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Adams Plating Company Superfund Site Lansing, Ingham County, Michigan

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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 486624 < z UJ J3 o O \ 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
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