Second Five-Year Review Report For Cannelton Industries ... · Sault Ste. Marie, Michigan. This review was conducted for the entire Site from October 2008 through August 2009. This

EPA Region 5 Records Ctr

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335947

Five-Year Review Report

Second Five-Year Review Report

For Cannelton Industries Inc Site

Sault Ste Marie Chippewa County Michigan

August 2009

PREPARED BY US Environmental Protection Agency

Region 5 Chicago Illinois

Approved by Date

_~(l JltL Richard C Karl Director Superfund Division

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Table of Contents

List of Acron)llls 5

Executive Summary 7

Five-Year Review Summary Fonn 9

I Introductionbullbull 11

II Site Chronology 12

III Background bullbullbullbullbull 13 Physical Characteristics 13 Land and Resource Use 14 History of Contamination 15 Initial Response 16 Basis for Taking Action 17

IV Remedial Actions 18 Remedy Selection 18 Remedy Implementation 19 GLNPO Legacy Act Dredging Project 22 Institutional Controls 23 Operation and Maintenance (OampM) 24 Reuse and Redevelopment 27

V Progress Since the Last Five-Year Review bullbull 28

VI Five-Year Review Process 28 Administrative Components 28 Community Notification and Involvement 28 Document Review 28 Data Review 29 Site Inspection 29

VII Technical Assessment bullbullbullbullbullbullbullbullbullbull 29

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives

Question C Has any other infonnation come to light that could call into question

Question A Is the remedy functioning as intended by the decision documents 29

used at the time of the remedy selection still valid 30

the protectiveness of the remedy 30 Technical Assessment Summary 30

VIII Issues bullbullbullbullbull 30

IX Recommendations and Follow-up Actions bullbullbullbullbullbullbullbull 31 X Protectiveness Statement(s) bull 31 XI Next Review bullbull 31

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Figures

Figure 1 Figure 2 Figure 3 Figure 4

Appendices

Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F

Site Location Site Plan Overview Tannery Plant and Discharge and General Waste Dumping Areas Final Dredge Limits for GLNPO Legacy Act Dredge Project

List of Documents Reviewed Photos Documenting GLNPO Legacy Act Dredging Project Field Memorandum- JuneJuly 2006 (4th

) Sampling Event Field Memorandum - AugustOctober 2008 Sampling Event Site Photos Documenting Site Conditions Site Inspection Checklist

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AOC AWQC CERCLA CFR City COCs CRA EPA ERT FS GLNPO ICs ICIAP MCLs MDEQ mgkg NCP ngfL NOAA NPDES NPL OampM PCOR PRPs RCRA RI RIfFS ROD Site SOW SRD UAO IlgfL US EPA USGS UUIUE

List of Acronyms

Administrative Order on Consent Ambient water quality criteria Comprehensive Environmental Response Compensation and Liability Act Code of Federal Regulations City of Sault Ste Marie Michigan contaminants of concern Conestoga-Rovers amp Associates Environmental Protection Agency Environmental Response Team Feasibility Study Great Lakes National Program Office Institutional Controls Institutional Control Implementation and Action Plan Maximum Contaminant Levels Michigan Department of Environmental Quality milligrams per kilogram National Contingency Plan nanograms per liter National Oceanic and Atmospheric Administration National Pollutant Discharge Elimination System National Priorities List Operation and Maintenance Preliminary Close Out Report Potentially Responsible Parties Resource Conservation and Recovery Act Remedial Investigation Remedial InvestigationFeasibility Study Record of Decision Cannelton Industries Site Statement of Work Substantive Requirements Document Unilateral Administrative Order micrograms per liter United States Environmental Protection Agency United States Geological Survey Unlimited UselUnrestricted Exposure

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6

Executive Summary

The remedial action implemented at the Cannelton Industries Superfund Site included excavation and off-site disposal of contaminated soils and tannery waste materials from the former Barren Zone (Zone B) Southern Shoreline of Tannery Bay and Western shoreline (Zone A) and for sediments to be left in place in the Tannery Bay for natural attenuation Excavation work was completed in 1999 and monitoring of the bay and other areas started in 2000

In 2006 as part of a joint effort through the Great Lakes National Program Office (GLNPO) Great Lakes Legacy Act the potentially responsible parties (PRPs) undertook voluntary remedial activities to remove impacted sediments within Tannery Bay and the Wetland Area on the Site EPAs Superfund program identified the sediment removal project as going beyond the remedy required in the Record of Decision (ROD) and ROD Amendment

The assessment of this five-year review for the Cannelton Industries Site found that the remedy is functioning as intended and is protective of human health and the environment in the short term Based on the Site inspection and data no inappropriate land or groundwater use was observed EPA is not aware of site or media uses which are inconsistent with the stated objectives of the ICs and cleanup goals Access is further restricted by use offencing Long-term protectiveness at the Site requires continued compliance with use restrictions to assure that the remedy continues to function as intended To assure proper maintenance and monitoring and effective ICs long-term stewardship procedures will be reviewed and a plan developed The plan will include a provision for regular inspection ofICs at the Site and annual certification to EPA that the ICs are in place and effective

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8

NPL status x Final D Deleted D Other (specify)

Remediation status (choose all that apply) D Under Construction D Operating x Complete

Multi Ie OUs D YES x NO Construction com letion date 09 27 1999

Lead a enc x EPA D State D Tribe D Other Federal Agency

Author affiliation US EPA

Review eriod 102008 to 82009

Date(s) of site ins ection 6 17 2009

Type of review x Post-SARA D Pre-SARA D NPL-Removal only D Non-NPL Remedial Action Site D NPL StateTribe-lead D Regional Discretion

Review number D 1 (first) x 2 (second) D 3 (third) D Other (specify)

Triggering action D Actual RA Onsite Construction at au DActual RA Start at OU D Construction Completion x Previous Five-Year Review Report D Other (specify)

action date (from WasteLAN) 08 20 2004

Due date (jive years after triggering action date) 08202009

Tri erin

[aU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN)

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Five-Year Review Summary Form contd

Issues

I EPA is pursuing the implementation of restrictive covenants Use restrictions in the form of zoning are in place and currently effective

Recommendations and Follow-up Actions

1 An Institutional Control Implementation and Action Plan (lCIAP) will be submitted to EPA for review and approval

Protectiveness Statement(s)

The assessment of this five-year review for the Cannelton Industries Site found that the remedy is functioning as intended and is protective of human health and the environment in the short term Based on the Site inspection and data no inappropriate land or groundwater use was observed EPA is not aware of site or media uses which are inconsistent with the stated objectives of the Ies and cleanup goals Access is further restricted by use offencing Long-term protectiveness at the Site requires continued compliance with use restrictions to assure that the remedy continues to function as intended To assure proper maintenance and monitoring and effective ICs long-term stewardship procedures will be reviewed and a plan developed The plan will include a provision for regular inspection ofICs at the Site and annual certification to EPA that the ICs are in place and effective

Other Comments Date oflast Regional review of Human Exposure Indicator (from WasteLAN) May 272009 Human Exposure Survey Status (from WasteLAN) Current Human Exposure Controlled Date oflast Regional review of Groundwater Migration Indicator (from WasteLAN) May 272009 Groundwater Migration Survey Status (from WasteLAN) Not a GW Site Ready for Reuse Determination Status (from WasteLAN) Undetermined

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I Introduction

The purpose of five-year reviews is to detennine whether the remedy at a site is protective of human health and the environment The methods filldings and conclusions of reviews are documented in five-year review reports In addition five-year review reports identify issues found during the review if any and recommendations to address them

Region 5 of the United States Environmental Protection Agency (EPA) has prepared this five-year review pursuant to Section 121 of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) and the National Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Part 300) CERCLA 121 states

If the President selects a remedial action that results in any hazardous substances pollutants or contaminants remaining at the site the President shall review such remedial action no less often than each five years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented In addition ifupon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104J or [106J the President shall take or require such action The President shall report to the Congress a list offacilities for which such review is required the results ofall such reviews and any actions taken as a result ofsuch reviews

EPA interpreted this requirement further in the NCP 40 CFR Section 300430(f)(4)(ii) states

Ifa remedial action is selected that results in hazardous substances pollutants or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure the lead agency shall review such action no less often than every five years after the initiation ofthe selected remedial action

EPA has conducted a five-year review ofthe remedial actions implemented at the Cannelton Industries Inc Site in Sault Ste Marie Michigan This review was conducted for the entire Site from October 2008 through August 2009 This report documents the results of the review

This is the second five-year review for the Cannelton Industries Inc Superfund Site The triggering action for this statutory review is the signature date of the previous five-year review as shown in EPAs WasteLAN database August 20 2004 The remedy implemented at the Site left hazardous substances pollutants or contaminants above levels that allow for unlimited use and unrestricted exposure in specific areas (zones) of the Site

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II Site Chronology

imiddotmiddotbullbullbull Si bullbullbullbull ~r rih +tJ h iir i igtmiddotjJrmiddotmiddotmiddotmiddotC lt bull Initial discovery of problem or contamination

r i gt bullbullbulllt

1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990

August 30 1990 September 6 1991

September 1991 - January 1992

September 1991 April 1992 July 1992 September 30 1992 April 12 1993 September 1993 - Summer 1994 October 4 1994 October 1994 - September 1995

January 5 1995 May 1995 June 5 1995 September 27 1996 April 4 and April 15 1997 May 14 1997 June - September 1997 November 1997 February 18 1998 July 311998 December 30 1998 June 8 1999 July 28 1999 September 27 1999 December 16 1999 June 2000 June - September 2000 June 2000 June 2002 October 2002

EPA Removal Action Response to fires within the Barren Zone trenches were dug to mitigate recurring fires Unilateral Administrative Order (UAO) to Conduct PRP Removal Action PRP Removal Action installation of sprinkler system and fencing of the Barren Zone NPL listing Administrative Order on Consent (AOC) for second PRP Removal Action PRP Removal Action to protect shoreline along the Barren Zone and extend the fence at the Site Remedial Investigation completed Feasibility Study completed Feasibility Study Addendum Completed Record of Decision signed AOC for Remedial Design and Pre-Design Studies Field work for Pre-Design Studies took place AOC for removal action PRP Removal Action to extend shoreline protection along the rest of the Site along St Marys River east and west of the Barren Zone Pre-Design Studies Report Completed approved 30 Design for Remedy Alternative Remedy Proposal by PRP ROD Amendment Modifications to Remedial Design AOCSOW Remedial Design Start Baseline Biomonitoring Event Michigan State University Soil Studies UAO for Remedial Action Sediment Stability Study Remedial design complete On-Site constructionremedial action start Consent Decree for Past Costs Construction completion date (PCOR) Construction Completion Report Operation amp Maintenance Plan Approved First Post-Remediation Biomonitoring Event First Monitoring Event Interim Remedial Action Report Community Meeting Five-Year ReviewPartial Delisting

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June 8 2004

August 2004 JunelJul 2006 Fall 2006

leted Se tember 2007 Au ustOctober 2008

III Background

Physical Characteristics

The Cannelton Industries Inc Site (Site) is located along the south shore of the St Marys River in the Upper Peninsula of Michigan in Sault Ste Marie Chippewa County in the NE 14 of Section II Soo Township (T47N RI W) Figure I depicts the location of the Site The Cannelton Site occupies approximately 75 acres bounded by the St Marys River to the north 4th Avenue and the Soo Railway to the south 18th Street to the west and 12th Street to the east

The Site is physiographically divided into two distinct areas by a small bluff located adjacent to South Street on its south side This bluff constitutes an elevation change of approximately 12 feet The upper area south of South Street is typically at an elevation ranging from 630 to 640 feet The lower area north of South Street is adjacent to the St Marys River at an elevation generally less than 610 feet mean sea level The lower area is divided further by a smaller bluff with about 6 feet of relief which may represent the former St Marys River shoreline as it existed prior to industrial activity in the area This smaller bluff is evident across the Site and runs basically parallel to South Street and the two-track in the western portion of the Site Most of the area north of this smaller bluff is wetland and is located within the 100-year floodplain with an elevation of3-to-5 feet above average river level which is 6002 to 6012 feet above sea level The remaining areas of the Site are not in the 100-year floodplain

Other pertinent Site features include a small bay located adjacent to and northeast of the Site called Tannery Bay A former commercial coal dock forms the eastern side of Tannery Bay while the southern and western sides are bordered by the Site The peninsula adjacent to Tannery Bay that forms its western shoreline is referred to as Tannery Point and is primarily wetland Four ponds exist on Tannery Point and are called Dump Pond Middle Pond Long Pond and Beaver Pond Tannery Point originated as part of a large pier that was filled in with scrap lumber and sawdust

Significant surface water features occurring at or near the Cannelton Site are the St Marys River wetlands along the river Seymour Creek which enters the St Marys River approximately 200 feet west of the Site and Ashmun Creek which enters the river about a half mile east of the Site The St Marys River is the sole outlet for Lake Superior the largest fresh water lake in the world and forms a connecting channel to Lake Huron the third largest fresh water lake in the world

A former tannery operated on the Site from the early 1900s to 1958 when the tannery burned down As shown on Figure 2 the Site is delineated by different zones or areas designated A to E The former plant area was located in Zone E Zone B was an area called the Barren Zone and was the area of highest concentration of tannery waste Zone A also referred to as the Western Shoreline had minimal tannery activities but is part of the property Zones C and D are along the shoreline and consist of the wetland area and Tannery Point and Bay

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The Cannelton Site is also located within the boundaries of the St Marys River Area of Concern which is one of 43 areas on the Great Lakes identified in 1985 by the International Joint Commission for development for a Remedial Action Plan The St Marys River was selected because 9 of the 14 beneficial uses identified under the Great Lakes Water Quality Agreement were impaired The St Marys River Area of Concern is ajoint effort between the United States and Canadian Governments

Land and Resource Use

The Site was the location of the former Northwestern Leather Tannery Company Prior to this a saw mill operated on the northeastern portion of the Site Tannery Point originated as part of a large pier which extended out into the river The pier created the western shoreline of Tannery Bay and it appears that the saw mill filled in much of the western side of the pier with scrap lumber and sawdust The pier also stopped some of the discharged tannery waste from going downstream and allowed the waste to fill in on the piers upstream side This combination of filling activities created what is now called Tannery Point and accounts for the fact that Tannery Point has evidence of tannery waste as well as saw mill waste material

Since 1958 when the tannery burned down the buildings were demolished and the property has been unused The current land use surrounding the Site is residential and light industrial There are approximately 400 single-family residences located within one-half mile of the Site boundary the majority of which are south and west of the Site The nearest residence is a small building containing several residential units adjacent to the Site directly south of Tannery Bay on South Street The nearby residences are connected to the Citys municipal water system

Currently the property remains unused after cleanup was completed in 1999 and local zoning is designated for industrial land use The 20-Year Master Plan for the City of Sault Ste Marie designates future land use in the Site area for general industry and high-density residential use in the area from 16th Street to 18th street and from 4th

Avenue to shoreline There is a strong interest by the City of Sault Ste Marie and the current land owner to reuse portions ofthe property for commercial light industrial and residential uses Plans are underway to achieve the reuse and redevelopment goals for the Site

The St Marys River connects Lake Superior and Lake Huron via the Soo Locks and is the boundary between the United States and Canada Currently the St Marys River is a major navigational channel and a drinking water source for Sault Ste Marie Michigan and Sault Ste Marie Ontario Canada The source for Sault Ste Maries municipal water supply is the St Marys River intake located approximately one mile upstream ofthe Cannelton Site The groundwater beneath the Site is not currently a drinking water source nor is it expected to be in the future

Most of the shore areas at the Cannelton Site are wetlands The St Marys River is the major hydrologic influence on the wetlands Some water also originates from a storm sewer that probably services the nearby residential building located on South Street in the eastern portion of the Site

The largest wetland area is located on Tannery Point The Tannery Point wetlands overlay sawmill and tannery waste The wetlands on Tannery Point include four ponds The ponds appear to have formed from decomposition and compaction of the fill material ie sawdust and lumber scrap A habitat survey conducted by EPA in 1992 evaluated wildlife habitat use of Tannery Point and Tannery Bay The habitat evaluation was accomplished through vegetation and small mammal inventories a fish survey general wildlife observations and soil profiles The survey found that the wetlands were primarily forested wetlands and emergent cattail marshes The majority of the trees in the wetland area consisted of Balsam poplar and speckled alder The understory and groundcover primarily was comprised of reed canary grass an invasive species and goldenrod and horsetail Tree cores taken from trembling aspen and red ash had mean ages of222 years (s=52 n=30) and 295 years (s=81 n=22) respectively During a 3shyday field investigation 41 bird species 9 mammal species and 4 amphibian species were observed using the Site Species observed included white-tailed deer ground hog green heron wood thrush mallard Canada goose and beaver Habitat utilization included nesting of waterfowl (Canada Goose) breeding of all amphibians observed feeding of most species observed and permanent residency of many of the species observed The diversity of habitat

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is believed to result from the activity of beaver Evidence of periodic clearing of wooded areas by the beaver can be found throughout many areas of the Site There are no known Federal- or State-listed endangered or threatened natural plant communities or natural features at the Site

Rather than base remedial efforts solely upon contaminant levels the impact of remediation on this apparently diverse and well-used wetland environment was taken into consideration The age of the trees a gauge of wetland maturity was weighed against the information generated on environmental risk Removal of contaminated wetland soils was thought to be more harmful to the established forested wetland (and wildlife use of the area) than allowing some level of contamination to remain in place

Recreational use of Tannery Bay appears to be limited to fishing and waterfowl hunting Tannery Bay is shallow so boating and swimming would be difficult although wading is possible but would be difficult because of the thick soft sediment and the prevalence of wood and bark debris from historical sawmill operations

The Site is underlain by a shallow aquifer which consists of glacial deposits and is primarily characterized as silty sand though there are also site-wide variations such as a linear deposit ofgravels and cobbles a fairly continuous layer of sand and gravel above bedrock and a thin layer of clay serving as a discontinuous confming layer in some of the deeper wells along the river The bedrock underlying the unconsolidated deposits the Jacksonville Sandstone has considerable topography at the Site There is a buried bluff in the bedrock located near South Street which causes the depth of bedrock to vary from approximately 30 feet south of South Street to approximately 60 feet near the river In spite of this there is a continuous aquifer connecting the upper and lower areas of the Site and the St Marys River The depth to the water table ranges from approximately 8 to 23 feet in the plant area and I to 7 feet in the area north of South Street

The Site-wide groundwater gradient is toward the St Marys River Vertical gradients are downward in the southern portion of the Site indicating a recharge zone and upward in the northern portion indicating a discharge to the river The average groundwater velocity for the Site was calculated to be 019 feetday or 70 feetyear The velocity may vary based on the different soil types found across the Site

History of Contamination

The Northwestern Leather Tannery Company operated until 1958 when the tannery was destroyed by fire During its period of operation (from 1900 to 1958) the tannery processed raw cowhides using a sophisticated and multi-step process that transformed raw animal hides to a finished leather The plant had no sewage system other than three drains which included pipes and open ditches running north to the shores of the St Marys River to what was referred as the waste discharge zone According to historical records and interviews with former employees no liquid waste was discharged to the east west or south of the plant During busy times of operation the plant might have discharged up to 132 chemical vats per day or approximately 250000 gallons per day through the drainage system Historical aerial photographs indicate that waste was discharged directly to the St Marys River and adjacent wetlands

The primary tannery waste discharge area covered a 4-acre area north of South Street and includes an irregularly-shaped area of approximately one acre which prior to cleanup was partially devoid of vegetation and contained multi-colored soils and tannery waste residues This area is referred to as the Barren Zone as depicted in Figure 2 The Barren Zone was the location where solid waste byproducts of the tanning process were dumped

The Western Shoreline area Zone A was also used as a dump site for barrels and general wastes from the tannery According to former employees of the tannery approximately two truck loads of plant wastes were disposed of per day These wastes were typically burned after disposal The former Tannery Plant and waste discharges are shown on Figure 3

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The wastes discharged from the tannery in the area adjacent to the river included metals cyanide sulfide calcium carbonate salts discharged as brine solutions and various leather fmishing solutions such as shellacs thinners formic and carbolic acids formaldehyde ammonia octoalcohol and other alcohols Chromium is the primary metal known to be disposed Tannery waste has been exempted as a listed hazardous waste under the Resource Conservation and Recovery Act (RCRA)

Aerial photographs indicate that some of the tannery waste deposited on the St Marys River shoreline eroded over time Both this eroded material and material disposed of during the plants operation were likely carried by the river downstream and deposited along the western shoreline of Tannery Point and downstream in Tannery Bay

Initial Response

Prior to EPAs involvement environmental sampling from 1978 through 1988 at the Site had partially delineated the nature of contamination The Michigan Department of Natural Resources (now the Michigan Department of Environmental Quality (MDEQraquo performed sampling in 1978 1979 and 1980 and the property owner periodically conducted sampling during the period from 1979 to 1986 In 1987 the United States Geological Survey (USGS) installed a monitoring well at the Site The majority of the historical on-site sampling had been limited to the area in or adjacent to the Barren Zone A minimal amount of groundwater surface water and sediment sampling had also been performed

EPAs removal program was first involved at the Site in 1988 due to recurring fires at the Site The fires which were located within the Barren Zone reportedly occurred spontaneously during the dry summer months and had been increasing in intensity EPA responded and excavated five trenches within the Barren Zone in order to delineate the source of the fires reduce methane build-up and to disperse heat build-up within the soils

In May 1989 EPA issued a Unilateral Administrative Order (UAO) to the PRPs property owner Cannelton Industries Inc and Algoma Steel Corporation its parent company The UAO directed the PRPs to install a sprinkler system to help reduce the incidence of fITes to further investigate the cause of the fITes and to construct a shoreline stabilization system in front of the Barren Zone to prevent waste materials from eroding into the river The sprinkler system was installed immediately and rip-rap was installed along the shoreline in front of the Barren Zone in November 1989 The investigation did not determine the cause of the fITes and once the sprinkler system was installed fITes did not occur again at the Site

In September 199 I an Administrative Order on Consent (AOC) was signed with EPA that required the PRPs to fence a larger area ofthe Site to prevent access to contaminated areas and to extend the shoreline stabilization both east and west of the existing rip-rap to protect adjacent shoreline areas from erosion In 1995 Cannelton Industries Inc under another AOC completed the shoreline stabilization from the western shoreline to the tip of Tannery Point

The Site was listed on the National Priorities List (NPL) on August 30 1990 Special Notice Letters were issued to PRPs requesting that they conduct the Remedial InvestigationFeasibility Study (RIfFS) for the Site Since no settlement was reached with the companies EPA funded the RIfFS The field work required for the RIffS took place from June 1989 to October 1990 Additional field work was conducted by EPAs Environmental Response Team (ERT) Edison New Jersey in October 1991 and May 1992 The fITst study involved additional sediment and soil toxicity tests and benthic macroinvertebrate studies The May 1992 field activities consisted of a habitat survey of the wetlands on site and some preliminary mapping of the extent of tannery waste in Tannery Bay Reports for each of these studies were prepared by ERT and can be found in EPAs Site files

The RI Report was published in September 1991 A Baseline Risk Assessment was completed in October 1991 The Feasibility Study (FS) was published for public review and comment in April 1992 An FS Addendum was completed in July 1992

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Basis for Taking Action

The sampling prior to the Remedial Investigation (RI) found soil samples from the Barren Zone were contaminated with cadmium chromium copper nickel lead zinc arsenic and cyanide

The RI results showed the primary contaminants at the Site to be metals The concentrations of inorganic compounds in soils and sediments at the Site closely followed the historical land use and the currents of the St Marys River The highest values were associated with the former tannery drains and discharge areas while elevated levels of metals were also present in the soils along the western shoreline of the Site where general refuse was dumped in the former plant area along the shoreline east ofthe main discharge area and in the adjacent wetlands Based upon their distribution within the soils and sediments the following metals were found to be elevated at the Site chromium arsenic lead mercury barium and cadmium Chromium was the most widespread inorganic contaminant in the soils and sediments at the Site Following are the maximum concentrations of metals (in milligrams per kilogram (mgkg)) detected in soils and sediments

Soils Sediments

Arsenic Barium Cadmium Chromium Lead Mercury

3600 10300

341 328000 10 100

25

296 202 261

40000 603 23

The groundwater and surface water at the Site were not widely impacted from the former tannery operations relative to maximum contaminant levels (MCLs) and ambient water quality criteria (AWQC) respectively

Human Health Risk Assessment Based on total estimated exposures and toxicity information current at the time of the 1992 Record of Decision (ROD) total carcinogenic risk levels to exposed populations from chemicals of potential concern at the Site ranged from 15 x 10 -3 to 75 x 10 -I These elevated risk levels were primarily caused by exposures to disposal and plant area soils other Site soils groundwater (future use only) and ambient air

Hazard indices exceeded 10 for all populations evaluated The carcinogenic risks associated with exposure to river water river sediments pond water and pond sediments were less than lxlOmiddot6 for all populations The hazard indices associated with exposure to river water river sediments pond water and pond sediments were less than 10 for all populations Based on the exposure assumptions and available toxicity information at that time the risks to human health associated with surface water and sediments were not significant

Ecological Risk Assessment The results of Pre-Design Studies indicated that soils and sediments which remained on-site did not pose a significant threat to terrestrial and aquatic organisms and that future biological monitoring would be necessary to verifY the protectiveness of benthic organisms and wildlife No impacts to the environment had been clearly associated with the levels of contamination in the ecological toxicity studies done to date In 1995 EPAs Emergency Response Team conducted an Ecological Risk Assessment focusing on the potential risk of mercury in Tannery Bay Results showed a low risk to mercury concentrations in the sediments This study also reconfirmed past studies that indicated there was no direct correlation with chemical concentrations in sediments and levels of toxicity found in test organisms

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IV Remedial Actions

Remedy Selection

Record ofDecision (September 30 1992) The initial ROD for the entire Site was signed on September 30 1992 The selected remedy included the excavation and consolidation of waste material soils and river sediments which exceeded specific chemical standards into an on-site landfill Collection and treatment of groundwater from constructiondewatering activities groundwater monitoring and land use restrictions for the landfilled area were other major components of the remedy Performance standards were described in the 1992 ROD but additional studies were also required to determine what levels of contaminants in soils and sediments would be protective of surface water and the ecosystem The remedial action objective of the selected remedy is to reduce and control potential risks to human health and the environment posed by exposure to site contaminations by excavating waste material and soils and sediments above human healthshybased criteria and containing the material in an on-site landfill

Pre-Design and Additional Studies On April 12 1993 the owner of Cannelton Industries Inc signed an AOC with EPA to design the remedy and perform Pre-Design Studies as required by the ROD and Statement of Work (SOW) for Remedial Design PreshyDesign Studies field work took place from September 1993 through the summer of 1994 A Pre-Design Studies report was completed in October 1994 with EPA modifications to the document in 1995 An Ecological Risk Assessment was also completed in January 1995 by EPAs ERT

The SOW for the Remedial Design required Pre-Design and Additional Studies to be performed at the Site in order to meet the requirements of the 1992 ROD The studies were to evaluate 1) the protection of groundwater and surface water from unacceptable contaminant discharges 2) direct toxicity of soil and sediment and 3) bioaccumulation of contaminants The soil leaching and groundwater studies showed that the quality of groundwater discharging from the Site was protective of the St Marys River and was expected to remain protective of surface water quality in the future The results for sediment toxicity and bioaccumulation studies indicated that due to chemical concentrations in soils and sediments in Tannery Bay the sediments did not pose a significant threat to aquatic organisms The Bioaccumulation Studies performed by HydroQual Inc for the Site (HydroQual April 1995) evaluated mercury in terrestrial organisms Meadow voles were collected and analyzed for mercury body burdens The body burden data were utilized in a terrestrial food chain model to evaluate mercury food chain threats to target receptors The results of the terrestrial evaluation of risks indicated that mercury was accumulated by the meadow vole and the accumulation was correlated with the soil mercury concentration However the results of the subsequent food chain risk evaluation indicated that there was not a current substantive ecological risk posed by mercury at the Site The risk assessment analysis conducted using the hazard quotient methodology indicated that dietary exposure to metals at the Cannelton Industries Site is generally less than 1-10 percent of the reference dose with only a few exceptions In all cases the hazard quotient was less than 1 The Ecological Risk Assessment conducted by EPAs ERT (1995) reconfirmed past studies that indicated there was no direct correlation with chemical concentrations in sediments and levels of toxicity found in test organisms

ROD Amendment (September 27 1996) Based on the results of the Pre-Design Studies a change in the remedy was proposed by Cannelton Industries in June 1995 At the same time on June 5 1995 the State of Michigan passed into law Part 201 of Michigan Natural Resources and Environmental Protection Act (NREPA formerly 641) which changed the environmental cleanup requirements and standards Part 201 standards are based on different land use scenarios and the potential exposure under each scenario (ie residential commercial industrial and recreational) The new regulations allowed for these land use scenarios to be incorporated into the cleanup criteria for the Site A revised proposed plan was developed and presented to the public for input in May 1996 The remedy proposed in the revised plan was more cost effective and addressed the communitys land use concerns while still effectively accomplishing the safe cleanup of the Site

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The revised cleanup plan took into account the future land use goals of the City of Sault Ste Marie The Citys 20shyYear Master Plan has areas within the current Site slotted for high-rise residential use recreational use along the river and light industrial or commercial use To accommodate these potential future land uses the zones within the Site were evaluated and cleanup levels were selected based on future use utilizing the States generic cleanup standards

The ROD Amendment was signed on September 271996 and consisted of bull Excavation and removal of contaminated soil and tannery waste down to clean sand from the Barren Zone

(Zone B) tannery waste from the southern shoreline of Tannery Bay and surficial debris and waste materials from the western shoreline of the Site to an off-site facility for appropriate disposal

bull Collection and treatment (if needed) of groundwater from constructiondewatering activities and discharge to the Publicly Owned Treatment Works If applicable NPDES standards are met water can be discharged to the river

bull Appropriate regrading and landscaping of the western shoreline regrading and backfilling as necessary of the excavated area in the Barren Zone (Zone B) to restore wetland

bull Construction of surface drainage system and maintenance of shoreline protection to prevent erosion bull Further evaluation of the stability of soils and sediments and monitoring study to evaluate the potential for

future releases or impacts ofmetal(s) to the environment evaluation of Tannery Bay using appropriate analysis to determine if erosion of sediments and site materials are a concern

bull Construction of a sheet pile containment system or other appropriate remedy for the Tannery Bay area if it is determined that erosion of sediment is a concern

bull Surface water groundwater sediment wetland soils and biological monitoring including bioavailability studies for site-specific metals (chromium cadmium mercury arsenic and lead) and

bull Implementation of deed restrictions to limit land use to industrial or recreational uses in specific areas (consistent with wetland protection regulations) while permitting residential use of other portions of the Site

Remedy Implementation

The AOC and SOW for Remedial Design was amended on April 15 1997 to comply with the September 27 1996 ROD Amendment An evaluation of Tannery Bay sediment stability and an evaluation of contaminant stability in wetland soil were conducted to help develop the long-term Operation and Maintenance Plan and other portions of the final remedial design Design of the remedy was completed on December 30 1998

Baseline Biomonitoring Study In the summer of 1997 the National Oceanic and Atmospheric Administration (NOAA) conducted a baseline biomonitoring (clam shell) study for EPA The purpose of the study was to assess bioavailability by measuring the uptake ofthe contaminants of concern (COCs) in tissues of caged clams Corbiculafluminea transplanted to Tannery Bay and reference areas in order to provide a baseline data set Unfortunately the study revealed that the clams used were obtained from a source which originally had elevated levels of mercury Post-Construction Studies are discussed further below

Pre-design Sediment Stability Studv-Stability of Tannery Bay Sedimellts Conestoga-Rovers amp Associates (CRA) July 1998 The goal of the sediment stability study was to determine whether sediments at the Site were eroding into St Marys River or whether new sediments were depositing over the existing sediments in Tannery Bay Based on a review of sediment shelf and vegetation growth within Tannery Bay using aerial photography over a 42-year period (1953 to 1995) sedimentation within Tannery Bay is evident Hydrodynamic and sediment transport modeling further support that Tannery Bay a shallow bay protected from wave and ice forces by a sediment shelf is a depositional area for sediments migrating into the Bay from St Marys River with the potential for significant resuspension of sediments being very low

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Unilateral Administrative Order for Remedial Action A Unilateral Administrative Order for Remedial Action became effective on February 18 1998 Cyprus Mines responded to this Order Cyprus Mines acquired the Site through the purchase of Cyprus-Amax who was the site owner at that time Cyprus Mines subsequently submitted the Remedial Action Work Plan to EPA which described the Remedial Construction activities necessary to implement the 100 Design On April 6 1999 EPA approved Cyprus Mines Remedial Action Work Plan which involved the following remedial activities

1 Western Shoreline Excavation and removal of surficial debris and disposal in an off-site landfill Regrading with clean soil and landscaping of the area as appropriate for future land use Construction of surface drainage works to prevent erosion and Placement of deed restrictions to limit future use of the shoreline area to recreational use and to limit groundwater use if monitoring results dictate a need

2 Barren Zone Excavation and removal ofthe sprinkler system and soil and tannery waste down to clean sand Dewatering of excavated materials and disposal in an off-site landfill Minimal backfilling as necessary of the excavated area with clean fill to maintain a stable shoreline and prevent erosion Appropriate revegetation and Placement of deed restrictions to limit future use of the Barren Zone to industrialresidential use

3 Wetland Area Further evaluation of the stability of soils Monitoring study to evaluate the potential for future releases of metals to the environment and Placement of deed restrictions to limit future use to industrial or recreational uses consistent with wetland protection regulations

4 Tannery BaySediments Removal of visible surficial waste along the southern shoreline of Tannery Bay where waste is not adequately covered or contained in order to minimize erosion and disposal in an off-site landfill Biological monitoring of sediment Physical monitoring of Tannery Bay using appropriate analysis to confirm that erosion of sediments does not become a concern in the future and Shoreline stabilization along the southern shoreline

5 Plant Area Removal of stockpiled soils on concrete slab Monitoring well abandonment throughout the Site and Placement of deed restrictions to limit future use to industrial uses

6 Long-Term Monitoring Verify that the groundwater quality discharging from the Site remains protective of the St Marys River Semi-annual groundwater sampling Semi-annual surface water sampling Monitoring of wetlands as warranted based on the Michigan State University study and Biomonitoring

On June 8 1999 Envirocon mobilized to the Site to begin remedial action activities Details of Envirocons completed construction activities are as follows

20

bull Removal of the ground level fife protection sprinkler system located in the Barren Zone concurrent with the clearing and fence removal operations

bull Removal and off-site disposal of approximately 306 tons of surficial wasteresidually-impacted soils and debris from the Western Shoreline Surficial debris consisted of scrap metals wood glass empty metal drums building materials unfmished leather a snowmobile concrete pieces and the like The shoreline was then graded to a maximum 4 to 1 (horizontal to vertical) slope in accordance with the specifications and common fill was placed and compacted to a depth of 6 inches Disturbed areas were covered with topsoil and seeded on October 14 1999 to enhance the western shorelines restoration

bull Excavation removal and off-site disposal of approximately 31528 tons of affected soils from the Barren Zone from July 20 to September 14 1999 Confirmatory soil sampling was conducted in accordance with MDEQ sampling protocols All transfer loading and off-site disposal of stockpiled soils to the selected landfills was completed utilizing haul trucks Common fill material was placed and compacted using the existing dozers and wheel tired loaders and haul trucks to achieve the specified compaction Grades along the west and east limits were matched with slopes along the Barren Zone to a 10 to 1 slope (horizontal to vertical)

bull On August 30 1999 Envirocon then commenced remediation of the southern Tannery Bay shoreline Approximately 159 tons of tannery-related wastes were removed and disposed of off site Following shoreline remediation the southern shore of Tannery Bay was stabilized with a geo-membrane overlain by large rock

bull To ensure that all excavated soils were properly dewatered and that the water was treated to within State standards a water treatment system was installed and the treatment plant discharge was directed to the two Frac tanks for holding until receipt and acceptance of the initial analytical results for the discharge Analytical results of the composite treated water were sampled and when the sample met the Substantive Requirements Document (SRD) permitted discharge concentrations for both hexavalent chromium and total mercury analyses the water was discharged directly to the S1 Marys River In total approximately 32 million gallons of excavation water and rainwater were treated through Envirocons water treatment system throughout the remedial construction activities

bull From July 26 to 28 1999 Envirocon abandoned 55 monitoring wells previously installed as part of the Remedial Investigation at the Site

bull On September 301999 following the placement and compaction of common fill in the proposed locations Envirocon proceeded to install three shallow monitoring wells (MW-IOI 102 and 103) within the Barren Zone as part of the long-term monitoring requirement for the Site All three monitoring wells were advanced to a depth of 15 feet below ground surface utilizing a 5-foot screen in each well

bull As of project completion a total of 31 99276 tons of soils and surficial waste had been disposed of off-site to Waste Management Incs Dafter and Waters landfills of which approximately 1854315 tons were disposed of at the Dafter landfill and the remaining 1344961 tons were disposed of at the Waters landfill and

bull Shoreline stabilizationlberm restoration was completed by restoring approximately 700 feet of berm along the entire length of the former Barren Zone following the excavation soil verification sampling and backfilling activities Also 600 feet of shoreline protection berm was constructed along the southern shore of Tannery Bay following the removal of shoreline waste and debris

On September 24 1999 representatives from EPA MDEQ Cyprus CRA and Envirocon conducted the Pre-Final Construction Inspection for the Site All construction activities had been completed as required and the only remaining activities at the Site were seeding and minor fmal activities EPA completed the Preliminary Close Out Report (PCOR) on September 27 1999 The remaining activities were completed at the Site in October 1999 and the EPA Final Inspection was conducted on October 191999

Details of the remedial construction activities were presented in a Construction Completion Report dated December 1999 and approved by EPA in 2000

Post-Construction Biomonitoring Study The flfst round of post-construction biological monitoring was conducted by HydroQual Inc and Applied Biomonitoring on behalf of Cyrpus Mines Corp from July to September 2000 using a different source of Corbicula

21

The study provided inconclusive results The second round of post-construction biological monitoring was scheduled for 2003 however due to difficulties obtaining test organisms in 2003 (information revealed that the clams were non-native species to the area) and low water levels in 2004 the second round of post-construction biological monitoring was delayed then determined not to be necessary upon the completion of the sediment dredging

GLNPO Legacy Act Dredging Project

July 2006 - Tannery Bay Funding Awarded to CyPrus Mines On July 112006 EPAs Great Lakes National Program Office (GLNPO) awarded funding under the Great Lakes Legacy Act to Cyprus Mines for a sediment source removal project The Great Lakes Legacy Act provided $48 million of the cost of the project and Cyprus Mines which owns the former tannery property contributed $26 million MDEQ provided $600000 through its Clean Michigan Initiative As part of this joint effort through the Great Lakes Legacy Act Cyprus Mines undertook voluntary remedial activities to remove heavy-metal impacted sediments within Tannery Bay and the Wetland Area The purpose of the action was to eliminate long-term biomonitoring and reduce the operation and maintenance requirements for the Site through the removal of elevated concentrations of site-specific metals within Tannery Bay and Wetlands Area to below performance standards EPAs Superfund program identified the sediment removal project as voluntary and going beyond that required in the ROD Amendment Weston Solutions was contracted by GLNPO as the supervising contractor with Cyprus Mines contracting CRA to provide engineering support

AugustSeptember 2006 - Tannery Bay Survey and Limit ofDredge Revision In August 2006 a detailed bathymetry survey and probing was conducted by Weston to establish and reconfirm the actual dredge limits The two bathymetry surveys included conducting additional sediment samples within areas of interpolation to better delineate and refme the extents of the dredge limits CRA also conducted two supplementary sampling events during the same timeframe in which 33 additional samples were collected All parties (GLNPO EPA MDEQ Cyprus Mines Weston and CRA) reviewed and refined the fmal dredge limits in order to maintain the cleanup criteria of2500 mgkg for chromium and 05 mgkg for mercury The fmal dredge limits were approved by all parties and are shown in Figure 4

200612007 Sediment Removal Mobilization sediment dredging and removal occurred over two construction seasons During the fall of2006 and summer 2007 approximately 44000 cubic yards of impacted sediments from Tannery Bay and 800 cubic yards from the wetlands were dredged dewatered and disposed in an off-site landfill Cleaning up contaminated sediment from the Tannery Bay and the Wetland Area removed about 1 million pounds of chromium and 70 pounds of mercury from the environment See Appendix B for photos

200612007 Sediment Verification Sampling Following the removal of the heavy-metal impacted sediments in 2006 and 2007 CRA collected sediment verification samples The analytical results of the sediment sampling were well below the established cleanup criteria and are presented in Westons Remedial Action Report dated October 302007

Summary ofGLNPO Dredgillg Project The GLNPO dredging project of Tannery Bay and the Wetlands Area consisted of the following remedial activities 1 Tannery Bay

Remedial dredging and removal of approximately 44000 cubic yards of metal-impacted sediment from Tannery bay for disposal in an off-site landfill Construction of shoreline protection along approximately 19000 linear feet of shoreline around Tannery Bay utilizing 24-inch diameter Filtersoxxreg containing inch aggregate manure compost waste and a native seed mixture Filtersoxxreg were placed in a terrace fashion overtop of coconut matting and held in place by stakes and live staked

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Construction of surface drainage works to prevent erosion and Placement of deed restrictions to limit future use of the shoreline area to recreational use and to limit groundwater use if monitoring results dictate a need

2 Wetland Area Remedial excavation and removal of approximately 800 cubic yards of soils from two mercury hotspots for disposal in an off-site landfill

3 Confirmatory Sediment Sampling Program Collection of 87 sediment samples including 9 duplicate and 8 matrix spikematrix spike duplicate samples

Institutional Controls

Institutional controls (ICs) are non-engineered instruments such as administrative andor legal controls that help minimize the potential for exposure to contamination and protect the integrity of the remedy Compliance with ICs is required to assure long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure (UUIUE) Institutional Controls were required as part of the ROD and ROD Amendment The table below summarizes institutional controls for these restricted areas

As previously noted in Section IV the Site had been divided into different sections with different ICs required for each section The ICs that are needed are dependent on the planned future use of the different sections of the Site Cleanup in the various areas was based on the anticipated future uses and the ICs that are needed are based on that cleanup Thus the remedial action in Zone A the Western Shoreline requires that use of this area is limited to recreational uses Use of Zones B the Barren Zone and Zone E the Plant area is limited to industrial uses while Zone C the Wetland Area is limited to industrial or recreational uses

Ta I Sommarybille osfItofIooaIeontro s Ta ble Media Engineered Controls amp Areas that Do Not Support UUIUE Based on Current Conditions

Soils - In Western Shoreline (Zone A) as identified in Figure 2

Barren Zone (Zone B) as identified in Figure 2

Wetland Area (Zone C) as identified in Figure 2

Soils - Plant Area (Zone E) as identified in Figure 2

Soils- Site Property as identified in Figure 2

Soils- Site Shoreline as identified in Figure 2

IC Objective Title of Institutional Control Instrument Implemented (note if planned)

Prohibit any land use other than recreational use

Deed restriction (zoning) Restrictive covenant is pending

Prohibit anyland use other than industrial use


Prohibit any land use other than industrial or recreational Any use must be consistent with wetland protection requirements


Prohibit any land use other than industrial use


Prohibit any landscaping construction or other development that would modifY the surface of the property such that slopes and precipitation runoff is changed


Prohibit any alterations to the shoreline protection along the northern boundaries of the Site


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The September 27 1996 ROD Amendment called for the implementation of deed restrictions to limit land use to industrial or recreational uses in specific areas (consistent with wetland protection regulations) while permitting residential use of other portions of the Site ICs currently in place include the Citys current industrial use zoning Additionally although not an IC access control is provided by a fence surrounding the former plant area and along South Street on the Site The fence along South Street although not required by the remedy remains to prevent trespassing and serves as an access control for the Site There are currently no concerns with soils or groundwater at the Site Warning signs were eliminated at the request of the City when remediation was completed

In a letter dated August 25 2008 EPA requested that the PRPs develop an Institutional Control Implementation and Action Plan (ICIAP) and IC evaluation activities are in progress The ICIAP will be submitted to EPA for review and approval The ICIAP will propose to implement additional ICs such as a restrictive covenant conduct evaluation activities as needed such as title work and conduct planning for long-term stewardship Once the ICIAP has been completed EPA will ensure that it is complied with and implemented Ifneeded EPA will prepare an IC Plan to plan for the additional IC activities

Current Compliance Based on the Site inspection and data no inappropriate land or groundwater use was observed EPA is not aware of site or media uses which are inconsistent with the stated objectives of the ICs and cleanup goals Access is further restricted by use of fencing In order for the site to be protective in the long-term EPA will work with the PRPs to implement restrictive covenants to strengthen the use controls However at this time the remedy appears to be functioning as intended since the property is not being used in a manner which is inconsistent with the required use restrictions Hence the remedy is protective in the short term

Long-Term Stewardship Long-term protectiveness at the Site requires continued compliance with use restrictions to assure that the remedy continues to function as intended To assure proper maintenance and monitoring and effective ICs long-term stewardship procedures will be reviewed and a plan developed The plan will include a provision for regular inspection ofICs at the Site and annual certification to EPA that the ICs are in place and effective

Operation and Maintenance (OampM)

EPA approved the November 1999 OampM Plan on May 5 2000 with modifications The plan was revised and the Final OampM Plan was submitted to EPA by CRA on behalf of Cyprus Mines Corporation on June 132000

The OampM requirements from the November 1999 OampM Plan included the following

1 Inspection and maintenance of the protected shoreline to ensure long-term integrity 2 Post-construction groundwater and surface water monitoring 3 Post-construction Tannery Bay monitoring including surface water sediment and biological monitoring to

assess potential changes in the bioavailability of site-related contaminants over time and 4 Post-construction wetland monitoring

In a letter from EPA to the PRPs dated March 26 2002 EPA stated that a third round of groundwater sampling would be required prior to discontinuing groundwater monitoring at the Site The first five-year review report discusses the results from the third round of groundwater sampling and summarizes the results from the December 2003 sampling event as either the same or lower compared to the previous two sampling events (June and November 2000) and states that the groundwater quality measured at the Site meets the performance criteria identified in the OampM Plan A fourth round of groundwater sampling was completed in July 2006 Results from the July 2006 sampling event show that the groundwater samples met the performance standards Historical groundwater monitoring has been completed in accordance with the requirements of the 1999 OampM Plan and monitoring has demonstrated that the Site poses no impacts to groundwater The groundwater monitoring wells were properly abandoned in June 2009

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Also identified in the previous five-year review two ofthe three biological monitoring studies had been completed a baseline event and one post-construction completion event The purpose of the biomonitoring studies as identified in the 1999 OampM Plan was to verify whether the selected remedy for the Site is effective at reducing concentrations ofbioavailable trace elements in Tannery Bay Specifically the objectives of the biomonitoring program were to determine 1) whether chromium total mercury methylmercury lead cadmium and arsenic in Tannery Bay sediments are available to aquatic biota residing in andor using the Bay and 2) whether exposure to bioavailable concentrations of metals may adversely affect local biota

Due to the fact that data from the baseline biomonitoring were compromised and the results from the first round of post-construction monitoring were inconclusive and considering the difficulties in obtaining a comparable test organism for the second round of post-construction biological monitoring both EPA and MDEQ agreed that the studies were no longer purposeful in determining whether or not the selected remedy for the Site is effective at reducing concentrations ofbioavailable trace elements in Tannery Bay Both agencies have determined that additional biological monitoring is not necessary at the Site with the completion of the GLNPO Legacy Act sediment dredging and after reviewing confirmation data The ROD amendment requirements for biological studies are no longer relevant and modification to the decision document is needed

Upon completion of the GLNPO Legacy Act dredging project review of the JuneJuly 2006 Sampling Event data and review ofthe 2007 verification data from the GLNPO dredging project the 1999 OampM Plan was revised

The OampM requirements from the April 2008 OampM Plan as approved by EPA on July 14 2008 include the following

1 Inspection and maintenance of the protected shoreline to ensure long-term integrity 2 Annual surface water monitoring depending on results changes may be suggested and submitted to EPA for

review and 3 Annual post-remedial sediment sampling depending on results changes may be suggested and submitted to

EPA for review

June July 2006 (fourth semi-annual) OampM Report 1 Inspection and Maintenance of the Remedial Action Components

Inspection activities were performed at the Site on July 27 2006 Inspection activities were completed to document the integrity and stability ofthe shoreline protection bluff slopes and fences remaining after the remedial action The inspection included an examination of the former plant area shoreline berms Barren Zone western shoreline bluffs and general Site conditions to ensure the integrity of the remedial action components No requirements for any further maintenance activities were identified at the time of the inspection

2 Groundwater and Surface Water Monitoring Groundwater Monitoring Fifteen groundwater samples and one quality control sample were collected during the JuneJuly 2006 sampling event Groundwater samples were collected from all eight downgradient monitoring wells (MWs 0447 101 102 10393-0193-02 and 93-03) and three of the four upgradient monitoring wells (MWs 32 02S and 12) and analyzed for site-specific metals and low level mercury Groundwater sampling locations are presented in Appendix C Figure 1 MW-44 could not be sampled as a result of an obstruction within the well at a depth of approximately five feet below ground surface

Analytical results are presented in Appendix C Results indicate that mercury was detected throughout the Site with the highest concentrations being 00024 micrograms per liter (IlgL) and 00012 IlgL at MW-12 and MW-02S respectively All detected mercury concentrations were well below the mercury performance criteria of 211giL for groundwater at the Site There was no detection of arsenic cadmium or lead

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Chromium was detected in the Former Barren Zone and the Wetland area with highest concentrations being 200 IlgL and 128 IlgL respectively All chromium concentrations were below performance criteria

In summary groundwater quality measured at the Site generally met the perfonnance criteria identified in the OampM Plan

Surface Water Monitoring Fifteen surface water samples were collected from twelve surface water locations and analyzed for arsenic cadmium chromium lead low level mercury total organics and hardness The analytical results are presented in Appendix C Surface water monitoring results from the previous two monitoring events (November 2000 and December 2003) in conjunction with the analytical results for the July 2006 monitoring event are presented in Appendix C for comparisontrend analysis

Analytical results indicate no detections of arsenic or lead in the surface water Cadmium was detected at the Long Pond location (SW-12) at a concentration of 012 IlgL However this does not exceed the performance criterion of 037 IlgL Chromium was detected within Tannery Bay (SW-8 SW-9 SW-lO and SW-I I) with a maximum concentration of 147 IlgiL at SW-9 Chromium also was detected atthe Long Pond location (SW-12) with a concentration of255 IlgiL All chromium concentrations are below the performance criterion of 436 IlgL Mercury was detected at concentrations ranging from 000052 IlgL to 00016 IlgL in all of the surface water samples Three locations (SW-9 SWIO and SWI I) showed mercury concentrations above the performance criterion of 000 13 IlgL

In summary the surface water quality measured at the Site was above the performance criteria identified in the OampM plan at 3 of 15 downstream locations in Tannery Bay

3 Tannery Bay Monitoring Tannery Bay monitoring included visual inspection of the sediments Visual inspection of the Tannery Bay was conducted on June 132006 No areas of significant deposition or erosion of either the shoreline or sediments within Tannery Bay were noted during the inspection as compared to the 1999 Remedial Action During this sampling event the collection of sediment elevations and biomonitoring sampling were not collected because the GLNPO Legacy Act dredging work was scheduled to begin in the fall of2006

4 Wetland Monitoring

Based on visual inspection of the wetland area relative to the 1999 Remedial Action no changes to the environment were noted

AugustOctober 2008 OampM Report 1 Inspection and Maintenance of the Remedial Components

Inspection activities were performed at the Site on August 62008 and October 222008 Inspection activities were completed to document the integrity and stability of the shoreline protection bluff slopes and fences remaining after the remedial action The inspection included an examination ofthe former plant area shoreline berms Barren Zone western shoreline bluffs and general Site conditions to ensure the integrity of the remedial action components No requirements for any further maintenance activities were identified at the time of the inspection However it was identified during the October inspection that the footings for the viewing platfonn needed to be reinforced to ensure its continued safe use

2 Surface Water Monitoring Fourteen surface water samples were collected on August 6 and October 22 2008 from twelve surface water locations and analyzed for arsenic cadmium chromium lead low level mercury total organics and hardness The analytical results are presented in Appendix D A historical summary of all surface water monitoring events collected to date is presented in Appendix D for comparison and trend analysis

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The August 2008 surface water analytical results show that levels for arsenic cadmium chromium and lead were all well below their respective Site performance criteria Results of the low level mercury sampling revealed levels of mercury below or marginally close to the surface water criteria of 13 nanograms per liter (nglL) within Tannery Bay A sample collected from the on-site pond (Long Pond) revealed mercury levels nominally above the 13 ngiL performance criterion at 17 ngiL

The October 2008 surface water analytical results show that levels of all site-related COCs namely arsenic cadmium chromium lead and mercury were all well below their respective Site performance criteria with the exception of the sample collected from Long Pond which revealed a mercury concentration nominally above the 13 ngiL performance criterion with a concentration of 14 ngiL

Based on a review of the historical trends for all site-related COCs concentrations of all contaminants have generally improved with time to levels generally near or below the performance criteria

3 Sediment Monitoring Fifteen sediment samples were collected during the August 2008 sampling event Sediment samples were collected from fifteen locations and analyzed for total chromium mercury and percent solids

Based on a review of the 2008 sediment analytical results all reported concentrations for total chromium and mercury levels were well below the Site performance criteria of2500 mgkg for chromium and 05 mgkg for mercury

4 Tannery BaylWetland Monitoring CRA conducted a visual inspection of the entire Site including Tannery Bay and the wetland area on October 22 2008 Based on a visual walkthrough of the Tannery Baywetland areas no areas of erosion along the restored shoreline or within Tannery Bay were noted during the inspection There is evidence of continuing cattail growth behind the restored shoreline

Reuse and Redevelopment

In 2002 EPA drafted a Notice ofintent to Delete portions of the Site from the NPL Zones A B and E have met all cleanup goals and these areas meet delisting criteria The deletion process began in March 2002 with the development of a draft package submitted to MDEQ for concurrence However concurrence has been delayed pending a response from the PRP (owner of the Site) with their assertion that the Site meets MDEQ land use closure criteria and related administrative requirements for closure EPA is satisfied that cleanup standards have been met for Zones A B and E and proposed these areas for partial delisting from the NPL in 2003 However NPL delisting requires state concurrence and a response to MDEQs request for additional sediment data and implementation of restrictive covenants prior to concurrence with NPL delisting of these areas These zones are ready for reuse and redevelopment The Site is currently zoned for industrial use but residential standards were achieved in Zone A recreational in Zone B and a mix of residentialindustrial standards are present in Zone E

Since the completion of remedial activities the City expressed an interest in utilizing portions of the Site for their Citys Public Works Building The City Cyprus Mines Corporation EPA and MDEQ began discussions regarding the reuse potential and the necessary steps needed to accomplish end use goals These steps include partial NPL delisting of Zones A B and E a more detailed delineation of property owned by Cyprus Mines Corporation with the areas that have met cleanup standards and a legal agreement for property transfer to the City of Sault St Marie Michigan Discussions between the City and Cyprus Mines Corporation have taken place and a draft agreement regarding property transfer has been developed Discussions will continue as all parties are working together to achieve the redevelopment goals for the Site

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V Progress Since the Last Five-Year Review

The following is the protectiveness statement from the previous five-year review

The remedy implemented at the Cannelton Site for the upland soils (zones A B and E) currently protects human health and the environment as source materials have been removed and residual contamination is below the siteshyspecific cleanup levels that were established to ensure protection ofhuman health and the environment However there remain uncertainties with regard to long-term protectiveness ofthe remedy for zones C Wetlands and D Tannery Bay Insufficient data has been collected to date that would allow us EPA to make a determination of long-term protectiveness for these areas Laboratory geochemical studies were used to infer the stability of contaminants in wetland soils however the bioavailability ofthe COCs in wetland soils to wildlife receptors never was measured under fluctuating environmental conditions Therefore the long-term protectiveness ofthe remedy for wetland receptors remains uncertain Spatial analysis ofsediment deposition patterns during the past two decades support the assumptions in the Amended ROD that Tannery Bay is a net depositional areafor sediment and the wetlands ofTannery Point are encroaching on Tannery Bay over the areas ofcontaminated sediment However additional questions remain regarding the effectiveness ofthe observed sedimentation and wetland encroachment on the anticipated decrease in bioavailability ofsite COCs

Table 2 Actions Taken Since the Last Five-Year Review

Issues from Previous Review

Recommendations Follow-up Actions

Party Responsible

Milestone Date

Action Taken and Outcome

Date of Action

Deed Restrictions have not been implemented

Implement required ICs PRP June 2006 An ICIAP has been requested from the PRPs

August 2008

Redevelopment Reuse for the Site needs to be fmalized

Finalize Redevelopment Reuse for the Site

Property owner and City

June 2006 Ongoing Ongoing

Delisting process needs to be fmalized

Finalize Delisting process

EPAlMDEQ June 2006 Ongoing Ongoing

VI Five-Year Review Process

Administrative Components

The five-year review process began in August 2008 when EPA notifed MDEQ and the PRPs that a five-year review would be performed for this Site

Community Notification and Involvement

EPA will notify the community that a five-year review was conducted at the Site through a public notice ad that will run in a local newspaper

Document Review

Documents reviewed for this five-year review include the ROD ROD Amendment Remedial Action and Construction Completion Report OampM Plan Monitoring and Biomonitoring reports as well as other documents for the Site A complete list of documents reviewed is found in Appendix A

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During this five-year review process EPA reviewed all investigation reports and decision documents for the Site The ROD and ROD Amendment were reviewed to ensure that all requirements have been met and implemented during remediation activities Remedial Action and construction completion reports were reviewed for actions implemented at the Site OampM reports provided overall data and information collected in the last five years

Data Review

Historical data for the Site was reviewed along with post-construction data collected during the Operation amp Maintenance phase Sediment biological monitoring surface water and groundwater data were evaluated based on the monitoring reports submitted by CRA on behalf of the Respondent (Cyprus Mines) which were reviewed and accepted by EPA

Site Inspection

The site inspection for the Cannelton Industries Superfund Site was completed on June 172009 MDEQ Project Manager Mary Schafer and the previous Project Manager Bruce VanOtteren met with CRA staff Kyle Malo and Rob Bressan and Ron Buchanan of Freeport -McMoran Copper amp Gold on-site at 9am on June 172009 A boat tour ensued for optimal viewing of the shoreline After the boat tour all parties participated in a walkover of the Site including the Shoreline Barren Zone Long Pond and Square Pond A copy of the site inspection checklist is included in Appendix F

The Site consists of several areas The WetlandWooded area the Barren Zone Long Pond Square Pond Tannery Bay and the Beaver Pond area In addition to these areas the shoreline has a berm and there are FilterSocks staked in along part of the shoreline The following is a summary of the site conditions noted during the site inspection

1) The WetlandWooded area is in good condition 2) The former Barren Zone has been excavated filled regraded and covered with vegetation The vegetation appears to be stable and healthy with the exception of the ruts from the vehicle used to remove the monitoring wells from the Site A 24 garter snake and a large toad were observed on site Also observed were several ducks with ducklings and several birds 3) Long Pond is stable and well vegetated 4) Square Pond is mixed The west side of this pond is okay and has duckweed etc growing the remainder of the water body appears to be stressed The water is clear and is not as well vegetated as comparable water bodies in the immediate vicinity It may be advisable to check the water and sediment quality 5) Tannery Bay is clear and the excavated area is visible 6) The Beaver Pond area has areas with stained sediments and dead algae 7) The Shoreline has been stabilized with the rock berm installed as part of the Remedial Action FilterSocks were also evident although not functioning as well as designed There are a few plants rooting into it and it is stabilizing the shore but it is mostly underwater and has not vegetated as anticipated However the shoreline is stable

VII Technical Assessment

Question A Is the remedy functioning as intended by the decision documents

YES The remedy implemented is functioning as intended based on the ROD and ROD Amendment Excavation of contaminated soils and tannery materials from the Barren Zone (Zone B) has eliminated the direct contact exposure Surface water continues to be sampled along with sediments to evaluate the decrease in metal concentrations Groundwater was not affected by contamination or excavation activities Performance standards for groundwater have been met and surface water concentrations continue to improve

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In 2006 as part of a joint effort through the GLNPO Great Lakes Legacy Act the PRPs undertook voluntary remedial activities to remove impacted sediments within Tannery Bay and the Wetland Area on the Site EPAs Superfund program identified the sediment removal project as going beyond that required in the ROD and ROD Amendment Upon completion of the dredging project in the fall of2007 approximately 44000 cubic yards of impacted sediments from Tannery Bay and 800 cubic yards from the wetlands were dredged dewatered and disposed of in an off-site landfill Dredging contaminated sediment from the Tannery Bay and the Wetland Area removed about 1 million pounds of chromium and 70 pounds of mercury from the environment

Specific ICs in the form of restrictive covenants have not been implemented yet Other ICs are in place however such as the Citys current zoning (industrial use) Additionally access controls exist because a fence surrounds the former plant area and along South Street on the Site The fence along South Street remains to prevent trespassing only and was not required as part of the remedy There are currently no concerns with soils at the Site Warning signs were eliminated at the request of the City when remediation was completed

Since soils were cleaned up to meet specific land use requirements parcels meet standards for residential industrial andor recreational use Currently all the property is zoned for industrial use However the Citys 20-Year Master Plan for future use lists certain areas within the property for residential use Since completion of remediation activities the City of Sault Ste Marie began discussions with property owners to potentially acquire the property To aid in the process EPA proposed that certain parcels (Zones A B and E) could be delisted from the NPL Partial delisting will be completed once the MDEQ requirements are met

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of remedy selection still valid

YES The remedial action objectives in the ROD Amendment are still valid Remediation goals were based on Michigans Part 201 standards for future use The Site was divided in parcels to better define the areas for cleanup and future use Although the property area is currently zoned for industrial use cleanup activities achieved levels for residential use in Zone A recreational use in Zone B and industrial use in Zone E Cleanup standards were developed based on the Citys 20-Year Master Plan for future uses in the area

Question C Has any other information come to light that could call into question the protectiveness of the remedy

NO No other information that could affect the protectiveness of the remedy was found as a result ofthis review

Technical Assessment Summary

This review found the remedy implemented at the Site to be working as intended by the ROD and ROD Amendment

VIII Issues

Table 3 Issues

Issues Affects Current Protectiveness

(YIN)

Affects Future Protectiveness

(YIN)

EPA is pursuing the implementation of restrictive covenants Use restrictions in the form of zoning are in place and currently effective

N Y

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IX Recommendations and Follow-up Actions

Table 4 Recommendations and Follow-up Actions

Issue Recommendations

and Party Oversight Milestone

Affects Protectiveness

(YIN)Follow-up Actions

Responsible Agency Date

Current Future

N YEPA is pursuing the An ICIAP will be PRP EPA February implementation of submitted to EPA for 2010 restrictive covenants review and approval

The ICIAP will propose to implement the ICs conduct evaluation activities as needed including planning for long-term stewardship If needed EPA will prepare an IC Plan to plan for the additional IC activities

In addition to the issue and recommendation listed in the tables above the following issue and recommendation was identified during this review but does not affect the protectiveness of the remedy

bull The decision document needs to be modified to eliminate the requirement for biological monitoring An Explanation of Significant Differences will be issued documenting any modifications to the decision document

X Protectiveness Statement(s)

The assessment of this five-year review for the Cannelton Industries Site found that the remedy is functioning as intended and is protective of human health and the environment in the short term Based on the Site inspection and data no inappropriate land or groundwater use was observed EPA is not aware of site or media uses which are inconsistent with the stated objectives of the ICs and cleanup goals Access is further restricted by use of fencing Long-term protectiveness at the Site requires continued compliance with use restrictions to assure that the remedy continues to function as intended To assure proper maintenance and monitoring and effective ICs long-term stewardship procedures will be reviewed and a plan developed The plan will include a provision for regular inspection of ICs at the Site and annual certification to EPA that the ICs are in place and effective

XI Next Review

Because the remedy implemented at the Site leaves certain parcels of the Site at levels that will not allow for unlimited use and unrestricted exposure future five-year reviews are required for the Site The next review will be conducted five years from the signature date of this review

31


2


Table of Contents


Executive Summary 7
















3

Figures


Appendices





4


List of Acronyms


5


6

Executive Summary




7


8













Tri erin


9


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31


Table of Contents


Executive Summary 7
















3

Figures


Appendices





4


List of Acronyms


5


6

Executive Summary




7


8













Tri erin


9


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31

Figures


Appendices





4


List of Acronyms


5


6

Executive Summary




7


8













Tri erin


9


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31


List of Acronyms


5


6

Executive Summary




7


8













Tri erin


9


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31


6

Executive Summary




7


8













Tri erin


9


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31

Executive Summary




7


8













Tri erin


9


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31


8













Tri erin


9


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31













Tri erin


9


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31


Issues







10


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31


I Introduction








11

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31

II Site Chronology



1978 June 11 - July 1 1988

May 25 1989

May 1989 - April 1990






12

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31

June 8 2004



III Background







13










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31










14










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31










15



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31



Initial Response







16




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31




Soils Sediments


3600 10300

341 328000 10 100

25

296 202 261

40000 603 23





17

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31

IV Remedial Actions

Remedy Selection





18















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31















19









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31









20













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31













21









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31









22



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31



























23











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31











24







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31







EPA for review





25












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31












26










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31










27







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31







Party Responsible

Milestone Date


Date of Action



August 2008













Document Review


28


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31


Data Review


Site Inspection







29










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31










VIII Issues

Table 3 Issues


(YIN)


(YIN)


N Y

30








Current Future







XI Next Review


31








Current Future







XI Next Review


31