository located in the Bronson Branch Public Library.
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contaminated ground water. The alternatives are described
in more detail later in this fact sheet. EPA has examined
the costs and effectiveness of the soil and ground water
cleanup alternatives and in this proposed plan fact sheet is
now announcing the Agency's recommended cleanup plan.
The plan is not yet final. The public will have until
Aug. 10. 2009. to comment on the proposals and EPA's
alternatives. The proposed plan could change based on
input from the public. Read the front-page box to find out
how you can participate in the process. EPA will hold a
public meeting on July 21. 2009, to discuss the cleanup
plan and hear questions and comments. Following the
comment period and public meeting. EPA will release its
final decision in a document called a "record of decision"
or ROD. which will also include a response by EPA to all
comments.
VOCs such as TCE and some metal contaminants in
the ground water and soil are a potential health threat
because the chemicals make the water unsafe to drink.The
pollution also presents potential risks from skin contact
with or incidental swallowing of the soil. The most heavily
contaminated ground water can also release VOC vapors
that rise through the soil where they can seep into the
foundations of homes and buildings causing hazardous
indoor air pollution. This problem is called vapor intrusion.
The health study concluded if people were to be regularly
exposed to the soil and ground water contamination on
the Fetzer site over a lifetime, health risk estimates would
exceed EPA's and Michigan's allowable standards. That
means the area must be cleaned up.
Based on environmental studies previously conducted for
two other nearby North Bronson Former Facilities areas
- L.A. Darling and Bronson Reel - contamination at the
former Fetzer facility is not believed to present significant
health risks to wildlife.
About the
The two properties that comprise the Fetzer site, located in
the North Bronson Industrial Area, are approximately 3.3
acres in total size. The surface of the property is vacant,
except for some minor substructures. The Scott Fetzer Co.
and its predecessors manufactured automobile electrical
parts, military and consumer products, appliance timers
and vacuum cleaners from 1910 to 1987. Pollutants came
from manufacturing operations that included chromium,
cadmium plating, silver, tin and zinc.
EPA. the state of Michigan and Scott Fetzer conducted
initial environmental investigations and cleanups from
1992 to 1995 dealing with the most dangerous toxic
waste at the site as well as physical hazards. The property
reverted to the state due to a tax delinquency in 1995.
Michigan then conducted additional cleanup activities
including demolishing buildings and removing some
contaminated soil.
Scott Fetzer Co. entered into a legal agreement called
an administrative order by consent with EPA in 2002
to conduct the remedial investigation and feasibility
study. EPA has now approved these studies as the basis
of this proposed cleanup plan. As a follow-up to this
investigation, Scott Fetzer will conduct additional soil
sampling around the Annex/CDF area. This will more fully
survey the contamination in this area to allow a better, final
cleanup plan.
If not cleaned up, the contamination in the ground water
can travel off-site and cause vapor intrusion problems and
continue to prevent the use of ground water for drinking.
Hazardous chemicals found at the site include
trichloroethylene, tetrachloroethylene, cis-1-2-
dichlorocthylcnc, 1,1-dichlorocthylcnc, trans-1-2-
dichloroethylene, vinyl chloride and cyanide. Some
metals were also detected and will be dealt with as part
of the selected cleanup plan. EPA has been monitoring
properties near the former Scott Fetzer property and the
adjacent L.A. Darling site. EPA has also identified several
homes affected by vapor intrusion. Vapor intrusion issues
are not included in this cleanup plan and are being handled
in a separate action. If EPA identifies any other homes with
elevated levels of indoor vapors, the Agency will work
with the homeowner to develop a customized cleanup plan
for their property at no cost to them.
The cleanup objectives for the site are to reduce chemical
levels in the soil and vapors to concentrations acceptable
for future industrial redevelopment of the former Plant #1
area, and residential use of the former Annex/CDF parcel.
The goal for ground water is to stop contaminated water
from moving beyond the property boundary and to clean
it to a level that is safe for drinking and other uses. The
ground water cleanup will be a temporary fix because a
more comprehensive plan will be implemented later to
deal with contamination from other sources.
The Scott Fetzer Co. evaluated five cleanup alternatives
for contaminated soil and six options for ground water.
EPA, in consultation with Michigan Department of
Environmental Quality, evaluated each of the 11 cleanup
alternatives against nine criteria required by law and then
picked its recommended options (see explanation of nine
criteria P. 6). The 11 alternatives are summarized below,
but full details are available in the feasibility study on file
in the Bronson Branch Public Library. All cost figures
include operation and maintenance expenses and are given
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in a financial calculation called "present worth" expressed
in terms of today's dollars.
Soil cleanup options
Soil Alternative SO-1 - No Action. A no-action
alternative is always included in a cleanup analysis as a
point of comparison. Cost: $0
Soil Alternative SO-2 - Institutional controls. In this
alternative potential for human exposures will be reduced
by modifications to the property deed. Surveys will be
done in areas where institutional controls will be applied.
Cost: $385,000
Soil Alternative SO-3 - Excavation and off-site
disposal. Under this alternative:
Some 5,850 cubic yards of contaminated
soil and sediment (mud) in sewers would
be removed and transported to an off-site
licensed hazardous waste landfill.
• Clean fill will be brought in to bring the
property elevation back to existing grade.
Temporary fencing would be installed during
the cleanup work to protect the public.
Cost: $1.4 million
Soil Alternative SO-4 -Air sparging/soil vapor
extraction and limited excavation (EPA's recommended
soil alternative). Under this alternative:
Soil would be excavated from one area where
cadmium exceeded cleanup standards and from
several high-concentration VOC source areas.
About 1,575 cubic yards of affected soil from
Plant #1, the Annex/CDF, and the industrial sewer
Soil cleanup alternatives
pipe would be excavated and disposed of at an off-
site commercial facility.
Additional contaminants would be extracted from
soil by installing an estimated 33 soil air sparging/
vapor extraction wells at the Plate #1 and Annex/
CDF areas. Air sparging wells would pump air
through the ground water and soil to convert
pollutants to vapor. The vapors are then captured
and treated by vapor extraction wells. The exact
number of wells needed would be determined
during the design phase.
• Institutional controls would be implemented such
as deed restrictions, covenants and city ordinances.
• Temporary fencing would be installed during the
cleanup work to protect the public.
Cost: $2.3 million
Soil Alternative SO-5 - In-situ chemical oxidation and
limited excavation. Under this alternative:
• In-situ (in-place) chemical oxidation would be
used to neutralize VOC-contaminated soil and
meet the cleanup standards. The chemical oxidant
would be delivered to underground soil by
mechanical mixing using excavators.
Limited excavation would be conducted in specific
areas where the cadmium cleanup standards are
exceeded.
• The industrial sewer pipe would be excavated and
disposed of at an off-site facility.
• Institutional controls would be implemented such
as deed restrictions, covenants and city ordinances.
• Temporary fencing would be installed during the
cleanup work to protect the public.
Cost: $1.5 million
Evaluation Criteria
Overall Protection of Human Health
and the Environment
Compliance with Applicable
or Relevant and Appropriate
Requirements
Long-Term Effectiveness and
Permanence
Reduction of Toxicity, Mobility or
Volume through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
SO-1
O
O
O
O
O
O
$0
O
SO-2
O
O
O
O
•
•
$385,000
O
SO-3
•
•
•
O
•
•
$1.4 million
•
SO-4
•
•
•
•
•
•
$2.3 million
O
SO-5
•
•
•
•
•
•
$1.5 million
O
To be determined after comment period
O Does not meet criteria O Partially meets criteria • Fully meets criteria
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Ground water cleanup options
Ground Water Alternative GW-1 - No Action. A no
action alternative is used as a comparison point.
Cost: $0
Ground Water Alternative GW-2 - Institutional
controls. In this alternative potential for human exposure
to the pollution will be reduced by restricting ground water
use at the North Branson site through modifications to the
property deed or a city ordinance. Cost: $385,000
Ground Water Alternative GW-3 - In-situ chemical
oxidation, funnel-and-gate and institutional controls.
Under this alternative:
• In-situ chemical oxidation would reduce VOC
mass in ground water source areas at Plant #1,
Annex/CDF, and the industrial sewer.
* A funnel-and-gate system would be installed to
prevent off-site movement of contaminated ground
water from the Fetzer property. The underground
funnel-like barrier directs ground water to a
zone that filters and cleans the water as it passes
through.
* Institutional controls would restrict ground water
use at the site, similar to GW-2.
It is anticipated the ground water system would need to run
for many years. Fencing would be required during on-site
activities followed by long-term monitoring of the ground
water. Ground water usage would be restricted until water
is safe to use. Cost: $3.5 million
Ground Water Alternative GW-4 -Air sparging/vapor
extraction, funnel-and-gate, and institutional controls.
Under this alternative:
• Air sparging/vapor extraction would remove
source area VOC mass in ground water at Plant
#1, Annex/CDF, and the industrial sewer.
* A funnel-and-gate system, identical to Alternative
GW-3, would prevent off-site movement of
contaminated ground water from the Fetzer
property.
• Institutional controls, similar to GW-2, would
restrict ground water use at the site.
It is anticipated the ground water system would need to run
initially for around five years. After this first phase of air
sparging/vapor extraction, evaluation of the ground water
contaminant concentrations would determine if additional
air sparging is necessary or effective. Fencing would be
required during on-site activities followed by long-term
monitoring of the ground water. Ground water usage
would be restricted until water is safe to use.
Cost: $5.1 million
Ground Water Alternative GW-5 - Air sparging/vapor
extraction, pump-and-treat, and institutional controls
(this is EPA's recommended ground water alternative).
Under this alternative:
• Air sparging/vapor extraction would remove the
source area VOC mass in ground water at Plant
#1. Annex/CD and the industrial sewer area.
• Ground water extraction wells and treatment by
air stripping would prevent off-site movement
of contaminated ground water from the Fetzer
property.
Institutional controls, similar to GW-2, would
restrict ground water use at the site.
It is anticipated the ground water extraction/treatment
system would need to run for many years. Fencing would
be required during on-site activities followed by long-
term monitoring of the ground water. Ground water usage
would be restricted until water is safe to use.
Cost: $4 million
Ground Water Alternative GW-6 - Pump-and-treat
and institutional controls. Under this alternative
* Ground water extraction wells would pump and
treat VOCs in an air stripping treatment system
and contain the movement of on-site ground water.
Institutional controls, similar to GW-2, would
restrict ground water use at the site until cleanup
standards were met.
Cost: $2.8 million
Of
EPA evaluated the cleanup options by comparing them
with the nine criteria required by federal law. A chart
showing the results of the soil alternative evaluation is
on P. 3. A chart showing the results of the ground water
alternative evaluation is on P. 5. The Agency determined
the no action alternatives for contaminated soil and ground
water would not protect people or the environment so they
were eliminated from consideration. Of the remaining
cleanup options, EPA selected Soil Alternative SO-4 and
Ground Water Alternative GW-5 as the best combination
of cleanup actions. Under Soil Alternative SO-4, a limited
area of soil would be removed, allowing for commercial,
industrial or recreational redevelopment of the property.
Ground Water Alternative GW-5 would provide for
treatment of contaminated ground water and would restrict
the movement of contaminated ground water beyond the
Fetzer property.
EPA recommends Soil Alternative SO-4 because
limited excavation of the remaining contaminated
soil, followed by air sparging/soil vapor extraction to
remove contaminants from soil above the water table,
and in combination with the ground water alternative,
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Ground water cleanup alternatives
Evaluation Criteria
Overall Protection of Human
Health and the Environment
Compliance with Applicable
or Relevant and Appropriate
Requirements
Long-Term Effectiveness and
Permanence
Reduction of Toxicity, Mobility,
or Volume through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
GW-1
O
o
O
o
o
o
$0
o
GW-2
O
O
o
o
•
•
$385,000
O
GW-3
•
•
•
•
•
•
$3.5 million
O
GW-4
•
•
•
•
•
•
$5.1 million
O
GW-5
•
•
•
•
•
•
$4 million*
•
GW-6
•
•
•
•
•
•
$2.8 million
O
To be determined after comment period
O Does not meet criteria O Partially meets criteria • Fully meets criteria
* The GW-5 alternative, in combination with SO-4 would result in combined costs of $1.8 million less
than each remedy as stand-alone alternatives. This is due to sharing of common operational elements.
would protect people, and be cost-effective and easily
implemented. Soil alternative SO-2 would be protective
for direct contact with contaminants but would limit use
of the property as contaminants would continue to affect
ground water. Soil Alternative SO-3 and SO-5 would deal
with soil contamination but overall are not as cost-effective
as the recommended alternative. Additionally, SO-5 would
be more difficult to implement and would more likely
experience cost increases.
Ground Water Alternative GW-5 in combination with Soil
Alternative SO-4 is cost-effective and uses a combination
of proven technologies to address various types of
contamination present in the ground water at the site.
Air sparging and soil vapor extraction would remove a
significant amount of VOCs from the ground water and the
soil below the water table. The air sparge/vapor extraction
system would operate for about five years, with remaining
contaminated ground water removed and treated.
Alternative GW-2 would protect people for immediate
exposures, but would not prevent off-site movement of
contaminants. Alternative GW-5 is also more cost-effective
than Alternatives GW-3 and GW-6. This is due to cost
efficiencies for the SO-4 and GW-5 combination that
would result in a total soil and ground water plan costing
$4.5 million. The combined SO-4 and GW-5 alternative
saves $1.8 million versus each option as a stand-alone
plan. Additionally, GW-5 is more reliably implementable
than GW-3 and GW-6, with less risk of cost increases.
Next steps
EPA, in consultation with MDEQ, will evaluate public
reaction to the preferred cleanup plans during the comment
period and at the public meeting before deciding on a final
choice. Based on new information or public comments,
EPA may modify its proposed option or select another of
the cleanup alternatives outlined in this fact sheet. EPA
encourages you to review and comment on the cleanup
alternatives. More detail on the cleanup alternatives is
available in the official documents on file at the Bronson
Branch Library.
EPA will respond to the comments in a responsiveness
summary, which will be part of the record of decision. The
ROD will describe the final cleanup plan selected for the
site. EPA will announce the selected cleanup plan in a local
newspaper and will place a copy of the ROD on file in the
information repository at the Bronson Branch Library.
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Evaluation criteria
EPA compares each cleanup option or alternative with these nine criteria established by federal law.
1. Overall protection of human health and the environment examines whether an option
protects both human health and the environment. This standard can be met by reducing or
removing pollution or by reducing exposure to it.
2. Compliance with applicable or relevant and appropriate requirements (ARARs) ensures
options comply with federal, state and local laws.
3. Long-term effectiveness and permanence evaluates how well an option will work in the long
term, including how safely remaining contaminants can be managed.
4. Reduction of toxicity, mobility or volume through treatment determines how well the
option reduces the toxicity (the chemical makeup of a contaminant that makes it dangerous),
movement and amount of contaminants.
5. Short-term effectiveness compares how quickly an option can help the situation and how
much risk exists while the option is under construction.
6. Implementability evaluates how feasible the option is and whether materials and services are
available in the area.
7. Cost includes estimated capital or startup costs, such as the cost of buildings, treatment
systems and monitoring wells. The criterion also considers costs to implement the plan, and
operate and maintain it over time. Examples include laboratory analysis and personnel to
operate equipment.
8. State acceptance determines whether the state environmental agency (in this case MDEQ)
accepts the option. EPA evaluates this criterion after receiving public comments.
9. Community acceptance considers the opinions of nearby residents and other stakeholders
about the proposed cleanup plan. EPA evaluates this standard after a public hearing and
comment period.
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SOUND PROOF AIR
EXTRACTION AND
TREATMENT BLDG
EXCAVATE SO LTt-Wfli
EXCEEDS PRG FOR CADMI
SCALE IN FEET
LEGEND
INDUSTRIAL SEWER
PROPERTY BOUNDARY
HISTORICAL SITE FEATURE
PROPOSED LOCATION OF DUAL
AIR SPARGE/SVE WELL
PROPOSED LOCATION
OF SVE WELL
GROUNDWATER EXTRATION WELL
SCALE: AS SHOWN
AREAS THAT EXCEED THE PRELIMINARY
REMEDIATION GOAL (PRG) FOR VOCs IN
GROUNDWATER
AREAS THAT EXCEED THE PRELIMINARY
REMEDIATION GOAL (PRG) FOR VOCs
IN SOIL
AREAS THAT EXCEED THE PRELIMINARY
REMEDIATION GOAL (PRG) FOR CADMIUM
IN SOIL
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EPA Proposes
Cleanup Plan for
Soil and
Underground Water
Former Scott Fetzer Facility
North Bronson
Superfund Site
(details inside)
Upcoming Public Meeting
Tuesday, July 21
7 p.m.
Bronson City Offices
141 S. Matteson St.
At the meeting, EPA will explain the proposed plan
and provide opportunities to ask questions and
make oral comments. You may also submit written
comments. If you need special accommodations for
the meeting contact Dave Novak by Tuesday,
July 21. His contact information is on P. 1.
On the Web
Site information is also posted on the web at:
www.epa.gov/region5/sites/bronson
To comment electronically:
www.epa.gov/region5/publiccomment/bronson-
pubcomment.htm
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