HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD COVER SHEET 

Name of Site: DSC McLouth Steel Gibraltar 

Plant EPA ID No.: MIN000510362

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 water 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). 
March 2015 1

HRS DOCUMENTATION RECORD

Name of Site: DSC McLouth Steel Gibraltar Plant

Date Prepared: September 2014

Date Modified: March 2015

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;

Figure 1 of this HRS documentation record)

General Location in State: Southeast portion of Michigan in the City of Gibraltar

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)

Longitude*: 83○ 12’ 01.05” West (Ref. 3, p. 1; 4, p. 1)

The 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 Scored
2

WORKSHEET FOR COMPUTING HRS SITE SCORE 

S S2

1. Groundwater Migration Pathway Score (Sgw)

(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 (Ssw)

(enter the larger of lines 2a and 2b as the pathway score) 10000 

3. Soil Exposure Pathway Score (Ss)

(from Table 5-1, line 22) NS ---

4. Air Migration Pathway Score (Sa)

(from Table 6-1, line 12) NS ---

5. Total of Sgw

2

 + Ssw 

2

+ Ss

2

+ Sa

2 10000 

6. HRS Site Score 50.00 

Divide the value on line 5 by 4 and take the square root.

Note: 

NS = Not Scored 
3

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET 

Factor Categories and 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. 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)

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 Scored 
4

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET 

Factor Categories 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

10,000

1000

Targets 

18. Food Chain Individual 50 20

19. Population

 19a. Level I Concentrations

**

** NS

 19b. Level II Concentrations ** NS

 19c. Potential Contamination ** 0.0000003

 19d. Population (lines 19a+19b+19c)

20. Targets (lines 18 + 19d)

**

**

0.0000003

20.0000003

21. HUMAN FOOD CHAIN THREAT SCORE 100 100.00

* -- Maximum value applies to waste characteristics category

** -- Maximum value not applicable

NS—Not Scored 
5

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/Bioaccumulation

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 26a+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

Feet

FILE: 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, Michigan
Marsh 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.18

FILE: D:\McLouth_Steel_Gibraltar\mxd\F2_Site_Features.mxd 8/4/2014 12:01:14 PM wojdakon
Marsh 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

Feet

FILE: 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.7
Mill 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

Feet

FILE: 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

Feet

FILE: 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

REFERENCES 

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 copy 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 TDL 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 Pollution 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 Site 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. 

12
13

29. Sample Location Map for November 16th and 17th 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 Quality 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., Countywide 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 Department of Natural Resources. Summary of Creel Survey Results 

for the St. Clair River, 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 Communications with attachment from Michael Thomas, Michigan Department of 

Natural Resources, 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 Quality, Forwarded to Omprakash Patel of Weston Solutions Inc. by 

Muniz, Nuria U.S, EPA, Subject: DSC Direct Observation. January 31, 2014. 2 pages. 

41. Affidavit from Eric. C. Anderson, County of Wayne, Michigan, Subject: McLouth Steel 

Gibraltar, Michigan. August 6, 2014. 3 pages 
14

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. Michigan 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. 
March 2015 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 Plant 

site (Site) is located at 28000 West Jefferson Avenue in Gibraltar, Wayne County, Michigan 

(Ref. 5, p. 8). The facility includes a leachate treatment lagoon system, and three landfills1 (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 mill pond (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 evaluated 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 Nos. 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). 

 1 The proposal included the mill building in the description of the facility and so it may be considered part of the 

release and NPL site. At this time, EPA and the State believe the mill building is not a concern and believe any 

possible contamination can be addressed under other programs. Consequently, EPA has removed the sentence 

concerning the mill building from the NPL proposal documentation record and is not considering the mill building 

as part of the NPL release. However, if further study does show that contamination has come to be located at the 

mill building, and that the contamination is not being adequately addressed, EPA, after consultation with the state,

may take appropriate action to include the mill in the NPL listing. For more details see the February 13, 2015 letter 

from MI and the accompanying EPA response available in the public docket on the site.
16

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 the 

treatment 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).

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 (Ref. 6, p. 8). 

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 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 record. 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 the 

drainage 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).
17

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 using the surface water migration pathway. The in-water segment includes 

the perennial segment of the ditch to which Source No. 1 drains, the Brownstown Creek and the 

Frank and Poet Drain, which flows south to its confluence with the Detroit River (Refs. 3, p. 1; 

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. 

Two 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 (Ammonia 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 

treatment 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 treatment 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, 

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

The treatment 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 

cooling 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, 

hydraulic, rolling, and slushing oils (Ref. 15, p. 7). Spent sulfuric acid contained in the Acid 
19

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 

impoundments, discharge through one outfall and contain similar hazardous substances, they are 

considered as 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 before 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. 

15, 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 lubricating, 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 not 
20

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 former 

outfalls contained hazardous waste discharging into the Frank and Poet Drain through an onfacility drainage ditch (see Table 4 of this HRS documentation record). 

Containment Factor Value: 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 

analyzed 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 constituents 
21

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. (WESTON) Superfund Technical Assessment and Response Team (START) conducted site 

assessment (SA) activities at the DSC facility (Ref. 22, p. 14). Nine waste samples were 

collected by WESTON START from the TMP, acid dosing pond, and sludge drying ponds (Ref. 

22, pp. 17). All waste samples 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-SD02-062007 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 constituents 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 constituents 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 Water Samples Collected from Source No. 1

Sample 

ID Date Location

Hazardous 

Substance MDL RL Substance Concentration Units References

MSGWWPSW-01-

14/02/11

2/14/2011

Water 

Retention 

Basin #1

(pH 

Adjustment 

Retention 

Basin)

Arsenic 0.15 1 5.2 μg/L

Ref. 7, pp. 

118, 2139, 

2148, 

2193-2195, 

2385-2388

Nickel 0.12 1 113 μg/L

Vanadium

0.18 1 3.4 μg/L

MSGWWPSW-02-

14/02/11

2/14/2011

Water 

Retention 

Basin #2

(Settling 

Pond)

Arsenic 0.15 1 4.1 μg/L

Ref. 7, pp. 

2139,

2196-2198, 

2385-2388

Nickel 0.12 1 75.5 μg/L

Strontium 0.03 5 422 μg/L

Vanadium 0.18 1 4 μg/L

MSGWWPSW-04-

14/02/11

2/14/2011

Water 

Retention 

Basin #4 

(Aeration 

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 limit 
23

Table 2: Analytical Results for the Waste Samples Collected from Source No. 1

Hazardous Substance 

Sample ID Date Location Substance RL MDL Concentration Units References

MSGWWP-SED01-14/02/11

2/14/2011

Water 

Retention 

Basin #1

(pH 

Adjustment 

Retention 

Basin)

Fluorene 1000 130 1,300 μg/kg

Ref. 7, pp. 63, 

1949, 1980, 

2080-2082, 

2116, 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

MSGWWP-SED02-14/02/11

2/14/2011 Water 

Retention 

Basin #2

(Settling 

Pond)

Antimony 2.1 0.028 2.4 mg/kg

Ref. 7, pp. 63, 

1949, 2043, 

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

MSGWWP-SED04-14/02/11

02/14/2011

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 0.10 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 limit 
24

Table 3: Analytical Results for Waste Samples Collected from the Acid Dosing Pond and Tandem Mill Ponds in 2007

Sample 

ID Date Location Depth (ft.) Hazardous Substance Substance Concentration RL Units References

DCRSDAD-01-

062007

6/20/2007

Acid 

Dosing 

Pond

0-0.5

Arsenic 70,000 1,800 μg/kg

Refs. 22, 

pp. 19, 38; 

23, p. 22; 

24, 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

Arsenic 25,000 4,000 μg/kg

Cadmium 2,500 800 μg/kg

DCRSDAD-02-

062007

6/20/2007

Acid 

Dosing 

Pond

0-0.5

Refs. 22, 

pp. 19, 38; 

23, p. 34; 

24, 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

DCRSDTMP1-

01-

062107

6/21/2007

Tandem 

Mill 

Pond #1

0-0.5

Total PCBs 21,000 780 μg/kg

Refs. 22, p. 

19, 39; 23, 

p. 16; 24, 

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 190,000 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

Refs. 22, p. 

19, 39; 23, 

p. 19-

21;24, p. 1

1,1-Dichloroethane 2,200 200 μg/kg

cis-1,2-Dichloroethene 4,400 200 μg/kg

2-Methylnaphthalene 2,000 980 μg/kg
25

Table 3: Analytical Results for Waste Samples Collected from the Acid Dosing Pond and Tandem Mill Ponds 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 560 200 μg/kg

Vinyl chloride 680 160 μg/kg

Arsenic 44,000 1,500 μg/kg

Cadmium 1,200 300 μg/kg

Refs. 22, p. 

19, 39; 23, Chromium 100,000 30,000 μg/kg

DCRSDTMP2-

01-

062107

6/21/2007

Tandem 

Mill 

Pond #2

0-0.5

p. 42; 24, 

p. 1 Copper 810,000 15,000 μg/kg

Lead 290,000 15,000 μg/kg

Selenium 630 300 μg/kg

cis-1,2-Dichloroethene 310 78 μg/kg

Refs. 22, p. 

19, 39; 23, 

p. 45-47; 

24, p. 1

2-Methylnaphthalene 440 390 μg/kg

Trichloroethene 180 78 μg/kg

1,2,3-Trimethylbenzene 99 78 μg/kg

1,2,4-Trimethylbenzene 240 78 μg/kg

DCRSDTMP3-

01-

062107

6/21/2007

Tandem 

Mill 

Pond #3

0-0.5

Arsenic 6,500 230 μg/kg

Refs. 22, p. 

19, 40; 23, 

p. 26; 24, 

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

DCRSDTMP4-

01-

6/20/2007

Tandem 

Mill 

Pond #4

0-0.5

Arsenic 6,700 140 μg/kg Refs. 22, p. 

19, 40; 23, 

p. 52; 24, 

p. 1

Cadmium 830 280 μg/kg

Chromium 20,000 2,800 μg/kg
26

Table 3: Analytical Results for Waste Samples Collected from the Acid Dosing Pond and Tandem Mill Ponds 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

DCRSDTMP4-

02-

062007

6/20/2007

Tandem 

Mill 

Pond #4

0-0.5

Arsenic 11,000 180 μg/kg

Refs. 22, p. 

19, 40; 23, 

p. 30; 24, 

p. 1

Cadmium 1,100 360 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 

Table 4: Analytical Results for the Outfall Effluent Samples Source No. 1

Hazardous Substance 

Sample ID Date Location Substance Concentration Units References

Arsenic 2.4 μg/L

Refs. 35, pp. 2, 

3, 6, 8; 40, pp.

1-2

S2-1 7/28/1993 Outfall

Cadmium 3.2 μg/L

Copper 7.6 μg/L

Nickel 9.4 μg/L

Lead 1.8 μg/L

001 9/3/1986 Outfall 001

Cobalt 2.5 μg/L

Ref. 27, pp. 3, 

7; 40, pp. 1-2, 

Chromium 7.8 μg/L

Mercury 0.0075 μg/L

Nickel 7.7 μg/L

Lead 0.34 μg/L

Notes: 

μg/kg – Micrograms per kilogram 

ID – Identification 

mg/kg – Milligrams per kilogram 
27

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 impoundments 

used 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 involved 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 4 
28

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 December 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 leachate 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 from 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). 

Mass of source in pounds: 434,961,900 

Hazardous Wastestream 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

Water Retention Basin #3 Unknown but > 0 Ref. 22, pp. 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, 3
29

Tandem Mill Pond #4 19,936 Ref. 25, pp. 1, 3

Acid Dosing Pond 33,792 Ref. 25, pp. 2, 3

Total (Square Feet) 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 hazardous waste quantity value for Area (Tier D) is 22,120 (287,560 

divided by 13) (Ref. 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: 86,922.38 
30

HAZARDOUS WASTE QUANTITY VALUE

Source No. 1 Hazardous Waste Quantity

Tier 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 22,120
31

2.2.1 Source No. 2 Identification 

Number of the source: Source No. 2 

Name 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 facility, 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 as Countywide Landfill (Refs. 41, p. 2). At this time the CWLF started accepting 

construction and demolition (C & D) waste (Refs. 41, p. 2). Soon after the CWLF began 

operations, the facility began experiencing leachate outbreaks on the side slopes (Refs. 41, p. 2). 

The leachate that percolated through the porous C & D waste would hit the dense McLouth 

waste and migrate latterly and come out the side slopes (Ref. 41, p. 2). This leachate tended to be 

clear or milky in color and had either no odor or a slight sulfur odor (Ref. 41, p. 2). The pH of 

this leachate tended to be around 7 (Ref. 41, p. 2). This leachate was very different chemically 

and physically from the McLouth Leachate, and it was reported to be pretty easy to tell the 

difference between the two types of leachate (Ref. 41, p. 2). The McLouth Steel waste leachate 

was easily identifiable, and it was red in color and had a strong phenolics smell (Ref. 41, p. 1). 

When tested with pH paper, the leachate ranged from a pH of 10 to a pH of 13 (Ref. 41, p. 1). 

In addition, by knowing where the landfill was leaking from, it could be estimated which type of 

leachate was present (Ref. 41, p. 2). If the leachate were coming out of the side slope above the 

dike/perimeter road, it was countywide or “upper leachate” (Ref. 41, p. 2). If the leachate was 
32

coming out from under the dike or through the dike, it was McLouth leachate or “lower leachate” 

(Ref. 41, p. 2). 

The combined leachate (i.e., upper and lower leachate) in the northwest portion of the CWLF 

flows through an 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 was 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 CWLF (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 CWLF, 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 

completed, and the sump locations were basically open ponds of leachate (Ref. 41, p. 3). These 

ponds were termed the east and west ponds (Ref. 41, p. 3). In reality, the east and west sumps 

and east 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 and one stand pipe on the east slope (Ref. 41, p. 3). These standpipes were 

pumped from a small tanker 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, installed 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 

(Refs. 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 upper 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). 

Responding 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 are 
34

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 consistently have 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). Periodically, 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: 

Landfill

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 appropriately covered (i.e., the source has no 

maintained engineered cover, or functioning and maintained run-on control system and runoff 
35

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 Substances

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 Location Hazardous Substance

Substance 

Concentration RL Units References

CWLFLLL111609-

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

CWLFLLL111609-

WW

11/16/2009 West Well

1,1-Dichloroethane 1.65 1

μg/L

Refs. 28, p. 

24, 25; 29, 

p. 1

2-

Methylnaphthalene 5.92 5

μg/L

Acetone 116 50

μg/L

Carbon disulfide 12.12 5

μg/L

Naphthalene 46.24 5

μg/L

2,4-Dimethylphenol 2,291 480

μg/L

2-Methylphenol 45.33 24

μg/L
36

Table 5: Analytical Results for Leachate Samples Collected from Countywide Landfill

Sample 

ID Date Location Hazardous Substance

Substance 

Concentration RL Units References

3,4-Methylphenol 799 24

μg/L

Phenol 18,970 480

μg/L

Mercury 6.52 0.5 ng/L

Arsenic 21.02 5

μg/L

Nickel 459 50

μg/L

Lead 6.39 2

μg/L

Selenium 21.32 8.5

μg/L

CWLFLLL111609-

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 μg/L

Lead 63.15 2 μg/L

CWLFLLL111609-

SP3

11/16/2009 Stand Pipe 

3

Naphthalene 4.28 24 μg/L

Refs. 28, p. 

24, 25; 29, 

p. 1

Mercury 25.15 0.5 ng/L

Arsenic 70.23 5 μg/L

Nickel 59.15 50 μg/L

Antimony 3.1 2 μg/L

Selenium 18.02 8.5 μg/L

Strontium 2,322 50 μg/L

Vanadium 126 10 μg/L

Arsenic 5.1 -- μg/L

A1LA 12/11/96 Stand Pipe Ref. 30, p. 

2 through 7 Copper 3.8 -- μg/L

Nickel 900 -- μg/L
Table 5: Analytical Results for Leachate Samples Collected from Countywide Landfill

Sample 

ID Date Location Hazardous Substance

Substance 

Concentration RL Units References

Lead 1.6 -- μg/L

Selenium 2.2 -- μg/L

Naphthalene 42 1.2 μg/L

Acenaphthene 5.4 1.2 μg/L

Fluorene 3.1 1.2 μg/L

Diethyl phthalate 8.4 1.2 μg/L

Phenanthrene 4.6 1.2 μg/L

Anthracene 2.6 1.2 μg/L

1,2,4 -

Trimethylbenzene 15 10 μg/L

A4LA 12/11/96 East Well

Arsenic 9.4 -- μg/L

Ref. 30, p. 

2, 3, 8, 9

Cadmium 0.4 -- μg/L

Copper 1.1 -- μg/L

Nickel 440 -- μg/L

Lead 4.3 -- μg/L

Selenium 3.5 --- μg/L

Naphthalene 28 1 μg/L

Acenaphthene 2.2 1 μg/L

Fluorene 1.2 1 μg/L

Phenanthrene 1.9 1 μg/L

A4LB 12/11/96 West Well

Arsenic 3.7 -- μg/L Ref. 30, p. 

2, 3, 12, 13 Cadmium 0.6 -- μg/L

37
38

Table 5: Analytical Results for Leachate Samples Collected from Countywide Landfill

Sample 

ID Date Location Hazardous Substance

Substance 

Concentration RL Units References

Copper 34 -- μg/L

Nickel 450 -- μg/L

Lead 12 -- μg/L

Acenaphthylene 4.9 1.2 μg/L

Naphthalene 3,000 120 μg/L

Acenaphthene 9.6 1.2 μg/L

Fluorene 19 1.2 μg/L

Phenanthrene 25 1.2 μg/L

Anthracene 4.6 1.2 μg/L

Fluoranthene 2.8 1.2 μg/L

Pyrene 4.4 1.2 μg/L

Bis(2-

ethylhexyl)phthalate 190 24 μg/L

CWLFLLL111609-

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 μg/L

Vanadium 31.25 10 μg/L

Selenium 7.45 8.5 μg/L

Strontium 2,525 50 μg/L

CWLFLLL111609-

SP7

11/16/2009 Stand Pipe 

7

Mercury 31.70 0.5 ng/L Refs. 28, p. 

24; 25; 29, 

Lead 3.01 2 μg/L p. 1
39

Notes:

μg/L – Micrograms per liter 

ng/L – Nanogram 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 or 
40

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. 

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

The hazardous 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 feet /3,400 = 634.18 

Area of source (ft2): 2,156,220 

Area Assigned Value: 634.18 

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

2.4.2.1.5 Calculation 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.) 

CWLF 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).

42
43

4.0 SURFACE WATER MIGRATION PATHWAY 

The surface water pathway evaluation for this Site includes the overland flow and flood 

migration 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 release 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 is (PPE 2) is where the 

ditch on the CWLF property discharges into the Frank and Poet Drain; Source No. 2 also has 

another PPE (PPE 3) in the Brownstown Creek and Source No. 2 has another PPE (PPE 4) that 

discharges 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 

Reference 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 into 
44

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 southerly 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 Creek 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 eastern border of the Site to its confluence with the Detroit River (Ref. 10, p. 1). 

The Frank 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 established 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 approximately 4.5 miles until it empties into Lake Erie (Ref. 10, p. 1). The Detroit 

River is a fishery (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 feet 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 very 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 Frank 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 – Source 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 macroinvertebrate 
47

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, and 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 waste 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 through 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 

operating 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 and 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 CWLF). 

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, cadmium, copper, cobalt, chromium, mercury, nickel, and lead.

Source 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: 550 
Table 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

Acenaphthene 2/ O.R. 10 0.4 4 500 2,000 Ref. 2, p. 

BI-1

Acenaphthylene 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. BI2

Naphthalene 2/ O.R. 1,000 0.4 400 50,000 2 7 X 10 Ref. 2, p. BI7

49

4.1.2 Drinking Water Threat 

Drinking water intakes are located within the 15-mile TDL (Ref. 6, pp. 9, 20). However, this

receptor was 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 

This section provides the toxicity, persistence, and bioaccumulation factor values for hazardous 

substances 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 determine 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. BI4

Phenol 2/ O.R. 10 1 10 50 500 Ref. 2, p. BI8

Arsenic 1, 2/ 

O.R.

10,000 1 10,000 5 50,000 Ref. 2, p. 

BI-1

Nickel 1, 2/ 

O.R.

10,000 1 10,000 5 50,000 Ref. 2, p. BI8

Lead 1, 2/ 

O.R.

10,000 1 10,000 5,000 5 X 107Ref. 2, p. BI7

Vanadium 2/ O.R. 10,000 1 10,000 500 1 X 106Ref. 2, p. BI10

Selenium 2/ O.R. 100 1 100 500 50,000 Ref. 2, p. BI9

Copper 1, 2/ 

O.R.

100 1 100 50,000 5 X 106Ref. 2, p. BI3

Fluorene 2/ O.R. 100 0.4 40 500 20,000 Ref. 2, p. BI5

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. BI1

Cadmium 1, 2/ 

O.R.

10,000 1 10,000 50,000 5 X 108Ref. 2, p. BI2

Cobalt 1, 2/ 

O.R.

10,000 1 10,000 50 500,000 Ref. 2, p. BI3

Chromium 1, 2/ 

O.R.

10,000 1 10,000 5 50,000 Ref. 2, p. BI3

Strontium 2/ O.R. 1 1 1 5 5 Ref. 2, p. BI9

2,Methylnaphthalene 2/ O.R. 1,000 0.4 400 50,000 2 X 107Ref. 2, p. 

BI-7

Pyrene 2/ O.R. 100 1 100 50,000 5 X 106Ref. 2, p. BI8

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

Trichloroethene 1 1,000 0.4 400 50 20,000 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

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-2
51

* 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 108. 

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

4.1.3.2.2 Hazardous Waste Quantity 

Table 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 87,556.56

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 

Hazardous 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 108. This 

product is multiplied by the Bioaccumulation Potential Factor Value subject to a maximum value 

of 1 x 1012. 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 108

(Subject to a maximum product of 1 x 108) 

Bioaccumulation Potential Factor Value: 50,000 

(Toxicity/Persistence x Hazardous Waste Quantity) x 

Bioaccumulation Potential Factor Value: 

(1 x 108) x (50,000) = 5 x 1012

(Subject to a maximum product of 1 x 1012) 

A Waste Characteristics Product Value of 1 x 1012 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 (see 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 are 

collected 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 Food 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 

fishery (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 

assigned (Ref. 1, Section 4.1.3.3.1). 

Food Chain 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 Level 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). 

Level 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). 

Level 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 

confluence 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 cfs, 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 (Pi)

Dilution 

Weight 

(Di)

Pi x Di 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 Pi 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 Environmental Threat- Waste Characteristics 

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation 

Table 9 – Environmental Threat - Toxicity/Persistence/Bioaccumulation Summary

Hazardous Source/ Ecosystem Persistence Ecosystem Ecosystem Toxicity/ 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

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

BI-7
55

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)

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. 10,000 1 10,000 50,000 5 X 108 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 106 Ref. 2, p. 

BI-8

Lead 1, 2/ 

O.R.

1,000 1 1,000 50,000 5 X 107 Ref. 2, p. 

BI-7

Vanadium 2/ O.R. 100 1 100 50,000 5 X 106 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 1 100 50,000 5 X 106 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 107 Ref. 2, BI8

Anthracene 2/ O.R. 10,000 0.4 4,000 50,000 2 X 108 Ref. 2, p. 

BI-1

Cadmium 1, 2/ 

O.R.

10,000 1 10,000 50,000 5 X 108 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 106 Ref. 2, p. 

BI-7

Pyrene 2/ O.R. 10,000 1 10,000 50,000 5 X 108 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 Release 
56

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 87,556.56

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 

Hazardous 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 108. This 

product is multiplied by the Bioaccumulation Potential Factor Value subject to a maximum value 

of 1 x 1012. 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 

108

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

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 108

(Subject to a maximum product of 1 x 108) 
57

Bioaccumulation Potential Factor Value: 50,000 

(Toxicity/Persistence x Hazardous Waste Quantity) x 

Bioaccumulation Potential Factor Value: 

(1 x 108) x (50,000) = 5 x 1012

(Subject to a maximum product of 1 x 1012) 

A Waste Characteristics Product Value of 1 x 1012 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

4.1.4.3 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 Concentrations 

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). 

Level 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, 

Section 4.1.4.3.1.2).

Level II Concentrations: Not Scored 

4.1.4.3.1.3 Potential Contamination 

Wetlands 
58

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 

Water 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 1-2 150

TOTAL 150 

TABLE 12. POTENTIAL CONTAMINATION FACTOR VALUE 

Type of Surface 

Water Body 

Dilution Weight 

(Dj) from HRS 

Table 4-13 

Sum of Sensitive 

Environment 

Values (Sj) 

Wetland 

Frontage Value 

(Wj) 

Potential 

Contamination 

Factor Value 

([Wj + Sj]*Dj) / 

10 

Minimal Stream

(Brownstown 

Creek and Frank 

and Poet Drain)

1 0 150 15

TOTAL 15

Potential Contamination Factor Value: 15 
59

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 SCORESHEET

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 46-48

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

13. DRINKING WATER THREAT SCORE 100 NS NS

* -- Maximum value applies to waste characteristics category 

** -- Maximum value not applicable 

NS—Not Scored 
61

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 Pages 46-48

Waste Characteristics 

15. Toxicity/Persistence/Bioaccumulation 

16. Hazardous Waste Quantity

17. Waste Characteristics

*

*

1000

 5 x 10

8

10000

1000

Pages 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 

100 100.00

* -- Maximum value applies to waste characteristics category 

** -- Maximum value not applicable

NS—Not Scored 
62

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET 

DSC McLouth Steel Gibraltar Plant – Source No. 1 (Treatment Lagoon System) 

Factor Categories and Factors

ENVIRONMENTAL THREAT1

Maximum 

Value

Assigned 

Value

HRS 

Documentation

Record Page

Likelihood of Release

2. Likelihood of Release (same as line 5) 550 550 Pages 46-48

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 SCORE 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 Scored 
63

SURFACE WATER OVERLAND FLOW/FLOOD MIGRATION COMPONENT SCORESHEET

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 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 46-48

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 Scored 
64

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 Pages 46-48

Waste Characteristics 

15. Toxicity/Persistence/Bioaccumulation 

16. Hazardous Waste Quantity

17. Waste Characteristics

*

*

1000

5 x 10

8

100

320

Pages 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 Scored 
65

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 46-48

Waste Characteristics

23. Ecosystem 

Toxicity/Persistence/Bioaccumulation

24. Hazardous Waste Quantity

25. Waste Characteristics

*

*

1000

5 x 108

100

320

Pages 54-56

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