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Page 1: US EPA Region VImage(s) in SDMS is equivalent to hard copy. Specify Type of Document(s) / Comments: ... Preliminary Remedial Investigation Activities Task JL-1 Background Data Collection

US EPA Region VImagery Insert Form

Document ID:

Some images in this document may be illegible or unavailable inSDMS. Please see reason(s) indicated below:

Illegible due to bad source documents. Image(s) in SDMS is equivalent to hard copy.

Specify Type of Document(s) / Comments:

Includes COLOR or RESOLUTION variations.Unless otherwise noted, these pages are available in monochrome. The source document page(s) is more legible than theimages. The original document is available for viewing at the Superfund Records Center.

Specify Type of Document(s) / Comments:

Confidential Business Information (CBI).This document contains highly sensitive information. Due to confidentiality, materials with such information are not available

in SDMS. You may contact the EPA Superfund Records Manager if you wish to view this document.

Specify Type of Document(s) / Comments:

Unscannable Material:Oversized or Format.

X || Due to certain scanning equipment capability limitations, the document page(s) is not available in SDMS. The originaldocument is available for viewing at the Superfund Records center.

Specify Type of Document(s) / Comments:

Maps

Document is available at the EPA Region 5 Records Center.

Specify Type of Document(s) / Comments:

EPA Region 5 Records Ctr

1111innnii208846

Page 1

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0 000 1 1

DRAFT WORK PLAN

FOR RI/FS

ANTRIM IRON WORKS SITE

ANTRIM, MICHIGAN

prepared by

Environmental and Safety Designs, Inc

Memphis, TN

Job No.: 1025-001

July, 1984

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TABLE OF CONTENTS

DRAFT WORK PLAN

TRANSMITTAL LBTTER

EXECUTIVE SUMMARY

Section >-. 0

i'.l

DRAFT MORE PLAN SUMMARY

Objectives of the Remedial Investigation and

Feasibility Study (RI/FS)

. 2 Scope of Work

3- Schedule

Section 2.0 PROBLEM ASSESSMENTi*''

2-. I Site History and Description

,2.2 Nature and Extent of the Problem

-2.3 Previous Investigations and Remedial Actions

.2,8 4 Environmental Settings

Section _>.0

J-. 1

3,« 2

3.3

SCOPE OF WORK

Introduction

Preliminary Remedial Investigation Activities

Task JL-1 Background Data Collection

Site Mapping

Quality Assessment Plan

Site Health and Safety Plan

Site Operations Plan Field Office

Subsurface Investigation of the Antrim

Iron Works Plant Site

Sampling and Analysis of Local Private

Wells (off-site)

Soil and Surface Water Sampling

Final Work Plans'

Remedial Investigation

Task 2-1 Hydrogeological Study

Task 2-2 Soil, Sediment and Water Sampling and

Analysis Program

Task

Task 1 ?

Task i *

Task s

Task 1 6

Task l

Task L-8

Task

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TABLE OF CONTENTS (continued)

DRAFT WORK PLAN

Task 2-3 Remedial Investigation Report

Task 3-1 Feasibility Study

Task 3-2 Conceptual Design

Task 3-3 Final Report

Section SUPPORT ACTIVITIES

Task -1 Meetings and Technical Support

Task £^*2: Community/Media Relations

Section >.t) PROJECT MANAGEMENT, COSTS, AND SCHEDULES

Project Management

Project Deliverables and Meetings

Cost Estimates

Project Schedule

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Executive Summary

The following is a Draft Work Plan for the Remedial Investigation

and Feasibility Study of Alternatives for the Antrim Iron Works

Site (a.k.a. Tar Lake) in Mancelona, Michigan.

The Draft Work Plan has been prepared for Gulf+Western

Manufacturing Company, Inc. which apparently is the owner of aPes$tbf4--

portion of the site. Other^ owners include the Mancelona Chamber

of Commerce, J. H. Gilmer (private individual), Moeke Lumber, and

the Antrim Iron Works Company or its successors. A Remediby •& «'

Action Master Plan (RAMP) has been prepared for the site^\ TheDraft Work Plan is designed to implement the RAMP. Where

proposed tasks differ from the RAMP, the difference is clearly

noted.

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1.0 DRAFT WORK PLAN SUMMARY

The following is a draft Work Plan for a Remedial Investigation

and Feasibility Study (RI/FS) of remedial alternatives for the

Antrim Iron Works Site (a.k.a. Tar Lake) in Antrim County,

Michigan. The Work Plan has been prepared as a draft due to

limited data available for detailed planning. The Draft Work

Plan therefore specifies: (1) actions already taken to acquire

site data; (2) actions required to prepare a Final Work Plan; and

(3) actions proposed to complete an RI/FS of the site.

The Draft Work Plan also includes a detailed schedule and budget

for the RI/FS. The overall format is:

* Work Plan Summary (Section 1)

* Problem Assessment (Section 2)

* Technical Approach (Section 3)

* Management Plan (Section 4)

* Costs and Schedule (Section 5)

The Draft Work Plan has been prepared for Gulf+Western

Manufacturing Company, Southfield, Michigan (G+W). The company

is the apparent owner of a portion of the site. The Draft Work

Plan assumes that overall Project Management will be performed by

G+W using specialized contractors. This assumption is made by

the Draft Work Plan authors for the purpose of developing a

Management Plan and should not be construed as a definite

commitment by G+W.

1.1 Objectives of the Remedial Investigation and Feasibility

Study (RI/FS)

The RI/FS objectives at the Antrim Iron Works Site are:

* to delineate the presence or absence of contamination at

the site;

1-1

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to determine whether groundwater contamination has

occurred in the vicinity of the site, the areal extent

of such contamination; and the impact, if any, on nearby

private wells;

^ to identify a list of potential remedial actions for the

Antrim Iron Worka Site and evaluate applicability/

feasibility of these actions for remediation of site

contamination;

* to recommend the most appropriate remedial alternative(a)

to mitigate negative site impacts (on-site and/or

off-site); and

£/ to prepare a conceptual design and cost estimates for any

remedial alternative(s) chosen for implementation.

The first step in achieving these objectives is a Remedial

Investigation (site investigation) that will provide the data

required to determine the appropriate remedial action. The

Remedial Investigation will provide the technical information

regarding the nature of the contributing waste materials at the

site; the flow paths and impacts of contamination on various

media; the flow paths and impacts of contamination if no remedial

action is taken; and identify potential risks to the public

health and welfare and the environmental impacts of various

remedial action alternatives.

The second atep in the planning process is the Feasibility Study,

which utilizes the data and conclusions of the Remedial

Investigation to develop, evaluate, and select final remedials

actions. The final step is to develop the conceptual design of

the selected remedial actions.

1-2

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1.2 Scope of Work

The Draft Work Plan proposes a four phase project, with

individual phases subdivided into specific tasks. The four

phases are:

Phase I - Activities Needed (or Completed) For Preparation of

Final Work Plan

Phase II - Site Remedial Activities

Phase III - Feasibility Study

Phase IV - Support Activities

All Phase I, II, and III tasks included in the Scope of Work are

described in Section 3, Technical Approach. Phase IV tasks are

described in Section 4, Management Plan.

The Scope of Work and associated technical approach are based

upon a series of assumptions, which are necessary due to the

limited data available on the site. Phase I tasks are designed

to eliminate as many of these assumptions as possible. The Final

Work Plan will therefore be prepared at the end of Phase I.

The technical approach, cost estimates, and schedule are based on

the following assumptions.

1. The area of investigation (definition of "site") has been

broadly defined to include Tar Lake, the fenced area

surrounding Tar Lake, the closed Mancelona landfill, Peckham

Lake, and Nelson Lake and surrounding land. Phase I tasks are

designed to yield sufficient data to determine the "site" more

scientifically.

1-3

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,l» kef

1.3 Schedule

The area of the site is subject to severe weather conditions

during winter months. The proposed project schedule in Section 5

allows for up to three months of delay due to weather-related

conditions that prevent sampling activities.

2. Level D worker protection procedures are assumed for all /

tasks, except sampling/drilling on Tar Lake itself, where —

Level C is required.

3. G+W Manufacturing Company will provide a field

office/laboratory/safety office adjacent to the site.

4.' It is assumed that the EPA Contract Laboratory Program (CLP) J

will not be used; however laboratories chosen will meet

QA/QC requirements equivalent to the CLP. All data

generated will be documented so that traceability and

accountability are maintained.

5. It is assumed for purposes of the groundwater investigation

in Phase II that the direction of groundwater flow in the

unconfined aquifer is generally to the northwest.

Preliminary investigations under Phase I are intended to

confirm this assumption. * "~

6. The surface/subsurface soil sampling protocol in Phase II

assumes that the specific location(a) of waste generating

processes can be identified from 1938 aerial photography.

In the event that insufficient detail is available,

geophysical methods such as ground penetrating radar, may be

utilized.

1-4

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2.0 PROBLEM ASSESSMENT

2.1 Site History and Description

The Antrim Iron Works Site is located in Antrim County, Michigan.

The site, shown in Figure 2-1, occupies 40+ acres just east of

Highway 131, approximately one mile south of Mancelona, Michigan

(population 1500). It is situated in a rural, undeveloped area

except to the northwest where the village of Antrim (population

540) is located.

From 1882 (source: Mancelona Herald, July 10, 1890) to 1945,

the site was the manufacturing location for companies producing

iron by the charcoal method. (Source: Mancelona Area Centennial

Commission). From 1882 to 1886, the site was occupied by the

John Otis Charcoal Iron Furnace Company. In 1886 the Antrim Iron

Works Company (AIWC) took over the site, and by 1890, AIWC

operated the world's largest charcoal furnace., AIWC produced

20,000 tons of iron annually, using hardwood charcoal made

on-site in kilns. In 1910 the company began producing charcoal^

in sealed retorts from which crude pyroligeneous liquor was crecovered. This liquor was then further processed into calcium

acetate, methanol, acetone, creosote oil, and wood tar. This/

secondary chemical manufacturing process produced a waste

equivalent to still bottoms which was discharged into a

depression on-site. This depression, now called Tar Lake,

received annually the waste aiii-L. bottoms generated from

45-50,000 cords of wood. The ?FrTTa~ce was closed in 1943. The

fgTTemlcal plarTt^ was closed in early 1944 and all AIWC operations ^-^j'^y

ceased in 1945 after which the company was placed in receivership

and the site was salvaged. The site received wood for tar

wastes, therefore, from 1910 to 1944.

No containerized wastes are present and no record of subsequent

waste discharges have been found. Current landowners include,

among others, G+W Manufacturing Company (a.k.a. Mount Clemens

Metal Products), the Township of Mancelona, Antrim Iron Works

Company or its successors and Moeke Lumber Co. The latter

2-1

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K.I

ANTRIM

COUNTY

TAR LAKE ttTft

VICINITY MAP

C A L E IH MlllS

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operates a lumber mill south of Tar Lake?) Figure 2-2 shows

propertyboundaries.The Township of Mancelona operated an

8-acre municipal landfill on the site for approximately eight

years (1961-1969). G+W has not utilized the site, except for two

warehouses located northwest of Tar Lake. These warehouses are

used to store machinery and parts for a plant located in

Mancelona, one mile north of Tar Lake (Source: G+W Manufacturing

Company).

The amount and type of wastes placed in the Mancelona landfill

are unknown. However, exposed portions of the landfill contain

drums and surface water in the landfill shows evidence of

leachate production.

It has been reported that Tar Lake caught fire in the 1960s and

burned for an unspecified period before being extinguished by

natural action.

The site itself is characterized by severe topographic relief

(see attached topographic map). No permanent or intermittent

streams are present and there appears to be no surface run-off

from the site. In addition to Tar Lake, the site contains many

//'large slag piles, piles of limestone, and ruins of AIWCi

operations. A strong chemical odor is present near Tar Lake. A

large sludge plume is evident on the west site of the lake.

Figure 2-2 shows site features and property boundaries.

2.2 Nature and Extent of the Problem

Data collection to date at the Antrim Iron Works Site and in the

surrounding area has been poorly coordinated. However, evidence

of off-site private well contamination by phenols was first

established in the 1940s and confirmed as recently as 1980.

Phenols are a typical "leachable" waste from wood tar waste

storage areas. Heavy metal contamination has also been

documented, although the source of these metals has not been

established. The apparent absence of surface run-off, the

evidence of existing off-site groundwater contamination, and the

2-3

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0»«[« KCVH1 C . f H O I M t ' A

P » O C l » C * » C O

C « « t « H A h C E l C K A C K A M I t *

O F : e U I » t » C C

• I ' t • I BCII»

C* l ( * • - • • A B t ' A C T U * •! C O — -

C e i l * A B T I l M i«o i C O• A T ( « W I L L

L**D O W N E R S H I P

L A K E V I C I N I T Y

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nature of the wood tar wastes have been considered in establish-

ing a tentative list of major environmental concerns for purposes

of the Draft Work Plan. The major concerns are:

* direct human contact with the wood tars in Tar Lake and

the associated sludge plume and contaminated soil;

* contamination of the unconfined aquifer on-site and

subsequent contamination of off-site drinking water wells;

* potential air quality problems due to the possibility of

a recurrence of the 1960s fire on Tar Lake; and

* potential for Tar Lake contaminants to enter the

environmental food chain due to exposure of flora and

fauna at the site.

2.3 Previous Investigations and Remedial Actions

A number of limited investigations of Tar Lake have been

conducted since 1949. A complete list may be found in the

Remedial Action Master Plan, April 30, 1984. A summary of

these investigations and findings is shown below.

1949 Eight private wells off-site were found to be contamin-

ated with phenols at low levels. One of the wells,

according to the owner, had been contaminated "for forty

years." Contaminated wells were located west and north-

west of the site.

1980 Elevated lead levels are found in several Mancelona area

wells.

1980 Analyses of Tar Lake sludge by MDNR exhibit heavy metals

and phenols.

1982 Monitoring wells (4) are installed at Tar Lake. Results

of analyses are reported as "inconclusive."

2-5

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1983 Limited testing of Tar Lake performed by G+W. Results

showed high phenol levels but no detectable heavy metals \ \ £

-*s1984 Soil samples taken by G+W at the Mancelona landfill /

show Low levels of lead, phenols, trichloroethylene, L Leas*

xylene, benzene, methylene chloride, methyl isobutyl/ ^^

ketone and traces of chryaotile asbestos fibers. .-/

In general, existing data has been used only as indicators of

potential problems rather than as determinants for the Work Plan.

There have been two remedial actions to date on the site. In

1949, city water was extended to the Village of Antrim and much

of the surrounding area. Local residents indicate that only a

few homes continue to use groundwater. In 1984, G+W erected a

six foot woven-wire fence topped with barbed wire to secure Tar

Lake from unauthorized access.

2.4 Environmental Setting

An independent evaluation of the environmental setting has not

been performed for the Draft Work Plan. The following is

excerpted from the Remedial Action Master Plan as a basis for

Work Plan review.

Geology

The Coldwater Shale Formation represents bedrock in southern

Antrim County. In this part of Michigan, the Coldwater is

apparently a deltaic sequence consisting of carbonates developed

with the gray, micaceous shale. The driller's log from an

exploratory oil well indicates that the Coldwater shale in the

vicinity of Tar Lake is about 330 feet in thickness and composed

primarily of shale with some dolomite. The Coldwater shale are

early Miasiasippian age sediments, which like the underlying

sedimentary formations, dip gently to the southeast toward the

Michigan Basin.

2-6

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At the site, about 400 feet of unconsolidated materials overlie

bedrock. These deposits are primarily Wisconsin age glacial

drift. The surficial material is glacial outwash composed ofsand and gravelly sand. Boring logs from groundwater wells

on-site indicate that the outwash deposits are at least 70 feet

thick. The vertical extent of the outwash deposits at the site,

as well as the stratigraphy of the remaining underlying glacial

drift, are unknown. The log from a Village of Mancelona water

supply well Indicates that a thick clay deposit exists below

approximately 100 feet of outwash deposit. However, the lateral

continuity and extent of this clay deposit is presently unknown.

Soils in the Tar Lake area fall predominately within the

taxanomic classification of two soil series; Kalkaska sand and

East Lake gravelly loamy sand. The Kalkaska and East Lake series

consist of somewhat excessively drained, rapidly permeable soil.

Hydrology

Tar Lake and the surrounding area are located within the Rapid

River drainage basin. Due to the very porous soils of the area,

drainage tends to be primarily internal with surface drainage

patterns being poorly developed. Any surface runoff occurring

around Tar Lake probably flows into the depressional area

occupied by the lake.

Two small lakes, Nelson and Peckham, are located within one-

quarter mile to the north and east of Tar Lake. The MDNR file

correspondence indicates that these two lakes and Tar Lake may be

over 70 feet deep. Their greater depths in relation to other

local pits may be the result of past sand excavation. (Actual

depth is unknown. Resistance was encountered at ca. 15 feet when

Tar Lake was probed in 1983).

Geohydrology

In Mancelona Township, groundwater is extracted from two

principal aquifers located within the glacial drift. The upper

2-7

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aquifer is unconfined and located in relatively thick deposits of

glacial outwash composed of sand and sandy gravel. Well logs

indicate that these outwash deposits are about 100 feet thick.

An underlying aquifer is confined and located in sand deposited

within the less permeable, clayey glacial moraine material. The

drilling log from a Village of Mancelona well indicates that the

top of the confined aquifer is located about 150 feet below the

ground surface. The Village of Mancelona extracts groundwater

from both aquifers, while the majority of local residential wells

are located within the relatively shallow unconfined aquifer.

At the Tar Lake site the groundwater table in the unconfined,

glacial outwash aquifer is about 35 to 50 feet below the ground

surface. On September 24, 1980, a local developer sponsored a

survey of static water levels in residential wells near the Tar

Lake site. The survey indicated that the direction of ground-

water flow in the unconfined aquifer was toward the northwest.

Contamination of this aquifer, in the area surrounding Tar Lake,

was reported as early as 1949. In 1949, a Michigan Department of

Conservation study of residential wells indicated the unconfined

aquifer was contaminated with creosol, possibly extending up to 3

miles to the northwest from Tar Lake. The extent of phenol

contamination of the groundwater has been estimated by the

Michigan Water Resources Commission to be 3 miles long, 1/2-mile

wide, and 200 feet deep.

The vertical extent of the unconfined aquifer at the Tar Lake

site is unknown. The existence and water quality of any confined

aquifers underlying the unconfined aquifer at the site are also

unknown.

Air Quality

Air quality does not appear to be a problem at this time.

However, if Tar Lake catches on fire as it did in the late 1960s,

air quality could be a local problem.

2-8

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Ecology

The Tar Lake site is located in the Hemlock-White Pine-Northern

Hardwoods region of Northern lower Michigan. Overall the

vegetation in the area around Tar Lake is characterized by upland

hardwoods (maple, beech, basswood), pine plantations, old field

communities and farmlands. The vegetative community probably

supports a large and varied wildlife population. Waterfowl

probably frequent the lakes and ponds (including Tar Lake) for

nesting, feeding and during migration. It is not known if

wildlife surveys of the area have been made. It is not known if

the lakes near Tar Lake are used as a recreational fishery.

Surveys of the lakes near Tar Lake for physical, chemical and

biological parameters are not available.

Soc ioeconomics

Estimates compiled for the Hazard Ranking System placed the total

population drinking well water within a three mile radius of Tar

Lake at about 3,000. Growth in the area has been primarily

single family homes built around the Village of Mancelona. A

small residentTal) housing development has been proposed on

property located within 1 mile to the southwest of Tar Lake.

Numerous residential homes are within 1/2-mile of the site. This

includes the community of Antrim which has a population of about500. / , 7 ~L_ _ _ _ , _ _ _ ^ *In 1977, (Ta facility plait^ was prepared for the Village of

Mancelona. \It indicated that no historical or archeological

sites on the

in the area.

National Register of Historical Places were located

2-9

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3.0 SCOPE OF MORE

3.1 Introduction

The Antrim Iron Works Site Remedial Investigation and Feasibility

Study of Alternatives will consists of 17 tasks divided among

four major project phases as follows:

I. Preliminary Remedial Investigation Activities

II. Remedial Investigation

III. Feasibility Study

IV. Support Activities

The tasks from each project phase are described respectively, in

Sections 3.2, 3.3, 3.4, and 4.0, which follow.

Preliminary Remedial Investigation Activities will include the

collection and assessment of pertinent site data prior to

commencement of certain RI/FS tasks. Tasks are described in

Section 3.2. Work plans, including health and safety

requirements, quality assurance requirements, and^site operations

plan, will also be prepared. '\

The Site Remedial Investigation Activities will include those

activities necessary to determine the extent and nature of wastes

on site and the degree of environmental contamination. The site

investigation will produce data of adequate technical quality for

evaluation of remedial alternatives during the Feasibility Study.

The Remedial Investigation is described in Section 3.3.

The Feasibility Study will identify and evaluate the appropriate

remedial actions for the site, based on existing data and

information gathered during the Remedial Investigation. yThe most

cost-effective remedial alternative-^will be recommended.

*\tSt/

3-1

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A conceptual design will be prepared for the selected remedial

alternative. Section 3.4 describes the Feasibility Study.

3.2 Preliminary Remedial Investigation Activities

The existing data on environmental contaminants on the Antrim

Iron Works Site is insufficient for the preparation of a Final

Work Plan. The tasks below (some of which have been initiated)

detail the activities needed to establish data for a Final Work

Plan.

Task 1-1 Background Data Collection

A search for background data has already been initiated for the

Antrim Iron Works Site. Sources surveyed and results are shown

below:

NASA/National Archives - A series of aerial orthophotographs of

the Tar Lake vicinity have been obtained for the years 1938,

1952, 1963, 1973, 1981. An infrared satellite photograph

from 1981 has also been obtained. These photographs depict

fe macro changes in the vicinity over the last 45 years. The

1938 photograph is particularly important since at the time

it was taken discharges were active.

Libraries (local) - Some historical data has been obtained

describing the locations on site of various waste generating

processes.

REMFIT/RAMP Sources - Photocopies of Tar Lake related EPA Region

V files have been obtained.

USDA/SCS - The soil survey of Antrim County has been obtained.

Additional information that has been identified but not yet

obtained includes:

State Health Dept. - 1976 and 1980 groundwater studies; localprivate well locations;

3-2

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P.

Local residents - data on Antrim Iron Works Company activities

MDNR - previous Tar Lake studies, area EIS studies, etc.

Local Libraries - Tar Lake clippings, esp. 1960's fire.

Local well drillers - drilling logs and historical data.

Task 1-2 - Site Mapping

Site mapping activities have already been initiated on the site.

Three maps have been prepared to date:

* topographic map (copy attached) at a scale of 1" - 100",

2-foot contours. Features shown include lakes with eleva-

tions, sludge areas, fencing, nearby structures, access

roads, etc. wL larger area has been aerially surveyed for ,

later preparation of maps with a wider coverage^J'

* property boundary survey map, delineating land ownership

and boundaries.

* USGS 15 minute series topographic map (Mancelona Quad-

rangle), last revision in 1956. Scale 1:62500. (Map has

been photo enlarged to Scale 1:6250.)

Task 1-3 Quality Assurance Plan

The Quality Assurance Plan will detail: site-specific details

on sampling; field analyses; surveying; chain-of-custody; sample

handling, packaging, preservation; £$p>shipping; recordkeepping

and documentation. All sample collection, sample preservation,

and chain-of-custody procedures used during this investigation

will be in accordance with the standard operating procedures as

specified in the Water Surveillance Branch Standard Operating

Procedures and Quality Assurance Manual (draft); United States

Environmental Protection Agency, Region IV, Environmental

services Division, August 29, 1980. All laboratory analyses and

quality assurance procedures used during this investigation will

be in accordance with standard operation procedures and protocols

as specified in the Analytical Support Branch Operations and

3-3

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Quality Assurance Manual; United States Environmental \

Protection Agency, Region IV, Environmental Services Division;

April, 1982 or as specified by the existing United States

Environmental Protection Agency standard procedures and protocols j

for the contract analytical laboratory program. J

Task 1-4 Site Health and Safety Plan

The site-specific health and safety requirements will be

identified for the AIWC Bite.

The purpose of the requirements will be to:

* Provide safety protection and procedures for site field

crews and subcontractors.

* Ensure adequate training and equipment to perform

expected tasks.

* Provide ongoiitffsite monitorTng"xjto verify preliminary

safety requirements and revise specific protection levels

as required.

* Protect the general public and the environment.

Based on available information, characterization of the hazards

present at the AIWC Site can only be approximated at this time.

The levels of protection determined during the field

reconnaissance will be modified in accordance with any new data

acquired in the course of the Remedial Investigation.

Task 1-5 Site Operations Plan and Field Office

A Site Operations Plan will be developed which outlines and

coordinates all activities at the site. The plan will be acompilation of study plans for individual field tasks and will

include the healtharxd—safety and quality assurance requirements

developed in pj ervTous tasks. xx y i 1 7r-l •—• ~~ 7 rf (KK{ V O/

3-4

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Sampling locations for the soil, surface water, groundwater, and

sediment samples may be revised based on site data obtained

during the field reconnaissance and from detailed review of

existing reference sources. Permission from adjacent landowners

for access and sampling will also be obtained under this task.

^G+W Manufacturing Company's Stamping Division Plant in Mancelona

has agreed to provide a Field Office in the warehouse located

adjacent to the site gate. This office will be equipped with

utilities, sample holding and processing area, a first aid area,

and secure equipment and sample storage areas.

Task 1-6 - Subsurface Investigation of the Antrim Iron Works

Plant Site

The possibility exists that there are buried tanks, pits and

other structures on the Antrim Iron Works Plant site. A

combination of geophysical techniques was proposed in the RAMP to

gather additional data to assess these potential sources of

contamination. The proposed techniques included a magnetometer

fe (MT) survey and a ground penetrating radar (GPR) survey.

While both of these techniques may have substantial merit, an

alternate method of preliminary study is proposed for the

processing and storage area ruins of the Antrim Iron Works site.

Stereo areal photographs have been obtained that show the Antrim

Iron Works as it appeared on August 04, 1938. Construction of an

original site topographic map from these photographs will |

delineate the position and approximate elevation of tanks,

vessels and structures that existed on-site. This map should

provide sufficient detail to guide the soil sampling program such

that the GPR survey would not be required. In the event that

1938 map is judged to be either incomplete or inaccurate, GPR

will be used to delineate the extent of buried undergroundJ f

structures. ,-'- r-

3-5

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The use of a magnetometer survey >Mf) on this site is not

recommended. High levels of. -^ambient magnetic noise are

anticipated because of the/large quantities of metallic Pig

iron, iron scrap, sla Ti iron ore and other ferromagnetic

materials discarded &£ this site. Soil contamination originating

from .Jt-p-yfoTigneous' liquor processing and refining will be

investigated in relation to specific structures, to be identified

on 1938 aerial photography. Tsoil^ borings^ will be drilled to

sample for contamination starting at \he level of original ground

(rather than the present elevation of rill), and will be confined

to the old chemical processing area located west of Tar Lake and

east of Hwy. 131.

Task 1-7 - Sampling and Analysis of Local Private Wells

(off-site)

The contamination of local water supply wells presents a

potential hazard to human health by direct contact and ingestion

of contaminated groundwater. To determine if such a threat

exists, a survey will be conducted to verify the locations of_

private residential, commercial and industrial wells within a

(i/mile radius of the Tar Lake site and to determine the nature

and frequency of their use. Additional wells, up to 3 miles'

northwest of the site, will also be included in the survey.

Sampling and an analysis will be performed to evaluate the

immediate need to provide alternative water supplies. These

analyses will also provide background data on ambient water

quality, both upgradient and downgradient of the site. The

monitoring program may continue during site remedial activities

and beyond, perhaps at a reduced scale, depending on the results

of the initial testing program.

All private well sampling and testing will conform to guidelines]

contained in the User's Guide to the U.S. EPA Contract Laboratory

Program (CLP), prepared by the Sample Management Office of CLP

and published August 1982. All groundwater samples are expected

to be "low concentration" samples according to CLP criteria.

3-6

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Groundwater samples will be analyzed for pH (field measured),

conductivity (field measured), inorganic and organic parameters

as defined by the/^PACLP^and for low concentrations of PAHs andtetrachlorodibenzo-p-dioxin.

The secondary objective of this task will be to establish

regional groundwater flow direction(s) and gradient(s), sourcesof hydraulic stress due to pumping (from high capacity municipal

or industrial wells) and other information necessary to locate

monitor wells for the off-site groundwater study. To accomplish

this goal, water level elevations and well depths will be

measured in selected wells. ^ / ~n*~*^ P- U>( -» ts» a* UJSffts <xs» at*£ A <* 3 *

Data from this survey will be utilized to construct a piezometric ~>

map of the groundwater table, and to construct elsgpTethesg:^snowing

chloride, phenol, and other significant parameters. Vertical

movement of the contaminant plume will be addressed insofar asthe data will allow, and interruptions to the natural groundwater

flow system will be identified. A monitor well installationprogram will be developed from this information.

The qroundwater sampling and analysis efforts should be closely

coordinated with the Michigan DNR and any of its ongoing

groundwater monitoring work. It is also expected that the

District Health office will assist in locating wells and incommunity support of this task.

To provide an Order-of -Magnitude cost estimate for this task it

was assumed that 16 residential wells will be sampled once andanalyzed. *

Task 1-8 Soil and Surface Water Sampling

During this preliminary investigation; a series of soil,

sediment, and surface water samples will be collected. These

samples will provide an approximation of contamination at the

site and will be used to select principal study areas for theFinal Work Plan. The following will be included:

3-7

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*

*

*

*

*

*

Tar Lake surface water - 2 samples

Tar Lake sediments - 2 samples

Tar Lake sludge plume - 2 samples

AIWC site surface soils - 20 samples

Mancelona landfill water - 2 samples

Mancelona landfill surface soils - 10 samples

Peckham Lake water - 2 samples

Peckham Lake bottom sediments - 2 samples

Nelson Lake water - 1 sample

Nelson Lake bottom sediment - 2 samples

Quality Control - 5 samples

These samples will be analyzed for organic and inorganic

parameters. Areas showing significant positive results will be

sampled more intensively during the Final Work Plan

implementation.

Task 1-9 Final Work Plan

At the completion of all preliminary site activities, a Final

Work Plan will be prepared which will incorporate the results of

the Preliminary Activities. It is expected that the Final Work

Plan will be sharply reduced in scope and will focus on those

areas/media showing environmental contamination.

3.3 Remedial Investigation

The tasks outlined below for the Remedial Investigation will be

part of the implemented Final Work Plan. The objectives of the

Remedial Investigation at the Tar Lake Site are as follows:

* To delineate the lateral and vertical extent of groundwater

contamination originating from the Tar Lake Site.

* To determine the chemical species that comprise groundwater

contamination and their probable sources at the Tar Lake

Site.

~)

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To determine the need and viability for aquifer restoration

at the Tar Lake Site.

To determine the direct pathways for groundwater contam-

ination at the Tar Lake Site.

To evaluate the viability of a no-action alternative for

remediation of contamination at the Tar Lake Site, including

an assessment of risks associated with the no-action

alternative.

To identify a list of remedial actions for the Tar Lake Site

and the evaluate their appropriateness/applicability in

remediating site contamination.

To recommend the most appropriate remedial alternative(s)

to mitigate the potential threats from on-site and/or

off-site contamination.

To prepare a conceptual design for any remedial alterna-

tive(s) chosen to be implemented at the Tar Lake Site.

Task 2-1 - Hydroqeologic Study. A hydrogeologic study will be

performed to evaluate the subsurface geology, water-bearing

formations and groundwater flow. This information is required to

determine:;

* The horizontal and vertical extent of any contaminant

plume that may be present.

* The ability of the site and local geology to prevent

pollutant migration.

* Groundwater and aquifer characteristics pertinent to

design and implementation of remedial actions.

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Available groundwater information including well data will be

reviewed by a geologist before initiating field work. Sources of

additional data include the USGS, State Department of Natural

Resources, local well drillers, the County Board of Health and

other nearby sites.

A geologist will visit the site to evaluate surface features,

identify locations of existing wells, and new monitoring well

locations.

An off-site geophysical study has been proposed in the RAMP. The

proposed study would consist of approximately 71,000 feet of

electrical resistivity surveying. Three parallel lines would be

extended northwest of the site for a distance of about 2i miles

each; six perpendicular transects would then be surveyed at right

angles from the other 3 lines, forming an orthogonal grid.

Electrical resistivity readings could be taken either by

conventional (ER) ground contact equipment, or electromagnetic

(EM) induction equipment.

We believe that the off-site geophysical survey would not result

in any usable information being generated concerning definition

of the groundwater contamination plume. Several limitations of

the electrical resistivity method apparently were not considered

during preparation of the RAMP.

1. Both the ER and EM methods rapidly loose sensitivity as a

function of increasing depth to the ground water table,

because they represent the average electrical resistivity

of an infinite half-space. With the water table at an

average depth of 60 feet below ground surface, small

changes in fluid conductivity (of groundwater) may be

easily masked by stratographic changes in the overlying

soil, such as clay lenses.

2. Clay lenses have been reported on well logs in the area,

and are believed to exist in shallow glacial deposits.

Major, random interferences to the electrical resistivity

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data should be anticipated as a result of clay lenses,

which would render results of the survey very "noisy."

3. Groundwater contamination from the Tar Lake site is

apparently limited to relatively low concentrations of

phenolics, other organics and certain "heavy metals".

Groundwater contamination is not present in the form of

electrolytes that would significantly alter electrical

conductivity of the aquifer. Although groundwater

contaminated by organic compounds may not be potable at

the 10 - 100 part per billion level, there is little

probability that the contamination plume can be defined

on the basis of its electrical resistivity (or

conductivity) properties.

The electrical conductivity properties of groundwater, both

within and beyond the contaminated plume, will be confirmed by

direct measurement during the Preliminary Hydrogeologic

Reconnaissance Survey (Task 1.7).

Subsurface conditions at the Tar Lake Site have not been

adequately defined to date. There is little data concerning

lithology, groundwater levels, and groundwater flow directions in

the site area. The only groundwater monitoring points currently

available are local domestic wells and three "upgradient"monitoring wells installed by an EPA contractor in 1982. A

subsurface investigation will be conducted and will consist of

the drilling and installation of up to 28 shallow monitoring

wells in the unconfined aquifer (60 - 80 feet deep) and up to 6

deep monitoring wells in the confined aquifer (150 - 180 feet

deep).

A phased approach for monitoring well installation will be

utilized. The on-site program will be implemented first,

followed by the off-site program. The off-site wells will be

installed following an interpretation of preliminary subsurface

data. The decision to install the additional wells can be made

following an evaluation of geologic data.

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This investigation will provide adequate information on

subsurface conditions, including lithology, groundwater levels

and flow directions in both the unconfined and confined aquifers,

contaminant migration through the groundwater; and the source(s)

of contamination. Data gathered through this investigation will

be used in the Feasibility Study to assess various remedial

options.

The initial on-site monitor well installation program will

consist of 9 shallow monitor wells drilled into the unconfined

aquifer. These will include a line of 6 monitor wells drilled

300 feet apart along the western boundary of the site, and are

intended to delineate contaminated plumes originating from Tar

Lake, the Mancelona sanitary landfill, or other undefined

pollution sources that may exist on the site. One monitor well

will replace EPA Well No. 4 (destroyed by vandals) close to Tar

Lake, and another will be placed immediately west at a small pond

(possibly, a remnant of the original Tar Lake) adjacent to the

inactive sanitary landfill. Finally, one monitor well will be

placed on the southeast corner of the site, presumably up-gradi-

ent from all pollution sources associated with the Tar Lake site.

Three deep monitor wells will be installed in the confined

aquifer, at a depth of 150 to 180 feet. These will be placed in

a triangular pattern to ascertain the groundwater flow direction,

which may be different from flow directions in the overlying

unconfined unit. Locations tentatively selected include west of

Tar Lake (beneath the apparent contaminated plume), north of Tar

Lake (south of the Mancelona Municipal Well Field), and the

southeast (upgradient) corner of the site. These tentative well

locations we illustrated on the attached topographic map.

The off-site groundwater monitoring program will consist of

approximately 20 shallow wells and 3 deep wells. All of these

will be drilled in the downgradient direction(s) to augment data

available from farm wells, domestic wells, springs and on-site

monitor wells. Locations will be determined after completion of

Task 1-7.

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Typical monitoring-well designs are shown in Figure 3-1. The

exact location and construction details of each well will be

determined in the field by the site hydrogeologist based on

background information and information gained throughout the

course of the drilling activities.

The conceptual plan for groundwater monitoring in the unconfined

portion of the aquifer is illustrated on Figure 3-2. A clay

aquitard (inferred from the Mancelona City Well Drilling Record)

is thought to exist at the Tar Lake Site, creating a lower

confined aquifer system. Wells drilled into either the lower

portion of the unconfined aquifer system or any portion of the

confined aquifer system are illustrated by the deeper well

construction plan, shown on Figure 3-1.

Pressure vacuum lysimeters will be installed in 7 shallow auger

borings, advanced 10 to 20 feet below the bottom of the

historical (1938) bottom area of Tar Lake. These borings will

provide sludge samples, soil samples and leachate samples to

assist in the analysis of Tar Lake as a contamination source.

Subsurface investigation costs were based on drilling and

installing six deep and 28 shallow monitoring wells, and 7

clusters consisting of 2 lysimeters, each. This has been to

prevent field delays resulting from the need to seek a contract

modification during drilling activities.

Groundwater monitoring wells will be constructed to comply with

applicable federal, state, and local agency regulations. All

well drilling and installation will be logged and inspected by a

qualified geologist. Procedures are:

* All drilling equipment, casing, and materials will be

decontaminated before drilling.

* Soil borings will be drilled with an eight-inch (nominal

diameter) hollow-stem auger. Standard penetration tests

and split-spoon sampling will be performed every five

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M O N I T O R-..

PECKMAM LAKEGROUND VMATER

•>

GROUND WATERFLOW D ' « E C T \ O K 1

CONTAMINATED XGROUND WATER -/PLUME

HYPOTHETICAL OOMTAMIHATION

PATHWAY MOOIL

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feet or lithology change, or as directed by a site

geologist, throughout the drilling process. The split

spoon samples taken will be stored in moisture-tight

jars. After the boring is advanced to the target depth,

a section of 2-inch flush joint PVC casing will be

installed, equipped with either a 5 or 10 foot section of

machine slotted PVC well screen. The shallow borings will

be extended to approximately 10 feet below the

encountered groundwater table and screened 6 to 8 feet

below the water table surface. Having some portion of

well screen above the water table will allow for the

sampling of immiscible fluids having a low specific

gravity (such as gasoline, oil or aromatic hydrocarbons),

as well as soluble substances that are dissolved in

groundwater.

* The deeper borings will be equipped with a 5-foot section

of well screen and set either immediately above or below

the confining clay aquitard (if present).

* All well screens will be constructed of 15 to 20 slot

size PVC screen, and will be developed in a natural sand

pack that results from the collapse of formation soil

around the screen, as the auger is withdrawn. Bentonite

pellets will be used to seal the portions of each

borehole that pass through clay aquitards, as directed by

the on-site geologist. An artificial sand pack will be

extended above the water table to approximately a depth

of 20 feet, or the first impermeable strata encountered

above the water table. A slurry of cement and bentonite

will be pumped into the annulus between the well casing

and the borehole to seal the well casing from external

leakage. Approximately 4 feet of stick-up will be leftabove the ground surface to facilitate sample collection

in winter conditions, and a protective steel casing with

locking cap will be installed to minimize damage from

vandal ism.

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* Upon completion, each well with be flushed with fresh

water to remove fines, and to ensure optimum hydraulic

communication with the aquifer. Flush water remaining in

the casing will be removed by bailing or by a temporary

bladder pump.

* Drilling equipment shall be decontaminated between

boreholes to prevent cross contamination. A portable

steam generator will be maintained on-site and used to

clean the augers, samplers,drill rods and all downhole

tools before, between and after holes are drilled for

this project.

* A measuring point will be established at the top of each

PVC well casing. This point will be marked and surveyed

to establish the elevation (to 0.01 feet, plus or minus)

with respect to a permanent benchmark.

* Hydraulic Conductivity tests should be performed on

selected shallow monitoring wells. Tests may be "rising

head" or "falling head" hydraulic conductivity tests, or

pumping tests. Rising head tests involve the removal of

a known volume of water and measurement of the rate of

recovery of the water level over time. Falling head tests

involve the addition of a known volume of water and

measurement of the recovery of the water level over time.

Pumping tests will involve measuring the rate of drawdown

in response to pumping a well at a constant rate for a

period of time. At the conclusion of each pumping test,

the rate of recovery of the pumping and observation wells

will be measured to gain additional data on aquifer

characteristics. The site geologist will determine which

tests to run based on site conditions.

* An individual bladder pump will be installed in each

monitor well to expedite purging of stagnant casing water

and to facilitated sample collection.

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* Representation soil samples will be tested in the

laboratory to aid in soil classification.

Soil borings will be advanced in the old Tar Lake bottom area by

means of a machine auger, hand-held power auger or wash borings,

as site conditions permit. These borings will be advanced to a

depth of 10 to 20 feet and adequately cased (as necessary) to

prevent inflow by liquids or semi-liquid sludges.

Soil samples will be obtained at changes in strata or on 5-feet

intervals, as directed by our geologist. A 2-inch split barrel

sampler driven by either a 140 Ib. drop weight or a hand operated

60 Ib. drive weight will be used to collect soil samplers. Soil

samplers will be preserved in glass jars and records will be kept

by the site geologist, same as for the monitor well borings .After

the target zone is reached, a pressure-vacuum soil water sampler

(lysimeter) will be emplaced in the borehole by embedding the

porous cup in diatomacious earth. The remainder of the lysimeter

barrel will be covered with sand, followed by a 50 Ib. plug of

dry bentonite powder. A cement - bentonite - sand slurry will be

used to fill the remainder of the borehole, to the ground

surface. In the event that double lysimeter installations are

placed in relatively deep holes, each lysimeter unit will be

backfilled with clean sand and separated by a bentonite clay

plug.

A hydrogeologic report of the site will be prepared to provide

documentation of data obtained during drilling and installing

wells. This report will include hydrogeologic profiles, aquifer

conditions, laboratory tests results, a plot plan boring logs,

and conclusions. To provide an Order of Magnatude cost estimate,

the following assumptions were made:

* About 3120 linear feet of soil drilling, casing and

installation of wells.

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Shallow wells, approximately 75 ft. deep:

8 on-site

20 off-site

Deep wells, approximately 170 ft. deep:

3 on-site

3 off-site

* 37 Bladder pumps will be installed (three in existing EPA

wells, 34 in proposed monitor wells).

* Sixty soil samples will be analyzed for soil

classification.

* 10 pressure-vacuum lysimeters will be emplaced in 7

boreholes. About 150 linear feet of soil drilling will

be needed to install the lysimeters.

Following installation and development of the monitoring wells, a

sampling and analysis program will be conducted. It is intended

to provide groundwater quality data that will characterize and

define the location of a contaminant plume. This data will be

used to plan further remedial investigations or to select

alternative remedial actions.

Groundwater levels will be monitored in all monitoring wells

quarterly for 1 year. One groundwater sample will be collected

from each existing and new monitoring well. The elevation of the

groundwater surface in each exploratory hole or monitoring well

will be recorded at the time of sample collection. The results

from initial set of groundwater samples and the groundwater

levels will be evaluated and the groundwater sampling program

reviewed and the level of effort for the task may be revised.

When sampling, wells will be pumped until temperature, pH, and

electrical conductivity values are constant, or a minimum of 5 to

10 well volumes have been pumped and the well allowed to recover

before samples are taken.

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The groundwater sampling and testing will be closely coordinated

with the MDNR and any of its ongoing groundwater monitoring work.

Groundwater samples will be analyzed for temperature (field

measured), pH (field measured), conductivity (field measured),

the inorganic and organic parameters defined by the EPA CLP, low

concentrations of PAH's and TCDD. Analytical parameters will be

reduced after first round sampling. A technical memorandum

summarizing the sampling and analysis program will be prepared to

present the test results and to evaluate the extent of

contamination.

Task 2-2 - Soil, Sediment and Water Sampling and Analysis

Program

The objective of sampling and analyzing the surface soil,

sediment, and water is to collect data on the depth, areal

extent, and concentration of hazardous constituents at potential

source areas on the site; to determine infiltration rates of the

near-surface soils; and to determine the degree of off-site

migration of contaminants. Before any soil samples are

collected, the site physical features and results from the

subsurface study will be examined and the scope of work refined

to set actual sample locations.

Soil sampling locations will be selected following an examination

of the original site map, to be constructed using 1938

orthophotography. Drilling locations and target depths will be

established for each of the areas formerly occupied by major

processing or storage facilities at the Antrim Iron Works.

Soil borings will be drilled with an eight-inch (nominal

diameter) hollow-stem auger. Standard penetration tests andsplit-spoon sampling will be performed. The split spoon samples

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will be taken both for lithological logging and for chemical

analyses; 6-inch segments will be stored in moisture-tight jars.

After the boring is advanced to the target depth, each boringwill be backfilled with auger spoil.

Soil samples will be retained in the field office. Those samples

selected for testing will be preserved and shipped to the

chemical laboratory for analysis.

For purposes of estimation, we anticipate that approximately 10

soil borings will be drilled to an average depth of 25 feet each.

The uppermost 6-inch grab sample below original grade (beneathrecent fill soil) will be analyzed for the organic and inorganic

parameters defined by the U.S. EPA CLP. The test results will be

required to evaluate off-site disposal of contaminated soils at a

landfill. Samples taken at depths below 6 inches will be

analyzed only if significant concentrations of contaminants are

detected in the preceding (overlying) sample. Levels of "signi-

ficance" will be set by an appropriate regulatory agency. For

the purpose of cost estimating, it has been assumed that a total

of 80 soil and 10 quality control samples will require analysis.

An additional phase of soil sampling and analysis may be

advisable to more closely define the areal or vertical extent of

contamination in the general site area. The appropriate amount

of additional work cannot be predicted at this time. For cost

estimating purposes, it has been assumed that one-third the

effort expended in carrying out the previously described soil

work will be required for the additional work.

Field permeability tests will be conducted to determine infiltra-

tion rates of the near-surface soils. The infiltration rates may

be used to approximate the on-site vertical rechare or to evalu-

ate the effectiveness of placing an impermeable cover system over

portions of the site. Six duplicate infiltrations tests will be

run at locations across the site (three contaminated and three

noncontaminated areas), using a single-ring infiItrometer or

similar device.

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The cost estimate assumes 60 soil samples will be analyzed.

Extraction procedure toxicity tests are assumed for half of these

samples.

Samples of sludge from Tar Lake will be obtained in 6 to 9

locations, utilizing 2-inch diameter PVC pipes. Ten-foot long

sections will be thrust into the pond bottom using the weight of

a 2-man drill crew, capped to initiate a vacuum for sample

retention, and having the drill crew pull out the sample by hand.

Each pipe sample will be capped, wiped clean (using a hexane

solvent, if necessary) and labeled. These samples will be cut

into smaller pieces at the field laboratory, and stored on-site.

Aliquots will be removed for chemical analysis as necessary.

Holes made in the sludge by pipe sample removal will be cased

with 4-inch PVC pipe, (gently) driven with a cushioned drive

weight or a gasoline powered jackhammer to "refusal", and washed

clean using a potable water flush. A split barrel sampling

spoon, driven with a 60 Ib. drop weight, will be used to sample

the lower part of the pond sediment, to confirm the boundary

between sludge and the soil bottom. These borings will not

penetrate more than a few feet into the lake bottom except for

those borings where lysimeters are to be installed. All sludge

borings will be grouted closed using a cement-bentonite slurry,

immediately upon completion. The 4-inch PVC casings will not be

removed to assure that the grout plug will not become diluted

with water or contaminated by sludges.

After the nature of the interface between sludge and soil is

ascertained by pipe samples and wash borings, simple probes will

be driven to "refusal" to delineate the bottom of Tar Lake. A

section of open-end drill rod will be driven using a 60 Ib drive

weight, than removed by hand. The probes will not be taken below

contaminated and three noncontaminated areas), using a

single-ring infiltrometer or similar device.

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Core samples from the upper 15 cm of sediment will be collected

for each general location where surface water samples are taken.

For cost estimating purposes, it was assumed that the following

number of sediment samples will be collected and analyzed from

each area.

Tar Lake 12

Nelson Lake 2

Peckham Lake 2

Quality Control _3_

Total 19

Water samples will be taken by Van Porn sampler at Peckham Lake

and Nelson Lake. Two samples from each lake, one at surface and

one at depth, will be taken. Tar Lake contains a shallow pool of

water overlying toward tar wastes. No depth sample of water will

therefore be taken. If during the preleminary tasks, one or more

surface run-off areas are found, surface run-off samples will be

attempted during heavy rainfall.

All sampling and testing will conform to guidelines in the User's

Guide to the U.S. EPA Contract Laboratory Program (CLP), prepared

by the Sample Management Office of CLP and published August 1982.

All samples are assumed to be low or medium concentration samples

according to the CLP criteria.

All soil and sediment samples collected will be analyzed for

organic and inorganic parameters as defined by the U.S. EPA CLP.

A soil, sediment, sampling and analysis technical memorandum will

be prepared that summarizes the data from the field work,

presents the analytical results and gives a preliminary

evaluation of the data.

Task 2-3 Remedial Investigation Report

At the conclusion of the data collection phase of the technical

approach, a draft Remedial Investigation Report will be prepared.

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The Remedial Investigation Report will consist of the following:

(a) environmental assessment - this report, also called an

endangerment assessment, identifies the hazardous substances

on-site which pose environmental/health risks and the "at

risk" receptors. The assessment also describes pathways

from by which the hazardous substances may reach receptors

and sufficient background information to estimate the level

of impact on receptors. This assessment becomes the basis

for evaluating the effectiveness of alternative remedial

measures. The assessment will be prepared as per

"Endangerment Assessment Guidance", (draft) May 1, 1984.

(b) summary of all data developed during the study, including a

reduction of this data, and identification of data gaps.

(c) a proposed list of remedial action alternatives for

evaluation; and a comparison of those alternatives based on:

costs (capital and operational); effectiveness; and

engineering feasibility.

Task 3-1 Feasibility Study

After selection of 'most probable' remedial alternatives, a

Feasibility Study will be prepared. Alternatives and

technologies identified in Task 2-3 will be evaluated using the

following criteria:

* Technical feasibility

* Environmental and public health impacts

* Cost

* Administrative and institutional factors

* Implementability

Evaluation and ranking of the candidate remedial measures will

result in a narrative presentation of the most desirable

alternatives. The degree to which each remedial measure

3-24

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satisfies the project objectives will be assessed and discussed.

Each of the proposed remedial measures will be evaluated by the

criteria developed during the Remedial Investigation.

Costs will be determined for each of the remedial alternatives. A

Feasibility Study will then be prepared.

Where appropriate, data necessary to substantiate the past

performance and reliability of the proposed remedial measures

will be provided.

Decisions about evaluation criteria will be made during the

review meetings before any remedial measure evaluation.

Information to be included in the Feasibility Study Report will

include:

* Supporting references on the feasibility of the remedial

measures chosen for evaluation.

* Justification for the elimination of any alternative

during initial screening of alternatives.

* Acceptable engineering practices related to the design

and implementation of the remedial measures chosen for

evaluat ion.

* Specific procedures and supporting data used to evaluate

each remedial measure for the evaluation criteria.

* The expected environmental and public health effects of

the remedial measure alternatives.

* Preliminary conceptual drawings and sketches used to

evaluate each remedial measure.

* The cost estimates for each remedial measure with

appropriate references provided.

The report will be prepared in a format that will be agreed upon

in the preliminary review meetings. All documents collected in

the remedial measure evaluation will be organized in a project

file and will be available for later reference.

3-25

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The draft report will be used by the EPA, the State, and the

responsible parties to select the remedial measure(s) to be

implemented. As a result of the cumulative comments from the

EPA, the State, responsible parties, and the public, a Record of

Decision (ROD) will be prepared by the EPA Regional Site Project

Officer to identify the chosen remedial measure(s) to be

implemented at the AIWC Site. The contractor will provide the

necessary assistance and/or documentation for preparation of the

ROD.

Task 3-2 - Conceptual Design

A conceptual design of the selected remedial measure will be

prepared for use in subsequent development of the detailed

construction plans. The conceptual design will be based on the

findings of the Remedial Investigation, laboratory and field

studies, and the remedial measure evaluation.

The conceptual design plan, which will include general arrange-

ment drawings and suggestions for the construction specifica-

tions, will accompany the final Feasibility Study Report. This

report will also contain site information needed for construction

design, such as test boring logs, borehole testing data, ground-

water conditions, and sampling analysis.The conceptual design

plan will include the following:

* The selected engineering approach with implementation

schedule;

* any special implementation requirements;

* applicable design criteria;

* preliminary site layouts;

* budget cost estimates including operation and maintenance

cost figures; and

* operation and maintenance requirements.

3-26

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Task 3-3 - Final Report

A final report will be prepared for submission to the EPA MDNR,and PRP's. The report will include a summary of the results of

the Remedial Investigation and Feasibility Study and will present

the data and conceptual design drawings for the chosen remedial

measure(s ) .

The final report may include but will not be limited to:

* Summary of assessment of contamination;

* Summary of remedial measure evaluation;

* Supporting data for chosen remedial measure(s);

* General arrangement drawings of remedial measure(s);

* Typical geologic and design cross-sections;

* Data from treatability studies necessary for final

design; and

* Preliminary cost estimates.

3-27

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4.0 SUPPORT ACTIVITIES

The following tasks are not directly related to the RI/FS

technical approach but are usually considered integral to the

process.

Task 4-1 - Meetings and Technical Support

For cost estimating purposes it is assumed that six meetings will

occur during the course of the project at which contractor

support/attendance will be required. One meeting has been held

at the site to date. Others are expected at the end of

significant review periods and possibly in support of community

participation activities.

In addition this task has been budgeted to include periodic

contractor involvement to support decision-makers during the

RI/FS. Requests for such support and/or meeting attendance will

be made through the designated G+W Project Officer.

Task 4-2 - Community/Media Relations

No specific tasks for community relations support have been

budgeted. It is expected that PRP's, EPA, and MDNR will develop

a protocol for community/media relations. Technical support for

these activities has been budgeted under Task 4-1. No budget

allowance has been made for audio-visual or text preparation for

public meetings.

4-1

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5.0 PROJECT MANAGEMENT, COSTS, AND SCHEDULES

5.1 Project Management

Due to uncertainties associated with Potentially Responsible

Party (PRP) initiated RI/FS projects, a detailed management plan

for the overall project has not been prepared. Uncertainties /

include the relationship between state and federal oversight ,

agencies, relationship of these agencies to the PRP's and roles• i ft

of various PRP's themselves. — ') •f ,Technical Project Management will be organized as follows: »

PROJECT MANAGER - Responsibilities include client interface,

cost tracking, and control, schedule main-

tenance, preparation of deliverables.

PROJECT GEOLOGIST - Responsible for all subsurface, groundwater,

and geological tasks. Reports to Project

Manager.

PROJECT ENGINEER - Responsible for engineering phases of the

Remedial Investigation and for performance of

the Feasibility Study and cost estimates.

Registered in Michigan.

PROJECT CHEMIST - Responsible for design and implementation of

sampling plans, interface with laboratory, and

QA/QC on analyses.

G+W PROJECT OFFICER - Responsible for monitoring project

performance, interface with RPA/MDNR,

and community/media relations.

Figure 5-1 illustrates the overall technical management of the

RI/FS.

5-1

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G+WProjectOfficer

EPAMDNR

Community

Project MGR

EnSafe, Inc.

SubcontractorsProjectEngineer

Geology

S&ME, Inc.

ProjectChemist

Laboratory

(not selectedStaff Resources

FIGURE 5-1

RI/FS Technical Management

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5.2 Project Deliverables and Meetings

The following project deliverables and meetings are planned;

TASK 1 Preliminary Meeting (Complete)

Draft Work Plan (Attached)

Topographic Maps (Partially Complete)

Quality Assurance Plan

Health & Safety Plan

Site Operations Plan

Preliminary Activity Report

Final Work Plan

Meeting to review final work plan

TASK 2

TASK 3

Soil, Sediment, and Water Report

Hydrogeologic Study Report

Endangerment Assessment

Remedial Investigation Report (Draft)

Remedial Investigation Report (Final)

2 meetings

Feasibility Study Work Plan

Feasibility Study

Conceptual Design Report

2 meetings

5.3 Cost Estimates

The following cost estimates have been prepared based upon

assumptions and conditions contained in the Technical Approach.

No estimates have been made for experts- inci 1 directly by

G+W, EPA, MDNR. A steriak indicates ts a incurred.

TASK NO.

1-1

1-2

1-3

1-4

Bkgrd Data, Draft Work Plan,

Mapping

Quality Assurance Plan

Health & Safety Plan

;TIMATE$ 12,460*

6,000*

1,270

1,270

5-3

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1-5 Site Operations/Field Office NA

1-6 Subsurface Investigation 1,000

1-7 Off-site well sampling 8,900

1-8 Soil & Surface Water Sampling 9,500

1-9 Final Work Plan 1,300

TASK 1 SUBTOTAL: $ 41,700

2-1 Hydrogeologic Study

drilling, lysimeters, borings $142,000

subsurface investigation 10,000

sampling and analytical (on-site) 32,000

sampling and analytical (off-site) 15,000

2-2 Soil, Sediment, and Water Study 29,200

2-3 Remedial Investigation Final Report 5,000

TASK 2 SUBTOTAL: $234,000

3-1 Remedial Alternatives Review 13,700

Laboratory Studies 8,000

Feasibility Study 34,800

3-2 Conceptual Design 6,000

TASK 3 SUBTOTAL: $ 62,500

4-1 Included in other tasks NA

PROJECT SUBTOTAL: $338,200

CONTINGENCY (15%): 50,800

PROJECT TOTAL: $389,000

5.4 Project Schedule

The AIWC Site project schedule is complicated by two variable

factors: mown length i?(r report r v periods ' severe

winter we; c conditions art* the site. A. note spec project

schedule wi. i be develop .fter the l > t Work PI 'as been

reviewed and project review times are determined. Allowing for

approximately 30 days review on major deliverables, the following

schedule is proposed. (Figure 5-1.)

5-4

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Lr.I

PHASE 1

Draft W. P. & Mapping Completed

QA/Hi>S/Site Ops. Plans

Field Office Set-up

Subsurface Investigations

Off-Site Well/Soil/SurfaceWater Sampling

Final Work Plan

PHASE 11

Hydrogeologic Study

Well Sampling & Analysis

Soil /Sediment /Water Study

Remedial Investigations Report

PHASE 111

Alternatives Review

Feasibility Study

Conceptual Design

WEEK MO 0

A= Deliverable Sept.

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Antrim Iron Works RI/FSProposed Schedule