McLouth_Steel_SW-SED_UFP-QAPP_(Final_3-29-18).pdf

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REMEDIAL INVESTIGATION/FEASIBILITY STUDY

QUALITY ASSURANCE PROJECT 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

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TABLE OF CONTENTS

APPENDICES .............................................................................................................................................. ii

INTRODUCTION ....................................................................................................................................... vi

QAPP Worksheet #1 & 2: Title and Approval Page

QAPP Worksheet #3 & 5: Project Organization and QAPP Distribution

QAPP Worksheet #4, 7 & 8: Personnel Qualifications and Sign-off Sheet

QAPP Worksheet #6: Communication Pathways

QAPP Worksheet #9: Project Planning Session Summary

QAPP Worksheet #10: Conceptual Site Model

QAPP Worksheet #11: Project/Data Quality Objectives

QAPP Worksheet #12: Measurement Performance Criteria

QAPP Worksheet #13: Secondary Data Uses and Limitations

QAPP Worksheet #14/16: Project Tasks & Schedule

QAPP Worksheet #15: Project Action Limits and Laboratory-Specific Detection/Quantitation Limits

QAPP Worksheet #17: Sampling Design and Rationale

QAPP Worksheet #18: Sampling Locations and Methods

QAPP Worksheet #19 & 30: Sample Containers, Preservation, and Hold Times

QAPP Worksheet #20: Field QC Summary

QAPP Worksheet #21: Field SOPs

QAPP Worksheet #22: Field Equipment Calibration, Maintenance, Testing, and Inspection

QAPP Worksheet #23: Analytical SOP’s

QAPP Worksheet #24: Analytical Instrument Calibration

QAPP Worksheet #25: Analytical Instrument and Equipment Maintenance, Testing, and Inspection

QAPP Worksheet #26 & 27: Sample Handling, Custody, and Disposal

QAPP Worksheet #28: Analytical Quality Control and Corrective Action

QAPP Worksheet #29: Project Documents and Records

QAPP Worksheet #34: Data Verification and Validation Inputs

QAPP Worksheet #35: Data Verification Procedures

QAPP Worksheet #36: Data Validation Procedures

QAPP Worksheet #37: Data Usability Assessment

References ii

APPENDICES

Appendix A RTI Analytical Standard Operating Procedures Appendix B Chain-of-Custody Form iii

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LIST OF ACRONYMS AND ABBREVIATIONS

ARARs

AST

CELRB-TD-EE

CELRB-TD-EH

CELBR-TD-HD

CELRE-PM

CELRL-ED-E

applicable or relevant and appropriate requirements above ground storage tank Corps of Engineers, Great Lakes and Ohio Rivers Division-Buffalo District- Technical Services Division-Environmental Engineering Team

Corps of Engineers, Great Lakes and Ohio Rivers Division -Buffalo District- Technical Services Division-Environmental Health Team

Corps of Engineers, Great Lakes and Ohio Rivers Division -Buffalo District- Technical Services Division-H&H Engineering Team

Corps of Engineers, Great Lakes and Ohio Rivers Division -Detroit District- Project Management Division

Corps of Engineers, Great Lakes and Ohio Rivers Division –Engineering Division- Engineering Team

CERCLA

COC

Comprehensive Environmental Response, Compensation, and Liability Act Chain-of-custody

COI

CRL

Constituent of interest Chicago Regional Laboratory

DL detection limit DoD

DQI

Department of Defense data quality indicator

DQO Data Quality Objective

DWSD

EDD

Detroit Water and Sewage Department electronic data deliverable

FS

FSP

Feasibility Study Field Sampling Plan

GSI

HAZWOPER

Groundwater to surface water interface Hazardous Waste Operations and Emergency Response

IA

LCS

Investigation area laboratory control sample (also called a “blank spike”)

LCSD laboratory control sample duplicate LOD limit of detection LOQ limit of quantitation

MDEQ

Michigan Department of Environmental Quality v

MPC method performance criteria MQO measurement quality objective MS/MSD matrix spike/matrix spike duplicate NCP National Oil and Hazardous Substances Contingency Plan PAL project action limit PARCCS Precision, Accuracy, Representativeness, Comparability, Completeness, and

Sensitivity PCB(s)

PCE

PDF

PID

Polychlorinated biphenyl(s) perchloroethene, aka tetrachloroethene, tetrachloroethylene, or perchloroethylene portable document format photoionization detector

PM Project Manager PQL practical quantitation limit

PUD

QA

Planned unit development quality assurance

QA/QC quality assurance and quality control QC quality control QSM Quality Systems Manual for Environmental Laboratories RI Remedial Investigation RPD relative percent difference SAP Sampling and Analysis Plan SOP standard operating procedure SSHP Site Safety and Health Plan SVOC(s) Semi-volatile organic compounds(s) TBD to be determined

TCE

TDS

TOC

TSS

trichloroethene aka trichloroethylene total dissolved solids total organic carbon total suspended solids

UFP-QAPP Uniform Federal Policy Quality Assurance Project Plan USACE United States Army Corps of Engineers

USEPA

VOA

United States Environmental Protection Agency volatile organic analysis

VOC volatile organic compound WS worksheet vi

INTRODUCTION

This Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP) has been prepared by the United States Army Corps of Engineers (USACE)-Buffalo District for the Remedial Investigation (RI) at the DSC McLouth Steel Gibraltar Plant in Gibraltar, MI. This UFP-QAPP (USEPA 2005, USEPA 2012), and its companion document, the Field Sampling Plan (FSP) comprise the Sampling and Analysis Plan (SAP) for this project. Together, these documents define investigation objectives, procedures, and quality assurance and quality control (QA/QC) for this project. Please note this UFP-QAPP was revised with a focus on surface water, sediment, and leachate. This UFP-QAPP may discuss all media at the Site, however details describing specific details for soil, groundwater, etc. will be included subsequent to acceptance of the associated comments and revisions.

The objective of this RI is to collect and evaluate Site information of sufficient quality and quantity to delineate the contamination; assess contaminant fate and transport and develop baseline risk assessments, and document the results in an RI Report. The work under this RI will be conducted based on the “Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (USEPA, 1988)”. The work is being conducted by the USACE, Buffalo District, in compliance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the National Oil and Hazardous Substances Contingency Plan (NCP), and United States Environmental Protection Agency (USEPA) guidance.

Summary or revisions made to this UFP-QAPP (Revision No. 1):

This UFP-QAPP has been revised in order to incorporate the subcontractors contact information, communication pathways, measurement performance criteria, chain-of-custody (COC) form, and standard operating procedures (SOPs) for a commercial laboratory. RTI Laboratories Inc. (RTI) will be the primary laboratory to be used for this project. Perfluorinated compounds (PFCs) in leachate was recently added to the list of required analyses and is incorporated within this QAPP. The USEPA Region 5 Chicago Region Laboratory (CRL) will be used for the analysis of PFCs in leachate. This QAPP has also been revised to indicate Level IV validation is required for any risk assessment decisions and is planned for this project. The information on all relevant worksheets has been updated and relevant SOPs have been provided as an attachment. All revisions/updates within the document have been highlighted for ease of identification.

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Table 1. Crosswalk: UFP-QAPP Workbook to 2106-g-05 QAPP (USEPA 2012)

Optimized UFP-QAPP Worksheets 2106-G-05 QAPP Guidance Section

1 & 2 Title and Approval Page 2.2.1 Title, Version, and Approval/Sign-Off

3 & 5 Project Organization and QAPP Distribution

2.2.3 Distribution List

2.2.4 Project Organization and Schedule

4 , 7 & 8 Personnel Qualifications and Sign-off Sheet 2.2.1 Title, Version, and Approval/Sign-Off

2.2.7 Special Training Requirements and

Certification

6 Communication Pathways 2.2.4 Project Organization and Schedule

9 Project Planning Session Summary 2.2.5 Project Background, Overview, and Intended Use of Data

10 Conceptual Site Model 2.2.5 Project Background, Overview, and Intended Use of Data

11 Project/Data Quality Objectives 2.2.6 Data/Project Quality Objectives and Measurement Performance Criteria

12 Measurement Performance Criteria 2.2.6 Data/Project Quality Objectives and Measurement Performance Criteria

13 Secondary Data Uses and Limitations Chapter 3 QAPP ELEMENTS FOR EVALUATING

EXISTING DATA

14 & 16 Project Tasks & Schedule 2.2.4 Project Organization and Schedule

15 Project Action Limits and Laboratory- Specific Detection / Quantitation Limits

2.2.6 Data/Project Quality Objectives and

Measurement Performance Criteria

17 Sampling Design and Rationale 2.3.1 Sample Collection Procedure, Experimental Design, and Sampling Tasks

18 Sampling Locations and Methods 2.3.1 Sample Collection Procedure , Experimental Design, and Sampling Tasks

2.3.2 Sampling Procedures and Requirements

19 & 30 Sample Containers, Preservation, and Hold Times

2.3.2 Sampling Procedures and Requirements

20 Field QC 2.3.5 Quality Control Requirements

21 Field SOPs 2.3.2 Sampling Procedures and Requirements

22 Field Equipment Calibration, Maintenance, Testing, and Inspection

2.3.6 Instrument/Equipment Testing, Calibration

and Maintenance Requirements, Supplies and Consumables

23 Analytical SOPs 2.3.4 Analytical Methods Requirements and Task Description

24 Analytical Instrument Calibration 2.3.6 Instrument/Equipment Testing, Calibration and Maintenance Requirements, Supplies and Consumables viii

Optimized UFP-QAPP Worksheets 2106-G-05 QAPP Guidance Section

25 Analytical Instrument and Equipment Maintenance, Testing, and Inspection

2.3.6 Instrument/Equipment Testing, Calibration

and Maintenance Requirements, Supplies and Consumables

26 & 27 Sample Handling, Custody, and Disposal 2.3.3 Sample Handling, Custody Procedures, and Documentation

28 Analytical Quality Control and Corrective Action

2.3.5 Quality Control Requirements

29 Project Documents and Records 2.2.8 Documentation and Records Requirements

31, 32 &

Assessments and Corrective Action 2.4 ASSESSMENTS AND DATA REVIEW

(CHECK)

2.5.5 Reports to Management

34 Data Verification and Validation Inputs 2.5.1 Data Verification and Validation Targets and Methods

35 Data Verification Procedures 2.5.1 Data Verification and Validation Targets and Methods

36 Data Validation Procedures 2.5.1 Data Verification and Validation Targets and Methods

37 Data Usability Assessment 2.5.2 Quantitative and Qualitative Evaluations of Usability

2.5.3 Potential Limitations on Data Interpretation

2.5.4 Reconciliation with Project Requirements

Remedial Investigation McLouth Steel Site, Detroit, MI

QAPP Worksheet #1 & 2: Title and Approval Page (UFP-QAPP Manual Section 2.1)

(EPA 2106-G-05 Section 2.2.1)

1. Project Identifying Information

a. Site name/project name: Remedial Investigation of the DSC McLouth Steel Gibraltar

Plant

b. Site location: Gibraltar, Michigan

c. USEPA ID Number: MIN000510362

2. Lead Organization - United States Army Corps of Engineers (USACE)

a. Project Manager:

Jeff Follett – Detroit District

b. Project Engineer and Field Lead:

Tim Ifkovich – Buffalo District

3. United States Environmental Protection Agency

a. Remedial Project Manager:

Demaree Collier

b. Chemist:

Alida Roberman, Ph.D.

QAPP Worksheet #3 & 5: Project Organization and QAPP Distribution (UFP-QAPP Manual Section 2.3 and 2.4) (EPA 2106-G-05 Section 2.2.3 and 2.2.4)

This project is being conducted by USACE personnel on behalf of the USEPA. Subcontractors will be utilized for drilling and laboratory analysis.

A physical copy or electronic version of the Uniform Federal Policy-Quality Assurance Project Plan (UFP-QAPP) will be made available to all field personnel, including subcontractors and other stakeholders, including USEPA, Michigan Department of Environmental Quality (MDEQ), and town officials (upon request).

QAPP Recipients Title Organization Telephone Number E-mail Address

Demaree Collier Project Manager USEPA 312-886-0214 Collier.Demaree@epa.gov

Cindy Fairbanks Project Manager MDEQ 517-284-5093 Fairbanksc@michigan.gov

Beth Place Geologist MDEQ 517-284-5139 Placeb1@michigan.gov

Jeff Follett Project Manager CELRE-PM 313-226-2210 Jeffrey.C.Follett@usace.army.mil

Peter Lorey Project Chemist CELRB-TD-EH 716-879-4158 Peter.M.Lorey@usace.army.mil

Tim Ifkovich Project Engineer CELRB-TD-EE 716-879-4161 Timothy.W.Ifkovich@usace.army.mil

Neil Miller Field Operations/DSSR CELRB-TD-EH 716-879-4274 Neil.T.Miller@usace.army.mil

Mark Legeza Field Operations CELRB-TD-EH 716-879-4106 Mark.Legeza@usace.army.mil

Karen Keil Project Risk Assessor CELRB-TD-EH 716-879-4227 Karen.G.Keil@usace.army.mil

Michelle Barker Senior Environmental Engineer CELRB-TD-EE 716-879-4198 Michelle.C.Barker@usace.army.mil

Jeffrey Hall Environmental

Engineering Section Chief

CELRB-TD-EE 716-879-4272 Jeffrey.S.Hall@usace.army.mil mailto:Collier.Demaree@epa.gov mailto:Fairbanksc@michigan.gov mailto:Placeb1@michigan.gov mailto:Jeffrey.C.Follett@usace.army.mil mailto:Peter.M.Lorey@usace.army.mil mailto:Timothy.W.Ifkovich@usace.army.mil mailto:Neil.T.Miller@usace.army.mil mailto:Mark.Legeza@usace.army.mil mailto:Karen.G.Keil@usace.army.mil mailto:Michelle.C.Barker@usace.army.mil mailto:Jeffrey.S.Hall@usace.army.mil

QAPP Recipients Title Organization Telephone Number E-mail Address

William Frederick Hydrogeologist CELRB-TD-HD 716-879-4243 William.T.Frederick@usace.army.mil

Neil Miller Acting Environmental Health Section Chief CELRB-TD-EH 716-879-4274 Neil.T.Miller@usace.army.mil

Chino Ortiz Project Manager RTI Laboratories 734-422-8000 ext 303 cortiz@rtilab.com

QAPP Worksheet #4, 7 & 8: Personnel Qualifications and Sign-off Sheet (UFP-QAPP Manual Sections 2.3.2 – 2.3.4)

(EPA 2106-G-05 Section 2.2.1 and 2.2.7)

ORGANIZATION: U.S. Army Corps of Engineers (USACE)

Name Project Title/Role Education/Experience Specialized Training/Certifications Signature/Date Jeff Follett Project Manager Electrical Engineer Program Management – Boston University Tim Ifkovich Project Engineer Geologist 40-Hour HAZWOPER w/annual refresher Peter Lorey Project Chemist Ph.D., chemistry 40-Hour HAZWOPER w/annual refresher, National Registry of Certified Chemists – Environmental Analytical Chemist

Karen Keil Human Health and Ecological Risk Assessment Lead

Ph.D., environmental toxicology

40-Hour HAZWOPER w/annual refresher

ORGANIZATION: CRL Laboratory

Name Project Title/Role Education/Experience Specialized Training/Certifications Signature/Date USEPA Region 5 Chicago Region Laboratory (CRL)

ORGANIZATION: RTI Laboratories Inc.

Name Project Title/Role Education/Experience Specialized Training/Certifications Signature/Date Chino Ortiz Laboratory PM NA NA

*Signatures indicate personnel have read and agree to implement this UFP-QAPP as written

QAPP Worksheet #6: Communication Pathways (UFP-QAPP Manual Section 2.4.2)

(EPA 2106-G-05 Section 2.2.4)

This worksheet (WS) should be used to document specific issues (communication drivers) that will trigger the need to communicate with other project personnel or stakeholders. Its purpose is to ensure there are procedures in place for providing the appropriate notifications and generating the appropriate documentation when handling important communications, including those involving regulatory interfaces, unexpected events, emergencies, non-conformances, and stop-work orders. Examples are provided below; additional drivers may be added as needed.

Communication Driver Organization Name Contact Information Procedure

(Timing, Pathway, Documentation, etc.)

Contractual updates including milestones and schedule

CELRE-PM USACE PM

Jeff Follett

313-226-2210 Jeffrey.C.Follett@usace.army.mil

Monthly reports, including schedule updates, are subject to PM review. PM for USACE will coordinate all project correspondence with the contractor.

Communication of new USACE directives

CELRB-TD-EE Tim Ifkovich 716-879-4161 Timothy.W.Ifkovich@usace.army.mil

USACE guidance and interaction for project team

Contractor project management needs; field progress reports

CELRE-PM USACE PM

Jeff Follett

313-226-2210 Jeffrey.C.Follett@usace.army.mil

Overall project management actions coordinated with the PM. The PM will maintain lines of communication among USACE, regulatory stakeholders, and subcontractors.

Stop work due to safety issues

USACE See Site Safety and Health Plan

(SSHP)

See SSHP All employees on site have stop-work authority. The Designated Site Safety Representative has overall authority for safety on site, and is responsible for ensuring all employees and subcontractors follow applicable safety plans.

QAPP changes prior to fieldwork and during project execution

CELRB-TD-EH Peter Lorey 716-879-4158 Peter.M.Lorey@usace.army.mil

QAPP changes following QAPP approval will be documented and reasons for the change will be clearly communicated to the client by the PM within 24 hours of receipt of information justifying the change. QAPP changes are subject to USEPA approval.

(Timing, Pathway, Documentation, etc.)

Field corrective actions CELRB-TD-EE Tim Ifkovich 716-879-4161

Timothy.W.Ifkovich@usace.army.mil The field lead will determine the need for field corrective actions. Any corrective actions will be communicated to the USACE PM within 24 hours.

Field implementation CELRB-TD-EE Tim Ifkovich 716-879-4161 Timothy.W.Ifkovich@usace.army.mil

Prepare Quality Control Reports, implement Final UFP-QAPP in the field, identify field discrepancies, and prepare field documentation.

Sample receipt variances / Laboratory quality control variances

USEPA Region

5 CRL

Lawrence Zintek

312-886-2925 zintek.lawrence@epa.gov

The laboratory PM will communicate any sample receipt issues immediately via phone or e-mail to the Project Chemist. If the issue requires action, the Project Chemist will consult with the PM, who will work with the Technical Manager to address any related field issues. Quality assurance (QA) /quality control (QC) issues will be reported to the Project Chemist. The Project Chemist will work with the laboratory to identify the issue and possible solutions; this information will be communicated immediately to the PM and Technical Manager.

Analytical corrective actions

USEPA Region

5 CRL

Lawrence Zintek

312-886-2925 zintek.lawrence@epa.gov

Analytical corrective actions will be made by laboratory personnel. Any action affecting data quality, turnaround-time, or data reporting will be communicated by the laboratory analysts to the laboratory PM, who will in turn communicate will the Project Chemist via e-mail or phone immediately upon identification of the issue. All issues will be documented and communicated by the Project Chemist to the Technical Manager and PM immediately.

Sample receipt variances / Laboratory quality control variances

Laboratory Chino Ortiz 734-422-8000, ext 303 cortiz@rtilab.com

The laboratory PM will communicate any sample receipt issues immediately via phone or e-mail to the Project Chemist. If the issue requires action, the Project Chemist will consult with the PM, who will work with the Technical Manager to address any related field issues. Quality assurance (QA) /quality control (QC) issues will be reported to the Project Chemist. The Project Chemist will work with the laboratory to identify the issue and possible

(Timing, Pathway, Documentation, etc.)

solutions; this information will be communicated immediately to the PM and Technical Manager.

Analytical corrective actions

Laboratory Chino Ortiz 734-422-8000, ext 303 cortiz@rtilab.com

Analytical corrective actions will be made by laboratory personnel. Any action affecting data quality, turnaround-time, or data reporting will be communicated by the laboratory analysts to the laboratory PM, who will in turn communicate will the Project Chemist via e-mail or phone immediately upon identification of the issue. All issues will be documented and communicated by the Project Chemist to the Technical Manager and PM immediately.

Data verification or validation issues, e.g., incomplete records

CELRB-TD-EH Peter Lorey 716-879-4158 Peter.M.Lorey@usace.army.mil

Under the direction of the Project Chemist, data will be verified in as close to real time as possible. The Project Chemist will coordinate between the subcontract laboratory and project team to resolve any discrepancies. The Project Chemist will immediately contact the laboratory PM upon identification of noncompliant laboratory actions.

The Technical Manager will be notified of any laboratory noncompliance and the impact on project objectives within 24 hours.

QAPP Worksheet #9: Project Planning Session Summary (UFP-QAPP Manual Section 2.5.1 and Figures 9-12)

(EPA 2106-G-05 Section 2.2.5)

Date of planning session: 10 August 2016 Location: Conference Call Purpose: Discuss how MDEQ would apply their Part 201 regulations and discuss the implications of the zoning-based Part 201 regulations on the investigation area (IA) boundaries proposed for the RI/FS purposes at the DSC McLouth Steel Gibraltar Plant Site.

Please note that revisions to the work plans have been made since this planning session was conducted.

Participants:

Name Organization Title/Role Email/Phone Tim Ifkovich CELRB-TD-EE Project Engineer See WS#3/5 Michelle Barker CELRB-TD-EE Senior Project

Engineer See WS#3/5

Karen Keil CELRB-TD-EH Risk Assessor See WS#3/5 Cindy Fairbanks MDEQ Project Manager See WS#3/5 Beth Place MDEQ Geologist See WS#3/5

MDEQ updated the Part 201 cleanup goals as of December 30, 2013. This update removed the limited residential and limited non-residential facility categories in Section 324.20120a of the Natural Resources and Environmental protection Act. However, the residential and non-residential facility categories still exist in the proposed ruling. Additional updates to the Part 201 cleanup goals are still under development with the largest impact occurring with how vapor intrusion will be handled.

For investigation under CERCLA, risk is typically characterized down to 1E-06. MDEQ’s residential cleanup goals are based on 1E-05. MDEQ requested that USACE characterize at least residential risk at the site, regardless of zoning or potential future use.

IA-01: This IA is zoned planned unit development and shall be compared to the more stringent of residential and groundwater to surface water interface (GSI) criteria. MDEQ Part 201 Residential Cleanup Criteria are considered Unlimited Use/Unrestricted Exposure and is considered the lowest criteria available. MDEQ was unsure whether areas of agricultural use are exempt to Part

201 standards. The agricultural field and area around Quarry Lake may have to be subdivided out from the rest of IA-01.

Subsequent to the conference call, MDEQ provided USACE with two additional historical documents referencing the Site. One of the documents show potential contaminant impact in fill material in the area around Quarry Lake which will lead to subdividing this area into an additional IA.

IA-02, -03, -04, -05, -06: These IAs are all zoned general industrial and shall be compared to the more stringent of non-residential and GSI criteria. The investigation area boundary between IA- 01 and IA-02 is currently identified as the creek. USACE shall adjust this boundary to match the boundary on the current zoning map. The City of Gibraltar has been contacted and have no plans at this point to change the zoning districts.

IA-07: Surface water shall be compared to surface water quality criteria. The MDEQ will check if their Rule 57 Water Quality Values numbers for Groundwater Surface Water Interface and Surface Water are the same.

Separate IA’s for ecological risk may be needed, which would likely focus on the surface water drainages (IA-07) and wetlands. Toxicologists from MDEQ may also provide input for the risk assessment.

IA-08: This IA will be split into two IAs to reflect the residential and industrial zoning districts.

The residential zoned portion of the current IA-08 shall be compared to the more stringent of residential and GSI criteria. The industrial zoned portion of the current IA-08 shall be compared to the more stringent of non-residential and GSI criteria.

IA-09, -10, -11, -12: These IAs are all zoned general industrial and shall be compared to the more stringent of non-residential and GSI criteria.

IA-13: The bedrock aquifer is not useable as a drinking water source due to its high saline content, however it is still considered “water of the state” and warrants protection. The upper aquifer is not continuous throughout the site and is also not useable as a drinking water source, however it is still considered “water of the state” and warrants protection.

GSI criteria also needs to be considered for groundwater because surface water is used for fishing and drinking. The more stringent of the residential drinking water and GSI criteria shall be used.

Restrictions may be applied to the use of groundwater in the future.

Default GSI criteria may be used or potentially higher site-specific GSI values may be developed after new data is gathered and MDEQ issues a ‘mixing zone determination memo’. The MDEQ will provide an example of a mixing zone determination from another site. This would apply to the groundwater as a site-specific GSI cleanup criteria. There would be specified GSI wells which would have to meet the site-specific GSI. The area surrounding the site has municipal water supplied from intakes along river and lake.

The creeks are identified as recreational. Daphnia toxicological studies may need to be performed for both creeks. An ecological risk assessment will also need to take into account the local fisheries along the Detroit River.

MDEQ shall provide USACE with an example of a mixing zone determination memorandum, communicate proposed changes to Part 201 cleanup goals, which may include an agricultural exemption, and verify whether their surface water quality criteria and groundwater surface water interface criteria are the same.

USACE provided MDEQ with the USEPA presumptive remedy guidance for landfills, as requested, on August 10, 2016.

MDEQ requested additional time to review the Data Quality Objectives (DQOs) provided to them on August 8, 2016. In addition, as a result of this conference call, the proposed IAs will be revised and the DQOs shall also be revised to reflect the new proposed IAs.

QAPP Worksheet #10: Conceptual Site Model (UFP-QAPP Manual Section 2.5.2)

(EPA 2106-G-05 Section 2.2.5)

QAPP Worksheet #11: Project/Data Quality Objectives (UFP-QAPP Manual Section 2.6.1)

(EPA 2106-G-05 Section 2.2.6)

11.1 State the Problem

Describing the problem.

The Site is a historic steel mill situated in the midst of residential neighborhoods and adjacent to the Detroit River International Wildlife Refuge. The Site consists of three landfills (Countywide Landfill, Landfill A, and Landfill B), a leachate treatment lagoon system, historic fill/soil areas, and adjacent lands not apparently used for waste disposal activities. Portions of the land within the site boundaries are actively farmed and also currently zoned residential. Countywide Landfill has historically had frequent leachate outbreaks that migrate into Brownstown Creek, Marsh Creek, and/or the Frank & Poet Drain, which drain into the Detroit River. Landfills A and B have also had historical leachate outbreaks. Leachate from Landfills A and B is collected and treated in the leachate treatment lagoon system which includes a series of 4 water retention basins, 2 ponds, and the partially closed Tandem Mill Pond. The lagoon system treated oily process water generated by steel mill operations and leachate from Landfills A and B. Treated water was then discharged through an outfall into the Frank & Poet Drain which leads to the Detroit River. The current system has not been properly maintained and does not reliably meet effluent discharge requirements.

Water discharged into the Frank & Poet Drain from the lagoon system contains documented contaminants.

Historic fill/soil areas include a large fill area west of the steel mill buildings, noted as “Landfill X” on the Historical Aerial Photo Analysis Report, which includes soil piles, and empty aboveground storage tanks (ASTs), drums, boilers, piping, and scrap material. Other ASTs and drums are deposited in an uncontrolled manner across the site. The Humbug Marsh, a Detroit River International Wildlife Refuge, is also located east of the Site.

A majority of the Site is zoned general industrial (M-3) or general commercial (C-2). However, vacant/undeveloped portions of the Site are zoned either one-family residential (R-1) or planned unit development (PUD), which allows for mixed-land uses (including residential).1

The City of Gibraltar utilizes surface water drawn from the Detroit River as its primary drinking water source. The Detroit Water and Sewerage Department (DWSD) uses water drawn from two intakes in the Detroit River; one to the north near the mouth of Lake St. Clair; and one to the south near Lake Erie.

Although the area is serviced through a municipal utility, there are sporadic private groundwater wells; the closest of which is located within two (2) miles of the Site.

Countywide Landfill and Landfills A and B

Determine the presence/nature and extent of landfill leachate seeps from each landfill that may impact all applicable media.

Determine the extent of landfilled material and extent of interim cap.

Assess current landfill conditions for future design of a permanent landfill cap.

Determine the presence/nature and extent of landfill gas on environmental quality.

Evaluate the potential for vapor intrusion pathway if volatile organic compounds are determined to be present in soil or groundwater above specific vapor intrusion screening levels.

Determine the potential human health and ecological risk associated with exposure to various media.

1 City of Gibraltar Zoning Map (revised in June 2002) http://www.cityofgibraltar.net/Portals/1016/general%20pdfs/zoning%20map%20201603170921.pdf http://www.cityofgibraltar.net/Portals/1016/general%20pdfs/zoning%20map%20201603170921.pdf

Determine fate and transport of potential contaminants.

Historic Fill Areas

Northwest Fill Area and Southeast Fill Area

Determine the nature and extent of the historic fill areas and potentially impacted soil associated with the fill areas.

Evaluate the potential for vapor intrusion pathway if volatile organic compounds are determined to be present in soil or groundwater above specific vapor intrusion screening levels.

Determine the potential human health and ecological risk associated with exposure to various media.

ASTs/Scrap Material

Determine if ASTs, drums, boilers, piping, and scrap material contain content and, if so, determine the nature and extent of impacts of content on all applicable media.

Evaluate the potential for vapor intrusion pathway if volatile organic compounds are determined to be present in soil or groundwater, if temporary monitoring wells are installed, above specific vapor intrusion screening levels.

Determine the potential human health and ecological risk associated with exposure to various media.

Leachate Treatment Lagoon System

Determine the nature and extent of the contents (surface water and sediment) of the leachate treatment lagoon system and impacted media, including the thickness of the sediment within each pond/basin.

Determine the potential human health and ecological risk associated with exposure to various media.

Surface Water Bodies (On-site Ponds and Bordering Conveyances)

Determine the nature and extent of impacted media associated with surface water bodies.

Determine if the surface water and sediment quality of the north, northwest, and south ponds near

CWLF, Brownstown Creek, Marsh Creek and/or the Frank & Poet Drain have been adversely impacted by groundwater and/or surface water discharges from the landfills, leachate treatment lagoon system, and/or historic fill areas.

Determine the potential human health and ecological risk associated with exposure to various media.

Determine fate and transport of potential contaminants.

If warranted, determine if off-site properties and receptors are being adversely impacted by releases to on-site surface water and sediment.

Groundwater

Determine the nature and extent of impacted Site groundwater.

Determine the potential for groundwater/surface water interaction in the areas of the landfills, leachate treatment lagoon system, and historic fill areas.

Determine the on-site potential human health risk associated if exposed to Site groundwater.

Determine the characteristics of the site hydrology that affect fate and transport of the constituents of interest (COI).

Determine what the current and future potential is for the groundwater to be used for drinking water purposes.

General Assumptions

Based upon a review of data obtained from previous investigations at the site, the initial list of COIs based on previous detections for each area for soil, groundwater, surface water, sediment, and leachate consists of:

o Volatile organic compounds (VOCs);

o Semi-volatile organic compounds (SVOCs);

o Metals;

o Pesticides;

o Polychlorinated biphenyls (PCBs);

o Herbicides; and o Miscellaneous parameters (i.e. cyanide, ammonia, etc.).

The contents of the ASTs/scrap material will be sampled for the COIs listed above. The ASTs/scrap material will also be sampled for lead and asbestos, if present.

Landfill gas readings will be collected at CWLF, Landfills A and B.

Based upon RI results, the presumptive remedy may include:

o Consolidation and regrading the landfill waste material where appropriate.

o Installation of final caps for proper closure of all of the landfills.

o Remediation of impacted media.

o Closure of all ponds associated with the leachate treatment lagoon system (Tandem Mill Pond, Acid Dosing Pond, and the Sludge Drying Pond).

o Resolution of leachate management and disposal needs.

o Enhancements to water retention basins for treatment of leachate from Landfills A and B.

o Implementation of a long-term remedy to protect human health and the environment.

o ASTs/scrap material may be properly recycled.

o Actions to reduce or limit conveyance of site contaminants to off-site properties or receptors via surface water drainages.

Establishing the planning team.

The following individuals are members of the planning team.

Name Title Organization Demaree Collier USEPA Region 5 Remedial Project Manager (RPM) Jeffrey Follett USACE Project Manager CELRE-PM Timothy Ifkovich Project Engineer CELRB-TD-EE Michelle Barker Senior Environmental Engineer CELRB-TD-EE Jeff Hall Chief, Environmental Engineering Section CELRB-TD-EE Steve Bousquet Chief, Environmental Health Section CELRB-TD-EH Peter Lorey Chemist CELRB-TD-EH Karen Keil Risk Assessor CELRB-TD-EH Chantelle Carroll Wildlife Biologist/ Ecological Risk Assessor CELRB-TD-RW Hal Harrington Biologist CELRE-PLE Rich Ruby Fisheries Biologist/Ecologist CELRB-PM-EA Neil Miller Health and Safety CELRB-TD-EH Shawn McCabe GIS Specialist/Database Manager CELRB-TD-EH Roseanne Weidner Industrial Hygienist CELRB-TD-EH William Frederick Hydrogeologist CELRB-TD-HD David Mitchell Geotechnical Engineer CELRB-TD-DC Cindy Fairbanks Michigan DEQ (Remediation and Redevelopment Division) Beth Place Michigan DEQ (Geology and Defense Site Management Unit)

Describing the conceptual site model of the potential hazard.

The basic elements of the preliminary conceptual site model (CSM) are:

1. Contamination Mechanisms

a. Landfilling of waste

b. Placement of fill and/or debris/scrap

c. Aboveground storage tanks

d. Insufficient cover over landfilled material

e. Creation of leachate treatment lagoon system and tandem mill ponds.

2. Source Media

a. Landfilled waste

b. Lagoons/ponds

c. ASTs/scrap material

3. Transportation Mechanisms

a. Volatilization or generation of dust from surface

b. Leaching to groundwater

c. Soil impacts from leachate seeps (as applicable)

d. Surface water drainage/discharges

e. Uptake through food chain

f. Groundwater migration and seepage/discharge to surface water

g. Landfill gas migration

h. Vapor migration from impacted media (if volatile organic compounds are determined to be present in soil or groundwater above specific vapor intrusion screening levels)

4. Exposure Media

a. Air

b. Food Chain (biological)

i. Non-game (forage fish, invertebrates, birds, small mammals)

ii. Game not likely to be caught on site, but may be impacted at nearby off-site locations (game fish and big and small game as identified permissible to hunt at the Humbug Island unit)

c. Surface water

d. Sediment

e. Surface soil

f. Subsurface soil

g. Groundwater

5. Exposure Routes

a. Ingestion (food chain, groundwater)

b. Dermal contact

c. Inhalation (fugitive dust)

d. Inhalation (vapors)

6. Current and Future Human Receptors

a. Resident/farmer

b. Maintenance worker

c. Commercial or industrial workers

d. Construction worker

e. Trespassers/recreational users

7. Current and Future Ecological Receptors

a. Aquatic organisms

b. Terrestrial organisms

Identifying the general intended use of collected data.

The intended use of the data collected is to:

1. Identify the nature and extent of source areas and impacted media, and subsequent fate and transport;

2. Allow for the collection of sufficient and appropriate data necessary to develop alternatives for the proper closure of the landfills and leachate treatment lagoon system;

3. Allow for the collection of sufficient and appropriate data necessary to determine whether areas outside the landfills and leachate treatment lagoon system have been impacted, or if no further action is needed;

4. Determine potential human health and ecological risks associated with exposure to various on-site media;

5. Allow for the collection of sufficient and appropriate data necessary to determine whether on-site drains and creeks provide habitat for ecological receptors which may be visiting the site from the neighboring international wildlife refuge, and therefore warrant protection, restoration, or mitigation to reduce exposure;

6. Allow for the collection of sufficient and appropriate data necessary to determine whether on-site drains and creeks are a source of fish for recreational anglers which may have adverse effects on human health; or forage fishes that have sufficient contaminant concentrations to impact game or non-game receptors;

7. Allow for the collection of sufficient and appropriate data necessary to determine whether off-site properties or receptors are being adversely impacted by discharges to on-site media (groundwater, surface water / sediment); and

8. Identify any imminent human health or ecological risks that may need to be mitigated through the implementation of interim remedial measures (IRMs).

Identifying available resources, constraints, and deadlines.

Data collected from previous investigations ranging from 1983 to the present is available for review. A cursory review of the historic data indicates that some data quality is marginal and the validity of some data is unclear. Some historic data are considered suitable for screening only (i.e., guide RI sampling and lessen the uncertainty of extent delineation, but not suitable for risk assessments). Historic stratigraphic data is inadequate due to irregular, inconsistent, and/or absent geologic descriptions. The most recent subsurface data collected (i.e., 1997) was found to be the most descriptive, although limited to the area around the leachate treatment lagoon system.

11.2 Identify the Goal of the Study

Specifying the primary study question.

The primary questions to be answered are:

What is the areal extent and what COIs are present in the source(s)?

What is the areal extent and what COIs are present in impacted media?

What type of habitat and benthic and fish communities are present in on-site surface water bodies (Frank & Poet Drain, Marsh and Brownstown Creeks)?

What is the potential on-site human health and ecological risk associated with exposure to various media?

What are the characteristics of the site geology and hydrology that affect fate and transport of the COIs?

What are the current conditions of Countywide Landfill, Landfill A, and Landfill B?

What is the current and future potential of the aquifer for drinking water purposes?

Determining the alternative actions.

The possible actions that would result from review of the data include:

Optimal configuration of the waste forms and installation of final caps for proper closure of all of the landfills.

Remediation of impacted media.

Closure of all ponds associated with the leachate treatment lagoon system (Tandem Mill Pond, Acid Dosing Pond, and the Sludge Drying Pond).

Resolution of leachate management and disposal needs at Countywide Landfill.

Enhancements to or optimization of water retention basins for treatment of leachate from Landfills A and B.

Implementation of a long-term remedy to protect human health and the environment.

ASTs/scrap material may be properly recycled.

Changes to site drainages that would either mitigate exposures, improve drainages, and/or enhance/restore habitat, as appropriate.

Specifying the decision statements.

The decision statements are as follows:

Determine if there is source media present in each source area.

Determine the areal extent of impacted media.

Determine fate and transport of COIs.

Determine the potential human health and ecological risks associated with exposure to various media.

Determine overall closure requirements.

11.3 Identify Information Inputs

Identifying the types of information that are needed to resolve the decision statements.

The types of information that are needed to resolve the decision statements are as follows:

Review of historical documents.

Review of historical aerial photo analysis.

On-site reconnaissance.

o Determination of ecological exposures including available habitat.

o Determination of on-site fishing spots.

Off-site investigation.

o Locating drinking water wells and local fishing spots.

o Determining potential exposures to human and ecological receptors, if necessary.

Intrusive investigative activities.

o Field measurements and observations.

o Collection of samples from each potentially impacted media for laboratory analysis and comparison to applicable or relevant and appropriate requirements (ARARs).

o Collection of samples for geotechnical analysis (important for remedy sustainability).

Identifying the source of information.

The planning team will obtain the required data during the RI field activities. In addition, historical data, historical aerial photo analysis, environmental data resources, and site reconnaissance will be used for screening, as described by the limitations discussed in Step 1.

Identifying how the Action Level will be determined.

Potential chemical-specific ARARs for the Site are as follows. Potential action- and location-specific ARARs will be identified in the RI/FS Work Plan. All contaminants detected during the RI will be compared against the following chemical-specific criteria:

Federal Regulation

Citation Description

Toxic Substances Control Act

40 CFR 761.61(4) PCB cleanup levels for PCB remediation waste

Clean Water Act - Toxic Pollutant Effluent Standards

40 CFR Part 129.100-105

CWA establishes effluent standards for contaminants, such as PCBs, in navigable waters of the US and regulates quality standards for surface waters.

State Regulation Citation Description

Michigan Act 451, Part 201 – Environmental Remediation

R 299.44 Generic Groundwater Cleanup Criteria1

R 299.48 Generic Soil Cleanup Criteria1,2

Michigan Act 451, Part 31 – Water Resources Protection

R 323.1041-

Surface Water Quality Standards for the protection of wildlife and human health3

1 Residential [MCL 324.201(1)(ss)] and non-residential [MCL 324.201(1)(ii)] land use categories are defined by statute. A remedy other than unrestricted residential must be consistent with the current zoning of the property.

2 Statewide default background levels, as listed in R 299.46 and 299.48, may be substituted if higher than the generic cleanup criterion. Background levels may be less than criteria for some inorganic compounds.

3 Surface water (in drainages/ponds/creeks) will be compared to surface water quality criteria for protection of aquatic life. Background values and risk-based consensus concentrations developed by MacDonald et al (USEPA 2002) will be used for screening sediment results.

Identifying appropriate sampling and analysis methods.

The attached Table 1 summarizes the appropriate sampling and analysis methods by media.

11.4 Define the Boundaries of the Study

Specifying the target population (i.e., media).

The target media include:

Soil

Groundwater

Surface water

Sediment

Leachate Landfill Gas

Vapor (if volatile organic compounds are determined to be present in soil or groundwater above specific vapor intrusion screening levels)

Bioaccumulation Analysis may be performed if appropriate o Fish tissue o Whole fish o Bioassays

Specifying the spatial boundaries for collecting data.

A title search has been performed to help determine the boundaries of the study area. For the purpose of this RI, the site area is bounded by Vreeland Road to the north; West Jefferson Avenue to the east; Gibraltar Road to the south; and the Consolidated Rail Corporation (Conrail) rail line to the west. The Site will be broken into 16 investigative areas (IAs) to focus the RI field activities and data analysis as related to impacts from known and potential sources. The sixteen study areas as referenced on Figure 1 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.

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.