NEGAUNEE TOWNSHIP, MARQUETTE COUNTY, MICHIGAN
The Pellestar Limited property is an abandoned industrial property located in an industrial area in Marquette County between Negaunee and Marquette, Michigan. Previous owners had used the property for research and development of pelletizing technologies and for metal recovery. After Pellestar, Ltd., closed down metal recovery operations in 1997, Marquette County took possession of the property. A private company has approached the county with an offer to purchase and redevelop the property for industrial use.
Under current conditions, elevated concentrations of lead in surface soil, unknown concentrations of contaminants in the lagoons' sediments, and site-related debris on the property could pose a public health hazard. However, there is no evidence of trespass at the site, which is currently idle, and the removal of physical hazards is expected to occur in the near future. Therefore, under current conditions, this site is categorized as "no apparent public health hazard" since exposure is not believed to be occurring.
The intended future use of the property is industrial. The site poses an indeterminate public health hazard under these future conditions. Additional investigation is needed to define the extent of lead contamination in the surface soil and to characterize the hazards posed by contaminants in the former waste lagoons.
The Michigan Department of Environmental Quality (MDEQ) has asked the Michigan Department of Community Health (MDCH) to evaluate the health risks associated with the Pellestar Limited property as part of its Brownfields Redevelopment Assessment (BFRA) of the property.
The Pellestar Limited property is located at 1201 County Road 492 in Negaunee Township, Marquette County, Michigan, east of the city of Negaunee and southwest of the city of Marquette (Figure 1). The property covers 18 acres and contains various buildings from previous industrial activities. There are four wastewater treatment lagoons on the northern part of the property (Figure 2). Lagoons 1, 2, and 3 were lined; however, lagoon 4 was unlined. There is an abandoned well on the property located near the northwest corner of the main building. Adjacent parcels are undeveloped woodlands to the north and east, and former industrial properties to the south and west (MDEQ 2001a).
In 1955, ownership of the property was transferred from the United States Steel Corporation to the Cleveland Cliffs Iron Company (CCIC). The property was vacant woodland until CCIC constructed a research and development facility for the processing and pelletizing of iron ore in the late 1950s. In early 1986, CCIC sold the property to the Michigan Technological University Fund, which established the Pellet Technology Corporation (PTC) to research and develop new pelletizing technologies. The PTC constructed a cylindrical blast furnace (called a "cupola"). In early 1993, the university sold the property to Pellestar, Ltd., who used the facilities to recover metals from used automobile airbag inflators and oil filters. In late 1997, Pellestar closed operations. In 1998, the Marquette County government foreclosed on and took possession of the property.
In 1999, the Marquette County Economic Development Corporation contracted for a two-phase Environmental Site Assessment (ESA) and a Baseline Environmental Assessment (BEA) of the property. BEAs are conducted by new property owners to document existing environmental conditions and to protect themselves from the liability for cleanup activities. Phase I of the ESA, consisting of a physical inspection and a document review, was completed in October 1999 and recommended a Phase II assessment. Fieldwork for Phase II of the ESA, including the collection of subsurface soil, sediment, and surface water samples, was conducted between November 9 and November 12, 1999. The results of the ESA were summarized in the Baseline Environment Assessment Report completed on November 29, 1999 (PCI 1999, TriMedia 1999). The results of this sampling are summarized in Tables 1 through 3 and are discussed below.
A private company has proposed to purchase and redevelop the Pellestar property for industrial use (MDEQ 2001a). Marquette County and Negaunee Township governments are planning to make the area surrounding the property into a large industrial park. It is anticipated that the Negaunee Township municipal water and sewer service will be extended to the area. It is unlikely that the on-site wastewater treatment lagoons will be used again in the future (MDEQ 2001a).
On April 19, 2001, the MDEQ visited the property to determine the type and location of areas of contamination to be sampled. In addition to the buildings and waste lagoons noted above, the MDEQ identified several areas of concern including: chromium sludge piles; waste soil piles on the south, west, and east sides of the main building; drums containing oil filters; drums in the storage building; a process grit pile adjacent to the main building; above ground storage tanks; areas of suspected underground storage tanks; and miscellaneous debris throughout the eastern area of the property.
The MDEQ conducted fieldwork for the BFRA for the Pellestar property on May 15 and 16, 2001. The fieldwork included a visual inspection of the property and collection of soil, sediment, and surface water samples (MDEQ 2001a, 2001b). The results of this sampling are summarized in Tables 1 through 4 and are discussed in the following sections. The objective of the BFRA was to identify the types and concentration of potential contaminants and to obtain information to set priorities for continued investigations.
The sampling results discussed in this consultation were taken from preliminary investigations of the property, and are not adjusted for limitations or bias in the sampling programs. The tables presented in this consultation provide concentration ranges for chemicals of concern detected in the samples collected.
Chemicals of concern for this consultation were those detected in any environmental medium sampled at the property at a concentration above the applicable MDEQ Generic Cleanup Criteria (MDEQ 2000). The MDEQ criteria are contaminant levels in environmental media that are developed to be protective of human exposure and the environment under specific land-use scenarios (i.e., residential, industrial, and commercial). These criteria are protective of frequent, long-term exposure. Therefore, contaminants at concentrations less than these conservative levels are not expected to pose a public health hazard. Concentrations that exceed these levels warrant further consideration to determine if public health hazards are likely.
The MDEQ criteria used in the present health consultation include: Soil Direct Contact Criteria (DCC), Soil Drinking Water Protection Criteria (DWPC), and the Groundwater Contact Criteria (GCC).
DCC are levels in soil that protect people from unacceptable exposure to contaminants through incidental (unintentional) ingestion of soil and dermal (skin) contact with soil. Residential DCC are protective of both adults and children who may live on the property. The industrial and commercial DCC are protective of adult on-site workers.
DWPC are levels in soil that are not expected to contaminate groundwater at levels greater than drinking water criteria. These criteria are based on models that describe how contaminants can leach from soil into groundwater that is used as a source of drinking water. These criteria are only applicable at a site if groundwater is currently used as a source of drinking water or could be used as drinking water in the future.
GCC are levels in groundwater that protect people from unacceptable exposure to contaminants through direct (skin) contact with contaminated water, which could be experienced by workers in subsurface excavations.
Environmental Contamination and Other Hazards
During the Phase II ESA in November 1999, the contractor for the Marquette County Economic Development Corporation collected 14 samples of subsurface soil to evaluate potential contaminant sources. Samples were taken from 2 feet to 20 feet below the ground surface and analyzed for Michigan 10 metals,(1) volatile organic chemicals (VOCs), semi-volatile organic chemicals (SVOCs) and/or polychlorinated biphenyls (PCBs). These data are summarized in Table 1. Analytes for each sample were selected based on the contaminants suspected for each source area. Four samples (2 feet deep) from the areas identified as the "chromium sludge" and "waste soil piles" in the southern part of the property contained chromium concentrations above the DWPC. The maximum concentrations of chromium and several other metals were in one sample taken from the waste soil pile (MDEQ 2000, TriMedia 1999).
The contractor also collected one sample each of sediment and water from lagoon 3 (Figure 2). The sediment sample was analyzed for all groups of contaminants described above. As shown in Table 2, the sediment sample contained lead, cadmium, chromium, zinc, acenaphthylene and 1,2,4-trimethylbenzene at concentrations above the MDEQ drinking water protection criteria. Lead was detected at a concentration exceeding the DCC for residential and industrial land use (MDEQ 2000, TriMedia 1999).
The lagoon water sample was analyzed for lead, VOCs, and SVOCs (Table 3). No contaminant was detected at a concentration exceeding the GCC (MDEQ 2000, TriMedia 1999).
During the BFRA fieldwork in May 2001, the MDEQ collected 20 samples of surface soil for standard chemical analysis (CLP) and subjected 65 samples of surface soil and other surface material on the property to x-ray fluorescence (XRF) analysis to determine their content of selected metals.(2) These data are presented in Table 4. Several of the surface soil samples were taken from areas of stained soil, sludge material, or from soil waste piles. A sample collected from material that had spilled from a bag marked "Monazite" in the southwest corner of the property contained arsenic at a concentration above the industrial DCC. Monazite is a mineral mixture of anhydrous phosphates of rare earth elements (cerium, lanthanum, neodymium, yttrium) and thorium. The sample was not analyzed for the constituents of monazite. A sample from a waste pile in the northwest corner of the property contained lead at a concentration above the industrial DCC. Various samples throughout the site contained concentrations of aluminum, arsenic, barium, cadmium, chromium, cobalt, iron, lead, magnesium, manganese, molybdenum, nickel, sodium, strontium, or zinc above the DWPC (MDEQ 2000, 2001b).
The MDEQ collected samples of subsurface soil from 12 borings (samples collected from 3-5 feet to 5-7 feet deep). These data are provided in Table 1. None of these samples contained any chemical at concentrations above the industrial DCC, although one sample was found to have a concentration of arsenic exceeding the residential DCC. Several samples contained concentrations of chromium, cobalt, iron, magnesium, manganese, or mercury above the DWPC (MDEQ 2000, 2001b).
The data from sediment samples taken by the MDEQ from the four lagoons (see Figure 2) on the property are shown in Table 2. The sample taken from the unlined lagoon 4 generally showed far lower contaminant concentrations than did the samples from the other lagoons (MDEQ 2001b). The top inch of lagoon 4 contained dead plant matter underlain by 6 inches of silty clay mixed with plant material. No organic contaminant was detected in the sample collected from lagoon 4, and all inorganic chemicals, except for iron, detected in that sample were at levels below the applicable MDEQ criteria.
MDEQ staff described the sediment samples from lagoons 1, 2, and 3 as composed of "black silty fine sand." A sheen was noted on the samples from lagoons 1 and 2, a "phenolic smell" on the sample from lagoon 1, and a "diesel smell" on the sample from lagoon 3. These observations indicate that organic contaminants are likely to be present in the samples. However, most of the data from the analysis of these samples are "unusable" because the analytical detection limits were elevated due to the presence of percentage levels of unidentified organic compounds (MDEQ 2001b). Some compounds were detectable even with the detection limits elevated. Samples from lagoons 1, 2, and 3, contained concentrations of acenaphthylene, aluminum, benzene, beta-hexachlorocyclohexane (beta-BHC), cadmium, chromium, cobalt, cyanide, iron, lead, manganese, 2-methylnaphthalene, naphthalene, nickel, phenanthrene, sodium, thallium, 1,2,4-trimethylbenzene, or zinc above the DWPC. The sediment samples from lagoons 1, 2, and 3 all contained lead concentrations above the industrial DCC.
The concentrations of chemicals detected in lagoon water are presented in Table 3. In general, the highest concentrations of chemicals of concern were found in lagoon 2. Lagoon 4 generally contained lower concentrations than the other three. There were no exceedances of the GCC.
The work plan for the BFRA included the construction of temporary monitoring wells in selected borings also used for collection of subsurface soil samples from the property (MDEQ 2001a). However, the on-site borings did not find groundwater above 80 feet below the surface, the limits of the equipment used by the MDEQ (MDEQ 2001b).
Several areas of concern were noted by the MDEQ during site visits including chromium sludge piles; waste soil piles on the south, west, and east sides of the main building; drums containing oil filters; drums in the storage building; a process grit pile adjacent to the main building; above ground storage tanks; areas of suspected underground storage tanks; and miscellaneous debris throughout the eastern area of the property. While the former lagoon area is surrounded by an earthen berm, the three lagoons that contain water would pose a physical hazard to trespassers or future site workers.
Human Exposure Pathways
To determine whether nearby residents are exposed to contaminants associated with a property, the Agency for Toxic Substances and Disease Registry (ATSDR) and MDCH evaluate the environmental and human components that lead to human exposure. An exposure pathway contains five major elements: 1) a source of contamination, 2) contaminant transport through an environmental medium, 3) a point of exposure, 4) a route of human exposure, and 5) an exposed population.
An exposure pathway is considered a complete pathway if there is evidence that all five of these elements are, have been, or will be present at the property. An exposure pathway is considered a potential pathway if there is no evidence that at least one of these elements are, have been, or will be present at the property. The table below lists the complete and potential pathways at the Pellestar Limited property.
Human Exposure Pathways
|Source||Environmental Transport and Media||Chemicals of Concern||Exposure Point||Exposure Route||Exposed Population||Time Frame||Status|
|Past industrial operations||Direct contact with waste, debris, drummed materials||Arsenic, lead, others unknown||On-site waste materials||incidental ingestion,
|Waste Materials, Storage Tanks, etc.||Releases to Surface soil||Table 4||On-site surface soil||incidental ingestion,
|Past Waste Disposal||Lagoon water||Table 3||On-site lagoons||incidental ingestion,
|Past Waste Disposal||Sediment||Table 2||On-site lagoons||incidental ingestion,
|Past industrial operations||Direct contact with waste, debris, drummed materials||Arsenic, lead, others unknown||On-site waste materials||incidental ingestion, dermal contact, inhalation||Workers||Past||Potential|
|Waste Materials, Storage Tanks, etc.||Releases to Surface soil||Table 4||On-site surface soil||incidental ingestion,
|Past Waste Disposal||Lagoon water||Table 3||On-site lagoons||incidental ingestion,
|Waste Materials, Storage Tanks, etc.||Releases to Subsurface soil||Table 1||On-site subsurface soil||incidental ingestion,
|Waste Materials, Storage Tanks, Contaminated Soil||Leaching to Groundwater||Table 1 - 4||On-site well||incidental ingestion,
Access to the Pellestar property is currently unrestricted. There is a gate at the main entrance to deter vehicle entry and the area immediately surrounding the property is wooded, further limiting vehicle access. There is no surrounding fence to restrict pedestrian trespass, and there is an off-road recreational vehicle (ORV) trail on the northern boundary of the property (Walczak 2001). However, no evidence of trespass (e.g., vandalism, graffiti, ORV tracks, etc.) was noted during the MDEQ site visits. Therefore, all exposure pathways for site trespassers are considered incomplete because there is no evidence to suggest that trespass is occurring on the property.
There is no information concerning past worker exposure and these pathways are therefore considered only potentially complete. All exposure pathways for on-site workers are currently incomplete since the property is idle.
The proposed future use of the property is industrial. The public may visit the site; however, exposure for on-site workers is likely to be more intense than that experienced by visitors.
It is expected that the waste materials, site debris, and waste drums currently on-site will be removed before the property is redeveloped for future use. It is possible, however, that some materials, particularly in the waste soil piles, will remain on-site or that contaminants in the waste piles could have migrated from waste to the underlying soil. Therefore, worker exposure to surface soil is considered a potentially complete pathway under the proposed future use.
Worker exposure to water and sediments in the lagoons and to subsurface soils are potentially complete under the proposed future land use. No details are currently available concerning specific future worker activities; therefore, it is difficult to predict whether workers will contact contaminants in subsurface soil and in the lagoons.
Exposure to groundwater that has been affected by contaminants leaching from soil or from waste materials is not a complete pathway currently or in the future. There is an abandoned well on the property; however no one is currently using the well. The Negaunee Township municipal water system will supply the property with drinking water in the future.
Table 4 lists the contaminants of concern detected in surface soil and waste materials at the Pellestar Limited property. Arsenic was detected above the industrial DCC in only one sample taken from material spilled from a bag labeled Monazite. Several other near-by samples contained concentrations of arsenic that were slightly greater than the residential criterion; however, the industrial criterion was not exceeded. Therefore, the single elevated sample of arsenic may be a result of the spilled Monazite rather than an indication of widespread surface soil contamination at the property.
Lead was detected at 1,980 parts per million (ppm) in one sample northwest of lagoon 1 (Figure 2). This concentration exceeds the industrial DCC of 900 ppm. The industrial lead criterion was developed based on the recommendations of the U.S. Environmental Protection Agency (EPA) and utilizes a methodology that relates soil lead concentrations to blood lead concentrations in women of child-bearing age that have site exposures (U.S. EPA 1996). The goal of this approach is to limit the risk of exceeding 10 micrograms lead per deciliter (µg/dL) of blood in the children born to exposed adult women. Children whose blood lead levels exceed this standard could incur adverse health effects including slowed mental development and lower intelligence later in childhood. The available evidence suggests that these effects will persist beyond childhood (ATSDR 1999). If adult women of childbearing age are employed as future site workers, exposure to these levels of lead in soil greater than 900 ppm could affect the health of their children.
There are no additional soil samples within 250 feet of the sample that contained an elevated concentration of lead. It cannot, therefore, be determined if this sample represents the lead concentration in the surrounding area. Lead detected in the closest samples, taken more than 250 feet away, ranged from 17.8 -326 ppm. Additional investigation is necessary to determine the extent of lead impacts in surface soil.
There were no exceedances of the industrial DCC in subsurface soil boring samples. Therefore, future workers at the site are not considered to be at risk for adverse health effects arising from exposure to subsurface soil contaminants.
The only exposure route through which on-site workers could be exposed to the lagoon water is through direct contact with the water. Concentrations of contaminants in the lagoon water were compared to the GCC and no exceedances were found. It should be noted that GCC values typically are compared to concentrations found in groundwater, not surface water. The water in the lagoons may leach into groundwater aquifers, potentially exposing workers in subsurface excavations to any contaminants originating in surface water. This pathway is not relevant; however, in cases where the depth to groundwater exceeds the depth at which utilities exist or at which subsurface work is likely to occur. The groundwater in the area was found to occur greater than 80 feet below surrounding grade (MDEQ 2001b). Therefore, the water found at the surface of the lagoon is not expected to pose a public health hazard.
Concentrations of chemicals of concern in sediment samples collected from lagoons are shown in Table 2. Only lead was detected at a concentration exceeding its industrial DCC. However, the detection limits for most analytes in lagoons 1, 2, and 3 were highly elevated due to the presence of percentage levels of unidentified organic compounds. These data suggest that lagoons 1 through 3 contain high concentrations of compounds that could pose a public health hazard to future site workers. Therefore, additional investigation is necessary to fully understand the potential risks.
ATSDR Child Health Initiative
Children may be at greater risk than adults from exposure to hazardous substances at sites of environmental contamination. They engage in activities such as playing outdoors and hand-to-mouth behaviors that may increase their intake of hazardous substances. They are shorter than most adults; therefore, they breathe dust, soil, and vapors that are closer to the ground. Their lower body weight and higher intake rate results in a greater dose of hazardous substance per unit of body weight. The developing body systems of children can sustain permanent damage if toxic exposures are high enough during critical growth stages (ATSDR 1998).
Lead has been detected in surface soil at the Pellestar property at levels exceeding MDEQ criteria for direct contact with soil. Young children, particularly the unborn and those under the age of five years, are sensitive to the neurodevelopmental effects of lead. These effects can occur at low levels of exposure and can include slowed mental development and lower intelligence later in childhood. The available evidence suggests that these effects will persist beyond childhood (ATSDR 1999). It is unlikely that small children will frequently visit the property under either current conditions or in the future if the site is redeveloped for industrial or commercial use. However, lead concentrations detected at the property could pose a risk to offspring of women working at the property in the future. Therefore, additional investigation is necessary to determine the extent of elevated concentrations of lead in surface soil.
Under current site conditions, the elevated concentrations of lead in surface soil, the unknown concentrations of contaminants in the lagoons, the lagoons themselves and the waste piles, waste drums, and other unsecured miscellaneous debris on the Pellestar property could pose a public health hazard. However, there is no evidence that people are trespassing on the property and removal of the waste materials as part of redevelopment of the property is expected to occur in the near future. Therefore, under current conditions, this site is categorized as "no apparent public health hazard" since exposure is not believed to be occurring.
The intended future use of the Pellestar property is industrial. The property poses an indeterminate public health hazard under these future conditions. Additional investigation of the high concentrations of lead found in surface soil and in the lagoon sediments is necessary to determine the extent of the area affected. Additional investigation is needed to determine if contaminants in the lagoons could pose a risk to groundwater or surrounding soil.
- Remove waste, drums, and other unsecured miscellaneous debris from the property and dispose of it in accordance with the requirements of the Michigan Natural Resources and Environmental Protection Act, 1994 PA 451, as amended.
- Take actions to limit access to the lagoons, either by fencing the area or filling the lagoons.
- Fully investigate the hydrogeology of the area to determine what, if any, effect contaminants on the property, including lagoons 1 through 3, may have on groundwater resources.
- Fully define the nature and extent of lead contamination in surface soil and implement any necessary remedial actions to prevent unacceptable exposure under the proposed future industrial use.
New environmental data or information concerning the future use of this property may require future health consultations.
The MDEQ will facilitate removal actions at the site, secure access to the lagoons, investigate the hydrogeology of the site to determine if impacts to groundwater have occurred, and further define the lead contamination detected in surface soil.
The MDCH will be available to consult on the appropriateness and efficacy of future remedial actions.
If any citizen has additional information or health concerns regarding the Pellestar Limited property, please contact the Michigan Department of Community Health, Environmental Epidemiology Division, at 1-800-648-6942.
ATSDR. 1998. Agency for Toxic Substances and Disease Registry, Division of Health Assessment and Consultation. Guidance on Including Child Health Issues in Division of Health Assessment and Consultation Documents. July 2, 1998.
ATSDR. 1999. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Lead, Update. July 1999.
MDEQ. 2000. Michigan Department of Environmental Quality. Memorandum to ERD staff, subject: Interim Environmental Response Division Operational Memorandum #18: Part 201 Generic Cleanup Criteria Tables. June 7, 2000. Available at <http://www.deq.state.mi.us/erd/>.
MDEQ. 2001a. Michigan Department of Environmental Quality. Brownfields Redevelopment Assessment Work Plan for Pellestar Limited. May 4, 2001.
MDEQ. 2001b. Michigan Department of Environmental Quality. Unpublished laboratory data. June 1, 2001.
MDNR. 1993. Howard, A., Michigan Department of Natural Resources, Environmental Response Division. Memo to staff, subject: MERA Operational Memorandum #15: Default Type A Cleanup Criteria. September 30, 1993.
PCI. 1999. Professional Consulting, Inc., for R. Osstyn. Phase I Environmental Site Assessment Report, Pellestar Limited. October 1999.
TriMedia. 1999. TriMedia Consultants, for Marquette County Economic Development Corporation. Baseline Environmental Assessment of Property Known as the Pellestar Limited. November 29, 1999.
U.S. EPA. 1996. U.S. Environmental Protection Agency, Workgroup for Lead. Recommendations of the Technical Review Workgroup for Lead for an Interim Approach to Assessing Risks Associated with Adult Exposures to Lead in Soil. December 1996.
Walczak, Joseph. MDEQ Project Manager. Personal communication September 26, 2001.
Michigan Department of Community Health
Linda Larsen, Principal Investigator
Christina Bush, Toxicologist
John Filpus, Environmental Engineer
Robin Freer, Resource Specialist
ATSDR Regional Representative
Regional Services, Region V
Office of the Assistant Administrator
ATSDR Technical Project Officer
Division of Health Assessment and Consultation
Superfund Site Assessment Branch
This Pellestar Limited Health Consultation was prepared by the Michigan Department of Community Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was begun.
Alan W. Yarbrough
Technical Project Officer, SPS, SSAB, DHAC, ATSDR
The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health consultation and concurs with the findings.
Lisa C. Hayes
for Chief, State Program Section, SSAB, DHAC, ATSDR
1. Including arsenic, barium, cadmium, chromium, copper, lead, mercury, selenium, silver, and zinc.
2. Antimony, arsenic, barium, cadmium, cesium, chromium, cobalt, copper, iron, lanthanum, lead, manganese, mercury, molybdenum, nickel, palladium, rubidium, selenium, silver, strontium, tellurium, tin, zinc, and zirconium.