Adams Plating Company Superfund Site Lansing, Ingham County, Michigan

FOURTH FIVE-YEAR REVIEW REPORT FOR ADAMS PLATING COMPANY SUPERFUND SITE LANSING, INGHAM COUNTY, MICHIGAN

us EPA RECORDS CENTER REGION 5

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Prepared by

U.S. Environmental Protection Agency Region 5 CHICAGO, ILLINOIS

Date /^-^Superfund Division TABLE OF CONTENTS

List of Acronyms iii Executive Summary iv Five-Year Review Summary Form vi I. Introduction 1 II. Progress Since The Last Review 2 Remedy Implementation Activities 3 Institutional Controls 4 System Operation/ Operation and Maintenance Activities 7 III. Five-Year Review Process 8 Administrative Components 8 Community Notification and Involvement 8 Document Review 8 Data Review 8 Site Inspection 11 Interviews 11 IV. Technical Assessment 11 Question A: Is the remedy flmctioning as intended by the decision documents? 11 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy selection still valid? 11 Question C: Has any other Information come to light that could call into question the protectiveness of the remedy? 12 Technical Assessment Summary 12 V. Issues/Recommendations and Follow-up Actions 13 VI. Protectiveness Statement 14 VII. Next Review 14

Figures:

Figure 1 - Site Location Map (at end of Appendix A)

Tables:

Table 1 - Protectiveness Determinations/Statements from the 2010 FYR 2 Table 2 - Status of Recommendations from the 2010 FYR 2 Table 3 - Summary of Planned and/or Implemented ICs 5 Table 4 - Issues and Recommendations/Follow-up Actions 13

Appendicess ..

Appendix A - Existing Site Information Appendix B - Deed Restrictions Appendix C - Groundwater Monitoring O&M Agreement (AOC) Appendix D - 2002 PRP Request and 2003 MDEQ Modification Approvals Appendix E - Newspaper Public Notice Appendix F - Site Inspection Checklist and Photos Documenting Site Conditions

11 LIST OF ACRONYMS

AM Action Memorandum AOC Administrative Order on Consent APC Adams Plating Company CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COCs contaminants of concern COPCs chemicals of potential concem DNRE Department of Natural Resources and Environment EPA United States Environmental Protection Agency ESD Explanation of Significant Differences FS Feasibility Study FYR Five-Year Review ICs Institutional Controls ICLAP Institutional Control Implementation and Assurance Plan LBWL Lansing Board of Water and Light LTS Long-Term Stewardship MCLs Maximum Contaminant Levels MDEQ Michigan Department of Environmental Quality mg/kg Milligrams per kilogram NCP National Contingency Plan NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PM Project Manager PRP Potentially Responsible Party RAOs Remedial Action Objectives RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision Site Adams Plating Company Superflind Site SVOCs semi-volatile organic compounds TCA Trichloroethane pg/L micrograms per liter UU/UE unlimited use/unrestricted exposure VISLs Vapor Intrusion Screening Levels VOCs volatile organic compounds

111 EXECUTIVE SUMMARY

This is the fourth five-year review (FYR) for the Adams Plating Company (APC) Superfund site (Site) located in Lansing, Ingham County, Michigan. The purpose of this FYR is to review information to determine if the remedy is and will continue to be protective Of human health and the environment. The triggering action for this statutory FYR was the signing of the previous FYR on June 25,2010.

The remedy for the Site included the following components:

• Excavation of contaminated soils and off-site disposal in a Solid Waste Management Act, 1978 PA 641, as amended (Act 641)/Resource Conservation and Recovery Act, 1976 PL 94-580, as amended. Subtitle D landfill; • Collection and treatment of water from excavation/dewatering activities; • Replacement of the excavated soil with clean fill and the installation of vertical barriers to reduce the potential for recontamination of the fill; • If necessary, land use restrictions including deed restrictions on installation of wells and excavation of contaminated soils; and • Groundwater monitoring to evaluate the effectiveness of the soil remediation and to monitor for continuing sources of contamination.

The following modifications were made to the Record of Decision (ROD) in a September 30, 1994, Explanation of Significant Differences (ESD):

• Two additional structures (garage and shed) needed to be removed due to their proximity to the excavation; • Cleanup standards were updated to 33.5 milligram per kilogram (mg/kg) for chromium and 5.8 mg/kg for arsenic based on post-ROD background sampling results; • Excavation proceeded to the maximum depth of 10 feet without a requirement to conduct verification sampling of the excavation floor, which might have allowed excavation to terminate above the 10-foot depth, as long as performance standards were met; • Samples were not analyzed for hexavalent chromium since performance standards for total chromium were achieved; and • Soils were excavated laterally until background cleanup levels were achieved or a building foundation was encountered.

Construction began in August 1994 and construction activities were completed in October 1994. The APC site achieved construction completion with the signing of the Preliminary Closeout Report on September 30, 1994. The fu-st FYR was completed on October 1, 1999. The second FYR was completed on June 27, 2005. The trigger action for this FYR was the completion date for the third FYR, June 25, 2010. Additional background information about the Site is provided in Appendix A.

A fire destroyed the APC building on December 27, 2010. As a result of the fire, the United States Environmental Protection Agency (EPA) performed a removal action from December 28, iv 2010 through December 5, 2011. During the removal action, hazardous fire suppression water was removed from the Site, the impacted residences, and the storm sewer. The fire suppression water and fire debris were placed into roll-off boxes for disposal. Scrap metal was removed and decontaminated for recycling. Contaminated soil under the former APC building foimdation was excavated, backfilled, and re-sodded. An underground storage tank was removed and its contents placed into an overpack drum for off-site disposal. Approximately 58,780 gallons of hazardous liquids, 2,050 tons of hazardous solids, and 13 roll-off boxes of non-hazardous solids were shipped to off-site locations for disposal or recycling as a result of the fire. In the fall of 2011, EPA initiated a supplemental Remedial Investigation/Feasibility Study (RI/FS) at the Site to determine if further cleanup actions are needed at the Site. The supplemental Rl/FS is ongoing.

A protectiveness determination of the remedy at the APC site cannot be made until further information is obtained. As a result of the December 27, 2010 fire, the Adams Plating facility was destroyed. The response action approved by the February 15, 2011 Action Memorandum (AM) was necessary to ihitigate the immediate threait to public health, welfare, and the environment posed by contaminated fire suppression water on city streets and yards and in residential basements, which compromised the effectiveness of the remedy implemented at the Site. The time-critical removal action met its goals by eliminating immediate threats to human health and the environment. Deed restrictions have been placed on the Adams Plating property restricting property use, prohibiting groundwater use, and prohibiting interference or disturbance of the previous Superfund response actions implemented by EPA.

Further information will be obtained by taking the following actions: finalize the supplemental RI/FS for the Site and determine if any additional remediation activities are needed. Additional groundwater data will be collected, and an evaluation of the vapor intrusion/indoor air pathway will be completed. It is expected these actions will take approximately 2 years to complete, at which time a protectiveness determination will be made.

Institutional controls (ICs) are required for this remedy. The existing IC on the APC property will be reviewed and modified, as necessary, to ensure long-term protectiveness. ICs on the adjacent warehouse property at 511 North Rosemary Street are still needed to prevent disturbance of contaminated soils beneath the warehouse building and to prevent exposure to contaminated groundwater and soils. The warehouse owner has expressed a willingness to record use restrictions on the property and Michigan Department of Environmental Quality (MDEQ) staff have engaged the current property owner to work in that direction. Long-term stewardship procedures need to be developed and implemented. The Site remedy components, including ICs, must be operated, maintained, monitored, and enforced to ensure long-term protectiveness. Five-Year Review Summary Form

Lead agency: EPA Author name (Federal or State Project Manager): Pablo N. Valentin

Author afniiation: EPA, Region 5 Review period: 11/7/2014 - 6/25/2015

Date of site inspection: 6/10/2015

Type of review: Statutory Review number: 4

Triggering action date: 6/25/2010

Due date (fiveyears after triggering action date): 6/25/2015

VI Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review: None Issues and Reeommendations Identified in the Five-Year Review:

OU(s): Issue Category: Institutional Controls OUl/Sitewide Issue: Use restrictions are not in place for the warehouse property; the IC for the APC property should be reviewed and modified, as necessary, to ensure long-term effectiveness. Recommendation: 1) Record restrictive covenant for the warehouse property at 511 North Rosemary Street to prohibit well installation and soil disturbance; 2) Review and modify, as necessary, the ICs for the APC property to ensure long-term effectiveness. Affect Current Affect Future Party Oversight Milestone Date Protectiveness Proteetiveness Responsible Party No Yes EPA/State EPA/State 12/31/2016

OU(s): Issue Category: Institutional Controls OUl/Sitewide Issue: Lack of long-term stewardship procedures to ensure long-term protectiveness of the remedy. Recommendation: Develop an Institutional Control Implementation and Assurance Plan (ICIAP) or equivalent document. Affect Current Affect Future Party Oversight Milestone Date Protectiveness Protectiveness Responsible Party No Yes EPA/State EPA/State 12/31/2016

OU(s): Issue Category: Remedy Performance OUl/Sitewide Issue: Increasing contaminant of concern (COC) concentration in some groundwater monitoring wells in recent sampling events. Recommendation: 1) Update the groundwater monitoring program to address the impacts of the December 2010 fire; 2) Evaluate the hydraulic separation between the drinking water aquifer and the unconfmed glacial aquifer as part of the supplemental REPS. Affect Current Affect Future Party Oversight Milestone Date Protectiveness Proteetiveness Responsible Party Unknown Yes EPA/State EPA/State 12/31/2016

Vll OU(s): Issue Category: Remedy Performance OUl/Sitewide Issue: Indoor air pathway not fully evaluated. Recommendation: Evaluate the indoor air exposure pathway as part of the supplemental RI/FS. Affect Current Affect Future Party Oversight Milestone Date Protectiveness Protectiveness Responsible Party Unknown Yes EPA/State EPA/State 12/31/2016

OU l/Sitcnide Protectivciicss Statement Protectiveness Determination: Addendum Due Date: Protectiveness Deferred June 30, 2017

Protectiveness Statement: A protectiveness determination of the remedy at the APC site carmot be made until further information is obtained. As a result of the December 27, 2010 fire, the Adams Plating facility was destroyed. The response action approved by the February 15, 2011 AM was necessary to mitigate the immediate threat to public health, welfare, and the environment posed by contaminated fire suppression water on city streets and yards and in residential basements, which compromised the effectiveness of the remedy implemented at the Site. The time-critical removal action met its goals by eliminating immediate threats to human health and the environment. Deed restrictions have been placed on the Adams Plating property restricting property use, prohibiting groundwater use, and prohibiting interference or disturbance of the previous Superfund response actions implemented by EPA.

Further information will be obtained by taking the following actions: finalize the supplemental RJ/FS for the Site and determine if any additional remediation activities are needed. Additional groundwater data will be collected, and an evaluation of the vapor intrusion/indoor air pathway will be completed. It is expected.these actions will take approximately 2 years to complete, at which time a protectiveness determination will be made.

Vlll I. INTRODUCTION The purpose of a FYR is to evaluate the implementation and performance of a remedy in order to determine if the remedy will continue to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in five-year review reports. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

EPA prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121 and the National Contingency Plan (NCP). CERCLA Section 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 offacilities 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 Code of Federal Regulations (CFR) Section 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 actions no less often than every five years after the initiation of the selected remedial action.'"

EPA Region 5 conducted a FYR on the remedy implemented at the APC Superfimd Site in Lansing, Ingham County, Michigan. EPA is the lead agency for developing and implementing the remedy for the Site. MDEQ, as the support agency representing the State of Michigan, has reviewed all supporting documentation and provided input to EPA during the FYR process.

This is the fourth FYR for the APC Site. The triggering action for this statutory review is the completion date of the previous FYR, June 25, 2010. The FYR is required due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use/unrestricted exposure (UU/UE). The Site consists of one Operable Unit (OU), which is addressed in this FYR. II. PROGRESS SINCE THE LAST REVIEW

Table 1: Protectiveness Del erminatlons/Statements from the 2010 FYR Protectiveness OU# Protectiveness Statement Determination Sitewide Short-term The remedy at the APC Site currently protects human health and the environment in the Protective short term. The monitoring program requires the evaluation of groundwater data, the contaminated glacial aquifer is vertically separated from the drinking water aquifer, and the continued maintenance of the warehouse and the APC building provide protection of human health and the environment. Additional data collection and evaluation are necessary to ensure the remedy continues to be protective of the drinking water pathway and the vapor intrusion/indoor air pathway in the long term. ICs are required for this remedy. The existing IC on the APC property will be reviewed and modified, as necessary, to ensure long-term protectiveness. ICs on an adjacent property are still needed to prevent disturbance of contaminated soils beneath the warehouse building and to prevent exposure to contaminated groundwater and soils. The warehouse owner has expressed a willingness to record use restrictions on the property and DNRE' staff continues to work in that direction.

Table 2: Status of Recommendations from the 2010 FYR Current Completion Recommendations/ Party Oversight Original OU# Issue Milestone Status Date (if Follow-up Actions Responsible Party Date applicable) OU 1 1. Use restrictions I. Record restrictive PRP MDEQ 1/30/2011 Ongoing N/A (Sitewide) are not in place covenant for the for warehouse warehouse property at 511 property; IC for North Rosemary Street; the APC property ensure they prohibit well should be installation and soil reviewed and disturbance. modified, as The IC for the APC MDEQ MDEQ 1/30/2011 Ongoing N/A necessary, to property Will be reviewed ensure long-term and modified, as effectiveness. necessary, to ensure long- term effectiveness.

2. Increasing 2. The groundwater PRP MDEQ 6/30/2011 Ongoing N/A COC monitoring program needs concentrations in to be updated. some The hydraulic separation PRP MDEQ 6/30/2012 Ongoing N/A groundwater between the drinking monitoring wells water aquifer and the in recent unconfined glacial aquifer sampling events. needs to be evaluated. Need to obtain data from MDEQ MDEQ 6/30/2012 Ongoing N/A the Lansing Board of Water and Light (LBWL) and District MDEQ office staff. Evaluate the LBWL MDEQ MDEQ 6/30/2012 Ongoing N/A sampling frequency and parameter list.

3. Indoor air 3. Evaluate the indoor air PRP MDEQ 6/30/2011 Ongoing N/A pathway not fully exposure pathway. evaluated.

' The Michigan Department of Natural Resources and Environment (DNRE) is now MDEQ. 2 Remedy Implementation Activities

On December 27, 2010, an on-site fire broke out at the Adams Plating facility. Mr. Adams, the only person onsite at the time of the firei suffered severe bums. During fu^e suppression efforts, contaminated water ran off-site into the street, residential basements and yards, and the storm sewer. EPA responded to the fire at the Site on December 28, 2010. Analysis of samples collected from the mn-off water revealed cyanide and elevated levels of chromium, copper, and nickel. Numerous vats, drums, and other containers were observed throughout the facility. The fire-damaged building was unsafe to enter, and bulging dmms and open-top vats of chemicals were observed through the entryway.

EPA issued an AM on February 15, 2011 to authorize an emergency time-critical removal action at the Site and nearby residences, and the removal action was conducted from December 28, 2010 through December 5, 2011. This response action was necessary to mitigate the immediate threat to public health, welfare, and the environment posed by contaminated fire suppression water on city streets, yards, and in residential basements from the fire at the APC Site. Laboratory analysis of fire suppression water migrating off-site was found to have Toxicity Characteristic Leaching Procedure results for chromium of 430 milligrams per liter, nearly 100 times higher than what.is characteristically toxic. During the time-critical removal action, hazardous fire suppression water was removed from the Site, the impacted residences, and the storm sewer. The suppression water was placed into a frac tank for off-site disposal. Fire debris was placed into roll-off boxes for disposal. Scrap metal was removed and decontaminated for recycling. Drums and containers were staged, categorized, bulked, and overpacked for off-site disposal. Contaminated soil was excavated, backfilled, and excavated areas were re-sodded. A 10,000-gallon underground storage tank was removed and its contents placed into an overpack drum. Approximately 58,780 gallons of hazardous liquids^ 2,050 tons of hazardous solids, and 13 roll-off boxes of non- hazardous solids were shipped to off-site locations for disposal or recycling.

In the fall of 2011, EPA requested additional investigation activities be performed to further evaluate the nature and extent of contamination at the Site. At the direction of EPA, CH2M HILL completed additional R1 fieldwork in the fall of 2013 to collect supplemental data to complete a human health risk assessment and screening-level ecological risk assessment. The information will be used to develop a focused FS, which will evaluate remedial altematives for addressing potential impact to human health and ecological receptors from hazardous substances, pollutants, or contaminants present at the Site. The objective of the supplemental RI activities is to collect the data necessary to support the selection of a remedial alternative that mitigates risks to human health and the environment that may remain at the Site after the completion of the 2010 through 2011 removal action.

Soil borings were completed to support delineation of contaminants in soil and groundwater in the immediate vicinity of the Site subsequent to the 2010 fire and the 2011 time-critical removal action efforts. Soil boring locations were selected to provide adequate site coverage, and included the area previously occupied by the APC building and two adjacent residential properties located north and south of the Site that may have been impacted by recent events. Due to the age and uncertain condition of the existing monitoring well network, each well was inspected for maintenance and repair needs. Upon completion of well repairs, and prior to completing groundwater sampling, the monitoring wells in the existing network were redeveloped to remove fine-grained material that had accumulated in the well screens over time. Two additional permanent monitoring wells were installed during the 2013 investigation activities to further delineate the extent of groundwater contamination in upper and lower saturated sand seams beneath the former APC building footprint and the immediate vicinity. Two rounds of groundwater sampling were completed. Collection of soil gas and sub-slab gas samples were attempted to assess the presence of gaseous volatile organic compounds (VOCs) in the subsurface. One sump water sample was collected from the basement sump at 517 Rosemary Avenue to determine if contaminated water was present beneath the residence. Two inorganic chemicals (hexavalent chromium and nickel) were identified as chemicals of potential concern (COPCs) in the basement sump water. Dermal contact exposures to COPCs in basement sump water will be quantified for current/future off- site residents (adult and child). Inhalation exposures to basement sump water will not be quantified because volatile COPCs were not detected in the sump water. There were exceedances of vapor intrusion screening levels in two soil gas samples collected within the location of the sub-slab foundation at the former Adams Plating facility. Due to these screening levels exceedances, EPA will collect additional soil gas samples to reassess homes where the high groundwater table inhibited sub- slab soil gas collection. Residences located within 100 feet of the two samples where screening level exceedances were observed will be included in the sub-slab and indoor air sampling effort.

Institutional Controls

The 1993 ROD provided for ICs, such as deed restrictions, to prohibit the installation of water wells in the area, and any future development that might disturb contaminated soils, if necessary. There were two areas where soil contamination remained, which were the soils under the APC building and the soils located under the warehouse at 511 North Rosemary Street.

The owner of APC placed an IC on the property (see Appendix B) in 1997. While the property use at the time was consistent with the restrictions cited in that instrument, the IC may need to be reviewed and modified, as necessary, to ensure long-term protectiveness in light of the niost recent activities that have taken place at the Site. Specifically, as a result of the December 2010 fire, the APC building no longer exists and soils under the foundation of the former APC building were excavated and disposed off-site during EPA's removal action.

EPA notified the then-owner of the 511 North Rosemary Street warehouse of the need for deed restrictions to be executed at his property. However, the owner at that time did not consent to ICs being placed on his property. At this time, EPA and MDEQ have no reason to believe that there are any plans to remove the warehouse building foundation. MDEQ staff conducts periodic site visits to observe any changes in land use and ensure the warehouse building remains intact. Future abandonment or demolition of the warehouse building will be brought to the attention of EPA by MDEQ. Furthermore, MDEQ has reported that the owner of the warehouse property has changed, and MDEQ staff have started to work with the current landowner to place a restrictive covenant on the warehouse property. The current owner has indicated a willingness to work with MDEQ toward implementation of the necessary ICs at the property.

The table below summarizes the ICs for these restricted areas. A map which depicts the current conditions of the Site and areas which do not allow for UU/UE will be developed in the IC evaluation activities discussed below. Table 3: Summary of Planned and/or Implemented ICs Media, engineered Title ofIC controls, and ICs Called Instrument areas that do ICs for in the Impacted IC Implemented not support Needed Decision Parcel(s) Objective and Date (or UU/UE based Documents planned) on current conditions The Adams Yes Yes Lot Nos. 76, There shall be no consumptive or other use Deed Plating 77, 172, 173 of the of groundwater underlying the Site restriction, Company Site that could cause exposure of humans or executed on animals to the groundwater underlying the June 27, 1997, Site; Ingham County Recorder's There shall be no residential or agricultural Office use of the Site, including, but not limited to, (under review) any on-site excavation, landfilling, mining, invasive construction, drilling, and installation of drinking water production wells, and, any commercial or industrial use of the Site shall be limited to the current electroplating and ancillary uses by Adams Plating Company (or a successor operator) and activities incidental thereto, except as approved by EPA and the MDEQ;

There shall be no change in the existing uses of any buildings by Adams Plating Company or a successor operator by way of installation, removal, construction or other changes of use of any buildings, wells, pipes, roads, ditches or any other structures or materials at the Site except as approved in writing by EPA and the MDEQ;

There shall be no tampering with, or removal of, the containment or monitoring systems that remain on the Site as a result of implementation of any response action by EPA, or any party acting as agent for EPA, and which is selected and/or undertaken by EPA pursuant to Section 104 of CERCLA;

There shall be no use of, or activity at, the Site that may interfere with, damage, or otherwise impair the effectiveness of any response action (or component thereof) selected and/or undertaken by EPA, or any party acting as agent for EPA, pursuant to Section 104 of CERCLA, except with written approval of EPA and the MDEQ, and consistent with all statutory and regulatory requirements. The Yes Yes Lot Nos. 79 There shall be no consumptive or other use Restrictive Warehouse and 80 of the groundwater underlying the Site that Covenant Building (511 could cause exposure of humans or animals (planned) N. Rosemary to the groundwater underlying the Site; Street) There shall be no residential, commercial, or agricultural use of the Site, including, but not limited to, any on-site excavation, landfilling, mining, invasive construction, drilling, and installation of drinking water production wells, except as approved by EPA;

There shall be no installation, removal, construction or use of any buildings, wells, pipes, roads, ditches or any other structures or materials at the Site except as approved, in writing by EPA;

Current Compliance:

Based on inspections and interviews, EPA is not aware of site or media uses which are inconsistent with the stated objectives of the ICs based on the site inspection. The remedy's effectiveness is being re evaluated pursuant to a fire in December 2010 that destroyed the AFC building. EPA conducted a removal action from December 2010 through December 2011. Currently, EPA is performing a supplemental RI/FS at the Site to determine if any additional actions need to be implemented at the Site to address human health and ecological risks.

IC Evaluation and Follow-up Actions Needed:

Additional IC activities may be required in order to enhance the ICs and ensure continued long-term protectiveness due to the fact that site conditions at the former Adams Plating facility have changed as a result of the December 2010 fire which destroyed the facility. Those actions include ensuring that the ICs will remain in place and effective, and assuring that long-term stewardship (LTS) procedures are in place to ensure the ICs are maintained, monitored, and enforced. EPA and MDEQ will develop an 6 ICIAP or similar document. The purpose of the ICIAP is to conduct additional IC evaluation activities to ensure that the implemented ICs are effective, to explore whether additional ICs are needed, and to ensure that LTS procedures are in place so that ICs are properly maintained, monitored, and enforced.

Long-term protectiveness requires continued compliance with the land and groundwater use restrictions to ensure the remedy continues to function as intended. LTS will ensure that the ICs are maintained, monitored, and enforced. Plans incorporating LTS procedures (e.g., an LTS plan or Operation and Maintenance [O&M] plan) should include the mechanisms and procedures for inspecting and monitoring compliance with the ICs as well as communications procedures. An annual report should be submitted to EPA to demonstrate: that the Site was inspected to ensure no inconsistent uses have occurred; that ICs remain in place and are effective; and that any necessary contingency actions have been executed. Results of IC reviews should be provided to EPA in an aimual ICs report and with a certification that the ICs remain in-place and are effective.

IC evaluation activities will include, as needed, updated maps depicting current conditions in areas that do not allow for UU/LfE, review of recording and title work to ensure the restrietions are still recorded, and that no prior-in-time encumbrances exist on the Site that are inconsistent with the ICs.

Long-Term Stewardship

Long-term protectiveness at the Site requires compliance with land and groundwater use restrictions to ensure the remedy continues to function as intended. The implemented ICs must be maintained, monitored, and enforced. The O&M Plan should include a provision for regular inspection of ICs at the Site and regular certifications to EPA that the required ICs are in place and effective.

System Operation/Operation and Maintenance Activities

The APC entered into an Administrative Order by Consent (AOC) with MDEQ in 1997 for implementation of groundwater monitoring activities at the Site. The ongoing groundwater monitoring events were being conducted by Strata Environmental Services, Inc., a contractor retained by APC for this purpose. The groundwater monitoring program for the APC Site was outlined in the Agreement for Groundwater Monitoring and Operation and Maintenance (AOC-ERD-97-002) between MDEQ and the APC (see Appendix C).

The groundwater monitoring program objectives were: to evaluate the effectiveness of soil remediation; to monitor contaminant migration from remaining contaminant sources; to establish a baseline for contaminant concentrations in groundwater upon completion of remedial action construction activities; to monitor general trends in contaminant concentrations over time; to monitor the rate and direction of groundwater flow upon completion of remedial action construction activities; to ensure protection of the bedrock aquifer; to evaluate whether or not an active source of contamination exists at the Site; and to determine whether or not further remedial action is required.

In January 2002, the APC petitioned MDEQ for a revision of the groundwater monitoring program. The request proposed to either eliminate some of the wells being tested or to increase the interval between sampling events. The APC also requested reducing analytical parameters or decreasing the number of groundwater monitoring wells since the first FYR. Groundwater sampling was delayed until 2003. An additional request prompted MDEQ, in September 2005, to reduce the groundwater sampling frequency to once every three years; sampling was performed in 2006 and 2009. Additionally, a partially reduced groundwater monitoring round (in which all wells were not sampled in 2009, but all wells were planned to be sampled in 2010) was offered for cost savings in 2009, but ultimately declined. The AOC and MDEQ's approval are located in Appendices C and D. Groundwater monitoring under the Agreement for Groundwater Monitoring and Operation and Maintenance has not been performed at the Site since 2010 due to the December 2010 fire. EPA collected one round of groundwater monitoring in the fall of 2013 and a second round of groundwater monitoring will be collected in late summer 2015 as part of the ongoing supplemental RJ/FS activities. The groundwater monitoring data, soil sample data, and soil vapor gas data collected during the supplemental RI/FS activities will be used to develop human health and ecological risk assessments to determine if there are additional risks to human health and the environment posed by site contaminants that may need to be addressed by future remedial actions at the Site.

III. FIVE-YEAR REVIEW PROCESS

Administrative Components

The AFC Site FYR was led by Mr. Pablo N. Valentin, EPA remedial project manager, with support activities provided by Ms. Mary Schafer, MDEQ project manager (PM). The review, which began on November 7, 2014, consisted of the following components: • Community Notification and Involvement • Document review; • Data review; • Site Inspection; and • FYR report development and review.

Community Notification and Involvement

A notice was published in the Lansing State Journal and the Lansing City Community News stating that a FYR was being conducted. Appendix E contains a copy of the Public Notice dated December 18, 2014. The notice invited the public to submit any comments to EPA and/or MDEQ. No public comments were received. A copy of the completed FYR report will be made available at the two Site Information Repositories in Lansing, Michigan: the Lansing Public Library at 401 South Capitol Avenue and the Lansing Township Hall at 3029 West Michigan Avenue.

Document Review

This FYR consisted of a review of relevant documents including O&M reports and groundwater monitoring data. Applicable soil and groundwater cleanup standards, as listed in the ROD, ESD, and Removal Action Report, were also reviewed.

Data Review

Groundwater Monitoring

The general objective of the groundwater monitoring program was to evaluate the effectiveness of the soil remediation at the Site. The specific objectives were: • Monitor contaminant migration from remaining residual contamination; • Establish a baseline for contaminant concentrations in groundwater upon completion of the remedial action construction activities; • Monitor general trends in contaminant concentrations over time; • Monitor the rate and direction of groundwater flow upon completion of the remedial action construction activities; • Ensure protection of the bedrock aquifer; • Evaluate whether or not an active source of contamination exists at the Site; and • Determine if further remedial action is required.

A baseline was established for contaminant concentrations in groundwater upon completion of soil remedial action construction activities in 1994. The groundwater baseline was established during the Phase I groundwater sampling in October 1994 and the Phase I Round 2 sampling in April 1995. To meet the specific objectives of the groundwater monitoring plan, Phase II sampling was required. Phase II sampling took place during October 1995, October 1996, May 1997, October 1997, December 1997, and April 1998. Phase III groundwater sampling began in October 1998. The December 2010 fire destroyed the APC building and groundwater monitoring under the Agreement for Groundwater Monitoring and Operation and Maintenance has not been performed at the Site since. However, EPA has collected groundwater monitoring data as part of the ongoing supplemental RJ/FS activities.

A total of 40 groundwater samples were collected in 2013 as part of the ongoing supplemental RI/FS data collection activities. Groundwater samples were collected from the existing 15 site monitoring wells. In addition, one round of groundwater samples was collected from the new site monitoring wells (MW-I3S and MW-I3D), and a total of four groundwater samples were collected from three soil borings (SB-06, SB-08, and SB-I2). Groundwater samples were submitted for VOCs, semi-volatile organic compound (SVOCs), dissolved and total metals, cyanide, and hexavalent chromium analyses. Results of the analyses were compared to the following MDEQ Part 201 generic residential cleanup criteria and EPA criteria: • Nonresidential drinking water; • Groundwater-to-surface-water interface; ' • Residential volatilization to indoor air; and • EPA maximum contaminant levels (MCLs).

The following VOCs were detected in at least one groundwater sample at concentrations exceeding one or more relevant criteria. As part of the supplemental RI/FS, the vapor intrusion/indoor air exposure pathway will be analyzed/explored.

Detected Compound Concentration Range Above Criteria Number of Samples Exceeding (micrograms per liter fpg/Lj) Criteria 1,1-dichIoroethane 910-2,400 2 1,1-dichloroethylene 7.7-10 2 cis-1,2-dichloroethene 100 1 trichloroethylene 10 1 The following SVOCs were detected in at least one groundwater sample at concentrations exceeding one or more relevant criteria.

Detected Compound Concentration Range Above Criteria Number of Samples Exceeding (ttg/L) Criteria bis(2-ethylhexyl)phthalate 14 1

The following metals were detected in at least one groundwater sample at concentrations exceeding one or more relevant criteria.

Detected Compound Concentration Range Above Criteria Number of Samples Exceeding (pg/L) Criteria aluminum 50 - 6,540 18 arsenic 10.8-12.9 2 1 cobalt 00

1 2 i j cyanide 10-123 12 hexavalent chromium 15.4-16.7 2 iron 317-39,100 80 manganese 63.9-460 62 nickel 183-2,210 6 silver 0.064-0.150 6 sodium 360,000 - 552,000 17

Shallow groundwater monitoring well MW-4S is adjacent to the residence at 517 N. Rosemary Avenue. Therefore, the groundwater analytical data collected from MW-4S were used to evaluate the potential for vapor intrusion at that residence. The uppermost hydrogeologic unit is generally associated with the greatest potential for vapor intrusion; therefore, the analytical data collected from the co-located deep monitoring well, MW-4D, were not used to evaluate the vapor intrusion pathway. The detected concentrations of VOCs were compared to EPA's Vapor Intrusion Screening Levels (VISLs) for a residential scenario and an industrial scenario. Two VOCs (1,1-dichloroethane and 1,1,1-trichloroethane [TCA]) were detected at MW-4S, and the detected concentrations were less than the residential and industrial VISLs. Two inorganic chemicals (hexavalent chromium and nickel) were identified as COPCs in the basement sump water sample (SP-01) collected from 517 N. Rpsemary Street. Dermal contact exposures to COPCs in basement sump water will he quantified for current/future off-site residents (adult and child). Inhalation exposures to basement sump water will not be quantified because volatile COPCs were not detected in the sump water.

There were exceedances of vapor intrusion screening levels in two soil gas samples collected within the location of the sub-slab foundation at the former Adams Plating facility. The groundwater analytical data collected from monitoring well MW-4S suggests there may be limited potential for vapor intrusion; however, sub-slab soil gas ^d/or indoor air samples are needed to further evaluate the vapor intrusion pathway using a multiple-lines-of-evidence approach. Due to these screening levels exceedances, EPA will collect additional soil gas samples to reassess homes where the high groundwater table inhibited sub-slab soil gas collection. Residences (sub-slab and indoor air) located within 100 feet of the two samples where screening levels exceedances were observed will be included in the sampling effort.

10 Site Inspection

EPA conducted the site inspection on June 10, 2015. Ms. Mary Schafer, MDEQ PM, was in attendanee. The purpose of the inspection was to assess site conditions in order to better evaluate data, exposure assumptions, construction completeness, ongoing remedy success, and general concerns regarding the Site.

EPA and MDEQ conducted a visual inspection of the remedy. The Site Inspection Checklist is presented in Appendix F, along with photos documenting site conditions at the time of the inspeetion. EPA and MDEQ walked the property taking note of the physical condition of the groundwater monitoring wells, the APC property, and the warehouse at 511 North Rosemary Street. The APC building was demolished as part of EPA removal activities after the December 2010 fire and the warehouse building located at 511 North Rosemary Street is still in use and in good condition. The monitoring wells were in good condition and have been redeveloped to be used as part of the ongoing supplemental RI/FS.

Interviews

No interviews were condueted during this FYR.

IV. TECHNICAL ASSESSMENT

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

The aetions implemented under the ROD as amended by the ESD were functioning as intended by the original deeision documents. However, as a result of the December 2010 fire, the Adams Plating facility was destroyed and response action was necessary to mitigate the immediate threat to publie health, welfare, and the environment posed by contaminated fire suppression water on city streets and yards, in the stormwater sewer, and in residential basements which compromised the effectiveness of the remedy implemented at the Site. EPA eonducted an emergency and time-critical removal action which was approved in the AM dated February 15, 2011. During the removal action, EPA placed suppression water into a ffac tank for off-site disposal. Fire debris was placed into roll-off boxes for disposal. Scrap metal was removed and decontaminated for recycling. Drums and containers were staged, categorized, bulked, and overpacked for off-site disposal. Contaminated soil was excavated, backfilled, and re-sodded. A 10,000 gallon underground storage tank was removed and its contents placed into an overpack drum. Approximately 58,780 gallons of hazardous liquids, 2,050 tons of hazardous solids, and 13 roll-off boxes of non-hazardous solids were shipped to off-site locations for disposal or recycling. The time- eritical removal action met its goals by eliminating immediate threats to human health and the environment. Currently, EPA is conducting a supplemental RI/FS at the Site to determine if any additional actions need to be implemented to address any remaining human health and ecological risks as a result of the fire.

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

No. The exposure assumptions, toxicity data, cleanup levels, and the RAOs are being re-evaluated under the supplemental RI/FS to determine if EPA will need to implement additional remedial actions at the Site beyond the December 2010 - December 2011 removal action.

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

Yes. A fire destroyed the Adams Plating facility on December 27, 2010. At this time, EPA is conducting a supplemental RI/FS at the Site to determine if any additional remediation will need to be conducted after completion of the December 2010 - December 2011 removal action. In addition, vinyl chloride was detected in the source area well, MW9D, at 15 pg/L in 2009. This appears to be a breakdown product of TCA, which was known to have been used as a degreaser at the APC. TCA continues to be detected below its MCL in Site groundwater monitoring wells. 1,4-dioxane will be added to the analyte list and evaluated for inclusion in the groundwater monitoring program.

Technical Assessment Summary

A fire destroyed the Adams Plating facility on December 27, 2010, and EPA conducted a removal action over December 2010 - December 2011 to address releases at the facility. EPA is currently conducting a supplemental RI/FS at the Site to determine if any additional remediation will need to be conducted.

Although the soil remediation was previously implemented in accordance with the decision documents, it is not known whether the remedy at the APC Site is currently functioning as intended. Groundwater concentrations showed significant reductions after the implementation of the original remedial action, but previous to and after the December 2010 fire, increasing trends were apparent in some of the monitoring wells. There have been changes in the MCL criteria for the COCs that were used in the baseline risk assessment. The MCL for arsenic has been changed to 10 pg/L; therefore, arsenic must be added back to the APC analytical parameter list. 1,4-dioxane will be added to the analyte list and evaluated for inclusion in the groundwater monitoring program. As a result of the December 2010 fire, the Adams Plating facility was destroyed and response action as approved by the February 15, 2011 AM was necessary to mitigate the immediate threat to public health, welfare, and the environment posed by contaminated fire suppression water. The time-critical removal action met its goals by eliminating immediate threats to human health and the environment. Deed restrictions have been placed on the Adams Plating property restricting property use, prohibiting groundwater use, and prohibiting interference or disturbance of the previous response actions implemented by EPA as a result of the Superftind actions.

It has also been determined that evaluation of the vapor intrusion/indoor air pathway is needed for long- term protectiveness. EPA's contractor attempted collection of soil gas and sub-slab gas samples to assess the presence of gaseous VOCs in the subsurface. One sump water sample was collected from the basement sump at 517 Rosemary Avenue to determine if contaminated water was present beneath the residence. Two inorganic chemicals (hexavalent chromium and nickel) were identified as COPCs in the basement sump water. Dermal contact exposures to COPCs in basement sump water will be quantified for current/future off-site residents (adult and child). Inhalation exposures to basement sump water will not be quantified because volatile COPCs were not detected in the sump water. There were exceedances of vapor intrusion screening levels in two soil gas samples collected within the location of the sub-slab foundation at the former Adams Plating facility. Due to these screening levels exceedances, EPA will collect additional soil gas samples to reassess homes where the high groundwater table inhibited sub- slab soil gas collection. Residences located within 100 feet of the two samples where screening levels exceedances were observed will be included in the sampling effort (sub-slab and indoor air). During the supplemental RI/FS, data will be collected to evaluate the indoor air exposure pathway and any vapor intrusion issues associated with the Site.

12 The ROD and site files were reviewed to determine whether ICs are in place and functioning as intended. The ROD provided for ICs, such as deed restrictions, to prevent direct contact, prohibit the installation of water wells at the Site and any future development that might disturb contaminated soils, if necessary. The APC has executed and filed deed restrictions on its property to prevent installation of wells and disturbance of soils under the APC building. The prior owner of the warehouse located at 511 North Rosemary did not placed deed restrictions on his property. MDEQ has indicated to EPA that the new owner for the warehouse property appears willing to place ICs on his property, and MDEQ continues to work with the landowner to develop deed restrictions for the property. MDEQ continues to periodically inspect the area to ensure the warehouse property continues to be maintained. LTS procedures need to be developed and implemented. The site remedy components, including ICs, must be operated, maintained, monitored, and enforced to ensure long-term protectiveness.

V. ISSUES/RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Tab e 4: Issues and Recommendations/Follow-up Actions Affects 1 Recom mendations/ Party Oversight Milestone Protectiveness? Issue ou# FoIIow-up Actions Responsible Agency Date (Y/N) Current Future OUl/ Use restrictions are Record restrictive covenant EPA/State EPA/State 12/31/2016 No Yes Sitewide not in place for the for the warehouse property at warehouse 511 North Rosemary Street to property; the IC for prohibit well installation and the APC property soil disturbance. should be reviewed and modified, as Review and modify, as necessary, to ensure necessary, the ICs for the long-term APC property to ensure long- effectiveness. term effectiveness. OUl/ Lack of long-term Develop an ICIAP or EPA/State EPA/State 12/31/2016 No Yes Sitewide stewardship equivalent document. procedures to ensure long-term protectiveness of the remedy. QUI/ Increasing COG Update the groundwater EPA/State EPA/State 12/31/2016 Unknown Yes Sitewide concentration monitoring program to in some address the impacts of the groundwater December 2010 fire. monitoring wells in recent Evaluate the hydraulic sampling events separation between the drinking water aquifer and the unconfined glacial aquifer as part of the supplemental RI/FS. GUI/ Indoor air Evaluate the indoor air EPA/State EPA/State 12/31/2016 Unknown Yes Sitewide pathway not fully exposure pathway as part of evaluated the supplemental RI/FS.

13 VI. PROTECTIVENESS STATEMENT

OUl/Sitt'wide Protectivciiess Statement Protectiveness Determination: Addendum Due Date: Protectiveness Deferred June 30, 2017 Protectiveness Statement: A protectiveness determination of the remedy at the AFC Site cannot be made until further information is obtained. As a result of the December 27, 2010 fire, the Adams Plating facility was destroyed. The response action approved by the February 15, 2011 AM was necessary to mitigate the immediate threat to public health, welfare, and the environment posed by contaminated fire suppression water on city streets and yards and in residential basements, which compromised the effectiveness of the remedy implemented at the Site. The time-eritieal removal action met its goals by eliminating immediate threats to human health and the environment. Deed restrictions have been placed on the Adams Plating property restricting property use, prohibiting groundwater use, and prohibiting interference or disturbance of the previous Superfund response actions implemented by EPA.

VII. NEXT REVIEW

The next FYR report for the Site is required five years from the completion date of this review.

14 APPENDIX A - EXISTING SITE INFORMATION.

A. SITE CHRONOLOGY

Table A-1; Site Chronology Event Date Underground Storage Tank (UST) containing Stoddard Mid-I950's Solvent removed because of leakage Property is transferred to James and Sheila Adams and begins 1964 operations as electroplating business Wastewater was discharged to a clay tile drain system Before 1971 The AFC was connected to the municipal sewer system 1971 The AFC was cited several times for violations of city codes Before 1980 regulating discharge of treated wastes to the municipal sewer Fretreatment of wastewater begins Early 1980's AFC Site is placed on the National Friorities List (NFL) March 1989 Fhase 1 of the RI begins August 1989 Teehnical assistance team collects four basement water November 28,1989 samples in nearby residenees Fhase II of the RI and PS begins March 1991 RI completed March 1993 FS completed July 1993 ROD signature September 29,1993 EFA performs remedial design/remedial action (RD/RA) September 1993 through September 1994 ESD issued September 30,1994 Freliminary Closeout Report September 30,1994 Site Final Closeout Report September 28,1995 1997 AOC Agreement for groundwater monitoring and April 21,1997 operation and maintenance from Steve Adams First FYR October 7,1999 Addendum to the first FYR September 28, 2001 MDEQ Approval for modifieation of groundwater monitoring April 3, 2003 Frequency Second FYR June 27, 2005 Third FYR June 25, 2010 Site Fire December 27, 2010 Site EFA Removal Action December 28, 2010 through December 5,2011 Site Supplemental RJ/FS Ongoing

B. BACKGROUND

Physical Characteristics

The Site is a parcel of land approximately one aere in size loeated at 521 Rosemary Street in Lansing, Michigan. The Site is located near the center of a one-mile radius bend of the Grand River 1 (River) (see Figure 1). The River is about one-mile north, one and one-quarter miles south, and two-miles east of the Site. Population density is approximately 1,800 people per square mile around the Site. The Site is composed of four lots of a block which contains numerous small businesses and private residences. The Site is physiographically located in the south central part of Michigan's Lower Peninsula. The Site lies approximately 850-feet above mean sea level. Area topography is flat or gently rolling as a result of glacial and post-glacial erosional processes. The Site is located on ground moraine and till plain approximately one-half mile north of the Lansing Moraine. Perennial surface water bodies or wetlands are not present on or near the Site. The nearest water body is a small pond located approximately 3,000 feet southwest of the Site. Surface water drainage is northeast, east, and southeast, following the general topography of the Site and surrounding area.

Land and Resource Use

The Site is situated in a densely populated mix of commercial, industrial, and residential area of the city of Lansing. Large commercial and public properties within a half-mile radius of the Site include now-closed automobile plant operations, a cemetery, several schools, three local parks, a golf course, and a hospital. The block on which the Site is located contains numerous private residences and several small service businesses. The nearest private residence is within 25 feet of the Site. Directly across the street from the Site and to the east lies the vacant property of the former General Motors Oldsmobile Production and Assembly Plant #2.

All residences and businesses in the vicinity of the APC Site receive their water from the municipal system, which serves the Lansing area. Lansing Township Well No. 4 was noted as the closest well at the time the ROD was written. Recent research reveals that municipal well No. 40-2 is now the closest. Well 40-2 is located on the north side of Saginaw Highway at Deerfield Avenue. It is a deep well and is maintained by the Lansing Board of Water and Light. Records indicate that private wells do not exist in the immediate vicinity of the Site.

History of Contamination

The APC building was occupied by the Verrakleen dry cleaning establishment before 1964. A dry cleaning fluid known as Stoddard Solvent, which is a mineral spirit that contains chlorinated hydrocarbons, paraffin, and aromatic hydrocarbons, was stored in a 500 gallon UST at the Site. This UST was removed in the mid-1950's due to leakage and the former location of the UST is not known.

In 1964, the property was transferred to James and Sheila Adams who began to operate the plant as an electroplating business. The facility is now owned by their son, Steve Adams. APC was a Resource Conservation and Recovery Act (RCRA) facility noticed as a conditionally exempt small quantity generator, changed from small quantity generator in 2006. Their manifest record does not indicate any solvent use.

Wastewater from the facility was discharged to a clay tile drain system prior to 1971. The APC connected to the municipal sewer in 1971. Wastewater started to be pre-treated in the early 1980's. During this time, wastewater was stored before pretreatment in a plank covered, partially buried, metal dipping tank. This 800 gallon tank was removed on an unknown date due to leakage.

. 2 Initial Response and Basis for Taking Remedial Action

In July 1980, the owner of the Meyer residence at 510 Grace Street, Lansing, Michigan, hired a backhoe operator to remove a tree from his property. An old tile drain was broken as the tree was uprooted. Later that month, green water began infiltrating the basement of that house. The Ingham County Health Department (ICHD) inspected and collected samples of the green water for analysis. The analyses indicated 130 to 150 parts per million (ppm) of total chromium in the water. At ICHD's suggestion, James Adams arranged to pump the water from the basement and transfer it by tank truck to the underground wastewater holding tanks at the APC building. The ICHD performed subsurface investigations at the Site that indicated plating waste had migrated through a sand lens and was not confined entirely to the tile drain system. Therefore, the ICHD urged James Adams to install a subsurface interceptor and collector system between the APC building and the basement of the residence. While the collection system appeared to reduce the volume of contamination reaching the residence, local and state agencies continued to express concern over the extent of contamination. In response to this concern, EPA conducted a detailed Site review in 1986. The Site was proposed for the NPL in June 1988. In March 1989, the Site was placed on the NPL. EPA conducted the RI in two phases. Phase I of the RI began in August 1989. Work on Phase II of the RI began in March 1991. The RI was published in March 1993 and the PS was completed in July 1993.

Soils

Elevated concentrations of chromium, copper, and nickel were found in soil samples from the Site. The maximum chromium concentration initially detected was 6,976 milligrams per kilogram (mg/kg). The maximum concentrations for copper and nickel were 1,810 and 880 mg/kg, respectively. Several VOCs were also detected at high concentrations, including 1,1-dichloroethane (maximum concentration at 5,300 microgram per kilogram [pg/kg]); 1,1,1-trichloroethane (TCA) (maxirrium concentration at 5,300 pg/kg); chloromethane (maximum concentration at 4,200 pg/kg); 2-butanone (maximum concentration at 4,200 pg/kg); and methyl ethyl ketone (maximum concentration at 4,200 pg/kg). EPA identified the contaminated soils as posing potential imacceptable risks to human health. Potential exposure routes included ingestion, dermal contact, and inhalation of contaminated soils at the Site by resident trespassers and construction workers. Remediation of contaminated soils under buildings was determined by EPA to be unnecessary because building foundations act as a cap and significantly reduce potential exposure to contaminated soils.

Groundwater

Groundwater contamination was detected at the Site in excess of MDEQ's cleanup criteria at the time of remedy selection (Michigan's Type B cleanup criteria established pursuant to the Michigan Environmental Response Act, 1982 PA 307, as amended [Act 307]). Since the groundwater was not found in useable quantities, or quality, and a connection to the drinking water aquifer was not established, it was deemed unnecessary to remediate the groundwater.

Surface Water

Surface water samples were collected from man-made groundwater collection systems and puddles, rather than natural surface water bodies. The highest concentration of chromium in a surface water sample (21,500 micrograms per liter [|ig/L]) was collected from a sump on APC property designated as the "green water drum," The highest concentration of chromium detected in a water sample from a nearby residential basement was 7,960 pg/L. Low concentrations of copper, nickel, and zinc were also detected in the water samples. Because the water was not used for drinking water purposes and did not pose an unaceeptable risk by other exposure routes, no remediation was necessary.

C. REMEDIAL ACTIONS

Remedy Selection

Remedial Action Objectives

The RAOs for the APC Site were identified in the July 1993 FS. The remedy was intended to prevent residents and trespassers from being exposed to contaminated soils through ingestion, dermal contact, and inhalation of particles.

Record of Decision

The ROD for the Site was issued on September 29, 1993. The selected remedy included the following major components:

• Excavation of contaminated soils and off-site disposal in an Act 641/RCRA Subtitle D landfill; • Collection and treatment of water from excavation and dewatering activities; • Replacement of the excavated soil with clean fill and installation of vertical barriers to reduce the potential for recpntamination of clean fill; • If necessary, land use restrictions including deed restrictions to prevent installation of wells and excavation of contaminated soils; and • Groundwater monitoring to evaluate the effectiveness of the soil remediation and to monitor for continuing sources of eontamination.

The soils targeted for excavation included an estimated 4,700 cubic yards of contaminated soils close to the old tile drain system and around existing buildings. Excavation was to proceed laterally until background levels were achieved and vertically to a maximum depth of ten feet. Soil contamination under the buildings was not considered to pose a risk to human health and the environment because the buildings provided an effective barrier. A depth of ten feet was the maximum realistic depth where EPA determined possible residential, trespasser, and construction worker exposure could occur during typical construction activities. After completion of the remedial action, a site-specific risk of 1x10'® or less carcinogenic risk and a hazard index ratio of 1.0 or less for exposure due to ingestion, dermal contact, or inhalation would result. Explanation of Significant Diiferences

An ESD for the Site was issued on September 30, 1994. The purpose of the ESD was to explain several modifieations to the selected remedy as presented in the ROD, as follows:

• Two additional structures (garage and shed) needed to be removed due to their proximity to the excavation; • Cleanup standards were updated to 33.5 mg/kg for chromium and 5.8 mg/kg for arsenic based on post-ROD background sampling results; • Excavation proceeded to the maximum depth of 10 feet without a requirement to conduct verification sampling of the excavation floor, which might have allowed excavation to terminate above the 10-foot depth, as long as performance standards, were met; • Samples were not analyzed for hexavalent chromium since performance standards for total chromium were achieved; and • Soils were excavated laterally until background cleanup levels were achieved or a building foundation was encountered.

Remedy Implementation

EPA took over the RD/RA phases of the project and performed the work after determining the PRP did not have the necessary resources to perform the work. The RA work assignment was awarded to PRC Environmental Management. PRC Environmental Management awarded a construction subcontract to MacKenzie Environmental Sciences, Inc.

Construction at the APC Site began on August 1, 1994 and was completed in October 1994. A total of 6,888 cubic yards of contaminated soil were removed and disposed at an approved landfill. A geocomposite liner was installed as a vertical barrier and the area was backfilled with a silty clay material.

Based on background data collection, cleanup standards for chromium and arsenic were established. The values were 33.5 mg/kg for chromium and 5.8 mg/kg for arsenic. During the initial soil verification sampling, all but nine of the analytical results were below the cleanup standard for chromium. The results above the cleanup standard triggered additional excavation until standards were met in subsequent samples or until a building foundation was encountered. All arsenic concentration levels were below the cleanup standard with the exception of three samples. One sample value of 6.4 mg/kg was judged to be acceptable by EPA and MDEQ because the sample was retrieved from a native clay with a typical background concentration of 6.3 mg/kg of arsenic. To achieve the cleanup standard for the other two samples, excavation continued an additional 20 feet to the west and was terminated when the standard was met. Excess human health risks due to contaminated soils were eliminated when the soils were removed for off-site disposal. Adams Plating Company 521 N. Rosemary St. Lansing, Ml 48917

isw«~ APPENDIX B Deed Restrictions M^JNOmCE John L. Cote Edward J. Casiedani Eleanor E Lyini 333 AJberc ^ve...Sui.e 500 Willingham Ronalii S. Griffith JohnE. Wieber Raynor a Zfllgin P.O. Box 1070 Raymond J. Haicstnan, Jr. niricia F. Claire Sandra rtiapiTMin Eau Lansing. MI 481126 Rnbeit L. Hood Cunis R. Hadley MartW.Geschw 5r'351-62C0Fax35MI95 Cote, P.O. James F. Gnves Jane A. Klepac L. ftgeOnses ST IOHN.S OmCE »attorneys & counselors at law Marianne £. Samper Robert a Bellgoaan. Jr. John A. Tbger Anthony S. Ki^i trfcmmsd 20 East Slate Slmi C F. Wiffinghai P.Ci Box 436 James L. Daltini, Jr. ^tedie A. Harhstm St lohns. .VI 48879 David C Homan Steven A. Mitchell dad 5i; -224.2240 Fax 224^68 Judith I. Danwo

July 15, 1996

Ms. Sally Beebe ^ .Project Manager Michigan Dept.. of Environmental Quality Environmental Response Division P.O. Box 30426 Lansing, Michigan 48909-7926 RE: Adams Plating MDEQ Docket No: AOC-ERD-97-002 Dear Ms. Beebe: Pursuant to the agreement for ground water monitoring and operation and maintenance, I enclose a copy of the recorded Deed Restrictions on the Adams Plating Company Superfund site, referencing the filing at Liber 2473, Page 206. I believe this will complete the administrative details for compliance with the agreement. If not, please advise Mr. Adams or myself at your earliest convenience. Thank you. Sincerely,

John A. Yeager JAY/nlh cc; USEPA yeager\843 831tr.06 Liber 2473 Pagi! ao6 M Ho S19S1 IGS8 a. 00 970023SK NISC 11.00 (l6/S7/m7 15:38:48 KQP 3.00 REBISIER OF DEDS Paula Jahasoa DBmcaMY,Nl Total 16.00

DEED RESTRICTIONS ON ADAMS PT.ATTWG COMPANY STTPKRITHNn STTP

Stephen J. Adams, a married man, and Cindy L. Adams, his wife, .521 North Rosemary Street, Lansing, Michigan, owners in fee simple of the real estate described below hereby impose restrictions on the described real estate, also known as the Adairs Plating Company Superfund Site (hereinafter "the Site") in Lansing, Ingham County, State of Michigan:

A parcel of land in the west half of the northeast cpaarter of Section 18, Township 4 North, Range 2 West, Lansing Township, County of Ingham, Michigan, being more particularly described as follows:

SUBDIVISION; MICHIGAN HEIGHTS Lot Nos: 76, 77, 172 and 173 Property Address: 521 North Rosemary Street Site: Adams Plating Company

This parcel contains one-quarter acre, more or less. Subject to all easements and restrictions of record.

The following restrictions are imposed upon the Site, its present and any future owners (including heirs to the above described owners of real estate), their authorized agents, assigns, employees or persons acting under their direction or control, for . the purposes of protecting public health or welfare and the environment, preventing interference with the performance, and maintenance, of any response actions selected and/or undertaken by the United States Environmental Protection Agency ("U.S. EPA") , or any party acting as agent for the U.S. EPA, pursuant to Section 104 of the Comprehensive Environmental Response, . Compensation and Liability Act ("CERCLA"). Specifically, the following deed restrictions shall apply to the Site, so long as . ^ contaminants are present at the site in excess of performance «=» standards provided for in the Record of Decision dated September § 23, 1993, and Explanation of Significant Differences, as amended, S and in excess of residential clean up criteria of Part 201 of the g Natural Resources and Environmental Protection Act, 1994 PA 451, ^ as amended by- 1995 PA 71, [MCL 324.20120a(1)(a) ] : o >~ 1.. There shall be no consumptive or other use of the a.. groundwater underlying the Site that could cause 8 exposure-of humans or animals to the groundwater underlying the Site;' Liber 2473 Page 207

2 . There shall be no residential or agricultural use of the Site, including, but not limited to, any on-site excavation, landfilling, mining, invasive construction, drilling, and installation of drinking water production wells, and, any commercial or industrial use of the. Site shall be limited to the current electroplating and ancillary uses by Adams Plating Company (or a successor operator) and activities incidental thereto, except as approved by U.S. EPA and the MDEQ; 3 . There shall be no chauige in the existing uses of any buildings by Adams Plating Company or a successor operator by way of installation, removal, construction or other changes of use of any buildings, wells,, pipes, roads, ditches or any other structures or materials at the Site except as approved in writing by U.S. EPA and the MDEQ; 4. There shall"be" no tampering with, or removal of, the containment or monitoring systems that remain on the Site as a result of implementation of any response action by U.S. EPA, or any party acting as agent for U.S. EPA, and which is selected and/or undertaken by U.S. EPA pursuant to Section 104 of CERCLA; and 5. There shall be no use of, or activity at, "he Site that may interfere with, damage, or otherwise impair the effectiveness of any response action (or component thereof) selected and/or undertaken by U.S. EPA, or any party acting as agent for U.S. EPA, pursuant to Section 104 of CERCLA, except with written Approval of U.S. EPA and the MDEQ, and consistent with all statutory and regijlatory requirements. The obligation to implement and maintain the above restrictions shall run with the land and shall remain in effect until such time as U.S. EPA files with the owner a written certification stating the above restrictions are no longer necessary, or, the Michigan DEQ certifies, in writing that is in a form suitable- for filing with the Register of Deeds, that contaminants no longer exceed the performance standards provided for in the Record of Decision and Explanation.of Significant Differences, as amended, and the residential clean up criteria of Part 201 of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended bv 1995 PA 71 [MCL 324.20120a(1) (a)]. Liber 8473 Page 80S

IN WITNESS WHEREOF, we have caused these Deed Restrictions to be executed this 27th day of June , 1997. WITNESSES:

Vie Becker i Stephen'J. /' Z': /f / DeeAnn Overton Cindy L y Adams

STATE OF MICHIGAN ) )SS' COUNTY OF INGHAM )

On the 27th day of June 1997, before me appeared Stephen J. Adams and Cindy L. Adams, who acknowledged there signatures above stated as their owivfree act and deed.

Dorothy L. Jo^ston ^Notary Public "county, Michigan My Comm. Expires: Drafted by: John A. Yeager Wiilingharr. and Cote' P.C. 333 Albert'Street, Ste 500 P.O. Box 1070 . East Lansing, MI 48826 yeager\a4 3 fl3agr •' • • : _ - • . 1 i \ O .• APPENDIX C Groundwater Monitoring O&M Agreement (AOC) MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

III the Matter of; Adams Plating Facility Ingham County, Michigan

MDEQ Docket No.: AOC-ERD-97-002

AGREEMENT FOR GROUNDWATER MONITORING AND

OPERATION & MAINTENANCE fO & M>

This Agreement for Groundwater Monitoring and O & M (hereinafter, the "Agreement") is entered into voluntarily by and between the Michigan Department of Environmental Quality (' MDEQ"), Environmental Response Division and the Adams Plating Company, a Michigan Corporation (hereinafter "Adams Plating"), for the purpose of specifying the agreed upon conditions for performance of groundwater monitoring, 0 & M inspections and other O & M activities, as warranted, at the Adams Plating facility. By execution of this Agreement, the MDEQ and Adams Plating stipulate and agree to be bound by all of the recitals, terms and conditions herein.

Whereas, any remedial action undertaken.pursuant to Section 20120b(3) of Part 201 of the Natural Resources and Environmental Protection Act (NREPA), 1994 PA 451, as amended, MCL 324.20101 or the Part 201 Rules, 1990 AACS R 299.5101 seg, which may include land use or resource use restrictions, monitoring, O & M, installation of permanent markers and continued financial responsibility, if determined by the MDEQ as necessary, shall be stipulated in a legally enforceable agreement with the MDEQ; and

Whereas, this Agreement pertains to Adams Plating and the Adams Plating property, located at 521 North Rosemary Street in Lansing, County of Ingham, State of ivOchigan, as d(iscribed m Attachment A; and

Whereas, the technical aspects of the 1993 Record of Decision (ROD) satisfy the substantive requirements of the former Michigan Environmental Response Act, 1982 PA 307, as amended which was in effect at the time the ROD was issued. No additional technical considerations will be necessary to address the June 1995 amendments to Part 201 of the NREPA. This Agreement satires the requirements of Section 20120b(3) of the NREPA, as amended in June 1995. Based on the foregoing recitals, the MDEQ and Adams Plating hereby stipulate and agree as follows;

I. PARTES BOUND 1.1 This Agreement shall apply to and be binding upon the MDEQ and Adams Plating and its successors and assigns. No change in ownership or corporate status of ..\dams Plating shall in any way alter Adams Plating's responsibilities under this Agreement. Any agreement assigning or transferring the rights, duties and benefits of this Agreement shall provide that the terms and conditions of this Agreement are binding upon the assignee or transferee. Adams Plating shall provide the MDEQ with written notice of the intent to transfer ownership of part or ali of their ownership interest in the property at the Adams Plating facility. Such tranrfer or assignment shall not occur without adequate and complete provision for the continued O & M of the remedy, and the prevention of exposures, as described in the deed restrictions for the Adams Plating property, as contained in Attachment B.

1.2 The signatories to this Agreement certify that they are authorized to execute and legally bind the parties they represent.

g. DEFINmONS 2.1 The terms "State" or "State of Michigan" shall mean the MDEQ and any authorized representatives acting on their behalf.

2.2 The "Plans" means the October 3, 1994, Final Groundwater Monitoring Plan, Volumes I and H, and the September 30, 1994, Final O M Plan;

2.3 Unless otherwise stated herein, all terms used in this document which are defined in Part 201 of NREPA shall have the same meaning in this document as in Part 201 of NREPA and the Part 201 Rules.

m FINANCIAL ASSURANCE MECHANISM 3.1 This portion of the Agreement is based on the current ability of Adams Plating to pay as shown by its financial records. If there is a substantial change in Adams Plating's financial condition, or if new information is obtained by the MDEQ regarding Adams Plating's ability to pay, then this section may be amended.

3.2 As of the date of execution of this Agreement and until further change as provided in Section 3.1 above, Adams Plating shall provide the following financial assurance mechanism to secure the performance of O & M, oversight, monitoring and other costs necessary to perform the work required by the Plans. Adams Platmg shall; (1) maintain sufficient funds in a deposit account in a banking institution to secure payment for the next monitoring event and any O & M associated with it, and such funds shall be on deposit to fully fund the monitoring and O & M as oi'30 days before the monitoring event is to begin and maintain such funds continuously until payment of the costs of the monitoring event and O & M; (2) upon request of the MDEQ, Adams F ating shall provide verification of the availability of such funds by bank records of balances, statements of financial condition, or other such financial records of Adams Plating, along with a current cost estimate for the cost of implementing the next monitoring event and O & M; and (3) upon request of the MDEQ, provide copies of receipts to verify that payments to contractors performing monitoring and O & M have been made and are current.

3.3 If the MDEQ determines that the financial assurance mechanism does not provide sufficient financial assurance for the payment of ongoing monitoring and O & M and other performance of the activities specified in the Plans, Adams Plating shall capitalize, revise and/or establish a new financial assurance mechanism to secure the ongoing monitoring, O & M and other activities called for by the Plans and this Agreement

IV. IMPLEMENTATION 4.1 Adams Plating agrees to implement and comply with the terms and conditions of the Plans and shall provide reports to the MDEQ project manager describing the activities that have b

4.2 Adams Plating shall submit for MDEQ approval any proposed modifications to the Plans, with a description of the proposed modification and rationale for the change. If modifications are not submitted and approved by the MDEQ, the monitoring and O & M activities should be conducted in accordance with the approved Plans. 4.3 O & M activities should be conducted concurrently with the groundwater monitoring events. The semiannual groundwater monitoring shall be conducted during the months of October and April, unless alternative dates are agreed upon in writing between Adams Plating and the MDEQ. Adams Plating shall provide the MDEQ ten (10) days notice prior to each sampling event. Furthermore, Adams Plating shall continue to perform the groundwater monitoring and O & M activities for a period of thirty (30) years, unless the MDEQ and Adams Plating jointly agree that the monitoring can terminate prior to the end of the thirty (30) year period. 4.4 Adams Plating shall designate a qualified contractor/consultant to perform the gi oundwater monitoring and O & M activities. All work shall be performed by, and under the direction of, qualified individual(s) with adequate expertise in the collection and preservation of samples; and with the expertise to be able to inspect the integrity of the monito ring wells and re port on any necessary or recommended repairs or alterations. Any necessary repairs, including well replacement, will be completed before the next scheduled groundwater sampling event. In addition, the samplers shall be familiar with, and abide by, the Plans and any approved modifications. A statement of qualifications and identification of personnel designated for the project, shall be provided to the MDEQ before the sampling events. The MDEQ should be notified and approve of any change in personnel in advance of the change. In addition, a copy of tliis Agreement should be provided to any and all contractors retained by Adams Plating for completing the work specified herein.

4.5 The National Oil and Hazardous Substances Pollution Contingency Plan (NCP), and the Comprehensive Environmental Response, Compensation and Liability Act, 1980 PL 96- 510, require that Five Year Reviews be conducted at sites where hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure. Because of the concentrations of contaminants remaining at Adams Plating, Five Year Reviews are required for this site. The MDEQ or EPA will be responsible for cijnducting these reviews. As a result of the Five Y'ear Reviews, modifications to the Plans are possible that would result in changes to the monitoring events. It is possible that this may include the need for additional monitoring wells. If so, the MDEQ would request Adams Plating to complete the work, or request compensation for completing the work according to Section Vn of tliis Agreement.

4.6 Within 30 days of the effective date of this Agreement, the owner shall provide the following information via certified mail to all persons with an easement interest in the Adams Plating property. The following should be contained in the Notice:

• The Adams Plating property is a "Facility" as defined in Part 201 of the NREPA. o A map of the Facility is attached, including the area of soil remediation and the location of the Claymax liner, which cjm not be penetrated. Soils under the Adams Plating building likely contain hiizardous substances, such as 1,1,1-trichloroethylene and chromium of unknown concentrations, that may present a potential source of exposure to individuals who engage in intrusive subsurface activities in this area. Groundwater at the Adams Plating property contains low levels of contaminants and may present an unacceptable risk if ingested. If additional information is needed, please contact the undersigned, and if it is available, arrangements will be made to provide the necessary information.

A copy of each certified letter should be sent to the MDEQ contact specified in Section X.

V. DEED RESTRICTION 5.1 Adams Plating shall record a Deed Restriction approved by the MDEQ and the EPA, with the Ingham County Register of Deeds. The Deed Restriction attached hereto as Attachment B should be recorded with the County wthin sixty (60) days of the Effective Date of this Agreement. 5 .2 Adams Plating shall provide a true copy of the recorded Deed Restriction to the \fDEQ and the EPA within fifteen (15) days after the document is recorded and returned. The copies provided to the MDEQ and the EPA shall include the liber and page number.

5.3 As part of the reporting requirements specified in Section IV of this Agreement, iA dams Plating shall confirm that the restrictions specified in the Deed Restriction are in compliance at Adams Plating.

VI. ACCESS TO PROPERTY AND RECORDS 6.1 From and after the EflFective Date of this Agreement, the MDEQ and its authorized employees and representatives, shall have an irrevocable right-of-access at all reasonable times ajid upon reasonable notice to the Adams Plating property for the purpose of determining and nKjnitoring compliance with the Plans, including the right to take samples, conduct inspections, take pictures, conduct oversight of the groundwater monitoring and inspect records related to the Plans. The MDEQ and authorized representatives shall also have access to other properties with monitoring wells. 6.2 This Agreement does not restrict or limit any right that the MDEQ may have to enter the Adams Plating property or other properties to which access is required for the protection of the public health, safety or the environment pursuant to specific statutory or regulatory authority. Consistent with the MDEQ's responsibilities under federal or state law, the MDEQ and its authorized representatives, shall use its best efforts to minimize interference and whenever possible employ efforts that are the least intmsive to the operations and commercial activities ori the Adams Plating property. "Best efforts" shall not require the MDEQ to incur any material cost increases in carrying out its responsibilities to protect public health, safety or the environment. 6.3 Adams Plating and its representatives, consultants and contractors shall preserve and retain, during the pendancy of this Agreement and for a period of ten (10) years after its termination, ail records, sampling or test results, and other documents relating to any requirement of this Agreement Adams Plating shall provide this documentation to the MDEQ, if requested,

Vn. PAYMENT OF OVERSIGHT COSTS 7.1 Adams Plating shall reimburse the MDEQ for all costs lawfully incurred by the State in overseeing implementation of the Plans and this Agreement. Oversight costs include, but are not limited to, costs incurred to observe and comment on field activities; review and comment on reports submitted to the MDEQ; collect and evaluate samples; purchase equipment and supplies to perform monitoring activities; attend and participate in any meetings; prepare and mail out public information newsletters; monitor compliance wth this Agreement; and Administrative costs, as well as

7.2a. Within sixty (60) days of the effective date of this Agreement, tire MDEQ will provide Adams Plating with a summary of all oversight costs incurred between October 1,1995, and the effective date of this Agreement. Adams Plating shall pay all oversight costs lawfiiUy incurred by the State from October 1, 1995, through the effective date of this Agreement in monthly installments, with the first monthly installment commencing within thirty (30) days of the date Adams Plating receives the summary of all oversight costs from MDEQ. Each monthly installment, except for the first installment, will be due on the first day of the month. All payments, with the exception of the payment constituting the final monthly installment, will be for an amount not less than one-thousand dollars ($1,000.00). A release and covenant not to sue for payment of oversight costs shall take effect upon payment by Adams Plating of all oversight costs lawfully incurred by the State.

7.2b Following each anniversary of the date of this Agreement, the >dDEQ will provide Adams Plating with a summary of all oversight costs incurred during the preceding year. Adams Plating shall pay oversight costs lawfully incurred by the State within sbcty (60) days of receipt of the oversight cost summary. A release and Covenant Not to Sue for payment of oversight costs shall take effect upon payment by Adams Plating of all oversight costs lawfully incurred by the State.

7.3 Payments are to be made by certified check payable to the "State of Michigan - Environmental Response Fund" and send to:

Cashiers Office MDEQ P.O. Box 30657 300 S. Washington Square, Suite 457 Lansing, Michigan 48909-8157

The certified check shall reference Adams Plating Facility, the Site ID No. 330001 and the Settlement ID No. ERD 2004. Costs recovered pursuant to this Agreement shall be deposited in the Environmental Response Fund in accordance with the provisions of Section 20108(3) of hlREPA, MCL 324.20108(3). Adams Plating shall also have the right to request the cost documentation pertaining to those costs; however, Adams Plating understands that it will be required to reimburse the State its costs for preparation of this cost documentation. "Cost documentation" shall include timesheets and travel vouchers of State employees, contracts, invoices and payment vouchers, to the extent they are available to the MDEQ.

Vm. COVENANT NOT TO SUE THE STATE/INDEMNinCATIQN Adams Plating hereby Covenants Not to Sue or take any civil judicial or administrative action against the State, its agencies, the MDEQ or their authorized representatives for any claims arising from or connected with execution of this Agreement. Adams Plating also agrees to indemnify the State of Michigan, its agencies, the MDEQ and their authorized representatives fi om any and all claims or costs of defending any and all claims brought by others based upon, arising from or connected with acts or omissions of Adams Plating. IX. REMEDIES FOR BREACH OF AGREEMENT 9.1 Adams Plating recognizes and understands that the MDEQ's remedies in the event Adams Plating breaches the terms and conditions of this Agreement may include but are not limited to, specific performance, issuance of unilateral admim'strative orders under Sections 20114(I)(h) or 20119 of the NREPA, MCL 324.20114(l)(h), 324.20119, reimbursement of c(3Sts, or any other statutory or common law authority subject to rights or defenses available to Adams Plating under applicable law.

9.2 Tliis Agreement shall not be construed as discharging the liability of Adams Plating or any other person or entity.

9.3 Nothing in this Agreement shall affect the duties and obligations Adams Plating may have with respect to permits or other governmental approvals or waive Adams Plating's duties and obligations under other applicable federal or state laws.

9.4 If any provision of this Agreement or the Plans lapse or are not complied with, and if Adams Plating fails to correct the lapse or violation within thirty (30) days of written notification of such lapse, the MDEQ, at its option, may perform the work necessary to bring Adams Plating back into compliance with this Agreement and the Plans and shall be reimbursed firom the financial assurance mechanism for such work.

X. NOTICES Whenever, under the terms of this Agreement, notice is required to be given or a report, sampling data, analysis or other document is required to be forwarded by one party to the other, such correspondence shall be directed to the following individuals at the specified addresses or at such other address as may subsequently be designated in writing:

As to MDEQ As to Adams Plating: Ms. Sally Beebe, Project Manager Mr. Steve Adams MDEQ, Environmental Response Division Adams Plating Company Superiimd Section 521 North Rosemary Street PO Box 30426 Lansing, MI 48917 Lansing, MI 48909-7926 517-321-8239 517-373-4110 (fax: 517-335-4887) via courier <- 301 South Capitol Avenue Lansing, MI 48933

XI. MODIFICATIONS This Agreement shall not be modified unless such modification is in writing and signed by the MDEQ and Adams Plating, Xn. RESERVATIONS OF RIGHTS BY THE STATE 12.1 The State reserves the right to bring an action against Adams Plating under federal and state law for recovery of all past response costs incurred by the State at the Facility which are not reimbursed as part of this Agreement. The State reserves the right to bring an action against Adams Plating under federal and state law for any costs incurred in the event that the State performs all or a portion of the response activities, for any future oversight costs incurred by the State in connection with response activities conducted at this Facility and for any natural resource damages and the costs of assessing natural resource damages. The State expreijsly reserves any and all rights and defenses that it may have to enforce this Agreement against Adams Plating, including the state's right to disapprove of response activities performed by Adams Plating and to require Adams Plating to perform tasks in addition to those detailed in this Agreement. The State reserves any rights it may have to undertake actions under federal and state law, including any response activities at any time and to perform any and all portions of the response activity which Adams Plating fails to perform to the State's satisfaction. Execution of this Agreement shall not affect or limit in any way any rights which the State may have in relation to any liabilities or obligations which Adams Plating or other persons may be subject to under Part 201 of the NREPA of other laws by virtue of any connections that Adams Plating or those other persons have or may have had with the Facility. The State reserves any and all rights it may have to take any enforcement action pursuant to any available legal authority, including the right to compel response activity; to seek injunctive relief, response costs, monetary penalties, and punitive damages; or seek other legal remedies that may be available for any violation of law or this. Agreement, mcluding the state's right to disapprove of the manner in which Adams Plating is implementing the Plans. Except as specifically provided herein, Adams Plating does not waive any defense to such an action by the State. 12.2 Nothing in this Agreement shall constitute or be construed as a release or covenant not to sue by the State regarding any claim, cause of action, or demand in law or equity against any person, firm, trust, trustee, joint venture, partnership, corporation, or other entity, for any liability it may have arising out of or relating in any way to the generation, storage, treatment, handling, t^^mspo^tation, release, or disposal of any hazardous substances, hazardous wastes, pollutants, contaminants, or injurious ^bstances found at, taken to, or taken fi-om the Facility. Tfiis Agreement shall not estop or limit any legal or equitable claims of the State against Adams Plating, its employees, authorized representatives or assigns, including, but not limited to, claims related to releases of hazardous substances, pollutants, contaminants, or injurious substances except as specifically provided for herein. Except as specifically provided for herein, Adams Pl ating does not waive any defenses to such claims of the State.

Xm. APPLICABLE LAW 13.1 This Agreement shall be construed in accordance with the laws of the State of Michigan. All actions required to be taken pursuant to this Agreement shall be undertaken in accordance with the requirements of Part 201 of the NREPA and its applicable Administrative Rules. 13.2 All tenns used in this Agreement which are defined in Part 201 of the NREPA, MCL 324.20101 et seq and/or the Part 201 Rules, 1990 AACS R 299.5101 et seq, shall have the same meaning in this Agreement as in Part 201 of the NREPA and the Part 201 Rules. If a conflict exists between the Rules and the statute, the statute prevails.

XIV. DISSOLUTION In the event that Adams Plating dissolves or otherwise ceases to conduct business and fails to make arrangements acceptable to the MDEQ for the continued implementation of the Plans, all rights under this Agreement in the financial assurance mechanism shall immediately and automatically vest in the MDEQ.

XV. SEVERABILITY The provi sions of this Agreement shall be severable, and if any provision is declared by a court of competent jurisdiction to be inconsistent with federal or state law, and therefore, unenforceable, the remaining provisions of this Agreement shall remain in fiill force and effect; except that such severance shall not be allowed if the severance of such provision causes the Agreement to fail in its essential purposes.

XVI- UNILATERAL WAIVER OF TERMS AND CONDITIONS Unilateral waiver by either party of any breach or failure to enforce any of the terms and conditions of this Agreement at any time, shall not in any way afiFect, limit or waive such party's rights thereafter to enforce and compel strict compliance with every other term and condition of this Agreement.

xvn. EFFECTIVE DATE This Agreement shall become effective on the date it is fiilly executed by all parties to this Agreement.

Alan J. Howard, Chief Date Environmental Response Division Michigan Draartment^ Environmental Quality

Steve Adams, President Adams Plating Company, a Michigan Corporation APPENDIX D 2002 PRP Request and 2003 DNRE Modification Approvals 521 N. Rosemary Street • Lansing, Ml 48917 Telephone 517/321-8239 • Fax 517/321-0316

April 5, 2002 APR -8 .

Ms Sally Beebe Environmental Response Division Superfund Section Knapps Centre P.O. Box 30426 Lansing, Michigan 48909

Dear Sally,

As I relayed to you during our telephone conversation on March 28"', I would like to request an amendment to the Ground Water Monitoring Plan. I appreciate your receptiveness to modifying the current plan and the proposed request for future monitoring. I have deferred seeking counsel on my proposal. Although you stipulated during our conversation that I should confer with my consultant regarding a proposed change, it is not financially feasible for Adams Plating to incur such charges at the current time.

The changes I am submitting lack the merit of a professional geologist. They are based upon the monitoring reports I have acquired from past events. The proposal I am submitting is based strictly from the information contained within these monitoring reports. The results from my acquisition of this data reflect what I perceive to be good judgement from a layman's point of view. This proposal is in no Vi/ay intended to diminish the importance of the Ground Water Monitoring Plan. Nor am I trying to diminish the level of professionalism in your office. I am submitting a revised plan on what has become a severely limited budget.

Adams Plating has suffered catastrophic losses during the current recession. Although economists have stated the recession is over, our business has not seen any gains and does not see any prospects in the future of a financial rebound. I postponed contacting you regarding changes to the plan on the offhand chance the economy would stimulate our finances. Regretfully economic stability has not occurred. I am well aware that the environment comes first and my business concerns are a distant second. I have tried my best to accommodate the concerns of the Department of Environmental Quality regarding issues instilled within the agreement. To date, my company has spent in excess of $100,000.00 on testing, well redevelopment and oversight charges. This amount of money is a sizable portion of my company's assets.

r IS DEQ Ms. Sally Beebe Grcund-Water VIonitoring Proposal April 5, 2002 Paqe2

First, I would like to reduce the number of chemicals being tested. Over the past five years, c<3vering both biannual and annual testing, none of these chemicals were found to be present in the sampling events. Therefore, 1 would logically assume that continued testing of these chemicals would not be necessary. Any chemicals found above the non detect limit will be retained for future analysis.

Requested chemicals for deletion from future testing;

1,1,1,2-Tetrachloroethane Carbon Tetrachloride 1,1,2,2-Tetrachloroethane Chlorobenzene 1.1-Dichloropropene Chloromethane 1,2,3-Trichlorobenzene Cis-1,3-Dichloropropene 1.2.3-Trichloropropane Dibromochloromethane 1.2.4-Trichlorobenzene Dibromomethane 1.2.4-Trimethylbenzene Dichlorodifluoromethane 1.2-Dibromo-3-Chloropropane Ethylbenzene 1,2-Dichlorobenzene Ethylene Dibromide 1,2-Dichloroethane Hexachlorobutadiene 1.2-Dichloropropane lodomethane 1.3.5-Trimethylbenzene Isopropylbenzene 1.3-Dichlorobenzene Methylene Chloride 1.3-Dichloropropane MTBE 1.4-Dichlorobenzene Naphthalene 2,2-Dichloropropane N-Butylbenzene 2,-Chloroethyt Vinyl Ether Nitrogen, Ammonia Cobalt Nitrogen, Nitrate 2-Butanone N-Propylbenzene 2-Chlorotoluene Sec-Butylbenzene 2-Hexanone Styrene 2-Methylnaphthalene Tert-Butylbenzene 4-Chlorotoluene Tetrachloroethene 4-Methyl-2-Pentanone Toluene Acrolein Total Xylenes Acrylonitrile Trans-1,2,-Dichloroethene Benzene Trans-1,3-Dichloropropene Bromobenzene Trichloroethene Bromochloromethane Trichlorofluoromethane Bromodichloromethane Vinyl Acetate Bromoform Vinyl Chloride Bromomethane •EQ Ms. Saliy Beebs Ground-Water Monitoring Proposal April 5, 2002 Page 3

Chemicals retained for future sampling events:

1.1.1-Trichlorethane Cis-1,2-Dichloroethene 1.1.2-Trichloroethane Copper 1,1-Dichloroethane Iron 1.1-Dichloroethene Lead 1.2-Dichloroethene Maganese Acetone Magnesium Aluminum Nickel Ammonia Nitrate Arsenic Potassium Barium Silver Beryllium Sodium Cadmium ^ Sulfate Calcium * Thallium Carbon Disulfide Total Cyanide Chloroethane Total Hexavalent Chromium Chloroform ) Vanadium Chrorrium Zinc

Secondly, defer annual sampling events to occur every other year. This in essence would mean that the next sampling event would occur in April of 2003. The every other year sampling program is based on the idea that the data benefits gained from annual sampling are not significant enough to warrant their continuance. Sampling every other year will provide the D.E.Q. with data to oversee the site and maintain standards. Hopefully the data already acquired from the site will support the rational of testing in this manner. With the current data fimily in place, I would like to suggest we move forward with testing every other year. By omitting this year's test, Adams Plating will be able to secure funds to offset the charges incurred by the D.E.Q. for the review of this proposal.

If you have any questions regarding this proposal or need further information pertaining to any of the contents, please feel free to contact me.

Sincerely,

Steve Adams Adams Plating STATE OF MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY LANSING lENNIPER M. GRANHOLM STEVEN E. CHESTER GOVEF;NOR DIRECTOR

April 3, 2003

Mr. Steve Adams Adams Plating Company 521 North Rosemary Street Lansing, Michigan 48917

Dear Mr. Adams;

SUBJECT: Approval of Modifications to the 1997 Agreement for Groundwater Monttorina and Operation and Maintenance (AOC-ERD-97-002) for the Adams Plating Company Superfund Site

This letter is in further response to your letter dated April 5, 2002, requesting modifications to the groundwater monitoring program for the Adams Plating Company Superfund site, located in Lansing Township, Michigan. An initial response letter was sent to you on April 22, 2002. The April 22, 2002 letter allowed a reduction in sampling frequency (i.e., sampling monitoring wells every other year, not every year). The purpose of this letter is to approve a reduced list of parameters for all of the monitoring wells. The list below is not the same as the list in your April 5; 2002 letter, so please be sure to use the parameter list in this letter for the next round of sampling, which is scheduled for the week of April 28, 2003.

The 1997 AOC-ERD-97-002 between the Department of Environmental Quality (DEO) and Adams Plating requires that you isubmit for our approval any proposed modifications to the tong- tenti monitoring program, including the rationale for the requested change. Your letter of April 5, 2002 met this requirement.

Groundwater data from the December 1998, June 1999, June 2000, and the May 2001 Groundwater Monitoring Evaluation Reports prepared by Strata Environmental Services, Inc. (Strata) has been reviewed to evaluate your request to reduce the parameter list. The DEQ hereby approves your request with modifications in accordance with Section 4.2 of AOC-ERD- 97-002. All the monitoring wells that are part of the Adams Plating groundwater monitoring prociram must be analyzed for the following parameters.

Acetone Sulfate Lead 1.1-tiichloroethane Nitrite/nitrate Manganese 1,1,1-trichloroethane Aluminum Nickel chloroethane Cadmium Sodium 1.2-di0hloroethane Chromium Thallium 1,1-dichloroethene Cobalt Vanadium cis-1,2,-dichloroethene Copper vinyl chloride Iron

CONSTTTIJTION HALL • 525 WEST ALLEGAN STTIEEr • P.O. BOX 30426 • LANSING, MICHIGAN 485)03-7926 vvww.michigan.gov • (517) 373-9607 Mr. Steve Adams Pace 2 Apr I 3, 2003

Hexavalent chromium and arsenic have been eliminated from your revised list, but may need to be added again in the future. Unless total chromium concentrations increase, it is not necessary to analyze for hexavalent chromium, the more toxic and unstable form of chromium. The current drinking water standard for arsenic is under review and may be reduced to a much lower concentration, requiring it to be added back to your parameter list.

Vinyl chloride has l)een added to your revised list even though it has not been detected at the site It is a breakdown product of 1,1,1-trichloroethane, which has been detected at the site. Cobalt has been added to the list as it has been detected in previous sampling events above our Part 201 drinking water criteria (Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended). Other parameters were deleted from your list because they may have been detected in the groundwater at this site but at concentrations that do not pose a risk, and therefore, additional monitoring is not necessary.

It is also important that the laboratory used to analyze the samples obtains a detection limit lower than the Part 201 cleanup criteria for each, of the atxjve parameters. Attached for your convenience is a list of the cleanup criteria. The parameters to be analyzed for at this site, along with the drinking water criteria have been highlighted for your convenience. Detection limits must be below the highlighted criteria. For example, in previous Strata reports, the method detection limit for aluminum was 100 ug/l, and the drinking water criterion is 50 ug/l. Future sampling should obtain a detection limit of less than 50 ug/l for aluminum.

The DEQ may conduct oversight of the April 28, 2003 groundwater monitoring activities. If you have any questions, please contact me,

Sincerely.

Sally Beebe, Senior Project Manager Superfund Section Environmental Response Division 517-373-4110

Attachment cc/att; Mr. Pablo Valentin, U.S. EPA Ms. Daria W. Devantier, DEQ/Adams Plating File - N1 Ms. Barbara Vetort, DEQ APPENDIX E Newspaper Public Notice 2A • Thunday. OacemtKr tS, 20U • Ljmng State Journal wwvw.lsj.com Snyder: Education reforms set for January

haven't looked at that de- decision in November. three months and make helped lead reform ef Governor's new agenda will tackle taiL- Some authorizers told the recommendations to Sny forts to nirn around transpaiency, higher standards Soyder also was asked Free Press they want to der and Detroit Mayor schools in New Orleans about state schools Super- know whether theyYe off MQce Duggan. Snyder following Hurricane Ka- By Jennifer Olxon and charters receivenearly $l inteodent Mike Flana the list. said hesupports theeffon trinn during a time when Ann Zanlewski billion a year in state tax gan's dedsion to put U The reforms are ex and will offer feedback. die sraieRecoverySchool payer money, often with charter authorizerson no pected to be announced "iDoeoftbethingsllike District expanded and little accountability or tice that they areat risk of during theeoveniar's Jan. in particular tbou^ It's a schools within it became Gov. Ridt Snyder in transparency in bow being suspended, which 20 State of the State ad cooinninity conversatioiL charters. January will announce those dollars arespenL would bar them, from dress. Whether a spedftc . In fact. I'm actually not Snyder reiterated his education reforms that The series also found opening new charters. reform requires legisla coming forward with displeasure with how will include more trans* academic performance is Their erisring schools tive approval would de ideas that we might have more than live years of parenc7 and raising Che for-profit charter tnan- tutional questions on der said. do something iegisiative- too long." dined to disci^ details. agement oompany, owns some of this. ... What 1 •A Snyder spokesman ly in the flrsi half of next .Along with the new Broader reforms about the contents of mostof its would say is. is again. I'm sold the governor was re year." education coalition, a dif the future of education to school buUdings, even Qot going to givea blanket ferring to fnatring a deci Snyder said he's seen ferent group of education the city will unfold later though those funushiogs statement onwhat 1would sion about the leaJersbip various draft plans creat leaders in Detroit has with input from a new and equipmeot may have say isOK ornot OK. 1have of DPS as a oewly formed ed by Paul Pastorek. a for been studying the possi «/hir-nHn« COalltiOO. purchased with tax a good workiog relacion- education ("ftalirinn 1^. mer Louisiana superin bility of creating auniver Snyder, in a wide-rang- payer money. sh5) with him. we've plores options for longer- tendent of education who sal enrollment system ii^ interview, would not Asked whether that is worked well together, and term reforms. has been advising bis of that would involve both discuss specifics when appropriare public policy, I would expea that tocon- The Coalition for the fice 00education issues in traditianal public and asked about refonning Snyder said: That's tDme." Future of Detroit School Detroit and beyond, but charter schools. the state's charter something that I oeed to The Michigan Depart- children, a group of busj- stressed be wants the co Snyder on Hiesday schools. The Free Press look SL _ I doDt have meot of Education s^ in ness, dvk and education alition to be at tbe fore- called common enroll published an eight-day enough data to give you a August, when- Flanagan leaders, will study prob ftont of educatioo reform ment 'an interesting series in June that found strong answer on that one announced the at-risk Use lems regarding educanoo ideas in Detroit idea." the state's roughly 300 at this point, because I that he would makea final in Detroit over tbe.nexr In Louisiana. Pastorek

who is from Belgutm, the ±e .American students." as a coach is 40-300. Swim experience is about be T tell them every year, longing to a group. Family atmospherw at the banquet and first Continued front Page lA "People have said chat Before every meet the day of practice, fm here • Midday Daay.3:4tl » PokerLona 6*. 8«. U.9*. Sv tbe swim team is a great team has dinner at a dif to make you a bener per they have to.pay to do team and they are great ferent family member's son," Dahlke said. Tm go • Evening OaOy3: OanicliittDA?: 1,2.11,15,38,44 clubs. There isn't school people," said Mourmaux. home. Dahlke says it'snot ing to make you fight and 833 SI.SOOJX» athletics anywhere else. "It's a big team, so we get unctunmoo for him to learn to get past whatever > Midday OaPyU: 5.13,28.43,55 ' That's an American CO meet a lot of people." come home Cram work is in front of you." 6197 Immersing exchange Po«Mr8alh33 Paw«rP(ay:3 thing." and have his swimmers That approach, mixed . Evening Daay*4: Dahlke believes that students in the experi watching a movie. .And at with the family atmos Wedrwfda/S jackpot SeO mifiar word-of-moutb may be ence of a new coaniiT and the end of the season, he phere sumun^g the • FantaiyS: the reason for tbe stream a new high school is the Cakes bis team on skiing program, is part ot what Tuesday's results of foreign students into goal, says Shanntm Horse. and canoe trips. drew Tbn Ela to the team 6.8,34, 36. - Maga MillicMiE 4|. 58.68.72.73 the program. While tbe She lives in the district 'It's like a famdy-cype this season. thing," senior captain "I was really surprised 371ackpoc SnO.OOO numbers vary from sea and isa representativefor MegaBahl Magapll«:5 son to season, exchange lpt>m«rinnal thiricnt RY. Conner Applebee said. because everybody, when • KenocS. 13.19.21. Witifwfsnm students have been a part change. Sheis hosting two "No matter where you're you jump in tte water and 23.24,26.28. 33. Friday^ jadcpoc SI25 mdion of tbe team for at least two students at her home this from, or who you are, start swunming, will start 34.38.41.47.51. decides. year. you're alwayswelcome on cheering you on," said Ha, 52.60,64,69, 73. "I don't remember a 'Trom my family, we the swim team. We're not who is from Vietnam. 77,78,79 team without at least one do encourage exchange exactly tbe most success "We're not that excited For bimy resu/B 24hotn 4oky, oE 3J5-S640. exchange student," students who we host to ful swim team, so if you like that in my country." Dahlke said. I've been pursue swimnung be come out, you got a spot Ha said thatisaspedaJ ttie head coachsince 1993, cause of the team building (on tbe team)." experience for hen and Fve always had at and group activities the The program's focus is . They don't care how least one.We're morelike team has," Hurst said. on acMevlng life-long good you are, or how slow Corrections and clarifications ly CO have seven or eight "Dahlke does a great job goals, rather than wins or fast ymi are. They than one or twa" of getting them involved and losses, says Dahlke, cheer you on." The Lansing State Journal strives to provide For Julie Mourmaux, so that they get to know who estimates his record accurate andâir reportou. It is our poUcy to cor rect suAstantive errors qf,îct If you think we may liove published incorrect ir/omujtion, please call makeup cotisistenc with POUCE SHU SEARCHING FOR WOMAN . 377-1174 or email carrections<9ls).ceTn. Robbery what witnesses saw dur ing the previous robber Foike v« looking for Scantavia Ronda ttuc,the woman nPagelA ies, the oews release said. chatged in tb« axupiracy. Anyona with infonnation jhouW Mitchell, according to all Laming polke Oeteg$vnd>y Jooaihan Daf fm. lowed the teller to a print rSden OdkJVf. 321JIG per Tbey are charged in TV U.S. Emri counter. At the counter fiw-year review ofche AdBnt Phiin| SwysAoid liu. 321 OnUOevta two robberies at the Aste- the man handed the teQer XowlBY Rd_ LansiD^ Mkh. TV St^criWid taw requtres Conuolv Rua JtM Mu«prnt edtion ra (Iredit Union on East a note chat read, 'Hand (tgultr dwdnim ot'iica dai haw been ekanedop- with didMiaOkMnri dcmyapplv ID 4K4Iwhere Jolly Road, on Sept. 9 and me $30,000 or you'll get «3Uc managed o ai^nniorttnity ibr you to (cU EACH Oiîai AcecsSUBfCnp- n* LanWig State JouiW torney's Office. Court Shopping Center. Tbe EPA aboul ti'U csnliiuatt any concens yoi tiavc. Cdiiuet: (KSN «274.9743)<1puilfehcd HON mdudcs aoceuu Mj:am, tablft. matak and thee44euw4- documents say. they were first mu askeda teller if OjAy 0/ Fcdvated Pimicaaore on their way to rob the the mstituQan was a cred Saua Paster Pablo Vakndo Inc.. a whoPyanmcd pec Fee no«(dormauon. coriurs <9001234.1719. Dearborn Federal Credit it umon and handed (he Conimuiiry Iflvalvemoii Remedial Project Manager Gamca Cahic. 120 Lleneoiea Union in Lansing Ibwn- teller a note. Coordiiiawr 3I2-333-2S86 5).. Lammg. u.48919. PeWdcx 312-133.1123 valenlin.paUu'Seta.gov DOCtagapHniarsng. Oa4ySlJ30 SimdayS3.0( ship. Tbey were traveling The man, speaking in a in two vehicles when they whisper, told the teller to P»w-w»«iWa-5« pQtQnaner; Send aoacsicnangcs 10Urnkqtuie Journal. 120 C. wete puiled over on inter "give him $30,000 or be larwvcv $U laneniM. 48919. Hie

Site name Date of inspection: \Q ^ '2.0 l5

Location and Region: iDAiO EPA ID: KXX) COG 5 ZCL7S Agency, office, or company leading the five-year Weather/temperature: review: P? rQ,m ; 72^F Remedy Includes: (Check all that apply) • Landfill cover/containment • Monitored natural attenuation • A^ess controls • Groundwater containment Cmstitutional controls • Vertical barrier walls • Groundwater pump and treatment • Surface water collection and treatment • Other VDcmri mof) 147)n

Attachments: • Inspection team roster attached • Site map attached Ao~5^5vfyici55~

1. 0«&M site manager Name Title Date Interviewed •at site •at office Dby phone Phone no. Problems, suggestions; DReport attached

2. O&M staff. ivame Title Date Interviewed: •at site •at office •by phone Phone no Problems, suggestions; •Report attached OSWERNo. 9355.7-03B-P 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.

Contact McCtCiiMxiynzytf CCbllOfl^ 5n~Z84'-S^ ^ ^ Title ^ Date Phone no. Problems; suggestions; Report attached , . . p re-eucxlTtri k/itv ciyvk-v- KL/f-s -

Agency Contact Name Problems; suggestions; Report attached

Agency Contact ,^'^ame Title Date Phone no. Problems; suggestions; Report attached

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

4. Other interviews (optional) Report attached. ITTA

D-8 OSWERNo. 9355.7-03B-P

m. ON-SITE DOCUMENTS & RECORDS VERIFTED (Check all that apply)

O&M Documents O&M manual Readily available N/A As-built drawings Readily available N/A Maintenance logs Readily available N/A Remarks

Site-Specific Health and Safety Plan Readily available ^ptoda^ N/A Contingency plan/emergency response plan Readily available Up to date Remarks

3. O&M and OSHA Training Records Readiiy available Up to date '^N/^ Remarks ^

4. Permits and Service Agreements Air discharge permit Readily available Up to date Effluent discharge Readily available Up to date Waste disposal, POTW Readily available Up to date Other permits Readily available Up to date Remarks

5. Gas Generation Records Readily available Up to date Remarks

6. Settlement Monument Records Readily available Up to date (|^^N/^ Remarks

7. Groundwater Monitoring Records Readily available datp N/A Remarks

8. Leachate Extraction Records Readily available Up to date Remarks

9. Discharge Compliance Records Air Readily available Up to date k N/A. Water (effluent) Readily available Up to date ,Cl^ Remarks

10. Daily Access/Security Logs Readily available Up to date Remarks

D-9 OSWER No. 9355.7-03B-P ly. O&M COSTS O&M Organization State in-house Contractor for State PRP in-house Contractor for PRP Federal Facility in-house Contractor for Federal Facility lit t Other S( k. bet nc. re. - gpft Qaxiyvi(t3cckrv:tTi^r'>^'Qaxiyvi(t3cc::^€rvrt ^ Of f-Xl^K.

2. O&M Cost Records P |A Readily available Up to date Funding mechanism/agreement in place Original O&M cost estimate Breakdown attached

Total annual cost by year for review period if available

From To Breakdown attached Date Date Total cost From To Breakdown attached Date Date Total cost From To Breakdown attached Date Date Total cost From To Breakdown attached Date Date Total cost From To Breakdown attached Date Date Total cost

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

V. ACCESS AND INSTITUTIONAL CONTROLS ^^^licable) N/A A. Fencing 1. Fencing damaged Location shown on site map Gates secured Remarks

B. Other Access Restrictions 1. Signs and other security measures Location shown on site map Remarks

D-10 OSWERNo. 9355.7-03B-P

C. Institutional Controls (ICs)

1. Implementation and enforcement Site conditions imply ICs not properly implemented Yes No Site conditions imply ICs not being fully enforced Yes No

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 Remarlcs

D. General

1. Vandalism/trespasstna ~ Location shown on site map ^=^^^^dalism evide^^ Remarks A

Land use changess onOft site N/A -r—— '1^1 I / I Remarks .None. U4u fiGctS desh-ticted Iv-v Q-p 7-o)n ^ Land use changes off site N/A Remarks

VI. GENERAL SITE CONDITIONS

A. Roads Apphcable

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

D-11 OSWERNo. 9355.7-03B-P

B. Other Site Conditions

Remarks-

Vn. LANDFILL COVERS Applicable

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 Length3_ Widths • Depths Remarks

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

Holes Location shown on site map Holes not evident Areal extent_ Depth Remarks

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

D-12 OSWEJi No. 9355.7-03B-P

8. Wet Areas/Water Damage Wet areas/water damage not evident Wet areas Location shown on site map Area! extent_ Ponding Location shown on site map Areal extent_ Seeps Location shown on site map Areal extent_ Soft subgrade Location shown on site map Areal extent_ Remarks

9. Slope Instability Slides Location shown on site map No evidence of slope instability Areal extent Remarks

B. Benches Applicable N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to inteiiupt the slope, in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay Remarks

2. Bench Breached Location shown on site map N/A or okay Remarks

3. Bench Overtopped Location shown on site map N/A or okay Remarks

C. Letdown Channels Applicable 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.)

1. Settlement Location shown on site map No evidence of settlement Areal extent_ _ Depth Remarks

2. Material Degradation Location shown on site map No evidence of degradation Material type Areal extent Remarks

3. Erosion Location shown on site map No evidence of erosion Areal extent_ _ Depth Remarks

D-13 OSWER No. 9355.7-03B-P

4. Undercutting Location shown on site map No evidence of undercutting Areal extent Depth Remarks

3. Obstructions Type No obstructions Location shown on site map Areai 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 Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks

Gas Monitoring Probes Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks

3. Monitoring Weils (within surface area of landfiU) Properly secured/locked Functiomng Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks

Leachate Extraction Weils Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarics

Settlement Monuments Located Routinely surveyed N/A- Remarks

D-14 OSWERNo. 9355.7-03B-P

E. Gas Collection and Treatment Applicable

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 Funrtioning N/A Remarks

2. Outlet Rock Inspected Functioning N/A Remarks

G. Detention/Sedimentation Ponds Applicable N/A

SlltationAreal extent Depth_ N/A Siltation not evident Remarks

Erosion Areal extent Depth_ Erosion not evident Remarks

3. Outlet Works Functioning N/A Remarks

4. Dam Functioning N/A Remarks

D-15 OSWERNo. 9355.7-03B-P

H. Retaining Walls Applicable T N/A

1. Defonnatians Location shown on site map Deformation not evident Horizontal displacement_ Vertical displacement Rotational displaceraeiit_ Remarks

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

I. Perimeter Ditches/Oif-Site Discharge Applicable C^WA^

1. Siltation Location shown on site map Siltation not evident Areal extent_ Depth Remarks

2. Vegetative Growth 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

Discharge Structure Functioning N/A Remarks

Vm. VERTICAL BARRIER WALLS Applicable (^/A^

Settlement Location shown on site map Settlement not evident Areal extent_ Depth Remarks

Pf.rtoi 05,. lonitoringType of monitoring_ Perform not monitored reqiienr Evidence of breaching • ,.al

D-16 OSWER -Vo. 9355.7-03B-P

LX. GROUNDWATER/SURFACE WATER REMEDIES Applicable

A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing, and Electrical Good conditioti 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 Readily available Good condition Requires upgrade Needs to be provided Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines Applicable

1. 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 OSWERNo. 9S55.7-03B-P

C. Treatment System Applicable

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

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

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

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

5. Treatment Bailding(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. Mooitoring Data

1. Monitoring Data routinelv submitted on tinisZ^ Is of acceptable quality

~2. Monitoring data suggests; ^e.i Groundwater plume is effectively contained Contaminant concentrations are declining

D-18 OSWER Mo. 9355.7-03B-P

D. Monitored Natural Attenuatioa MoDitoring Wells (natural attenuation remedy) Properly secured/locked Functioning Routinely sampled Good cog All required wells located Needs Maintenance 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 OBSERVATIONS 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 plumm minimize infiltration and gas emission, etc.)., COcxs trrv

t o direct P&r>x:)Dc^( <^cL-W o ^ I wTv i7\'i nM- HsR.q

^ "S'u^fvtgi '6 -to I f

B. Adequacy of O&M Describe issues and obligations related to the implementation and scope of O&M procedures. In particular,pamcuiar, discussaiscuiis theirincix relatdonsfaipreiauocuiiup toto mcthe i;urrcnicurrent anuand long-Leniilong-term pruLccuvcucssprotectiveness oiof methe remcQy.remedy. • / ^^ r'ovX:AcLI _ i ,0^ (II \ jj'e.il_ • 1 ^ _ /

D-19 OSWER No. 9355.7-03B-P C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised^the:dIOTA jivthe future.

D. Opportnnltles for Opdmization Describe possiblejssibleIT/A opportopportunities for optimization in monitoring tasks or the operation of the remedy.

D-20 Photo 1- Adams Plating Site property overlooking Rosemary Street

Photo 2 - Vegetative cover over area of Time Critical Excavation Photo 3 - Warehouse Property 511North Rosemary Street

Photo 4 - Sump Connection at S17 North Rosemary Street Photo 5 - sump discharge pipe 517 North Rosemary Street

Photo 6 - Sump discharge Point Photo 7 - Monitoring Well MW-02