five-year review report third five-year review report

u s EPA RECORDS CENTER REGION 5

434199

Five-Year Review Report

Third Five-Year Review Report for

Roto-Finish Co. Inc. Site Portage, Michigan Kalamazoo County

April 2012

PREPARED BY:

U. S. Environmental Protection Agency Region 5

Superfund Division 77 West Jackson Boulevard

Chicago, Illinois 60604

Approved by: Date:

Richard C. Karl, Director Superfund Division U.S. EPA Region V

Third Five-Year Review Report

Table of Contents

List of Acronyms Executive Summary Five-Year Review Summary Forms

I. Introduction I II. Site Chronology 2 III. Background 2

A. Physical Characteristics 2 B. Land and Resource Use 2 C. Contamination History 3 D. Initial Response 3 E. Basis for Taking Action 4

rV. Removal and Remedial Actions 4 A. Voluntary Non-Time-Critical Removal Action (NTCRA) for Groundwater 4 B. Remedy Selection 5 C. Remedy Implementation 6 D. Institutional Controls 6 E. Operation and Maintenance 7

V. Progress since the Last Review 8 VI. Five-Year Review Process 9

A. Administrative Components 9 B. Community Involvement 9 C. Document Review 9 D. Data Review 10 E. Site Inspection 11

VII. Technical Assessment 11 Vin. Issues 13 IX. Recommendations and Follow-up Actions 13 X. Protectiveness Statement 13 XI. Next Review 13

Attachments

Attachment 1 Roto-Finish Site Location Map and Current Monitoring Well Network Attachment 2 Roto-Finish Extent of Total VOCs Groundwater Plume Map Attachment 3 ROD Cleanup Criteria Attachment 4 Support Agency Comments

List of Acronyms

AMEC AMEC Environment & Infrastructure, Inc. ARAR Applicable or Relevant and Appropriate Requirement CD Consent Decree CERCLA Comprehensive Environmental Response Compensation and Liability Act CFR Code of Federal Regulations CMW Core Monitoring Well DCA Dichloroethane DCE Dichloroethene DRC Declaration of Restrictive Covenant and Grant of Environmental Protection

Easement EE/CA Engineering Evaluation and Cost Analysis EW Extraction Well ICs Institutional Controls ITW Illinois Tool Works KCHCSD Kalamazoo County Health and Commimity Services Department MCL Maximum Contaminant Level MDEQ Michigan Department of Environmental Quality MNA Monitored Natural Attenuation MW Monitoring Well NCP National Contingency Plan NPL National Priorities List NTCRA Non-Time Critical Removal Action O&M Operation and Maintenance POOR Preliminary Closeout Report PRP Potentially Responsible Party RA Remedial Action RAO Remedial Action Objective RD Remedial Design Rl/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager SOW Statement of Work TCA Trichloroethane TCE Trichloroethene U.S. EPA United States Environmental Protection Agency UU/UE Unlimited Use and Unrestricted Exposure VAS Vertical Aquifer Sampling VC Vinyl Chloride VOC Volatile Organic Compound VP Vertical Profile

Executive Summary

The United States Environmental Protection Agency (U.S. EPA), Region 5, conducted the five-year review of the remedy being implemented at the Roto-Finish Co., Inc., Superfund Site (the Site) in Portage, Michigan. This is the third five-year review for the Site. The five-year review is required due to the fact that the goals of unlimited use and unrestricted exposure at the Site are not likely to be achieved within a five-year timeframe.

The 1997 Record of Decision (ROD) selected monitored natural attenuation (MNA) as the remedy for the plume of contaminated groundwater associated with the Site. A Preliminary Close-Out Report was also issued along with the 1997 ROD.

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-term, restrictive covenants are necessary to prohibit the use of groundwater until cleanup objectives are met. Institutional controls must be implemented, maintained, monitored, and enforced to ensure long-term protectiveness.

Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name:

EPA ID:

Region: 5

Roto-Finish Co. Inc.

MID005340088

State: MI City/County: Portage/Kalamazoo

NPL Status: Final

SITE STATUS

Multiple OUs? No

Has the site achieved construction completion? Yes

Lead agency: U.S. EPA

REVIEW STATUS

Author name (Federal or State Project Manager): Nan Gowda

Author affiliation: U.S. EPA

Review period: December 2011 - April 2012

Date of site inspection: December 6, 2012

Type of review: Policy

Review number: 3

Triggering action date: May 1, 2007

Due date (fiveyears after triggering action date): May 1, 2012

Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

None

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 1

Affect Current Protectiveness

No

Issue Category: Institutional Controls

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

Recommendation: Complete and record DRCs for the Roto-Finish site to prohibit the use of contaminated groundwater at the Site.

Affect Future Protectiveness

Yes

Implementing Party

PRP

Oversight Party

EPA

Milestone Date

June 2013

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 1

Affect Current Protectiveness

No

Issue Category: Remedy Performance

Issue: Continued groundwater monitoring is necessary to fiarther evaluate the biodegradation rate and to determine if an appropriate contingency remedy is necessary.

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

Affect Future Protectiveness

Yes

Implementing Party

PRP

Oversight Party

EPA

Milestone Date

March 2013

Five-Year Review Summary Form (continued)

Operable Unit: 1

Protectiveness Statement(s)

Protectiveness Determination: Short-term Protective

Protectiveness Statement: The remedy at the Site is protective of human health and the enviromnent 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-term, 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 Protectiveness Statement (if applicable)

Site-wide Protectiveness Determination: Short-term Protective

Protectiveness Statement: The remedy at the Site is protective of human health and the envirorunent 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-term, 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.

Roto-Finish Co. Inc. Site Portage, Kalamazoo County, Michigan

Third Five-Year Review Report

I. Introduction

The purpose of the five-year review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify deficiencies found during the review, if any, and identify recommendations to address them.

The United States Environmental Protection Agency (U.S. EPA) has prepared this Third Five-Year Review report pursuant to CERCLA § 121 and the National Contingency Plan (NCP). CERCLA § 121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with Section 104 or 106, the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

The U.S. EPA interpreted this requirement fiirther in the NCP; 40 CFR §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above such levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.

U.S. EPA conducted the five-year review of the remedy implemented at the Roto-Finish Co., Inc., Superfund Site (the Site) in Portage, Michigan. This review was conducted by Nan Gowda, Remedial Project Manager (RPM) for the entire Site fi-om December 2011 through April 2012. This report documents the results of the review.

This is the third five-year review for the Roto-Finish Site. The first and second five-year reviews were completed on September 24, 2002 and May 1, 2007, respectively. The triggering action for this policy review was the signature date of the second five-year review report signed on May 1, 2007. The five-year review is required due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and unlimited exposure (UU/UE) for more than five years after construction is complete at the site.

II. Site Chronology

Chronology of Site Events Event

Manufacturing Operations Lagoons and Visibly stained soils excavated and disposed in off-site landfill Listed on the NPL as Final Action Memorandum to execute Engineering Evaluation and Cost Analysis Unilateral Administrative Order issued to conduct non-time critical removal action. Remedial Investigation and Feasibility Study completed Preliminary Close-Out Report Record of Decision signed First Five-Year Review Report Second Five-Year Review Report

Date 1950-1988

1979-1984 June 10, 1986

November 1994

January 1995 October 1996 March 31, 1997 March 31, 1997 September 24, 2002 May 1,2007

III. Background

A. Physical Characteristics

The former Roto-Finish property (Attachment 1) is located at 3700 E. Milham Avenue in the northeast area of Portage, Michigan. This property covers approximately 7 acres and is located about 0.2 miles west of Sprinkle Road, directly east of the Kalamazoo/Battle Creek International Airport. Attachment 2 depicts the Site's total volatile organic compound (VOC) groundwater plume as identified during the December 2005 monitoring event. The Site (the former Roto-Finish property and its associated groundwater plume) are currently estimated to cover 115 acres. Rivers and creeks near the Site include Olmstead Drain/Davis Creek, located approximately 0.75 miles northeast of the Site, and Portage creek located about 2 miles northwest of the Site.

Site ground surface relief is generally flat, with elevation variations mostly less than 10 feet across the Site. Geology near the Site is primarily characterized by thick deposits of glacial outwash materials consisting of stratified sands, silts, and gravels. There is much discontinuous layering and numerous lenses of fine grained drift sediments, such as silts and clays. In the absence of other industrial activit}', groundwater flow at the Site would generally move to the northwest, toward Davis Creek and Portage Creek, and on a regional basis toward the Kalamazoo River, which is about 4 miles north of the Site.

B. Land and Resource Use

A firm called Central Manufacturing Services, Inc. (CMS) is now occupying the former Roto-Finish manufacturing facility. This firm is engaged in commercial warehousing. The immediate Site area is zoned for industrial usage. Other nearby industrial activity includes

plastic color pigment production, a building supply business, surgical supply manufacturing, and pharmaceutical research and manufacturing.

Both Portage and the nearby city of Kalamazoo obtain municipal water from groundwater. The ROD indicated that there are seven municipal wells in the vicinity of the Site. One well, Kalamazoo Coimty Station 13 well, located about 1.3 miles northeast of the site, was abandoned and plugged in 1998. Two Portage wells, located about 0.3 miles northeast and upgradient of the Site, used to serve the nearby Lexington Green residential development but are no longer in use due to high arsenic content. From 1989 to 2005 these two Portage municipal wells were used only to flush fire hydrants due to their high iron content. The four remaining functional wells identified in the ROD include Kalamazoo Well Stations 8 and 18 (locatedl.3 miles north of the site), the Portage Creek Well and the Garden Lane 5 Well. There have been no detections of Site contaminants in these wells.

C. Contamination History

The Roto-Finish Company manufactured specialized equipment to debur 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. Plant operations were conducted in one of two primary areas: the manufacturing building, which provided oflices, plus shop areas used for equipment manufacturing and storage; and the chip/compound building, which was used for production and storage of polishing media.

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 cormected to these water supply/sewerage service lines.

In 1979, the 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.

D. Initial Response

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 Nafional Priorities List (NPL). From 1987-1988, negotiations were conducted concerning performance of a Remedial Investigation/Feasibility Study (RI/FS). A Consent Agreement was signed in 1988, indicating

the RI/FS would be performed privately, with oversight from U.S. EPA and MDEQ. The RI/FS was conducted in three phases, from 1989-1996, and completed in October 1996.

E. 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- trichloroethane (TCA); trichloroethene (TCE); 1,1,2-TCA; benzene; tetrachloroethene; and chlorobenzene.

The RI/FS did not identify any unacceptable degree of current or future cancer or non-cancer risk through exposure to Site soils. Extension of municipal water supply into the Site vicinity means that there is no current unacceptable degree of risk to those dovwigradient groundwater users hooked up to the municipal supply. The RI/FS showed that unacceptable cancer risks would result based on concentrations of chemical present in groundwater at the time, if groundwater within the area of former Roto-Finish facility was used for drinking and showering (dermal adsorption, inhalation, and ingestion). The total sum of increased cancer risk under these conditions was calculated to be 2 additional cases of cancer per every 100 workers exposed. Under a residential risk scenario, five additional cancer cased per 100 residents exposed were predicted.

The RI/FS found that ecological risks from both soil and groundwater were limited at the site.

IV. Removal and Remedial Actions

A. Voluntary Non-Time-Critical Removal Action (NTCRA) for Groundwater

In 1994, Illinois Tool Works Inc. (ITW), a potentially responsible party (PRP) for the site conducted a voluntary Engineering Evaluation/Cost Analysis (EE/CA) to explore removal options that would address the highest areas of groundwater contamination at the Site. This NTCRA was intended to fiinction 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 the U.S. EPA issued a unilateral administrative order in early 1995 calling for implementafion of the voluntary NTCRA. The NTCRA consisted of the installation of two extraction wells (EW-1 and EW-2) and associated piping located between Site monitoring wells MWAl and MWA4 (see Attachment 1). 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 would be representative of long-term conditions under which the natural attenuation remedy would be performing. The extraction wells currently remain in shut down mode although they are being maintained in case they need to be reactivated in the fiature as a contingency remedy.

B. Remedy Selection

The ROD for the Site was signed on March 31,1997. The purpose of the remedy, as described in the ROD, is to eliminate or reduce the risks posed by potential fiiture exposure to contaminated groundwater and to restore the contaminated aquifer to its potential fiiture use as a supply of municipal, residential and industrial drinking water.

The selected remedy, which deals with management of groundwater migration, includes:

• Natural attenuation (primarily via intrinsic biodegradation) to restore the contaminated aquifer to the lower of either Maximum Contamination Levels (MCLs) 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 performing 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 performance 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 to institutional controls, modifications to the monitoring program, and implementation of the contingency remedy, if necessary.

C. Remedy Implementation

The Remedial Design/Remedial Action (RD/RA) is governed by the 1998 Consent Decree (CD) and Statement of Work (SOW) signed by two potentially responsible parties. Pre-design investigations were 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. In September 2007, U.S. EPA approved the PRP's Performance Monitoring Plan (PMP) and other remedial design documents for groundwater monitoring of a total of thirty-three (33) wells at the Roto-Finish Site. These monitoring wells included the sampling 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. In addition, U.S. EPA has required quarterly groundwater sampling of the five core monitoring wells. Additional wells installed as part of the approved PMP were also required to be sampled for the first eight quarters. One upgradient well was not installed due to access restrictions. Only two upgradient wells are now part of the PMP.

Field work completed in 2008 included installation of eight Performance Monitoring Wells:

• PW-1, PW-2, PW-3, PW-4, and S-1, designated as performance and sentry wells; • CMW-3S, CMW-3D, and MW-B7D as vertical monitoring wells; and • Two replacement wells: CMW-5R which replaced CMW-5 that was lost in 2007 due to

the expansion of the airport taxiway; and MW-C5R which replaced MW-C5, believed to have been lost during airport runway modifications that took place in 2007. MW-C5 was subsequently relocated and is included with the monitoring network.

ITW conducts annual sampling of the entire performing monitoring network as part of long-term monitoring at the site.

D. Institutional Controls

Institutional controls (ICs) are non-engineered instruments, such as administrative and/or legal controls, that help minimize the potential for exposure to contamination and protect the integrity of the remedy. Compliance with ICs is required to assure long-term protectiveness for any areas which do not allow for Unlimited Use and Unrestricted Exposure (UU/UE).

The table below summarizes institutional controls for these restricted areas.

Instil Media, Engineered Controls & Areas that do not support UTJAJE based on current conditions. Groundwater - current area that exceeds ground water cleanup standards.

utional Controls Summary IC Objective

Prohibit groundwater use until cleanup standards are achieved

^ Table Title of Institutional Control Instrument Implemented (note if planned) Kalamazoo County Sanitary Code, Article III Water Supply Regulations, Chapter 13-15 Restrictive Covenant for the former Roto-Finish Property and adjacent site properties, if possible.

ICs currently in place include:

• A Kalamazoo County ordinance (Kalamazoo County Sanitary Code. Article III Water Supply Regulations, 2003) that requires the issuance of a well permit for the construction of a private drinking water well from the Environmental Health Bureau within the Kalamazoo County Health and Community Services Department (KCHCSD). The Site has been identified by KCHCSD as a groundwater contamination site of concern. When the KCHCSD receives an application for installation of a residential well, the location for the proposed well is evaluated for the proximity to the known area of groundwater contamination. If the proposed well location is near a known groundwater contamination area an additional review is conducted in order to determine whether a well permit is issued or denied.

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

Additionally, although not an institutional control selected in the CERCLA ROD, the Kalamazoo/Battle Creek International Airport's current policies prohibit the construction of water supply wells on airport property.

Current Compliance: Based on the Site inspection and data reviewed, U.S. EPA is not aware of site or media use which are inconsistent with the stated objectives of the ICs and cleanup goals. Therefore, at this time, the remedy appears to be functioning as intended since the property is not being used in a manner which is inconsistent with the required use restrictions or other ICs. However, long-term protectiveness requires compliance with effective ICs.

Long-term Stewardship: Long-term protectiveness at the site requires continued compliance with use restrictions to assure the remedy continues to function as intended. To assure proper maintenance, monitoring and enforcement of effective ICs, long-term stewardship procedures will be reviewed and the Operation and Maintenance (O&M) Plan will be revised as necessary.

Review of Existing ICs: For placing land use restrictions on properties when required for a Superfund site, MDEQ now requires the use of a restrictive covenant called "Declaration of Restrictive Covenant and Grant of Environmental Protection Easement (DRC)". The content of a DRC must meet the requirements of Section 20114c of Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended ('•T4REPA"), MCL 324.20101 et seq., and R299.5524 of the Part 201 Administrative Rules. In January 2012, ITW submitted a draft DRC for the Roto-Finish Properly based on April 2011 MDEQ Model Restrictive Covenant. U.S. EPA is currently reviewing the DRC for the Roto-Finish Site.

E. Operation and Maintenance

The primary activities associated with operation and maintenance of the Site include maintenance of monitoring wells and ICs. Monitoring well inspections are conducted during the annual or quarterly sampling events. Generally, well caps and locks are inspected and replaced

7

as necessary. Based on the December 5, 2011 site inspection, all existing monitoring wells at the Roto-Finish Site are in good condition.

V. Progress since the Last Review

U.S. EPA, in its second Five-Year Review Report (May 1, 2007), concluded that the remedy selected for the Roto-Finish Site remained protective of human health and the environment in the short term. In order to be protective of human health and the environment in the long-term, U.S. EPA made eight specific recommendations. The following table summarizes these recommendations and follow-up actions to be taken:

Action Taken Since the Last Five-Year Review Recommendations from Previous Review

Complete IC Study to evaluate ICs, revise ICs, and propose IC monitoring plan Develop an IC Plan to document the process to complete IC study, to evaluate existing ICs (including title work) and determine if additional or revised ICs are required, and for developing an IC monitoring plan within the O&M Plan. Propose additional monitoring well locations and submit the PMP for Approval Implement a well maintenance plan Develop a contingency plan which identifies the triggers that will indicate when additional actions need to take place, indicate what actions will be taken, and the implementation time frame Propose an adequate and effective contingency remedy Redevelop/rehabilitate monitoring wells MW-A3, MW-A5, and MW-Bll, if they are determined to be necessary in the long-term monitoring network Determine biodegradation rate along the core of the plume upon completion of the baseline sampling

Party Responsible

PRP

PRP

PRP

PRP

PRP

PRP

PRP

PRP

Action Taken

In Progress

In Progress

Completed

Completed

Completed

Completed

Completed

Completed

Institutional Control Study and Plan: In its second Five-Year Review Report (2007), U.S. EPA had recommended that an IC study be conducted to evaluate, revise, and propose an IC monitoring plan. It is to be noted that the risk to human health and the environment is due to the potential use of groundwater at and downgradient from the Roto-Finish Site. The 1997 ROD for the Site chose MNA as the remedy to bring the groundwater to beneficial uses. U.S. EPA believes that the only ICs necessary to protect human health and the envirormient are restrictive covenants to prohibit groundwater use in the area. Therefore, no fiirther IC study or plan is necessary.

Performance Monitoring Plan: In September 2007, U.S. EPA approved the PMP for Remedial Action at the Roto-Finish Site. ITW installed additional monitoring wells as required in the PMP and are conducting long-term monitoring of a total of 33 groimdwater wells on an armual basis. The plimie core wells are monitored on a quarterly basis.

Well Maintenance Plan: Section 6.3 of the PMP discusses long-term maintenance of monitoring wells at the Site. Monitoring wells will be inspected armually as part of sampling events. The condition of monitoring wells would be evaluated with regards to the need for

rehabilitation, redevelopment, repair and/or replacement. The inspection would include 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 would 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.

Contingency Plan: Section 8.0 of the PMP discusses the Contingency Plan to respond to any differences in the actual performance of the remedy and actual site conditions, as compared to the expected performance of the remedy and expected site conditions.

Contingency Remedy: A contingency remedy which would consist of enhancements to accelerate the natural attenuation process is discussed in Section 9.0 of the PMP.

Biodegradation Rate along the core of the plume: The 2011 Roto-Finish Annual Performance Monitoring Report discusses Biodegradation Progress, Bulk attenuation and degradation rate estimates, and the conditions for degradation of chlorinated compounds.

VT. Five-Year Review Process

A. Administrative Components

The Roto-Finish five-year review team was led by Nan Gowda, U.S. EPA Remedial Project Manager for the Roto-Finish Site and Beth Mead-O'Brien of the MDEQ. The review team's responsibilities included the following components.

• Conmiunity Involvement • Document Review • Data Review • Site Inspection

B. Community Involvement

A notice was published on December 7, 2011, in the local newspaper, the Kalamazoo Gazette, that a five-year review was being conducted. Since the newspaper was published, no member of the community or any other individual has offered any comments on the five-year review of the Roto-Finish Site.

C. Document Review

The five-year review consisted of the review of the following documents:

1. Roto-Finish Superfund Site Record of Decision (March 31,1997) 2. Roto-Finish Consent Decree (July 27, 1998) 3. Draft Pre-Design Investigation Summary & Site Conceptual Model, Roto-Finish Site

(August 2006) 4. Roto-Finish Superfiand Site Five-Year Review Report (September 2002)

5. Roto-Finish Superfund Site Second Five-Year Review Report (May 2007) 6. Performance Monitoring Plan for the Roto-Finish Site (November 2007) 7. 2010 Roto-Finish Annual performance Monitoring Report (April 2011) 8. 2011 Roto-Finish Annual Performance Monitoring Report (February 2012)

D. Data Review

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 (PCE), Trichloroethene (TCE), 1,1-Dichloroethene (1,1-DCE), and Vinyl Chloride (VC). The concentrations reported below were taken from the 2011 Annual Performance Monitoring Report (February 2012).

1. Maximum PCE concentration was 17|ig/L in MW-B2B, above the ROD cleanup level of 5)ig/L. PCE was also detected, but below MCLs, in two other wells: MW-309R (0.88^g/L) and MW-310 (1.3|ag/L).

2. Maximum TCE concentration was 20|ig/L in MW-2B, above the ROD cleanup level of 5|ag/L. TCE exceeded the ROD cleanup levels in six of the 32 wells sampled.

3. Maximum 1,1-DCE concentration was 70^g/L in MW-Al, above the ROD cleanup level of 7|ig/L. 1,1-DCE exceeded the ROD cleanup levels in seven of the 32 monitoring wells sampled.

4. Maximum VC concentration was 15|ag/L in MW-B6 above the ROD cleanup level of 2|ag/L. VC exceeded the ROD cleanup levels in 16 of the 32 wells sampled.

In addition, 1,1 Dichloroethane (1,1-DCA) remained the most commonly detected VOC in the groundwater at the Site. 1,1- DCA was detected in 21 of the 32 wells sampled in September 2011. The highest concentration of 1,1-DCA was detected in MW-Al at a concentration (520^g/L) was below the ROD cleanup level of 880|ig/L. The highest concentration reported for total VOCs reported during the September sampling event was 601 |ag/L reported in MW-Al, primarily from the two compounds: 1,1-DCA (520|ig/L) and 1,1-DCE (70\igfL). MW-Al is located near the southwest comer of the main Roto-Finish building.

Arsenic was detected above its MCL of 10|ag/L in MW-Sl located on the east side of the main Roto-Finish building. As discussed in Section III Background - Land and Resource Use, nearby wells (located about 0.3 miles northeast of the Site) that previously served Lexington Green residential development also contained high arsenic concentrations. Therefore, it appears that arsenic concentrations at the Site are consistent with natural background concentrations.

A comparison of maximum concentrations of volatile organic compounds detected since 1991 indicates that the contaminants of concern (COCs) have decreased significantly. Maximum groundwater concentrations of PCE at the Site have decreased from 25|ag/L to 17|.ig/L, concentrations of TCE have decreased from 150^g/L to 20|ig/L, concentrations of 1,1-DCE have decreased from 220|ig/L to 70|ig/L, and concentrations of VC have decreased from 120[ig/L to

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15|ig/L from October 1991 to September 2011. Since 1991, total VOCs have decreased from a maximum concentration of 2856|ag/L to 601)ig/L.

Although there is significant reduction in contaminant concentrations at the Site, a review of the data indicates a slower rate of degradation than was originally predicted. It appears that at low VOC concentrations the rate of degradation slows down. In addition, observed groundwater flow direction since 2007 has shifted from a more westerly direction to the current northwest orientation. 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.

For long-term protectiveness, additional restrictive covenants are necessary to prohibit the use of contaminated groundwater at the Site. ITW is working with U.S. EPA in preparing the required restrictive covenants for the Roto-Finish Site. In January 2012 ITW submitted a draft DRC for the Roto-Finish Properly based on April 2011 MDEQ Model Restrictive Covenant. U.S. EPA is currently reviewing the DRC for the Roto-Finish Site.

E. Site Inspection

An inspection of the Roto-Finish Site was performed as part of this five-year review on December 6, 2011, by Nan Gowda of the U.S. EPA and Mike Hoffman 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. Caps and locks for all 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 prohibits the drilling of a drinking water well without a permit. The airport policy prohibits installation of water supply wells on the airport property. No activities were observed that would have violated these ICs.

VII. Technical Assessment

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

Yes. A comparison of maximum concentrations of volatile organic compounds detected since 1991 indicates that the contaminants of concem (COCs) have decreased significantly. Maximum groundwater concentrations of PCE at the Site have decreased from 25/ig/L in October of 1991 to 17|ig/L in September 2011. Maximum groundwater concentrations of PCE at the Site have decreased fi-om 25|ig/L to 17|ig/L, concentrations of TCE have decreased from 150|ag/L to 20pg/L, concentrations of 1,1-DCE have decreased from 220|ag/L to 70^g/L, and concentrations of VC have decreased from 120^g/L to 15|ag/L from October 1991 to September 2011. Since 1991, total VOCs have decreased from a maximum concentration of 2856|ag/L to 601tig/L.

Although there is significant reduction in contaminant concentrations at the Site, a review of the data indicates a slower rate of degradation than was originally predicted. It appears that at

11

low VOC concentrations the rate of degradation has slowed down. The remedy is functioning as intended but at a slower rate than originally predicted.

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

Yes. The September 2002 Five-Year Review 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 Attachment 3. Although there was no MCL for 1,1 -DCA at the time of the ROD, MDEQ Part 201 criteria was 880ug/L for 1,1-DCA. Therefore, the corrected ROD cleanup criterion is 880ug/L for 1,1 -DCA. 1,2-DCE was appropriately corrected to distinguish each isomer with a separate cleanup criteria; cis- 1,2-DCE is 70ug/L and trans- 1,2-DCE is lOOug/L. Also, effective January 23, 2012, the MCLs for Arsenic changed from 50|ag/L to 10|jg/L.

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

No. There is no other information that calls into question the protectiveness of the remedy.

MDEQ was given a 30-day time frame from March 23, 2012, to review a draft five-year report for the Roto-Finish Site. Their comments were received late and are included as Attachment 4 to this report. For the reasons explained in this report, U.S. EPA does not agree with MDEQ's responses to the three Technical Assessment questions and other comments on this report.

Technical Assessment Summary

The Long-Term Groundwater Monitoring Network is complete. There are ICs in place that restrict groundwater use, but additional controls are needed to restrict groundwater use within all affected portions of the groundwater plume. The remedy is currently protective of human health and the envirormient in the short-term. Although there is significant reduction in contaminant concentrations at the Site, a review of the data indicates that the remedy appears to be fianctioning as intended at a slower rate of degradation than originally predicted. There have been no 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 contaminants of concem 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.

12

VIII. Issues

The following issues were identified for the Site during this Five-Year Review:

Issues

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

Affects Current Protectiveness

(Y/N)

N

N

Affects Future Protectiveness

(Y/N)

Y

Y

IX. Recommendations and Follow-up Actions

The following recommendations and follow-up actions have been identified:

Recommendations and Follow-Up Actions

Issue

Institutional Controls

MNA

Recommendations/ Follow-up Actions

Complete a DRC for the Roto-Finish site to prohibit the use of contaminated groundwater at the Site. Continue groundwater monitoring to further evaluate the biodegradation rate and determine if a contingency remedy is necessary.

Responsible Party

PRP

PRP

Oversight

U.S. EPA

U.S. EPA

Milestone Date

June 2013

March 2013

Affects Protectiveness

(Y/N) Current

N

N

Future

Y

Y

X. Protectiveness Statement

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-term, restrictive covenants 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.

XI. Next Review

The next five-year review for the Site is required five years from the date of this review.

13

Attachment 1

Roto-Finish Site

Location Map and Current Monitoring Well Network

',V-C2A

\-m-c5-

\

W-rBI-1

•85!

FIGURE 1-1 PBtf=ORMANCe

MONrrORINQ NETWORK

- ^ PSFOfiMANCe W a i ^ (32)

• HYDRAUUC MOHTOflWQ WHIS

WIMPWaXS

OTHER WBJia

(»)

(6)

(8)

D FORNiBl EXTRACTION WELLS (2)

0 500' 1000

SCALE: 1 INCH = 500 FEET (2011 AEFBAL PHOTO)

c i ^

i £MW-4 ,CMW-2 i n

1 ' •^^"^P^ l f f l - - CMW-3S CMW-1

' / ^ . PW-4

• iVn

Attachment 2

Roto-Finish Site

Extent of Total VOCs in Groundwater Plume

ATTACHMENT 2

Total VOCs (ug/L) -12/2005 Plume Definition

MW-B1i

l _ .

J V

c a

0 200 400 600 800 Scale 1" = 500 n ITMACTEC

Attachment 3

Roto-Finish Site

Revised ROD Cleanup Criteria

UNITED STATES ENVIRONMENTAL PROTECTTION AGENCY REGION V

DATE: May 31,2005

SUBJECTT: Roto-Finish 1997 ROD Cleanup Criteria (Table 6) Corrections/Clarification

FROM: Katherine Rodriguez RPM, RRS #4

TO: File

In March 1997 U.S. EPA issued a Record of Decision (ROD) which outlined the remedy selection process and selected the cleanup actions for the Roto-Finish site (the site) located in Kalamazoo County, Portage, Michigan. The remedy selected was Monitored Natural Attenuation (MNA). Currently the site is in the Remedial Design Stage.

The current issue is the performance standards for groundwater cleanup in Table 6 of the ROD. The ROD states that the performance standards are the lower of either Maximum Contaminant Levels (MCLs) 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 Contaminant Level Goals (MCLGs) apply when less than the MCL. The source for the Michigan criteria was MDEQ Environmental Response Division Operational Memoranda #8, Revision 4, and #14, Revision 2.

In the process of pre-design studies, MACTEC, the contractor for the Potentially Responsible Party, (Illinois Tool Works) presented in the Phase I Report of the Remedial Design Work Plan (April 24,2002) inaccuracies in the performance standards for groundwater cleanup objectives documented in the ROD. MACTEC proposed corrections to the criteria using the most current documentation of the Michigan criteria. Operational Memoranda #18 Attachment A Groundwater: Residential and Industrial-Commercial Part 201 Generic Cleanup Criteria and Screening Levels.

The September 2002 Five-Year Review states on page 25, "The 1997 ROD incorrectly attributed an MCL to i,l-Dichloroethane (DCA). Actually, MCL consideration for this compound is still under review. This compound is one of those slated for fiirther water quality standard development, and in the field has been detected more frequently than any other VOC. Also the 1997 ROD inappropriately added together the separate MCLs for the cis/trans form of i,2-DCE, rather than noting their individual MCLs. Despite these oversights, basic assumptions concerning exposure, toxicity and desired cleanup levels are justified. The agency must monitor developments related to any eventual MCL that may be established for 1,1-DCA. However, at this time, the original remedial approach is still likely to be compatible with MCL development which may occur for 1,1-DCA."

The performance standards for the site were memorialized at the time of the ROD. The agencies have decided to reduce any future confusion of the performance standards by correcting Table 6 of the ROD using the information available at the time of the ROD, see attached Revised Roto-Finish March 1997 ROD Cleanup Criteria (Table 6) (Incorporates corrections). In the future, if there are more significant/fundamental changes to the remedy, it is suggested to consider the Michigan criteria updates as was proposed by MACTEC in the Phase I Report and the MCL developments as was indicated in the Five-Year Review.

REVISED ROTO-FINISH MARCH 1997 ROD CLEANUP CRITERIA (TABLE 6) (Incorporates corrections)

Contaminant

3/97 ROD Stated Cleanup Criteria

(UQ/I)

Federal*^' MDEQ'^'

MACTEC's Proposed

Corrections to Criteria (RD Ph 1

Report) (ug/l)

Actual Agency Cleanup Criteria at Time of ROD (ug/l)

Federal* ' IVIDEQ' '

Corrected ROD

Cleanup Criteria'^' (ug/I) Rationale

Volatiles

Acetone

Benzene

Bromodlchloromethane

Carbon Disulfide

Chloroebenzene

Chloroethane

Chloroform

Dichlorodifluoromethane

None available

5

IOC'"'

None available

100

None available

100'^'

730

5

100

800

100

220

100

Compound not listed in 3/97 ROD

No change

No change

No change

No change

No change

430

No change

1,700

None available

5

100'*'

None available

100

None available

100'*)

None available

730

5

100

800

100

220

100

1,700

730

5

100'"'

800

100

220

100'"'

t

1,700

No change

No change

No change

No change

No change

6/5/95 Part 201 Criteria; 430 ug/l is based on 6/6/00 Part 201 criteria (post 3/97 ROD)

No change

6/5/95 Part 201 Criteria

Page 1 of 9

REVISED ROTO-FINISH MARCH 1997 ROD CLEANUP CRITERI/i

Contaminant

1,1-Dichloroethane

1,1-Dichloroethene

1,2-Dichloroethane

1,2-Dlchloroethene

Ethyl Benzene

4-methyl-2-pentanone

Methylene Chloride

Tetrachloroethene


(uq/i)

Federal'^'

5

7

5

170

700

None available

5

5

MDEQ'^'

5

7

5

170

700

370

5

5

MACTEC's Proposed


Report) (ug/l)

880

No change

No change

cis-1,2-DCE 70 trans-1,2-DCE 100

74

1,800

No change

No change


Federal'^'

None available

7

5

cis-1,2-DCE 70;

trans-1,2-DCE100

700

None available

5

5

MDEQ'^'

880

7

5

cis-1,2-D C E 70;

trans-1,2-DCE100

74

370

5

5

^ (TABLE 6) (Incorporates corrections)

Corrected ROD Cleanup Criteria''*

(ug/l)

880

7

5

cis-1,2-DCE 70 trans-1,2-DCE 100

74

370

5

5

Rationale

ROD incorrectly cited MCL as 5 ug/l when there w as no MCL for this compound at the time of the ROD; ROD incorrectly cited Part 201 criteria as 5 ug/l when it was 880 at the time of the ROD (6/5/95 Part 201 Criteria)

No change

No change

6/5/95 Part 201 Criteria; ROD incorrectly cited total 1,2-DCE instead of citing the cleanup criteria for each isomer separately

ROD incorrectly cited Part 201 criteria as 700 ug,'! when the aesthetic criteria was 74 ug/l at the time of the ROD (6/5/95 Part 201 Criteria)

6/5/95 Part 201 Criteria; 1,800 ug/l is based on 6/6/00 Part 201 criteria (post 3/97 ROD)

No change

No change

Page 2 of 9


Contaminant

Toluene

1,1,1-Trichloroethane

1,1,2-Trlchloroethane

Trichloroethene

Vinyl Chloride

Total Xylenes


(ug/l) r

Federal'^'

1.000

200

3(5)

5

2

10,000

MDEQ'^'

1,000

200

5

5

2

10,000

MACTEC's Proposed


Report) (ug/l)

790

No change

5

No change

No change

280


Federal' *

1,000

200

3(5)

5

2

10,000

—1

MDEQ'="

790

200

5

5

2

280

Corrected ROD Cleanup Criteria'^'

(ug/l)

790

200

3

5

2

280

Rationale

ROD incorrectly cited Part 201 criteria as 1,000 ug/l v/hen the aesthetic criteria was 790 ug/l at the time of the ROD (6/5/95 Part 201 Criteria)

No change

ROD criteria based on Non-Zero Maximum Contaminant Level Goal i

No change

No change

ROD incorrectly cited Part 201 criteria as 10,000 ug/l when the aesthetic criteria was 280 ug/l at the time of the ROD (6/5/95 Part 201 Criteria)

Semivolatiles

Ben2o(a)anthracene None

available 1.2 2.1 None

available 1.2 1.2 6/5/95 Part 201 Criteria; 2,1 ug/l is based on 6/6/00 Part 201 criteria (post 3/97 ROD)

Page 3 of 9


Contaminant


Federal' ) MDEO ,(3)

MACTEC'S Proposed

Corrections to Criteria (RD Ph I

Report) (ug/l)


Federal'^' MDEQ (3)

Corrected ROD Cleanup Criteria'^'

Rationale

Benzo(b)fluoranthene

Benzo(k) fluoranthene

Benzo(g,h,i)perylene

Ben2o(a)pyrene

Bis(2-ethylhexyl)phthalate

Chrysene

Di-n-octyl phthalate

1,2-Dlchlorobenzene

None available

None available

None available

2

6

None available

None available

600

1.2

12

26

0.2

6

120

130

600

No change

No change

No change

None available

None available

None available

0.2

6

None available

None available

600

1.2

12

26

0.2

6

120

130

600

6/5/95 Part 201 Criteria; 2 ug/l is based on 1.2 6/6/00 Part 201 criteria (post 3/97 ROD)

6/5/95 Part 201 Criteria; 5 ug/l is based on 12 6/6/00 Part 201 criteria (post 3/97 ROD)


6/5/95 Part 201 Criteria; 5 ug/l is based on 0.2 6/6/00 Part 201 criteria (post 3/97 ROD).

6 No change


130 No change

600 No change

Page 4 of 9


Contaminant

1,4-Dichloroben2ene

Fluoranthene

lndeno(1,2,3-cd)pyrene

2-Methylnaphthalene

4-Nitrophenol

Pentachlorophenol

Phenanthrene

Phenol


(ug/l)

Federal'^'

75

None available

None available

None available

None available

1

None available

None available

MDEQ'="

75

880

1.2

ID

None available

1

26

4,400

MACTEC's Proposed


Report) (ug/l)

No change

210

5

260

No change

No change

52

No change


Federal'^'

75

None available

None available

None available

None available

1

None available

None available

MDEQ'^'

75

880

1.2

ID

None available

1

26

4,400

Corrected ROD Cleanup Criteria'"

(ug/l)

75

880

1.2(2)*

None available

None available

1

26

4,400

Rationale

No change



260 ug/l is based on 6/6/00 Part 201 criteria (post 3/97 ROD)

No change


No change

Page 5 of 9

REVISED ROTO-FINISH MARCH 1997 ROD CLEANUP CRITERI/i

Contaminant


(Uq/1)

Federal'^' MDEO'^'

MACTEC's Proposed


Report) (ug/l)


Federal'^' MDEQ' '

k (TABLE 6) (Incorporates corrections)

Corrected ROD

Cleanup Criteria"' (ug/l) Rationale

Inorganics

Aluminum

Antimony

Arsenic

Barium

Calcium

Chromium

Cobalt

Copper

Iron

None available

6

50 ' "

2,000

None available

100

None available

1,300'^'

None available

ID

6(6)

50'^'

2,000'®'

None available

100'®'

37

1,400'®'

300'®'

50

No change

No change

No change

No change

No change

40

1,000

No change

None available

6 .

50 ' "

2,000

None available

100

None available

1,300'^'

None available

50'®'

6(6)

50'®'

2,000'®'

None available

100'®'

37

1,400'®'

300'®'

50'®'

6(6)

fO» (® '

2,000'®'

None available

100'®'

37

1,300

300'®'

6/5/95 Part 201 Aesthetic Criteria

No change

No change

No change

No change



No change

Page 6 of 9

REVISED ROTO-FINISH MARCH 1997 ROD CLEANUP CRITERIA

Contaminant

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Sodium

Thallium


(ug/l)

Federal'^'

15'®'

None available

None available

2

ioo'«i

None available

None available

0.5'®'

MDEQ'"

4(9)

420.000

860

2(6)

100'®'

None available

160,000

2'®'

MACTEC's Proposed


Report) (ug/l)

No change

400,000

50

No change

No change

No change

120,000

2


Federal'^'

15'®'

None available

None available

2

100'^'

None available

None available

0.5'®'

MDEQ'^'

4(6)

420,000

50'®'

2(6)

100'®'

None available

160.000

2(6)

^ (TABLE 6) (Incorporates corrections)

Corrected ROD Cleanup Criteria'''

(ug/l)

4(6)

420,000

50'®'

2(6)

100'®'

None available

160,000

0.5'®'

Rationale

No change


ROD incorrectly cited Part 201 criteria as 860 ug/l when the aesthetic criteria was 50 ug/l at the time of the ROD (6/5/95 Part 201 Criteria)

No change

No change


ROD criteria based on Non-Zero Maximum Contaminant Level Goal

Page 7 of 9


Contaminant


Federal'^' MDEQ' '

MACTEC's Proposed

Corrections to Criteria (RD Ph

Report) (ug/l)


Federal'^' MDEQ'"


Rationale

Vanadium

Zinc

Cyanide

None available

None available

200

64'®'

2,400'®'

200

4.5

No change

No change

None available

None available

200

64'®'

2,400'®'

200

64'®'

2,400'®'

200

6/5/95 Part 201 Criteria; 4.5 ug/l is based on 6/6/00 Part 201 criteria (post 3/97 ROD)

No change

No change

NOTE: Reference to "6/5/95 Part 201 Criteria" refers to said generic residential drinking water criteria listed in Op Memo 8, Revision 4 dated June 5, 1995 as cited in the March 1997 ROD.

ID: Inadequate data to develop criterion.

*Criterion followed by () (ie., x (y) or 1.2 (2)) means the corrected ROD cleanup criteria is the first number (ie., 1.2) followed by the Target Method Detection Limit (TMDL) pursuant to RRD Op Memo 2, Attachment 1,10/22/04 (i.e., 2). Cleanup criteria remains at the first number (x) as modified to meet the ROD criteria or the current TMDL at the time of cleanup demonstration, whichever is higher.

(1): In addition to achieving Maximum Contaminant Levels and Michigan drinking water criteria, the groundwater must be restored to an aggregate risk of 1E-04 or less for cancer risks and a hazard Index less than 1.0 for noncancer risks at all points throughout the aquifer. Performance standards for groundwater contaminants attributable to background groundwater quality conditions will be established based on the results of site-specific background groundwater monitoring.

(2): Sources: Code of Federal Regulations (CFR) 40 Part 141; "Drinking Water Regulations and Health Advisories" by U.S. EPA Office of Water, May 1995. Non-zero Maximum Contaminant Level Goals (MCLGs) apply when less than the MCL.

(3): Source: MDEQ Environmental Response Division Operational Memoranda #8, Revision 4, and #14, Revision 2.

Page 8 of 9


Contaminant


(ug/l)

Federal'^' MDEQ'"

MACTEC's Proposed

Corrections to Criteria (RD Ph I

Report) (ug/l)


Federal'^' MDEQ'"


Rationale

(4): 1994 proposed rule for disinfectants and disinfection by-products: total for all trihalomethanes combined cannot exceed 80 ug/l.

(5): Non-Zero Maximum Contaminant Level Goal (MCLG).

(6): Site-specific background, as defined in Michigan Act 451, Part 201 Rule 701 (b) (, may be substituted if higher than the cleanup criteria.

(7): Under review (at the time of the 3/97 ROD).

(8): Action level (at the time of the 3/97 ROD).

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

Page 9 of 9

Attachment 4

Support Agency Comments

STATE OF MICHIGAN

DEPARTMENT OF ENVIRONMENTAL QUALITY

LANSING

RICK SNYDER DAN WYANT

GOVERNOR DIRECTOR

April 24, 2012

Mr. Nanjunda Gowda United States Environmental Protection Agency Region 5 77 West Jackson Boulevard, SR-6J Chicago, Illinois 60604-3590

Dear Mr. Gowda:

SUBJECT: Michigan Department of Environmental Quality (MDEQ) Staff Comments on the March 23, 2012, Draft United States Environmental Protection Agency (USEPA) Third Five-Year Review for the Roto-Finish Superfund Site, Portage, Michigan

MDEQ staff has reviewed the March 23, 2012, draft USEPA third Five-Year Review (5-YR) for the Roto-Finish Superfund site and offers the following comments in addition to the comments included in my December 22, 2011, letter to you (copy attached). Said letter essentially reiterated and provided the MDEQ's clarifications to the issues and recommendations in USEPA's second 5-YR (2007), because it is not apparent that these 2007 issues and recommendations have been adequately addressed at the site. The USEPA has failed to provide documentation that these issues and recommendations have been adequately addressed. The final 5-YR needs to adequately address and incorporate MDEQ's comments into the final third 5-YR document and implement them in order for the MDEQ to consider the remedy protective and complete.

Please remember that the MDEQ did not concur with the 1997 Record of Decision (ROD) for the site. Due to the MDEQ management's decision to end state involvement at this site for lack of federal funding, limited MDEQ staff, the lack of USEPA progress and cooperation (see December 22, 2011, letter to you), and the MDEQ's repeated identification of the same issues that still need to be resolved, the MDEQ comments on the draft third (2012) 5-YR review are focused primarily on identifying key problems with the issues, recommendations, and the follow-up action portions of the draft third 5-YR.

Key Comments In Addition to MDEQ's December 22. 2011. Letter

The Answers to the Technical Assessment Questions of the Draft 5-YR Need Correction

• Question A states: "Is the remedy functioning as intended by the decision documents?" Cited answer: "Yes". Corrections Needed: The answer should be "No" for the reasons identified in this correspondence.

• Question B states: "Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of remedy selection still valid?" Cited answer: "Yes". Corrections Needed: The answer should be "No" for the following reasons:

o The USEPA arsenic maximum contaminant level (MCL) changed from 50 micrograms per liter (fjg/L) to 10 |jg/L since the 1997 ROD was issued; the site cleanup criteria for arsenic needs to be changed to reflect this new criteria.

CONSTITUTION HALL • 525 WEST ALLEGAN STREET • P.O. BOX 30473 • LANSING, MICHIGAN 48909-7973 www.michigan.gov/deq • (800) 662-9278

http://www.michigan.gov/deq

Mr. Nanjunda Gowda 2 April 24,2012

o There is elevated arsenic in the source area groundwater above cleanup criteria that will not be addressed under a monitored natural attenuation (MNA) remedy and is not specifically addressed in the draft restrictive covenant for the Roto-Finish property. The arsenic needs to be addressed at the site through either a new remedy that will treat arsenic or through monitoring and inclusion of arsenic in the Roto-Finish Restrictive Covenant (RC) to ensure no exposure or migration above the revised arsenic 10 |jg/L MCL cleanup criteria.

• Question C states: "Has any other information come to light that could call into question, the protectiveness of the remedy?" Cited answer: No. Corrections Needed: The answer should be "Yes" because the groundwater flow direction has shifted from a westerly direction to a north/northwesterly direction, making the plume core monitoring wells ineffective. Additionally, new plume core monitoring wells need to be installed and monitored to determine degradation rates along the new plume core. Because the groundwater flow direction has shifted and may shift back again, accurate degradation rates need to be developed for the historic westerly plume; the existing calculations are inaccurate. See details in this correspondence for further clarification.

Monitored Natural Attenuation (MNA) Is Not An Appropriate Remedy For This Site. • The groundwater contaminant plume has expanded to the west and north-northwest as

evidenced by increased concentrations in monitoring wells at the perimeter of the plume and vinyl chloride detections in downgradient wells that had previously been non-detect for this compound; MNA can only be considered when there is a non-expanding plume, contrary to Roto-Finish site conditions. This further indicates that MNA is not effective at this site.

• The groundwater flow has shifted directions, making an MNA remedy an ever-shifting target; additional monitoring wells need to be installed and sampled to delineate the plume boundaries and monitor the new core of the shifted plume because the existing plume core wells do not track the new groundwater flow (contaminant plume) direction.

• The Roto-Finish site's continuing sources of contamination negates an MNA remedy, as evidenced by continuing significant source area groundwater contaminant concentrations; additional source remediation should occur to stop additional groundwater from becoming contaminated.

• To date, the calculated degradation rates (including those in the 2011 annual report) have not been done accurately, have not followed the procedures and methods outlined in the USEPA November 2000 Roto-Finish Remedial Design Work Plan and have not taken into account the shift in groundwater flow direction that would cause the existing plume core monitoring wells to be useless for ongoing degradation rate calculations, because they no longer represent the core of the groundwater contaminant plume; additional appropriate, accurate plume core monitoring wells need to be installed, monitored and accurate degradation rates calculated for both the former and the new groundwater contaminant plume direction.

The Contingency Remedy Needs to Be Developed and Implemented Due to MNA Not Being an Effective Remedy for the Site: the Contingency Remedy in the Final Performance Monitoring Plan is Inadeguate.

Monitoring Wells Must Be Installed and Sampled Downgradient to Monitor the Shift in Groundwater Flow/Contaminant Plume Direction from the West to the North/Northwest.

Mr. Nanjunda Gowda 3 April 24,2012

Short- and Long-Term Protectiveness Statement in the third 5-YR Needs to Be the Same as the Second (2007) 5-YR. The MDEQ has attached a copy of the 2007 5-YR protectiveness statements to facilitate the language that needs to be included in the third 5-YR, because site conditions have not sufficiently changed to warrant changes to the 2007 5-YR protectiveness statements.

Declaration of Restrictive Covenant (RC) for the Roto-Finish Property • Please provide the MDEQ with a copy of the draft Roto-Finish property RC. • This draft Roto-Finish property RC needs to not only protect against exposure (drinking,

contact) to contaminated groundwater, but also to exposure to contaminated soils at the property (construction activities below the ground surface) as evidenced by ongoing groundwater source area contaminant concentrations.

Need to Continue Quarterly Groundwater Sampling • Given the changing groundwater flow direction and the corresponding need to install and

quarterly monitor new plume core monitoring wells, the expanding plume, the inadequate degradation rate calculations, and the potential downgradient receptors, the MDEQ recommends continuing quarterly groundwater sampling, contrary to AMEC's (the potentially responsible party's consultant) proposal to reduce sampling to annual events. In addition, the actual sampling performed must be modified to ensure that representative samples are being collected during each sampling event.

Need to Install and Sample Sentry Wells Upgradient of Private Wells and Sample Private Wells • The MDEQ disagrees with the USEPA's conclusion that "there is no threat to

[downgradient] residential wells or justlflcatlon for residential well sampling associated with the Roto-Finish plume."

• The MDEQ's concern with the downgradient receptors Is a need for monitoring points located between the plume and any downgradient receptors.

• The MDEQ has sampled downgradient private drinking water wells In the past and detected site-related contamination.

• Because of this, the presence of private wells along the new flow path to the north/northwest and the fact that the groundwater flow direction could potentially shift back in the direction of these downgradient private wells, the MDEQ strongly encourages the USEPA to ensure installation and regular monitonng of sentry wells (frequency based on groundwater travel rates) and regular monitoring of the private water wells.

Need to Install Monitoring Wells Upgradient of Roto-Finish Source Area • Consistent with an existing agreement, at least one upgradient monitoring well needs to

be Installed and screened at a deeper depth similar to most of the on site contaminated monitoring wells to evaluate the quality of groundwater entering the site.

• Owner compensation should not be an issue for this installation.

Need to Address the High Arsenic Concentrations in Source Monitoring Well S-1. • The USEPA arsenic MCL changed from 50 pg/L to 10 |jg/L since the 1997 ROD was

issued; the site cleanup criteria for arsenic needs to be changed to reflect this new criteria.

• The only source monitoring well, S-1, continues to have concentrations signiflcantly above the arsenic 10 pg/L MCL each time it is sampled. See Table 4-3 in the 2011 Roto-Finish Annual Performance Monitoring Report for further details. Concentrations

Mr. Nanjunda Gowda April 24, 2012

are typically around 100 pg/L with sporadic detections below 50 pg/L. See above text for further details.

• The cited Monitoring Well Maintenance Plan, the Contingency Plan, and the monitoring well redevelopment/rehabilitation activities are all Inadequate.

Request to Include All of MDEQ's Comments in the 5-YR

The MDEQ is requesting (consistent with the PMC Groundwater Superfund Site 5-YR and Metamora Landflll Superfund Site 5-YR) that If all of MDEQ's comments are not fully incorporated into the 5-YR and the remedy, that the USEPA attach this MDEQ correspondence to the final executed third 5-YR and Incorporate the following Into the Executive Summary of the final third 5-YR:

"The MDEQ has a different interpretation than the USEPA on how the remedy Is being implemented, the level of protectiveness, and compliance with the ROD. The MDEQ's support agency comments can be found In Attachment 4 of this Report. Please note that any USEPA response to MDEQ comments in the final third 5-YR shall not be considered by the MDEQ to adequately address MDEQ's comments unless the MDEQ provides such written confirmation to the USEPA after the USEPA issues the final third 5-YR."

Please feel free to call to discuss these further.

Sincerely,

' ^ O ^ Uyi i) Beth Mead-O'Brien, Project Manager Superfund Secfion Remediation Division 517-335-3098

Sincerely,

cU^^M Charles Graff, Geologist Superfund Section Remediation Division 517-335-2596

Attachments cc: Mr. David Kline, MDEQ

Mr. Robert Franks, MDEQ Mr. Eric Alexander, MDEQ Roto-Finish Site File (02)

imO' F' 'A Sea^i Fi'^ (V^ liu^[£K^C>^^

Frpe-Year Review Staamary Fona - cont

Issues: 1) In Older for the remedy to be protective in the long-tenn, effective institutional controls (ICs) mast be

iroplemeated and maintained. :>|v 2) A biodegradation rate along the core of the groundwatfir Jjlume has yet to be determined. 3) A long-term groundwater monitoring well network and gjcondwater monitoring plan to track

expansion and migration of the plume and to monitor ftS'ptAential impact to down^dient receptors has not been implemented. i •-•

4) A monitonng well maintenance plan has not been implemented. 5) Monitoring wells MW-A3, MW-A5, and MW-Bl 1 hav&low yield and high turbidity, limiting the

ability to provide representative sample results. 6) Apparent inadequate contingency remedy (due to the inability of the two NTCRA extractioD wells to

fully capture the extent of the contamination plume without significant improvements, i.e., additional groundwater extraction wells).

7) A contingency plan has yet to be developed and approved.

Recommendations and FoUow-up Actions: 1) A. Complete IC study within the Remedial Design to evaluate ICs and revise ICs and propose an IC

monitoring plan B. Develop an IC Plan to document the process to complete the IC study, to evaluate existing ICs Cmcluding title work) and determine if additional or revised ICs are required, and for developmg an IC monitoring plan within the O&M Plan

2) Determine biodegradation rate along the core of the plume upon completion of baseline sampling 3) Propose additional monitoring well locations and submit the Performance Monitoring Plan for

approval 4) Implement a well maintenance plan 5) Redevelop/rehabilitate monitoring wells MW-A3, NrW-A5. and MW-B11 if they are determmed to be

necessary in the long-term monitoring network 6) Propose an adequate and elTective contingency remedy 7) Develop a condngency plan which identifies the triggers that will bdicate when additional actions

need to take place, indicate what actions will be taken, and the implementation time frame

Protectiveness Statenient(s): The remedy at the Site is expected to be protective of human health and the enviroirment upcn attainment of groundwater cleanup goals.: jllJhe goals of unlimited a ^ and unlimited exposure will be achieved through monitored natural attenuation. EPA expects these goals to be achieved within the next 40-50 years. In the interim, exposure pathways that could result in unacceptable risks are being monitored and controlled. All immediate threats to human health and the environment have been eliminated.

Long-term Protectiveness: In order to make a deterniination:rcgarding long-term protectiveness of the selected remedy, EPA needs additional information. Long-term protectiveness will be determined when: • the rate of attenuation is accurately calculated, • an adequate groundwater monitoripg well network is installed to fully bound the phime, to detect any

expansion and nugration of the groundwater plume, and to monitor for potential impact on downgradient receptors,

• the long-term groundwater monitoring and monitoring well maintenance plan is implemented,

vii

« institDtKiuI controls are imp)e>nealed aod monitored lo restrict grousdwatcr use in ail aieas aifecled by the cootamiaated groundwater pinine uoti! groundwater resionuioo cleanup standards are achieved,

• n ippfopiiale and effective coatjogeocy lensedy is proposed. • a ccntingcncy plan is developed which identify the triggers {\.e., cootamiaidon in scatlnei wells

npgradieat of gicundwater receptors) thai will indicate when additional acthms tseed to lake place, iDdkate what actions will be taken, aod the inqjieinenia icffl time frame.

Tbese six i«|aiienien!s are ouremly being detcnnir»ed. revised, and reviewed as: pant oTtbe RD ptocess. It is expected that ttiese actions will be completed by January 200S. A long-term {M jteciiveacss detemimaiion will be made in as addendnm lo this FYR reporL

vm

STATE OP MICHIGAN

DEPARTMENT OF ENVIRONMENTAL QUALITY

t i ^ ^ ' LANSING

RICK SNYDER DAN WYANT GOVERNOR DIRECTOR

December 22, 2011

Mr. Nanjunda Gowda Regional Project Manager United States Environmental Protection Agency Region 5 77 West Jackson Boulevard (SR-6J) Chicago, Illinois 60604-3590

Dear Mr. Gowda;

SUBJECT; Roto-Finish Superfund Site Upcoming Draft Five-Year Review

This letter identifies the Roto-Finish Superfund site issues that the Michigan Department of Environmental Quality (MDEQ) staff wants the United States Environmental Protection Agency (USEPA) to incorporate into the upcoming draft Five-Year Review (SYR) for the site as well as clarify MDEQ's future involvement at this site. The issues presented here are consistent with the May 14, 2007, USEPA letter to Mike Hoffman (formerly MACTEC, now AMEC) transmitting the May 1, 2007, SYR because these issues have not yet been addressed. The May 14, 2007, USEPA letter identifies the following SYR Issues and Recommendations and Follow-up Actions with MDEQ clarifications provided in parentheses and /ifa//cs below. If should be noted that the 2007 SYR indicated that all of the recommendations need to be appropriately implemented in order for this site remedy to be protective in the long-term.

Issues: 1. In order for the remedy to be protective in the long-term, effective institutional controls (ICs) must be implemented and maintained. {MDEQ: to date, this has not yet been addressed).

2. A biodegradation rate along the core of the groundwater plume has yet to be determined. {MDEQ: while AMEC did degradation calculations on two separate occasions, they were both done incorrectly. Additionally, the groundwater plume has since spread further downgradient resulting in the need to install additional monitoring points to monitor the larger groundwater plume. The groundwater flow direction has changed since the last 5YR, which means that the plume core as defined before the last SYR no longer defines the core of the groundwater plume, and must therefore, be redefined through vertical aquifer sampling borings and new monitoring wells installed to monitor the plume core for the long term. AMEC must perform appropriate degradation rate calculations, first for the data already collected from the original plume core monitoring wells, and then along a new, second set of plume core monitoring wells to address the shift in the groundwater flow direction. It will take at least eight sampling events to develop sufficient data to be able to calculate degradation rates along the new plume core).

3. While a long-term groundwater monitoring well network and groundwater monitoring plan to track expansion and migration of the plume has been implemented, it does not include sentinel wells and monitoring for potential impacts to downgradient receptors. {MDEQ: Additional monitoring well installation and monitoring is particularly important not

CONSTITUTION HALL • 525 WEST ALLEGAN STREET • P.O. BOX 30473 • LANSING, MICHIGAN 48909-7S73 www.michigan.gov/deq • (800) 662-9278

http://www.michigan.gov/deq

Mr. Nanjunda Gowda 2 December 22,2011

only to track plume expansion and migration, but also to track and monitor the shift in groundwater flow direction. Additionally, the MDEQ has previously pointed out that there is a long-standing need for sentinel well installation and sampling; and private well sampling to monitor and prevent contaminant exposure in the downgradient private drinking water wells. Additionally, the 5YR should clarify that part of the reason for groundwater monitonng is to evaluate whether or not plume expansion is occurring. If it is occurring, then monitored natural attenuation, by definition, is a failed remedy at this site and contingency remedy(ies) beyond those that exist need to be developed and implemented).

4. A monitoring well maintenance plan has not been implemented. (MDEQ: This is of impodance to ensure that the sampling that occurs from the monitoring wells provides representative samples. This plan was supposed to have been done already; approval of one of their draft documents was contingent upon submittal of an approvable monitoring well maintenance plan, however, this document was never submitted, at least to MDEQ's knowledge).

5. Monitoring wells MW-A3, MW-AS, and MW-Bl 1 have low yield and high turbidity, limiting the ability to provide representative sample results.

6. Apparent inadequate contingency remedy (due to the inability of the two NTCRA extraction wells to fully capture the extent of the contamination plume without significant Improvements, i.e., additional groundwater extraction wells). (MDEQ: The contingency remedy should also specify if, and when, the contingency remedy should be implemented. The MDEQ has observed the groundwater contaminant plume expand over the years after implementation of the 1997 Record of Decision (ROD) indicating the need for development and implementation of a contingency remedy).

7. A contingency plan has yet to be developed and approved.

Recommendations and Follow-up Actions: 1 A. Complete an IC study within the Remedial Design to evaluate ICs, revise ICs, and propose an IC monitoring plan.

1B. Develop an IC Plan to document the process to complete the IC study; to evaluate existing ICs (including title work) and determine if additional or revised ICs are required; and for developing an IC monitoring plan within the O&M Plan. (MDEQ: This recommendation should be clarified to require the ICs to comply with MDEQ Restrictive Covenant (RC)/IC guidance and use MDEQ RC/IC models).

2. Determine biodegradation rate along the core of the plume upon completion of baseline sampling. (MDEQ: AMEC completed the baseline sampling, but performed inappropriate degradation calculations and needs to calculate them correctly for this data set from the original plume core. Additionally, the groundwater plume has since migrated further downgradient congruent with the new groundwater flow direction. These changes result in the need to delineate the new plume core; install and sample a new, second set of core monitoring wells along the new plume core; complete new baseline sampling; and perform appropriate degradation rate calculations along this second plume core to address the shift in the groundwater flow direction).

Mr. Nanjunda Gowda 3 December 22,2011

3. Propose additional monitoring well locations and submit the Performance Monitoring Plan for approval. (MDEQ: The additional monitoring wells proposal should include new plume core monitoring wells to track the new groundwater flow direction, additional monitoring wells to evaluate plume migration and extent, and sentinel wells placed upgradient of nearby pnvate water wells that may be impacted by site-related contamination. The groundwater sampling plan should also include sampling the downgradient private wells and corresponding new sentinel wells at a frequency to provide adequate protection to these downgradient receptors).

4. implement a well maintenance plan.

5. Redevelop, rehabilitate, or replace monitoring wells MW-A3, MW-A5, and MW-B11 since they are necessary components of the long-term monitoring network.

6. Propose an adequate and effective contingency remedy.

7. Develop a contingency plan which identifies the triggers that will indicate when additional actions need to take place, indicate what actions will be taken, and the implementation time frame.

MDEQ Future Involvement at Roto-Finish The MDEQ has worked diligently with the USEPA for decades at this site. The MDEQ has repeatedly identified to the USEPA and the responsible parties the same issues as stated in the 2007 SYR with very little progress made to address this failing remedy. The actions requested are the essential components of the 1997 ROD. The remedy chosen for this site is Monitored Natural Attenuation, but the current monitoring network does not adequately monitor the extent of the plume. Degradation rates are supposed to be submitted in each annual monitoring report, yet of the two rates submitted (2003 and 2009), neither one was performed adequately. Very little has changed in the progress of this remedy in achieving the remediation goals or providing adequate protection. Due to limited federal funding, limited staff, and the lack of progress and cooperation at this site, the MDEQ will refrain from further participation on the Roto-Finish site.

If you have any questions or concerns, please contact me either via e-mail at o'[email protected] cr at the phone number given below.

Since

/^y^^^^^or Beth Mead O'Brien Project Manager Budget Tracking and Site Management Unit Superfund Section Remediation Division 517-335-3098

cc: Mr. Steven Padovani, USEPA Mr. Robert Franks. MDEQ Mr. Eric Alexander, MDEQ Mr. Charles Graff, MDEQ

»Roto-Finish Superfund Site File

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mailto:[email protected]

five-year review report third five-year review report

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