EPA Region 5 Records Ctr.

290511

0. . . . .

WORK PLAN

TAR LAKE SITE Mancelona, Michigan

Remedial InvestigatioiVFeasibility Study

WA No. 021-RICO-0571/ Contract No. 68-W6-0025

May 18,1999

Contents

Section Page

Introduction 1 ** General 1

Project Background 3 Purpose 3

Project Approach 5 Conceptual Site Model 5 Site Background and Identification of Areas of Concern 6 Areas of Concern — Data Needs Evaluation 7

Iron Production Area 7 Creosote Area 12

* Nelson Lake 14 Peckham Lake 16

. East Tailing Area 17 * Tar Lake Area 18

Retort and Chemical Production Area 20 Drainage Ditch Area 22

' Groundwater 23 Surface Water Discharge Area 29 Background SampUng 31

Scope of Work and Task Descriptions 32 Task 1 — Project Planning and Support (PP) 32

Subtask 1.1 RI/FS Work Plan 32 Subtask 1.2 Quality Assurance Project Plan 33 Subtask 1.3 Project Management 33 Subtask 1.4 Develop Health and Safety Plan (HASP) 36 Subtask 1.5 Develop Sampling and Analysis Plan 36

Task 3 —Data Acquisition 36 Subtask 3.1 Field Set-Up 36 Subtask 3.2 Mobilization and Demobilization 37 Subtask 3.3 Field Investigation 38 Subtask 3.4 Site Characterization Technical Memorandum 43

Task 4 —Sample Analysis 43 Task 5 —Analytical Support and Data Validation 44

Subtask 5.1 Laboratory Management 44 Subtask 5.2 Validate Data 45

Task 6 —Data Evaluation 45 Task 7 —Risk Assessment 48

Subtask 7.1 Risk Assessment Approach Memorandum 48 Subtask 7.2 Ecological Risk Assessment 49 Subtask 7.3 Human Health Risk Assessment 50

Task 8—Treatability Study and Pilot Testing 53 Task 9 —Remedial Investigation Report 53

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CONTENTS

Subtask 9.1 RI Report 53 Task 10 —Remedial Altematives Screening 55

Subtask 10.1 Prepare Technical Memorandum 55 Task 11 —Remedial Altematives Evaluation 56

•" Task 1 2 - F S Report 57 Subtask 12.1 Prepare FS Report 57

Task 16 —Work Assignment Closeout 58 Subtask 16.1 Package and Return Documents to Government 58 Subtask 16.2 Prepare Closeout Report 58

Project Management 59 Project Organization 59 Schedule Contiol 59 Cost Contiol 60 Coordination with the USEPA and Ml DEQ 60 QuaUty Contiol 60

^ Project Schedule 61 References 62

^ Appendix

A Resumes

A Figures Page

1 Site Location Map 3 2 Site Features Map 3

A 3 Conceptual Model of Hydrogeology and Contaminant Flow 6 4 Antiim t o n Company 1897 Plat Map 8 5 1929 Sanbome Map 8

A 6 Iron Production and Creosote areas Sample Locations 10 7 Nelson Lake —SampUng Locations 15 8 Peckham Lake Sample Locations 16

A 9 East TaUing Area Sample Locations 18 10 Tar Lake Area Sampling Locations 19 11 Chemical Production Sampling Locations 21

^ 12 Drainage Ditch Investigation Area 23 13 Onsite Monitoring Well Locations 40 14 Offsite Monitoring WeU Locations 40

A 15 CH2M HILL Project Organization 59 16 Project Schedule 61

Tables

1 Summary of Tar Lake 2 2 Primary Materials 7

^ 3 Sample Matrix/Analyte/Estimated Number of Field and QC Samples 11 4 Estimated Analytical Costs 44 5 Comparison of P-Level to E-Grade for Key Personnel 59

^ 6 Summary of CH2M HILL DeUverables 61

MKE/991030001.DOOV2

Acronyms and Abbreviations

AIC AOC ARARs bgs BNA CLP DB DQO DUP EB ERB ERT FSP GC/MS GFAA

gps kg L MDEQ MDL

^ig mg MS MW NPL ND OU PAH PRP PTEA QA QAO QAP QAPP QAU QC RA RCRA RD RI/FS ROD RPM

Artiian Iron Company Administiative Order of Consent AppUcable or Relevant and Appropriate Requirements Below Groimd Surface Base-Neutial-Acid Extiactables (Semivolatile Organics) Contiact Laboratory Program Deep Boring Data QuaUty Objective DupUcate Equipment Blank Emergency Response Branch Emergency Response Team Field SampUng Plan Gas Chromatography/Mass Spectiometiy Graphite Furnace Atomic Absorption gallons per second Kilogram Liter Michigan Department of Environmental QuaUty Method Detection Limit Microgram Milligram Matrix Spike Monitoring WeU National Priorities List Nondetect Operational Unit Polynuclear Aromatic Hydrocarbons Potentially Responsible Party Preliminary Endangerment Assessment QuaUty Assurance QuaUty Assurance Officer QuaUty Assurance Plan QuaUty Assurance Project Plan Quality Assurance Unit QuaUty Contiol Remedial Action Resource Conservation and Recovery Act Remedial Design Remedial Investigation/Feasibility Study Record of Decision Remedial Project Manager

SAS Special Analytical Services SD Matiix Spike Duplicate SM Site Manager SOP Standard Operating Procedure SOW Statement of Work SPLP Synthetic Precipitation Leaching Procedure SVOC Semivolatile Organic Compound TB Trip Blank TCLP Toxic Characteristic Leaching Procedure TOC Total Organic Carbon USEPA United States Environmental Protection Agency VOC Volatile Organic Compound

Introduction

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General This Work Plan defines the scope of activities, schedule, and budget for accompUshing the Remedial Investigation/FeasibiUtyStudy (RI/FS) for the Tar Lake site in accordance with Work AssignmentNo. 021-RICO-0571 Statement of Work (SOW).

Site investigation activities, removal actions, and remedial tieatabiUty studies have been conducted by the potentiaUy responsible party (PRP), Michigan Department of Environmental QuaUty (MDEQ), the USEPA Region V Superfimd Division, the USEPA Region V Emergency Response Branch (ERB), and the USEPA Emergency Response Team (ERT). The majority of the historical information relates to the actual Tar Lake and the on and offsite groundwater. Most of this information relates to Tar Lake is no longer relevant as Tar Lake has been removed, but the groundwater information and applicable Tar Lake information will be used on this RI/ FS. The submittals generated from the aforementioned activities and reviewed in support of this project are Usted in Table 1. The data quality of the; historic data wiU be evaluated prior to use on the RI/FS.

The objectives of the RI include:

• Adequately characterize site and through the use of existing information supplemented with the minimum amoimt of additional information, produce a complete RI report

• Complete an ecological and human health risk assessment to evaluate and quantify for the presence of risk and if present, the magnitude of risk under an industiial, commercial, and recreational scenario

The objective of the FS is:

• Identify and characterize, through the use of historic information and the information coUected in support of the RI report, produce a feasibility study that will eliminate, reduce or contiol risks to human health and the environment.

The RI/FS activities identified in the SOW are the foUowing:

^ Task 1 (PP) - Project Planning and Support Task 3 (Fl) - Data Acquisition (Field Investigation) Task 4 (SN) - Sample Analysis

^ Task 5 (AN) - Analytical Support and Data Validation Task 6 (DE) - Data Evaluation Task 7 (RA) - Risk Assessments Task 8 (TT) - TreatabiUty Study Task 9 (RR) - Remedial Investigation Report Task 10 (RS) - Remedial Altematives Screening

^ Task 11 (RE) - Remedial Alternative Evaluation Task 12 (FS) - Feasibility Study Report Task 16 (CO) - Work Assignment Closeout

MKE«1030001.DOC/V2

INTRODUCTION

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TABLE 1 Summary of Tar Lake

Invest igat ion Type

Draft Interim Risk Assessment

Remedial Action Master Plan

Preliminary Investigation

Terrain Conductivity Survey

Preliminary Endangerment Assessment

Evaluation of Compounds Present In Groundwater

Toxicological Evaluation and Risk Assessment for Compounds in Groundwater

Site Investigation

Phased Feasibility Study

Feasibility Study on Tar Lake

Draft Focused Feasibility Study

Pre-Design Report

Draft Proposed Tar Removal Work Plan

Generated By

USEPA

CH2M HILL

EnSafe

EnSafe

EnSafe

Gradient Corporation

Gradient Corporation

Gradient Corporation

Gradient Corporation

USEPA

EnSafe

EnSafe

EnSafe

Date

April 1981

April 1984

April 1985

1986

October 1988

April 1989

May 1989

March 1990

October 1990

March 1992

August 1993

January 1995

August 1997

Area

Tar and groundwater

Site Wide

On and offsite groundwater

On and offsite groundwater

Onsite Groundwater

Site Groundwater

Tar Lake Site

Onsite groundwater

Tar Lake

Tar Lake Tar

Offsite groundwater

Tar Lake

Tar Lake

Appl icab le In format ion *

Mean concentrations and %*' % of the mean concentration for onsite groundwater and the tar.

Limited historic offsite PW metal, phenol, and PAH results

8 onsite groundwater well boring logs and limited metals results. Private well physical characteristics, limited field results, taste and odor information, metal results from select PWs, results for select organics from select PWs

Historic groundwater plume delineation information.

Historic onsite MW metal results and chemical characteristics of select akiylphenols

Potential phenol sources to groundwater. Municipal landfill leachate pond physical and chemical characteristic's.

Limited amount of risk information on the dimethylphenols.

•

Analytical results for the groundwater in the MWs located beneath Tar Lake. Analytical results included VOCs, SVOCs, Metals, and Phenols

Metal results for the groundwater immediately beneath Tar Lake. Calculated [1] 50s and risk factors for the Alkylphenols.

Tar Lake remedial options and tar characteristics

Private wells depth of well, taste and odor characteristics. MW DB1-DB4 well location, depth and screening infonnation

Tar Lake contaminated soil nature and extent. Onsite well physical infonnation. Soil treatability altematives

TCLP and metal results for the groundwater immediately beneath Tar Lake. Offsite well survey form.

Applicable information does not necessarily mean it is of sufficient quality to used in this RI/FS

MKEy991030001.DOCA/2

INTRODUCTION

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Project Background The Tar Lake site, located in Antiim County, Michigan, occupies over 200 acres just east of Highway 131, north and south of Elder Road, about 1 mile south of Mancelona (Figure 1). The site is the former location of an iron manufacturing facility that produced iron via the charcoal method. The primary contaminant source at the site is a 4-acre area of tar and tar-contaminated soUs that reached depths of 27 feet (Figure 2). This area typically contains ponded water —the feature from which the "Tar Lake" name is derived. A USEPA ERT removed most of the tar from this 4-acre site. The RI will identify the remaining areas of tar and tar contaminated soil. Other current site features include slag pUes, limestone piles, one sludge pile on the west side of Tar Lake, several existing buildings, building foundations, two kettie lakes, a municipal landfill, and the remains of tank supports and cooling water ditches. In September 1983, Tar Lake was listed on the National Priorities List (NPL).

Under the April 21,1986 Administiative Order on Consent (AOC), Fifty-Sixth Century, the PRP and current property owner, was to conduct a Remedial Investigation/Feasibility Study (RI/FS) at Tar Lake. Conducting the RI in two phases was proposed in the PRP Work Plan. The first phase was the development of a preliminary endangerment assessment (PEA), which would include limited groundwater sampling. The second phase, yet to be conducted, will be a more detailed investigation based on the findings and results of the PEA. USEPA found the October 4,1988 Draft PEA to be deficient and did not approve it.

Additional work at the site was performed by the PRP to evaluate the nature and extent of contamination in the soil and groundwater beneath Tar Lake. The sampling and analyses

4l definitively established a relationship between the tar and the groundwater.

Based on taste and odor observations in groundwater monitoring weUs and in residential weUs, as reported by residents and confirmed by MDEQ, the contamination in groundwater related to the site extends at least 3.5 miles downgradient from the site. USEPA divided the remediation of the site into two operable units (OUs) because the tar and tar-contaminated soils are a continuing source of contamination to the groundwater, which is a threat to the environment as weU as a threat to human health. OUl is being addressed by the remediation of Tar Lake through source removal and onsite groundw^ater treatment. OU2 will address the areas of the site not yet investigated and will address the long-term action for groundwater.

Purpose The purpose of this project is to assess and address the human health and ecological risks of OU2, if any, and return this site to beneficial reuse.

The RI wUl be completed using the minimum amount of data necessary to characterize and define the extent of contamination in OU2. The RI wiU quantify risk to determine acceptabiUty under potential industiial, commercial, recreational and / or residential reuse scenarios. The RI will be developed to maximize the use of existing information, and wiU focus additional data coUection and evaluation efforts on completion of the characterizationand nature and extent evaluations of those areas lacking complete information.

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INTRODUCTION

The FS will propose and evaluate remedial altematives that will eUminate, reduce or contiol risks to human health and the environment such that the site can be returned to beneficial reuse.

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MKE/991030001.DOOV2

Project Approach

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This Work Plan has been developed to identify and describe the activities necessary to complete the RI/FS for OU2. The foUowing approach has been developed to focus efforts and complete this RI/FS effectively and efficiently:

• Maximize the use of existing information. Field investigations and tieatabUity testing have been conducted at the site (Table 1). This existing data has been reviewed and used to build a preUminary conceptual model which shows where adequate information exists and where additional information needs to be provided to complete nature and extent evaluations and aUow development and evaluation of remedial alternatives..

• Focus final investigation and evaluation efforts on key areas of concern. Potential investigation areas and additional information needs have been identified to complete the site characterization efforts.

• Develop a sound conceptual site model. The site model will be a synthesis of the site characterization and nature and extent data into a clear and informative picture of site conditions. This conceptual site model will be used to complete the feasibility study necessary to identify the appropriate remedial action for OU2.

If the contiactor identifies that the risks are found to be more significant than expected during the field investigation or during any other portion of this study, the WAM wiU be consulted and the ramifications of the discovery will be assessed. Depending on the risk, the project could initiate a change order that aUows for further investigation, or it could be investigated as part of the pre-design to the remedial phase of this site, or it may be decided that the risk warrants no further action.

The USEPA WAM wiU work in conjunction with the State of Michigan Site Manager to ^ assess if the needs of both regulating bodies are being met. In support of this, CH2M HILL

wiU provide the foUowing submittals to the State of Michigan on the same schedule as they are supplied to the EPA; the Work Plan, the Risk Assessment Technical Approach

gl Memorandum, the Site Characterization Memorandum, the RI Report including the risk assessments, and the FS Report.

** Conceptual Site Model The conceptual site model integrates and presents site information (source areas,

• contaminant release mechanisms, and environmental pathways of potential concern). When properly developed it is valuable resource for understanding site conditions and identifying potential actions. A conceptual site model can show how physical conditions at a site

•• tianslate into migration mechanisms and potential exposure pathways. When nature and extent information and potential receptor locations are superimposed on those physical conditions it is easier to see whether or not a pathway is complete and also easier to

•• evaluate the extent of potential risk. For this project, a prelimina:ry conceptual site niodel

MKEy991030001.DOCW2

PROJECT APPROACH

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was developed using existing information. A comprehensive site model will be developed from the additional site investigation and feasibility study.

Site Background and Identification of Areas of Concern The site history and previous site investigations indicate that the majority of the native site soil is covered by slag (the waste left after the melting of ores and the separation of iron from them). Historic TCLP results indicate that the slag does net leach contaminants at rates sufficient to contaminate soils or groundwater. It is not anticipated that slag will present unacceptable risks. The soils beneath and around the chemical manufacturing and tar disposal areas are potentiaUy contaminated with process residual. Contamination detected to date is consistent with affects that would be expected based on what is known about historic disposal practices and spills. In the area of Tar Lake, PAHs and alkyl phenols contamination has been detected throughout the vadose zone soil down to the water table. The majority of soU contamination is believed to be a result of tlie slow leaching of dissolved phase contaminants from tars disposed on the ground surface in a surface depression. Although the tars are denser than water, they are too viscous to penetiate the soUs appreciably. An LNAPL was also identified in the area of the former chemical production area that was Ukely the result of spills or leaks of wood liquor or chemical product. The dissolved phase contaminants then migrate in the groundwater downgradient horn the site. It is postulated that the bacteria feeding on the contaminant mixture quickly uses up the available oxygen creating a reduced environment in the groundwater plume. This type of reducing environment would mobilize the naturally occurring iron allowing it to tiavel in the grotmdwater long distances (greater than 3.5 miles). This mechanism would explain in part why past investigations have detected iron in groundwater for such a long distance downgradient front past process areas. The extent of phenol, PAH, and other chemical/elemental groundwater contamination has not been defined to date. The preliminary hydrogeologic conceptual site model cross section is illustiated in Figure 3. The primary materials to be investigate by this RI/FS and their chemical constituents are provided in Table 2.

Information about the site history and previous site investigations were used to develop areas of concern (AOC). A "data needs evaluation" has been conducted to determine the

H extent to which these areas of concern require investigation. This evaluation was completed through the following process:

• Identify the size, known features and condition of each AOC

• Review the industiial process used in the area and identify likely contaminants generated by the process

• Identify the hypothesis on risk

• Summarize how risk will be evaluated

• Estimate matiices, number of samples, and analytes to be sampled and analyzed, and sample purpose/rational

• Summarize assumptions about the area and the information used in supporting the analysis of this area.

MKEy99103000l.DOOV2

Perched Water

Saloon Creek

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LEGEND.

Water Level

Well Screen

Site-related contaminant plume

^ ^ ^ ^ ^ ^ Clayey Unconsolidated Deposits

FIGURE 3 Conceptual Model of Hydrogeology

and Contaminant Flow Tar Lake RI/FS Work Plan

E151995.PP.01 Conceptual Model 4-12-99111 CH2IVIHILL

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PROJECTAPPROACH

TABLE 2 Primary Materials

Material Potentially Affected AOC

Chemical Constituents Comment

Tar Creosote Organics - the majority of tar is nonvolatile Area stable heavy organic molecules, often

contains semivolatile compounds and very Tar Lake small amounts of volatile compounds leftover Area from production. These volatile compounds

can leach or desorb into the soil.

Tar is not very mobile in any natural environment. It is also insoluble in water.

Creosote

Slag

Creosote Area

Chemical Production Area

Site Wide

Pyroligneous Chemical Wood Liquor Production

Area

Acetate of Lime

Retort and Chemical Production Area

Metals - Metals are often bound w/ithin the tar

Organics - frequently contains substantial amounts of naphthalene, anthracene, and phenols. It is composed of hydrocarbons with boiling points between 200 and 400 degrees Celsius.

Metals inert

typically bound and the material is

Contains volatile organic compounds, poly-aromatic hydrocarbons, phenols, pyridines, ammonia, cyanide, thiocyanate, sulfide compounds, methanol and acetone.

This material is mostly composed of calcium acetate used in the manufacturing of acetone, acetic acids, acetates, and iron.

Creosote is more mobile than tar and will travel downwards in sandy soils. It is practically insoluble in water, but will dissolve in trace quantities.

TCLP data indicates that the slag does not leach the metals test for at concentrations slightly greater than the reporting limits. While multiple sources of ore were used at the production facility, the metals present in the slag, and their leachable concentrations, are assumed to be equivalent between the ores.

The liquor is collected as the off gases from charcoal production are condensed. It is soluble in water in trace quantities, and can desorb and leach into soils. The liquor was also distilled to make acetone and methanol.

This compound is soluble in water. It Is also easily biodegradable. It is not a major contaminant of concern because most of it is expected to have biodegraded over the last fifty years.

Areas of Concern—Data Needs Evaluation

Iron Production Area

The amount and type of data needed to adequately characterize this area has been determined by physical observation and the evaluation of historical site operations, preliminary estimates of the significance of the likely risks, as well as data needs in

MKE/991030001.DOC/V2

PROJECT APPROACH

^ evaluation of potential remedial actions. There is no known soil or groundwater data for this area.

. Historical Operations and Contaminants of Concern

The Iron Production Area includes the portion of OU2 north of Elder Road with the exception of the Creosote Production Area and Nelson Lake (see Figure 1). These latter two

• areas are discussed separately below. The Iron Production Area is about 15 acres (1,100 by 600 feet) and is the oldest operational area of the site. Iron production using charcoal-produced onsite began here in 1882. An 1897 plat map (Figure 4) shows the location of the

•• earUest facUities. These included:

• 34 charcoal kilns gl • a large stock house

• the iron furnace, air preheat ovens, pig iron casting room, air blower engine room, steam boUer room and machine shop

** The 1929 site fire protection Sanbome maps (Figure 5) shows sirrdlar facUities although the buUdings are larger and the charcoal kilns are no longer present. Additional buildings north of Elder Road shown on these maps include the machine shop, blacksmith shop, locomotive engine house, and the acetate dryer building.

The charcoal kUns were arranged in 2 rows paralleling the western bluff of Nelson Lake. ig The two rows of kUns began about 50 feet north of Elder Road and ended about 700 feet

north of the road. Based on an engraving in the July 10,1890 Mancelona Herald, the kilns were each about 15 feet in diameter and 15 feet in height. The kilns were used to heat

i l hardwood in an oxygen-limited environment to produce charcoal. Though typical practices of that time period and historic drawings do not show any means for it, it is likely that offgases were not coUected from these kilns. This would Umit the amount of contamination

g | associated with the kUns because most contamination would be typically associated with chemicals condensed from the offgases. Some contamination could be present as a result of smaUer scale condensation on the insides of the retorts each time the retort is allowed to

gl cool to remove the charcoal and recharge with wood. Therefore, the contaminants expected to be present in this location are largely those associated with retorting wood (PAHs, VOCs, phenols, pyridines, ammonia, cyanide, thiocyanate and suUide compounds).

The stock house shown on the 1897 plat map (Figure 4) was a covered building for storage of iron ore and possibly Umestone. It measured about 500 feet long and 90 feet wide. It was located adjacent to the rows of kiUis. The later Sanbome maps of 1926 and 1929 show an ore stock house slightly larger (90 by 550 feet) located about 100 feet west of the earUer stock house location. Contaminants would not be expected to be associated with ore or limestone storage other than naturaUy occurring inorganic elements present in the ore and Umestone.

The iron furnace, air preheat ovens, pig iron casting room, air blower engine room, steam boUer room and machine shop were all located in the cential portion of the Iron Production

m Area. The air preheat ovens and the boilers, used to generate steam for the air blower steam engines, were likely heated with charcoal or coal and possibly wood tar (after 1910 when sealed retorts for offgas recovery and condensation were in use). The furnaces were charged

m with charcoal, iron ore and Umestone in the production of pig iron. The iron was routinely tapped and allowed to cool and harden in a sand bed on the floor of the casting room. Slag (the remaining minerals combined with limestone) was also tapped and routed to a pit were

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PROJECT APPROACH

it was allowed to air cool. It was later excavated and disposed at locations throughout the site. It appears slag covers much of the western bluff and sideslopes of Nelson Lake. Widespread contamination is not expected to be associated with the cential area of the Iron Production Area other than the naturally occurring inorganics originally present in the ores. WhUe fuels such as charcoal, coal and tars were used in this area, they were burned and would not be expected to leave behind organic contaminants. Organic contaminants could be associated with the machine shop, although during the period of operation, the solvents used were the more biodegradable petioleum based solvents. Chlorinated solvents were not in use at the time.

The additional buUdings shown on the later Sanbome maps such as the blacksmith shop and the locomotive engine house also would not be expected to be significant sources of existing organic contaminants for similar reasons. The acetate dryer building was used for the storing sacks of dry acetate of lime. WTiile some occasional spillage of dry acetate of Ume may have occurred in this building, it is not expected to be present at concentiations of concern in soil or groundwater because of the relatively small quantities potentially spilled, acetate is also easUy biodegraded, and over 50 years have elapsed since the building was demoUshed in the late 1940s.

Data Quality Objectives

The data quality objectives for this area are:

• Collect data on organic and inorganic constituents in the surficial soils that are of sufficient quaUty to support the risk assessment. Note: organic compounds are not expected to be of concern in this area. The evaluation of historical operations and wastes produced indicate that the organic contamination that could have been produced are not expected to remain in the soUs of the Iron Production Area.

• Delineate and record the extent of charcoal and tar distiibution.

Inorganics present in the original ore and limestone may be present throughout the 15-acre area, either from remnants of the ore or from the slag. In general, the inorganic compounds would not be substantially different in concentiations than that present in the ore, and, therefore, are expected to be of minimal risk. However, since naturally occurring levels of arsenic can be a health risk concern, it is considered important to document the concentiations of inorganics present in the surficial soils.

WTien developing DQO's for this area, potential exposure scenarios must also be considered. Future land use of the Iron Production Area is anticipated to be industiial, commercial, or recreational. Exposures to groundwater are not expected to result in significant risk based on the much lower potential for contaminant leaching to groundwater compared to the portion of the site south of Elder Road. Because the groundwater plume emanating from Tar Lake is only marginally exceeding drinking water MCLs, groundwater contamination from the Iron Production Area is expected to be below MCLs. Recent toxic characterization leaching procedure (TCLP) analysis of slag shows leachate below detection levels for nearly aU inorganics.

To delineate the extent of residual tar or charcoal, most of the information collected will be in the form of visual observation. Additional data for evaluating remedial actions will likely be limited to delineating the extent of materials and wastes used/produced in this area that

MKB991030001.DOC/V2

PROJECT APPROACH

may have had an environmental impact. The extent of tar or charcoal can then be used to delineate the area of potential remediation if unacceptable risks (as determined by the surface soil sample analytical results and risk assessment) are found.

Site Investigations

Because minimal risks are expected to be associated with the Iron Production Area, a focused sampling effort is planned for site characterization and risk assessment. The initial data wUl be evaluated, and, if the risks found based on these limited samplings are more significant than expected, additional sampUng for more precise evaluation of contaminant extent and risks will be considered.

Surficial soU samples consisting of composites from the 0 foot to 2 feet below ground surface (bgs) interval will be collected from a total of 12 locations. The 12 locations are shown on Figure 6 and summarized below.

• One sample for inorganic analysis from the former casting room (IPOl)

• Two samples for inorganic analysis from the former ore storage house (IP02 and IPOS)

• Three samples for inorganic analysis from the area of the former stock house and slag disposal (IPOS tiirough IP06)

• Three samples for total and synthetic precipitation leaching procedure (SPLP) inorganic and organic analysis along the former alignment of the charcoal kUns (1P07 through 1P09)

• Three samples for total and SPLP inorganic and organic analysis along the base of the western Nelson lake bluff (IPIO through 1P12)

The composited soil samples wUI consist of the material from the 0 to 2-foot interval that wiU pass through a 0.5-inch sieve. Physical descriptions of the samples will be recorded as the samples are composited. If possible, the approximate percent of ore, slag, charcoal and tar in the samples wiU be identified. Investigations of soil below 2 feet bgs are not planned because of the Umited leachabUity of contaminants and the expected minimal contamination. Table 3 summarizes the samples to be collected and the analysis to be performed.

In addition to the surficial soil sampling, the areas containing surficial ore, charcoal, and tar, if present, will be delineated visually using hand augers and/or shovels. The presence of tiees together with branch and leaf litter currently obscures the identification of materials on the surface. A 2-day effort for a crew of 2 people is planned for the visual identification task.

A limited investigation of groundwater contamination is planned and will be addressed on a site wide basis. The groundwater data needs evaluation is provided later in this section.

MKEy991030001.DOCA/2

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^ H !

I f ^• I 111

P L A N ^ N -̂' I

I I

I I

i ' r k 1 iH'* '̂'

I^^r

" / T ^

Id*'' ^ P p / v o "

LEGEND.

O Surface Soil Sample

® Subsurface Soil Sample

Tjs£.e_

FIGURE 6 Iron Production and

Creosote Areas Sample Locations Tar Lake RI/FS Work Plan

~ CHZMHILL

Table 3 Sample Matrix, Analyte, Number of Field and QC Samples

Area

ESackground

Creosote Area

Discharge Zone

East Tailings Area

Groundwater

On Si's Wells

m\i-tfK

Saloon Creek

Off Sire: IP Area

PWs

DB-3

MWIA, DB-3,

Iron P'oduction

Nelson Lake

Peckham Lake

Retort and

Chemical

Production

Area

Tar Lake Area

Matrix

Surface Water

Sediment

Groundwater

Soil

Subsurface Soil

Subsurface Soil

Subsurface Soil

Subsurface Soil

Surface Soil

Surface Soil

Surface Soil

Surface Soil

Tar

Tar

Tar

Tar

Sediment

Sediment

Surface Water

Surface Soil

Surface Soil

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Soil

Soil

Soil

Soil

Soil

Sediment

Surface Soil

Surface Water

Sediment

Surface Water

Groundwater

Subsurface Soil

Subsurface Soil

Subsurface Soil

Subsurface Soil

Surface Soil

Surface Soil

Surface Soil

Surface Soil

Slag/Soil

Slag/Soil

Slag/Soil

Slag/Soil

Analytes

VOCs, SVOCs, metals, hardness

VOCs, SVOCs, metals, TOC, Grain Size

Groundwater Parameters

VOCs, SVOCs, metals

metals

SPLP metals

SPLP VOAs and SVGAs

VOAs, SVGAs

metals

SPLP metals

SPLP VOAs and SVGAs

VOAs, SVGAs

metals

SPLP metals

SPLP VOAs and SVGAs

VOAs, SVGAs

metals, phenols, TOC

metals, phenols, TOC, grain size

metals, ammonia, hardness, phenols

metals

SPLP metals

Groundwater Parameters

Groundwater Parameters

Groundwater Parameters

Groundwater Parameters

Groundwater Parameters, odor, taste, alkyl

VOC, SVOC, Iron, Ammonia

TOC

metals

SPLP metals

SPLP VOAs and SVGAs

VOAs, SVGAs

VOAs, SVGAs, metals, TOC, grain size

VOAs, SVGAs, metals

VOAs, SVGAs, metals, hardness

VOAs, SVGAs, metals, TOC, grain size

VOAs, SVGAs, metals, hardness

LNAPL Organics

metals

SPLP metals

SPLP VOAs and SVGAs

VOAs, SVOAs

metals

SPLP metals

SPLP VOAs and SVOAs

^OAs, SVOAs

metals

SPLP metals

SPLP VOAs and SVOAs

\IOAs, SVOAs

rotals

Field

Samples

10

10

£i

10 •3

3

3

3

4

4

4

4

3

3

3

3

7

3

3

3

3

8

4

2

12

20

4

3

12

6

6

6

5

1

1

6

2

1

6

6

6

6

11

11

11

11

5

5

5

5

281

QC Dup EB IMS SD TB

1 1 1 1 1

1 1 1

1 1 1

1 1 1 1 1

1 1

1 1 1

1 1 1 1

1

1 1 1 1 1

1 1 1 1 1

1 1 1

1 1 1 1

1 1 1 1 1

1 1 1

1 1 1

1 1 1 1 1

2 2 1 1 2

1 1 1 1

1 1 1 1

1 1 1

1 1 1 1 1

1

3 3 2 2

3 3 1 1

3 3 2 2 3

3 3 1 1 3

1 1

1 1 1 1

1 1 1

1 1 1 1 1

1 1

1 1 1 1 1

1 1 1

40 41 21 21 28

Total

15

13

8

15

5

3

6

3

8

4

5

9

8

3

6

3

11

3

8

3

3

0

11

7

2

17

28

4

4

16

10

6

6

8

1

1

11

3

1

16

14

19

17

13

15

14

16

7

5

10

8

432

"Groundwater suite of analytes is composed of VOAs, SVOAs, ammonia, ON, HON, sulfite, sulfate, H2S, metal BOD, COD, Chlorides, total & dissolved metals (Fe, Mn, As), reduction potential, conductivity, possible other natural attenuation parameters.

Table3.xls 5/18/99

file:///IOAs

PROJECT APPROACH

Key Assumptions

Several assumptions were made that are inherent in the data qiiality objectives and the investigation plan for the Iron Production Area. These are:

• Operations and faciUty locations are/were limited to those identified on the available maps (summarized above).

• Future land use wUl either be industiial, commercial, or recreational.

• Contaminant affects to groundwater are expected to be minimal because of Limited leachabiUty of inorganics and limited presence of organic contaminants in soU.

• Future onsite groundwater use will be restiicted.

Creosote Area

Historical Operations and Contaminants of Concern

The Creosote Area has been assigned a preUminary size of 1 acre and encompasses reported (not confirmed) tar contamination. It surrounds the former creosote production area located north of Elder Road (see Figure 2) that appears to have been about 25 feet by 130 feet. The area appears to have included a building and 10 circular stiuctures that were likely tar and creosote storage tanks. It is unclear when creosote production began, but it would have been after 1910 when sealed retorts were first used at the Antiim Iron Works (The Mancelona Area Centennial Commission, The Mancelona Area 1872-1972). The production area may have operated until 1945 when the Antiim Iron Works shut down. The creosote was likely produced by refining the tar that remained from the condensed retort offgases. The waste from this operation would be a heavier, more dense tar. The "Refinery" and the "Tar Plant" are present on the 1929 map (Figure 6) in the same location.

No specific records of the operational history of the creosote production area are available, but some information can be inferred from a general knowledge of the creosote production process and the characteristics of creosote. A former site worker (personal communication) recalled that some of the waste tar from the chemical production area south of Elder Road was piped to the creosote production area. The tar was likely heated to separate the creosote component. The disposal of the waste tar after refining is unknown. It may have been burned in the boilers, disposed on the ground or to the nearest location where it would flow away from the production area. If the latter was the case, the likely area of disposal would have been the bluff on the western side of Nelson Lake or the northern portion of Tar Lake.

The waste tar is very viscous and would remain largely on the surface of the ground. If this material eroded or moved down the bluff to Nelson Lake in sufficient quantity, it may be present at the bottom of the lake because it is denser than water. Leaks or spills of creosote may have occurred at the facility during the several decades of operation.

Creosote is a fairly viscous DNAPL and would be expected to remain in the unsaturated zone; although, if disposed in sufficient quantity, it may have migrated to the water table. The main contaminants of concern are the PAHs, VOCs, phenols, pyridines, amrrr^nia, cyanide, thiocyanate and sulfide compounds.

MKE/991030001.DOC/V2

PROJECT APPROACH

Data Quality Objectives

The following are the data quaUty objectives for this area:

• Collect data on organic and inorganic constituents in the surficial soils that are of sufficient quality to support the risk assessment.

• Visually deUneate and record the extent of charcoal, creosote, and tar distiibution.

There is no known soU or groundwater analytical data for this area. MW-13 is located slightiy north of Elder Road, but is side gradient to the creosote production area. The evaluation of historical operations showed that other than visible evidence of a tarry substance on the ground, little information is available on potential soU and groundwater contamination.

The anticipated future land use of the Creosote Area will be industiial, commercial, or recreational. Sufficient data are needed to support quantification of health risk for this area.

Additional data are needed to evaluate the remedial altematives which assess risk based on surficial soU inorganic and organic compound concentiations. ITie area of risk will likely be delineated by visible tar contamination. The extent of tar will be used to delineate the area of potential remediation, if unacceptable risks are found. Visual identification will be used for delineation of extent.

The presence of slag on the Nelson Lake bluff will make delineation of tar disposal, if it occurred, difficult. The slag may be many feet thick and the slope is about 45 degrees. An attempt wUl be made to delineate tar with hand tools, but further delineation wiU not be attempted with borings because of safety and access concerns.

Site Investigations

The objectives of sampUng in the Creosote Area are to deUneate the extent of tar (the waste production of creosote production) or charcoal and assess the risk associated with these materials. Sampling wUl target the area of operation, the area of visible tar contamination and the overland route of potential tar flow toward Nelson Lake. Contamination at concentiations exceeding acceptable risk levels is anticipated to be limited to the tar layer in the area of the former Creosote buUding. SampUng at the base of the Nelson Lake bluff is planned under the Iron Production Area investigation and sampling of Nelson Lake sediments is planned under the Nelson Lake investigation.

Three samples of tar found on the ground surface will be taken from locations spaced throughout the visible tar area. The tar will be visibly horizontally and vertically delineated. The three tar samples will be analyzed for the total and SPLP organic and inorganic analytes.

Discrete surficial soil samples coUected from the 0 to 2-feet bgs interval will be sampled from a total of four locations (Figure 6) and summarized below. These soil samples will be coUected from below any visible tar. The locations are as follows:

• One sample for total ?nd SPLP organic and inorganic analysis from the center of the former creosote buUding (CROl)

MKEy991030001.DOC/V2

PROJECT APPROACH

• One sample for total and SPLP organic and inorganic analysis from the center of the tank area irtunediately north of the former creosote building (CR02)

• One sample for total and SPLP organic and inorganic analysis from visibly tarry areas outside of the former creosote building (CR03)

• One sample for total and SPLP organic and inorganic analysis from an area downslope of visibly tarry areas and toward Nelson Lake (CR04)

Three subsurface soU samples wiU be collected from the location (CROl) in the center of the former creosote buUding. They wiU be selected based on visible and organic vapor screening of soUs continuously sampled from the ground surface to below the water table (50 feet or more in depth) The samples will be submitted for total and SPLP organic and inorganic analyses. If contamination reaches the water table, a focused groundwater investigation wUl be considered for this area (no cost has been budgeted for such an effort).

Table 3 summarizes the samples to be collected and the analysis to be performed. A 1-day effort for a crew of 2 people is planned for the visual delineation subtask.

Key Assumptions

Several assumptions were made that are inherent in the data quality objectives and the investigation plan for the Creosote Area. These are:

• Operations and facUity locations are limited to those identified on the available maps and summarized above.

• Future land use wiU either be industiial, conimercial, or recreational.

• Widespread tar or creosote contamination has not been observed and is assumed not to be present. Contamination is generally Umited to the visible tar area surrounding the former creosote production building location.

• Delineation of tar on the bluff is planned, but because of the presence of slag on the Nelson Lake bluff, delineation, if it occurred, would be dUficult. The slag may be many feet thick and the slope is about 45 degrees. An attempt will be made to delineate tar with hand tools, but further delineation will not be attempted with borings because of safety and access concerns.

• Groundwater is not expected to be affected and further investigation to delineate the horizontal and vertical extent of groundwater contamination in this area is not currently anticipated.

Nelson Lake

Historical Operations and Contaminants of Concern

Nelson Lake is a smaU kettle lake located 150 feet north of Elder Road, directly east of the old iron production area of Antiim Iron Company (AIC) (Figure 2). The area of the lake is roughly 5.8 acres. Although the lake is on private property, the close proximity of the lake to Elder Road allows for easy access by trespassers. Also, the ovA^er uses the lake for personal recreation. The lake has no maintained access points. A preliminary site visit in the

MKEy99l030001.DOC;V2

PROJECT APPROACH

spring of 1998 identified potential ecological receptors (amphibians, reptiles, birds, and mammals) that may come in contact with surface water or sediments of the lake.

Nelson Lake was used as a cooling water source for the AlC's blast furnace. Pumping capacity was approximately 500 gaUons per minute. The water was pumped from the lake, used as cooling water (most likely primarily for blast furnace cooling), and either returned to Peckham Lake, Nelson Lake, or the drainage ditch along what is currently Hwy 131. It is believed that the high rate of withdrawal from Nelson Lake resulted in its complete draw down. Nelson Lake then could have acted as groundwater low (sink) and may have pulled surrotmding groundwater into the lake along with potential onsite contaminants. In addition, tars and other associated process wastes/compounds (oils, PAH's from the adjacent creosote operations) may have pushed or have eroded down the west-bank (downgradient of the Creosote area) and into Nelson Lake.

Data Quality Objectives

The data quaUty objective for this area is to coUect data on the organic and inorganic constituents in Nelson Lake's surface water and sediment that is of sufficient quality to support the risk assessment.

There is currently no analytical data on potential surface water and sediment contamination in and around the Lake due to AIC's operations. Likewise, there is little known about the use of the lake by human or ecological receptors. Assessment of potential risk to human and ecological receptors, based on the above assumptions, wUl require a focused sampling of surface water and sediments within Nelson Lake. The information is being collected to support the historic based conclusions that while there have been environmental impacts to Nelson Lake, they have not resulted in sufficient risk to require remedial action.

Site Investigations

Nelson Lake has no known tiibutaries that flow into the lake, therefore physical and chemical parameters of surface water were assumed to be homogenous, requiring only one sample (Table 3). Based on the historical information summarized above, characterization of Nelson Lake sediments will require collection sediment sample from five locations (three discrete surface, three subsurface, and two composite surface sediments).

Three discrete surface sediment samples, NSDOl, NSD04, and NSD05 (top 4 inches) wiU be collected along the west shore (Figure 7). Immediately beneath each of these samples, a subsurface sediment sample will be collected. These samples will be collected from 4 inches bgs to 48 inches bgs or refusal, which ever occurs first. This area may have potentially received contamination from several different sources (surface water runoff, iron and charcoal production wastes, and later creosote area wastes) adjacent to Nelson Lake.

In the areas of Nelson Lake not likely to have received waste materiaL composite samples wiU be collected. A composite sample (NSD02) will consist of sediment collected from three samples locations equidistant along the north shore. The top 4 inches of sediment from each location wiU be coUected and composited for analysis. Likewise, the top 4 inches of sediment from three locations along the East shore will be coUected and composited into one sample (NSD05).

MKE/991030001 D0CW2

iA15l995\DHAWINCS\oo^'025£d22 12-«PR-1999

0 50' 100'

l U U U U J ' I APPROXIMATE SCALE

LEGEND

© ® (9)

SOIL SAMPLE

SEDIMENT SAMPLE

c ; i i P F A r r U / A T T P C A U P I r

FIGURE 7 NELSON LAKE SAMPLE LOCATIONS ANTRIM IRON WORKS SITE TAR LAKE ANTRIM, MICHIGAN ^ ^ • • ^ ^ • | | [ 1 | | | |

PROJECT APPROACH

One soil sample (NSOl)will be coUected at the soil surface water interface of Nelson Lake directly downgradient of the creosote area. (Figure 7). This sample wiU be advanced up to four feet bgs as a means to look for tar. If tar is encountered, th(? soil directly below the tar wUl be coUected for sample analysis. If no tar is encountered, tlie soil over the length of the boring wUl be composited into one sample for analysis of VOCs, SVOCs, and metals.

Key Assumption

Waste was only disposed of along the west shore of Nelson Lake.

Peckham Lake

Historical Operations and Contaminants of Concern

Peckham Lake is located approximately 250 ft. east of Tar Lake and approximately 200 ft. south of Elder Road. There is an unnamed county road on the land between the west side of the lake and Tar Lake (Figure 8). Peckam is roughly an 11-acre kettle lake. Surrounding land is privately owned, but unrestiicted access to the lake is possible from the county road. There are no maintained pubUc access points to the lake, and it is not currently maintained by the MDNR for recreational fishing. Interviews with some local residence indicate that people do use the Peckham Lake for swimming and fishing. A preliminary site visit in the spring of 1998 identified potential ecological receptors (amphibians, reptiles, birds, and mammals) that may come in contact with surface water or sediments.

Peckham Lake was also used to supply cooling water for plant operations and to receive cooling water discharge. Local residence referred to lake by its nick-name, "Hot Water " Lake, due to the discharge of heated water from the faciUty to a smaU connecting pool at the extieme southem end of the lake. Remnants of the old sluice-ways are stiU present along the west bank of the lake. The sluice-way runs paraUel to the west shore of the lake and has a discharge point midway along the west shore and another discharge point at the southem end of the lake. Large withdrawals of cooUng water similar to those taken from Nelson Lake are beUeved to have occurred based on a 1926 Sanbome map showing a cooling water pipe from the direction of Peckham Lake, a site photograph showing a structure similar to a pump house alongside the lake and recollections of a former AIW's employee. Large cooling water withdrawals may have had temporary, localized affects on groundwater patterns and potentiaUy contaminated groundwater from plant operations could have moved toward and into Peckham Lake.

Data Quality Objectives

The data quaUty objective for this area is to coUect data on the organic and inorganic constituents in Peckham Lake's surface and sediment that is of sufficient quality to support the risk assessment.

There is currently no information regarding potential contamination of surface water and sediment in Peckham Lake. Access to the lake by ecological receptors, a source of food and habitat, is high based on a preliminary site investigation. Likewise, people have been observed fishing in the lake. This information is being coUected to support the conclusions that whUe there have been environmental impacts to Peckham Lake, it was a long time ago, and they currently do not result in sufficient risk to require remeidial action.

MKEfl91030001.DOCA/2

rM51995\0R*WINCS\KKlkgd«.

PROJECT APPROACH

Site Investigations

Assessment of potential risk to human and ecological receptors, based of the above assumptions, wiU require some sampUng of surface water and sediments within Peckham Lake. The surface and sediment samples will be analyzed for VOCs, SVOCs, and metals.

Peckham has no known tiibutaries that flow into the lake; physical and chemical parameters of surface water were assumed to be homogenous, requiring only two samples (Table 3). One sample (PSW02) wUI be collected from the small pool area at the southern end of the lake and the other from the main body of the Lake (FSWOl).

Characterization of sediments from the main lake portion will be done by the coUection of four sediment samples (Figure 8). Along the west shore (the area of the greatest possibiUty of waste disposal) three sediment samples (collecting the top 4 mches) will be collected equidistant along the shore. One of these three surface sediment samples (PSD02) wiU be collected at the sluiceway discharge point located about midway on the west shore. An additional subsurface sediment sample, PSD04, (4 feet deep or untU refusal) will also be coUected downgradient of the sluiceway. This sample will be collected to investigate for an underlying tar layer. If tar is encountered a soil sample will be collected from immediately beneath the tar layer. If no tar is found, the soil from the length of boring will be composited into one sample.

Two sediment samples wiU be collected within the small pool at the southern end of the lake. One surface sediment sample, PSD05, (top 4 inches) will be collected from within the discharge pool. In addition, one subsurface sediment sample, PSD06, wiU be collected immediately downgradient of the discharge point (sluiceway). This sample wiU be collected to investigate for an underlying tar layer. Lf tar is encountered a soU sample will be coUected from immediately beneath the tar layer. If no tar is found, the soil from the length of boring (up to 4 feet bgs) wUl be composited into one sample.

Key Assumption

Waste, if disposed of in Peckham Lake, was only disposed of along the western shore

East Tailing Area

Historical Operations and Contaminants of Concern

The East Tailing Area includes about 40 acres east of Peckham Lake where tailings were disposed. This area was identified based on a 1938 aerial photograph. In the photograph it appears that tailings had been placed on the surface and graded level. Visual observations of this area in the fall of 1998 found evidence of weathered tailing material intermixed with soil throughout this area. It is a flat area covered with grasses —a large portion of it recently planted with pine tiees of less than 2 feet in height.

Contaminants of concern are Umited to the inorganics present in the taUing material. The inorganic concentiations are expected to be similar to that which was originally present in the iron ore.

Data Quality Objectives

The following are data quality objectives for this area:

MKEfl91030001.DOCA/2

PROJECT APPROACH

• CoUect data on total and SPLP inorgaruc constituents in the surficial soils that are of sufficient quality to support the risk assessment. Note: orgaruc compounds are not expected to be of concern in this area. The evaluation of historical operations and wastes produced indicate that the organic contamination that could have been produced is not expected to remain in the surficial soils for the length of time since operations ended.

• Delineate and record the extent of tailing distiibution.

There is no known soU or groundwater data for this area.

Site investigations

Because of the Ukely minimal risks associated with the East Tailing Area, a focused sampling effort is planned for site characterization and risk assessment. If risks based on the focused sampling are more significant than expected, additional sampling for more precise evaluation of contaminant extent and risks will be considered.

Surficial soU (0 to 2 feet bgs) samples (soU wiU be coUected from beneath the tailings if tailing material is present at the randomly selected sampling location) wUl be collected from 3 locations (Figure 9). They wUl be analyzed for total and SPLP inorganic constituents.

To ensure that the soU samples are mostly soil and not tailings, the sample will be passed through a 0.5-inch sieve prior to placing in the sample container. Physical descriptions of the samples will be recorded as the samples are composited. If possible, the approximate percent of tailing in the samples will be identified. Investigations of surface soil below 2 feet bgs are not planned because of the limited leachability of contaminants and the expected marginal contamination. Table 2 summarizes the samples to be collected and the analysis to be performed.

In addition to the surficial soil sampling, the areas containing tailings wUl be delineated using hand augers and/or shovels. The extent of the taUings will be recorded using GPS. A 1-day effort for a crew of 2 people is planned for the visual identification task.

Key Assumptions

The foUowing assumptions were made that are inherent in the data quality objectives and the investigation plan for the East Tailing Area:

• Iron, charcoal or chemical production facilities were not present in this area. Historic information provides no reason to believe that any activity occurred in this area other than tailing disposal.

• Because historic information shows operations in this area being lunited to tailing disposal and the assumption that the tailings are not leaching to groundwater. Groundwater would not be expected to be contaminated from organic contaminants.

Tar Lake Area

Historical Operations and Contaminants of Concern

The Tar Lake Area is located east of the retort and chemical production area. It received the waste tars from the production of charcoaL and the chemical production from the condensed crude pyroligneous liquor. (Figure 2). USEPA is currently removing the tars for

MKE/991030C01.DOGV2

I-\I51995\0WAWWCS\ lorll>6

PROJECT APPROACH

offsite energy recovery or landfill disposal. The tar removal action is expected to be complete by the summer of 1999. Contaminated soils from below the tars will remain foUowing the removal action. Additional investigations of the Tar Lake area wiU focus on characterizing the remaining contamination in the soils. The contarrvinants associated with the tars include PAHs, VOCs, phenols, pyridines, ammonia, cyanide, thiocyanate and sulfide compounds.

In addition to the soUs, tar-contaminated slag may also remain at the site following the removal action. A large area of slag along the northern perimeter of Tar Lake is being relocated onsite to aUow excavation.of tar from below the slag. Portions of the slag may also be contaminated as indicated by perched contaminated water in lenses within the slag.

Data Quality Objectives

The following are data quality objectives for this area:

• CoUect data on organic and inorganic constituents in the surface and subsurface soils that are of sufficient quality to support the risk assessment. Note: organic compounds are expected to be of concern in this area. The evaluation of historical operations and wastes produced indicate that the organic contamination that could have been produced and tiapped in the tar. Now that the tar has been disturbed, the VOCs could be mobiUzed.

• Collect data on the organic and inorganic constituents in the tar (coated on slag) that is of sufficient quaUty to assess risk.

Substantial data is avaUable for the delineation of the horizontal and vertical extent of the tar and contaminated soU. Because the tar removal may alter the contaminant concentiations in the soU immediately underlying the tar, re-characterization of this soil is necessary. Also, characterization of the potentially tar contaminated slag in this area is necessary.

Future land use of the Tar Lake area is anticipated to be industiial, commercial, or recreational. This is consistent with the City and Township of Mancelona future development plans. Exposures to onsite groundwater may result in risk exceeding acceptable levels. Contaminants leaching from the soil or tarry slag may contiibute to the risk. The contaminant levels in the soil and slag need to be characterized to asses the risk from the above exposure scenarios.

Additional data needed for evaluation of remedial actions is not anticipated at this time because substantial delineation work has already been performed.

Site Investigations

The USEPA Tar Lake On Scene Coordinator (OSC) collected two soil samples from each of the five sampling locations spread across Tar Lake basin following completion of the tar removal. The five locations represent distinct types of tar as identified during the removal action. At each location two composite soil samples were taken. The first was composite from 0 to 1 inch bgs and the second was composited from 2 to 3 inches bgs (Figure 10). These soU samples are being analyzed for total and SPLP inorganic and organic compounds.

MKE/991030001.DOGV2

l.\l51995V0WAWIWCSMorl>6

PROJECT APPROACH

M In addition, five slag samples wiU be taken from the stockpile of relocated slag. The locations wUI be evenly spaced throughout the stockpile. To coUect r. sample that will be able to be analyzed, the slag will be passed through a 0.5-inch sieve prior to placing in the

^ sample container. Physical descriptions of the slag will be recorded as the samples are composited. These slag samples wUI be analyzed for total and SPLP VOCs, SVOCs, and metals. Table 3 summarizes the samples to be collected and the analysis to be performed.

Additional investigations of groundwater are discussed under the groundwater investigation section.

• " Key Assumption

It is assumed that the future land use in this area will be industiiaL commerciaL or recreational.

Retort and Chemical Production Area

" Historical Operations and Contaminants of Concern

The Retort and Chemical Production Area includes the currently fenced area south of Elder ^ Road from US 131 to Tar Lake (Figure 2). The Retort and Chemical Production Area is about

11 acres. Chemical production first began in this area sometime between 1897 and 1910 based on the available plat maps. Later, a large retort was added in this area and the

1̂ chemical production facUities were expanded. The following are the main facilities identified on the 1929 Sanbome map (Figures 5):

JI

4

• The retort buUding, measuring 70 by 325 feet

• The acetate of Ume house

• The chemical buUding along with 5 steel alcohol storage tanks and 17 wooden liquor tanks

• The steam boUer room, electiical generator building, 2 storage houses, a water cistern and water cooling reservoir

The retort building was sealed during charcoal production so that the offgases could be recovered and condensed to crude pyroligneous liquor. The liquor was first reacted with lime to produce acetate of lime in the acetate of lime building. This building was located about 200 feet northeast of the retort building. It is unclear where the offgases were condensed, but this most likely was performed in the acetate of Ume house. If so, it is most Ukely that the offgases were conveyed from the retorts in pipes located in shallow tienches connecting the buUdings. Such tienches (estimated to be about 4 by 4 feet in cross section by a former employee) were reported as present throughout the facility and also likely contained steam Unes for the operation of machinery and the distiUation columns. Above ground piping of offgases is also unlikely because tars would more easily condense in the pipes causing plugging during the cold winter weather of northern Michigan. Contaminants of concern associated with the retort building are Ukely limited to inorganic compounds present in the ash. Contaminants such as the PAHs, VOCs, phenols, pyridines, ammonia, cyanide, thiocyanate and suUide compounds may also be present if condensation of the offgases occurred in the retorts or in the pipes carrying offgases between buildings.

MKE/991030001 D0C/V2 20

PROJECT APPROACH

^ These contaminants, in addition to acetate, may be present in soils beneath the former acetate of lime buUding.

The remaining pyroUgneous Uquor was distilled in the chemical buUding into methanoL ^ acetone, alcohol and tar. DistUlation of creosote oils from the tar may have also have

occurred in the chemical buUding, although a separate area north of Elder road for creosote production appears on the 1926 and 1929 Sanbome maps. Wooden tarUcs were used to store

** the Uquor. The tanks appear to be about 15 feet in diameter bas(?d on the Sanbome maps. A raUroad siding was adjacent to the buUding, Ukely for fUIing product into railroad tank cars. At least five steel tanks for storage of alcohol were also located nearby. The waste tars were

*" drained down a sluice way to Tar Lake. Some waste tar may have been used in fueling the adjacent boUers used for steam production. Contaminants of concern associated with the chemical production building are PAHs, VOCs, phenols, pyridines, ammonia, cyanide,

** thiocyanate, sulfide, methanol, acetone and ethanol.

Operations in the steam boUer room and electiical generator room are not likely to have fli contaminated soU significantly. Although tars may have been used as fuels in the boilers,

they would Ukely have been destioyed rather than accumulate in soUs below or surrounding the buUding.

Data Quality Objectives The foUowing are data quality objectives for this area:

• CoUect data on organic and inorganic constituents in the surficial and subsurface soils that are of sufficient quaUty to support the risk assessment

• DeUneate and record the extent of LNAPL and its smear zone

There is Umited data on soU contamination in this area. The available information is Umited 4 to that obtained during the recent installation of the groundwater air sparging system.

During instaUation of an air sparge weU, a light nonaqueous phase liquid (LNAPL) was fovmd floating on the water table just east of the former chemical building location,

i i Groundwater data is available indicating significant groundwater contamination beneath the chemical production area, although substances on the standard CLP organic analyte list are generaUy in concentrations less than 100 jig/L. Because groundwater below this area is

t$ downgradient of tar lake, the groundwater contamination may be primarily from Tar Lake rather than the soils of the Chemical Production area.

i i Site Investigations The area of contamination found around the sparge well and each of the significant facilities in the Retort and Chemical Production Area will be investigated with a focused

-• sampling program. If risk, based on the limited sampling, is found to be greater than the acceptable range, additional sampling for more precise evaluation of contaminant extent and risks wUl be considered.

Surficial soU samples consisting of composites from the 0 to 2 feet bgs interval will be coUected from the foUowv-ig 11 locations (Figure 11):

** • Two samples for total and SPLP inorganic and organic analysis from the former retort location

MKE«91030001.DOOV2

I I I 1 I IA151995\0l»*wlNCS\imbl025o.aan ie-lilAY-1999

WATER COOLING BUILDING

©

FENCE

1984 LAKE BOUNDARY

SURFACE SOIL SAMPLES

SUBSURFACE SOIL SAMPLES

200'

FIGURE 11 CHEMICAL PRODUCTION AREA SAMPLING LOCATIONS ANTRIM IRON WORKS SITE TAR LAKE ANTRIM, MICHIGAN ^^ft49||||U|| I

PROJECT APPROACH

• Nine samples spaced on about 200-feet centers for total and SPLP inorganic and organic analysis from soils throughout the area

RecenUy placed soUs or roadway gravel at the sample location wUl be removed prior to sampUng. If slag is present, the composited soil samples will be passed through a 0.5-inch sieve prior to placing in the sample container. Physical descriptions of the samples wUI be recorded as the samples are composited. If an area of surface soil is shown to exceed acceptable risk, additional subsurface sampling for more precise evaluation of extent and risks wiU be considered.

Surface and subsurface soU contamination wiU be investigated in the chemical production buUdings and tank area because of the greater potential for leaching of contaminants and the need to delineate the LNAPL extent. Six soil borings will be advanced to the water table at the following locations:

• One boring through the former acetate of lime production building • Two borings through the former chemical production building • Three borings through the former wood Uquor storage tank area

At each location soU samples wUl be collected at 5-foot intervals from the surface to the water table for organic vapor screening. Base on screening and visual evidence, up to five soU samples wiU be submitted for analysis of total and SPLP inorganics and organics. Also at each location, the soU sample at the water table will be evaluated for the presence of LNAPL. A groundwater grab sample will also be collected for visual identification of LNAPL and a sample of LNAPL will be collected either from the sparge well or a boring and submitted for analysis of organics.

Table 3 summarizes the samples to be coUected and the analysis to be performed.

Key Assumptions

The foUowing assumptions were made that are inherent in the data quality objectives and the investigation plan for the Retort and Chemical Production Area:

• Operations and facility locations are/were limited to those identified on the available maps and summarized above.

• Future land use wiU be industiial, commercial, or recreationaL and wiU limit the chances that this area will provide significant habitat for flora and fauna.

• Delineation of underground pipe networks using geophysics was considered but rejected because of the difficulty in adequately characterizing contamination remaining in piping. The amount of sampUng would be very great to adequately characterize the potential contamination relative to the potential threat it poses. Future industiial land use and development restiictions will need to take into account the potential for encountering subsurface structures and isolated areas of tars and soil contamination.

Drainage Ditch Area

Historical Operations and Contaminants of Concern

Historically, Nelson Lake was used, as a cooling water source for the AIC's blast furnace. Pumping capacity was approximately 500 gallons per minute. Tlie cooling water was either

MKB991030001.DOCA/2 22

PROJECT APPROACH

returned to Peckham Lake or Nelson Lake, but for an unknown period of time the cooling water was discharged to the drainage ditch that ran along the western edge of the site between the raU Unes and what is now currently Hwy 131.

The drainage water, as told by a former employee, tiaveled do^vn the eastern edge of Hwy 131 to approximately where the former saw miU was located. At this point the water was diverted under the highway and aUowed to flow into a low area west, southwest of the discharge point. At this point the water evaporated and dissipated into the sandy soil.

It was reported that tar lined the bottom of this drainage ditch.

Data Quality Objectives

The foUowing are data quality objectives for this area:

• CoUect data on organic and inorganic constituents in the surficial soUs and groundwater that are of sufficient quaUty to support the risk assessment.

• Delineating the extent of tar, if found.

There is no data on soU contamination in this area. Current land use of the drainage Area is industiial, conrmercial, and residential. Under this scenario residents could be exposed to COPCs associated with tars potentially remaining in this area.

Site Investigations

The drainage ditch area wUl be investigated with a focused sampUng program. If risk, based on the Umited sampling, is foimd to be greater than the acceptable range, additional sampling for more precise evaluation of contaminant extent and risks wiU be considered.

Surficial soU samples consisting of composites from the 0- to 2-feet bgs interval will be coUected from 5 locations shown on Figure 12. Two additional samples wUl be located at the time of field event. The samples will be analyzed for SVOCs, and Metals.

The area west of Hwy 131 where the water pooled wiU be investigated to assess if the cooling water could have pulled the tar down in to the subsurface soils. A soil borings will be advanced to the water in the middle of this low. Soil samples wiU be collected at 5 foot intervals from the surface to the water table for organic vapor screening. Base on screening and visual evidence, one soil samples will be submitted for analvsis of total and SPLP inorganics and organics.

Table 3 summarizes the samples to be collected and the analysis to be performed.

Key Assumption

The locations of past activities are Umited by information verbaUy provided, summarized above.

Groundwater Much of the historic grotmdwater information is for onsite groundwater. There is much less information available for offsite groundwater. The information developed to date provides a generally complete and consistent picture of the local and site hydrogeology. This

MKE/991030001.DOCW2 23

l-\t519«5\DRAIlnNCS\t

PROJECT APPROACH

information is being used to focus the groundwater investigation, but the following represent the major areas of uncertainty:

• The southem and northern extent of the groundwater plume leaving the site • The horizontal extent of the groundwater plume(s) • The vertical extent of the plume • Current chemical and physical conditions of the on and offsite groundwater

Historical Operations and Contaminants of Concern

• Our current understanding of the site hydrogeology and related groundwater contamination is based upon the previously listed documents and the results of site visits.

Conceptual Hydrogeologic ModelExisting information on physical conditions as well as site characterization data have been used to develop a preliminary conceptual site model. The following sections outline the information used to frame the hydrogeologic portion of the conceptual site model.

Onsite

Environmental and Safety Designs, Inc. et al (1985) conducted an investigation at the site involving installation of four monitoring wells. The following are highlights of this effort:

• Sandy deposits were encountered from near ground surface to about 101 feet below ground surface (bgs). They reported that no "significant aquitard or aquiclude stiata" was encountered during the drilling effort.

• The Depth to water measurements for the monitoring wells ranged from about 30 to 70 feet bgs.

• The interpretive groundwater elevation contours indicated that groundwater flow is generally to the northwest, roughly parallel to a line drawn from Tar Lake to the intersection of US 31 and Elder Road. The calculated hydraulic gradient was .006 ft/ft. The groundwater flow between the north end of Tar Lake and Elder Road does, however, appear to have a more northerly direction component. The authors suggest that this could be due to pumping from Nelson Lake.

• There appear to be no hydrogeologic barriers between the lake and the aquifer.

Offsite

As part of the same effort surrunarized above. Environmental and Safety Designs, Inc. et al (1985) conducted an offsite water weU survey. The foUowing are highlights of this effort:

• Forty-six private wells, three Mancelona production wells, and five "GuU+Western" were inventoried (weU logs were not included with the report). The bulk of the wells were located west to northwest from the site, but there were a few wells that were positioned to the south and north of the site.

• Well depths ranged from about 65 to 200 feet. The wide range of well depths is anticipated in some cases because of the topographic relief in. the area. However, for some wells, the relationship of neighboring well depths is not clear. For example, PW-2

MKD991030001.DOaV2 24

PROJECT APPROACH

and PW-9 have similar top of casing elevations (1098.96 and 1098.27 feet respectively) with similar groundwater depths (66.57 and 67.64 feet respectively). However, the well depth reported for PW-2 is 84 feet while 198 feet is reported for PW-9. It is not known if this relates to a specific feature of the hydrogeologic setting (i.e., a clayey deposit encountered at some locations which necessitated driUing a deeper weU borehole).

• Original static water levels ranged from about 48 to 180 ft.

• Groundwater levels w^ere measured in "selected private w^ells" whose locations were generaUy scattered across the area from southeast to northwest. A groundwater flow direction to the northwest generally parallel to a line from Tar Lake toward the intersection of Alden Highway and Bailey Road can be inferred from the resulting groundwater contour map.

• Mancelona production weU CW-2 supplies most (up to 75%) of the City's water needs. This well was driUed to 93 feet and encountered "medium to coarse sand all the way down". The authors further comment that, "Because of the obvious connection between City WeU No. 2 and Pumphouse Lake (Pumphouse Lake) it is not surprising that Pumphouse Lake has been reduced to a swampy meadow, due to dewatering." CW-3 is reported to extiact groundwater "from an aquifer confined between two clay aquitards", assumed to be screened in the 153 to 175 feet interval. The driUing log for the well reported the following sequence of unconsolidated materials:

- 0-98 feet Fine-medium sand - 98-153 feet Blue Clay - 153-175 feet Fine-medium sand - 175- (?) Blue clay

• They summarize the water weU review by stating that, "In virtuaUy every case, nothing except sand and gravel is reported within the aquifer zone. Within the area surveyed on Figure 3-1 (Environmental and Safety Designs, Inc. et al. 1985), the only well completed within an aquifer confined by clay aquitard stiata is Mancelona City Well No. 3 (CW-3)."

• In the Draft Focused Feasibility Study (1993), Environmental and Safety Designs, Inc. indicated that "with the exception of minor clay lenses", the unconsoUdated deposits overlying bedrock consist of "relatively clean, medium grained, brown sand." They estimated the thickness of the unconsolidated glacial deposits as 400 to 600 feet based on gas exploration data. The sandy unconsolidated deposit extends up to 170 feet deep along the long-axis of the offsite plume. This was based on driUing and installation of four monitoring wells —DB-1 through DB-4.

Summary of Hydrogeologic Model

The site conceptual hydrogeologic model is:

• Sandy unconsolidated subsurface deposits are ubiquitous through-out the investigation area to a depth of at least 100 feet and possibly deeper.

• Significant clayey unconsolidated deposits appear to be limited to an area north of the Tar Lake site.

MKE/991030001.DOCA/2 25

PROJECT APPROACH

• Groundwater depths range from 30 to 70 feet onsite and from 40 to 180 feet offsite.

• The groundwater gradient direction is to the northwest and the hydraulic gradient is about 0.006 ft/ft.

• The investigation area includes the onsite groundwater and the groundwater migrating from the site down to the Saloon Creek wetland area (approximately 4.5 mUes northwest of the site).

• The surface water bodies within the investigation area are hydrauUcaUy connected to the groundwater system.

Groundwater Contamination

Onsite

Environmental and Safety Designs, Inc. et al (1985) findings are surrunarized as follows:

• That MW-3, -6, -7, -8, and -9 were impacted by Tar Lake based on "elevated" groundwater conductivity measurements.

• Two wells were sampled for volatile organics, acid extiactables, base/neutial extractables, and tiace metals analyses. These analyses were conducted via "library scans" and, although the sampled wells exhibited "phenolic" odor, no volatile organic peaks were reported and the peaks reported for the acid extiactable analysis and the base/neutial extiactable analysis were related to sample handUng or laboratory contamination. Further sampUng of all onsite weUs for phenol analysis was conducted and compoimd peaks were noted but were not identified.

• Iron was the only tiace metal they reported as present above apparent detection or reporting Umits and the concentiations reported ranged from 0.67 to 6.9 mg/L. Arsenic was analyzed for MW-8 and -9 and was reported as below detection/reporting limits.

• Gradient Corporation (1990) reported the foUowing based on the analyses of one tar, 5 soU, and 2 groundwater samples from the site.

• Groundwater concentiations of alkylphenols, monoaromatic hydrocarbons, and ketones were approximately 0.01 to 1% of tar concentiations.

• There was an observed decrease in contaminant concentiations with increasing distance from Tar Lake. Biodegradation was suggested to explain the sharp decline (vertically and horizontally) in contaminant concentiations.

• Results of a Michigan Department of Environmental Quality's (MDEQ 1998) sampling effort were available as weU. MDEQ reported analytical results for nine 3-well monitormg nes ts -MW-1 A, -IB, -IC, -2A, -2B, -2C, -3 A, -3B, and -3C. The nested weUs ranged in depth as follows:

- MW-IA - MW-IB - MW-IC - MW-2A - MW-2B - MW-2C

MKE/991030001.DOCA/2

58 to 99 feet 55 to 91 feet 55 to 91 feet 88 to 111 feet 88 to 109 feet 72 to 114 feet

26

PROJECT APPROACH

- MW-3A 72 to 121 feet - MW-3B 75 to 119 feet - MW-3C 75 to 119 feet

• Samples were collected from all wells for general chemistiy, metals. Phenols, VOCs, SVOCs, and Pesticides/PCBs analyses. In generaL these results appear to support the concept that site related groundwater contamination attenuates rapidly with increasing distance form the site because:

• The phenol compound concentiations reported for the MW-IA nest (which is immediately downgradient of Tar Lake) were one to three orders of magnitude higher than the intermediate (MW-2A and -2B) and distant downgradient (MW-3A and -3B) locations. Also, there were six different phenol compounds detected at MW-IA whereas there was only one compound (2,4-Dimethylphenol) detected at the downgradient locations. Similar tiends were noted for the other chenucal groups, most notably the VOCs.

• At the MW-IA nest for example, ethylbenzene concentiations decreased from 100 | ig/L at 69 feet bgs to non-detect at 99 feet bgs.

Offsite

As part of their offsite well survey effort. Environmental and Safety Designs, Inc. et al (1985) reported:

• PW-la, -2, and -28b were selected for volatile organics, acid extiactables, and base/neutial extiactables analyses via Ubrary scan as described for the onsite monitoring weUs. The results surrunary is as foUows:

- No peaks were identified for the volatUe organics.

- A "phenoUc type" compound was identified from the PW-28b acid extiactable analysis.

- Base/neutial extiactable compound peaks were identified from the PW-28b analysis.

• PW-9, -10, -11, -12, -14, -22, -26 and -34 were analyzed for "priority pollutant phenols" and detection's of a single phenol compound were reported for PW-10 and -26.

• PW-la, -2, -7, -9, -10, -11, -12, -14, -22, -26