us hl'a ruc.orus uentbr rl uion s 508980 fourth five-year ... · us hl'a ruc.orus uentbr...

US hl'A RUC.ORUS UENTbR Rl UION S

508980

FOURTH FIVE-YEAR REVIEW REPORT FOR ROTO-FINISH CO. INC. SUPERFUND SITE

KALAMAZOO COUNTY, MICHIGAN

Prepared by

U.S. Environmental Protection Agency Region 5

CHICAGO, ILLINOIS

^ Marga^t M. Guerriero, Acting Director ^ ^Superfund Division

Date

Table of Contents

LIST OF ABBREVIATIONS & ACRONYMS 2

I. INTRODUCTION 3

FIVE-YEAR REVIEW SUMMARY FORM 4

II. RESPONSE ACTION SUMMARY 5

Basis for Taking Action 5

Response Actions 5

Status of Implementation 7

Institutional Controls 7

Systems Operations/Operation & Maintenance 9

III. PROGRESS SINCE THE LAST REVIEW 9

IV. FIVE-YEAR REVIEW PROCESS 10

Community Notification, Involvement & Site Interviews 10 Data Review 10

Site Inspection 12

V. TECHNICAL ASSESSMENT 12

QUESTION A: Is the remedy functioning as intended by the decision documents? 12 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? 13 QUESTION C: Has any other infomiation come to light that could call into question the protectiveness of the remedy? 13

VI. ISSUES/RECOMMENDATIONS 13 OTHER FINDINGS 15

VII. PROTECTIVENESS STATEMENT 15

VIII.NEXT REVIEW 16

APPENDIX A - Reference List APPENDIX B - Site Chronology APPENDIX C - Location Map and Current Monitoring Well Network APPENDIX D - Institutional Control Map APPENDIX E - Historical Pfizer Pumping Rates APPENDIX F - Revised ROD Cleanup Criteria

LIST OF ABBREVIATIONS & ACRONYMS

AMEC Amec Foster Wheeler Environment & Infrastructure, Inc. ARAR Applicable or Relevant and Appropriate Requirement CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC Contaminants of concern DCA Dichloroethane DCE Dichloroethene DRC Declaration of Restrictive Covenant EE/CA Engineering Evaluation and Cost Analysis EPA United States Environmental Protection Agency FYR Five-Year Review ICs Institutional Controls ITW Illinois Tool Works MCL Maximum Contaminant Level MDEQ Michigan Department of Environmental Quality MNA Monitored Natural Attenuation NCP National Contingency Plan NPL National Priorities List NTCRA Non-Time Critical Removal Action O&M Operation and Maintenance OU Operable Unit PCE Tetrachloroethylene PMP Perfomiance Monitoring Plan PRP Potentially Responsible Party RAO Remedial Action Objectives RD/RA Remedial Design/Remedial Action RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager Site Roto-Finish Co. Inc. Superfund Site SOW Statement of Work TCA Trichloroethane TCE Trichloroethene pg/L Micrograms per Liter UU/UE Unlimited Use and Unrestricted Exposure VC Vinyl Chloride VOC Volatile Organic Compound

I. INTRODUCTION

The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

The United States Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP)(40 CFR Section 300.430(t)(4)(ii)), and considering EPA policy.

This is the fourth FYR for the Roto-Finish Co. Inc. Superfund Site (Site). The triggering action for this review is the completion date of the previous FYR. The FYR has been prepared due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure (UU/UE).

The Site consists of one Operable Unit (OU), and it addresses the groundwater remedy.

The Roto-Finish Co. Inc. Superfund Site FYR was led by Kathleen Meier, EPA Remedial Project Manager (RPM) for the Roto-Finish Site. Participants included Nan Gowda, RPM, EPA; Janet Pope, Community Involvement Coordinator, EPA; Amy Gahala, Hydrologist, United States Geological Service; Beth Mead-O'Brien, Project Manager, Michigan Department of Environmental Quality (MDEQ); and Chuck Graff, Geologist, MDEQ. The potentially responsible parties (PRPs) and MDEQ were notified of the initiation of the FYR, which began on 4/25/2016.

Site Background

The former Roto-Finish property is located at 3700 E. Milham Avenue in the northeast area of Portage, Michigan. This property covers approximately seven acres and is located about 0.2 miles west of Sprinkle Road, directly east of the Kalamazoo/Battle Creek International Airport. Several businesses are now occupying the former Roto-Finish manufacturing facility. During the FYR site visit, signs were identified for the following businesses; Relativeways, Beebe Law Group, I-Trailer (Clark Logic). The immediate Site area is zoned for industrial usage.

The Roto-Finish Company manufactured specialized equipment to debuir and polish metal castings, mechanical parts, and similar objects that required a smooth finish. Manufacturing operations at the Site began in the late 1940s to early 1950s, and continued until 1988 when the business was sold and the facilities were closed. During the time of plant operation, Roto-Finish used two systems for waste disposal. Wastes from rest rooms and laboratories were routed through a system of septic tanks, dry wells, and a tile field. Wastewater from manufacturing and testing processes was discharged to one of five on-site lagoons. These lagoons were located near the eastern edge of the plant property, along the east and north sides of the chip/compound building. These lagoons were in service until 1980. In 1980

both the municipal sanitary sewer system and municipal water supply were extended to the plant, and Roto-Finish connected to these water supply/sewerage service lines.

In 1979, MDEQ, formerly known as the Michigan Department of Natural Resources, conducted sampling of sediment and water within the wastewater lagoons. Elevated levels of heavy metals such as cadmium and chromium were detected. From 1979 to 1984, the Roto-Finish Company, under oversight from MDEQ, performed lagoon excavation, including the excavation of visibly stained surface soils. Excavated materials were taken off-site for subsequent landfill disposal. Excavated areas were backfilled with clean material. On June 10, 1986, the Site was included on the National Priorities List (NFL).

FIVE-YEAR REVIEW SUMMARY FORM

NFL Status: Final

Multiple OUs? No

Has the site achieved construction completion? Yes

REVIEW STATUS

Lead agency: EFA

Author name (Federal or State Project Manager): Kathleen Meier

Author affdiation: EFA

Review period: 6/1/2016 -4/15/2017

Date of site inspection: 6/1/2016

Type of review: Policy

Review number: 4

Triggering action date: 4/27/2012

Due date (fiveyears after triggering action date)-. 4/27/2017

II. RESPONSE ACTION SUMMARY

From 1979 to 1984, the Roto-Finish Company, under oversight from MDEQ, performed lagoon excavations ineluding the excavation of visibly stained siirfaee soils. Excavated materials were taken off-site for subsequent landfill disposal. Excavated areas were backfilled with clean material.

On June 10, 1986, the Site was included on the NPL. From 1987-1988, negotiations were conducted concerning performance of a Remedial Investigation/Feasibility Study (Rl/FS). A Consent Agreement was signed in 1988, indicating the RI/FS would be performed privately, with oversight from EPA and MDEQ. The RI/FS was conducted in three phases, from 1989-1996, and completed in October 1996.

Basis for Taking Action

The RI/FS indicated that, subsequent to completion of the source control removal action, the primary remaining threat at the Site was posed by contaminated groundwater. Hazardous substances that were released and/or found in the Site groundwater and exceeded either maximum contaminant levels (MCLs) or Michigan Part 201 Residential Drinking Water Criteria include: vinyl chloride (VC); 1,1-dichloroethene (DCE); 1,1,1- triehloroethane (TCA); trichloroethene (TCE); 1,1,2-TCA; benzene; tetrachloroethene; and chlorobenzene.

The Rl/FS did not identify any unacceptable degree of current or future cancer or non-cancer risk through exposure to Site soils. Extension of the municipal water supply into the Site vicinity means that there is no current unacceptable degree of risk to those downgradient groundwater users hooked up to the municipal supply. The RI/FS showed that unacceptable cancer risks would result based on concentrations of chemicals present in groundwater at the time, if groundwater within the area of the former Roto-Finish facility was used for drinking and showering (via dermal adsorption, inhalation, and ingestion).

Such risk was calculated to be two additional cases of cancer per every 100 individuals exposed for a potential future industrial drinking water scenario, and five additional cancer cases per 100 individuals in the case of a residential exposure scenario. The RI/FS found that ecological risks from both soil and groundwater were limited at the site. &•

Response Actions

Voluntarv Non-Time-Critical Removal Action for Groundwater In 1994, Illinois Tool Works Inc. (ITW), a potentially responsible party (PRP) for the site, conducted a voluntai7 Engineering Evaluation/Cost Analysis (EE/CA) to explore removal options that would address the highest areas of groundwater contamination at the Site. This Non-Time-Critical Removal Action (NTCRA) was intended to function until such time as the overall RI/FS could be completed, and a final site remedy selected and implemented.

The EE/CA was finished in late 1994, and EPA issued a unilateral administrative order in early 1995 calling for implementation of the voluntary NTCRA. The NTCRA consisted of the installation of two extraction wells (EW-l and EW-2) and associated piping located between Site monitoring wells MW-A1 and MW-A4 (see Appendix C). At the time, this location represented the area of highest known groundwater contamination. By mid-1995, the extraction system was installed and operating. Extracted groundwater was discharged to the Kalamazoo wastewater treatment plant.

In July 2001 the extraction system was shut down. The shutdown of the NTCRA extraction wells was intended to be temporary in order to allow the aquifer to return to a state of equilibrium so data collected during the pre-design of the 1997 remedy would be representative of long-term conditions under which the natural attenuation remedy would be performing. The extraction wells cun-ently remain in shut down mode although they are being maintained in case they need to be reactivated in the future as a contingency remedy.

Remedy Selection The Record of Decision (ROD) for the Site was signed on March 31, 1997. The remedial action objectives (RAOs) for the Site are to eliminate or minimize the threat posed to human health and the envirotiment by preventing exposure to groundwater contaminants; restore the contaminated groundwater to Federal and State applicable or relevant and appropriate requirements (ARARs), including drinking water standards, and to a level that is protective of human health and the environment within a reasonable period of time; and to control further migration of groundwater contamination beyond its cun-ent extent such that potential receptors are not unduly exposed to excessive contaminant levels.

The selected remedy includes:

• Natural attenuation (primarily via intrinsic biodegradation) to restore the contaminated aquifer to the lower of either MCL or the Michigan Act 451 Part 201 Generic Residential Drinking Water Criteria. Based on the potential for exposure to multiple contaminants in the groundwater, the cumulative risks from exposure to groundwater will also be reduced to lE-04 or less for carcinogenic risks and a hazard index of less than 1.0 for non-cancer risks.

• Institutional controls (ICs) to limit groundwater use until the aquifer is restored to cleanup levels.

• Monitoring programs to track the progress and the effectiveness of natural attenuation, and to identify any changes in land and groundwater use, and any changes in groundwater conditions.

• Maintenance of the existing groundwater extraction system in working condition so it can be implemented as a contingency remedy, if necessary, to respond to any decreases in the actual rate of biodegradation, or any unanticipated changes in site condition to the extent that the remedy is not perfonning as anticipated or is no longer protective.

• Development of contingency plans to respond to differences in the actual performance of the remedy and actual site conditions, as compared to expected perfonnance of the remedy and expected site conditions. This includes changes in land or groundwater use; differences between the predicted and actual fate and transport of groundwater contaminants and contaminant concentrations; differences between the projected and the actual rate of intrinsic biodegradation; and changes in the protectiveness of the remedy. The contingency plan may include modification of ICs, modifications to the monitoring program, and implementation of the contingency remedy, if necessary.

Remedy Implementation The Remedial Design/Remedial Action (RD/RA) is governed by the 1998 Consent Decree and Statement of Work (SOW) signed by two PRPs. From 2001 to 2006, significant field and investigative work was conducted in a series of five phases under the terms of the SOW and the RD work plan in order to gather sufficient information to complete the RD and implement the RA. This work more fully defined the dimensions of the groundwater plume and characterized contaminant concentrations.

In September 2007, EPA approved the PRPs' Performance Monitoring Plan (PMP) and other remedial design documents for groundwater monitoring of a total of thirty-three wells at the Roto-Finish Site. The PRPs installed additional monitoring wells as required in the PMP and are conducting long-term monitoring of a total of 33 groundwater wells on an annual basis. The plume core wells are monitored on a quarterly basis. The monitoring well network in the approved PMP consists of three Background wells, one Source Area well, three Plume Boundary (Cross Gradient) wells,, five Plume Core wells, eleven Performance wells, four Vertical Plume Monitoring wells, and six Sentry wells. One Background well was not installed due to access restrictions. Only two Background wells are now part of the performance monitoring network. In addition to the 32 wells in the performance monitoring network, one additional well (MW-C2B) is being sampled quarterly at the Agency's direction (see Appendix C for the map of the monitoring well network).

Status of Implementation

No other remedial implementation activities have taken place since the last FYR.

Institutional Controls

ICs are non-engineered instruments, such as administrative and/or legal controls, that help minimize the potential for exposure to groundwater contamination at the Site. Compliance with ICs is required to assure long-term protectiveness for any areas which do not allow for UU/UE.

The ROD requires ICs "to limit groundwater use until the aquifer is restored to cleanup levels." A summary of the implemented ICs for the Site is listed in the following table and the ICs are further discussed below.

Table 1: Summary of Planned and/or Implemented ICs

Media, engineered controls, and areas that do not snpport UU/UE based on

current conditions

ICs Needed

ICs Called for in the Decision

Documents

Impacted Parcel(s)

IC Objective

Title of IC Instrument Implemented and Date (or

planned)

Roto-Finish Site (Groundwater)

Yes Yes Roto-Finish Site

Prohibit the installation of drinking water wells or using existing wells as a source of drinking water

Declaration of Restrictive Covenant on the former Roto-Finish property, recorded in Kalamazoo County Recorder's Office on November 13, 1995.

Kalamazoo County Sanitary Code, Article 111 Water Supply Regulations, Chapter 13-15.

Groundwater Yes Yes Curient area Prohibit Kalamazoo County Sanitary (off-site) that e.xceeds groundwater Code, Article III Water Supply

ground use until Regulations. Chapter 13-15. water cleanup cleanup standards are standards achieved

A map showing the current ICs is included in Appendix D.

Status of Access Restrictions and ICs: ICs cuiTently in place include:

• A Declaration of Restrictive Covenant on the former Roto-Finish property, dated November 13. 1995.

• A Kalamazoo County ordinance (Kalamazoo County Sanitary Code. Article III Water Supply Regulations, 2003) that allows the department to deny the application of a water well permit or to issue a restricted use permit in a known contaminated groundwater aquifer.

The Roto-Finish Site has been identified as a Part 201 site by MDEQ. Part 201 sites are known sites of contamination in excess of state cleanup standards that are monitored by MDEQ. Also, Part 127 of State of Michigan Public Act 368, 1978 as amended requires that upon connection to a municipal water supply where a private well exists, the well must be abandoned and plugged. While most of the residents in the City of Portage are connected to the city's municipal water supply system, EPA recommends a study to inventory the private wells that are downgradient of the site and sampling of those wells until appropriate sentinel wells are relocated.

Additionally, although not an IC, the Kalamazoo/Battle Creek Intemational Airport's practice has been to prohibit the construction of water supply wells on the airport property, where most of the contaminant plume remains. The airport practice is useful as an informational control, but an enforceable IC would be preferred to ensure long-term protectiveness of the remedy.

CuiTent Compliance: Based on the Site inspection and data reviewed, EPA is not aware of Site or media uses which are inconsistent with the stated objectives to be achieved by the ICs.

IC Follow up Actions Needed: While effective ICs are in place, EPA will explore options to enhance and update the Restrictive Covenants both on and off-site.

Eons-Term Stewardship: Since compliance with ICs is necessary to ensure the protectiveness of the remedy, planning for long-temi stewardship is required to ensure that the ICs are maintained, monitored and enforced so that the remedy continues to function as intended. The PRPs should develop an amendment to the PMP that outlines procedures for inspecting and monitoring compliance with the ICs, and an annual report should be submitted to EPA to demonstrate that the Site was inspected, that no inconsistent uses have occurred, that ICs remain in place and are effective, and that any necessary contingency actions have been executed.

Systems Operations/ODeration & Maintenance

The primary activities associated with operation and maintenance (O&M) of the Site include maintenance of monitoring wells and ICs. Section 6.3 of the PMP discusses O&M of monitoring wells at the Site. Under the PMP, monitoring wells are to be inspected annually as part of sampling events. The condition of monitoring wells is to be evaluated with regards to the need for rehabilitation, redevelopment, repair and/or replacement. The inspection should include a determination of the condition of well locks, well plugs, casing, protective covers, and any damage from vehicle traffic, frost heave, or other cause. Well repairs are to be made should there be evidence of damage to the top of the well, including the riser, well cap, concrete pad, stick-up cover or well cover.

Monitoring well inspections are conducted during the annual or quarterly sampling events. Generally, well caps and locks are inspected and replaced as necessary. This FYR recommends that the PRPs evaluate the condition of the well network to ensure that: 1) the wells and the screening depth of the wells are optimally located to define and monitor the plume due to the shifting of the plume that has been noted since approximately 2007; and 2) aging wells and other wells as indicated by field parameters are tested and redeveloped as necessary.

III. PROGRESS SINCE THE LAST REVIEW

This section includes the protectiveness determinations and statements from the last FYR as well as the recommendations from the last FYR and the current status of those recommendations.

Table 2: Protectiveness Determinations/Statements from the 2012 FYR

ou# Protectiveness Determination

Protectiveness Statement

1 Short-term Protective

The remedy at the Site is protective of human health and the environment in the short-term because all immediate threats to human health and the environment have been eliminated. Exposure pathways that could result in unacceptable risks are being monitored and controlled through the annual monitoring of the long-term monitoring network at the Site. Flowever, in order for the remedy to be protective in the long-teim, additional restrictive covenants or other ICs are necessary to prohibit the use of groundwater until cleanup objectives are met. ICs must be implemented, maintained, monitored, and enforced to ensure long-term protectiveness.

Sitewide Short-term Protective

The remedy at the Site is protective of human health and the environment in the short-term because all immediate threats to human health and the environment have been eliminated. Exposure pathways that could result in unacceptable risks are being monitored and controlled through the annual monitoring of the long-term monitoring network at the Site. However, in order for the remedy to be protective in the long-teiui, additional restrictive covenants or other ICs are necessary to prohibit the use of groundwater until cleanup objectives are met. ICs must be implemented, maintained, monitored, and enforced to ensure long-term protectiveness.

Table 3: Status of Recommendations from the 2012 FYR

Issue Recommendations Current Status

Current Implementation

Status Description

Completion Date

(if applicable) 1) In order for the remedy to be protective in the long-term, effective ICs must be implemented, monitored, maintained, and enforced to assure that the remedy is functioning as intended.

While effective ICs are in place, EPA will explore options to enhance and update the Restrictive Covenants both on and off-site.

Ongoing EPA recommends a review of the options to enhance and update the Restrictive Covenants

NA

2) Continued groundwater monitoring is necessary to further evaluate the biodegradation rate and to determine if an appropriate contingency remedy is necessary.

Continue groundwater monitoring to further evaluate the biodegradation rate and to determine if a contingency remedy is necessary.

Ongoing EPA recommends a review of the monitoring network to be sure that wells are placed appropriately, updated/ redeveloped as needed, and a review of the sampling protocol.

NA

IV. FIVE-YEAR REVIEW PROCESS

Community Notification, Involvement & Site Interviews

A public notice was published in the local newspaper, the ''Kalamazoo Gazette^ on 2/27/2017, stating that there was a FYR and inviting the public to submit any comments to EPA. The results of the review and the report will be made available at the Site information repository located at the Portage Public Library, 300 Library Lane, and at http://www.epa.gov/superfund/roto-fmish.

Data Review

Although there has been a significant reduction in contaminant concentrations at the Site, a review of the data indicates degradation is slower than was originally anticipated by the ROD. It appears that at low VOC concentrations, degradation slows down. Continued groundwater monitoring at the site is necessary to determine the need for enhancements to the natural attenuation process as outlined in the contingency remedy of the PMP, section 9.0.

Groundwater at the site naturally flows toward the northwest. However, the local groundwater flow has been significantly influenced by industrial pumping by a Pfizer manufacturing facility located approximately 1.5 miles southwest of the site. Starting in approximately 2007, the observed groundwater flow direction started to shift from a westerly direction to the current northwest orientation due to a reduction in groundwater pumping by the Pfizer facility. The contaminated plume has likewise been affected by the shift in groundwater flow and therefore, it is recommended that the monitoring network

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http://www.epa.gov/superfund/roto-fmish

be analyzed for contaminant trends and degradation behavior to further determine the current flow-path of the plume. Appendix E tracks the amiual pumping rates of the Pfizer facility.

Groundwater sampling of the Performance Monitoring Wells was conducted under the protocol of the Final PMP. Major contaminants of concern (COCs) at the Site are tetrachloroethene 1.1-Dichloroethene (1,1-DCE), TCE, and VC. The data review is based on the 2015 Annual Perfonnance Monitoring Report (February 2016) and quarterly monitoring reports from December 2015 through June 2016 for the Roto-Finish Site. The data is consistent with concentrations detected over the past five years.

1. PCE was detected in only three wells with levels varying from 0.14 micrograms per liter (pg/L) to 3.8 pg/E below the ROD Cleanup criteria of 5 pg/L. Maximum PCE concentration of 3.8 pg/L was detected in MW-310 located within the Site property.

2. 1,1-DCE was detected in sixteen wells with levels varying from 0.47 pg/L to 86 pg/L. Four of the wells exceeded the cleanup criteria of 7 pg/L. Maximum 1,1-DCE concentration of 86 pg/L was detected in MW-Al located within the Site property. The four other wells with levels exceeding the cleanup criteria are MW-310 (7.5 pg/L), CMW-4 (14 pg/L), PW-3 (20 pg/L)

3. TCE was detected in eleven wells with levels varying from 0.13 pg/L to 10 pg/L. Five of the wells exceeded the cleanup criteria of 5 pg/L. Maximum TCE concentration of 10 pg/L was detected in MW-310 located within the Site property. The four other wells exceeding the cleanup criteria are MW-B5C (8.2 pg/L), CMW-1 (9.8 pg/L), CMW-2 (8.9 pg/L), and CMW-4 (5.6 pg/L).

4. VC was detected in seven of the 33 wells sampled with levels varying from 0.61 pg/L to 11 pg/L. Five of the wells exceeded the cleanup criteria of 2 pg/L. Maximum VC concentration of 11 pg/L was detected in MW-310 located within the Site property. The four other wells exceeding the cleanup criteria are MW-B5C (8.2 pg/L), MW-C2B (2.1 pg/L), CMW-1 (3.3 pg/L), and CMW-5R (4.3 pg/L).

In addition, 1,1 Dichloroethane (1,1-DCA) was detected in 25 of the 33 wells sampled with levels varying from 0.47 pg/L to 7.9 pg/L, with the exception of MW-Al with a maximum concentration of 680 pg/L below the cleanup criteria of 880 pg/L. MW-Al is located within the Site property.

A comparison of maximum concentrations of VOCs detected since 1991 indicates that the COCs have decreased significantly. Maximum groundwater concentrations of PCE at the Site have decreased from 25 pg/L to 3.8 pg/L, concentrations of TCE have decreased from 150 pg/L to 10 pg/L, concentrations of 1,1-DCE have decreased from 220pg/L to 86 pg/L, and concentrations of VC have decreased from 120pg/L to 11 pg/L from October 1991 to September 2015.

Arsenic is only sampled from one well, MW-Sl, located on the east side of the main Roto-Finish building, where it was detected with levels varying from 7.3 pg/L to 163 pg/L above its MCL of 10 pg/L. EPA recommends that arsenic samples should be taken from more wells than the cuirent sampling protocol of one well.

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Site Inspection

An inspection of the Roto-Finish Site was peifornied as part of this FYR on June 1, 2016 by Nan Gowda, EPA; Beth Mead-O'Brien, MDEQ; Chuck Graff, MDEQ; and Mike Floffman of AMEC representing ITW. The purpose of the inspection was to assess the protectiveness of the remedy, including the integrity of the wells installed at the Site. With the exception of a broken brace at the north extraction well, caps and locks for the monitoring wells were found to be in good condition and properly labeled.

The restrictive covenant that is in place on the former Roto-Finish property prohibits the drilling of water wells or using existing wells as a source of drinking water. The Kalamazoo County ordinance limits the drilling of a well in areas with known groundwater contamination. The aiiport practice has been to prohibit installation of water supply wells on the airport property. No activities were observed that would have violated these ICs.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Question A Summary: Unknown. Due to the shifting of the plume, EPA has found that the data is insufficient to make a conclusion that migration of contaminated groundwater is stabilized. Therefore, EPA cannot determine that the MNA remedy is functioning as intended.

It appears that at low VOC concentrations, degradation has slowed down and at this point, continued degradation needs to be confirmed. In addition, the groundwater tlow direction has shifted from a westerly direction to a north/northwesterly direction, making the plume core monitoring wells less effective. The performance monitoring network needs to be evaluated and updated. A detailed, robust analysis that correctly identities and, if necessary, relocates the plume core wells, is needed to accurately detemiine whether degradation is occurring at a sufficient rate. New sentinel wells are also needed to provide adequate warning of any potential contaminant migration toward downgradient private well users. Residential wells sampled in 2016 by MDEQ did not detect any contamination.

A comparison of maximum concentrations of VOCs detected since 1991 indicates that the COCs have decreased significantly. Maximum groundwater concentrations of PCE at the Site have decreased from 25 pg/L to 3.8 pg/L, concentrations of TCE have decreased from 150 pg/L to 10 pg/L, concentrations of 1,1-DCE have decreased from 220 pg/L to 86 pg/L, and concentrations of VC have decreased from 120 pg/L to 11 pg/L from October 1991 to September 2015. Several constituents continue to exceed ROD Cleanup Criteria, and because operating businesses occupy the site, EPA recommends an assessment of the potential for the vapor intrusion pathway and if needed, appropriate investigations.

A review of the ICs and the results of the Site inspection show that effective ICs are in place to restrict groundwater use. Additional controls, such as a Groundwater Restricted Zone, should be explored to enliance the existing groundwater use restrictions within all affected portions of the groundwater plume to enhance the long-term protectiveness of the remedy. EPA is not aware of anyone currently drinking contaminated groundwater.

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QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?

Question B Summary; Yes. The September 2002 FYR Report for the Roto-Finish Site indicated inaccuracies in the 1997 ROD with the MCLs for 1,1-dichloroethane (DCA) and 1,2-DCE. A memo was added to the file on May 31, 2005 to clarify these errors as well as others. The corrected ROD cleanup criteria are included in Appendix F. Although there was no MCL for 1,1-DC A at the time of the ROD, MDEQ Part 201 criteria was 880 ug/L for 1,1-DCA. Therefore, the corrected ROD cleanup criterion is 880 ug/L for 1,1 -DCA. 1,2-DCE was appropriately corrected to distinguish each isomer with a separate cleanup criterion; cis-1,2-DCE is 70 ug/L and trans- 1,2-DCE is 100 ug/L. Also, effective January 23, 2012, the MCL for arsenic changed from 50 pg/L to 10 pg/L.

QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?

No. Long-term groundwater monitoring has been ongoing. There is significant reduction in contaminant concentrations at the Site. ICs are in place that restrict groundwater use, but additional controls are needed to restrict groundwater use within all affected portions of the groundwater plume to enhance the long-term protectiveness of the remedy. EPA is not aware of anyone currently drinking contaminated groundwater. The remedy is currently protective of human health and the environment.

There have been no other changes in the physical conditions of the Site that would affect the protectiveness of the remedy. There have been no changes in the toxicity factors for the COCs that were used in the baseline risk assessment, and there have been no changes to the standardized risk assessment methodology that could affect the protectiveness of the remedy. There is no other information that calls into question the protectiveness of the remedy.

VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

Issues and Recommendations Identifled in the Five-Year Review:

OU(s): 1 Issue Category: Changed Site Conditions OU(s): 1

Issue: Although there is significant reduction in contaminant concentrations at the Site, a review of the data indicates degradation is slower than was originally predicted. It appears that at low VOC concentrations degradation slows down.

OU(s): 1

Recommendation: Continued groundwater monitoring at the site is necessary to determine the need for enhancements to the natural attenuation process as outlined in the contingency remedy part of the PMP.

Affect Current Protectiveness

Affect Future Protectiveness

Party Responsible

Oversight Party

Milestone Date

No Yes PRP EPA/State 4/24/2019

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Issue: Observed groundwater flow direction since 2007 has shifted from a more westerly direction to the current northwest orientation. The plume boundaries may not be understood given the current monitoring network.

OU(s): 1

Recommendation: Re-evaluate the monitoring needs at the Site and identify any new monitoring wells and upgrades to the monitoring program needed via an amendment to the PMP; install new monitoring wells; implement new monitoring program. To address potential downgradient receptors, a private drinking water well inventory should be conducted and private drinking water wells that are potentially downgradient of the contaminant plume should be routinely sampled.



Party Responsible

Oversight Party

Milestone Date

No Yes PR? EPA/State 4/24/2019


Issue: VOC contamination remains underground as a potential source for vapor intrusion.

OU(s): 1

Recommendation: Assess the potential for the vapor intrusion pathway and if needed, conduct appropriate investigations and remedial actions.



Party Responsible

Oversight Party

Milestone Date


OU(s): 1 Issue Category: Institutional Controls OU(s): 1

Issue: In order for the remedy to be protective in the long-term, effective ICs must be implemented, monitored, maintained, and enforced to assure that the remedy is in functioning as intended.

OU(s): 1

Recommendation: While effective ICs are currently in place, EPA will explore options to enhance and update the Restrictive Covenants both on and off-site.



Party Responsible

Oversight Party

Milestone Date


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OU(s): 1 Issue Category: Institutional Controls OU(s): 1

Issue: Long-term stewardship procedures are needed to ensure that effective ICs are monitored, maintained and enforced.

OU(s): 1

Recommendation: Modify the existing PMP to include procedures for monitoring and tracking compliance with existing ICs, communicating with EPA, and providing an annual certification to EPA that the ICs remain in place and are effective.



Party Responsible

Oversight Party

Milestone Date


OTHER FINDINGS

In order for EPA to make the detennination that the MNA remedy is working, degradation rates, monitoring well redevelopment, sampling protocol, and individual well trends and flow direction need a more robust analysis due to apparent stagnating degradation and changes in the hydraulic flow regime. Plume core wells need to be reviewed to determine if they need to be re-identified or relocated. EPA notes that the chloride equivalent method used by the PRP to assess biodegradataion rates should not be the only method used when assessing a site where the core of the plume has shifted.

EPA recommends that arsenic samples should be taken from more wells than the cuirent sampling protocol of one well, because of exceedances of the MCL. Due to association with 1,1,1 TCA and other associated contaminants that have been detected, EPA also recommends sampling for 1,4 dioxane.

VII. PROTECTIVENESS STATEMENT

OUl and Sitewide Protectiveness Statement

Protectiveness Detennination. Short-term Protective

Protectiveness Statement The remedy at the Site is cuiTently protective of human health and the environment because all immediate threats to human health and the environment have been controlled. Exposure pathways that could result in unacceptable risks are being monitored and controlled through the annual monitoring of groundwater via the long-term monitoring network at the Site. The existing restrictive covenant on the Roto-Finish property, the Kalamazoo County Ordinance, and the Kalamazoo/Battle Creek International Airport's practice of prohibiting installation of water supply wells in the aiiport property limit the use of groundwater at and downgradient from the Site. However, in order for the remedy to be protective in the long tenri, the following actions need to be taken to ensure protectiveness:

----- --• Continued groundwater monitoring at the site is necessary to detennine the need for

enhancements to the natural attenuation process as outlined in the contingency remedy part of the PMP.

15

Re-evaluate the monitoring needs at the Site and identify any new monitoring wells and upgrades to the monitoring program needed via an amendment to the PMP; install new monitoring wells; implement new monitoring program. To address potential downgradient receptors, a private drinking water well inventory should be conducted and private drinking water wells that are potentially downgradient of the contaminant plume should be routinely sampled. Assess the potential for the vapor intrusion pathway and if needed, conduct appropriate investigations and remedial actions. EPA will explore options to enhance and update the Restrictive Covenants both on and off-site to restrict groundwater use in all areas affected by the contaminated groundwater plume until groundwater restoration cleanup standards are achieved. The PMP should also be amended to outline procedures for inspecting and monitoring compliance with the ICs.

VIII. NEXT REVIEW

The next FYR report for the Roto-Finish Co. Inc. Superfund Site is required no less than five years from FPA's signature date of this review.

APPENDIX A - Reference List

Remedial Investigation/Feasibility Study Report, Limno Tech Inc. Sept. 1996. SEMS Document 155592

EPA Superfund Record of Decision, EPA, March 31, 1997. SEMS Document 145386

MDEQ Correspondence of non-concurrence of the ROD MDEQ, July 21, 1997. SEMS Document 168091

Five-Year Review EPA, Sept. 24, 2002. SEMS Document 167562

Phase II Report Pre-Design Field Studies Roto-Finish Site Portage Michigan, MACTEC, Feb. 10, 2003 SEMS Document 271465

Second Five-Year Review EPA, May 1, 2007. SEMS Document 268504

Final Performance Monitoring Plan for Remedial Action, MACTEC, Nov. 16, 2007. SEMS Document 476526

Third Five-Year Review EPA, April 27, 2012. SEMS Document 434199

2012 Annual Performance Monitoring Report, AMEC Environmental & Infrastructure, Inc., Feb. 28, 2013. SEMS Document 476532

MDEQ Correspondence: MDEQ Staff Comments on the March 23, 2012 Draft USEPA Third Five-Year Review for the Roto-Finish Superfund Site, Portage, Michigan, MDEQ, April 24, 2012. In the Appendix of the 2012 FYR

SITEWIDE READY FOR ANTICIPATED USE (SWRAU), EPA, Sept. 26, 2012. SEMS Document 442036

2013 Annual Performance Monitoring Report, Amec Foster Wheeler & Infrastructure, Inc., Jan. 17, 2013. SEMS Document 928488

2014 Annual Performance Monitoring Report, Amec Foster Wheeler & Infrastructure, Inc., Jan. 29,20B.-SEMS-Dscument 932503 » ^ ^

MDEQ Correspondence: Review of "2014 Roto-Finish Performance Monitoring Report, "from Amec Foster and Wheeler Environment and Infrastructure, Inc., dated January 29, 2015, Kalamazoo County MDEQ, April, 1 2015. SEMS Document 932509

2015 Annual Performance Monitoring Report, Amec Foster Wheeler & Infrastructure, Inc., Feb. 23, 2016. SEMS Document 928489

MDEQ Correspondence: Roto-Finish Superfund Site Upcoming Draft Fourth Five Year Review MDEQ, March 30, 2016. SEMS Document 932509

APPENDIX B - Site Chronology

Chronology of Site EventS'

Manufacturing Operations 1950- 1988

Lagoons and Visibly stained soils excavated and disposed in off-site landfill

1979-1984

Final NFL listing June 10,1986

Action Memorandum to execute Engineering Evaluation and Cost Analysis

November 1994

Unilateral Administrative Order issued to conduct non-time critical removal action.

January 1995

Remedial Investigation and Feasibility Study completed October 1996

Preliminary Close-Out Report March 31, 1997

Record of Decision signature March 31,1997

Remedial Design/Remedial Action Consent Decree July 27, 1998

Remedial Design investigation and fieldwork (five phases) 2001-2006

First Five-Year Review Report September 24,2002

Second Five-Year Review Report May 1,2007

Third Five-Year Review Report April 27,2012

SWRAU September 26,2012

Fourth Five-Year Review Report April 27, 2017

APPENDIX C - Location Map and Current Monitoring Wei! Network

PCT=OBMANCE MONROINQ NETWOFIC

^ FBFORMANre WaLS {m

A HYDfUkULC MOMTOfSNCa mss m

^ *nMP*ELL8

C OTVBHWBJLS

• RJRMS1©CTRACT10NVmJJ3 60 0 500' 1000'

SCALE: 1 INCH = 500 FEET •W-ICTB19

Institutional Control (10) Review Areas Depicting Required and Implemented Institutional Controls

Roto-Finish Co. Kalamazoo County, Ml

Superfund U.S. Environmental Protection Agency i O

EPA Region S Records Ctr.

270922 MID005340088

Legend I I Roto Finish Site Boundary Declaration of Restrictive Covenant: Access Easement (1995) - Impiemented 10*

Deciaration of Restrictive Covenant: Well Restrictions (1995) - Implemented IC* Groundwater Plume Area - Required IC

I \ I Kalamazoo Airport Policy (1997)*" j j Kalamazoo County Sanitary Code (2003) - Implemented IC"

• See the Illinois Tool Works Inc., Dedaration of Restrictive Covenant (1995), Kalamazoo County, Ml for restriction details

** See the Kalamazoo County Sanitary Code (2003), Chapter 14, for restrictions regarding well construction and permits within Kalamazoo County, Ml

•" Kalamazoo Airport Policy (1997) that restricts well construction on airport property

N

EPA Oisdaimer Ptsase IM advised thai araas dapictad In the map hava traan aatlmatad. Tha map doaa no) (vaata ary rights enfbrceabia try any patty. EPA may raflna or change this data and map at any time

G^S Created try Sarah Baclrhcusa U.S. EPA Region 5 on 3094)7

APPENDIX E - Historical Pfizer Pumping Rates

Figure 3-17. Upjohn/Pharmacia/Pfizer Historic Groundwater Pumping (1960-2015)

35

Q O

O) c •Q. E 3 Q.

5 o

Q d)

30

25

20

15

10

A '1 > •

•'

J 1971 -1995 value 3 from RI/FS Table 3-3 1£

PI 96-2015 da larmacia/Pfi

a from :er

1960-1965 withdrawal! Portage (A

Values inci > for both Up ten et al., IS

jde the com john and Gil 72)

oined y of

12

10

O) c

8'Q.C c CO

og 6= ®

c .2 < =

• 4

1960 1965 1970 1975 1980 1985 1990

Year 1995 2000 2005 2010 2015

P:\3160040119\WaterLevelData\Historicpumping.xls

APPENDIX F - Revised ROD Cleanup Criteria

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION V

DATE: May 31, 2005

SUBJECT: Rcxo-Fidish 1997 ROD Cleanup Criteria (Table 6) Coiteclions/Clarification

FROM: Katbcrinc Rodriguez RPM.RRS#4

TO: File

In Maith 1997 U.S. EPA issued a Kccord of DedsLon (ROD) which ODlltned ihe remedy sctcCtion process and selected the cleanup aciicms for the Roto-Finish site (the site) located in Kalamazoo County, Portage;, Michigan. The icmedy selected was Monitored Natuial Attenaatton (MNA). Currently the site is in the Remedial Design Stage.

The current issue is the performance slandaids for groundwaier cleanup in Table 6 of the ROD. The ROD states that Ihe performance standards are tlie lower of either Maximum CoftUcninant Levels (MO^) or Michigan Part 201 Residential Drinking Water Criteria. The source for the Federal MCLs was Code of Federal Regulations 40 Part 141; Drinking Water Regulations and Health Advisories" by U.S. EPA Office of Water, May 1995, where the Non-zero Maximum Conuminant Ijcvel Goals (MCLGs) apply when less than the MCL. The source for the Michigan criteria was MDEQ EnvironmeiUal Response Division OpetatkMnal Memoranda #8. Revision 4, and 414, Revision 2,

In the process of pre-des^n studies, MACTEC, the cunlracior for the Puicnttally Responsible Party, (Illinois Tool Works) presented in the Phase 1 Report of the Remedial Design Work Plan (April 24,2002) inaccuracies in the pcrfomiance standards for groundwater cleanup objectives documented in Ihe ROD. MACTHC proposed concctions to the crilcrta using Ihe most cunenl documcnlalion of Ihe Michigan crkeria. Opcralional MemOtmnda #IS Attachmcni A Groundwater: Residential and Indastrial-ComirKicial Part 201 Generic Cleanup Crilcria and Screen ing Levels.

The September 2002 Five-Year Review states on page 25, "The 1997 ROD inconeclly attributed an MCL to 1,1-DichluTocthane (DCA). Actually. MCL considerdtion for this compound is still under review. I1iis compnund is one of Lhnve slated for fiiilher water quality standard devdopmcnl. and in the field has been detected mote frequently than any othw VOC, Also the 1997 ROD inappropriaiely added together Ihe separate MCLs for the cisArans form of L2-DCE. rather ilum noting their individual MCLs. E>espilc these oversiglits, bask assumptions concerning exposure, toxicity and desired cleanup levels are justi6^. The agency must niHmilor developments related to any eventual MCL that may be established for I, I-DCA. HQWCVCT, at this lime, the original remedial approach is still likely to be compatible with MCL development whkh may occur for 1,1-DCA."

The pcrformartcc standards for the site were memorialized at the time of the ROD. The agencies have decided to reduce any future ccnfusion of the performance scaitdiitds by canecting Tabic 6 of the ROD using the infonnation available at the lime of the ROD, see attached Revised Roto-Froish March 1997 ROD Cleanup Criteria (Table 6) (Incorporates corrections), fn Ihe futuie, if there arc more .signihcant/fundamenial changes to the remedy, it is suggested to consider the Michigan criteria updates as was pri^osed by MACiEC in the Phase 1 Report and the MCL developments as was indicated in the Five-Year Review.

REVISED RQTO-FINISH MARCH 1997 ROO CLEANUP CRiTERIA fTABLE 6) flncorporatgs correctkyis)

Coptarninafit

3/97 ROO Steted Cleanup Critena

liasi MPEQ'^'

MACTECs Proposed

Corradions to Criteria (RD Ph I

Report) {ug/D

Actual AgerKy Cleanup Criteris at Time of ROD fuq/l)

Federal*^ MDEQ'^*

Corrfltied ROD Cleanup Criteria'"

. Ratonala

Volstllia

Acetortft None

availat>ie 730 No change Nona

availatite 730 730 No change

Bertzene S 3 No change 5 5 S No chartge

Brocnodictiloromethana ^QOW 100 No change 100^» 100 IOQW No change

Carbon Dlsulllda None

available 800 No change None

available aoo 800 No change

Chloroebenzene 100 100 No change 100 100 100 No change

Chtoroethane None

available 220 430 None

available 220 220 6/S/95 Part 201 Crilefiaj 430 ug/lia based on 6/6/00 Part 201 criteria (post 3/97 ROD)

Chloroform 100"^> 100 No change ioo'*> 100 lOO'^^ No change

Dldhlorodifluoromslhane Compound not listed

in 3/97 ROD 1700 None

available 1,700 1.700 6/5/95 Part 201 Criteria

Pago T el 9

REVJSED ROTO-FINISH MARCH 1997 ROD CLEAWUP CRfTERIA (TABLE 6) (Incorpocates correcttorwl

3^97 RCtO Stated Ctoanup Cflterls

MACTE<ri» ' P70f)OM(t

Corrections to

ActuaJ Agency Cleaixip Criteria at Time of ROD (ugfl) Corrected ROD

Contaminant PedifaF MDEQ<^ Criteria (RD Ph 1

Report) (ufl/l) FetJerai'^' MDEQ'^' Ctoanup Critarla'^^

Rationale

1,1'Dichloro« thane $ 5 6BQ Norro

availabte 6B0 aeo

ROD Incorrectly cited MCL as 5 ug/l when there was no MCL for this compound at the time of the ROD; ROO incorrectly died Part 201 crMeha as 6 ugfl wt^n it was 8^0 at the time of the ROD (SfS^S Part 201 Criteria)

1,1<Dich(orD«thana ' 7 7 No change 7 7 7 No d^nge

1,2-Dichto«'C>aU>ane 5 5 No chenge 5 S & No change

I.Z-OighlonMlhanB 170 170 fiiS'1,2'DCe 70

1ransr1^-DCE 1Q0

Cl5-1,2, OCE 70; bans-l ,2-•CE 100

cla-1.2. DCE 70; lrans-i;j-DCE 100

ds-1,2-DCE 70 tranS't,2.DCE 100

6/5/95 Part 201 Criteria; ROD rncorrectly cited total I^Z'DCE insleetl of dting the cleanup criteria for aach Isomer sepsrataJy

Ethyl Benzene 700 700 74 TOO 74 74

ROD incorrecliy cited Part 201 criteria as 700 ug/t when the aesthetic crSleria was 74 ugd al the time of the ROD {^95 Part 201 Crltsria)

4-niiBlhy1-2'penlanon& Norta

avaiiabfe 370 1,800 None

availatsiB 370 370

6/5/95 Part 201 Criteria; 1,600 ug/i a based on S/6/00 Part 201 criteria (post 3/97 ROO)

Methylene Chloride 5 5 No change 5 3 S No change

TetrecWofoethene 5 5 No change i 5 5 s No change

2 0^ 9

REVISED ROTO-FINJSH MARCH 1997 ROD CLEANUP CRITEfiJA fTABLE 6) (IncDfjJoratea cofractions)

3^7 ROD Stated Cleanup Critaria

MACTEC's Proposed

Coirectionato

Actual Agency Cleenup Criteria at Time of ROD tug/l) Cprreded ROD

Contamkiant Fftderat-'" MDEQ"' Criteria (RD Phi

Reoort) Federali'^ MDEQ»» Cleanup Ciitafia^^^

(ugrt) Rationale

Toluena 1.0QD 1.000 700 1.000 790 790

ROD incorrectly cited Part 201 criteria as 1,000 ugl! the aesthetic criterra wes 790 ugH at the time of the ROD (6/5/95 Part 201 Criteria)

1,1,1-Trfohtonjathans 200 200 No change 200 200 200 No change

1,t,2-TriclitoPO0thafw 3is> 5 5 3i6t 5 3 ROD criteria based on f^n-Zero Maximum Contamteant Level Goal

Trtchtofoetfwne 5 S No change 5 S 5 No change

Vinyl Cliforide 2 2 No diange 2 2 2 No change

Tola! Xylenas 10,000 ' 10,000 260 10.000 260 280

ROD incorrecuty cated Part 201 ciiterfa as 10.000 ug/l whan the aesthelic criteria was 260 ug/l at the time of Ihe ROD (6/5/96 Part 201 Criteria)

Samivolatiln

fidnzo(a^nthraoene Nona

availabte 1.2 2.1 Nona

BvallaWe 1.2 1.2 fi/S/95 Part 201 Criteria; 2.1 ug/! is based on 6/aOO Part 201 criteria (post 3/97 ROD l

REVfS£D ROTO-FINISH MARCH 1997 ROD CLEANUP CRfTERIA fTAELE a) flncarporalas cofmctions)

3f97 ROD Slated Cleanup Criteria

tuprt)

MACTEC's Ptoposed

CorrecHons to

Actual Agant^ Cleanup Criteria at Time of ROD (ugrt) ' Conaclod ROD

Contaminant Federal^' MDEQ^' Criteria (RD Ph 1

Report) fug/1) Fflderal'^' MDEQ^^ Cleanup Criteria'^'

' fUOil) Rationale

Bsnzci(£i)1Iuoranthen« None

avaiiabJe t.2 2 Nona

avaiable 1 12 12 6/5/95 Part 201 Criteria; 2 ug/l is based an mm Part 201 oriterta (post 3/97 ROD)

Beniorit) fluorerithare Nona

avalteble! 12 5 Nona

avBllaDia 12 1 12 6/5/95 Part 201 Criteria; S ug/i la based on 6/6/00 Part 201 crileriB (post 3/97 ROD)

Benzo{9.h.i jper>ters None 1

avîîe 26 5 None

avallatria 26 26 erS)95 Part 201 Criteria; S ug/I is tMSftri on S/6/00 Part 201 criteria (poet 3/97 ROD)

Bertzo(s}pymne 2 02 5 0.2 0.2 02 6/5/96 Part 201 Crileha; 5 ugil is based on 6/6/00 Part 201 criteria (post 3/97 ROD},

Bt$(2*athythBXYt)phlhBlBts 6 6 ^k> change S 6 6 No charge

Chrysena None

availafeia 120 5 Nona

avallatrie 120 120 6/5/95 Part 201 Critaria; 5 ug/l Is based on 6/6/00 Part 201 criteria (post 3/97 ROD)

DI-D-cctyf ptithaiata None

avallalstB 130 fte Change None

aiîtable 130 130 No change -

1,2-DlchSDrDb«nzane 600 600 No change 600 300 600 No change

Page 4 of 9

REVISED ROTO-FINISH 1997 ROD CLEANUP CRITERIA fTABLE 6) fJncorpDfates oorre<^lort«)

3/97 ROD Slat«i Cl«aaup C^rfa

(uoft)

MACTEC's Proposed

Correcttona to

Actual Agenc/ Cleanup Criteria at Time of ROD {uafll Corrected ROD

Contsrrilnant MDEQt" Criteria (RO Phi

Ratwrt) {uafl> Federai^^ MDEQ"^ Cleanup Criteria^'

fua/l} Rationale

l,4-PlchlQroberizan« 75 7S No diaage 75 75 75 No change

FluoranSherte Norve

avaiiablo sao 210 None

available 880 880 6/5/95 Part 201 Criteria; 210 ug/l i$ based on 8W00 Part 201 criteria (post 3/97 ROD]

lncleno(1,2,3-ctl)pyrene Worw

available 1.2 5 None

available 1.2 1.2 (2r 0/5/95 Pari 201 Criteria.* S Is based on 6/6/00 Part 201 criteria (post 3/97 RQOJ

Nona avallsbla ID 2BD

None avalable ID Novw avaitable

260 ugA is based on 6/6/00 Part 201 criteria (post 3/97 RODJ

4-NltrQplienQl Nona

available Nona

evaiable No charge None

available None

available None avattabla

PentacnioropheiiDl 1 1 , No change 1 1 1 No change

Phenanthrene Nona

^ available 26 52 Nona

available 25 25 6/5/95 Part 201 Criteria; 52 ug/J is based on 6/6/00 Part 201 criteria (post 3/97 ROD)

Ptienol None

avaiieble 4.400 Nophange None,

available 4.400 4^0 No cbarwse

P^ge 5 of 9

FiEVISED ftOTO'FINJSH MARCH 1 &97 ROD CLEANUP CRITERIA (TABLE 6) firtccsrporatas COfTOCtona)

3/97 ROD Slated Cteervup Cdtecia

MACTECs Propoeed

Corrections lo

Actu^ Agency Cleanup Crrtetia et Time of ROD (uoll) Corrected ROD

Conitaminiint Federal'®' MDEQP' Crltaria {RD Ph 1

Report) (ug/l) FedBrai"?' MDEQ"' Cleanup Criteria'"

Jugfl) i Rationale

Inorflanlcs

Aluminwm None

available ID 50 Norse

available 50'" 50^" Pert 201 Aesthetic Criteria

Antimony 6 6® No change 6 . giS) 6"' No chartge

Arsanlc 5(5«n SO'® No change 50'^> 50'" (OVi" No change

Barium 2,000 : 2,000^® No change 2,000 2,000'" 2.000'" No change

Calcium Norte

available < None

avaHattle No crvange None

available None

available None avallaUe

Chromium 10D 100'" No change 100 100*" 100'" No change

Cobalt Norse

evallabie 37 40 None

available 37 37 ^5/95 Part 201 Crifleriai 40 ug/l is based on 6/5/00 Part 201 crilerla (post 3/97 ROD]

Coppar t.3CW® 1,400'®^ 1,000 1.300"' 1,400'" 1.300

SfSm Part 201 Chtarie; f ,000 ug/l is ^ based on 5/0/00 Part 201 criteria {post 3«7 ROD)

Iron None

available 300"*' No change None

avellabis 300'" 300'" No dsenge

Page e of 9

REVISED ROTO-FINISH IVtARCH 1997 ROD CLEANLTP CRFTERfA fTABLE 6) fincoroorates corractiona)

3/97 ROC Cteanup

(U£

> Stated CrRftrIa m

ktACTEC's Proposed

CDirectlorvs to

Actual Agency Peanup Criteria at Time of ROD (uort) ' Corrected ROD

Contaminant Federaf'^' MOEO^ Criteria (RD Ph 1

Fteocwi) fug^/1) Federal® MDEQ^' Cleanup Crlteria''^^

(cg/l) Rstbnaie

Lead No change 15<« 4lBJ 4W No change

Magneslumi Rorie

available 420,000 400,090 Nana

available 420.000 420,000

6/5/95 Part 201 Ciiterie: 400.000 ug/i is based on 6/6/00 PartlOt criteria (pest 3/S7 ROD)

Manganosa fi/ona

available aeo 50 hfone

available 50^^ SOt*>

ROD Incorrectly cited Part 201 criteria as 669 ug/I when the aesthetic criteria was SO ug/l at the time of the ROD (6/5/95 201 Critaria}

Mercury 2 No change 2 219} 2® No <^ange

Nfck^ 190^' ; 10tf«> No dianga lOCjfl 100^1 10D® No change

Potassium Nofie

available Nptw

avaU^le No cbange Nona

available Ncne

avallabte None available

Sodium None

available 160,000 120.000 Ncma

available 160,000 160,000

fi/5/95 Part 201 CfUerta; 120,000 ugiff Is ^ based on 6/6/90 Part 201 criteria (post 3/97 ROD)

Thallium 0.5«^ 2tej 2 2l8> a5<« ROD criteria l>ased on Non-Zero Maximum Contaminant Level Goal

Page 7 of &

REVISED ROTO-FINISH MARCH 1997 ROD CLEANUP CRITERIA STABLE 6) flncorporgtes coftactlow^

3/37 ROD Ststed Cleanup Crfterfa

(ug/f)

MACTEC's Proposed

Corrections to

Actual Agency Cleanup Criteria at Time of ROD (ugfl) Corrected ROD

Contaminant Federal'^^ MDEQ<^> Ct^rta(R0Ph1

Reportl (ufl/1) Federei'^^ MDEQ^^^ Cleanup Crttaria^^'

(ug/l) Rationale

Vanadium None

avs4abie 64'"^ 4.S None

available 64^*' wW 6i/5/9fi Part 201 Criteria; 4.5 ug/l is based on 6/6/00 Part 201 criteria (post 3/97 ROD)

Zinc Mons

available No change None

available 2.400<"' 2j4W>»' No change

Cvsnide 20O 200 No chanoe 200 200 200 No change

NOTE^ Rater«oca to '6/5/3S Part 201 Ciitaria" refers to said generic residential drinlung vrater criteria listed in Op Memo S, Revlsiorr 4 dated June 5,199S as cited In ttie Manc>i 1997 ROD.

iq- Inadequate data to develop gitefian.

'Criterion fotlowed by (i®., x (y) or 12 (2)) means the corrected ROD deanup criteria m the first number (ie., 1.2) foiiovred by the Target Method Detection Limit (TMOL) pursuant to RRQ Qp Memo 2, Attachment 1,10/22/04 (i.e., 2). Claenup criteria remeina at the first niimlser {%) as modified to rneetthe ROD criteria or the ciirreint TMDL at the tfme of cleanup demonstration, whichever Is higher.

(1); in addition to achieving Maximum Conlamioant Levels and Michigan drinking water diteira, the groundwater must be restored to an aggregate risk of 1E-04 or tees for car»cer rtdrs and a hazard Index less than 1.0 fdr twcencer rieks at ait points throughout the aquifer. Performance standards for groundwater contaminants attributable to background groundwater quality condibcra wW be estabiiBhed based on the results of site-specific background proundwatsr monitoring.

(2): Sourcas; Code of Federal Regulations (CFR) 40 Part 141; "Orinking Wafer Regulalions and Health Advisories" by U.S. EPA Office of Water, May 19&5- 'Nofi'zaro Maximum Coniaminant Level Goafs fMClGB) apply when less than the MCL.

(3): Scufce: MDEQ Environmenfal Response DWswn Operattonail Memoranda *8. Revision 4, and #14, Rsvlaion 2.

Pegs a of 9

REVISED ROTQ-FINiSH MARCH 1997 ROD CLEANUP CRITERIA (TABLE 6} flr^carporates correcttona]!

Contaminart

3/87 ROD Slated Cleanup C^ena

("W) Federal'^' MOEQ'^^

MACTEC's Propoaed

Correctiena to Crlt«i2{RD Phi

Repgrtli (ug/l)

Actual Agency Cleanup Criteria at Time of ROD (ug^)

FedBfai^' MDEQ'^'

Corrected ROD Cleanup Crlterla^^'

M Rationale

<41: 1&94 propoaad ruie for diaintectants and dtalnrecllon by-products: lotel for all trihatorn>ethanes combined cannot exceed 80 upfl-

(5>: Non-2ero Vlsxlimim Contaminant Level Goal fMCLG).

<6): Site-specific background, as defined in Mlchigar> Act 461, Part 201 Rule 701(b> (, may be aubstituted if Msher than the cleanup critefia.

fT}: Under reviaw {at lhe«ma of tna 3/97 ROD >.

(6): Action letfgj {at the time of the 3/97 ROD).

(9): Being remanded (at the tfme of the 3/97 ROD).

Page 8 of9