McLouth_Steel_SW-SED_FSP_(Final_3-30-18).pdf

REMEDIAL INVESTIGATION/FEASIBILITY STUDY

FIELD SAMPLING PLAN

DSC MCLOUTH STEEL GIBRALTAR PLANT

CITY OF GIBRALTAR, MICHIGAN

EPA SITE ID NO. MIN000510362

PREPARED FOR:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY,

REGION 5

77 WEST JACKSON BOULEVARD, SR-6J

CHICAGO, ILLINOIS 60604-3507

INTERAGENCY AGREEMENT/AMENDMENT NO. DW96958743-01-0

PREPARED BY:

U.S. ARMY CORPS OF ENGINEERS - BUFFALO DISTRICT

1776 NIAGARA STREET

BUFFALO, NEW YORK 14207

REVISION NUMBER: 1

MARCH 2018

Page i

TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................................... i

LIST OF FIGURES ..................................................................................................................................... iii

LIST OF TABLES ....................................................................................................................................... iv

APPENDICES ............................................................................................................................................. iv

ACRONYM LIST ......................................................................................................................................... v

1. INTRODUCTION ................................................................................................................................. 1-1

1.1 GENERAL......................................................................................................................................... 1-1

1.2 SITE DESRIPTION .......................................................................................................................... 1-1

1.3 SITE HISTORY ................................................................................................................................ 1-2

1.4 CONSTITUENTS OF INTEREST .................................................................................................... 1-4

1.5 STUDY AREAS ................................................................................................................................ 1-4

1.6 SUMMARY OF PREVIOUS INVESTIGATIONS .......................................................................... 1-8

1.6.1 Existing Soil Data ..................................................................................................................... 1-8

1.6.2 Existing Groundwater Data ..................................................................................................... 1-10

1.6.3 Existing Surface Water Data ................................................................................................... 1-11

1.6.4 Existing Sediment Data ........................................................................................................... 1-13

1.6.5 Existing Leachate Data ........................................................................................................... 1-14

1.7 GEOLOGIC/HYDROGEOLOGIC SETTING ............................................................................... 1-15

1.8 PROJECT OBJECTIVES ................................................................................................................ 1-16

2. PROJECT ORGANIZATION ............................................................................................................... 2-1

3. PRELIMINARY CONCEPTUAL SITE MODEL ................................................................................ 3-1

3.1 IDENTIFICATION OF CONTAMINATION MECHANISM, SOURCE MEDIA, AND

TRANSPORT MECHANISMS ....................................................................................................... 3-1

3.2 IDENTIFICATION OF EXPOSURE MEDIA, PATHWAYS, AND RECEPTORS ....................... 3-2

3.2.1 Human Receptors ...................................................................................................................... 3-2

3.2.2 Ecological Receptors ................................................................................................................ 3-2

3.2.3 Soil ............................................................................................................................................ 3-3

3.2.4 Surface Water and Sediment ..................................................................................................... 3-3

3.2.5 Groundwater ............................................................................................................................. 3-4

4. FIELDWORK AND ANALYSIS .......................................................................................................... 4-1

4.1 GENERAL......................................................................................................................................... 4-1

4.2 MOBILIZATION/DEMOBILIZATION ........................................................................................... 4-1

4.3 CLEARING/GRUBBING ................................................................................................................. 4-2

4.4 SURFACE WATER AND LEACHATE SAMPLING ..................................................................... 4-3

4.5 SEDIMENT SAMPLING .................................................................................................................. 4-5

4.6 FISH TISSUE SAMPLING ............................................................................................................... 4-7

4.7 INVESTIGATION DERIVED WASTE ........................................................................................... 4-7

5. DATA QUALITY AND RECORD KEEPING ..................................................................................... 5-1

5.1 FIELD NOTES .................................................................................................................................. 5-1

5.2 PHOTOGRAPHS .............................................................................................................................. 5-2

5.3 SAMPLE NUMBERS AND LABELS ............................................................................................. 5-2

5.4 SAMPLE CHAIN-OF-CUSTODY FORMS ..................................................................................... 5-4

5.5 PACKAGING AND SHIPMENT ..................................................................................................... 5-4

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6. FIELD VARIANCES ............................................................................................................................ 6-1

7. EQUIPMENT DECONTAMINATION ................................................................................................ 7-1

8. PROJECT SCHEDULE ......................................................................................................................... 8-1

9. REFERENCES ...................................................................................................................................... 9-1

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LIST OF FIGURES

(Following Text)

Figure 1-1 Site Location Map

Figure 1-2 Site Features

Figure 1-3 Current Zoning and the Delineation of Investigation Areas

Figure 1-4 Delineation of Investigation Areas

Figure 1-5 Historical Soil Sample Locations

Figure 1-6 Historical Groundwater Sample Locations

Figure 1-7 Historical Surface Water Sample Locations

Figure 1-8 Historical Sediment Sample Locations

Figure 1-9 Historical Leachate Sample Locations

Figure 3-1 Preliminary General Conceptual Site Model for Human Health Exposure at the McLouth

CERCLA Site – Flow Diagram

Figure 3-2 Preliminary General Conceptual Site Model for Screening Ecological Risk at the McLouth

CERCLA Site – Flow Diagram

Figure 3-3 Countywide Landfill Preliminary Geologic Conceptual Site Model

Figure 3-4 Detroit Steel Company Property Preliminary Geologic Conceptual Site Model

Figure 4-1A Countywide Landfill Proposed Discrete Surface Water and Sediment Sampling Locations

Figure 4-1B Brownstown and Marsh Creek Proposed Discrete Surface Water and Sediment Sampling

Locations

Figure 4-1C Frank & Poet Drain Proposed Discrete Surface Water and Sediment Sampling Locations

Figure 4-1D Detroit Steel Company Property Proposed Discrete Surface Water and Sediment Sampling

Locations

Figure 4-1E Countywide Landfill Proposed Leachate Sampling Locations

Figure 4-1F Detroit Steel Company Property Proposed Leachate Sampling Locations

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LIST OF TABLES

(Following Figures)

Table 1-1 Summary of Historically Detected Soil Analytical Results in Investigation Areas Zoned for General Industrial or Commercial Use

Table 1-2 Summary of Historically Detected Soil Analytical Results in Investigation Areas Zoned for Residential or Planned Unit Development Use

Table 1-3 Summary of Historically Detected Groundwater Analytical Results in Investigation Areas

Zoned for General Industrial or Commercial Use

Table 1-4 Summary of Historically Detected Groundwater Analytical Results in Investigation Areas

Zoned for Residential or Planned Unit Development Use

Table 1-5 Summary of Historically Detected Surface Water Analytical Results

Table 1-6 Summary of Historically Detected Sediment Analytical Results

Table 1-7 Summary of Historically Detected Leachate Analytical Results

Table 3-1 McLouth Draft CSM Components

Table 4-1 Water Body and Creek Segment Sampling Rationale

Table 4-2 Discrete Sample Location Coordinates and Volatile Organic Compound Sample Locations for Surface Water and Sediment

Table 4-3 Proposed Leachate Sampling Locations

Table 4-4 Sample Analytes, Containers, Preservation, and Holding Time

Table 4-5 Field Quality Control Summary

APPENDICES

(Following Tables)

Appendix A USACE Engineering Manuals

Appendix B ASTM Standard Practices and Standard Operating Procedures

Appendix C Field Activity Forms

Appendix D Composite Sub-Sample Estimation and Concentration Threshold Analysis

Appendix E Random Number Generator Results for Volatile Organic Compound Sample Locations for

Surface Water and Sediment

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ACRONYM LIST

3D three-dimensional ACM asbestos containing material ADP Acid Dosing Pond AST above ground storage tank ASTM American Society for Testing and Materials bgs below ground surface C&D construction and demolition CERCLA Comprehensive Environmental Response, Compensation and Liability Act CERCLIS Comprehensive Environmental Response, Compensation and Liability Act

Information System CFR Code of Federal Regulations CH4 methane CLP Contract Laboratory Program cm/sec centimeters per second CO2 carbon-dioxide COC chain-of-custody COI constituent of interest COPC constituent of potential concern CSM Conceptual Site Model CTI Construction Testing & Inspection Inc.

CWLF Countywide Landfill DO dissolved oxygen DoD Department of Defense DOT Department of Transportation DQOs Data Quality Objectives DSSR Designated Site Safety Representative ELAP Environmental Laboratory Accreditation Program EM Engineering Manual EQM Environmental Quality Management, Inc.

FS Feasibility Study FSP Field Sampling Plan GSI Groundwater-Surface Water Interface H2S hydrogen sulfide HHRA human health risk assessment HSAs hollow stem augers IA investigation area IAA Interagency Agreement ID inside diameter IDW investigation derived waste LIDAR Light Detection and Ranging MCL maximum contaminant level McLouth McLouth Steel Products Corporation MDEQ Michigan Department of Environmental Quality mg/kg milligrams per kilogram mg/L milligrams per liter NAD 83 North American Datum of 1983 NCP National Oil and Hazardous Substances Contingency Plan

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NFRAP No Further Remedial Action Planned NPL National Priorities List NAVD 1988 North American Vertical Datum-1988 OD outside diameter ORP oxidation reduction potential O2 oxygen PA Preliminary Assessment PAHs polycyclic aromatic hydrocarbons PCBs polychlorinated biphenyls PID photoionization detector PM Project Manager PPE personal protective equipment PVC polyvinyl chloride QA/QC quality assurance/quality control RA Re-Assessment RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study ROD Records of Decision SDP Sludge Drying Pond SLERA Screening Level Ecological Risk Assessment SOP standard operating procedure SSHO Site Safety and Health Officer SSHP Site Safety and Health Plan SVOC semi-volatile organic compound the Site DSC McLouth Steel Gibraltar Plant TMP Tandem Mill Pond TSCA Toxic Substances Control Act UFP-QAPP Uniform Federal Policy for Quality Assurance Project Plans µg/L micrograms per liter USACE U.S. Army Corps of Engineers USCS Unified Soil Classification System USEPA U. S. Environmental Protection Agency VOCs volatile organic compounds

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1. INTRODUCTION

1.1 GENERAL

The following Field Sampling Plan (FSP) has been developed to support the Remedial Investigation (RI)/Feasibility Study (FS) at the DSC McLouth Steel Gibraltar Plant Site (the Site), U.S. Environmental Protection Agency (USEPA) Site ID No. MIN000510362, which is located in Gibraltar, Michigan (Figure 1-1). The U.S. Army Corps of Engineers (USACE) will perform the RI/FS under the authority of Interagency Agreement (IAA) No. DW-96-95874301-0 with the USEPA. Please note this FSP was developed with a focus on surface water, sediment, and leachate. General sections of this FSP may discuss all media at the Site, however details describing specific field activities for soil, groundwater, landfill investigation, etc. (Section 4.0) will be included subsequent to acceptance of the associated comments and revisions.

The field activities described within this FSP are consistent with the elements of an RI/FS set forth in the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA; 42 [USC] 9601 et seq.), as amended; the National Contingency Plan (NCP) of March 8, 1990 (40 Code of Federal Regulations [CFR] Part 300); and the USEPA guidance document entitled "Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA" (USEPA, 1988).

This FSP is supported by a Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) and a Site Safety and Health Plan (SSHP) that contains procedures and plans to be followed during the RI to protect the health and safety of field personnel. The UFP-QAPP and SSHP are contained in separate documents.

1.2 SITE DESRIPTION

The Site is located at 28000 West Jefferson Avenue, Gibraltar, Wayne County, Michigan (Figure 1-2). The geographic coordinates of the approximate center of the investigation area are 42°06'16.33" north latitude and 83°12'31.65" west longitude. The site consists of approximately 350 acres and was historically operated as a steel finishing operation with three landfills and a leachate treatment lagoon system. These site features are designated as Landfills A and B and the associated leachate treatment system, and Countywide Landfill (CWLF) located at 15701 Vreeland Road (Figure 1-2). Landfills A and B are located on the east side of the site and have an associated leachate treatment lagoon system. These landfills historically accepted steel manufacturing waste including mill scale, blast furnace dust, filter cake, and grit from McLouth Steel Products Corporation (McLouth) in Trenton as well as from on-site McLouth operations in Gibraltar. CWLF is located on the west side of the site and also historically accepted steel manufacturing waste from the Trenton and Gibraltar facilities, and later operated as a construction and demolition (C&D) debris landfill. The site also includes historical fill areas, ponds and areas of former ponds that were drained and filled with gravel and clay, on-site surface water conveyances including Marsh and Brownstown Creeks, and the Frank & Poet Drain, and native/undeveloped land.

For the purpose of this RI, the Site is bounded by West Jefferson Avenue, an International Wildlife Refuge, and residential homes to the east. Vreeland Road, residential homes, commercial property, and undeveloped land containing radio towers are north of the site. Gibraltar Road, residential homes, and a rail spur are to the south. The Consolidated Rail Corporation rail line and commercial properties are located to the west. Two rail lines and the Frank & Poet Drain bisects the site between Countywide Landfill and Landfill Areas A and B. Brownstown Creek drains into the Frank & Poet Drain, which flows into the Detroit River. The Trenton Channel of the Detroit River is approximately 1,500 feet east of the site. Two municipal drinking water intakes (i.e., the Belle Isle and Fighting Island intakes) are located on the Detroit

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River upstream from the Site. The Humbug Marsh, a Detroit River International Wildlife Refuge, is directly across West Jefferson Avenue from the Site.

1.3 SITE HISTORY

Operations at the Site began in 1954. McLouth owned and operated the property as a steel finishing facility, including annealing, pickling, and cold rolling processes. The Site consists of several different areas including: CWLF, Landfills A and B, the leachate treatment lagoon system, and other historic fill areas, which are described below. Portions of the land within the site boundaries are actively farmed and also currently zoned residential (Figure 1-3).

The Site was input into the CERCLA Information System (CERCLIS), the USEPAs inventory of hazardous waste sites, by the USEPA on August 1, 1980. The Site was originally assessed in the CERCLA process with Preliminary Assessments (PA) in 1987 and 1990 and given No Further Remedial Action Planned (NFRAP) status and archived. At the request of the Michigan Department of Environmental Quality (MDEQ), the USEPA conducted a removal action at the Site in 2010 which subsequently led to the Site being reentered into CERCLIS by the USEPA on March 2, 2010. The CERCLIS ID for the Site is MIN000510362. On March 23, 2011, based on new data, the Site was unarchived so that the MDEQ could conduct a Re-Assessment (RA) of the Site. Following the RA, the USEPA requested the Site be evaluated for National Priorities List (NPL) inclusion due to the following needs: 1) installation of final caps for all landfills; 2) resolution of leachate management and disposal needs; and 3) implementation of a long-term remedy to protect human health and the environment (MDEQ, July 2013). USEPA follows the provisions of the CERCLA of 1980, as amended, and the NCP for sites listed on the NPL. The Site was listed on the NPL on March 26, 2015. The NPL-listed site excludes the portion of the site housing the former steel mill building. The primary exposure pathway leading to the NPL listing is the surface water migration pathway.

Countywide Landfill

Development of CWLF began in the late 1970s by McLouth and filling operations began in January 1981.

The formerly active portion of the landfill is approximately 50 acres in size and is located to the west of the steel mill. The landfill is technically made up of a lower and upper landfill. The lower landfill was originally constructed over a dense native clay with engineered clay dikes around the perimeter and was formerly known as McLouth Steel Area 4. The lower landfill accepted steel manufacturing waste including mill scale, blast furnace dust, filter cake, and grit from the Trenton and Gibraltar plants until 1999. After the lower landfill no longer accepted steel mill waste, a C&D debris landfill was constructed on top of the lower landfill. At this time, the landfills were then collectively known as CWLF. The upper landfill received the last load of C&D waste in August 2007. CWLF is currently not operating and does not have an operating license.

Other areas around CWLF include: 1) an area historically used as an excavation/staging area located west of the North Pond; 2) on-site surface water conveyances including Marsh Creek, Brownstown Creek and the Frank & Poet Drain; 3) an area southwest of Marsh and Brownstown Creeks that appears to be largely native/undeveloped land in the Historical Aerial Photo Analysis and currently used for soy farming; 4) a former quarry located south of CWLF, which was partially filled in with road construction and other unknown debris and is currently known as Quarry Lake; and 5) a native/undeveloped area of grasslands, woodlands, and wetlands east of the North and South Ponds. An abandoned above ground storage tank (AST) has also been found in this area near the entrance to CWLF.

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Landfills A and B

Landfill A was constructed in 1977. The landfill is located south of the leachate treatment lagoon system and is approximately 23 acres in size. Landfill A was included in an industrial waste landfill license issued to McLouth in 1976 under Michigan’s original Solid Waste Management Act, 1965 PA 87. Landfill A was filled from 1977 into the early 1980s and initially capped in 1984. Construction of Landfill B began in 1959. The landfill is located west of the lagoon system and is approximately 32 acres in size. Landfill B was filled from the 1960s into the early 1970s, prior to landfill licensing requirements. Both landfills were constructed over a dense native clay with engineered clay dikes around the perimeter of the landfills. Both landfills accepted steel manufacturing waste including mill scale, blast furnace dust, filter cake, and grit from the Trenton and Gibraltar plants.

Other areas around Landfills A and B include the Frank & Poet Drain, and largely native/undeveloped land west of the Frank & Poet Drain.

Leachate Treatment Lagoon System

The leachate treatment lagoon system includes a series of interconnected ponds and basins including:

• Four water retention basins o water retention basin #1 (pH adjustment pond), o water retention basin #2 (solids settling pond), o water retention basin #3, and o water retention basin #4 (aeration pond #2);

• Two ponds o The Acid Dosing Pond (ADP), and o the Sludge Drying Pond (SDP); and

• Five ponds that make up the partially closed Tandem Mill Pond (TMP).

The lagoon system treated landfill leachate and oily process water generated by steel mill operations. The treated water was then discharged into an on-facility ditch. Spent noncontact cooling water used to cool the rollers, air compressors, generators, and annealing furnaces was also discharged to a storm drain, located west of the mill building. The effluent from the lagoon system and noncontact cooling water then mixed and discharged to the Frank & Poet Drain. The interconnections between the operational basins and ponds has been modified over time and currently share a common discharge point through an outfall from water retention basin #4.

Several abandoned ASTs have also been found around the leachate treatment lagoon system, west and south of the TMPs.

Historic Fill Areas

There are two main historic fill areas including the area north of Landfill B, and the area directly south of the ADP and SDP. The area north of Landfill B was formerly known as the northwest fill area and recently dubbed ‘Landfill X’ in the Historical Aerial Photo Analysis, however, there is no historical evidence available to indicate it is an actual landfill. The Historical Aerial Photo Analysis shows significant areas of the northwest fill area cleared in June 1959 with a more defined boundary appearing in August 1960.

After 1975, the area appears inactive and by 1978 vegetation can be seen growing within the boundaries of the area. Available information for the northwest fill area is very limited and the actual use of the area is unknown. Numerous abandoned ASTs and scrap material have also been found in this area. The area

1-4 directly south of the ADP and SDP was formerly known as the southeast fill area, however the actual use of the area is unknown. Review of the Historical Aerial Photo Analysis does not show much activity in this area.

1.4 CONSTITUENTS OF INTEREST

Based upon a review of data obtained from previous investigations, the following constituents of interest (COIs) that have been found at the site are listed below.

Countywide Landfill

Historically, samples from the two leachate streams at CWLF have been found to contain carbazole, mercury, silver, polychlorinated biphenyls (PCBs), selenium, vanadium, zinc, cyanide, carbon disulfide, phosphorus, naphthalene, 2,4-dimethylphenol, phenol, nickel, ammonia, and high pH.

Landfills A and B

Leachate from these landfills has been found to contain naphthalene, phenol, mercury, 2,4-dimethylphenol, barium, cyanide, ammonia, and high pH.

Leachate Treatment Lagoon System

Water discharged into the Frank & Poet Drain from the leachate treatment lagoon system contains documented phenols, PCBs, metals, and high pH.

1.5 STUDY AREAS

The Site has been broken into sixteen investigation areas (IAs) to focus the RI field activities and data analysis as related to impacts from known and potential sources of contamination. The study area boundaries may change based upon considerations made for future land use, findings of RI field activities, re-aligning risk areas, etc. The IA’s were further sub-divided into decision units, as explained below. The boundaries of the sixteen (IAs) are shown on Figure 1-4. The IA’s and decision units are as follows:

1. IA-01 is associated with the area southwest of Marsh and Brownstown Creeks that appears to be largely native/undeveloped in the Historical Aerial Photo Analysis; and is bound by Marsh and Brownstown Creeks to the northeast, two rail lines to the southeast, Gibraltar Road to the south, and the Consolidated Rail Corporation rail line and commercial properties to the northwest. It is currently utilized for soy farming.

a. Decision Units within this IA: This IA is not part of the current (spring 2018) surface water/sediment sampling effort, as it does not contain any surface water discharges or bodies. The analysis of historic documentation indicates that this area of the site was not used for any waste disposal/management purposes. However, there may be floodplain impacts from the presence of Brownstown and Marsh Creeks that traverse this IA which warrant sampling in a subsequent phase of investigation.

2. IA-02 is associated with the area around Quarry Lake; and is bound by Brownstown Creek to the northeast, two rail lines to the southeast, and IA-01 to the west and south.

a. Decision Units within this IA: Sediment and surface water will be sampled from Quarry

Lake. This will be designated DU-QL.

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3. IA-03 is associated with CWLF and surrounding undeveloped land; and is bound by a former pond area to the northeast, two rail lines to the southeast, Marsh and Brownstown Creeks to the southwest, and the Consolidated Rail Corporation rail line and commercial properties to the northwest.

a. Decision Units within this IA: Leachate samples will be collected from 6 locations at the edge of the landfill cover as part of the current (spring 2018) surface water/sediment sampling effort. These samples will be evaluated as part of DU-CWLF. An additional 4 leachate samples may be collected from proposed geotechnical borings on the landfill as part of a later phase of the RI.

4. IA-04 is associated with the small pond northwest of CWLF and filled ponds north of CWLF, as seen in the Historical Aerial Photo Analysis; and is bound by a former fill/staging area to the north, the North and South Ponds to the east, CWLF to the south, and the Consolidated Rail Corporation rail line and commercial properties to the west.

a. Decision Units within this IA: The small pond (“northwest pond”) will be sampled as part of the current surface water/sediment sampling effort. Surface water and sediment samples from this pond will be part of DU-NWP.

5. IA-05 is associated with a former excavation/staging area north of CWLF, as seen in the Historical

Aerial Photo Analysis; and is bound by Vreeland Road to the north, the North Pond to the east, a former pond area to the south, and the Consolidated Rail Corporation rail line and commercial properties to the west.

a. Decision Units within this IA: The only samples obtained within this IA to be evaluated as part of this phase of the risk assessment are groundwater samples obtained as part of the previous GSI sampling effort. These samples are considered part of IA-16 (groundwater).

The groundwater-based decision units are discussed below in conjunction with IA-16.

6. IA-06 is associated with the larger North and South Ponds on the CWLF property; and is bound by a former fill/staging area to the north and west, undeveloped land to the east, and an area of former ponds to the south.

a. Decision Units within this IA: The 2 ponds will be broken into three DU’s as follows: The north pond (NP) will be split in two DUs. Aside from the larger size driving the need for breaking this pond into 2 DU, there could be a gradient of sediment contamination due to a potential sediment depositional area near the drainage ditch inlet in the south half of the North Pond. Although the surface water may be relatively homogeneous, and exposure may not be segregated to one end of the pond, the potential heterogeneity in pond sediment supports breaking the pond into 2 DU’s. The northern portion of the pond will be designated DU-NP-001, the southern portion of the north pond will be designated DU-NP- 002, and the south pond in this IA will be designated DU-SP.

7. IA-07 is associated with the undeveloped area northeast of CWLF; and is bound by Vreeland Road to the north, two rail lines to the southeast, CWLF to the south, and the North and South Ponds to the west.

a. Decision Units within this IA: The drainage swale in IA-07 leading into the IA-06 ponds will be sampled as part of the current sediment sampling effort. The direction of flow within this drainage area is unknown. The flow likely originates from the Frank and Poet Drain, rather than from leachate from the CWLF. Therefore, although Figure 4-1C indicates a connection between these 2 points on a continuous drainage swale, the north (IA-07) portion of this drainage will be assessed separately from any sediment found in the southern (IA-03) portion of this drainage swale. This ditch in IA-07 will be designated

DU-DD7.

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8. IA-08 is associated with the on-site surface water conveyances including Marsh and Brownstown Creeks, and the Frank & Poet Drain.

a. Decision Units within this IA: Several reaches of each of these Creeks and Drain will be sampled as part of this surface water/sediment characterization phase. Each reach sampled will become its own decision unit. In addition, samples will be collected from areas of these Creeks and Drain from upgradient, off-site locations. The upgradient sample results will be used to differentiate site-associated releases to the water bodies from ambient, non-site related releases. As indicated in Table 1, the most upgradient, off-site reach will be designated as the 1st DU in each of the Creeks and Drains, and each subsequent downgradient reach sampled will be given a sequential DU number. There will be two DU’s in Marsh Creek (1 off-site, and another DU on-site), four DU’s in Brownstown Creek (1 off-site, and 3 on-site), and five DUs in Frank and Poet Drain (1 off-site, and 4 on-site).

9. IA-09 is associated with the undeveloped area west of IA-10, as seen in the Historical Aerial Photo

Analysis; and is bound by IA-10 to the east, Gibraltar Road to the south, and two rail lines to the west. This area is currently zoned for general commercial use.

a. Decision Units within this IA: This IA is not part of the current (spring 2018) surface water/sediment sampling effort, as it does not contain any surface water discharges or bodies. The analysis of historic documentation indicates that this area of the site was not used for any waste disposal/management purposes. However, there may be floodplain impacts from the presence of Brownstown and Marsh Creeks that traverse this IA which

10. IA-10 is associated with the undeveloped area west of Landfills A and B and the Frank & Poet

Drain, as seen in the Historical Aerial Photo Analysis; and is bound by the Frank & Poet Drain to the east, Gibraltar Road to the south, two rail lines to the northwest, and IA-09 to the west. This area is currently zoned for residential use.

a. Decision Units within this IA: This IA is not part of the current (spring 2018) surface water/sediment sampling effort, as it does not contain any surface water discharges or bodies. The analysis of historic documentation indicates that this area of the site was not used for any waste disposal/management purposes. However, there may be floodplain impacts from the presence of Brownstone and Marsh Creeks that traverse this IA which

11. IA-11 is associated with Landfills A and B; and is bound by historic fill areas to the north, West

Jefferson Avenue to the east, and the Frank & Poet Drain to the west. The leachate treatment lagoon system also forms an inclusion into IA-09.

a. Decision Units within this IA: Leachate samples will be collected from 6 locations across Landfills A and B as part of the current (spring 2018) surface water/sediment sampling effort. These samples will be evaluated as part of DU-AB. An additional 7 leachate samples may be collected from proposed geotechnical borings on the landfills as part of a later phase of the RI.

12. IA-12 is associated with a historic fill area, formerly known as the southeast fill area; and is bound by the leachate treatment lagoon system to the north, Landfill A to the east and south, and Landfill B to the west.

a. Decision Units within this IA: No surface water, sediment, or groundwater samples are planned for this IA; only soil samples will be collected during a later phase of the RI.

Decision units for soil within this IA will be presented in the plans associated with that sampling and investigation.

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13. IA-13 is associated with the portion of the leachate treatment lagoon system that includes the TMPs, ADP, and SDP; and is bound by the water retention basins to the north, Landfill A to the east, a historic fill area to the south, and Landfill B to the west.

a. Decision Units within this IA: This IA consists of 7 ponds, each of which will be considered its own decision unit. The identification of the DUs in this IA are as follows:

i. TMP1 (tandem mill pond #1)

ii. TMP2 (tandem mill pond #2)

iii. TMP3 (tandem mill pond #3)

iv. TMP4 (tandem mill pond #4)

v. TMP5 (tandem mill pond #5)

vi. ADP (acid dosing pond)

vii. SDP (sludge drying pond)

14. IA-14 is associated with the portion of the leachate treatment lagoon system that includes the water retention basins, a former oils storage pad area east of retention basin #2, and a former drum storage area west of retention basin #1; and is bound by the steel mill buildings to the north and east, the TMPs to the south, and Landfill B to the west.

a. Decision Units within this IA: This IA consists of 4 water retention basins, each of which will be considered its own decision unit. In addition, there is a depression from which a surface water sample will be taken. Finally, there is a ditch that traverses this IA and crosses into the adjacent IA-15 which will also be sampled. The identification of the DUs in this IA are as follows:

i. RB1 (water retention basin #1)

ii. RB2 (water retention basin #2)

iii. RB3 (water retention basin #3)

iv. RB4 (water retention basin #4)

v. DEP (depression in IA-14)

vi. 14/15 DD (drainage ditch traverses both IA-14 and 15)

15. IA-15 is associated with a historic fill area, formerly known as the northwest fill area and is bound by undeveloped land containing radio towers to the north, the steel mill buildings to the east, Landfill B to the south, and two rail lines to the west.

a. Decision Units within this IA: The drainage ditch that originates partly in IA-14 and partly in neighboring off-site former steel mill building property (split upgradient of IA-15) and traverses IA-15 will be sampled as part of this investigation. There will be 5 discrete samples collected along the length of the ditch crossing IA-14 and IA-15. This surface water/sediment DU will be designated 14/15DD. In addition, a groundwater sample was obtained within IA-15. Groundwater previously sampled within this IA will be included in the groundwater DU-GW-E3.

16. IA-16 is associated with all groundwater across the Site. Groundwater previously sampled (as part of the GSI sampling effort) will be evaluated in this phase of the risk assessment.

a. Groundwater decision units will be used to delineate groundwater sampling results according to geography as well as by a logical sub-contamination area, as follows:

i. DU-GW-W1: Quarry Lake (DU-QL). Note that no groundwater samples were collected in this area of the site during the recent GSI sampling. A groundwater sample is planned for subsequent RI phase.

ii. DU-GW-W2: Samples from IA-03 and IA-04 (likely impacted areas on CWLF).

iii. DU-GW-W3: Samples from IA-05 and IA-07 (disturbed or adjacent properties with wells).

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iv. DU-GW-E1: Samples from IA-11 and IA-12 (plant-site landfills).

v. DU-GW-E2: Samples from wells surrounding and within the pond systems (IA’s

13 and 14).

vi. DU-GW-E3: Samples from IA-15 historic fill area.

17. Background: As discussed as part of IA-08, samples will be collected from upgradient (off-site) areas of Marsh and Brownstown Creeks, as well as Frank & Poet Drain. These background areas will be designated as follows:

a. BC-001 (Brownstown Creek upgradient/off-site)

b. MC-001 (Marsh Creek upgradient/off-site)

c. FP-001 (Frank and Poet Drain upgradient/off-site)

1.6 SUMMARY OF PREVIOUS INVESTIGATIONS

A summary of the findings of each of these previous investigations and remedial activities may be found in the RI/FS Work Plan.

A summary of COI impacted media follows and has been broken down by study area.

1.6.1 Existing Soil Data

Previously collected data from the Site was evaluated in order to determine the potential extent of COI impacted soils. A summary of historically detected analytical results for soil samples in IAs zoned for general industrial or commercial use (IA-03, -04, -05, -06, -07, -09, -11, -12, -13, -14, and -15) and IAs zoned for residential or planned unit development use (IA-01, -02, and -10) compared to the more stringent of the Part 201 Generic Residential Drinking Water Protection Criteria, Groundwater-Surface Water Interface (GSI) Protection Criteria, Direct Contact Criteria, USEPA Resident Soil Regional Screening Levels, and Toxic Substances Control Act (TSCA) limits (40 CFR 761.61); or Statewide Default Background Levels are presented in Tables 1-1 and 1-2, respectively. Historical soil sampling locations are presented on Figure 1-5.

The USACE has reviewed available soil data and determined concentrations of COIs were detected above screening criteria in four of the nine general industrial and commercial zoned IAs (Table 1-1).

IA-03

Soil sample analytical results show minimal impact to soils in IA-03. Maximum concentrations of ammonia-nitrogen (0.76 milligrams per kilogram [mg/kg]) and iron (20,000 mg/kg) in background soil sample BS-1; and chloride (2,500 mg/kg) in background soil sample BS-2 were detected above screening criteria near the northwest and southwest sides of CWLF, respectively, and are the only compounds that exceed screening criteria. Soil samples collected from cover material at two leachate outbreak areas on the west and east sides of CWLF, also indicate exceedances of chloride, ammonia-nitrogen, and iron. No other compounds were detected in soil above screening criteria.

IA-04

There are no soil sample analytical results available for IA-04.

IA-05

There are no soil sample analytical results available for IA-05.

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IA-07

One soil sample has been collected within IA-07 showing minimal impact to soils. Concentrations of chloride (2,400 mg/kg) and iron (18,000 mg/kg) were detected above screening criteria in background soil sample BS-4 located along the north side of IA-07 near Vreeland Road, west of the Frank & Poet Drain. No other compounds were detected in soil above screening criteria.

IA-09

There are no soil sample analytical results available for IA-09.

IA-11

Soil sample analytical results show minimal impact to soils in IA-11. Maximum concentrations of the semi-volatile organic compound (SVOC), m,p-cresol (1.1 mg/kg) and arsenic (2.65 mg/kg) at GMW3 located near the northwest side of the ‘panhandle’ portion of Landfill A; and iron (31,000 mg/kg) in background soil sample BS1A1 located on the east side of Landfill A are the only compounds detected above screening criteria. Soil samples collected from cover material at 10 leachate outbreak areas across Landfills A and B, also indicate elevated concentrations of benzo(a)anthracene, phenol, ammonia-nitrogen, and iron above screening criteria. No other compounds were detected in soil above screening criteria.

IA-12

There are no soil sample analytical results available for IA-12.

IA-13

Soil sample analytical results indicate soil in IA-13 has been primarily impacted by metals. Maximum concentrations of SVOCs including m,p-cresol (1.6 mg/kg), benzo(a)anthracene (0.5 mg/kg), benzo(a)pyrene (0.5 mg/kg), and benzo(b)fluoranthene (0.6 mg/kg) at GSB1T located near the southwest corner of the TMP; and fluoranthene (10 mg/kg) and fluorene (19 mg/kg) at GSB2 located near the northwest corner of the TMP were detected above screening criteria. A maximum concentration of the PCB arochlor 1260 (0.42 mg/kg) at GB4, located south of the TMP, was detected above screening criteria.

Maximum concentrations of metals including cadmium (8.47 mg/kg) and zinc (2,600 mg/kg) at GB4;

lead (1,500 mg/kg), mercury (1.55 mg/kg) and silver (4.24 mg/kg) at GMW5 located south of the SDP;

arsenic (11.9 mg/kg) at GMW7 located west of the TMP ponds; and barium (1,050 mg/kg) and copper (71.5 mg/kg) at GSB1T were also detected above screening criteria. No other compounds were detected in soil above screening criteria.

A sample collected from a sludge pile located between TMP-3 and TMP-4 also indicated elevated maximum concentrations of SVOCs methylene chloride (0.18 mg/kg) and phenanthrene (42 mg/kg);

PCBs including arochlor 1248 (0.84 mg/kg) and arochlor 1260 (1.1 mg/kg); and metals including arsenic (12 mg/kg), barium (110 mg/kg), copper (65 mg/kg), lead (28 mg/kg), selenium (0.44 mg/kg), and zinc (280 mg/kg) above screening criteria. No other compounds were detected in the sludge sample above screening criteria.

IA-14

Soil sample analytical results indicate soil in IA-14 has been primarily impacted by metals. Maximum concentrations of SVOCs including benzo(a)anthracene (1.6 mg/kg), benzo(a)pyrene (1.1 mg/kg), 1-10 benzo(b)fluoranthene (1.4 mg/kg), and indeno(1,2,3-c,d)pyrene (0.3 mg/kg) at GMW9 located north of retention basin #2; and bis(2-ethylhexyl)phthalate (80 mg/kg) at GSB3 located near the northeast corner of the TMP were detected above screening criteria. A maximum concentration of the PCB arochlor 1248 (0.35 mg/kg) at GMW8, located west of retention basin #1, was detected above screening criteria.

Maximum concentrations of metals including arsenic (12.6 mg/kg), copper (76.4 mg/kg), silver (1.81 mg/kg), and zinc (725 mg/kg) at GMW8 were also detected above screening criteria. No other compounds were detected in soil above screening criteria.

IA-15

There are no soil sample analytical results available for IA-15.

The USACE has reviewed available soil data and determined concentrations of COIs were detected above screening criteria in one of the three residential and planned unit development zoned IAs (Table 1-2).

IA-01

There are no soil sample analytical results available for IA-01.

IA-02

Soil sample analytical results indicate soil in IA-02 has been primarily impacted by polycyclic aromatic hydrocarbons (PAHs) and metals. Maximum concentrations of PAHs including benzo(a)anthracene (5.5 mg/kg), benzo(a)pyrene (5.2 mg/kg), benzo(b)fluoranthene (4.7 mg/kg), benzo(k)fluoranthene (4 mg/kg), fluoranthene (13.5 mg/kg) and phenanthrene (9.1 mg/kg); and metals including arsenic (19 mg/kg), barium (757 mg/kg), lead (857 mg/kg), selenium (3.3 mg/kg), and zinc (701 mg/kg) were detected above screening criteria in sample Trench#3 located in a fill area west of Quarry Lake. Copper was also detected above screening criteria at a maximum concentration of 92 mg/kg in sample Trench#2 also located in a fill area west of Quarry Lake. No other compounds were detected in soil above screening criteria.

IA-10

There are no soil sample analytical results available for IA-10.

1.6.2 Existing Groundwater Data

Previously collected data from the Site was evaluated in order to determine the potential extent of COI impacted groundwater. Groundwater across the site has been combined into one investigation area (IA- 16). A summary of historically detected analytical results for groundwater samples in IAs zoned for general industrial or commercial use (IA-03, -04, -05, -06, -07, -09, -11, -12, -13, and -14) and IAs zoned for residential or planned unit development use (IA-01, -02, and -10) compared to the more stringent of the USEPA Maximum Contaminant Levels (MCLs), Part 201 Generic Residential Drinking Water Protection Criteria, GSI Protection Criteria, and USEPA Tapwater Regional Screening Levels are presented in Tables 1-3 and 1-4, respectively. Historical groundwater sampling locations are presented on Figure 1-6.

The USACE has reviewed available groundwater data and determined concentrations of COIs were detected above screening criteria in twenty-four groundwater monitoring wells across the Site and two test trenches in IA-02 (Tables 1-3 and 1-4).

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IA-16

Analytical results indicate groundwater in IAs zoned for general industrial or commercial use has been primarily impacted by phenolic compounds, PAHs, and metals. Maximum concentrations of 2,4-dimethylphenol (1,520 micrograms per liter [µg/L]) and 3,4-methylphenol (250 µg/L) in perched groundwater at GMW4 located south of the TMP; and phenol at MW-02 (700 µg/L) located along the southwest edge of CWLF were detected above screening criteria. Several PAHs were detected above screening criteria at A06U, GMW4, GMW4D, GMW9, MW-103R, and MW-105. The highest concentrations of PAHs were detected at A06U located north of the northwest fill area, with the exception of naphthalene which was detected in perched groundwater at GMW4. Maximum concentrations of chloride (2,270 milligrams per liter [mg/L]), cyanide (1.8 mg/L), and ammonia-nitrogen (32.4 mg/L) were also detected above screening criteria in samples collected from the zone of perched groundwater at GMW4. Maximum concentrations of cobalt at A01UR (17.2 µg/L) located north of CWLF, aluminum (3,140 µg/L), arsenic (8 µg/L), iron (6,680 µg/L), and vanadium (8.9 µg/L) at A06U, copper (60 µg/L) and lithium (311 µg/L) at GMW4, boron (422 µg/L) and cadmium (2.1 µg/L) at GMW4D, and manganese at A03D (529 µg/L), all located along the east edge of Landfill A; mercury at A07D (0.048 µg/L) located at the south end of Landfill A; and strontium (34,700 µg/L) and thallium (0.12 µg/L) at MW-107 located north of the North Pond were also detected above screening criteria. No other metals were detected above screening criteria.

Analytical results indicate groundwater in IAs zoned for residential or planned unit development use has been primarily impacted by metals. Three PAH compounds including: fluoranthene (8 µg/L), naphthalene (6 µg/L), and phenanthrene (13 µg/L) were detected above screening criteria in groundwater sample Trench#3 located in a fill area west of Quarry Lake. No other SVOCs were detected above screening criteria in any of the samples. In the Landfill A area, maximum concentrations of chloride (344 mg/L), aluminum (14,900 µg/L), antimony (1.4 µg/L), cobalt (10 µg/L), copper (20.8 µg/L), iron (20,600 µg/L), lead (11 µg/L), lithium (43.8 µg/L), manganese (598 µg/L), thallium (0.7 µg/L), and vanadium (37.4 µg/L) were detected above the screening criteria in well A02D. Concentrations of ammonia-nitrogen (0.58 mg/L) and strontium (13,100 µg/L) were also detected above screening criteria at A08D near Landfill A. Arsenic was detected above screening criteria at Trench#3 (10 µg/L) near Quarry Lake.

No other metals were detected above screening criteria.

1.6.3 Existing Surface Water Data

Previously collected data from the Site was evaluated in order to determine the potential extent of COI impacted surface water. A summary of historically detected analytical results for surface water samples compared to GSI Protection Criteria is presented in Table 1-5. Historical surface water sampling locations are presented on Figure 1-7.

The USACE has reviewed available surface water data and determined concentrations of COIs were detected above GSI Protection Criteria at twenty-seven sampling locations across the Site.

IA-02

Surface water analytical results indicate there were no compounds detected at concentrations exceeding screening criteria in the sample collected from the water filled portion of the quarry, currently known as Quarry Lake.

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IA-04

Analytical results indicate surface water in the small pond northwest of CWLF has been primarily impacted by pesticides and metals. The pesticides aldrin (0.015 µg/L) and heptachlor (0.064 µg/L) were detected in surface water sample EPA-MLSS-WS-004 above GSI criteria in October 2015, however were not detected in January 2016. Maximum concentrations of chloride (360 mg/L), cyanide (0.086 mg/L), and TDS (1,800 mg/L) were detected above GSI criteria in sample EPA-MLSS-WS-004. Maximum concentrations of metals including arsenic (28 µg/L), selenium (10 µg/L), silver (0.27 µg/L), and vanadium (32 µg/L) were also detected above GSI criteria. No other compounds were detected above GSI criteria. A moderate odor and milky appearance were also observed at the sample location in October 2015 and January 2016.

The odor and color may be related to the analytical results for surface water sample EPA-MLSS-WS-004 collected in January 2016 were similar to that of leachate sample EPA-MLSS-WL-001 (see Section 1.6.5) collected from the CWLF leachate collection sump in January 2016.