five-year review report - united states environmental ... overflowed to an on-site drainage ditch...

EPA Region 5 Records elr.

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334790

Five-Year Review Report

First Five-Year Review Report

for

Shiawassee River Site

Howell, Michigan

August 2009

PREPARED BY:

United States Environmental Protection Agency Region 5

Chicago, Illinois

Approved by: Date:

[This page intentionally left blank.]

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Table of Contents

List of Acronyms 5

Executive Summary 7

Five-Year Review Summary Form 9

I. Introduction 11

II. Site Chronology 12

III. Background 14 Physical Characteristics 14 Land and Resource Use 14 History of Contamination 14 Investigations, Initial Responses, Agency Decisions, and Legal Actions 15 Basis for Taking Action 20

IV. Remedial Actions 21 Remedial Action Objectives 21 Remedy Implementation 21 Institutional Controls 22 Post-remediation Monitoring 23

V. Progress Since the Last Five-Year Review 24

VI. Five-Year Review Process 24 Administrative Components 24 Community Notification and Involvement 24 Document Review 24 Data Review 25 Site Inspection 27

VII. Technical Assessment 27

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and

Question C: Has any other information come to light that could call into question

Question A: Is the remedy functioning as intended by the decision documents? 27

remedial action objectives used at the time of the remedy selection still valid? .... 27

the protectiveness of the remedy? 27 Technical Assessment Summary 27

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VIII. Issues 28

IX. Recommendations and Follow-up Actions 28

X. Protectiveness Statement(s) 29

XI. Next Review 29

Figures

Figure 1 - Site and River Transect Locations 16 Figure 2 - Former CFC Facility Layout.. 17 Figure 3 - Annual average transect post-remediation monitoring data 26

Tables

Table 1 - Chronology of site events 12 Table 2 - Final removal volumes and estimated volumes of soils and sediments

targeted for removal/disposal 22 Table 3 - Institutional Controls Summary Table 22 Table 4 - Summary of average transect annual monitoring data 25 Table 5 - Issues 28 Table 6 - Recommendations and follow-up actions 28

Attachments

Attachment 1 - Michigan Department of Environmental Quality Correspondence Attachment 2 - Site inspection checklist

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CIC

CERCLA

CFC

CFR

cy

EPA

ERG

FDA

FP

ICs

Judgement

mg/kg

MDEQ

MDNR

NCP

NPL

PCB

ppm

PRGs

PRPs

RPM

ROD

RS

Site

SWAC

TSCA

ug/L

UU/UE

2001 ROD

List of Acronyms Community Involvement Coordinator

Comprehensive Environmental Response, Compensation, and Liability Act

former Cast Forge Company facility

Code of Federal Regulations

cubic yards

United States Environmental Protection Agency

Environmental Research Group, Inc.

Food and Drug Administration

floodplain

institutional controls

Consent Judgement by the State of Michigan

milligrams per kilogram (equivalent to ppm)

Michigan Department of Environmental Quality

Michigan Department of Natural Resources

National Contingency Plan

National Priorities List

polychlorinated biphenyl

parts per million (equivalent to mg/kg)

preliminary remediation goals

potentially responsible parties under CERCLA

Remedial Project Manager

Record of Decision

river sediment

Shiawassee River Site

surface weighted average concentration

Toxic Substances Control Act

micrograms per liter

unlimited use / unrestricted exposure

Record of Decision, Shiawassee River Site, September 28, 2001

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Executive Summary

The Shiawassee River Site (Site) includes the former Cast Forge Company facility (CFC) in Howell, Livingston County, Michigan, and approximately eight miles of the Shiawassee River downstream to the Steinacker Road area.

The Cast Forge Company (Cast Forge) purchased the CFC in 1969 and produced aluminum wheels until 1981. Process cooling water related to this production contaminated with polychlorinated biphynels (PCB)-containing oils was discharged to an unlined lagoon, which periodically overflowed to an on-site drainage ditch leading directly to the Shiawassee River. Solids from the lagoon were also spread over the ground east of the lagoon.

Several areas at CFC were historically associated with various waste handling and disposal processes, including the unlined lagoon, a former settling tank and discharge pipe, a former lined lagoon, overflow ditch, an overflow lagoon, and a former discharge area.

CFC is bordered by wetlands, the South Branch of the Shiawassee River, and Highway M59. The river was contaminated with PCBs near the facility and downstream approximately 8 miles to the north. PCB-contaminated sediments were also carried over the river bank to the adjacent floodplain.

After investigations, a removal action was conducted in 1981 by Cast Forge under an agreement between Cast Forge and the State of Michigan. This included removal of 2,531 pounds of PCBs contained in 1,805 cubic yards (cy) of PCB-contaminated sediment and 500 cy of sand.

The Site was placed on the National Priorities List (NPL) in 1983. After subsequent investigations and evaluations, the United States Environmental Protection Agency (EPA) issued a Record of Decision (ROD) for the Site on September 28, 2001. The 2001 ROD required excavation and disposal of PCB-contaminated soils, river and floodplain sediments, institutional controls and monitored natural recovery. To evaluate whether the preliminary remediation goals (PRGs) have been met by natural recovery, the 2001 ROD indicated a comprehensive sampling of the river would be conducted in 2012. However, given the evaluation of post-remediation sampling, EPA will explore whether comprehensive sampling can be expedited.

The remedy is protective of human health in the short term, as exposure pathways that could result in unacceptable risks to humans are currently being controlled. However, in order for the remedy to be protective in the long-term, comprehensive monitoring data needs to show that PCB concentrations are decreasing in accordance with the expectations described in the 2001 ROD. The CFC facility is currently zoned for industrial use and fish advisories are in place. The site is currently being used commercially and it appears that the fish advisories are effective. Long-term protectiveness requires continued compliance with effective institutional controls and while the current site use is consistent with the zoning, EPA will continue working with the property owner to supplement the zoning control with a restrictive covenant for the CFC property. Compliance with institutional controls will be ensured by implementing, monitoring, maintaining and enforcing ICs and by maintaining the fish advisories until such time as fish tissue concentrations decrease to acceptable levels.

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN): Shiawassee River

EPA 10 (from WasteLAN): MID980794473

Region: 5 State: MI Cit ICounty:

NPL status: x Final 0 Deleted 0 Other (specify

Remediation status (choose all that apply): 0 Under Construction 0 Operating X Complete

Multiple OUs?* 0 YES X NO Construction completion date: September 27,2005

Has site been put into reuse? 0 YES X NO

REVIEW STATUS

Lead agency: x EPA 0 State 0 Tribe 0 Other Federal Agency

Author name: James Hahnenberg

Author title: Remedial Project Manager IAuthor affiliation: U.S. EPA

Review period: 10/30/2008 to August 2009

Date(s) of site inspection: April 16, 2009

Type of review: X Post-SARA o Pre-SARA o NPL-Removal only o Non-NPL Remedial Action Site o NPL StatefTribe-lead o Regional Discretion

Review number: x 1 (first) 0 2 (second) 0 3 (third) 0 Other (specify)

Triggering action: o Actual RA Onsite Construction at au #__ X Actual RA Start o Construction Completion o Previous Five-Year Review Report o Other (specify)

Triggering action date (from WasteLAN): 8/27/2004

Due date (five years after triggering action date): 8/27/2009

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Five-Year Review Summary Form, cont'd.

Issues:

1) Additional comprehensive sampling data is needed to determine if the remedy is functioning as intended.

2) EPA is pursuing the implementation of restrictive covenants for the CFC property. Use restrictions, in the form of zoning, are in place and currently effective.

3) Fish consumption advisories for the river are in place and appear to be effective, but additional information needs to be gathered to further assess the effectiveness of the fish advisories.

Recommendations and Follow-up Actions:

1) EPA will contact the PRP to discuss expediting comprehensive sampling.

2) Request restrictive covenants for CFC property; submit IC Work Plan for EPA review and approval.

3) Further evaluate effectiveness of fish advisories.

Protectiveness Statement(s):


Other Comments: none.

Fill in the data below:

Date of last Regional review of Human Exposure Indicator (from WasteLAN): 5/27/2009 Human Exposure Survey Status (from WasteLAN): Current Human Exposure Controlled Date of last Regional review of Groundwater Migration Indicator (from WasteLAN): 5/27/2009 Groundwater Migration Survey Status (from WasteLAN): Not a groundwater site Ready for Reuse Determination Status (from WasteLAN): Undetermined

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I. Introduction

The purpose of five-year reviews 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 issues found during the review, if any, and recommendations to address them.

The United States Environmental Protection Agency (EPA) is preparing this five-year review pursuant to Section 121 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 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.

EPA interpreted this requirement further 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 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.

EPA Region 5 has conducted a five-year review of the remedial actions implemented at the Shiawassee River Site in Howell, Michigan. This statutory review was conducted from October 2008 through August 2009. This report documents the results of the review.

This is the first five-year review for the Shiawassee River Site (Site). The triggering action for this review is the date of the remedial action start for the Site as shown in EPA's WasteLAN database: August 27,2004.

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II. Site Chronology

Table 1: Chronology of site events

Event Date

Release of PCBs 1971 -1976

Unlined lagoon closed and replaced with underground storage tank

1973

MDNR stream sediment sampling discovers elevated PCB levels

1974

Former Cast Forge Company facility (CFC) identified as primary source of PCBs by MDNR

1975

Discharge of process wastewater from lined to unlined lagoons discovered by MDNR

April 1977

Process wastewater transported off-site October 1977

Sediment and fish sampling by MDNR 1977

Unauthorized discharge from CFC reported 1978

Soil sampling by MDNR February 1979

Unauthorized discharge from CFC March 1979

Additional sampling of sediments, soils and ground water by Cast Forge

1980

MDNR fish sampling found high PCB concentrations

June 1981

Sediment sampling in the river June - October 1981

Livingston County Health Department posts fish consumption advisories from the South Branch Shiawassee River from Howell downstream to Owosso, Michigan

July 1981

Michigan Attorney General executes a Consent Judgement with Cast Forge

June 19,1981

PCB contaminated sediments from the river and materials from facility discharge removed

July 1981 - January 1982

NPL Listing Proposal December 30, 1982

Placed on the NPL December 30, 1983

Fish sampling by MDNR July 1985

Signature of Preliminary Closeout Report September 29, 1985

Fish sampling at Chase Lake 1986

Potentially Responsible Parties (PRPs) notified April 16, 1986

Remedial Investigation/Feasibility StUdy started February 19, 1987

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Event Date

MDNR issues a Proposed Plan August 25, 1998

Public meeting for Proposed Plan September 10, 1998

Notification to public that decision on Proposed Plan would be postponed and EPA would assume the lead for the project

July 1999

Additional PCB sampling of soils and sediments 1999 - 2000

Additional sampling of soils at facility November 1999 - April 2000

Supplemental Remedial Investigation/Feasibility Study issued

February 2001

Proposed Plan issued July 9,2001

Record of Decision signed September 28, 2001

UAO issued for Remedial Design April 2, 2002

PRP pre-design sampling 2003

MDEQ submittal to EPA - Technical Memorandum for the Sediment Survey of the South Branch of the Shiawassee River, Howell, Michigan

November 2003

MDEQ submittal to EPA - Technical Memorandum for the Second Phase of the Remedial Investigation Activities at the South Branch of the Shiawassee River, Howell, Michigan

April 2004

Remedial Actions begin November 1, 2004

Consent Decree for Remedial Action entered March 7, 2005

MDEQ submittal to EPA - Technical Memorandum for the Third Phase of the Remedial Investigation Activities at the South Branch of the Shiawassee River, Howell, Michigan

July 2005

Remedial Actions completed August 15, 2005

Pre-final Inspection August 17, 2005

Annual post-remediation sampling August 2006

Additional sediment and soils sampling by MDEQ September 2006 - January 2007

Annual post-remediation sampling July 2007

Annual post-remediation sampling August 2008

MDEQ submittal to EPA - Fourth Phase of the Remedial Investigation Activities

May 15, 2009

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III. Background

Physical Characteristics

The Shiawassee River Site includes the former Cast Forge Company facility (CFC [now called Hayes Lemmerz]), 22440 West Highland Road, in Howell, Livingston County, Michigan, and approximately eight miles of the Shiawassee River downstream to the Steinacker Road area (Figures 1 and 2).

There are several areas at CFC that were historically associated with various waste handling and disposal processes (see Figure 2) as follows:

• an initial unlined lagoon; • a former settling tank and discharge pipe; • a former lined lagoon, overflow ditch, • an overflow lagoon; and • a former discharge area.

CFC covers about 51 acres and is bordered on the north and east by wetlands, on the west by the South Branch of the Shiawassee River, and on the south by Highway M59 (Figure 2). The portion of the river contaminated with polychlorinated biphenyls (PCBs) begins at Highway M59 and proceeds downstream in a northerly direction approximately 8 miles to Steinacker Road. The river ranges from about 20 to 45 feet wide. PCB-contaminated sediment was carried over the river bank to the adjacent floodplain during high flow events.

Land Resource and Use

The South Branch of the Shiawassee River is bordered by forested floodplains, rural areas, and wetlands. Residences are located along the river. No PCB contamination has been found at any of the residences located along the river.

History of Contamination

The Cast Forge Company (Cast Forge) purchased CFC at 22440 West Highland Road in 1969, and produced aluminum wheels there until 1981 when the property was sold. Cast Forge used hydraulic oils containing PCBs during the production of die cast wheels. Based on available records, it is believed that during the years 1971 and 197'2, Cast Forge used significant quantities of PCB oils. It is also believed that Cast Forge purchased 112,500 pounds of these PCB oils. In 1972, the plant changed to a phosphate ester lubricant, but residual PCBs remained in the die-casting equipment until 1976 when it was removed by flushing.

During the period from 1969 through 1974, Cast Forge discharged process cooling water contaminated with PCB-containing oils to an unlined lagoon located to the north of CFC. The lagoon periodically overflowed to an on-site drainage ditch, which led directly to the Shiawassee River. In addition, historical information and aerial photographs show that solids from the lagoon were collected and spread on the ground in the area east of the former lagoon.

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Investigations, Initial Responses, Agency Decisions, and Legal Actions

In 1973, the Michigan Department of Natural Resources (MDNR) became aware of two unauthorized discharges to the river from CFC. The oily waste discharges prompted MDNR to direct Cast Forge to close the unlined lagoon and replace it with an underground settling tank. While the settling tank was effective in controlling solids in the waste stream, it would on occasion overflow into a storm drain leading to the river. As a control measure, hay bales were placed at the outfall in an attempt to absorb the oils.

MDNR conducted a routine stream sediment sampling survey of the South Branch of the Shiawassee River in 1974 and found elevated levels of PCBs. In 1975, MDNR identified the CFC as the primary source of the PCB contamination. In 1976, Cast Forge reported that they had complied with the request of the Michigan Water Resources Commission to flush their equipment in order to remove any residual PCBs. During this period (1974 to 1977), Cast Forge also modified their wastewater system to eliminate the use of the settling tank, replacing it with a synthetic-lined lagoon with a discharge pipe to the wetland area east of the plant buildings.

In April 1977, MDNR staff found that Cast Forge was discharging its process wastewater from the lined lagoon to an area north of where the former unlined lagoon had existed. MDNR ordered Cast Forge to cease the discharge. In response, Cast Forge modified their wastewater system to include an unlined overflow ditch and an overflow lagoon. This modification was an interim measure until a wastewater containment system, constructed inside the building in October 1977, could be placed into service. Thereafter, process wastewater was transported off-site for disposal.

In 1977, MDNR performed sediment and fish sampling in the river. Sediment concentrations of PCBs ranged from 43.7 milligrams per kilogram (mg/kg) (dry weight) near the site (Marr Road) to 0.6 mg/kg (dry weight) in the Shiawassee town Reservoir. All fish species (including carp, minnows, northern pike, black crappies, white suckers, sunfish, rock bass, and bluegills) collected downstream of Cast Forge for a distance of 10.5 miles contained PCB concentrations above the federal Food and Drug Administration (FDA) recommended safe limit of 2 mg/kg. The principal PCB detected was Aroclor 1242. PCB concentrations (40 to 45 mg/kg, wet weight basis) were generally highest in fish collected closest to the site (at Marr Road), although a single carp collected approximately 20 miles downstream contained 240 mg/kg (wet weight). Small fish (minnows, sunfish) were analyzed whole, while portions of a filet were taken from larger fish for analysis.

In 1978, another unauthorized discharge from the CFC to the river was reported. Subsequent investigation by MDNR in February 1979 found Arochlor 1248 in several soil samples collected at the CFC. One sample was found to have a concentration of 41 ,000 mg/kg. Yet another unauthorized discharge occurred in March 1979, which prompted MDNR to install three monitoring wells around the lined lagoon. Sampling from the wells showed low concentrations (0.2 micrograms per liter (ug/l) of Aroclor 1254, and 7.3 ug/I of Aroclor 1242) of PCBs in groundwater to the north and to the east of the lagoon, respectively.

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FIGURE 1 SITE AND RIVER TRANSECT LOCATIONS

LEGEND

SITE AREA

RIVER TRANSECT

Nole: Transect 37 approximately 2.5 miles no<1h oIlhe FOOI1Of CFC Facility.

eENTACT Leading the Nation in Customer Care

- --1" = 1000'

HIAWASSEE RIVER SUPERFUND SITE

1000,

HOWELL,MI

16

-----------~--------~

,..

I. I

FORMER CAST FORGElHAYES LEMMERZ

FACIUTY (2440 WEST HIGHLAND ROAD)

I ' ! 7- __ 4..~~()fWNAGfOJlV£Rr

I - _

'\

\

\ , \ \,

....... ,/

.( ,, \ \ \ \'

, '\

'\ - '-\ \

i ; I ~'...

I / I -

i ! i !

LEGEND

SURFACE DRAINAGE DITCH

BURlED DtSCHAAGEIORAlINAG£ P1PE OR CIA.VERT

FACUTY PERt.lETER FENCE

ry IDENTlFlED WETLAND AREA

FSF5-0EUNEATEO AREA WHERE PCBS >10 mgIKg

100 50 0

Io-..••..I..••-J 1-·101)'

100 !

FIGURE 2 FORMER CFC FACILITY LAYOUT_DE_

17

In 1980, Cast Forge hired Environmental Research Group, Inc. (ERG) to replicate previous MDNR investigations. ERG installed two monitoring wells and collected soil and groundwater samples for analysis. No PCBs were detected in the groundwater, but soil contamination was found at a depth of eight feet in the area of the former storm drainage ditch. A second investigation in the river, from the plant to a distance of ten miles downstream, conducted by ERG during 1980, found PCB Aroclors as high as 150 mg/kg (dry weight) in sediment samples and sediment contamination above 1 mg/kg (dry weight) over the entire river reach. In sediment, Aroclor 1242 was reported as the most frequently occurring PCB, while Aroclors 1248 and 1254 were also detected.

MDNR fish sampling efforts in June 1981 found high concentrations of PCBs in samples collected from 1 to 10.5 miles downstream of the CFC. Sediment sampling in the river conducted in June, July and October of 1981 also detected PCB contamination. In July 1981, the Livingston County Health Department posted warnings against the human consumption of fish from the South Branch Shiawassee River from Howell downstream to Owosso, Michigan.

On June 19, 1981, the Michigan Attorney General executed a Consent Judgement (Judgement) with Cast Forge that had been under negotiation since 1977. The JUdgement directed that Cast Forge undertake the following actions at the plant site and in the affected river:

o Reroute the existing storm drain north of the plant building;

o Install soil erosion protection (a berm);

o Remove PCB-contaminated muck from the discharge area west of the plant and from the river;

o Remove the lined lagoon including standing water, sediments, and the plastic liner;

o Remove contaminated soil from the flatlands area;

o Properly transport and dispose of all contaminated material at an off-site facility; and

o Pay the State of Michigan $700,000 in natural resource damages and $50,000 to reimburse the State for costs incurred in cleanup actions in the river.

The overflow lagoon and spillway were removed prior to issuance of the Judgement. Though EPA was a not a signatory to the 1981 Consent Judgement, it did review drafts of the settlement agreement and participated in the settlement discussions. In addition, the Regional Counsel for Region 5 provided Cast Forge with a letter which stated that since the agreement required that the work would be done in compliance with Federal law, EPA had no objections to the entry of the Consent Judgement. The Consent JUdgement contained the following provision: "Any cleanup of the south branch of the Shiawassee River shall hereafter be the responsibility of the State of Michigan and not of Cast Forge."

A-1 Disposal of Plainwell, Michigan, was contracted to undertake the cleanup of the plant site during JUly and August of 1981, under MDNR oversight. A second cleanup contract

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was awarded to A-1 Disposal in January 1982 to address the discharge area west of the plant and the river. The goal of this project was to reduce the concentration of PCB contamination in stream sediments for a distance of approximately eight miles downstream of CFC. A backhoe was used to remove PCB-contaminated material from around the discharge area and a dragline was used to remove contaminated sediments from an area in the river near Bowen Road. Vacuum extraction via a series of hoses and tanks was also used to remove the PCB contaminated sediments from the river. As most of the PCBs were determined to be tied up in organic material in the river, the vacuum action focused on removing the organic material without taking in the surrounding sand and gravel material. This sediment removal took place primarily in the section of the river between CFC and Bowen Road. Solids from the vacuum operation were removed by a filtration system, which included three filters in series. The dewatered solids and spent carbon from the filters were then transported to a licensed landfill permitted to take PCB-contaminated wastes of this type.

The removal effort resulted in the collection of an estimated 2,531 pounds of PCBs in 1,805 cubic yards (cy) of river sediment and 500 cy of sand and gravel used as filter media. Pursuant to the federal PCB Spill Cleanup Policy, 40 CFR 761.60, and the Toxic Substances Control Act (TSCA), the contaminated sediments, sand and gravel were segregated into two fractions based on concentration. Solids with PCB concentrations of 50 mg/kg or greater (approximately 260 cy) were segregated from approximately 2,045 cy of solids having lower PCB concentrations which did not subject them to TSCA standards. These materials were transported off-site for disposal at an approved licensed landfill. Although the sediment removal project was intended to clean up a total of eight miles of the river, it ended at the end of 1982 after extending only 1.5 miles downstream, due to the costs of the removal being higher than anticipated. As a result, the Site was placed on the NPL in September 1983 with the State taking the lead in conducting the remedial investigation of the Site.

Fish sampling was conducted by the MDNR, Surface Water Quality Division, in July 1985. The sampling was conducted at two locations downstream: Byron Road, approximately 9 river miles downstream of the CFC, and New Lothrup Road, approximately 1.5 river miles downstream of the confluence of the South Branch Shiawassee River with the Shiawassee River. PCB concentrations continued to exceed the FDA 2.0 mg/kg safe limit for fish at both the Byron Road and New Lothrup Road locations.

Fish tissue samples were also collected by MDNR during 1986 in the vicinity of Chase Lake Road. Results of the sample analyses indicated PCBs at concentrations greater than the FDA safe limit of 2.0 mg/kg in 18 of 20 fish samples. The highest concentrations were found in carp, which ranged from 4.9 to 45.0 mg/kg PCBs.

In July 1999, the Michigan Department of Environmental Quality (MDEQ) issued an information bulletin informing the public that the decision on the remedy would be postponed until additional investigations concerning the extent of PCB contamination were performed. It also informed the public that EPA would take over the lead of the investigation and remediation of the Site.

Additional sampling at CFC began in November 1999 and was completed in April 2000. This sample data was released to the public in the Data Evaluation Report dated May 2000. In February 2001, a Supplemental Feasibility Study report was issued to the public based on an evaluation of PCB samples obtained at the Site in late 1999 and early 2000. On July 6, 2001,

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EPA issued a revised Proposed Plan and on September 28, 2001, a Record of Decision (ROD) was signed for the Site. MDEQ did not concur with the 2001 ROD in a letter dated March 31, 2003.

Basis for Taking Action

Based on the risk assessment, consumption of fish by nearby residents was the only current exposure pathway that was estimated to potentially cause adverse non-cancer health effects. The Cast Forge facility was evaluated as if the area remained zoned for industrial use. The concentration in soil on the Cast Forge property was used to assess the level of risk of exposure to soils surrounding the residences. Under these assumptions, the magnitude of cancer and non-cancer health risks in the future is essentially the same as for current industrial land use conditions. Thus, residents are the group at greatest risk from contaminant exposure, due primarily to fish consumption.

Other than the remedial activities described below, site conditions are unchanged since the 2001 ROD.

Groundwater Contamination

MDNR collected groundwater samples from five monitoring wells and one private well on the former CFC facility during January 1988. None of these samples contained detectable concentrations of PCBs. Therefore, no action regarding ground water was required in the ROD.

Soil and Sediment Contamination

Investigations conducted prior to the ROD showed PCB contamination in soils and sediments at levels that presented a risk to human health primarily by fish consumption.

Comparison Between 1988 and 1999 PCB Analytical Results

Analysis of 1988 and 1999 data for the Site indicated that PCB contamination was decreasing steadily in the river, although still at levels indicating unacceptable potential risks to residents. As stated in the 2001 ROD:

"Comparison between the 1988 and the 1999 PCB analytical results show some important trends in the data: increased PCB concentrations at Transects 7 (non-detect in 1988 vs. 300 mg/kg in 1999 in river sediment (RS)) and 9 (15 mg/kg vs 99 mg/kg in the floodplain (FP)), and significantly reduced PCB levels in Transects 12 through 19, 21, 23 and the remainder of the 8 mile reach. For example, Transect 12 in 1988 had concentration levels of 137, 400, and 147, mg/kg FP and in 1999 had levels of nondetect to 0.71 mg/kg. Similarly, Transects 14 and 16 had PCB levels in 1988 at 32, 767, 102, 63 mg/kg FP, 2 mg/kg RS and 49, 76, 20 mg/kg FP, 1 mg/kg RS respectively; whereas PCB levels in 1999 had increased slightly to 7 mg/kg RS but been reduced to 2, 4, 5 mg/kg FP at Transect 14 and 3, 7,10 mg/kg FP and non-detect to 0.78 mg/kg RS at Transect 16.... Analysis of all the historical data of the Site showed that PCB contamination was decreasing steadily in the river. "

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Contaminant Migration

Based on the comparison of data from 1988 and 1999, the PCBs appeared to be dispersing downstream from the CFC facility, without accumulating in any particular location. Sampling in the Shiawassee town Reservoir and Shaw Lake downstream of the CFC facility, which would act as sediment traps for material moving downstream, primarily showed nondetectable levels of PCBs.

IV. Remedial Actions

Remedial Action Objectives

The remedial action objective is to protect human health and the environment from imminent and substantial endangerment due to PCBs attributed to the Site. To achieve this remediation objective, the ROD called for PCB-contaminated sediment above 5 mg/kg to be removed so that the five-mile reach of the river beginning at M-59 would reach an average PCB sediment concentration of approximately 1 mg/kg (which is equivalent to 1 part per million (ppm)) immediately after active remediation; the ROD then called for monitored natural recovery over time to achieve the long-term preliminary remediation goals (PRGs). The long-term PCB PRG range for the Shiawassee River sediment, 0.003 to 0.2 mg/kg, is based on protecting mink through dietary consumption of fish. The ROD estimated that it would take 18 years and 7 years, respectively, to attain these long-term goals by natural recovery processes.

Remedy Implementation

The remedy selected in the 2001 ROD required excavation and off-site disposal of PCBcontaminated soils, and river and floodplain sediments, and that institutional controls be placed on the CFC property to ensure that it remained zoned for industrial use. Therefore, the following actions were taken from November 1, 2004, to August 15, 2005:

• Excavation of 154 cy of PCB-contaminated soils at CFC and disposal off-site. • Excavation and off-site disposal of 160 cy of PCB-contaminated floodplain soil at four

different locations. • Removal and off-site disposal of 50 cy of PCB-contaminated river sediments.

A total of 364 cy of PCB contaminated sediments and soils were excavated.

Additional sampling and evaluations performed during pre-design activities reduced the quantities required for remediation that had been estimated in the 2001 ROD. Volumes estimated in the 2001 ROD and volumes actually removed during remedial actions are summarized in Table 2 below. The reduced volumes of sediments and soils removed relative to the 2001 ROD volumes estimates are due to more detailed characterization conducted during the design phase which indicated a smaller volume of PCB contamination exceeding 2001 ROD cleanup standards.

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Post remediation monitoring is required to ensure that natural recovery of the river is occurring, including comprehensive sampling currently scheduled for 2012.

Table 2. Final removal volumes and estimated volumes of soils and sediments targeted for removal/disposal

Site sub-area . '

2001 ROD removal volume estimate (cy)

F.inalremO"al '. volume' fey)

PRG (mg/kg) .

CFC soils 795 154 10 River sediments 1600 50 51

Floodplain sediments 561 160 10 Total 2956 364 --

1 First mile of river only; sediments above 5 mg/kg were to be removed in order to reach an average concentration of 1 mg/kg.

Institutional Controls

Institutional controls (ICs) are required to ensure the protectiveness of the remedy. ICs are non-engineered instruments, such as administrative and legal controls that help to minimize the potential for human exposure to contamination and that protect the integrity of the remedy. ICs are required to assure the long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure (UUlUE), and are requ~red to maintain the integrity of the remedy. ICs are required at the Shiawassee River Site because PCB contamination remains at the Site above levels that would allow for unlimited use or unrestricted exposure.

Table 3 below summarizes the institutional controls that are in place and/or needed for the areas of the Site that do not allow for UU/UE.

Table 3. Institutional Controls Summary Table .'

Media, Engineered

Controls & Areas IC IC Instrument Implemented or that Objective Planned

Do Not Support Uu/UE .

CFC facility* Restrict the site to industrial use Zoning for industrial use (in place); Planned: Deed restriction with current owner and/or maintaining zoning for site.

River* Prevent consumption of fish Fish consumption advisories (in place)

..*Maps which depict the current conditions of the site and areas which do not allow for UU/UE will be developed as part of the Ie Work Plan discussed below.

Current Status of Access and Use Restrictions (Institutional Controls)

River Restrictions: There are current fish advisories for the Shiawassee River. These advisories will be maintained until the levels in fish fall within an acceptable level for

22

consumption. EPA does not currently have any information indicating that fish consumption is occurring. However, additional information needs to be gathered to further assess the effectiveness of the fish advisories.

CFC site: The CFC site is currently zoned for industrial use, which is in compliance with the required IC objectives. However, the restrictive covenant required by the 2001 ROD has not yet been put in place for the CFC site due to the unwillingness of the property owner to sign such a restriction. The current PRP performing the remedy, Johnson Controls, and EPA will again, in the next six months, request that the current property owner implement such a restriction. This requirement will be included in the IC Work Plan discussed below.

Follow-up Actions Required: EPA sent a letter to Johnson Controls on October 20, 2008, requiring an IC Work Plan which embodies certain IC evaluation activities, implementation of the deed restriction for the CFC property called for in the 2001 ROD, and planning for long-term stewardship. The IC Work Plan will plan to implement the required ICs and plan for long-term stewardship to ensure that the ICs are maintained, monitored and enforced. IC evaluation activities are in progress. If needed, an IC Plan will be developed by EPA.

Current Compliance: Based on the Site inspection and data, EPA is not aware of site or media uses which are inconsistent with the stated objectives of the ICs and cleanup goals. Fish consumption advisories are presently in-place and appear to be effective. Proprietary ICs are not in place, but the CFC property is currently being used only for industrial purposes in accordance with zoning requirements. Therefore, at this time, the remedy appears to be protective in the short term since the Site is not being used in a manner which is inconsistent with the required use restrictions or ICs. Long-term protectiveness requires continued compliance with effective institutional controls and while the current site use is consistent with the zoning, EPA will continue working with the property owner to supplement the zoning control with a restrictive covenant for the CFC property.

Long-Term Stewardship: Long-term protectiveness at the Site requires compliance with use restrictions to ensure the Site is not being used in a manner that is inconsistent with the IC objectives. To assure proper maintenance and monitoring and effective ICs, long-term stewardship procedures will be reviewed and a plan developed.

Post-remediation Monitoring

Following completion of the remedial action construction activities in 2005, annual monitoring was conducted in August 2006, July 2007, and August 2008, with each sampling event consisting of 30 samples of PCB-contaminated river sediments. These results are presented in a report by ENTACT LLC, entitled Sediment Summary Report for the Shiawassee River Superfund Site, prepared for Johnson Controls, Inc., May 26,2009 (ENTACT Report). Additionally MDEQ completed sampling and analysis in 2006 and early 2007, with the results presented in a report by Gannett Fleming (for Michigan Department of Environmental Quality, Remediation and Redevelopment Division), entitled Technical Memorandum for the Fourth Phase of the Remedial Investigation Activities at the South Branch of the Shiawassee River, Howell, Michigan, dated December 2008 (MDEQ Report). The data collected to-date are further discussed in Section 6 of this report, below.

23

Annual monitoring is currently planned to be conducted on an annual basis, with a comprehensive monitoring event currently scheduled for 2012. Monitoring requirements after 2012 will be determined after evaluating the data from the comprehensive monitoring event.

V. Progress Since the Last Five-Year Review

This is the first five-year review for the Site. The triggering action was the initiation of the first remedial action that began August 27,2004, with the start of soil and sediment excavations. In 2004 and 2005, 364 cubic yards of PCB-contaminated sediments and soils were excavated and disposed off-site. Post-remediation sampling was conducted in 2005, 2006, 2007, and 2008. This five-year review is required because hazardous substances, pollutants, or contaminants remain above levels that allow for unlimited use and unrestricted exposure.

VI. Five-Year Review Process

Administrative Components

This Shiawassee River Site five-year review report was prepared by James Hahnenberg, EPA Remedial Project Manager. The five-year review consisted of a Site inspection and review of relevant documents and data. EPA sent a letter on October 30, 2008, to Daria Devantier, MDEQ, notifying the State agency that EPA was initiating a five-year review. MDEQ sent a letter to EPA on May 15, 2009, addressing continuing concerns regarding State cleanup requirements and institutional controls. (See Attachment 1.)

Community Notification and Involvement

Via advertisements placed in the April 10, 2009, Livingston County Daily Press and Argus, EPA informed the community that a five-year review effort had commenced for the Site. Readers of the notice were given information as to the location of local site information repositories, and were provided names, mailing addresses, toll-free and direct dial phone numbers, and e-mail addresses of both the EPA Community Involvement Coordinator (CIG) and the Remedial Project Manager (RPM) for further information. The notice requested that interested persons relay any information of interest, comments, or site matters to either the CIC orthe RPM.

Community interest regarding the Site has been minimal. Previous meetings and discussions with residents indicate few issues of concern to the community.

Document Review

The primary documents reviewed were analytical results and evaluations and postremediation sampling by ENTACT, presented in the 2009 ENTACT Report, and the MDEQ data collected in 2006 and early 2007 and presented in the 2008 MDEQ Report, both of which were mentioned above. Additionally, a review of both reports by EPA Region 5 FIELDS personnel was considered. Other documents reviewed included EPA's 2005 Preliminary Closeout Report and the 2001 ROD. The complete list of documents reviewed is as follows:

24

• ENTACT, Sediment Summary Report for the Shiawassee River Superfund Site, prepared for Johnson Controls, Inc., May 26,2009 (ENTACT Report).

• EPA, FIELDS, Comparison of 2003 ENTACT sediment PCB data with 2006 MDEQ's, July 22, 2009.

• EPA, FIELDS, Histograms and Statistics for Pre-Remediation (1999, 2003) and Post-Remediation (2006, 2007, 2008) Sampling, June 26, 2009.

• EPA, FIELDS, Shiawassee River Superfund Site: Analysis and Comments on ENTACT 2009 Report, July 9,2009.

• EPA, FIELDS, Shiawassee River Superfund Site: Mann-Kendall Statistical Analysis and Comparison to ENTACT 2009 Results, July 9,2009.

• EPA, Preliminary Closeout Report, Shiawassee River Site, Howell, Michigan, September 28, 2005.

• Gannett Fleming, Technical Memorandum for the Fourth Phase of the Remedial Investigation Activities at the South Branch of the Shiawassee River, for the Michigan Department of Environmental Quality, December 2008 (MDEQ Report).

• Letter dated May 15, 2008, from Daria Devantier, MDEQ, to James Hahnenberg, EPA, with enclosures (Attachment 1).

Data Review

The 2001 ROD indicated the PCB PRG of 0.2 ppm would be met within 7 years following the completion of cleanup activities, i.e., in 2012. However, as discussed below, the data contained in the ENTACT and MDEQ Reports do not indicate that the 0.2 ppm goal will be met in 2012, as prescribed in the 2001 ROD, by natural recovery processes. More specifically, the ENTACT Report does not show a consistent decrease in PCB concentrations in sediments, as summarized in Table 4 and Figure 3 below.

a e4. s f average transect annual mOnitoring data T bl ummary 0

Year Transect 2003' 20062 .. 20072 20082

S-21 (S-N) - 0.071 0.098 1.098 S-21 (C-S-N) - 41.275· 9.163 14.723

T-10 4.800 0.293 0.384 1.490 T-11 0.615 0.315 0.998 1.378

T-12N 1.296 0.746 0.529 1.843 T-12S - 0.488 0.572 1.574

Ave. T-10, T-11, T-2N 2.237 0.451 0.637 1.570 Ave. all transects - 7.304 1.957 3.684

Table Footnotes 1 From Appendix E, Summary of Data Used for Mann-Kendall Trend Analysis, ENTACT Report. 2 From Table 4, ENTACT Report.

25

Additionally, utilizing data from the ENTACT Report, EPA Region 5 FIELDS personnel employed a nonparametric Mann-Kendall Statistical Test for trends to evaluate potentially decreasing PCB trends from 1999 through 2008. This analysis found no statistical evidence of a downward trend in PCB concentrations in sampled river sediment.

Based on EPA's review of the data described above, the following conclusions have been made:

• The surface weighted average concentration (SWAC) for the site may not be below the 2001 ROD goal of 1 ppm for PCBs that the ROD anticipated would be achieved immediately following active remediation activities.

• Monitored natural recovery appears not to be occurring and it is unlikely that the ROD goal of reaching a PCB SWAC of 0.2 ppm will be met by 2012 (within 7 years following the completion of active remediation activities as per the 2001 ROD).

MDEQ's sample results are generally consistent with the data in the ENTACT Report. However, there are questions regarding the spatial accuracy of some MDEQ sample locations and data quality issues in the MDEQ Report. MDEQ has committed to work with EPA to resolve these questions. Once these concerns are addressed, MDEQ ~esults will be given further consideration.

Annual average transect post remediation monitoring data

Average PCB Concentrations (ppm)

1.6

1.4

1.2

1

0.8

0.6

0.4

0.2

o 20082006 2007

Years

Figure 3. Annual average transect post-remediation monitoring data

26

Site Inspection

EPA made arrangements with PRP representatives and their consultants to be present at a site inspection conducted on April 16, 2009. The inspection examined the river and the CFC facility to determine if site conditions had changed and to confirm the current remedy status of ongoing remedial activities. Site conditions are unchanged since active remedial activities were completed in 2005. The site inspection checklist is included as Attachment 2.

VII. Technical Assessment

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

It is uncertain if the remedy is functioning as intended by the 2001 ROD. Annual monitoring and other data suggest natural recovery is not occurring. Further evaluation of existing data is needed as well as completion of comprehensive Site sampling.

In the short term, fish consumption advisories are presently in place and appear to be effective. The CFC facility is currently zoned only for industrial use but no restrictive covenant has been placed at the site. Currently, the Site is not being used in a manner that is inconsistent with the required use restrictions or ICs. Thus, exposure, at present, is controlled at the Site. Comprehensive monitoring data needs to be collected (currently scheduled for 2012) to fully evaluate whether the remedy is functioning as intended, and additional information needs to be gathered to further assess the effectiveness of the fish advisories.

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

Yes. Site conditions are unchanged and there are no new promulgated standards.

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

No. Besides the information already discussed in this report, no other information has come to light that could call into question the protectiveness of the remedy.

Technical Assessment Summary

It is uncertain if the remedy is functioning as intended by the 2001 ROD, and currentlyavailable data suggest that monitored natural recovery is not occurring. Fish consumption advisories are in place and appear to be effective, industrial-use zoning is in place for the CFC facility, and the Site is not being used in a manner that is inconsistent with the required use restrictions or ICs. Further evaluation of existing data is needed, as well as completion of comprehensive Site sampling and further assessment of the effectiveness of the fish advisories.

27

VIII. Issues

Table 5. Issues

Issue . ...

Affects Current. Protectiveness

(YIN)

,

Affects Future ,... .Protectiveness

. (YIN) Additional comprehensive sampling data is needed to determine if the remedy is functioning as intended.

N y

EPA is pursuing the implementation of restrictive covenants for the CFC property. Use restrictions, in the form of zoning, are in place and currently effective.

N y

Fish consumption advisories for the river are in place and appear to be effective, but additional information needs to be gathered to further assess the effectiveness of the fish advisories.

N y

IX. Recommendations and Follow-up Actions

Table 6. Recommendations and follow-up actions

Issue Recommendations

and . Follow-up Actions

.

Party Responsible

Oversight! Support Agency

Milestone Date

Affects . Protectiveness·

(YIN)

Current Future

Additional EPA will contact EPA MDEQ October N Y comprehensive the PRP to discuss 31,2009 sampling data is expediting needed to determine comprehensive if the remedy is sampling. functioning as intended

EPA is pursuing the Submit IC Work PRP EPA and December N Y implementation of Plan for EPA review MDEQ 31,2009 restrictive covenants and approval. for the CFC property. Use restrictions, in the form of zoning, are in place and

Request restrictive covenants for CFC property.

PRP EPA and MDEQ

February 28,2010

currently effective.

Fish consumption Further evaluate EPA State December N Y advisories for the effectiveness of fish 31,2010 river are in place and advisories. appear to be effective, but additional information needs to be gathered to further assess the effectiveness of the fish advisories.

28

X. Protectiveness Statement(s)


XI. Next Review

The next five-year review for the Site is required no later than five years from the date of this review.

29

Attachment 1 - Michigan Department of Environmental Quality Correspondence

STATE OF M,CHIGAN

DEPARTMENT OF ENVIRONMENTAL QUALITY LANSING Diet

JENNIFER M. GRANHOLM STEVEN E. CHESTER GOVERNOR DIRECTOR

May 15, 2009

Mr. James Hahnenberg United States Environmental Protection Agency Region 5 77 West Jackson Boulevard (SR-J6) Chicago, Illinois 60604-3590

Dear Mr. Hahnenberg:

SUBJECT: Shiawassee River Superfund Site, Howell, Michigan Five-Year Review Issues, Comments on Draft Sediment Summary Report

The Michigan Department of Environmental Quality (MDEQ) seeks to share with the United States Environmental Protection Agency (USEPA) concerns associated with a site in advance of an upcoming Five-Year Review (5YR). A 5YR is due for this site by August 27,2009. Contained in this letter are continuing concerns the MDEQ has had with this site since the Record of Decision (ROD) non-concurrence letter was issued from MDEQ Director Steven E. Chester on March 31,2003. Essentially, the MDEQ asserted that the cleanup goals selected will not meet state cleanup requirements for polychlorinated biphenyls (PCBs) and that the proposed institutional controls would not extend to those areas off-site where PCBs were intended, by USEPA's design, to remain. The MDEQ continues to believe concepts outlined in this site's ROD will fail to achieve its stated goals.

Correspondence has already been sent continuing this dialogue to which the MDEQ has not received a response. Specifically, in the enclosed letter dated July 7, 2006, the MDEQ asserted that the USEPA's implemented removal work failed to achieve the excavation requirements of the ROD. The letter prOVided a statistical analysis wherein it was found that it is extremely unlikely that the ROD goal of 1 part per million was achieved and that reductions in PCB concentrations are likely dramatically less than those reported in the Preliminary Remedial Action Completion Report. The issues contained within the JUly 7,2006, letter must be addressed in the 5YR.

Since the date of that 2006 letter, the MDEQ undertook, by its own initiative and funding, a comprehensive investigation post-USEPA removal work, as a first step in designing a remedial action to address the risks posed by PCBs in this river. The results of that investigation are presented in the enclosed Technical Memorandum for the Fourth Phase of the Remedial Investigation Activities at the South Branch of the Shiawassee River, Howell, Michigan (Tech Memo). This hard copy is for the Administrative Record for this site. As depicted on the figures contained within this Tech Memo, once you get downstream of the former Cast Forge facility, data points

CONSTITUTION HAlL. 625 WEST ALLEGAN STREET· P.O. BOX 30426 • LANSING, MICHIGAN 48909-7928 www.mlchigan.gav. (517) 373-9837

http://www.mlchigan.gov

Mr. James Hahnenberg 3 May 15, 2009

/.;"\ ,'~ ... ~,/The fact is that at least three removal actions have been implemented at this site

between work the MDEQ and the USEPA have conducted, yet the MDEQ's Tech Memo continues to document PCB levels far in excess of this river's ability to mitigate the PCB's risks via natural recovery. There are insufficient monitoring measures in place through the ROD to ascertain whether risks will appropriately be abated.

If there is any hope in addressing the risks posed by this site, two things must happen. First, comprehensive removal of PCBs at the source must be conducted. Natural recovery is reliant upon burial of contaminated sediments and reduction of interactions with surface water. Much more of the "source material" must be excavated not only from the river itself but from the banks and floodplains as well. Structures such as dams affect depositional processes. It is not a foregone conclusion that the Shiawassee Town Dam will remain on this river. The ROD fails to acknowledge this fact altogether. The basis for the USEPA's sole remaining natural recovery effort will be compromised should there be a catastrophic failure of the dam. No provisions have been made to address this structure as a component of this remedy. The 5YR must address these realities. The MDEQ continues to believe that no amount of time will help the natural recovery of the system to sufficiently address the known ongoing risks from PCBs. It had been the state's objective to implement additional sediment removal at the Shiawassee River using state resources. Given that the state has not yet been able to secure stable, long-term funding for our cleanup program, this is now but a future hope. In lieu of that, it remains the MDEQ's hope that the USEPA will recognize the need for additional sediment removal beyond what was specified in the ROD, and the unlikelihood that natural recovery will ever work in such a dynamic river system as this and take the necessary steps to address these realities.

This letter is also being used to forward comments in regard to the draft Report. There is only time and resource to provide comments general in nature. Additionally, given the MDEQ's continuing non-concurrence of the ROD, it does not make sense to extensively and exhaustively comment on the continuation of an approach the state is already on record as not supporting.

In that vein, there is a reliance on sweeping statements and conclusions that are not supported by an analysis of the data. For instance, on page iv, it states "The data also suggest that weathering processes are affecting PCBs in floodplain soils by concentrating higher chlorinated PCB molecules and potentially making them less mobile. There is also some incidental data suggesting that biodegradation is also affecting PCB concentrations in the river sediments." While data is referenced, the report does nothing to analyze that data to actually support these statements. There are many instances of this type of categorical conclusions of data without textual analysis. On page 20, the Report states that"... there is little if any evidence of significant erosion of surficial floodplain soils back into the river channel." No backup documentation is offered, such that MDEQ could evaluate this conclusion. Where analysis is offered, the MDEQ is likely to have a different interpretation. Page 21 states "The known hotspots have been remediated." While this may be true, it is well understood that, particularly with sparse data sets, the known hotspots are likely only a


significantly above acceptable state aquatic levels for PCBs are depicted. There are also many data points that document exceedances of the USEPA's own ROD for the site as well. Specifically, the ROD states that "... PCB-contaminated sediment will be remediated so that the five mile reach beginning at M-59 of the river will reach an average PCB sediment concentration of approximately 1 mglkg [milligram per kilogram] immediately after active remediation...." The active remediation referred to here is the excavation work that the USEPA conducted in 2004 and 2005. Please note the concentrations depicted in this Tech Memo are noted in mglkg so as to make easy comparisons to the USEPA's ROD objective. It cannot be expected that a dynamic river will successfully cover PCBs and remove those contaminants from the aquatic and, consequently, human food chain when those PCBs are still found in concentrations in excess of the USEPA's own initial excavation goals. The 5YR must address the PCB concentrations documented in this Tech Memo remaining in this river post-USEPA excavation work. It is our expectation that this Tech Memo will be appended to and discussed in the 5YR.

•

Not only does this illustrate that the ROD's immediate objectives were not met, but also illustrates that reliance upon surface weighted average concentrations (SWAC) in developing a remedial action within a dynamic riverine environment is an invalid approach when data are sparse. At this site, the SWAC approach was based on a far too limited data set to make a legitimate remedial propos.al for the site. The USEPA has, in the past, questioned the MDEQ's use of biased sampling at this and other sites to illustrate some of our concerns. Yet, the draft Sediment Summary Report (Report) acknowledges on page 18 that PCBs favor sorbtion onto particulate matter that is organic in nature, particularly finer-grained material. This illustrates not only the need to tailor investigations at riverine environments with PCBs with biased sampling during investigations, but that confirmation sampling strategies in these environments to confirm remedial efforts should include an element of biased sampling as well. The USEPA's confirmation process of its own work failed to take into account the known sorption reality of PCBs and may yet be one more reason why the design and· . implementation of the excavation at this site failed.

Interestingly, the draft Report already foretells that the removal conducted has not set the stage to assure the success of natural recovery. Specifically, early work to document natural recovery's march toward achieVing long-term remedial goals found that by comparing "... the 2007 data to the 2008 data; the average PCB concentration by area increased in all six areas. In one area (at supplemental transect 521-01) the average increase exceeded an order-of-magnitude. Of the 30 sample locations, 29 showed increased concentrations between 2007 and 2008...." Even with the comparison of the decreasing concentrations between 2006 and 2007, it appears that levels are being found that still document failure to have achieved the USEPA's initial excavation objectives that the removal work did not set the stage to allow for natural recovery. This should be expected in a dynamic river: initial appearance of a removal action setting the stage for natural recovery, but persistent action of the river undoing that work.


small percentage of the total such as yet unknown hotspots. This statement conveys a far greater degree of success than is warranted in light of data contained within the MDEQ Tech Memo. Specifically, the MDEQ has identified many hotspots that had not previously been found but that are now documented in the MDEQ Tech Memo. There may also be many other hotspots as the sampling plan was not designed to identify hotspots.

The Conceptual Site Model {CSM} does not acknowledge the effects of groundwater input into the Shiawassee River system in terms of hydrology and the hydrogeology of the floodplain and channel. The CSM does not, therefore, appear to acknowledge the constant interaction of contaminated floodplain and river channel sediments with both surface water and groundwater. In a system where groundwater provides the base flow of the river (such as at the Shiawassee River), the constant flushing and interaction with surface water and groundwater does not provide the basis for a long-term natural recovery.

The MDEQ has reservations with many statements in the CSM, conclusions in regard to fate and transport, SWAC, sampling strategies, etc. and especially with those conclusions found in the Conclusions and Recommendations section.

Please let me know if you have any questions regarding the comments and concerns outlined in this letter. We would be happy to discuss the results of our work in support of your preparation of the draft 5YR. Any advance notice you can give of when the draft 5YR will come would be greatly appreciated.

Sincerely,

Df::~E~~ Specialized Sampling Unit Superfund Section Remediation and Redevelopment Division 517-373-8436

Enclosures cc: Dr. John Kern, Kern Statistical Services, Inc.

Mr. David Kline, MDEQ Mr. James Heinzman, MDEQ Mr. John Bradley, MDEQ Mr. Matthew Baltusis, MDEQ

STATE OF MICHIGAN

DEPARTMENT OF ENVIRONMENTAL QUALITY LANSINO DIG

JENNIFER M. GRANHOLM STEVEN E. CHESTER GOVERNOR DIRECTOA

July 7,2006

Mr. Richard C. Karl, Director Superfund Division United States Environmental Protection Agency Region 5 77 West Jackson Boulevard (S-6J) Chicago, Illinois 60604-35490

Dear Mr. Karl:

SUBJECT: Preliminary Remedial Action Completion Report for the Shiawassee River Superfund Site, Howell, Michigan.

The purpose of this letter is to provide additional comment concerning the Preliminary Remedial Action Completion Report (PRACR) for the Shiawassee River Superfund site and to express concern with how the United States Environmental Protection Agency (USEPA) is using the surface weighted average concentration (SWAC) process to designlimplement and evaluate the effectiveness of sediment cleanups.

The Shiawassee River PRACR was received in this office on November 16, 2005. The Michigan Department of Environmental Quality (MDEQ) provided comments via a January 6, 2006, letter to the remedial project manager. Since providing these comments, we have solicited the services of a statistical consultant to assist us in evaluating USEPA's claims about reduction of polychlorinated biphenyl (PCB) levels in Shiawassee River sediments. We had originally intended to share and discuss the results of this statistical evaluation and other site issues during our mid-year review meeting. However, since the mid-year review meeting was canceled, we are describing our concerns with the SWAC process and implementation of this remedy in this letter.

The Record of Decision (ROD) remedy·for this site combined active remediation of sediment and floodplain soils with monitored natural recovery. The MDEQ, in a letter dated March 31, 2003, from Director Steven E. Chester, did not concur with the remedy identified in the ROD because the remedy would not meet state cleanup requirements for PCB within the sediments and floodplain soils, and because the downstream extent of the remedy was not sufficient. As described in the ROD, only a portion of the contamination was to be addressed, and institutional controls were to be limited to only the fonner Cast Forge Company (CFC) property, even though institutional controls are necessary on the contaminated floodplain properties where contamination will remain in place above applicable state criteria. This being the case, the ROD remedy will not be protective of human health and the environment.

• Putting aside the disagreements over the ROD cleanup levels and institutional controls desaibed above, the remedy, as implemented, removed only about 360 cubic yards which is only 12 percent of the 3000 yard amount of contaminated material described as needing to be removed in the selected ROD alternative. Also, of the 360 cubic yards removed only 50 cubic yards were river sediments rather than the 1600 cubic yards of river sediment that were to be removed per the ROD.

CONSTTTUTJON HALL· 625 WEST AlLEGAN STREET °P.Q BOX 304211 • lANSING. MICHIGAN 48909-7928 www.mlchlgan.llIllI o (517) 373-9837

Mr. Richard C. Karl 2 July 7,2006

We are concerned about the amount of PCB concentrations reduction claimed for river sediments as a result of the remedy. Per the ROD, the USEPA's goal was to achieve a post remediation SWAC of 1 parts per million (ppm) along the first five-mile stretch of river downstream of the CFC Facility. Attached is a statistical review of the Preliminary Remedial Action Completion Report: Shiawassee River Superfund Site, Howell, Michigan, which was prepared by Kern Statistical Services, Inc. (Kern) for the MDEQ. This review indicates that it is extremely unlikely that the ROD goal of 1 ppm was achieved and the reductions in PCB concentrations are likely dramatically less than those reported in the PRACR. The basic conclusion of the review by Kern is that it is likely that the sediment remediation activities undertaken at the site had no substantive effect on PCB concentrations in the river sediments and consequently resulted in little or no risk reduction. Based on the methodology used in the Kern memo it is estimated that the remedial activities resulted in the PCB concentration in surface sediment being reduced from 1.4 ppm to 1.37 ppm in the first five-miles downstream of the CFC Facility.

We have attached this statistical review so that this statistical evaluation can be used to better guide future work at the Shiawassee River site. In addition, we continue to maintain that long-term sediment monitoring should be supplemented with fish tissue monitoring since fish tissue consumption is the basis for the risk assessment and sediment remediation levels selected in the ROD.

We request that the USEPA consult with the MDEQ prior to initiating future projects in Michigan where the USEPA plans to use the SWAC process to guide remedial decisions or evaluate cleanup effectiveness. In such instances appropriate staff at both agencies should engage in substantive discussions, so that the agencies can agree on how best to define the extent of sediment contamination and estimate the effectiveness of remedial effQrts prior to the selection and implementation of these remedies.

If you have any questions regarding the issues presented in this letter, please contact Mr. David Kline at 517-373-8354 or you may contact me.

Sincerely,

~4,. :;fJ Andrew W. ~arth, Chief Remediation and Redevelopment Division 517-335-1104

Attachment cc: Ms. Wendy Carney, USEPA

Mr. Larry Schmidt, USEPA Mr. James Hahnenberg, USEPA Dr. John Kern, Kern Statistical Services, Inc. Mr. David Kline, MDEQ Mr. George Jackson, MDEQ Mr. Matthew Baltusis, MOEQ Ms. Sunny Krajcovic, MDEQ Shiawassee River Superfund Site File

5175 NE River RD Sauk Rapids MN

Tel: (320) 230-5185 Fax: (320) 230-5251

[email protected]

To: Janet Kracjcovic Michigan Department ofEnvironmental Quality Remediation and Redevelopment Division Superfund Section

From: JohnW.Kcm

Re:

cc:

Review of. Preliminary Remedial Action Completion Report: Shiawassee River Superfund Site, Howell, M1

Date: 05122105

Following is a review of the Preliminary Remedial Action Completion Report: Shiawassee River Superfund Site, Howell, Michigan written by ENTACT and Associates, LLC (ENTACO on behalfof Johnson Controls Industries for United States Environmental Protection Agency (USEPA) Region V. This review was conducted by Kern Statistical Services, Inc. for the Michigan Department ofEnvironmental Quality (MDEQ). This review focuses on the validity ofreported estimates ofreducDon ofPCB concentration in surface sediments as a result ofremedial actions conducted at the site.

Summary Findings 1) The estiniates ofpost-remedial surface PCB concentrations reported in the Preliminary Remedial

Action Completion Report (PRACR) W1derestimate actual post-remedial concentrations. 2) Based on independent estimates reported in this memorandum, post remedial surface PCB

concentration at the site were reduced by less than 0.2% within the fl1St mile downstream ofthe facility and even less within the first five miles downstream of the facility.

3) In order fur the EPA remedy to have achieved the stated level ofsuccess wouJd require that aJJ PCB deposits were identified and properly delineated and that PCB concentrations within the removed sediments exceeded 394ppm. Based on sampling conducted during the remedy, very little ofthe remediated sediments exceeded 50ppm. Therefore the stated level ofrcducDon in PCB concentnltion is extremely unlikely.

4) Based on sampling conducted downstream ofthe site by Gannett Fleming, it is believed that PCB contamination is pervasive throughout the in-stream sediments to depths ofat least three feet. There is little geological evidence that PCB contamination is consolidated within small isolated deposits but rather that contamination is wide spread throughout the river.

5) Floodplain PCB data reported in the PRACR were not reviewed in detail, but due to the small extent ofthe areas where soils were removed, it is anticipated that success was similarly over stated in the PRACR.

Introduction The PRACR states that prior to the remedial actiOD, average surface concentrations in sediments in the river were approximately 3.0 ppm and 1.4 ppm in the tirst mile and first 5 miles downstream ofthe facility respectively. PCB contaminated sediments were removed from an approximately 749 ~ area in the first mile ofthe river. The RA completion report indicates that post removal PCB concentrations in surface sediments are currently 1.14 ppm and 0.88 ppm in the flJ'St 1- and S-miles downstream oftie site respectively. Although less than one one-hundredth ofa percent ofthe totaJ surface area was remediate, the PRACR estimated that surface PCB concentrations were reduced by 61% and 37% respectively. In what follows, it is ShOWD that this magnitude ofreduction in the surfitce average concentration is not plausible due to the smalllateraJ extent of the remedial footprint. To achieve these levels ofreduction, in the first mile downstream ofthe site, pre-remedial surface concentrations within the removal footprint would have bad to exceed at least 394ppm. Similarly, to achieve the estimated reduction in the first S miles would have

KERN StaUsUcal Servlc:u, Inc. Last printed 512412006 12:30 PM DRAFT Page 10f3

required that the pre-remedial concentration in the removal footprint exceeded SS4ppm (Equation (1) AND Table I). Given that ENTACT reportedly tested the sediments removed from the river and found very little sediment exceeding the SOppm TSCA limits, the estimated reductions in surface concentration are extremely unlikely. Because the remediated areas were so small the effect of the sediment removal was essentially negligible.

Methods 'The measure of effectiveness reported by ENTACT in the PRACR was the estimated reduction ofPCB concentration in surface sediments. 'The methods used to estimate this average are biased because they WI to account for the almost certain presence ofadditional unremediated "hot spots" ofsimilar size and nature to those detected by the sampling design. In what follows a mathematically justified method is described for estimating the reduction in PCB concentration as a result ofremoving selected known PCB deposits.

Define 8 1 to be the area from which sediment is to be removed and B3 to be the area of the remainder ofthe

site. Given unbiased estimates, 11 and 12 ofthe surface averages within these areas respectively, the overall average can be written as the spatially weighted average of these two values

Defining ZI ptUl to be the post remedial concentration in area B1 it can be shown that the reduction in

average PCB concentration is given by

2Reduction=( B1 )X~I-ZIPO.,) Bl+~

In 'Words. the reductIon In surface average is given by the proportion of the area of the site remediated multiplied by the reductIon in concentration within that area. So reduction in surface concentration requires either remediation ofa significant proportion of the site or large reductions in concentration within the remediated area.

Remedial areas and pre- and post-cleanup PCB concentrations reported by in the PRACR were used as inputs to, Equation (2) to estimate the reduction in PCB concentration at the site. Additionally, Equation (2) was rearranged and solved for the difference in pre- and post-remedy PCB concentration that would correspond with the reported overall average concentration.

Results The PRACR reported that the pre-remedial surface sediment PCB concentration was 3.0ppm in the first mile and I.4ppm in the first Smiles downstream ofthe facility. Subsequent to the removals the postremedial PCB concentrations were estimated to be I.l6 and 0.88 respectively (Table I)ffor an reduction of by 1.84ppm and 0.S2ppm respectively as a result ofthe remedy.

A total of749 square feet (0.017acres) were remediated and the averages ofthe reported pre- and postremedy concentrations within the remedial footprint were approximately 41ppm and Sppm respectively. So within the remedial footprint concentrations were apparently reduced by 36ppm. The total surface area of river sediments was not reported, however assuming that the river is approximately 30 feet wide, one arrives at areas of3.6 acres within the first mile and 18.2 acres within the fust five miles. On an area basis 0.47% (0.01713.6) ofthe first mile was and 0.09% (0.0017/18.2) ofthe first five miles was remedia!ed. The estimated reduction in PCB concentration based on Equation (2) is (0.0047x36=O.17ppm) within the first mile downstream ofthe facility and (0.OO09x36=O.03ppm) in the first five miles downstream ofthe facility. These reductions are dramatically less than those reported in the PRACR. Based on these estimates it is likely that the sediment remediation activities undertaken at the site probably

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Last printed 512412006 12:30 PM Draft Page 2 of3

had no substantive effect on surface PCB concentrations and consequently resulted in little or no risk reduction.

The PRACR reported PCB reductions of 1.84ppm and O.52ppm in the first mile downstream and first five miles downstream of the site respectively. These estimates are much lower than that obtained by application ofEquation (2) above. Based on the methods descn"bed above post remedial PCB concentration in surface sediment is estimated to be 2.83ppm and 1.37ppm in the fll"st mile and first five miles downstream ofthe facility respectively. If the PRACR estimates area accurate, it would be necessary for the surface sediments in the remediated footprint to exceed 394ppm and 554ppm for the first mile and first five mile estimates respectively.

Discussion PRACR estimates ofpost remedial surface PCB concentrations are significantly lower than those obtained through the methods documented above. The PRACR method underestimates post-remedial concentrations because it is insensitive to the size ofthe area ofthe remediated footprint and does not account for the high likelihood that UDl'Cmediated and unsampled areas can be expected to contain deposits ofPCB contaminated sediments similar to those that were remediated. It is unreasonable to expect that remediation of less than 1 percent ofthe aerial extent ofriver sediments could reduce the overall average by over 50% as reported in the PRACR. The reported reductions would only be possible ifthe contaminated sediments are distributed within very small consolidated deposits and that these deposits have been identified and accurately delineated. Given that the PCBs were transported as oil it is much more likely that PC B contamination would be widely distributed within the sediments.

•

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• •

Table 1. Implication. of EPA e.timatel of polt-remedlal SWAC. USEPA Estimate. (ppm)

Pr. Eltimated Remadlatlon Po.toRemedlation Reduction

Mila 1 3 1.18 1.14 Mila 1·5 1.4 0.88 0.52

Revill8d Estimates

TotalNea Remedlated Percent Estimated Poat Back Calculated Footprint

~ (Aa!I) Remedlated Remedy SWAC Average <ppm)' 3.8 0.017 0.47% 2.83 384 18.2 0.017 0.09% 1.37 554

Notal: 1) MInimum lIyerage lurtace concentration neceuary for EPA e.timatel to be accurate•

Attachment 2 - Site inspection checklist

OSWER No. 9355.7-03B-P

Please note that "O&M" is referred to throughout this checklist. At sites where Long-Term Response Actions are in progress, O&M activities may be referred to as "system operations" since these sites are not considered to be in the O&M phase while being remediated under the Superfund program.

Five-Year Review Site Inspection Checklist (Template)

(Working document for site inspection. Information may be completed by hand and attached to the Five-Year Review report as supporting documentation ofsite status. "N/A" refers to "not applicable.")

I. SITE INFORMAnON

Date of inspection: A I/) f ~ I It, }a:Jl~Site name:"'~L, : tA i.-V It ('" ~t? 'C ill v-P('

Location and Region: Ho i-Vi II i1 ;y;.[ .'.!4J." ,J"M;~" r EPA 10: fV\ I Dq &'0 7 q '1 '-f 7J 0./

Agency, office, or company leading the five-year Weather/temperature: ..-G, ~oreview: U. {>. E rt\ - {le.C\ ioi-t ~ Cc:o\ - r "#

Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other E'fJ- ttlJ.t-,\-(~ /<";,',,(I~!.cd i' f <;'0: I ~ t' " v '{>f 5:ep-{,''"''''"...+ k L--A .{ lee,,"£' e{ c, ,'",- <:.. <!vi.' .... ....~± .I ~c :/.$

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager AJ /A N/A- Vi A, Name Title Date

Interviewed at site at office by phone Phone no. Problems, suggestions; Report attached

2. O&M staff fVlA ,vi f'r tJ/A Name Title Date

Interviewed at site at office by phone Phone no. Problems, suggestions; Report attached

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OSWER No. 9355,7-03B-P

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency f1 j' c l. ,-'ile i-, ()~fll ,iftt"-t-.'f [.f- bI1V",-" f<. c-"ir,'Trjl d! efi f ..-f</ Contact Oti". ,"a, ., tv /) i? .?: ~ 't{'~..- U"'I+ L~;er 4~)...?-o:J S-/1~ 3.13- ¥-!(3(

Name Title Date Phone no. Problems; suggestions; Report attached

Agency Contact


Agency Contact


Agency Contact


4. Other interviews (optional) Report attached.

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c OSWER No. 9355.7-03B-P

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents O&M manual Readily available Up to date As-built drawings Readily available Up to date Maintenance logs Readily available Up to date I

Remarks

2.

3.

4.

5.

Site-Specific Health and Safety Plan Contingency plan/emergency response plan

Remarks

O&M and OSHA Training Records Remarks

Permits and Service Agreements Air discharge permit Effluent discharge Waste disposal, POTW Other permits

Remarks

Gas Generation Records Remarks

6.

7.

8.

9.

10.

Settlement Monument Records Remarks

Groundwater Monitoring Records Remarks

Leachate Extraction Records Remarks

Discharge Compliance Records Air Water (effluent)

Remarks

Daily Access/Security Logs Remarks

Readily available Up to date Readily available Up to date N/<f£

Readily available Up to date C@

Readily available Up to date / .Readily available Up to date ~

Readily available Up to date Readily available Up to date N/Py~

Readily available Up to date ~

Readily available Up to date c@

Readily available Up to date @

Readily available Up to date @J

Readily available Up to date .~Readily available Up to date lBW

Readily available Up to date @~

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IV. O&M COSTS

1. O&M Organization State in-house Contractor for State PRP in-house Contractor for PRP Federal Facility in-house Contractor for Federal Facility Other ?Jlflc

2. O&M Cost Records Readily available Up to date Funding mechanism/agreement in place A

Original O&M cost estimate IJ I Breakdown attached

Total annual cost by year for review period if available

From To Breakdown attached Date Date Total cost





3. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: !JIlt

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable ~ A. Fencing

1. Fencing damaged Location shown on site map Gates secured N/A Remarks

B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A Remarks

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(, OSWER No, 9355.7-li3B-P

C. Institutional Controls (ICs)

l. Implementation and enforcement Site conditions imply ICs not properly implemented Yes No N/A Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by) Frequency Responsible party/agency Contact

Name Title Date Phone no.

Reporting is up-to-date Yes No N/A Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A Violations have been reported Yes No N/A Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A Remarks

D. General

1. Vandalism/trespassing Location shown on site map No vandalism evident Remarks

2. Land use changes on site N/A Remarks

3. Land use changes off site N/A Remarks

VI. GENERAL SITE CONDITIONS p::--.

A. Roads Applicable ~ 1. Roads damaged Location shown on site map Roads adequate N/A

Remarks

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OSWER No. 9355.7-IJ38-P

B. Other Site Conditions

Remarks

VII. LANDFILL COVERS Applicable (NIp) A. Landfill Surface

1. Settlement (Low spots) Location shown on site map Settlement not evident Areal extent Depth

Remarks

2. Cracks Location shown on site map Cracking not evident Lengths Widths Depths

Remarks

3. Erosion Location shown on site map Erosion not evident Areal extent Depth Remarks

4. Holes Location shown on site map Holes not evident Areal extent Depth Remarks

5. Vegetative Cover Grass Cover properly established No signs of stress Trees/Shrubs (indicate size and locations on a diagram)

Remarks

6. Alternative Cover (armored rock, concrete, etc.) N/A Remarks

7. Bulges Location shown on site map Bulges not evident Areal extent Height Remarks

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, .. " -~ I..

OSWER No. 9355.7-li3B-P

8. Wet AreaslWater Damage Wet areas Ponding Seeps Soft subgrade

Remarks

9. Slope Instability Areal extent Remarks

B. Benches Applicable

channel.)

1. Flows Bypass Bench Remarks

2. Bencb Breacbed Remarks

3. Bencb Overtopped Remarks

C. Letdown Channels Applicable

1. Settlement Areal extent Remarks

2. Material Degradation Material type Remarks

3. Erosion Areal extent Remarks

Wet areas/water damage not evident Location shown on site map Areal extent Location shown on site map Areal extent Location shown on site map Areal extent Location shown on site map Areal extent

Slides Location shown on site map No evidence of slope instability

N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined

Location shown on site map N/A or okay



N/A (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

Location shown on site map No evidence of settlement Depth

Location shown on site map No evidence of degradation Areal extent

Location shown on site map No evidence of erosion Depth

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OSWER No. 9355.7-113B-P

4. Undercutting Location shown on site map Areal extent Depth Remarks

5. Obstructions Type Location shown on site map Areal extent

Size Remarks

6. Excessive Vegetative Growth Type No evidence of excessive growth Vegetation in channels does not obstruct flow Location shown on site map Areal extent

Remarks

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive Properly secured/locked Functioning Routinely sampled Evidence of leakage at penetration N/A

Remarks

2. Gas Monitoring Probes Properly secured/locked Functioning Routinely sampled Evidence of leakage at penetration

Remarks

3. Monitoring Wells (within surface area of landfill) Properly secured/locked Functioning Routinely sampled Evidence of leakage at penetration

Remarks

4. Leachate Extraction Wells Properly secured/locked Functioning Routinely sampled Evidence of leakage at penetration

Remarks

5. Settlement Monuments Located Remarks

No evidence of undercutting

No obstructions

Good condition Needs Maintenance

Good condition Needs Maintenance N/A



Routinely surveyed N/A

D-14


E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities Flaring Thermal destruction Collection for reuse Good condition Needs Maintenance

Remarks

2. Gas Collection Wells, Manifolds and Piping Good condition Needs Maintenance

Remarks

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) Good condition Needs Maintenance N/A

Remarks

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/A Remarks

2. Outlet Rock Inspected Functioning N/A Remarks

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Areal extent Depth N/A Siltation not evident

Remarks

2. Erosion Areal extent Depth Erosion not evident

Remarks

3. Outlet Works Functioning N/A Remarks

4. Dam Functioning N/A Remarks

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OSWER No. 9355.7-IJ3B-P

H. Retaining Walls Applicable N/A

I. Deformations Location shown on site map Defonnation not evident Horizontal displacement Vertical displacement Rotational displacement Remarks

2. Degradation Location shown on site map Degradation not evident Remarks

I. Perimeter Ditcbes/Off-Site Discbarge Applicable N/A

I. Siltation Location shown on site map Siltation not evident Areal extent Depth Remarks

2. Vegetative Growtb Location shown on site map N/A Vegetation does not impede flow

Areal extent Type Remarks

3. Erosion Location shown on site map Erosion not evident Areal extent Depth Remarks

4. Discbarge Structure Functioning N/A Remarks

VIII. VERTICAL BARRIER WALLS Applicable ~ 1. Settlement Location shown on site map Settlement not evident

Areal extent Depth Remarks

2. Performance MonitoringType of monitoring Perfonnance not monitored

Frequency Evidence of breaching Head differential Remarks

D-16


IX. GROUNDWATERISURFACE WATER REMEDIES Applicable (N/A) A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing, and Electrical Good condition All required wells properly operating Needs Maintenance N/A

Remarks

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs Maintenance

Remarks

3. Spare Parts and Equipment I

Readily available Good condition Requires upgrade Needs to be provided Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A

l. Collection Structures, Pumps, and Electrical Good condition Needs Maintenance

Remarks

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs Maintenance

Remarks

3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be provided

Remarks

D-17


C. Treatment System Applicable N/A

1. Treatment Train (Check components that apply) Metals removal Oil/water separation Bioremediation Air stripping Carbon adsorbers Filters Additive (e.g., chelation agent, flocculent) Others Good condition Needs Maintenance Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date Equipment properly identified Quantity of groundwater treated annually Quantity of surface water treated annually

Remarks

2. Electrical Enclosures and Panels (properly rated and functional) N/A Good condition Needs Maintenance

Remarks

3. Tanks, Vaults, Storage Vessels N/A Good condition Proper secondary containment Needs Maintenance

Remarks

4. Discharge Structure and Appurtenances N/A Good condition Needs Maintenance

Remarks

5. Treatment Building(s) N/A Good condition (esp. roof and doorways) Needs repair Chemicals and equipment properly stored

Remarks

6. Monitoring Wells (pump and treatment remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A

Remarks

D. Monitoring Data

1. Monitoring Data Is routinely submitted on time Is of acceptable quality

2. Monitoring data suggests: Groundwater plume is effectively contained Contaminant concentrations are declining

0-18


D. Monitored Natural Attenuation

I. Monitoring Wells (natural attenuation remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A

Remarks

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVAnONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant PIUf{).: minimize infiltration and gas emission, etc.). _"

eM..ed~ VVktS /-/(b"" 'f;,;.i4?1 cer( j}l?r ..j1 e Ao '

,

(

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy.

Cu·.yv Ie.... ~.~ V' ,-....ft,,,I' '4'" (/"

,< V'\ d£.)( H \

£.vI' Ii lA € I n Ct~ ~ t' S.s. +i--eJ '-vJr.'rCt +:"..... ft~<t{. <.; -<.t=fi-e' (e"k-e ..-lc.../.

I

D-I9


C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope ofO&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future.

INCllIt£«

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

N/A

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