HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD COVER SHEET

Name of Site: DSC McLouth Steel Gibraltar Pl an t
EPA ID No.: MID005320254 Contact Person(s)

U.S. Environmental Protection Agency (EPA), Region V: Nuria Muniz, National Priority List Coordinator 77 West Jackson Boulevard, Mail Code: SR-6J Chicago, Illinois 60604 (312) 886-6312
Site Investigation: Joseph Walczak Site Assessment Program Manager Michigan Department of Environmental Quality
Pathways, Components or Threat Not Scored 

### The ground water migration, ground water to surface water migration component of the surface water migration, soil exposure, and air migration pathways are not scored as part of this Hazard Ranking System (HRS) evaluation. The ground water, ground water to surface wat er component of the surface water migration, soil exposure, and air migration pathways were not included because a release to these media does not significantly affect the overall site score and because the surface water migration pathway produces an overall site score above the minimum required for the site to qualify for inclusion on the National Priorities List (NPL).1 HRS DOCUMENTATION RECORD

Name of Site: DSC McLouth Steel Gibraltar Plant Date Prepared: September 2014 EPA Region: V
Street Address*: 28000 West Jefferson Street City, County, State, Zip Code: Gibraltar, Wayne County, Michigan 48173 (Ref. 3, p . 1 ; 4, p. 1; Fig ure 1 of this HRS documentation record)
General Location in State: Southeast portion of Michigan in the City of Gibralt ar Topographic Map: U.S. Geological Survey 7.5-Minute Series Topographic Map of Rockwood, Michigan – Ontario Quadrangle, 1967, Photorevised 1973 (Ref . 3, p. 1)

Latitude*: 42 ○ 06 ’ 11.07 ” North (Ref. 3, p. 1; 4, p. 1) Longit ude*: 83 ○ 12 ’ 01.05” West (Ref. 3, p. 1; 4, p. 1)

T he latitude and longitude listed above mark the approximate location of the center of Tandem Mill Pond area (Ref. 4, pp

. 1, 2).

*The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the general area where the Site is located. They represent one or more locations EPA considers to be part of the Site based on the screening information EPA used to evaluate the Site for NPL listing. EPA lists national priorities among the known “releases or threatened releases” of hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A Site is defined as where a hazardous substance has been “deposited, stored, disposed, or placed, or otherwise come to be located.” Generally, HRS scoring and the subsequent listing of a release merely represent the initial determination that a certain area may need to be addressed under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more information is developed regarding where the contamination has come to be located.

Scores Groundwater Migration Pathway - NS Surface Water Migration Pathway - 100.00 Soil Exposure Pathway - NS Air Migration Pathway - NS
HRS SITE SCORE 50.00

NS – Not Scored2 WORKSHEET FOR COMPUTING HRS SITE SCORE

S S 2 1

. Groundwater Migration Pathway Score (S gw ) (from Table 3-1, line 13) NS

--- 2a. Surface Water Overland/Flood Migration Component (from Table 4-1, line 30) 100.00 10000
2b Groundwater to Surface Water Migration Component (from Table 4-25, line 28) NS
2c. Surface Water Migration Pathway Score (S sw ) (enter the larger of lines 2a and 2b as the pathway score) 10000
3. Soil Exposure Pathway Score (S s ) (from Table 5-1, line 22) NS

--- 4. Air Migration Pathway Score (S a ) (from Table 6-1, line 12) NS

---
5. Total of S gw 2 + S sw 2 + S s 2 + S a 2 10000

6. HRS Site Score 50.00 Divide the value on line 5 by 4 and take the square root.

Note: NS = Not Scored3

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET

Factor Categories a nd Factors

DRINKING WATER THREAT Maximum Value Assigned Value

Likelihood of Release 1. Observed Release 550 550 2. Potential to Release by Overland Flow: 2a. Containment 10 NS 2b. Runoff 25 NS 2c. Distance to Surface Water 25 NS 2d. Potentia l to Release by Overland Flow (lines 2a[2b + 2c]) 3. Potential to Release by Flood: 3a. Containment (Flood) 3b. Flood Frequency 3c. Potential to Release by Flood (lines 3a x 3b) 4. Potential to Release (lines 2d + 3c, subject to a maximum of 500) 5. Likelihood of Release (higher of lines 1 and 4) 500

10 50 500 500

550 NS

NS NS NS NS

550 Waste Characteristics 6. Toxicity/Persistence 7. Hazardous Waste Quantity 8. Waste Characteristics *

* 100 NS NS NS Targets 9. Nearest Intake 50 NS 10. Population 10a. Level I Concentrations ** NS 10b. Level II Concentrations ** NS 10c. Potential Contamination ** NS 10d. Population (lines 10a+10b+10c) 11. Resources **

** NS NS 12. Targets (lines 9 + 10d + 11) ** NS

13. DRINKING WATER THREAT SCORE 100 NS *

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable NS —Not Scored4

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET

Factor Categor ies and Factors

HUMAN FOOD CHAIN THREAT Maximum Value Assigned Value

Likelihood of Release

14. Likelihood of Release (same as line 5) 550 550

Waste Characteristics 15. Toxicity/Persistence/Bioaccumulation 16. Hazardous Waste Quantity 17. Waste Characteristics *

* 1000 8 5 x 10 10
, 0 00

1000 Targets 18. Food Chain Individual 50 20 19. Population 19a. Level I Concentrations **

** NS 19b. Level II Concentrations ** NS 19c. Potential Contamination ** 0. 00 00003 19d. Population (lines 19a+19b+19c) 20. Targets (lines 1 8 + 19d) **

** 0.0000003 20 .00 00003 21. HUMAN FOOD CHAIN THREAT SCORE 100 100 .00
*

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable NS

— Not Scored5

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET

Factor Categories and Factors

ENVIRONMENTAL THREAT Maximum Value Assigned Value

Likelihood of Release

2. Likelihood of Release (same as line 5) 550 550
Waste Characteristics

23. Ecosystem Toxicity/Persistence/Bioac cumulation 24. Hazardous Waste Quantity 25. Waste Characteristics *

* 1000 8 5 x 10 10 , 000

1000 Targets

26. Sensitive Environments 26a. Level I Concentrations 26b. Level II Concentrations 26c. Potential Contamination 26d. Sensitive Environments (lines 26 a+26b+26c) 27. Targets **

**

**

**

** NS NS NS 15 15 15
28. ENVIRONMENTAL THREAT SCORE 60 60

29. WATERSHED SCORE 100 100

30. SURFACE WATER OVERLAND FLOW/FLOOD COMPONENT SCORE 100 100 *

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable NS - Not Scored

## GIBRALTAR PLANT COUNTRYWIDE LANDFILL

Contract No.: EP-S5-06-04 TDD: S05-0008-1304-007 DCN: 2145-2A-BJSK 0 2,000 FeetFILE: D:\McLouth_Steel_Gibraltar\mxd\F1_Site_Location.mxd 8/4/2014 12:00:47 PM wojdakon

Legend Image Source: ESRI USA Topo Maps

Prepared For: U.S. EPA REGION V Prepared By: WESTON SOLUTIONS, INC
750 E. Bunker Court Suite 500 Vernon Hills, IL 60061 Figure 1 Facility Location Map DSC McLouth Steel Gibraltar Plant Gibraltar, Wayne County, MichiganMarsh Creek

Brownstown Creek Mill Building

Leachate Treatment Lagoon System
Frank and Poet Drain Landfill A Landfill B Countywide Landfill

Contract No.: EP-S5-06-04 TDD: S05-0008-1304-007 DCN: 2145-2A-BJSK 0 1,600 Feet Legend
Flow Direction
On-site Ditch
Perennial Stream
Source No. 1 - Surface Impoundments Image Source: ESRI World Imagery

Prepared For: U.S. EPA REGION V Prepared By: WESTON SOLUTIONS, INC
750 E. Bunker Court Suite 500 Vernon Hills, IL 60061 Figure 2 Facility Features Map DSC McLouth Steel Gibraltar Plant Gibraltar, Wayne County, Michigan Source: Ref. 6, p.18FILE: D:\McLouth_Steel_Gibraltar\mxd\F2_Site_Features.mxd 8/4/2014 12:01:14 PM wojdakonMarsh Creek

Brownstown Creek Frank and Poet Drain Countywide Landfill

Landfill B

Landfill A Gibraltar Plant

Leachate Treatment Lagoon System

Contract No.: EP-S5-06-04 TDD: S05-0008-1304-007 DCN: 2145-2A-BJSK 0 1,750 FeetFILE: D:\McLouth_Steel_Gibraltar\mxd\F3_Source_Locations.mxd 8/4/2014 12:01:37 PM wojdakon

Legend
Flow Direction Source No. 1 - Surface Impoundments On-site Ditch
Perennial Stream Image Source: ESRI World Imagery

Prepared For: U.S. EPA REGION V Prepared By: WESTON SOLUTIONS, INC
750 E. Bunker Court Suite 500 Vernon Hills, IL 60061 Figure 3 Source Location Map DSC McLouth Steel Gibraltar Plant Gibraltar, Wayne County, Michigan Source: Ref. 6, p.18; 19, p.7Mill Building

Landfill B

DCR-SLUDGE-01 DCR-SD-TMP2-01-062107

DCR-SD-TMP3-01-062107 MSG-WWP-SED-10-14/02/11

MSG-WWP-SED-02-14/02/11 MSG-WWP-SW-02-14/02/11

DCR-SD-AD-01-062007 DCR-SD-AD-02-062007 DCR-SD-TMP4-01-062007 DCR-SD-TMP4-02-062007 MSG-WWP-SED-01-14/02/11 MSG-WWP-SW-01-14/02/11 MSG-WWP-SW-DUP-14/02/12 MSG-WWP-SED-04-14/02/11 MSG-WWP-SED-DUP-14/02/11 MSG-WWP-SW-04-14/02/11

DCR-SD-TMP1-01-062107 Approximate Location Outfall (S-2)

Approximate Location Outfall Sample 001

Contract No.: EP-S5-06-04 TDD: S05-0008-1304-007 DCN: 2145-2A-BJSK 0 400 FeetFILE: D:\McLouth_Steel_Gibraltar\mxd\F4_Source_Char_Sampling.mxd 8/4/2014 12:02:01 PM wojdakon Legend Outfall Sampling Locations Source Characterization Sampling Locations Acid Dosing Pond Tandem Mill Pond #1
Tandem Mill Pond #2
Tandem Mill Pond #3
Tandem Mill Pond #4
Water Retention Basin #1 (pH Adjustment Pond) Water Retention Basin #2 (Settling Pond)
Water Retention Basin #3 Water Retention Basin #4 (Aeration Pond #2) On-site Ditch
Perennial Stream Image Source: ESRI World Imagery

Prepared For: U.S. EPA REGION V Prepared By: WESTON SOLUTIONS, INC
750 E. Bunker Court Suite 500 Vernon Hills, IL 60061 Figure 4 Source Characterization Sampling Location Map DSC McLouth Steel Gibraltar Plant Gibraltar, Wayne County, Michigan Note: All sampling locations are approximate (Ref.7, pp. 20-21; Ref. 22, pp. 16-17, 27; Ref. 25, pp. 8; Ref. 35 pp. 8; Ref. 40, pp. 1, pp. 2)Marsh Creek

Brownstown Creek Gibraltar Plant

Frank and Poet Drain Countywide Landfill

Landfill B

Landfill A MSG-FPD-SED-04-14/12/10

MSG-FPD-SED-03-14/12/10 MSG-FPD-SED-02-15/12/10 MSG-FPD-SED-01-15/12/10

Contract No.: EP-S5-06-04 TDD: S05-0008-1304-007 DCN: 2145-2A-BJSK 0 1,000 FeetFILE: D:\McLouth_Steel_Gibraltar\mxd\F5_Sed_Sampling.mxd 8/4/2014 12:02:29 PM wojdakon

Legend Sediment Sampling Locations On-site Ditch
Perennial Stream Image Source: ESRI World Imagery

Prepared For: U.S. EPA REGION V Prepared By: WESTON SOLUTIONS, INC
750 E. Bunker Court Suite 500 Vernon Hills, IL 60061 Figure 5 Sediment Sampling Location Map DSC McLouth Steel Gibraltar Plant Gibraltar, Wayne County, Michigan Note: All sediment sampling locations are approximate (Ref. 7, p. 16)11 

### REFEREN CES

1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System, Final Rule, as presented in Volume 55 Federal Register (FR) 51532-51667. December 14, 1990. 138 pages.

2. EPA. Superfund Chemical Data Matrix (SCDM) Methodology. Data versions: 6/20/2014. A complete cop y of SCDM is available at: http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm [73 pages]

3. U.S. Geological Survey (USGS). 7.5-Minute Series Topographic Map: Rockwood Quadrangle, Michigan – Ontario. Scale 1:24,000. 1967. Photorevised 1973. [1 map]

4. Weston Solutions Inc. (WESTON). Longitude and Latitude Calculations for McLouth Steel Gibraltar Site by Megan Abbott, March 24, 2014. [2 pages]

5. Michigan Department of Environmental Quality (MDEQ), Waste Management Division and Environmental Response Division, Comprehensive Corrective Action and Remedial Consent Order for Trenton and Gibraltar Facilities, WMD Order No. 111-15-99, December 17, 1999. [190 pages]

6. MDEQ, CERCLA Re-Assessment Report for McLouth Steel Corp Gibraltar Plt. March 28, 2013. [25 pages]

7. Environmental Quality Management, Inc. Draft Environmental Assessment Report, Former McLouth Steel-Gibraltar Complex Site, Gibraltar, Wayne County, Michigan. Prepared for: U.S. EPA. May 6, 2011. [2405 pages]

8. Reference Number Reserved.

9. WESTON. 15 -Mile T DL Map prepared by David Hernandez, October 16, 2013. [1 map]

10. USGS. 2011 . 7.5 -Minute Series Topographic Map: Rockwood, Michigan. Scale 1:24,000. [1 map]

11. EPA Region V Pollution Report. Site Mobilization. Former McLouth Steel GibraltarComplex Site. March 2, 2010. [2 pages]

12. EPA. Region V Poll ution Report. Former McLouth Steel Gibraltar-Complex Site. March 24, 2010. [2 pages]

13. U.S. Fish and Wildlife Service. National Wetlands Inventory, Wetlands Mapper. Retrieved on October 2, 2013 from http://www.fws.gov/wetlands/Data/Mapper.html . [1 page]

### 14. EPA. Decision Document for Approval of the Frank and Poet Drain TMDL Report. 2007.

[15 pages]

15. Environmental Strategies Corporation, Interim Response Activity Work Plan, August 7, 2001. 181 pages.

16. USGS. Surface-Water Annual Statistics for the Nation, Gaging Station No. 04165710: Detroit River at Fort Wayne at Detroit, MI. Retrieved on October 2, 2013 from http://waterdata.usgs.gov/mi/nwis/uv/?site_no=04165710&PARAmeter_cd=00065,00060

. [4 pages]

17. Michigan Department of Natural Resources, Fisheries Division. Status of the Fisheries in Michigan Waters of Lake Erie and Lake St. Clair, 2012. 2013. [26 pages]

18. Ohio Department of Natural Resources, Office of Coastal Management. Lake Erie Bathymetry. October 2007. [1 page]

19. Sena, David. WESTON. Project Note to McLouth Steel Gibraltar Site file. Subject: McLouth Steel Si te Visit. November 11, 2013. [31 pages]

20. Michigan Department of Environmental Quality. Michigan Fish Contaminant Monitoring Program, 2005 Annual Report. Document Number MI/DEQ/WB-06/091. 2005. [247 pages]

21. Michigan Department of Community Health. 2011-2012 Michigan Fish Advisory: A Family Guide to Eating Michigan Fish. [31 pages]

22. WESTON. Draft Site Assessment Report for Detroit Cold Rolling, Gibraltar, Wayne County, Michigan. December 12, 2007. [49 pages]

23. Graczyk, Lisa. Dynamac Corporation. Detroit Cold Rolling Tandem Mills Ponds Site, Gibraltar, Michigan, Data Validation Report; with attached analytical data. July 10, 2007. [87 pages]

24. RTI Laboratories. Chain of Custody Records, Case No. 0706716, June 2007. [3 pages]

25. Sena, David. WESTON., Area Calculation for Source 1. 4 pages.

26. Michigan Department of Environmental Quality, McLouth Steel Gibraltar, Michigan. February 10, 2014. 2 Pages.

27. Michigan Department of Natural Resources, Report of Wastewater Survey, September 2, 1986. 17 pages.

28. Sample Results, March 8, 1994, 1999, May 15, 2006, March 16, 2007, September 10, 2008, September 18, 2008, September 22, 2008, November 16, 2009, and November 17, 2009 . 38 pages.

1213



### 29. Sample Location Map for November 16 th 

### and 17 th 

### 2009 Sample Collection, Countywide Landfill and DSC 1A and 1B. 1 page.

30. E-mail Communications with attachments from Kecskemet, Tracy, Michigan Department of Environmental Qualit y to Muniz, Nuria U.S. EPA, Subject: DSC, February 21, 2014. 30 pages.

31. Kalkirtz, Victoria, Martinez, Michelle and Alexandria Teague, University of Michigan, Environmental Justice and Fish Consumption Advisories on the Detroit River Area of Concern, May 2008. 141 Pages.

32. DSC Limited, Environmental Affairs Department, DSC Gibraltar Plant, Request for NPDES Permit Modification, May 10, 2000. 2 pages.

33. E-mail with attachments from Muniz, Nuria, U.S. EPA, to Omprakash Patel of Weston Solutions Inc., Cou ntywide Inspection Forms from 87 to 98. February 20, 2014. 28 pages.

34. NTH Consultants Limited, Leachate Removal/Disposal Feasibility Study, Countywide Landfill, June 30, 2000. 100 pages.

35. Michigan Department of Natural Resources, Environmental Laboratory, Analytical Data for McLouth Steel Gibraltar. July 29, 1993. 8 pages.

36. State of Michigan De partment of Natural Resources. Summary of Creel Survey Results for the St. Clair Rive r, Lake St. Clair, and the Detroit River, 2002-05. April 2011. 75 pages.

37. E-mail Communications with attachment from Parker, Carolyn, Michigan Department of Environmental Quality , Forwarded to Omprakash Patel of Weston Solutions Inc. by Muniz, Nuria U.S, EPA, Subject: DSC. July 14, 2014. 4 pages.

38. E-mail Comm unications with attachment from Michael Thomas, Michigan Department of Natural Resour ces, Forwarded to Omprakash Patel of Weston Solutions Inc. by Muniz, Nuria U.S, EPA, Subject: Documentation of fisheries Detroit River. May 14, 2014. 5 pages.

39. Wayne County Department of Public Services, Land Resource Management, Affidavit regarding the use of the Lake Erie/Detroit River Fishery by Jerry Webb. August, 6, 2014. 2 pages.

40. E- mail Communications with attachments from Kecskemet, Tracy, Michigan Department of Environmental Qualit y, Forwarded to Omprakash Patel of Weston Solutions Inc. by Muniz, Nuria U.S, EPA, Subject: DSC Direct Observation. January 31, 2014. 2 pages.

41. Affidav it from Eric. C. Anderson, County of Wayne, Michigan, Subject: McLouth Steel Gibraltar, Michigan. August 6, 2014. 3 pages14



### 42. E-mail Communications with attachment from Anderson, Eric, Wayne County, Forwarded to Omprakash Patel of

Weston Solutions Inc. by Muniz, Nuria U.S, EPA, July 28, 2014. 2 pages.

43. Email Communications with attachment from Kecskemeti, Tracy, MDEQ, to Muniz, Nuria, U.S., EPA, Subject: Flow Data. February 28, 2014. 67 pages.

44. Michigan Department of Natural Resources, Analytical Data and Compliance Sampling Inspection Field Sheets. 1995. 19 pages.

45. WESTON. Wetland Frontage Calculation. August 18, 2014. 2 pages.

46. Affidavit from Eric. C. Anderson, County of Wayne, Michigan, Subject: McLouth Steel Gibraltar, Michigan. April 16, 2014. 8 pages.

47. Mi chigan Department of Environmental Quality, Application for Solid Waste Disposal Area Operating License; Gibraltar Land Company; Countywide Landfill; Waste Data System Number 424881; License Number 9113. September 6, 2005. 10 Pages.15



### SITE DESCRIPTION

This site is the location of releases from the DSC McLouth Steel Gibraltar Plant facility and the associated landfill initially operated by McLouth Steel. The DSC McLouth Steel Gibraltar Pl an t site (Site) is located at 28000 West Jefferson Avenue in Gibraltar, Wayne County, Michigan (Ref. 5, p. 8 ). The facility includes the former steel mill building, a leachate treatment lagoon system, a nd three landfills (i.e., Countywide Landfill, and Landfills A and B) (Ref. 7, p. 7 ; Figure 2 of this HRS documentation record). The leachate treatment lagoon system is located south of the former steel mill building and consists of a series of five interconnected basins and ponds (i.e., surface impoundments), and the partially closed tandem m ill p ond (TMP) (Ref. 6, p. 6). An observed release by direct observation from Source No. 1, the lagoon leachate treatment system, of wastewater discharging to an on-facility ditch that discharges to the Frank and Poet
Drain is ev aluated in this HRS documentation record (see sections 2.2.1 and 4.1.2.1.1 of this HRS documentation record). A separate landfill, the Countywide Landfill (CWLF) was partially constructed by the McLouth Steel Products Corporation and is located west of the lagoon leachate treatment system and the Frank and Poet Drain (Refs. 7, p. 9; 34, p. 4). An observed release by direct observation from Source No. 2, the CWLF, of leachate discharging to a ditch that drains to the Frank and Poet Drain is evaluated in this HRS documentation record (see sections 2.2.1 and 4.1.2.1.1 of this HRS documentation record). Source No s. 1 and 2 are discussed in more detail, below.

The McLouth Steel Company owned and operated the property as a steel finishing facility, including annealing, pickling, and cold rolling processes beginning in the early 1950s (Ref. 6, p. 5). In 1996, mill operations ceased when the facility was sold to the Detroit Steel Company, Ltd. (DSC) (Ref. 6, p. 5). In 2007, 42 acres of the property, including the former mill building, were sold to Steel Rolling Holdings, Inc. (Ref. 6, p. 5).

The partially closed TMP historically received oily process water from the former steel mill, where it was acidified to allow oil to separate from the water before being pumped into thetreatment lagoons for additional processing prior to discharge through an outfall into an onfacility ditch that discharged into the Frank and Poet Drain (Refs. 6, p. 6; 15, p. 46). The
leachate treatment lagoon system also receives leachate from Landfills A and B (Ref. 6, p. 12).16



### Landfills A and B are located to the south and to the west of the leachate treatment lagoon system, respe ctively, and are approximately 23 and 32 acres in size, respectively (Ref. 6, p. 8).
The steel mill sludge was disposed in these landfills (Ref. 6, p. 8). Leachate from Landfills A
and B is tr eated in a lagoon system and discharged into an on-facility ditch that discharges to the Frank and Poet Drain under an expired National Pollutant Discharge Elimination System (NPDES) permit (Ref. 6, p. 7). The treatment system consists of solids settling, pH adjustment, ammonia reduction, and aeration (Ref. 6, p. 7). The current system has not been properly maintained and does not reliably meet effluent discharge requirements (Ref. 6, p. 7).

West of the mill is the Countywide Landfill (CWLF). The landfill is approximately 93 acres and waste including steel manufacturing waste including mill scale, blast furnace dust, filter cake and grit were disposed in the CWLF (Ref. 6, p. 8).

Two sources are scored as part of the DSC McLouth Steel Gibraltar Plant site in the HRS
documentation reco rd. Source No. 1 is a series of nine interconnected wastewater treatment ponds located immediately south of the Gibraltar Plant facility buildings that reportedly has an outfall that discharges to a drainage ditch connected to the adjacent Frank and Poet Drain (See section 2.2.1 of this HRS documentation record). Historically, the ponds treated process water generated during steel rolling activities, and the discharge of wastewater was monitored under the National Pollutant Discharge Elimination System (NPDES) permit program (Ref. 6, pp. 6-7). Although the existing NPDES permits have expired, the ponds continue to discharge to thedrainage ditch (Ref. 6, pp. 6, 12). Samples collected from the individual ponds and from the onfacility ditch have confirmed the presence of hazardous substances (See section 2.2.1 of this HRS documentation record).

Source No. 2 is a landfill known as Countywide Landfill that accepted wastes from Gibraltar Plant. The leachate from the landfill would discharge from the base of the dike into an on property ditch that is connected to the Frank and Poet Drain (Refs. 33, pp. 22, 24; 41, pp. 2, 3).

The site is evaluated usi ng the surface water migration pathway. The in-water segment includes the perennial segment of the ditch to which Source No. 1 drains, the Brownsto wn Creek and the
F rank and Poet Drain, which flows south to its confluence with the Detroit River (Refs. 3, p. 1;17



### 9, p. 1). The Detroit River discharges into Lake Erie, and both the Detroit River and Lake Erie reportedly have fisheries associated with them (Refs. 3, p. 1; 39, pp. 1-2).18



### 2 .2 Source Characterization
Source characterization for the Site includes identification of the sources, hazardous substances associated with the sources, and pathways potentially threatened by the hazardous substances.
T wo sources have been evaluated at the Site for HRS purposes:

 Source No. 1 –

Leachate Treatment Lagoon System

 Source No. 2 – Countywide Landfill

2.2.1 Source No. 1 Identification
Number of the Source: Source No. 1

Name and Description of the Source: Leachate Treatment Lagoon System (Surface Impoundments including water retention basin #1 (pH Adjustment Pond), water retention basin #2 (Settling Pond), water retention basin #3, water retention basin #4 (aeration pond #2), the acid dosing pond (A mmonia Reduction Pond), and four ponds that make up the TMP) (Refs. 7, p. 19 ; 15, p. 46).

The leachate treatment lagoon system includes nine surface impoundments used for various

tr eatment functions for waste from various parts of the operations at the facility prior to discharge through a common pipe into an on-facility ditch that discharges into the Frank and Poet Drain (Refs. 6, p. 6, 7, 8; 15, p. 46). The configuration of interconnection between the
leachate t reatment lagoon system ponds has been modified over time and is currently configured to share a common discharge point through an outfall from water retention basin #4 (Refs. 15,

p p

. 9, 46; 32, p. 2; 35, p. 8; 40, pp. 1-2).

The trea tment system consists of solids settling, pH adjustment, ammonia reduction, and aeration (Ref. 6, p. 7). The cooling and process water and process oils including lubricating, hydraulic, rolling and slushing oils were discharged into TMP (Ref. 15. p. 7). The TMP is an earthen
surface impoundment that is part of the treatment lagoon system for oil separation and was a component of the NPDES permitted treatment system (Ref. 15, pp. 7-8). The TMP received

co o ling water from the rolling mill and other process waters from the cold mill and ancillary production operations (Ref. 15, p. 7). Process and cooling water contained lubricating , hydrauli c, rolling, and slushing oils (Ref. 15, p. 7). Spent sulfuric acid contained in the Acid19



### Dosing Pond (ADP) was used in the TMP (Ref. 15 , pp. 7, 46). ADP also received leachate from landfills 1A and 1B ((Ref. 15, pp.8, 46). DSC has also installed a wastewater treatment system
to treat the leachate from Landfill 1A and 1B before the leachate is discharged to the wastewater treatment ponds (Ref. 15, p. 8, 46). Landfills A and B are located to the south and to the west of the leachate treatment lagoon system, respectively, and are approximately 23 and 32 acres in size, respectively (Refs. 6, p. 8; 15, p. 46). The steel mill sludge was disposed in these landfills (Ref. 6, p. 8). Leachate from Landfills A and B is treated in a lagoon system and discharged to the Frank and Poet Drain under an expired National Pollutant Discharge Elimination System (NPDES) permit (Ref. 6, p. 7). The waste water treatment ponds also include four treatment ponds (water retention basins) (Ref. 15, p. 46) 

### . All four treatment ponds are interconnected and discharge though one outfall (Ref. 15, p. 46). 

### Since all ponds including the TMP, ADP and 4 waste water treatment ponds (water retention basins) are interconnected, classified as surface impoundment s, discharge through one outfall and contain similar hazardous substances, they are
considered a s one source (Source No. 1) (Ref. 15, p. 46; see Tables 1-3 of this HRS documentation record).

At the time the facility was built, the six-acre TMP was excavated to ten feet into native clay for the purpose of separating oil in process water (Ref. 22, p. 10). The TMP historically received oily process water from the former steel mill, where it was acidified to allow oil to separate from
the water be fore being pumped into the treatment lagoons for additional processing prior to discharge through an outfall into an on-facility ditch that discharges into the Frank and Poet Drain (Ref. 6, p. 6). The TMP is sectioned into a minimum of four smaller ponds (Refs. 22, pp

. 1 5, 27). In 1997, approximately 300,000 gallons of free-floating oil and rag material were removed using recovery booms (Ref. 22, p. 11). Oil in the TMP is composed of process oils including lubricatin g, hydraulic, rolling, and slushing oils (Ref. 6, p. 8). The composition of the

non -aqueous materials in the TMP included primarily free-floating oil and rag material (Ref. 22, p. 11). In 1998, the booms were reconfigured and by May 1999, approximately 57,500 gallons of oil were removed, with the remaining 4,800 gallons of oil removed by June 1999 (Ref. 22, p. 11). The soil on the banks of the TMP has adsorbed some oil (Ref. 22, p. 11). TMP still contains residual oils mixed with storm water (Ref. 6, p. 6). Water discharged into the Frank and
Poet Drain contains phenols, polychlorinated biphenyls (PCBs), metals, and has a high pH value (Ref. 6, p. 8) . DSC is operating under an expired NPDES permit for the discharge and is not20



### monitoring for constituents of concern contained in the discharge (Ref. 6, p. 12). Dead birds allegedly have been found in the site vicinity due to the oils found in the TMP (Ref. 6, p. 8).

Source Containment

Release to Surface Water via Overland Migration and/or Flood: A surface water containment factor value of 10 (Ref. 1, p. 51609, Table 4-2) is assigned because the source discharged through an outfall that discharges into the on-facility ditch that is connected to Frank and Poet Drain (Refs. 6, p. 7; 15, pp. 9, 46 ). The results of samples taken from the current and formeroutfalls contained hazardous waste discharging into the Frank and Poet Drain through an onfacility d rainage ditch (see Table 4 of this HRS documentation record).

Containment Factor Va lue: 10

2.2.2 Hazardous Substances On February 14, 2011, waste samples and wastewater samples were collected from three treatment ponds : the settling pond (Basin 2), the pH adjustment pond (Basin 1), and the aeration pond (Basin 4) (Ref. 7, pp. 19, 20). Wastewater samples and waste samples were collected from four locations within each pond, composited, and submitted for laboratory analysis (Ref. 7, pp,
19 -21). Wastewater sample MSG- WWP

- SW -01 and waste sample MSG- WWP -SED-01 were collected from the pH adjustment retention basin; Wastewater sample MSG-WWP- SW -02 and

waste sample MSG- WWP -SED-02 were collected from the settling pond; and Wastewater sample MSG- WWP

- SW -04 and waste sample MSG- WWP -SED- 04 were collected from aeration Basin No. 2 (Ref. 7, pp. 19-21, 62-64, 117-119). The wastewater and waste samples were analyz ed for Appendix IX volatile organic compounds (VOCs), Appendix IX semi-volatile organic compounds (SVOCs), Appendix IX pesticides, Appendix IX PCBs, metals, cyanide and

mercury (Ref. 7, p. 17). The VOCs were analyzed by Method SW-846 Method 8260B; SVOCs were analyzed by SW-846 Method 8270C; PCBs were analyzed by SW-846 Method 8082, pesticides were analyzed by SW-846 Method 8081A, metals were analyzed by SW-846 Methods 6010B, 6020 and 7470A; and cyanide was analyzed by SW-846 Method 9012A (Ref. 7, pp.
2357 -2360, 2385-2388). The Wastewater and waste sampling locations are presented in Figure 4
of this HRS documentation record. Table 1 summarizes the hazardous waste constituents21



### detected in wastewater samples and Table 2 summarizes the hazardous constituents detected in waste samples.

On June 20 and 21, 2007, The U.S. Environmental Protection Agency and Weston Solutions, Inc. (W ESTON) Superfund Technical Assessment and Response Team (START) conducted site assessment (SA) ac tivities at the DSC facility (Ref. 22, p. 14). Nine waste samples were
collected b y WESTON START from the TMP, acid dosing pond, and sludge drying ponds (Ref.
22 , pp. 17 ). All waste sa mples were analyzed for SVOCs, PCBs, metals, and total organic halides (TOH) (Ref. 22, p. 17). Two samples from the TMP were also analyzed for VOCs (Ref.
22 , p. 17). Waste samples were collected from the top 6 inches to 1 foot of waste surface (Ref.
22 , pp. 16). Waste water samples were collected from the approximate center of each pond (Ref.
22 , p. 17 ). Waste samples DCR- SD

- AD

- 01 -062007 and DCR- SD

- AD -02-062007 were collected from the acid dosing pond; waste samples DCR- SD

- SD -01 -062007 and DCR- SD

- SD

02 -062007 were collected from the sludge drying pond; and waste samples DCR- SD -TMP1-01

- 062107, DCR- SD -TMP2-01-062107, DCR- SD -TMP3-01-062107, DCR- SD -TMP4-01-062007,
and DCR- SD -TMP4 -02 -062007 were collected from the TMP (Ref. 22, p. 19). The VOC samples were analyzed by SW-846 Method 8260B, SVOCs were analyzed by SW-846 Method 8270C, PCBs were analyzed by SW-846 Method 8082, and metals were analyzed by SW-846 Methods 6020A, 7471A, and 7470A (Ref. 23, p. 1). The waste water and waste sampling
locations are presented in Figure 4 of this HRS documentation record. Table 3 summarizes the
hazardous waste c onstituents detected in waste samples.

On June 13, 1995, an effluent sample from the final outfall was collected and analyzed by Michigan Department of Natural Resources Environmental Laboratory (Ref. 44, pp. 1-19). In 1986, sample 001 was collected from outfall 001 from pond 3 (Refs. 27, pp. 3, 7; 40, pp. 1, 2).
Hazardous waste co nstituents were detected in the outfall effluent sample (001) from pond 3 (see
Table 4 of this HRS documentation record). Table 4 of this HRS documentation record summarizes the hazardous waste constituents detected in outfall effluent samples.22 Table 1 : Analytical Results for Waste W ater Samples Collected f rom Source No. 1 Sample ID Da te Location Hazardous Substance MDL RL Substance Concentration Units References

MSG

WWP

SW

- 01

- 14/02/11 2/14/2011 Water Retention Basin #1
( pH Adjustment R etention B asin ) Arsenic 0.15 1 5.2 μ g/L
Ref. 7, pp. 118, 2139,

2148, 2193

- 2195, 2385

- 2388 Nickel 0.12 1 113 μ g/L Vanadium

0.18 1 3.4 μ g/L

MSG

WWP

SW

- 02

- 14/02/11 2/14/2011 Water Retention Basin #2
( S ettling P ond ) Arsenic 0.15 1 4.1 μ g/L

Ref. 7, pp. 2139, 2196

- 2198 , 2385

- 2388 Nickel 0.12 1 75.5 μ g/L Strontium 0.03 5 422 μ g/L

Vanadium 0.18 1 4 μ g/L

MSG

WWP

SW

- 04

- 14/02/11 2/14/2011 Water Retention Basin #4 ( Ae r ation Pond # 2 ) Arsenic

0.15 1 2 mg/L Ref. 7, pp. 2139, 2199

- 2202, 2385

- 2388 Nickel 0.12 1 43.9 mg/L Strontium 0.03 5 434 mg/L Notes: ID – Identification μg/L – Micrograms per liter mg/L – Milligrams per liter MDL – Method detection limit RL – Reporting limit23 T able 2 : Analytical Results for the Waste Samples Collected from Source No. 1 Hazardous Substance Sam ple ID Date Location Substance RL MDL Concentration Units References

MSG

WWP

- SED

01

- 14/02/11 2/14/2011 Water Retention Basin #1 ( pH Adjustment R etention B asin ) Fluorene 1 0 00 1 30 1,3 00 μg/kg

Ref. 7, pp. 63, 1949, 1980, 2080

- 2082, 21 16, 2357

- 2362 , 2364 Arsenic 1.5 0.27 2.3 mg/kg Chromium 3 0.091 19.7 mg/kg Cobalt 0.74 0.022 2.5 mg/kg Copper 3 0.49 10 mg/kg Nickel 1.5 0.17 80.1 mg/kg Vanadium 1.5 0.12 5.2 mg/kg Cyanide 1.5 0.29 2.5 mg/kg

MSG

WWP

- SED

02

- 14/02/11 2/14/2011 Water Retention Basin #2 (Settling Pond ) Antimony 2.1 0.028 2.4 mg/kg

Ref. 7, pp. 63, 1949, 204 3 , 2083

- 2085, 2357

- 2362 , 2364 Arsenic 1.1 0.19 16.4 mg/kg Chromium 2.1 0.065 44.2 mg/kg Cobalt 0.53 0.016 4.1 mg/kg Copper 2.1 0.35 80.8 mg/kg Nickel 1.1 0.12 91.3 mg/kg Strontium 5.3 0.029 147 mg/kg Vanadium 1.1 0.084 9.1 mg/kg Aroclor 1260 35 4.9 49 μg/kg

MSG

WWP

- SED

04

- 14/02/11 02/14/ 20 11 Water Retention Basin #4 Aeration Pond # 2 Arsenic 1.3 0.23 14.9 mg/kg

Ref. 7, pp. 63, 1949, 2086

- 2088, 2357

- 2362 , 2364 Chromium 2.6 0.078 47 mg/kg Cobalt 0.64 0.019 10.6 mg/kg Copper 2.6 0.42 64.4 mg/kg Lead 1.3 0.048 49.3 mg/kg

Nickel 1.3 0.14 138 mg/kg Vanadium 1.3 0.1 0 18.4 mg /kg Notes: μg/kg – Micrograms per kilogram ID – Identification μg/L – Micrograms per liter mg/kg – Milligrams per kilogram MDL – Method detection limit RL – Reporting limit24 Table 3: Analytical Results for Waste Samples Collected from the Acid Dos ing Pond and Tandem Mill Pond s in 2007
Sample ID Date Location Depth ( ft. ) Hazardous Substance Substance Concentration RL Units References

DCR

SD

AD

- 01

- 062007 6/20/2007 Acid Dosing Pond 0

- 0.5 Arsenic 70,000 1,800 μg/kg

Ref s

. 22, p p . 19 , 38 ; 2 3, p. 22; 2 4 , p. 1 Cadmium 2,400 360 μg/kg

Chromium 150,000 36,000 μg/kg
Copper 1,300,000 18,000 μg/kg

Lead 1,100,000 18,000 μg/kg
Mercury 43 29 μg/kg

Selenium 700 360 μg/kg

Arse nic 25,000 4,000 μg/kg

Cadmium 2,500 800 μg/kg DCR

SD

AD

- 02

- 062007 6/20/2007 Acid Dosing Pond 0

- 0.5 Ref s

. 22, p p . 19 , 38 ; 2 3, p. 3 4; 2 4, p. 1 Chromium 150,000 80,000 μg/kg
Copper 210,000 40,000 μg/kg

Lead 88,000 40,000 μg/kg

Selenium 4,300 800 μg/kg

DCR

SD

TMP1

- 01

- 062107 6/21/ 2007 Tandem Mill Pond #1 0

- 0.5 Total PCBs 21,000 780 μg/kg

Ref s

. 22, p. 19 , 39 ; 2 3, p. 16; 2 4, p. 1 Aroclor 1248 9,000 780 μg/kg

Aroclor 1260 12,000 780 μg/kg

Arsenic 100,000 2,600 μg/kg

Cadmium 3,000 520 μg/kg

Chromium 190,00 0 52,000 μg/kg
Copper 1,300,000 26,000 μg/kg

Lead 1,100,000 26,000 μg/kg

Selenium 1,100 520 μg/kg

n
- Butylbenzene 320 200 μg/kg Ref s

. 22, p. 19 , 39 ; 2 3, p. 19

- 21; 2 4, p. 1 1,1

- Dichloroethane 2,200 200 μg/kg

cis

- 1,2

- Dichlor oethene 4,400 200 μg/kg

2

- Methylnaphthalene 2,000 980 μg/kg25

Table 3: Analytical Results for Waste Samples Collected from the Acid Dos ing Pond and Tandem Mill Pond s in 2007
Sample ID Date Location Depth ( ft. ) Hazardous Substance Substance Concentration RL Units References

Naphthalene 990 980 μg/kg

n
- Propylbenzene 310 200 μg/kg
1,2,3

- Trimethylbenzene 650 200 μg/kg
1,2,4

- Trimethylbenzene 1,900 200 μg/kg
1,3,5

- Trimethylbenzene 560 2 00 μg/kg
Vinyl chloride 680 160 μg/kg

Arsenic 44,000 1,500 μg/kg

Cadmium 1,200 300 μg/kg Ref s

. 22, p. 19 , 39 ; 2 3, Chromium 100,000 30,000 μg/kg

DCR

SD

TMP2

- 01

- 062107 6/21/2007 Tandem Mill Pond #2 0

- 0.5 p. 42; 2 4, p. 1 Copper 810,0 00 15,000 μg/kg

Lead 290,000 15,000 μg/kg

Selenium 630 300 μg/kg

cis

- 1,2

- Dichloroethene 310 78 μg/kg

Ref s

. 22, p. 19 , 39 ; 2 3, p. 45

- 47; 2 4, p. 1 2

- Methylnaphthalene 440 390 μg/kg

Trichloroethene 180 78 μg/kg
1,2,3

- Trimeth ylbenzene 99 78 μg/kg
1,2,4

- Trimethylbenzene 240 78 μg/kg

DCR

SD

TMP3

- 01

- 062107 6/21/2007 Tandem Mill Pond #3 0

- 0.5 Arsenic 6,500 230 μg/kg

Ref s

. 22, p. 19 , 40 ; 2 3, p. 26; 2 4, p. 1 Cadmium 830 460 μg/kg

Chromium 18,000 4,600 μg/kg
Copper 21,000 2,300 μg/kg

Lead 29,000 2,300 μg/kg

Selenium 470 460 μg/kg

DCR

SD

TMP4

- 01

- 6/20/2007 Tandem Mill Pond #4 0

- 0.5 Arsenic 6,700 140 μg/kg Ref s

. 22, p. 19 , 40 ; 2 3, p. 52; 2 4, p. 1 Cadmium 830 280 μg/kg

Chromium 20 ,000 2,800 μg/kg26 Table 3: Analytical Results for Waste Samples Collected from the Acid Dos ing Pond and Tandem Mill Pond s in 2007
Sample ID Date Location Depth ( ft. ) Hazardous Substance Substance Concentration RL Units References

062007 Copper 20,000 1,400 μg/kg

Lead 16,000 1,400 μg/kg

Selenium 420 280 μg/kg

DCR

SD

TMP4

- 02

- 062007 6/20/2007 Tandem Mill Pond #4 0

- 0.5 Arsenic 11,000 180 μg/kg

Ref s

. 22, p. 19 , 40 ; 2 3, p. 30; 2 4, p. 1 Cadmium 1,100 36 0 μg/kg

Chromium 33,000 3,600 μg/kg
Copper 42,000 1,800 μg/kg

Lead 37,000 1,800 μg/kg
Mercury 28 26 μg/kg

Selenium 520 360 μg/kg

Notes: μg/kg – Micrograms per kilogram ft. – feet RL – Reporting Limit

T able 4 : Analytical Re sults for the Outfall Effluent Samples Source No. 1 Hazardous Substance Sample ID Date Location Substance Concentration Units References Arsenic 2. 4 μ g/L Ref s

. 35 , p p. 2, 3, 6, 8 ; 40, pp. 1

- 2 S2

- 1 7 / 28 / 1993 Outfall Cadmium 3.2 μ g/L Co pper 7.6 μ g/L Nickel 9.4 μ g/L Lead 1.8 μ g/L

001 9 / 3 / 1986 Outfall 001 Cobalt 2.5 μ g/L

Ref. 2 7, pp. 3, 7 ; 40, pp. 1

- 2 , Chromium 7.8 μ g/L Mercury 0.0075 μ g/L Nickel 7.7 μ g/L Lead 0.34 μ g/L Notes: μg/kg – Micrograms per kilogram ID – Identification mg/kg – Milligrams per kilogram27



### 2.4.2 Hazardous Waste Quantity 2.4.2.1.1 Hazardous Constituent Quantity The hazardous constituent quantity for Source No. 1 could not be adequately determined according to the HRS requirements; i.e., the total mass of all CERCLA hazardous substances in
the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). There are insufficient historical and current data ( e. g. , manifests, potentially responsible party (PRP) records, state records, permits, waste concentration data) available to adequately calculate the total mass of all CERCLA hazardous substances in the source and the associated releases from the source. Therefore, there is
insufficient information to evaluate the associated releases from the source to calculate the hazardous constituent quantity for Source No. 1 with reasonable confidence. Scoring proceeds to the evaluation of Hazardous Wastestream Quantity (Surface Water Pathway) according to the HRS (Ref. 1, Sec. 2.4.2.1.1 and 2.4.2.1.2).

Hazardous Constituent Quantity Value (S): Not Calculated Are the data complete for hazardous constituent quantity for this area? No 2.4.2.1.2 Hazardous Wastestream Quantity The Gibraltar facility has a lagoon treatment system that includes nine surface impoundmentsused for various treatment functions prior to discharge through a common outfall pipe into an onfacility ditch that discharges into Frank and Poet Drain (Refs. 6, p. 6, 7, 8 ; 15, pp. 9, 46; 32, p. 2; 35, p. 8; 40, pp. 1-2; 42, pp. 1-2 ). Prior to 2000, the configuration of the leachate treatment system invol ved collection of the leachate from Landfill A and conveyed it to Former Acid Dosing Pond (Ref. 32, p. 2). As of 2001, the waste water from acid dosing pond is conveyed to Tandem Mill Pond which also received leachate from Landfill 1B; wastewater from the Tandem Mill Pond is transferred to water retention basin #1; wastewater from water retention basin #1 is conveyed to water retention basin #2; wastewater from water retention basin #2 is transferred to water retention basin #3; wastewater from water retention is transferred to water retention basin #4; and, wastewater from water retention basin #4 is discharged to an on-facility ditch, which drains to the Frank and Poet Drain (Ref. 15, p. 46). The wastewater samples were collected from an outfall that suggested that hazardous waste constituents were being discharged through the outfall and conveyed to the Frank and Poet Drain through an on-facility ditch (Refer to Table 428



### of this HRS documentation record). MDEQ extracted effluent flow from their NPDES database for the flow for the Gibraltar facility (Ref. 43, p. 1). The flow information from April 18, 2004 through Dece mber 31, 2013 was available at the time of preparation of this documentation record package (Ref. 43, p. 2-66). Based on the information provided by MDEQ the effluent
flow was landfill leac hate treated by the lagoon system (Ref. 32, pp. 1-2 ; 40, pp. 1-2; 43, pp. 1-
2 ). The total flow from outfall 001A from water retention basin #4 from the period of April 18, 2004 through December 31, 2013 was added to arrive at total flow of 43,496,190 gallons of effluent has been discharged in batches fro m the outfall from water retention basin #4, into the

on -facility ditch discharging into Frank and Poet Drain (Ref. 43, pp, 1-67). HRS Table 2-5 uses
a conversion rate of

2,000 pounds per 200 gallons. (Ref. 1, Section 2.4.2.1). Therefore, 434,961,900 pounds of effluent containing hazardous constituents were discharged into a ditch discharging into Frank and Poet Drain. The hazardous wastestream quantity in pounds (W) is divided by 5,000 to obtain the assigned value as shown below (Ref. 1, Table 2-5).

Ma ss of source in pounds: 434,961,900 Hazardous Wastestrea m Quantity Value (W): 434,961,900/5,000 = 86,992.38

2.4.2.1.3 Volume The depth of each treatment lagoon is not known; therefore, the volume of the source cannot be adequately determined. Volume is assigned a value of 0 and scoring will proceed to an evaluation of area according to the HRS (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).

2.4.2.1.4 Area The approximate area of each treatment lagoon was calculated and is summarized on the following table (Ref. 25, pp. 1-3).

Total Area of Source No. 1 Leachate Area (square Reference Treatment Lagoon System feet) pH Adjustment Pond ( Water Retention Basin #1) 49,296 Ref. 25, pp. 1, 3 Settling Pond ( Water Retention Basin #2) 43,952 Ref. 25 , pp. 1, 3 Wat er Retention Basin #3 Unknown but > 0 

### Ref. 22, p p

. 27, 29 Aeration Pond #2 ( Water Retention Basin #4) 62,976 Ref. 25 , pp. 1, 3 Tandem Mill Pond #1 14,080 Ref. 25 , pp. 1, 3 Tandem Mill Pond #2 35,088 Ref. 25 , pp. 1, 3 Tandem Mill Pond #3 28,440 Ref. 25 , pp. 1, 329 

### Tandem Mill Pond #4 19,936 Ref. 25 , pp. 1, 3 Acid Dosing Pond 33,792 Ref. 25 , pp. 2, 3
Total (Square F eet) 287,560

The approximate area for Source No. 1 is 287,560 square feet. Using the area calculated for
Source No. 1 in the equation for surface impoundment (e.g., area is divided by 13) from Table 2- 5, (Ref. 1, p. 51591) the haza rdous waste quantity value for Area (Tier D) is 22,120 (287,560 divided by 13) (Re f. 1, Section 2.4.2.1.4, p. 51591).

2.4.2.1.5 Calculation of Source Hazardous Waste Quantity Value Source No. 1, Leachate Treatment Lagoon System The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 1 Hazardous Waste Quantity Value (Ref. 1, Section 2.4.2.1.5, p. 51591). The highest value assigned is to Tier B. Therefore, the Source No. 1 Hazardous Waste Quantity Value is 86,922.38.

Source No. 1 Hazardous Waste Quantity Value: 86,922.3830 HAZARDOUS WASTE QUANTITY VALUE

Source No. 1 Hazardous Waste Quantity
T ier Measure Source Value Tier A, Hazardous Constituent Quantity Not Evaluated Tier B, Hazardous Wastestream Quantity 86,922.38 Tier C, Volume Not Evaluated Tier D, Area 22,12031

2.2.1 Source No. 2 Identification



### Number of the source: Source No. 2

Na me and description of the source: Countywide Landfill (CWLF) (Landfill)

Source No. 2, the CWLF, is an approximately 93 acre landfill property located to the west side of
the fa cility, west of the Frank and Poet Drain and railroad tracks; north of Brownstown Creek; east of Canadian National North America rail line and commercial properties; and south of Vreeland Road (Refs. 3, p. 1; 6, pp. 5, 8; 10, p. 1). As of 2005, the active fill portion of the CWLF occupied approximately 49.5 acres (Ref. 47, p. 3).

The CWLF was formerly owned and operated by the McLouth Steel Company, which was originally licensed in 1976 under Michigan’s Solid Waste Management Act, 1965 PA 87 (Ref. 6, p. 5). A portion of the landfill (approximately 43 acres) was constructed by McLouth Steel and was known as McLouth Steel Area 4 (Refs. 28. p. 4; 41, p. 1). The waste from the McLouth Steel Company was accepted on or before 1999. After 1999, the McLouth Steel Area 4 was
renamed a s Countywide Landfill (Refs. 41, p. 2). At this time the CWLF started accepting

co nstruction and de molition (C & D) waste (Refs. 41, p. 2). Soon after the CWLF began operations, the f

acility began experiencing leachate outbreaks on the side slopes (Refs. 41, p. 2).
The leac hate that percolated through the porous C & D waste would hit the dense McLouth
waste and mi grate latterly and come out the side slopes (Ref. 41, p. 2). This leachate tended to be
clear or milk y in color and had either no odor or a slight sulfur odor (Ref. 41, p. 2). The pH of
this leacha te tended to be around 7 (Ref. 41, p. 2). This leachate was very different chemically and phy sically from the McLouth Leachate, and it was reported to be pretty easy to tell the
differe nc e between the two types of leachate (Ref. 41, p. 2). The McLouth Steel waste leachate was easily identifia

ble, and it was red in color and had a strong phenolics smell (Ref. 41, p. 1). When tested with pH pa

per, the leachate ranged from a pH of 10 to a pH of 13 (Ref. 41, p. 1).
In a ddition, by knowing where the landfill was leaking from, it could be estimated which type of
leacha te was present (Ref. 41, p. 2). If the leachate were coming out of the side slope above the dike/perimeter r oad, it was countywide or “upper leachate” (Ref. 41, p. 2 ). If the leachate was32



### coming out from under the dike or through the dike, it was McLouth leachate or “lower leachate” (Ref. 41, p. 2).

The combi ned leachate (i.e., upper and lower leachate) in the northwest portion of the CWLF flows through a n on-facility ditch into the southern end of a large pond present on the northern portion of the property (Refs. 33 pp. 22, 24; 42, p. 2; 46, p. 8). The large pond discharges into Frank and Poet Drain from the northern portion of the pond (Refs. 33 pp. 22, 24; 42, p. 2; 46, p. 8). During inspections by MDEQ, the releases of leachate from other parts of the CWLF were seen discharging to the Frank and Poet Drain (Refs. 33, pp. 1, 3, 17, 22, 27)

The CWLF received steel manufacturing wastes from McLouth Steel Products in Trenton as well as from the Gibraltar Plant (Ref. 6, p. 5). Wastes included mill scale, blast furnace dust, filter cake, and grit (Ref. 6, p. 5). The filling operations continued until the mid-1980s (Ref. 6, p. 5). Those areas not filled were noted to contain ponded water (Ref. 6, p. 5).

In 1982, a permit wa s issued for the continued operation of a Type III landfill under the former Solid Waste Management Act, 1978 PA 641 (Ref. 6, pp. 5-6). A clay cutoff dike was constructed along the perimeter of the landfill to provide lateral leachate containment (Ref. 34, p. 4). The ponded water areas were reportedly filled with construction debris from re-construction of roadways near the area (Ref. 6, p. 6). In August 2007, the last load of waste was disposed of
at the CW LF (Ref. 37, p. 2). In February 2008, Gibraltar Land Company (GLC) informed MDEQ that they did not have funds for management of leachate and also ceased pumping of leachate as of February 27, 2008 (Ref. 37, p. 2). An access agreement was signed between GLC and MDEQ and their contractors to access the landfill for management of leachate and initiate any closure and corrective action activities, as necessary (Ref. 37, p. 2).

Following obtaining funding from MDEQ, GLC’s contractor Advanced Resource Recovery resumed pumping leachate and transporting it for disposal to their disposal facility in Inkster, Michigan (Ref. 37, p. 2). As of July 2014, Advance Resource Recovery still is continuing to pump and dispose of the leachate from the CWLF facility (Ref. 37, p. 4). As part of site improvement under taken by CWL F, a leachate collection line was installed at the base of the north face of the landfill (Ref. 41, p. 2). This collection line collected the lower leachate as well as any upper leachate that managed to migrate through the McLouth Steel waste (Ref. 41, p. 2).33



### The line was constructed with a high point in the middle, and leachate was directed to the east and west sump (Ref

. 41, pp. 2, 3).

During the time Countywide Landfill was operating, the sump locations were never fully comple ted, and the sump locations were basically open ponds of leachate (Ref. 41, p. 3). These ponds were te rmed the e ast and west ponds (Ref. 41, p. 3). In reality, the east and west sumps
and ea st and west ponds are the same locations and the terms were used interchangeably (Ref. 41, p. 3). To control the leaking of upper leachate, the facility installed a series of six stand pipes on the west slope a nd one stand pipe on the east slope (Ref. 41, p. 3). These standpipes were pumped from a small tan ker truck on the landfill property, and the leachate was dumped mainly in the west pond, thus mixing the leachate (Ref. 41, p. 3). Large tanker trucks would then pump
leachate from the pond and take it to an approved Publicly Owned Treatment Works (POTW) for disposal (Ref. 41, p. 3).

A toe drain pipe, inst alled by McLouth, exists at the northeast corner of the active fill area within the landfill footprint (Ref. 34, p. 5). Liquids from this drain pipe are diverted into the East Leachate Pond (Ref. 34, p. 5).

After the CWLF owners walked away in 2008, the MDEQ took over active leachate removal (Ref s. 37, p. 2; 41, p. 4). The EPA came in 2010 and constructed a perimeter leachate collection
line on both the east and west sides of the landfill (Ref. 41, p. 3). These lines were designed to

convey uppe r leachate to the leachate collection sumps/ponds eliminating the need to pump the stand pipes to control the leachate, upon the completion of these lines the two leachates were comingled in the sumps (Ref. 41, p. 3).

Respondi ng to a request by the MDEQ in 2010, the EPA constructed a leachate collection system for the CWLF, filled the eastern and western leachate ponds with stone and covered them with clay, installed a loading pipe with level indicator, leveled and graded the cap, and seeded the exposed areas of CWLF (Ref. 6, p. 6). The CWLF is currently not operating and does not have an operating license (Ref. 6, p. 6). The MDEQ manages the leachate through a Perpetual Care Fund (PCF) for the landfill, a fund established for financial assurance licensed under Part 115, Solid Waste Management, of the Natural Resources and Environmental Protection Act,
1994 PA 451, as amended (Ref. 6, p. 6). Approximately 10,000 gallons per day of leachate are34



### pumped and hauled off-site, 5 days per week. The balance of the PCF is expected to be exhausted by

the end of 2013 (Ref. 6, p. 6).

The 

### CWLF had never been fully closed or properly capped and, as a result, and was noted in
2013 to consistentl y ha ve leachate breakouts that run into Brownstown Creek (Ref. 6, pp. 6, 8). The leachate from the CWLF was manually pumped out of the standpipes and two wells and then consolidated into two open ponds, referred to as east and west sump (Refs. 34, p. 5; 37, p. 1; 41, p. 3). Pe riodically, the leachate is removed from the sumps by a vacuum truck and disposed
of off property. When the leachate is consolidated into the sump, the upper and lower leachate mixes (Refs. 41, p. 3). The leachate from the upper CWLF could be discharged to the wastewater

treatment plant without pre-treatment (Ref. 36, p. 3). However, the leachate from the lower CWLF does not meet the local limits and would require pre-treatment (Ref. 36, pp. 3, 4).

The contamination associated with Source No. 2 was based on sampling conducted by EPA in November 2009 when six leachate samples from the CWLF were collected (East Well, West Well, Standing Pipe #1, Standing Pipe #3, Standing Pipe #5, and Standing Pipe #7) (Ref. 11, p. 1). The approximate extent of waste disposal area is shown in (Ref. 42, p. 1).

Location of the source, with reference to a map of the Site:

Source No. 2 is located on the west side of the Site, west of Frank and Poet Creek and railroad tracks; north of Brownstown Creek; east of Canadian National North America rail line and commercial properties; and south of Vreeland Road (Refs. 3, p. 1;6, pp. 5, 8; 10, p. 1). Refer to Figure 2 of this documentation record package for the location of the source.

Source Type for HRS evaluation purposes:

Landf ill

Source Containment



### Release to Surface Water via Overland Migration and/or Flood: A surface water containment factor value of 10 (Ref. 1, p. 51609, Table 4-2) is assigned because there are no records documenting that the CWLF were lined and appropriatel y covered (i.e., the source has no maintained engineered cover, or functioning and maintained run-on control system and runoff35



### management system) (Ref. 6, p. 7); and because the leachate from the landfill was observed to be discharging into the Frank and Poet Drain and Brownstown Creek (Ref. 33, pp.1, 3, 17, 22, 27).

2.2.2 Hazardous Substanc es


### In November 2009, U.S. EPA collected six leachate samples from Countywide Landfill (East Well, West Well, Standing Pipe #1, Standing Pipe #3, Standing Pipe #5, and Standing Pipe #7) (Ref. 11, p. 2). Leachate from the CWLF is the product of percolation of precipitation and ground water through steel waste and construction debris and contains high concentrations of phenolic compounds, metals, and high pH (Ref. 12, p. 1). Specifically, leachate contains carbazole, mercury, silver, PCBs, vanadium, cyanide, carbon disulfide, phosphorus, naphthalene, 2, 4-dimethylphenol, phenol, and nickel (Ref. 6, p. 8). Table 5 summarizes hazardous constituents detected in the leachate samples collected from East Well, West Well, Standing Pipe #1, Standing Pipe #3, Standing Pipe #5, and Standing Pipe #7 (Refs. 11, p. 1 ; 28, p. 24, 25 ).

Table 5: Analytical Results for Leachate Samples Collected from Countywide Landfill
Sample ID Date Loc ation Hazardous Substance Substance Concentration RL Units References

CWLFL

LL

111609

- EW 11/16/2009 East Well Mercury 1.74 0.5 ng/L Refs. 28, p. 24 , 25; 29, p. 1 Selenium 14.04 8.5 μg/L

Strontium 2,643 50 μg/L

CWLFL

LL

111609

- WW 11/16/2009 Wes t Well 1,1

- Dichloroethane 1.65 1 μ g/L

Refs. 28, p. 24 , 25; 29, p. 1 2

- Methylnaphthalene 5.92 5 μ g/L

Acetone 116 50 μ g/L
Carbon disulfide 12.12 5 μ g/L

Naphthalene 46.24 5 μ g/L 2,4

- Dimethylphenol 2,291 480 μ g/L

2

- Methylphenol 45 .33 24 μ g/L36 

### Table 5: Analytical Results for Leachate Samples Collected from Countywide Landfill
Sample ID Date Loc ation Hazardous Substance Substance Concentration RL Units References

3,4

- Methylphenol 799 24 μ g/L
Phenol 18,970 480 μ g/L Mercury 6.52 0.5 ng/L
Arsenic 21.02 5 μ g/L
Nickel 459 50 μ g/L

Lead 6.39 2 μ g/L
Selenium 21.32 8.5 μ g/L

CWLFL

LL

111609

- SP1 11/16/2009 Stand Pipe 1 Mercury 40.34 0.5 ng/L Refs. 28, p. 24 , 25; 29, p. 1 Arsenic 8.96 5 μ g/L

Lead 63.15 2 μ g/L

CWLFL

LL

111609

- SP3 11/16/2009 Stand Pipe 3 Naphthalene 4.28 24 μ g/L

Refs. 28, p. 24 , 25; 29, p. 1 Mercury 25.15 0.5 ng/L

Arsenic 70.23 5 μ g/L

Nic kel 59.15 50 μ g/L
Antimony 3.1 2 μ g/L

Selenium 18.02 8.5 μ g/L

Strontium 2,322 50 μ g/L

Vanadium 126 10 μ g/L

Arsenic 5.1

-- μ g/L

A1LA 12/11/96 Stand Pipe Ref. 30, p. 2 through 7 Copper 3.8

-- μ g/L

Nickel 900

-- μ g/L

### Table 5: Analytical Results for Leachate Samples Collected from Countywide Landfill
Sample ID Date Loc ation Hazardous Substance Substance Concentration RL Units References

Lead 1.6

-- μ g/L

Selenium 2.2

-- μ g/L
Naphthalene 42 1.2 μ g/L
Acenaphthene 5.4 1.2 μ g/L

Fluorene 3.1 1.2 μ g/L
Diethyl phthalate 8.4 1.2 μ g/L

Phenanthrene 4.6 1.2 μ g/L

Anthracene 2.6 1.2 μ g/L
1,2,4

- Trimethylbenzene 15 10 μ g/L

A4LA 12/11/96 East Well Arsenic 9.4

-- μ g/L

Ref. 30, p. 2, 3, 8, 9 Cadmium 0.4

-- μ g/L

Copper 1.1

-- μ g/L

Nickel 440

-- μ g/L

Lead 4.3

-- μ g/L

Selenium 3.5

--- μ g/L
Naphthalene 28 1 μ g/L
Acenaphthene 2.2 1 μ g/L

Fluorene 1.2 1 μ g/L

Phenanthrene 1.9 1 μ g/L

A4LB 12/11/96 West Well Arsenic 3.7

-- μ g/L Ref. 30, p. 2, 3, 12, 13 Cadmium 0.6

-- μ g/L

3738 

### Table 5: Analytical Results for Leachate Samples Collected from Countywide Landfill
Sample ID Date Loc ation Hazardous Substance Substance Concentration RL Units References

Copper 34

-- μ g/L

Nickel 450

-- μ g/L

Lead 12

-- μ g/L
Acenaphthylene 4.9 1.2 μ g/L

Napht halene 3,000 120 μ g/L
Acenaphthene 9.6 1.2 μ g/L

Fluorene 19 1.2 μ g/L

Phenanthrene 25 1.2 μ g/L

Anthracene 4.6 1.2 μ g/L

Fluoranthene 2.8 1.2 μ g/L
Pyrene 4.4 1.2 μ g/L
Bis(2

- ethylhexyl)phthalate 190 24 μ g/L

CWLFL

LL

111609

- SP5 11/16/2009 Stand Pipe 5 Mercury 4.54 0.5 ng/L

Refs. 28, p. 24 , 25; 29, p. 1 Lead 14.68 2 μ g/L

Vanadium 31.25 10 μ g/L

Selenium 7.45 8.5 μ g/L

Strontium 2,525 50 μ g/L

CWLFL

LL

111609

- SP7 11/16/2009 Stand Pipe 7 Mercury 31.7 0 0.5 ng/L Refs. 28, p. 24; 25; 29, p. 1 Lead 3.01 2 μ g/L39



### Notes:

μg/L – Micrograms per liter

ng/L – N anogram per liter

RL – Reporting Limit

SP

– Stand Pipe

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity



### The hazardous constituent quantity for Source No. 2 could not be adequately determined according to the HRS; that is the total mass of all CERCLA hazardous substances in the source
and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). There are insufficient historical and current data (manifests, PRP records, state records, permits, waste concentration data, etc.) available to adequately calculate the total
mass of all CERCLA hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to evaluate the associated releases from the source to calculate the hazardous constituent quantity for Source No. 2 with reasonable confidence. Scoring proceeds to the evaluation of Hazardous Wastestream Quantity (Surface Water Pathway) according to the HRS (Ref. 1, Sec. 2.4.2.1.1 and 2.4.2.1.2).

Hazardous Constituent Quantity Value (S): Not Calculated

Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2 Hazardous Wastestream Quantity



### The hazardous wastestream quantity for Source No. 2 could not be adequately determined according to the HRS; that is the mass of hazardous wastestreams plus the mass of any additional CERCLA pollutants is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.2). There are insufficient historical and current data (manifests, PRP records, state records, and permits) available to adequately calculate the mass of the hazardous wastestream or40



### the mass of any additional CERCLA hazardous substances in the source. Therefore, there is
insufficient information to evaluate the associated releases from the source to calculate the hazardous wastestream quantity for Source No. 2 with reasonable confidence. Scoring proceeds to an evaluation of volume according to the HRS (Ref. 1, Sec. 2.4.2.1.2 and 2.4.2.1.3).

Hazardous Wastestream Quantity Value (W): Not Calculated

Are the data complete for hazardous wastestream quantity for this area? No

2.4.2.1.3 Volume



### The depth of the CWLF is not known; therefore, the volume of the source cannot be adequately determined. Volume is assigned a value of 0 and scoring will proceed to an evaluation of area according to the HRS (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).

2.4.2.1.4 Area



### The approximate area of the fill portion of the CWLF property is 49.5 acres (Ref. 34, p. 4);
therefore it occupies approximately 2,156,220 square feet.

(4 9.5 acres)(43,560 square feet/1 acre) = 2,156,220 square feet

The haza rdous waste quantity evaluation equation for a landfill is A/3,400 (Ref. 1, Table 2-5). The area source will be assigned an area hazardous waste quantity value of 634.18.

2,156,220 square f eet /3,400 = 634.18

Area o f source (ft 2 

### ): 2,156,220

Area Assigned Value: 634.18

Referen ces: Ref. 1, Sec. 2.4.2.1.4, p. 51591; 6, p. 8; 47, p. 3

2.4.2.1.5 Calcul ation of Source Hazardous Waste Quantity Value

Source No. 2, Countywide Landfill

### The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source

No. 2 Hazardous Waste Quantity Value (Ref. 1, Section 2.4.2.1.5, p. 51591). The highest value assigned is Tier D.

Source No. 2 Hazardous Waste Quantity Value: 634.18

Other Possible Sources



### Landfills A and B: Landfills A and B are located to the south and to the west of the leachate treatment lagoon system, respectively, and are approximately 23 and 32 acres in size, respectively (Refs. 6, p. 8; 29, p. 1; Figure 3 of this HRS documentation record ). The steel mill sludge was disposed in these landfills (Ref. 6, p. 8). Leachate from Landfills A and B is treated in a lagoon system and discharged into an on-facility ditch that discharges to the Frank and Poet Drain under an expired National Pollutant Discharge Elimination System (NPDES) permit (Ref. 6, p. 7). The leachate treatment lagoon system receives leachate from Landfills A and B (Ref 6, p. 12). The leachate from Landfills A and B consist of phenols and has a high pH (Ref. 6, p. 12). Analytical results from sediments at the outfall revealed naphthalene, PCBs, and phenols (Ref. 6,

p. 12).

Seepage from Landfill B : An outfall pipe coming from Landfill B was present on facility property (Refs. 7, p. 21; 19, pp. 1, 8; 29, p. 1 ). Water had collected in the ditch running from the
outfall pipe (Ref. 7, p. 21, 22). During a site visit by EPA, Michigan Department of Environmental Quality (MDEQ) and WESTON START, it was observed that, although capped, the pipe was dripping liquid into the ditch (Ref. 19, pp. 1, 7-10, 30). On February 14, 2011, surface water sample MSG-WWP- SW -07 and sediment sample MSG- WWP -SED-10 were collected from the intermittent ditch immediately downstream of the outfall pipe near Landfill B (Ref. 7, p. 21, 120). Samples from the lagoon leachate treatment system, which leachate from landfills A and B is treated, were shown to contain hazardous substances (Refs. 6, p. 6; 15, pp. 9, 10, 46; see Tables 2 and 3 of this HRS documentation record.)

CW LF Leachate Ponds: The leachate from the CWLF has been reported to flow into the east and west ponds located on the CWLF property (Refs. 46, pp. 6, 8; 41, p. 3). Responding to a request by the MDEQ in 2010, the EPA constructed a leachate collection system for the CWLF, filled

41

### the eastern and western leachate ponds with stone and covered them with clay, installed a

loading pipe with level indicator, leveled and graded the cap, and seeded the exposed areas of CWLF (Ref. 6, p. 6). Hazardous substances were confirmed in samples of leachate from the CWLF (see Table 5 of this HRS documentation record).

4243



### 4.0 SURFACE WATER MIGRATION PATHWAY 

### The surface water pathway evaluation for this Site includes the overland flow and flood migrati on component.

4.1 OVERLAND/FLOOD MIGRATION COMPONENT
4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component



### This section describes the overland flow and flood migration component of the surface water pathway. This section also includes a definition of the hazardous substance migration path, an
observed relea se to the Frank and Poet Drain, and a definition of targets related to the human food chain threat. The probable point of entry (PPE) 1 for Source No 1 is where an on-facility
ditch discharges into the Frank and Poet Drain; PPE for Source No 2 i s (PPE 2) is where the
ditch on the CWLF property discha rg es into the Frank and Poet Drain; Source No. 2 also has
another P PE (PPE 3) in the Brownstown Creek and Source No. 2 has another PPE (PPE 4) that discharg es into Frank and Poet Drain at approximately the northern end of the property. The 15- mile target distance limits (TDLs) for PPE 1, PPE 2, PPE 3 and PPE 4 are illustrated in
Refere nce 9 of this HRS documentation record.

Definition of In-water Segments
The watershed evaluated includes the Frank and Poet Drain and the Brownstown Creek, extending from the most upstream PPEs (PPE 3 and PPE 4) to 15 miles downstream of PPE 1 into Lake Erie (Refs. 3, p. 1; 9, p. 1; 10, p. 1). The surface water drainage pattern for the Site is generally to the southeast, except for drainage from the ditches that drain Source Nos. 1 and 2 (Ref. 3, p. 1).

15 Mile TDL for PPE 1 begins where the on-facility ditch that drains Source No. 1, the leachate treatment lagoon system, discharges into Frank and Poet Drain. The Frank and Poet Drain flows southerly into Detroit River (Ref. 9, p. 1; Figure 3 of this HRS documentation record). The Detroit River flows into Lake Erie (Refs. 3, p. 1; 9, p. 1; 10, p. 1).

15 Mile TDL for PPE 2 begins where the ditch on the CWLF property that drains Source No. 2, the CWLF, discharges into Frank and Poet Drain. The Frank and Poet Drain flows southerly into44



### Detroit River (Ref. 9, p. 1; Figure 3 of this HRS documentation record). The Detroit River flows into Lake Erie (Refs. 3, p. 1; 9, p. 1; 10, p. 1).

15 Mile TDL for PPE 3 begins in the southwest area of CWLF where the overland flow path from the landfill property discharges into Brownstown Creek (Ref. 9, p. 1). Brownstown Creek
flows southe rly into Frank and Poet Drain which flows southerly into Detroit River (Refs. 9, p. 1; 10, p. 1). The Detroit River flows into Lake Erie (Refs. 3, p. 1; 9, p. 1; 10, p. 1).

15 Mile TDL for PPE 4 begins on the northern end of the property where an on landfill property pond discharges into the Frank and Poet Drain which flows southerly into Detroit River (Ref. 9,

p . 1; Figure 3 of this HRS documentation record ). The Detroit River flows into Lake Erie (Refs. 3, p. 1; 9, p. 1; 10, p. 1).

Brownstown Creek

The Brownstown Creek, a perennial stream, flows along the western portion of the CWLF in a southeast direction and merges with Frank and Poet Drain (Refs. 9, p. 1; 10, p. 1 ). The
Brownstown C reek is partially lined with wetlands (Refs. 13, p. 1; 45, pp. 1, 2).

Frank and Poet Drain
The Frank and Poet Drain, a perennial stream, traverses the Site in a southeast direction for approximately 1.2 miles from the northern border of the Site to the eastern border (Ref. 10, p. 1; Figure 2 of this HRS documentation record). The Frank and Poet Drain flow is contiguous with freshwater forested/shrub wetlands throughout the entire 1.5 miles that it flows through the Site (Refs . 10, p. 1; 13, p. 1; 45, pp. 1-2). The Frank and Poet Drain flows approximately 0.8 mile
from the ea stern border of the Site to its confluence with the Detroit River (Ref. 10, p. 1).

The Fra nk and Poet Drain was listed on Michigan’s 2007 Section 303(d) list of impaired surface
water bodies due to its poor macroinvertebrate communities (Ref. 14, p. 2). As a result, in 2007,
the EPA establish ed a TMDL for Total Suspended Solids (TSS) in the Frank and Poet Drain (Ref. 14, pp. 4-5 ).45



### Detroit River The Detroit River is joined by the Frank and Poet Drain approximately 1.5 miles from the furthest downstream PPE (PPE No. 1) (Refs. 9, p. 1; 10, p. 1). The Detroit River flows
southward a

pproximately 4.5 miles until it empties into Lake Erie (Ref. 10, p. 1). The Detroit
River is a fisher y (Refs. 17, pp. 2, 19: 36, pp. 5, 7, 12, 16, 19, 37-40; 38; 39 ).

From 2009 to 2011, the average discharge within the Detroit River at USGS stream gauge 04165710, located approximately 15.7 miles upstream of the confluence of the Frank and Poet Drain and the Detroit River, was 188,766 cubic f ee t per second (cfs) (Ref. 16, p. 1-4), making the HRS classification of this reach of the Detroit River a Very Large River (Ref. 1, Table 4-13). While this flow measurement is from an upstream location, the flow within the TDL is at or above this amount, given that there are several other surface water bodies entering the River (e.g., the Frank and Poet Drain) downstream of this location (Refs. 9, p. 1; 10, p. 1; 16, p. 1).Therefore, the flow within the TDL is at least 188,766 cfs, the reach is classified for HRSpurposes as a v ery large river (greater than 10,000 cfs) (Ref. 1, Table 4-13).

Lake Erie
The Detroit River discharges into Lake Erie, a Great Lake, approximately 6 miles from the PPE No. 1 (Refs. 9, p. 1; 10, p. 1). The remaining 9 miles of the 15-mile TDL are contained within Lake Erie (Refs. 9, p. 1; 10, p. 1). Lake Erie is a fishery (Refs. 17, p. 2, 19; 39, pp. 2 ).

The 15-mile TDL includes a portion of Lake Erie with water depths less than 20 feet and water depths greater than 20 feet but less than 200 feet, classifying the shallower zone of Lake Erie (i.e., water depths less than 20 feet deep) within the 15- mile TDL as shallow ocean zone or Great Lake and the deeper portion (i.e., water depths greater than 20 feet deep but less than 200 feet deep) of Lake Erie within the 15-mile TDL as moderate depth ocean zone or Great Lake (Refs. 1, Table 4-13; 9, p. 1; 10, p. 1; 18, p. 1).

For the site , the overall TDL starts at the most upstream PPEs (PPE 3 and PPE 4) and extends downstream 15 miles from PPE 1, the most downstream PPE (Ref. 9, p. 1).46



### 4 .1.2.1 Likelihood of Release

4.1.2. 1.1. Observed Release
Based on visual observation and analytical data from site visits and previous investigations conducted in association with the discharges to the on-facility ditch system, an observed release
to the Fra nk and Poet Drain is documented by direct observation. The basis for the observed release by direct observation is discussed in the following sections.

Direct Observation

–

Material containing hazardous substances seen entering surface water, or is known to have entered surface water (Ref. 1, Section 4.1.2.1.1)

Direct Observation

– So urce No. 1: The Gibraltar facility has a lagoon treatment system that includes surface impoundments used for various treatment functions prior to discharge through a common outfall pipe into an on-facility ditch that discharges into the Frank and Poet Drain (Refs

. 6, pp . 6, 7, 8, 18; 15, p. 46; 19, pp. 1, 5-20, 31). This outfall is operating under an expired NPDES permit (Ref. 6, p. 7). Majority of the ditch downstream of the outfall is perennial stream (Ref. 9, p. 1; 26, pp. 1, 2). Flowing water was observed in this drainage ditch (Ref. 19, p. 1). During the November 2013 site visit conducted by the EPA, MDEQ, and WESTON START, standing and flowing water was observed in the entire ditch system beginning with the length of ditch that receives discharge from the outfall north of Landfill B and the outfall from Water Retention Basin #4 (Ref. 19, pp. 1, 5-20, 31). Samples were collected from the outfall showed
that hazardous waste constituents were being discharged through the outfall (Refer to Table 4 of this HRS documentation record). The outfall sample locations are shown Figure 4 of this HRS documentation record package. Based on the effluent flow information for the period between April 2004 and December 2013 provided by MDEQ total flow of 43,496,190 gallons of effluent has been discharged into the ditch discharging into Frank and Poet Drain with flow rates ranging from 0-0.962 million gallons per day (Ref. 43, pp, 1-67). The samples collected from the two
outfalls show hazardous waste constituents (arsenic, cadmium, copper, cobalt, chromium, mercury, nickel, and lead) being discharged through the outfall (Refer to Table 4 of this documentation record package). The Frank and Poet Drain was listed on Michigan’s 2007 Section 303(d) list of impaired surface water bodies due to its poor macroinvertebrate47



### communities (Ref. 14, p. 2). As a result, in 2007, the EPA established a TMDL for TSS in the Frank and Poet Drain (Ref. 14, p. 4-5 ).

Direct Observation

–

Source No. 2: A portion of the Countywide landfill (approximately 43 acres) was constructed by McLouth Steel, and was known as McLouth Steel Area 4. (Refs. 34. p. 4; 41, pp. 1, 2). The waste from the CWLF was placed directly on waste from McLouth Steel, a nd therefore, CWLF was a vertical expansion on top of McLouth Steel waste (Ref. 41, p. 2). A clay cutoff dike was constructed along the perimeter of the landfill to provide lateral leachate containment (Ref. 28, p. 4). The pH as measured by pH paper for leachate produced by
McLouth Steel was te ranged from a pH of 10 to 13 (Ref. 41, p.1). The pH leachate produced by CWLF waste is around 7 (Ref. 41, p. 2).

The combined leachate (i.e., upper and lower leachate) in the northwest portion of the CWLF flows throug h a ditch into a southern end of a large pond present on the northern portion of the property (Refs. 33 pp. 22, 24; 46, pp. 8). The large pond discharges into Frank and Poet Drain from the northern portion of the pond (Ref. 33 pp. 22, 24).

During inspections by MDEQ between 1987 and 1998, the leachate from the CWLF, while operati ng as the McLouth Steel Area 4 Landfill, was seen discharging into the Frank and Poet Drain from a drainage ditch along the eastern side of the landfill (Ref. 33, pp.1, 3, 17, 22, 27; 41, pp. 1-2). Leachate was also observed to flow into the Brownstown Creek, which runs on the

western a nd southern sides of the CWLF (Ref. 33, p. 16, 22; see Figure 3 of this HRS documentation record). A 1998 Wayne County Department of Environment, Land Resource Management Division, inspection report noted the pH of leachate from the CWLF, while operating as the McLouth Steel Area 4 landfill, from active leachate discharges on the east, central area and northeast corner was measured to be between 12 and 13 (Refs. 33, p. 4; 41, pp.
1 -2 ). Leachate samples collected from the east and west side of the CWLF collected in 1996 and 2009 showed hazardous waste constituents (mercury, 1,1 dichloroethane, 2-methylnaphthalene, carbon disulfide, naphthalene, 2,4-dimethylphenol, 2-methylphenol, 3,4-methylphenol, phenol, arsenic, nickel, lead, vanadium, antimony, selenium, copper, acenaphthene, fluorene, dimethyl phthalate, phenanthrene, anthracene, 1,2,4- trimethylbenzene, cadmium, acenaphthylene,48



### fluoranthene, pyrene, strontium and bis(2ethylhexyl)phthalate) being discharged into the Frank and Poet Drain (Refer to Table 5 of this HRS documentation record package for leachate sample
results from CW LF).

Hazardous Substances Released

Source No. 1: The leachate samples collected from the treatment lagoon system show the

presence of the following hazardous substances (Table 4 of this documentation record package ):

Arsenic, ca dmium , copper, cobalt, chromium, mercury, nickel, and lead.

Sou rce No. 2: The leachate samples collected from the CWLF show presence of the following
hazardous substances (Table 5 of this HRS documentation record package):

Mercury, 1,1 dichloroethane, 2-methylnaphthalene, carbon disulfide, naphthalene, 2,4- dimethylphenol, 2 -methylphenol, 3,4-methylphenol, phenol, arsenic, nickel, lead , vanadium antimony, selenium, strontium, copper, acenaphthene, fluorene, diethyl phthalate, phenanthrene , anthracene, 1,2,4- trimethylbenzene, cadmium, acenaphthylene, fluoranthene,

pyrene , and bis(2ethylhexyl)phthalate.

Observed Release Factor Value: 550Table 6

- Human Food Chain Threat

- Toxicity/Persistence/Bioaccumulation Summary Hazardous Source/ Toxicity Persistence Toxicity/ Bioaccumulation Toxicity/ Reference Substance O.R. Persistence Factor Persistence Factor Value Bioaccumulation Value (Fresh) Factor (Table 4

- 12) Value Acenapht hene 2/ O.R. 10 0.4 4 500 2,000 Ref. 2, p. BI

- 1 Acenaphth y lene 2/ O.R. 1 0.4 0.4 500 200 Ref. 2, p. BI

- 1 Mercury 1, 2/ 10,000 1 10,000 50,000 5 8 X 10 Ref. 2, p. O.R. BI

- 7 1,1 Dichloroethane 2/ O.R. 10 0.4 4 5 20 Ref. 2, p. BI

- 4 Carbon disulfide , 2/ O.R

. 10 0.4 4 5 20 Ref. 2, p. BI

2 Naphthalene 2/ O.R. 1,000 0.4 400 50,000 2 7 X 10 Ref. 2, p. BI

7

49 

### 4.1.2 Drink ing Water Threat
Drinking water intakes are located within the 15-mile TDL (Ref. 6, pp. 9, 20). However, th is

rece ptor w as not included because it would not have a significant impact on the overall site

score.

4.1.3.2 Human Food Chain Threat

– Waste Characteristics

Th is section provides the toxicity, persistence, and bioaccumulation factor values for hazardous
substance s that are available to migrate from Site sources to surface water in the watershed via the overland/flood hazardous substances migration path for the watershed (Ref. 1, Section 4.1.3.2.1), the hazardous waste quantity value for the watershed (Ref. 1, Section 4.1.3.2.2), and the calculation of the human food chain threat-waste characteristics factor category value (Ref. 1, Section 4.1.3.2.3). The highest combined toxicity, persistence, and bioaccumulation factor is
used to deter

mine the waste characteristics factor value for the human food chain threat of the surface water migration pathway (Ref. 1, Section 4.1.3.2.1.4).

Hazardous substances that meet the criteria for an observed release to surface water (and all
hazardous substances associated with the sources that have a surface water containment factor value greater than 0 for the watershed) are presented in Table 6 of this HRS documentation record. The hazardous substance with the highest toxicity/persistence/bioaccumulation factor value for the watershed is used to assign the value to this factor (Ref. 1, Section 4.1.3.2.1.4).50 Table 6

- Human Food Chain Threat

- Toxicity/Persistence/Bioaccumulation Summary Hazardous Substance Source/

O.R. Toxicity Persistence Toxicity/ Persistence Factor Value (Table 4

- 12) Bioaccumulation

Factor Value (Fresh) Toxicity/

Persistence Bioaccumulation Factor Value Reference

2,4

- Dimethylphenol 2/ O.R. 100 1 100 500 50,000 Ref. 2, p. BI

4 Phenol 2/ O.R. 10 1 10 50 500 Ref. 2, p. BI

8 Arsenic 1, 2/ O.R. 10,000 1 10,000 5 50,000 R ef. 2, p. BI

- 1 Nickel 1, 2/ O.R. 10,000 1 10,000 5 50,000 Ref. 2, p. BI

8 Lead 1, 2/ O.R. 10,000 1 10,000 5,000 5 X 10 7 Ref. 2, p. BI

7 Vanadium 2/ O.R. 10,000 1 10,000 5 00 1 X 10 6 Ref. 2, p. BI

10 Selenium 2/ O.R. 100 1 100 50 0 5 0 ,000 Ref. 2, p. BI

9 Copper 1, 2/ O.R. 100 1 100 50,000 5 X 10 6 Ref. 2, p. BI

3 Fluorene 2/ O.R. 100 0.4 40 500 20,000 Ref. 2, p. BI

5 Phenanthrene 2/ O.R. 1 0.4 0.4 5,000 2,000 Ref. 2, BI

- 8 Anthracene 2/ O.R. 10 0.4 4 50,000 200,000 Ref. 2, p. BI

1 Cadmium 1, 2/ O.R. 10 ,000 1 10,000 50,000 5 X 10 8 Ref. 2, p. BI

2 Cobalt 1, 2/ O.R. 10,000 1 10,000 50 500,000 Ref. 2, p. BI

3 Chromium 1, 2/ O.R. 10,000 1 10,000 5 50,000 Ref. 2, p. BI

3 Strontium 2/ O.R. 1 1 1 5 5 Ref. 2, p. BI

9 2,Methylnaphthalene 2/ O.R. 1,000 0.4 400 50,000 2 X 10 7 Ref. 2, p. BI

- 7 Pyrene 2/ O.R. 100 1 100 50,000 5 X 10 6 Ref. 2, p. BI

8 Antimony 2/O.R 10,000 1 10,000 5 50,000 Ref. 2, p. BI

- 1 Cis

- 1,2

- 1 1,000 1 1,000 50 50,000 Ref. 2, p. Dichloroethylene BI

- 4 Tr ichloroeth ene 1 1,000 0.4 400 50 20,00 0 Ref. 2, p. BI

- 10 Polychlorinated 1 10,000 1 10,000 50,000 5 8 X 10 Ref. 2, p. biphenyls (PCBs) BI

- 8 Vinyl Chloride 1 10,000 0.0007 7 5 35 Ref. 2 p. BI

- 10 Diethyl phthalate 2/O.R. 1 1 1 500 500 Ref. 2, p. BI

- 4 Bis(2

- ethylhexyl) 2/O.R. 100 1 100 50,000 5 6 X 10 Ref. 2, p. phthalate BI

- 251

* Persistence values assigned are based on the Detroit River, which is the predominant water body between the PPE and the nearest fishery (Refs. 1, pp. 51612; 9, p. 1; 39, pp. 1- 2) Detroit River, which is a perennially flowing water classified as a Very Large River, and Lake Erie, which is classified as a Great Lake (depth 20 to 200 feet) (Refs. 1, Table 4-13; 16, pp. 1, 2; 18, p. 1) **Bioaccumulation factor value and persistence for freshwater O.R. – Observed Release


### The hazardous substances with the highest Toxicity/Persistence/Bioaccumulation Factor Value are mercury, PCBs and cadmium each with a value of 5 x 10 8



### .
Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000

4.1.3.2.2 Hazardous Waste Quantity

Tab le 7

- Hazardous Waste Quantity Summary Source Hazardous Waste Source Number Quantity Value (Section 2.4.2.1.5) Containment Value for Surface Water 1 86,922.38 10 2 634 .18 10
Total 87, 55 6.56



### The sum of the source hazardous waste quantity values is used to assign the Hazardous Waste Quantity Factor Value (Ref. 1, Sec. 2.4.2.2 and Table 2-6). The sum of the source hazardous waste quantity values for Surface Water Pathway, rounded to the nearest integer, is 87,557.

Sum of values: 87,557 Haz ardous Waste Quantity Factor Value: 10,000 (Ref. 1, Table 2- 6)

4.1.3.2.3 Waste Characteristics Factor Category Value


### The waste characteristics factor category value is assigned based on the Waste Characteristics Product. The Waste Characteristics Product is the product of the Toxicity/Persistence Factor Value and the Hazardous Waste Quantity Factor Value subject to a maximum of 1 x 10 8 

### . This product is multiplied by the Bioaccumulation Potential Factor Value subject to a maximum value
of 1 x 10 12 

### . The hazardous substances with the highest Toxicity/Persistence/Bioaccumulation factor values for the watershed are mercury, PCBs and cadmium (Ref. 1, Section 4.1.3.2.3, see
also Table 6 of

this HRS documentation record ).52 

### Toxicity/Persistence Factor Value: 10,000 Hazardous Waste Quantity Factor Value: 10,000
(Toxicity/Persistence x Hazardous Waste Quantity): 10,000 x 10,000 = 1 x 10 8 

### (Subject to a maximum product of 1 x 10 8 

### )
Bioaccumulation Potential Factor Value: 50,000 (Toxicity/Persistence x Hazardous Waste Quantity) x

Bioac cumulation Potential Factor Value:

(1 x 10 8 

### ) x (50,000) = 5 x 10 12 

### (Subject to a maximum product of 1 x 10 12 

### )

A Waste Characteristics Product Value of 1 x 10 12 

### receives a waste characteristics factor value of 1,000 (Ref. 1, Table 2-7).
Hazardous Waste Quantity Assigned Value: 10,000 Waste Characteristics Factor Category Value: 1,000
4.1.3.3 Human Food Chain Threat-Targets An observed release by direct observation has been documented within the surface water migration pathway (s ee section 4.1.2.1.1 of this HRS documentation record). The 15-mile TDL includes the Frank and Poet Drain, Detroit River, and Lake Erie (Ref. 9, p. 1). Sections of
Detroit River and Lake Erie, both located within the 15-mile TDL, are fisheries, and fish ar e coll ected for human consumption from these fisheries (Refs. 17, p. 2-3, 19; 20, pp. 26, 29; 21, pp. 6, 7; 36, pp. 5, 7, 12, 16, 37-40; 38, pp. 1-5; 39, pp. 1-2).

4.1.3.3.1 F ood Chain Individual There are observed releases by direct observation of hazardous substances having bioaccumulation factors of 500 or greater to the surface water in the watershed, and there is a
fisher y (or portion of fishery) present within the 15-mile TDL (Ref. 1, p. 51620; see section 4.1.2.1.1 of this HRS documentation record). Therefore, a food chain individual score of 20 is
assi gned (Ref. 1, Section 4.1.3.3.1).

Food C hain Individual Factor Value: 20 (Ref. 1, Section 4.1.3.3.1)53



### 4.1.3.3.2 Population
The Population Factor for the watershed is based on three factors: Level I concentrations, Level II concentrations, and potential human food chain contamination (Ref. 1, Section 4.1.3.3.2).

4.1.3.3.2.1 Leve l I Concentrations
The Level I concentrations factor value is not scored because there are no known fisheries subject to Level I concentrations (Ref. 1, Section 4.1.3.3.2.1).

Lev el I Concentrations: Not Scored

4.1.3.3.2.2 Level II Concentrations
The Level II concentrations factor value is not scored because there are no known fisheries subject to Level II concentrations (Ref. 1, Section 4.1.3.3.2.2).

Lev el II Concentrations: Not Scored

4.1.3.3.2.3 Potential Human Food Chain Contamination
Detroit River within the 15-Mile TDL is used for fishing (Refs. 17, pp. 2-3, 19; 20, pp. 2-29; 21, pp. 7; 31, pp. 15, 54, 62 ; 36, pp. 5 , 7, 12, 16, 19, 37-40; 38; 39). Fish from Detroit River are
harvested (Refs. 36, pp, 5, 11, 12, 16, 37-40; 39, pp. 1-2). The fishery downstream of the
confluenc e of the Frank and Poet Drain and the Detroit River is used for fishing, and some of the
fish caught are consumed by fishermen (Refs. 38, p. 1; 39, pp. 1, 2). Data to estimate pounds of fish caught annually for human consumption from Detroit River within the 15-mile TDL are not available; however, because this river is fished, the annual production for human consumption is known to be greater than zero pounds. As such, a human food chain population value of 0.03 is assigned from Table 4-18 of the HRS (Ref. 1, Table 4-18). For the Detroit River, the dilution weight was based on the average annual flow data collected by the United States Geological Survey (USGS) at a gauging station located near Detroit, MI upstream of the site (Ref. 16, pp. 1-
2 ). Based on stream flow of at least 188,766 c fs , the Detroit River at the fishery is classified as a very large river with a dilution weight 0.00001 (Refs. 1, Table 4-13; 16, p. 1).54

TABLE 8. POTENTIAL: HUMAN FOOD CHAIN CONTAMINATION Identity of Fishery Annual

Production (Pounds) Type of

Surface
Water Body

(Table
4

- 13) Average

Flow

(cfs) Population

Value (P i ) Dilution

Weight (D i ) P i x D i Reference

Detroit
River Greater than

0 Very

Large
River At least

188,766 0.03 0.00001 0.000003 Refs. 1,
Tables 4

- 13, 4

- 18; 16, p. 1; 17, p. 3; 39, pp. 1, 2



### Detroit River - Product of Pi x Di = 0.03 x 0.00001
Product of P i x Di: 0.0000003

4.1.4 Environmental Threat

Sensitive environments (i.e., wetlands) are located within the TDL (Refs. 13, 20, 21, 23).

4.1.4.2 Envir onmental Threat- Waste Characteristics
4.1.4.2.1 Ecosyste m Toxicity/Persistence/Bioaccumulation

Table 9

– Environmental Threat

- Toxicity/Persistence/Bioaccumulation Summary Hazardous Source/ Ecosystem Persistence Ecosystem Ecosystem Toxici ty/ Reference Substance O.R. Toxicity Toxicity/ Bioaccumulation Persistence Persistence Factor Bioaccumulation Factor Value Value Factor (Table 4

- 12) (Fresh) Value Acenaphthene 2/ O.R. 10,000 0.4 4,000 500 2,000 Ref. 2, p. BI

- 1 Mercury 1, 2/ 10,000 1 10,000 50,000 5 8 X 10 Ref. 2, p. O.R. BI

- 7 Carbon disulfide 2/ O.R. 100 0.4 40 5 200 Ref. 2, p. BI

- 2 Naphthale ne 2/ O.R. 1,000 0.4 400 50,000 2 7 X 10 Ref. 2, p. BI

- 755 Table 9

– Environmental Threat

- Toxicity/Persistence/Bioaccumulation Summary Hazardous Substance Source/

O.R. Ecosystem

Toxicity Persistence Ecosystem Toxicity/ Persistence Factor Value (Table 4

- 12) Ecosystem

Bioaccumulation Factor Value (Fresh) Toxici ty/

Persistence Bioaccumulation Factor Value Reference

2,4

- Dimethylphenol 2/ O.R. 100 1 100 500 50,000 Ref. 2, p. BI

- 4 Phenol 2/ O.R. 10,000 1 10,000 50,000 5 X 10 8 Ref. 2, p. BI

- 8 Arsenic 1, 2/

O.R. 10 1 10 50,000 500,000 Ref. 2, p. BI

- 1 Nickel 1, 2 /

O.R. 100 1 100 50,000 5 X 10 6 Ref. 2, p. BI

- 8 Lead 1, 2/

O.R. 1,000 1 1,000 50,000 5 X 10 7 Ref. 2, p. BI

- 7 Vanadium 2/ O.R. 100 1 100 50,000 5 X 10 6 Ref. 2, p. BI

- 10 Selenium 2/ O.R. 1,000 1 100 500 50,000 Ref. 2, p. BI

- 9 Copper 1, 2/

O.R. 1,000 1 10 0 50,000 5 X 10 6 Ref. 2, p. BI

- 3 Fluorene 2/ O.R. 1,000 0.4 400 500 200,000 Ref. 2, p. BI

- 5 Phenanthrene 2/ O.R. 10,000 0.4 4,000 5,000 2 X 10 7 Ref. 2, BI

8 Anthracene 2/ O.R. 10,000 0.4 4,000 50,000 2 X 10 8 Ref. 2, p. BI

- 1 Cadmium 1, 2/

O.R. 10,000 1 10,000 50,000 5 X 10 8 Ref. 2, p. BI

- 2 Chromium 1, 2/

O.R. 10,000 1 10,000 500 50,000 Ref. 2, p. BI

- 3 2, Methylnaphthalene 2/ O.R. 100 0.4 40 50,000 2 X 10 6 Ref. 2, p. BI

- 7 Pyrene 2/ O.R. 10,000 1 10,000 50,000 5 X 10 8 Ref. 2, p. BI

- 8 Antimony 2/O.R 10, 000 1 10,000 5 50,000 Ref. 2, p. BI

- 1
Trichloroethene 1 100 0.4 40 50 2,000 Ref. 2, p. BI

- 10 Polychlorinated 1 10,000 1 10,000 50,000 5 8 X 10 Ref. 2, p. biphenyls (PCBs) BI

- 8 Diethyl phthalate 2/O.R. 10 1 10 500 5,000 Ref. 2, p. BI

- 4 Bis(2

- ethylhexyl) 2/O.R. 1,000 1 1,000 50,000 5 7 X 10 Ref. 2, p. phthalate BI

- 2 * Persistence values assigned are based on the Detroit River, which is the predominant water body between the PPE and the nearest fishery (Refs. 1, pp. 51612 ; 9, p. 1; 39, pp. 1- 2) . The Detroit River, which is a perennially flowing water classified as a Very Large River, and Lake Erie, which is classified as a Great Lake (depth 20 to 200 feet) (Refs. 1, Table 4-13; 16, pp. 1, 2; 18, p. 1)
**Bioaccumulation factor value and persistence for freshwater O.R. – Observed Release56



### The hazardous substances with the highest Toxicity/Persistence/Bioaccumulation Factor Value are mercury, phenol, PCBs and pyrene.

Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000

4.1.4.2.2 Hazardous Waste Quantity

Table 10

- Hazardous Waste Quantity Summary Source Hazardous Waste Source Number Quantity Value (Section 2.4.2.1.5) Containment Value for Surface Water 1 86,922.38 10 2 634 .18 10
Total 87,55 6.56



### The sum of the source hazardous waste quantity values, rounded to the nearest integer, is used to assign the Hazardous Waste Quantity Factor Value (Ref. 1, Sec. 2.4.2.2 and Table 2-6).

Sum of values: 87,557 Ha zardous Waste Quantity Factor Value: 10,000 (Ref. 1, Table 2- 6)

4.1.4.2.3 Waste Characteristics Factor Category Value


### The waste characteristics factor category value is assigned based on the Waste Characteristics Product. The Waste Characteristics Product is the product of the Toxicity/Persistence Factor Value and the Hazardous Waste Quantity Factor Value subject to a maximum of 1 x 10 8 

### . This product is multiplied by the Bioaccumulation Potential Factor Value subject to a maximum value
of 1 x 10 12 

### . The hazardous substances with the highest Toxicity/Persistence/Bioaccumulation factor values for the watershed are mercury, Phenol, PCBs and pyrene each with a value of 5 x
10 8 

### (Ref. 1, Section 4.1.3.2.3, see also table 9 of this HRS documentation record).

Toxicit y/Persistence Factor Value: 10,000 Hazardous Waste Quantity Factor Value: 10,000
(Toxicity/Persistence x Hazardous Waste Quantity): 10,000 x 10,000 = 1 x 10 8 

### (Subject to a maximum product of 1 x 10 8 

### )57 

### Bioaccumulation Potential Factor Value: 50,000 (Toxicity/Persistence x Hazardous Waste Quantity) x

Bioaccumulation Potential Factor Value:

(1 x 10 8 

### ) x (50,000) = 5 x 10 12 

### (Subject to a maximum product of 1 x 10 12 

### )

A Waste Characteristics Product Value of 1 x 10 12 

### receives a waste characteristics factor value of 1,000 (Ref. 1, Table 2-7).
Hazardous Waste Quantity Assigned Value: 10,000 Wa ste Characteristics Factor Category Value: 1,000

4.1.4.3 Environmental Threat

– Targets

4 .1.4.3.1 Sensitive Environments
The Population Factor for the watershed is based on three factors: Level I concentrations, Level II concentrations, and potential contamination (Ref. 1, Section 4.1.4.3.1 ).

4.1.4.3.1.1 Level I Con centrations
The Level I concentrations factor value is not scored because there are no known environmental targets subject to Level I concentrations (Ref. 1, Section 4.1.4.3.1.1).

L evel I Concentrations: Not Scored

4.1.4.3.1.2 Level II Concentrations The Level II concentrations factor value is not scored because the observed release by direct observation does not result in an adequate length of wetland frontage for evaluation (Ref. 1,
Se ction 4.1.4.3.1.2 ).

Level II Concentrations: Not Scored

4.1. 4.3.1.3 Potential Contamination

Wetlands58



### There is wetland frontage along the Brownstown Creek and the Frank and Poet Drain (Refs. 13, p. 1; 45, pp. 1-2). Approximately 5.67 miles of HRS-eligible wetland frontage is contiguous to the Brownstown Creek and the Frank and Poet Drain and evaluated as subject to potential contamination (Ref. 45, pp. 1-2).

TABLE 11. POTENTIAL CONTAMINATION

– SENSITIVE ENVIRONMENTS Type of Surface Wate r Body Wetland Frontage Reference Wetland Value (Ref. 1, Table 4

- 24) Minimal Stream ( Brownstown Creek and Frank and Poet Drain ) 5.67 Ref. 45, pp 1

- 2 1 5 0

TOTAL 15 0

TABLE 1 2

. POTENTIAL CONTAMINATION FACTOR VALUE Type of Surface Water Body Dilution Weight

(D j ) from HRS Table 4

- 13 Sum of Sensitive

Environment Values (S j ) Wetland

Frontage Value (W j ) Potential

Contamination Factor Value ([W j + S j ]*D j ) / 10 Minimal Stream ( Brownstown Creek and Frank and Poet Drain ) 1 0 1 5 0 1 5

TOTAL 1 5



### Potential Contamination Factor Value: 1559 APPENDIX A

SOURCE-SPECIFIC SCORESHEETS
The DSC McLouth Steel Gibraltar Plant site contains two areas of waste deposition. Since there are two separate observed releases to the Frank and Poet Drain by direct observation (i.e., one from each source), source-specific scoresheets were generated in the evaluation of this site. These source-specific scoresheets, on a line by line basis, refer to the relevant page in the HRS documentation record where the values were determined and show that even if the two sources were evaluated independently, they both would qualify for listing.60

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESH EET DSC McLouth Steel Gibraltar Plant

– Source No. 1 (Treatment Lagoon System)
Factor Categories and Factors

DRINKING WATER THREAT Maximum Value Assigned

Value HRS

Documentation Record Page

Likelihood of Release 1. Observed Release 2. Potential to Release by Overland Flow: 2a. Containment 2b. Runoff 2c. Distance to Surface Water 2d. Potential to Release by Overland Flow (lines 2a[2b + 2c]) 3. Potential to Release by Flood: 3a. Containment (Flood) 3b. Flood Frequency 3c. Potential to Release by Flood (lines 3a x 3b) 4. Potential to Release (lines 2d + 3c, subject to a maximum of 500) 5. Likelihood of Release (higher of lines 1 and 4) 550

10 25 25 500

10 50 500 500

550 550

NS NS NS NS

NS NS NS NS

550 Pages 4 6

- 4 8

Waste Characteristics 6. Toxicity/Persistence 7. Hazardous Waste Quantity 8. Waste Characteristics *

* 100 NS

NS NS NS

Targets 9. Nearest Intake 10. Population 10a. Level I Concentrations 10b. Level II Concent rations 10c. Potential Contamination 10d. Population (lines 10a+10b+10c) 11. Resources 12. Targets (lines 9 + 10d + 11) 50

**

**

**

**

**

** NS

NS NS NS NS NS NS

13. DRINKING WATER THREAT SCORE 100 NS NS *

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable NS —Not Scored61

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET DSC McLouth Steel Gibraltar Plant

– Source No. 1 (Treatment Lagoon System)

Factor Categories and Factors

HUMAN FOOD CHAIN THREAT Maximum Value Assigned

Value HRS

Documentation Record Page Likelihood of Release

14. Likelihood of Release (same as line 5) 550 550 Page s 4 6

- 48

Waste Characteristics 15. Toxicity/Persistence/Bioaccumulation 16. Hazardous Was te Quantity 17. Waste Characteristics *

* 1000 5 x 10 8

10000 1000 Page s 49

- 52

Targets 18. Food Chain Individual 19. Population 19a. Level I Concentrations 19b. Level II Concentrations 19c. Potential Contamination 19d. Population (line s 19a+19b+19c) 20. Targets (lines 18 + 19d) 50
**

**

**

**

**

** 20

NS NS 0.0000003 0.0000003 20.00 00003 Pages 52

- 54

21. HUMAN FOOD CHAIN THREAT SCORE 100 100.00

*

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable NS

— Not Scored62

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET DSC McLouth Steel Gibraltar Plant

– Source No. 1 (Treatment Lagoon System)

Factor Categories and Factors

ENVIRONMENTAL THREAT 1 Maximum Value Assigned

Value HRS

D ocumentation Record Page Likelihood of Release

2. Likelihood of Release (same as line 5) 550 550 Pages 4 6

- 48

Waste Characteristics

23. Ecosystem Toxicity/Persistence/Bioaccumulation 24. Hazardous Waste Quantity 25. Waste Characteristics *

* 1000 NS

NS NS NS

Targets

26. Sensitive Environments 26a. Level I Concentrations 26b. Level II Concentrations 26c. Potential Contamination 26d. Sensitive Environments (lines 26a+26b+26c) 27. Targets **

**

**

**

** NS

NS NS NS

NS NS

28. ENVIRONMENTAL THREAT SC ORE 60 NS NS

29. WATERSHED SCORE 100 100

30. SURFACE WATER OVERLAND FLOW/FLOOD COMPONENT SCORE 100 100

*

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable 1

– The Environmental threat was not evaluated for Source No. 1, the treatment lagoon system, because these targets (wetlands) would not have a significant impact on the overall site score associated with Source No. 1. NS - Not Scored63

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESH EET

DSC McLouth Steel Gibraltar Plant

– Source No. 2 (Countywide Landfill)
Factor Categories and Factors

DRINKING WATER THREAT Maximum Value Assigned

Value HRS

Documentation Record Page

Likelihood of Release 1. Observed Release 2. Potential to R elease by Overland Flow: 2a. Containment 2b. Runoff 2c. Distance to Surface Water 2d. Potential to Release by Overland Flow (lines 2a[2b + 2c]) 3. Potential to Release by Flood: 3a. Containment (Flood) 3b. F lood Frequency 3c. Potential to Release by Flood (lines 3a x 3b) 4. Potential to Release (lines 2d + 3c, subject to a maximum of 500) 5. Likelihood of Release (higher of lines 1 and 4) 550

10 25 25 500

10 50 500 500

550 550

NS NS NS NS

NS N S NS NS

550 Pages 4 6

- 48

Waste Characteristics 6. Toxicity/Persistence 7. Hazardous Waste Quantity 8. Waste Characteristics *

* 100 NS

NS NS NS

Targets 9. Nearest Intake 10. Population 10a. Level I Concentrations 10b. Level II Concentrations 10c. Potential Contamination 10d. Population (lines 10a+10b+10c) 11. Resources 12. Targets (lines 9 + 10d + 11) 50

**

**

**

**

**

** NS

NS NS NS NS NS NS NS

13. DRINKING WATER THREAT SCORE 100 NS NS

*

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable NS —Not Scored64

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET

DSC McLouth Steel Gibraltar Plant

– Source No. 2 (Countywide Landfill)
Factor Categories and Factors

HUMAN FOOD CHAIN THREAT Maximum Value Assigned Value HRS Documentation Record Page

Likelihood of Release

14. Likelihood of Release (same as line 5) 550 550 Page s 4 6

- 48

Waste Characteristics 15. Toxicity/Persistence/Bioaccumulation 16. Hazardous Waste Quantity 17. Waste Characteristics *

* 1000 5 x 10 8

100 320 Page s 49

- 52

Targets 18. Food Chain Individual 19. Population 19a. Level I Concentrations 19b. Level II Concentrations 19c. Potential Contamination 19d. Population (lines 19a+19b+19c) 20 . Targets (lines 18 + 19d) 50
**

**

**

**

**

** 20

NS NS 0.0000003 0.0000003 20.0000003 Pages 52

- 54

21. HUMAN FOOD CHAIN THREAT SCORE 100 42.67 *

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable NS

— Not Scored65

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET DSC McLouth Steel Gibraltar Plant

– Source No. 2 (Countywide Landfill)
Factor Categories and Factors

ENVIRONMENTAL THREAT Maximum Value Assigned

Value HRS

Documentation Record Page Likelihood of Release

2. Likelihood of Release (same as line 5) 550 550 Pages 4 6

- 4 8
Waste Characteristics

23. Ecosystem Toxicity/Persistence/Bioaccumulation 24. Hazardous Waste Quantity 25. Waste Characteristics *

* 1000 5 x 10 8

100 320 Page s 5 4

- 56

Targets

26. Sensitive Environments 26a. Level I Concentrations 26b. Level II Concentrations 26c. Potential Contamination 26d. Sensitive Environments (lines 26a+26b+26c) 27. Targets **

**

**

**

** NS

NS 15 15 15 Pages 57, 58

28. ENVIRONMENTAL THREAT SCORE 60 32

29. WATERSHED SCORE 100 74.67

30. SURFACE WATER OVERLAND FLOW/FLOOD COMPONENT SCORE 100 74.67

*

-- Maximum value applies to waste characteristics category **

-- Maximum value not applicable NS - Not Scored