EPA Region 5 Records Ctr.
//1111111/11 111111111/1111/ 11/111111/11/ 334806
Third Five-Year Review Report
Organic Chemicals, Inc. Superfund Site City of Grandville Kent County, Michigan
September, 2009
PREPARED BY:
United States Environmental Protection Agency Region 5 Chicago, Illinois
Approved by: Date: _----&Jc (! K~ Richard C. Karl, Director Superfund Division Table of Contents
Executive Summary iv Five-Year Review Summary Form vii I. Introduction 1 Purpose of the Review 1 Authority for Conducting the Five-Year Review 1 Who Conducted the Five-Year Review 1 Other Review Characteristics 2 II. Site Chronology 2 III. Background 3 Physical Characteristics 3 Land and Resource Use 5 History of Contamination 5 Initial Response 7 Basis for Action 8 IV. Remedial Actions 9 Remedy Selection 9 Cleanup Standards 10 Remedy Implementation 11 System Operations/Operation and Maintenance (O&M) 12 Institutional Controls 13 Status ofICs and IC Follow up Actions Needed 14 V. Progress Since the Last Review 16 Protectiveness Statement from the Last Five Year Review 16 Status of Recommendations from the Last Five Year Review 16 Results of Other Implemented Actions 17 VI. Five-Year Review Process 18 Administrative Components 18 Community Involvement 18 Document Review 18 Data Review 19 Site Inspection 19 VII. Technical Assessment 20 Question A: Is the remedy functioning as intended by the decision documents? 20 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? 21 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? 22 Technical Assessment Summary 22 VIII. Issues 23 IX. Recommendations and Follow-up Actions 23 X. Protectiveness Statement 24 XI. Next Review 24 Tables Table 1 - Chronology of Site Events Table 2 - Hazardous Substances and Media Table 3 - Groundwater Cleanup Goals Table 4 - Soil Cleanup Goals Table 5 - Institutional Control Summary Table 6 - Actions Taken Since the Last Five-Year Review Table 7 - Issues Table 8 - Recommendations and Follow-up Actions
Figures Figure 1 - Site Location Map Figure 2 - Existing Site Characteristics
,e~ttachments Attacr.ment 1 - Former Site Layout Attachment 2 - Site Monitoring Wells Attachment 3 - Situation Assessment Report Attachment 4 - 2009 Groundwater VOC Data Attachment 5 - Select VOCs in Groundwater versus Distance Attachment 6 - Isopleths for Total Performance Standard Compounds (2009) Attachment 7 - Photos Documenting Site Conditions
11 List of Acronyms
APC alternate point of compliance ARAR Applicable or Relevant and Appropriate Requirement CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency ESD Explanation of Significant Difference ICs Institutional Controls MCL Maximum Contaminant Level MCLG Maximum Contaminant Level Goal MDEQ Michigan Department of Environmental Quality MNA monitored natural attenuation NCP National Contingency Plan NPL National Priorities List O&M operation and maintenance PAH polyaromatic hydrocarbon PCB polychlorinated biphenyl ppb parts per billion PRP Potentially Responsible Party PSGM post shutdown groundwater monitoring RA Remedial Action RAO Remedial Action Objective RD Remedial Design RIIFS Remedial InvestigationlFeasibility Study ROD Record of Decision SRI Superfund Redevelopment Initiative TPI Total Petroleum Inc. UUIUE unlimited use or unrestricted exposure VOC volatile organic compound
III Executive Summary
EPA, Region 5 has conducted a third five-year review ofthe remedial actions implemented at the Organic Chemicals, Inc (OCI) Superfund Site in Grandville, Michigan. This review was conducted from June, 2009 through September, 2009. This report documents the results of the review.
The GCI property is located at 3291 Chicago Drive, S.W., in the city of Grandville (population 16,263), Kent County, Michigan. The OCI property is approximately 5 acres and is located in anlndustrial and commercial area. The OCI property formerly had several buildings and structure~, occupying the property. The chemical manufacturing operation, which was housed in two buildings along the western boundary of the property, produced specialized industrial chemicals and pharmaceutical intermediates. The solvent recovery operation was housed in several buildings along the southeastern portion ofthe property. Other structures included a warehouse, several drum and storage tank areas, an office building, a boiler facility and a wastewater pre-treatment facility. OCI stopped operations in May 1991. Grandville-based 4-J Trucking Company purchased the OCI site property in November 2006.
Remnants of former site activities are located throughout the site and most of the central portion of the site is covered with concrete slabs. A recessed loading bay remains in front of the large former solvent building located on the eastern portion of the site. The groundwater extraction and treatment system is housed in the building adjacent to the former solvent building. A large pile of debris from on-site demolition is located towards the rear of the property. Monitoring wells are located throughout the site.
The primary contaminants of concern found at the Site were/are chlorinated solvents and benzene, toluene, ethylbenzene, and xylene (BTEX) compounds in soil and groundwater. EPA organized cleanup at the Site into two operable units (OUs). OU 1 (ROD signed September 30, 1991) was an interim action to address groundwater by containing the contaminant plume migration. OU 2 (ROD signed February 5, 1997), selected responses to remediate the groundwater to comply with Maximum Contaminant Level (MCLs), and the soil contamination to be protective in an industrial setting. The OU 2 Record of Decision (ROD) also allowed for an Alternate Point of Compliance (APC) for attainment of the groundwater st'mdards. An ESD was signed or. September 29,2003 that documented the temporary shutdown of the groundwater extraction and treatment system. During this shutdown, a study was conducted to evaluate the potential for an APC for the groundwater, as allowed by the OU 2 ROD. The second modification in the ESD addresses groundwater performance standards, MCLs, and a provision in the Consent Decree's Statement of Work (SOW). The last modification noted in the ESD was the off-site disposal of the soil versus the originally planned on-site treatment and disposal of the hazardous material. The soil remedial action (RA) was started in September 2001 and was completed in September 2003. The Completion of Remedial Action Report was submitted in March 2004.
IV This third five-year review has identified the following recommendations and resulted in the following determinations:
Question A: Is the remedy functioning as intended by the decision documents?
Yes. The conclusion drawn from this third five-year review, including the review of documents, ARARs, risk assumptions, cleanup goals, and the results of the Site inspection, is that the remedy is functioning as intended by the OU2 ROD, as modified by the ESD.
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?
Yes, the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy selection are still valid, except for the MCL for arsenic, discussed in the report. Land and groundwater use at the Site is still consistent with the assumptions used to determine where cleanup would be performed. There have been no changes in the physical conditions of the OCI Site that would affect the protectiveness of the remedy.
Question C: Has any other information come to light that could call into question the protectiveness of the remedy?
No other events have affected the protectiveness of the remedy and there is no other information that calls into question the short-term protectiveness of the remedy. The Site soil was cleaned to industrial use goals, and the Site is being used for industrial purposes. There are no newly identified ecological risks. Natural or man-made disasters have not affected the Site. The discussion in the body of this third five-year review will highlight some issues that may affect the protectiveness of the remedy in the long-term.
Protectiveness Statement:
The remedy at the OCI Site currently protects human health and the environment in the short-term. There are no current exposure pathways and the remedy appears to be functioning as designed. The removal of soils to eliminate the source of contamination has achieved the remedial objectives to minimize the migration of contaminants to groundwater and surface water, and prevent direct contact with, or ingestion of, contaminants in soils which were remediated. There is no current groundwater use and ICs for groundwater have been placed to prevent unacceptable future use or exposures. However, long-term protectiveness requires compliance with effective ICs. To that end, soil ICs must be implemented to address the residual soil contamination and restrictions on the construction of new buildings over the groundwater plume without vapor abatement systems, and the effectiveness of the groundwater ICs must be reviewed. Also, the ICs must be monitored, maintained and enforced. The ongoing MNA of groundwater is expected to meet the groundwater cleanup standards in the long-term, but continued evaluation of groundwater contaminants is necessary, and additional assessment of the expected timeframe and additional trend analysis would be helpful to track progress of MNA.
v !~ecommendations and Follow-up Actions
The following table summarizes the recommendations and follow-up actions that have been identified as a result of this third five-year review for the OCI Site. Implementation of the r~commendationsand follow-up actions will be tracked and monitored to ensure that they are completed in a timely manner.
Recommen d a t"Ions an d F 0 IIow-u p At"C IOns Affects Protectiveness? Recommendationsl Party Oversight Milestone (YIN) Follow-up Actions Responsible Agency Date Current Future An IC work plan will be submitted by IC Work the PRPs to EPA for review and Plan by approval for Ie activities including 12/15/10 implementation of soillCs and n~viewing the dfectiveness of groundwater ICs. The IC work plan EPAlPRP EPA N Y shall also include other IC evaluation activities including a review of the long term stewardship procedures to ensure that the ICs are monitored, maintained and enforced. Work with PRPs to implement a Approve EPAlMDEQI groundwater pilot study, including EPA work plan N y PRP a-.:ceptable monitoring. by 10/30/10 Sample for anenic. EPAlMDEQI 2010 EPA N Y PRP sampling Update O&M Plan for groundwater 2010 plan monitoring: by 4/30/10; 2010 work; Evaluate Evaluate need for additional constituents constituents; and EPAIMDEQI by 12115/10; EPA N Y Post-pilot monitoring. PRP Post-pilot plan after pilot study work completed I
VI Five-Year Review Summary Form
SITE IDENTIFICATION
NPL status: Final Remediation status Operating Multiple OUs?* YES Construction completion date: 09 129 12003 Has site been ut into reuse? YES
Author affiliation: U.S. EPA, Re ion 5 9/27/2009 16,2009
Review number: third Tri Triggerin action date (from WasteLAN): 9/27/2004 Due date (five ears after tri gering action date): 9/27/2009 * ["OU" refers to operable unit.) *. [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.)
Vll Five-Year Review Summary Form, cont'd.
I=;sues: See Table 7 from the report: rcs not in place for soil. Also, effectiveness of existing groundwater rcs must be reviewed along with long term stewardship procedures.
Occasional exceedances of groundwater standards at the APC boundary.
Arsenic MCL has changed since last FYR.
Approved groundwater monitoring plan was completed in 2009 - new monitoring program needed.
Recommendations and Follow-up Actions: See Table 8 from the report: An rc workplan will be submitted by the PRPs to EPA for review and approval for IC activities including implementation of soil ICs and reviewing the effectiveness of groundwater rcs. The rc workplan shall also include other rc evaluation activities including a review of the long term stewardship procedures to ensure that the ICs are monitored, maintained and enforced.
Work with PRP to implement a groundwater pilot study, including acceptable monitoring.
Sample for arsenic.
Updatt: O&M Plan for groundwater monitoring: 2010 work Evaluate need for additional constituents Post-pilot monitoring
Protectiveness Statement(s): The remedy at the OCI Site currently protects human health and the environment in the short-term. There are no current exposure pathways and the remedy appears to be functioning as designed. The removal of soils to eliminate the source of contamination has achieved the remedial objectives to minimize the migration cf contaminants to groundwater and surface water, and prevent direct contact with, or ingestion of, contaminants in soils which were remediated. There is no current groundwater use and rcs for groundwater have been placed to prevent unacceptable future use or exposures. However, long-term protectiveness requires compliance with effective ICs. To that end, soil ICs must be implemented to address the resldual soil contamination and restrictions on the construction of new buildings over the groundwater plume without vapor abatement systems, and the effectiveness of the groundwater ICs must be n:viewed. Also, the ICs must be monitored, maintained and enforced. The ongoing MNA of groundwater i'. expected to meet the groundwater cleanup standards in the long-term, but continued evaluation of groundwater contaminants is necessary, and additional assessment of the expected timeframe and additional trend analysis would be helpful to track progress ofMNA.
Other Comments: None
Vlll Organic Chemicals, Inc, Superfund Site Grandville, Michigan Third Five-Year Review Report
I. Introduction
Purpose of the Review
The purpose of five-year reviews is to detennine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and recommendations to address them.
Authority for Conducting the Five-Year Review
The United States Environmental Protection Agency (EPA) is preparing this third five year review pursuant to CERCLA §121 and the National Contingency Plan (NCP). CERCLA §121 states:
Ifthe 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 jive years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, ifupon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104j or [I06j, the President shall take or require such action. The President shall report to the Congress a list offacilitiesfor which such review is required, the results ofall such reviews, and any actions taken as a result ofsuch reviews.
EPA interpreted this requirement further in the NCP; 40 CFR §300.430(t)(4)(ii) states:
Ifa remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allol't'for unlimited use and unrestricted exposure. the lead agency shall review such action no less often than every jive years after the initiation ofthe selected remedial action.
Who Conducted the Five-Year Review
EPA, Region 5 has conducted a third five-year review ofthe remedial actions implemented at the Organic Chemicals, Inc (DCI) Superfund Site in Grandville, Michigan. This review was conducted from June, 2009 through September, 2009. This report documents the results of the review. pther Review Characteristics
This i;; the third five-year review for the OCI site. The triggering action for this statutory review is the issuance of the second five-year review report on September 27,2004, following initiation of the remedial action on February 9, 1994. The first five-year revi{~w was completed on September 15, 1999. The second five-year review was completed on September 27,2004. This five-year review is required due to the fact that hazardous substances, pollutants, or contaminants remain on site above levels that allow for unlimited use and unrestricted exposure.
1I. Site Chronology
Table 1 provides a summary chronology of EPA's major activities at the OCI Site.
Ta ble 1. Chrono 02)' 0 fM'aJor S·tI e Events EVENT DATE Active operations: 1941 - 1991 Refinery & bulk oil storage operations 1941-1968 OCI operations 1968 - 1991 Proposed on NPL December 30, 1982 Listed on NPL September 8, 1983 Phase I RIfFS March 29, 1989 - July 17, 1991 OU 1 ROD September 30, 1991 Unilateral Administrative Order for OU 1 January 2, 1992 RD for pump & treat system January 2, 1992 - February 9, 1994 Phase II RI/FS July 2, 1992 - March 1996 Pre-final inspection of pump & treat system January 13, 1995 Construction of pump & treat system May 1995 - September 1996 Operation of pump & treat system May 1995 - July 1997 OU 2 ROD February 5, 1997 First five-year review September 15, 1999 Groundwater Consent Decree February 7, 2000 Alternate Point of Compliance demonstration February 16, 2000 - ongoing Soil Consent Decree February 1,2001 RD for soil remediation February 16,2001 - September 26,2001 Soil remediatIOn, in phases September 2001 - November 2003 Pre-final Inspection for soil remediation September 18, 2003 ESD& PCOR September 29,2003 Final Inspection of entire site January 16, 2004 Second five-}ear review September 27,2004 New owner purchases Site November 2006 Third five-year review September 2009
2 III. Background
Physical Characteristics
The GCI property is located at 3291 Chicago Drive, S.W., in the city of Grandville (population 16,263), Kent County, Michigan. The GCI property is approximately 5 acres. Figure 1 shows the site location. The Chesapeake and Ghio Railroad, which runs southeast of the facility and along the north side of Chicago Drive, has an elevated rail bed acting as a barrier to surface drainage. There is no visible surface drainage linking the site and the Grand River, located about 0.95 miles to the north. Two gravel quarries have been identified near the OCI site, one located 0.3 miles northwest, and the other quarry is 0.2 miles northeast of the site. Both quarries are inactive and filled with water.
Site Location Map
The GCI property is bordered by Tenneco Packaging Inc., on the east, Htrans Holdings (Holman Concrete) on the west, and by Developers Inc., on the north. These properties, along with others, comprise an industrial and commercial park which extends up to Interstate-196, approximately 2,000 feet north of the GCI Site. Residential areas are approximately 200 feet
3 southeast ofthe Site and 1,700 feet to the southwest. Across Interstate-196, north of the Site, is a wetland area that extends north to the Grand River, and the highway transects the sensitive ecosystem and the industrial park/commercial park.
Figure 2 shows the current Site characteristics. Most of the Gel Site property is fenced. Substantial portions of the Site's surface are covered by concrete slabs from former facility operations. One former facility building and the building that houses the Site's inactive groundwater extraction and treatment system are located along the eastern edge of the Site.
E istiog Site Characteristics Letter corresponds to photograph onphotographpagesofreport 1------ [ J Sloped area separates lower ~ iowctfJ"rllOllofJite portion of the site from upper area :
I Existing chain link fence is well ----;~---;--_t~SIo:P~.~i_~_ " within property boundary I. I H Pile ofdebris created from Site-t-EJ clearing and removal I dtb IS I G Monitoring wells located on site, those near truck traffic are protected by mounds and bollards
F Building housing inactive pump and treat system
E Former solvent building in fair condition, roof repairs needed befor~ building could be reused I
D Concrete slabs located throughout, gravel has been brought in to level I site with pad grade I
C Remnant structure -.-.:...--'----+----~
B Former loading bay
A Existing site access----__t ->o..~
C Existing vegetation
OCI Superfund Site ISite Characteristics I t 3291 Chicago Drive, Grandville Michigan o so 100 North
Figure 2: Existing Site Characteristics
4 Land and Resource Use
The OCI property formerly had several buildings and structures occupying the property (see Attachment 1). The chemical manufacturing operation, which was housed in two buildings along the western boundary of the property, produced small quantities of specialized industrial chemicals and pharmaceutical intermediates. The solvent recovery operation was housed in several buildings along the southeastern portion of the property. Other structures included a warehouse, several drum and storage tank areas, an office building, a boiler facility and a waste water pre-treatment facility. OCI stopped operations in May 1991, because of financial problems and the inability to obtain a Resource Conservation and Recovery Act (RCRA) Part B permit. OCI conducted RCRA closure of some of the equipment and tanks in 1992; although it never completed a complete closure.
The approximate 5-acre OCI Site is located in an industrial corridor and is accessed via Viaduct Drive SW, a service road for Chicago Drive SW. Site infrastructure includes access to all major utilities and a utility power pole is located near the center of the site. The site's topography is generally flat with the northern portion of the site sloping downward to a lower area of the site. A chain-link fence surrounds a majority of the property. The eastern edge of the property lies outside the fence and is covered in trees and tall grasses. Otherwise, the site is generally open with a few trees scattered in the southern portion of the site.
Remnants of former site activities are located throughout the site and most of the central portion of the site is covered with concrete slabs from the former buildings or secondary containment systems. A recessed loading bay remains in front of the large former solvent building located on the eastern portion of the site. The groundwater extraction and treatment system (now on standby) is housed in the building adjacent to the former solvent building. A large pile of debris from on-site demolition is located towards the rear of the property. Monitoring wells are located throughout the site.
Grandville-based 4-1 Trucking Company purchased the OCI site property in November 2006 via county tax sale, following implementation of the site's cleanup, which remediated the site to industrial use standards. In 2007, following a baseline environmental assessment and additional site sampling, cleanup, and building removal by the new site owner, 4-1 Trucking Company has returned the site to use as a truck storage and transportation facility, consistent with the industrial use standards established for the cleanup.
No natural resource areas are associated with the OCI Site, which is located in an industrial/commercial park.
History of Contamination
The Site was previously used for petroleum refining from 1941 to 1945, and transport and storage operations from 1945 to 1966. A succession of petroleum-related industries leased the land prior to its purchase by Spartan Chemicals. Anne R. Herald, owner of the property from approximately 1900 to 1942, issued an oil and gas lease for the entire property to Gerald 1. Wagner on December 7, 1937. Mr. Wagner then leased the premises for oil and gas exploration
5 to various third parties. During tenure of these leaseholds, two oil production wells were drilled onsite. One was a dry hole and the other was never completed or maintained. Attempts made to identify the exact locations of these wells by reviewing existing data were unsuccessful.
All oil and gas exploration leases were summarily voided by Ms. Herald on February 7, 1941. Other petroleum industry operations included a refinery commenced onsite in the early 1940's. Total Pipeline Corporation, a petroleum transporter, leased an oil and gasoline warehouse and tank facility onsite during this period. Its facilities were then taken over by its parent company, Total Petroleum, Inc., which operated onsite through 1964. Leonard Fuels purchased the Site in 1964 and sold the property to Total Realty in 1966. In 1968, Spartan Chemical Company acquired the Site property for the solvent reclamation and chemical manufacturing operations of its subsidiary, Organic Chemicals Company (now Organic Chemicals, Inc.). OCI operated on the Site from 1968 and stopped operation in 1991. In 1979, OCI became the owner of the premises by conveyance of deed from Spartan Chemical Company.
Historical aerial photographs, which were taken between 1960 and 1978, show changes to the physical facilities of the OCI site. In a 1960 photograph, three large vertical tanks with t"\'o sumps for containing spills were present along the northwestern portion of the former refinery. By 1967, these tanks were no longer present. In 1973, the terrain on the western portion of the former refinery was being regraded and leveled. The ground was visibly scarred from earth-moving activity. In this same year, there was a seepage lagoon on the OCI property which appean:d to contain liquid waste. Two new buildings and six additional vertical storage tanks had been added to the facility in 1973. A 1978 aerial photograph indicates that the west p'Jrtion of the former refinery was abandoned. This area was owned by Haven-Busch, Co., and was being used as an open storage yard for this steel fabrication company. Haven-Busch, Co. has since closed both their corporate office and their steel fabrication plant and was sold to Padnos Iron and Metal.
A chemical fire occurred on-site on October 11, 1976, damaging part of the OCI facilities. The blaze was reported as being started by a spark from a metal drum dragged across a floor. The spark ignited barrels of solvents stored nearby. According to retired Grandville Fire Chief Osterink, the fire was contained in the building and prevented from spreading to other storage tanks outside.
OCI reported a chemical spill at the site in November, 1979, to the Michigan Department of Natural Resources (MDNR). The Michigan Department of Environmental Quality (MDEQ) now addresses the Site. On November 3, 1979, 2,200 gallons of lacquer thinner were spilled by an operator onto the ground onsite. Some of the spilled lacquer thinner was recovered and disposed of in the onsite seepage lagoon. That same year, MDNR asked OCI to perfornl a study to investigate suspected ground-water contamination on the site. This study was completed in 1981. Samples taken from monitoring wells north and west of a former seepage pond on the site indicated that the ground water was contaminated with volatile organic compounds (VOCs).
On April 14, 1980, the OCI Site was classified as a potential hazardous waste site by EPA. The Site was listed on the National Priority List on September 8, 1983. EPA summarized
6 the problem in its Potential Hazardous Waste Site log as "known groundwater contamination by organic solvents."
Between 1968 and 1980, company records indicate that OCI discharged its process waste and cooling water, which included FOO 1-F005 RCRA-regulated hazardous wastes into the on-site seepage lagoon. These RCRA-regulated wastes are listed because of their concentrations of specific chemicals. In June 1980, OCI ceased discharge of wastewater to the seepage lagoon. In 1980, the company installed a wastewater pre-treatment facility with discharge to the City of Grandville sanitary sewer system. The pre-treatment facility included two 9,000 gallon sedimentation tanks and a 30,000 gallon aeration basin with pH adjustment. Also, drums were discovered on the northeast side of the Site that were removed. Additional soil was removed; although, some contamination remained at a depth ofapproximately five feet, and the excavation was backfilled with sand.
In 1986, MDNR investigated a complaint that OCI personnel were illegally disposing hazardous wastes at the facility. As a result of this investigation, EPA cited OCI as being in violation of RCRA laws, which regulate, in part, the handling and disposal of hazardous wastes, and fined the company for the violations.
Subsequently, an anonymous caller reported to MDNR that there were drums buried on the property. In 1987, OCI, in cooperation with MDNR, voluntarily conducted an investigation. Approximately 150 buried drums were discovered and removed from near the southwest comer of the warehouse building. Groundwater samples from monitoring wells near the burial location and soil samples from the bottom of the excavated area showed VOC contamination.
Initial Response
In September 1981, seepage lagoon sludges were excavated and transferred to railroad cars. The total removed soil filled approximately seven railroad cars. These sludges were disposed of at Chern-Met Services, Inc., in Wyandotte, Michigan.
A Preliminary Assessment (PA) for the Site was completed by EPA in 1983. The PA documented potential groundwater contamination from the solvent-contaminated seepage lagoon. Soils beneath this pond were also found to be contaminated. A potential for drinking water contamination and potential endangerment of flora and fauna in nearby wetlands were indicated in the PA.
In September 1986, MDEQ Law Enforcement Division personnel responded to a complaint of alleged illegal disposal of hazardous wastes at the facility. Reportedly, OCI personnel were disposing of sludges and other residues generated from the solvent recovery operations by placing these materials into drums and roll-off containers along with their normal nonhazardous solid waste materials. Analyses of waste material taken from solid waste storage units (roll-offs and 55 gallon drums) revealed the presence of various contaminants including methylene chloride, toluene, ethylbenzene, xylenes, and Arochlor 1242 polychlorinated bi phenyls (PCBs). Analyses of soil samples taken from the vicinity of the solid waste storage units revealed the presence of methylene chloride, toluene, xylenes, 1,1, I-trichloroethane,
7 trichloroethene, tetrachloroethene, chlorofonn, 1, I-dichloroethene, 1,2-dichloroethene, and PCBs. As a result of this investigation, OCI was cited by EPA on December 3,1986, to be in "iolation of RCRA. Among the violations cited were: (I) the unreported generation of hazardous waste from a drum cutting operation; (2) the routine transport of hazardous waste from the Site by unauthorized agents; (3) failure to prepare hazardous waste manifests; and (4) shipment of hazardous waste to unauthorized facilities. Based on these findings, EPA levied fines of $22,500 on OCI.
During August/September 1987, OCI conducted a voluntary investigation in cooperation \\lith MDEQ. Approximately 150 buried drums were discovered and removed from the southwest corner of the OCI warehouse building. Some of these drums contained sludge and liquid residues. Groundwater samples taken at that time from a nearby company, Prein & Newhofs monitoring well, B-ll, indicated the presence of 1,I-dichloroethene, 1,1 dichloroethane, cis-l ,2-dichloroethene, dibromochloromethane, toluene, ethylbenzene, and xylenes. Monitoring well B-ll was located south and slightly west of the warehouse building. The drum burial area was excavated down to approximately 17 feet below grade. Soil samples f:~om the bottom ofthe excavation indicated residual contamination ofmethylene chloride (13 ug/kg) and tetrachloroethene (2.7 ug/kg).
OCI stopped operations in May 1991, because of financial problems and the inability to obtain a RCRA Part B pennit. OCI conducted RCRA closure ofsome ofthe equipment and tanks in 1992, although a complete closure was not perfonned. Piping that may contain hazardous wa~te residue remains on-site. This piping does not appear to have contributed significantly to groundwater contamination.
Basis for Action
The primary contaminants of concern found at the Site were/are associated with the past operation of the seepage pit by OCI, chemical spills at the Site and past oil related activities. The primary areas of concern are: the fonner seepage lagoon, the fonner lacquer thinner spill site and the petroleum sludge lagoons (see Figure 3). The Site contaminants identified during the Remedial Investigation (RI) include elevated levels of chlorinated solvents and benzene, toluene, ethylbenzene, and xylene (BTEX) compounds in soil and groundwater. Lower concentrations of other volatile and semi-volatile organic compounds were also detected. The nature and extent of c'Jntamination is presented in the Focused Feasibility Study (FFS) and Phase II RI Report and summarized in the following sections.
Exposure to soil and groundwater were associated with unacceptable potential human health risks due to exceedances of EPA's risk management criteria for the reasonable maximum exposure scenarios. The carcinogenic and non-carcinogenic risks were highest for potential exposure to contaminated groundwater from a future residential ingestion pathway. Soil contaminants posed the greatest carcinogenic risk to human health through dennal contact and ingestion by future workers, primarily from PCBs, polynuclear aromatic hydrocarbons (PAHs), and dioxin/furans. Unacceptable potential risks were also identified for trespassers from soil. Ecological risks were within or below acceptable ranges, based on the qualitative ecological risk a ~sessment.
8 Hazardous substances that were released at the Site and have performance standards in each medium are shown in Table 2.
Table 2: Hazardous Substances and Media SOIL GROUNDWATER Benzo(a)anthracene Vinyl Chloride Benzo(a)pyrene 1,2-Dichloroethane Benzo(b)f1uoranthene 1,1,1-Trichloroethane Bis(2-ethylhexy)phthalate Benzene Beryllium Toluene Lead Ethylenebenzene Dibenzo(a,h)anthracene Xylene Indeno( 1,2,3-cd)pyrene Arsenic ,
Dieldrin I Barium 2,3,7,8-TCDD (TEF) Total Chromium
PCB (Arochlor-1248) I Copper Lead i Mercury
IV. Remedial Actions
Remedy Selection
EPA organized cleanup at the Site into two operable units (OUs). au 1 was addressed as the first response, which was an interim action to address contamination in the upper ground water system (UGS) by stopping the contaminant plume migration. The final au, au 2, selected responses to remediate the groundwater to comply with Maximum Contaminant Level (MCLs), and the soil contamination to be protective in an industrial setting. The au 2 Record of Decision (ROD) also allowed for an Alternate Point of Compliance (APC) for attainment of the groundwater standards. The APC was granted by EPA on June 9, 2004, and included the OCI property and the adjacent property to the west, Htrans Holdings.
The au 1 ROD was signed for the Site on September 30, 1991. The Remedial Action Objectives (RAOs) were developed as a result of data collected during the Phase I RI/ FFS. This included a single remedial activity to contain and remediate the contaminated groundwater.
The selected remedy had the following specific components: For contaminated groundwater associated with the Site, construct and operate a groundwater pump and treat system to contain the contaminant plume. The treated water was to be discharged into Roy's Creek in compliance with the substantive requirements of a NPDES permit.
The au 2 ROD was signed for the Site on February 5, 1997. Response actions for the Site were developed from the Phase I and II RI based on the unacceptable human health risks identified in the risk assessment. The au 2 ROD selected a remedy and allowed for a
9 contingency remedy for the contaminated groundwater by requiring treatment to meet MCLs or granting an APC if certain conditions were met.
The OU 2 ROD also addressed the contaminated soils by excavation and solidification! stabilization. The soil, which was the principal threat at the Site, was to be addressed by excavation of approximately 6,000 cubic yards of the contaminated soil and on-site treatment by solidificatiol1Jstabilization. After the au 2 ROD was signed, the potentially responsible parties (PRPs) provided a more accurate estimate, indicating that the volume of contaminated soils was only 2,500 cubic yards. Therefore, the remedy was modified by EPA to allow for excavation and off-site disposal of soil.
An ESD was signed on September 29,2003. This ESD documented the temporary shutdown of the groundwater extraction and treatment system to evaluate the need for continued operation of the system. During this shutdown, a study was conducted to evaluate the potential DJr an APC for the groundwater, as allowed by the au 2 ROD. The APC allows the system to be discontinued indefinitely as long as groundwater monitoring demonstrates compliance with the APC and other requirements within the ROD. The second modification in the ESD addresses groundwater performance standards, MCLs, and a provision in the Consent Decree's Statement of Work (SOW). The last modification noted in the ESD was the off-site disposal of the soil versus the originally planned on-site treatment and disposal of the hazardous material.
Cleanup Standards
Cleanup goals for the groundwater are MCLs throughout the contaminant plume for Contaminants of Concern identified in the Phase II RI/ FS, as shown in Table 3. Granting of the APC did not change the groundwater cleanup goals, but changed the trigger for treatment system operation from throughout the contaminant plume to the APC boundary at the OCI property and the adjacent property to the west, Htrans Holdings:
Tahie 3. GrOUD dwater CIeaDUp Goa s [ GROUNDWATER CONTAMINANT CLEANUP GOAL (ppb) Arsenic 50 Barium 2,000 Total Chromium 100 Copper 1,300 lead 15 Mercury 2 1,2-Dichloroethane 5 1,1,1-Trichloroethane 200 Vinyl Chloride 2 Benzene 5 Toluene 1,000 Ethylbenzene 700 Xylene 10,000
10 The selected remedy for the OU 2 ROD (as modified by the ESD) addressed the principal threat at the Site by excavation and off-site disposal of the contaminated soils. Table 4 below lists the soil contaminants and the cleanup goal for those contaminants.
T a ble 4. S·I01 CIeanup Goa s SOIL CONTAMINANT CLEANUP GOAL (ppb) Benzo(a)anthracene 3,153 Benzo(a)pyrene 2,967 Benzo(b)fluoranthene 3,519 Bis(2-ethylhexy)phthalate 14,488 Beryllium 420
Lead 900,000 1 Dibenzo(a,h)anthracene 2,350 I Indeno( 1,2,3-cd)pyrene 2,595 Dieldrin 20 2,3,7,8-TCDD (TEF) 0.085 PCB (Arochlor-1248) 7,739
Remedy Implementation
No CERCLA removal actions or non-CERCLA response actions have been performed since the signature of either ROD.
The dates that the au 1 pump and treat system remedial design was started and completed were January 2, 1992 to February 9, 1994, respectively. The groundwater system operated from May 1995 until July 1997. The system was shut down at that time when the effluent from the treatment plant, discharging to Roy's Creek, did not meet the discharge standards and failed aquatic toxicity testing. The system was never restarted because the remedy in the au 2 ROD allowed for an APC, which allowed the PRPs to turn off the extraction and treatment system if certain conditions were met, while maintaining the system for future use if necessary. The State of Michigan's Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Part 201), which is an ARAR for the Site, requires a demonstration that the contaminant plume is being reduced by a naturally occurring process and that the contaminants will not exceed the groundwater performance standards at the approved APC. The work plan for this demonstration was approved on December 15,2000. Monitoring of the well network began in September 2001 and is ongoing through 2009. The APC Demonstration Report was submitted on September 12,2003 and was approved on June 9, 2004. Attachment 2 shows the monitoring wells sampled in the APC demonstration. .
During the APC demonstration, the only contaminant that exceeded the MCL performance standard at the APC was benzene. The SOW did not include benzene as a contaminant of concern for groundwater if all the other performance standards were met. This was because there is an oil plume that covers about 20 acres, including the OCI site. The oil plume contains benzene. Given that there are 12 other groundwater contaminants that have
11 MCLs as a performance standard (seven of which are volatiles and three are toluene, ethylbenzene, and xylene (TEX) from the BTEX oil designation that includes benzene), and all 12 would have to be below their respective performance standards to achieve compliance, it was considered appropriate to not include benzene as a contaminant of concern because the oil contamination is not subject to action under CERCLA. The reason that the TEX chemicals were included as a contaminant of concern was that GCI was a solvent recycler and used the TEX chemicals extensively.
The dates for the soil remedial design start and completion are February 16,2001, and September 26,2001, respectively. The ROD estimated that approximately 6,000 cubic yards of soils would exceed the cleanup levels and need to undergo solidification/stabilization prior to on site disposal. The ROD also allowed for a small part ofthis volume to be taken off-site for disposal as solid waste if necessary. During the remedial design, the volume of soils which needed to be removed from the site to meet the established cleanup levels was determined to be approximately 2,500 cubic yards. In addition, sampling and excavation of soils at the Site r,~vealed that a significant volume of soils might either contain higher levels of contamination or contain enough waste material that solidification/stabilization would be difficult to implement. Since the volume and nature of wastes can change the cost-effectiveness of various disposal options, the PRPs compared the costs of off-site disposal of all soils to the costs of soliditicationJstabilization and on-site disposal and identified significant savings for off-site disposal. Therefore, the waste was sent off-site. Also, drums that were disposed of on the Site were remediated along with contaminated soil removed from the Site. The soil RA was started in September 2001 and was completed in September 2003. The Completion of Remedial Action Report was submitted in March 2004.
A Unilateral Administrative Order was issued on January 2, 1992 to the Abitibi PRP Group for design, construction, and operation and maintenance ofthe interim action groundwater pump and treat system.
Two consent decrees have been entered requiring implementation of the final OU 2 rl~medies for this Site. The first consent decree was entered on February 7, 2000, with the Abitibi PRP Group (U.S. vs. Abitibi Price Corporation, et al.) and requires the development and implementation of the groundwater remedial response, including the APC study and long-term monitoring. The second consent decree was entered on February 1,2001, with Total Petroleum Il1c. (TPI), and requires the design and implementation of the soil remediation.
System Operations/Operation and Maintenance (O&M)
The groundwater interim action, pump and treat system operated from May 1995 until July 1997. Because the APC Demonstration Report (2003) was approved by EPA, it is unclear if the system will be required to be turned on again. If contaminant concentrations in the groundwater exceed performance standards at or beyond the APC boundary (unless the exceedance is benzene alone), the PRP's are required to resample, submit a written explanation of the exceedance, and submit a plan that proposes additional actions to establish compliance. If the plan is to restart the groundwater treatment plant, the PRP's will be directed to repair and upgrade the system.
12 Quarterly groundwater sampling started in the summer of 1995, continued through October 2000, and began again in October 2001 through July 2003. As part of EPA's approval of the APC Demonstration Report, a post shutdown groundwater monitoring (PSGM) program was established. The PSGM program requires sampling from a group of monitoring wells that represent different areas of the upper groundwater system. These designated areas are: background; source area; sentry (plume interior); and APC Boundary. Also, groundwater samples are collected from the deeper groundwater systems to monitor vertical gradients. Attachment 2 shows the PSGM monitoring wells. The PRPs are required to conduct a total of four semi-annual sampling rounds followed by three annual sampling rounds over a five year period under the PSGM program. Currently, groundwater is sampled annually, and the third and final annual monitoring results were submitted in September 2009. EPA, in consultation with MDEQ, will re-evaluate groundwater monitoring requirements after review of the next results.
The capital cost of constructing the pump and treat system was $398,000. The projected cost of operating the treatment plant without being upgraded is $280,000 annually. Ground water monitoring during the operation of the treatment system or with the approved APC is about $127,000 annually. Because PRPs are conducting the work, specific annual system O&M costs and variations from anticipated costs or between operating years are not available.
The soil remediation requires no O&M other than maintenance of the existing concrete slabs or a similar barrier. Contamination which is suspected to be present under some of these slabs will be addressed by institutional controls if the barriers are removed as a result of future development. If additional work is required at the Site, including but not limited to replacement or maintenance of the slabs, it will be handled through the Modification Clause in the TPI Petroleum Inc., Consent Decree or by a new Site owner.
Institutional Controls
Institutional controls (ICs) are required to ensure the protectiveness of the remedy. ICs are non-engineered instruments, such as administrative and legal controls that help to minimize the potential for human exposure to contamination and that protect the integrity of the remedy. ICs are required to assure the long-term protectiveness for any areas that do not allow for unlimited use or unrestricted exposure (UU/UE), and are required also to maintain the integrity of the remedy. ICs are required at the OCI Site because the groundwater remedy has not yet achieved full protectiveness necessary for UU/UE. ICs are also required because the soil cleanup goals were selected to be protective of industrial use exposure. The remaining levels of contaminants in soil do not allow for UU/UE. Restrictive Covenants for the groundwater are in place and can be found in Appendix H of the APC Demonstration Report.
As noted in Table 5, a proprietary control is preferred, such as an environmental covenant that is consistent with model language provided by MDEQ and the Office ofthe Michigan Attorney General. Currently, soil and groundwater are, or will be, subject to the institutional controls listed in the Table 5.
13 Table 5: Institutional Control Summary Media, Engineered IC Objective Title of IC Instrument Controls, & Areas Implemented tbat Do Not Support lJUfUE Based on Current Conditions Groundwater* Prohibit: residential use of the Site; Restrictive Covenants were use of groundwater for drinking or recorded with Kent County other purposes (until cleanup Recorder of Deeds on March standards are achieved); extraction 29, 1999 and April 26, 2000. and off-site transfer of groundwater As a precaution, covenants will without adequate management. be reviewed for consistency with the model. Soil* Prohibit: other Site uses besides No ICs are currently in place. industrial; building construction Use restrictions need to be unless vapor mitigation is included; implemented (the use of the off-site transfer of soil without model restrictive covenant will adequate management; and be explored). A Work Plan will subdividing the Site. Maintain or be submitted for EPA approval replace existing barriers. to implement the ICs and to develop a plan to ensure long term stewardship. * }vfaps which depict the current conditions ofthe Site and areas which require restrictions will be developed as part ofthe implementation ofinstitutional controls or Ie Plan.
Status oncs and IC FoUow up Actions Needed
Groundwater ICs
Restrictive Covenants were recorded with Kent County Recorder of Deeds on March 29, 1999 and April 26, 2000 to restrict groundwater use. Those instruments must be required to ensure their e::fectiveness. EPA will require that the PRPs submit an IC work plan for EPA approval to incorporate the IC evaluation activities and any corrective measures or recommended ft)llow-up actions. Additionally, consideration should be given to revising the ICs using the model. The State of Michigan has been developing model language in recent months for covenants to tnsure that such instruments are enforceable under state law. This model language is in the tinal stages of development. EPA is evaluating these alternate instruments and will be providing the models to the PRPs for consideration for revising the existing ICs.
ICs must be implemented on the soil to ensure that the remedy functions as intended. As mentioned above, EPA will request that the PRPs develop an IC work plan for EPA approval. The work plan will also consist of IC evaluation activities and a draft IC Action Plan to implement the ICs and long-term stewardship procedures. The IC evaluation activities will include a map which depicts the current conditions ofthe Site and areas which do not allow for UUIUE, and title work to
14 ensure no prior encumbrances exist on the Site which are inconsistent with the ICs to be implemented. An environmental covenant which will "run with the land" and be enforceable against future land owners will be prepared, and the existing restrictive covenants will be reviewed in light of the new model covenant that the State of Michigan has approved. As mentioned above, EPA will be providing the model covenants to the PRP for consideration implementing the soil ICs.
Because the existing barriers and concrete slabs must remain in place or be replaced, the IC work plan will call for accurate mapping of the existing barriers and a procedure to ensure that they remain intact. This is particularly important because the current owner has placed a significant amount of gravel over the surface, so the existing barriers are difficult to observe. Accordingly, EPA will review the Work Plan and provide direction to the PRPs on how to revise their IC work plan.
EPA anticipates that the ICs for soil will have the following major restrictions:
I) A prohibition on all site uses that are not compatible with the industrial site uses;
2) A prohibition on demolition, excavation or the conduct of other intrusive activities that could affect the integrity of existing building foundations and concrete slabs unless provisions are made to replace these features with an engineered barrier of equal or greater competence;
3) A prohibition that any buildings constructed at the site have the provisions to prevent the migration of volatile chemicals into indoor air;
4) A prohibition on the off-site transport of soils at the site without first testing those soils for hazardous characteristics and then managing those soils in accordance with all federal and state environmental regulations; and
5) A prohibition on subdividing the site into more than one unit to limit the possibility that workers would have repeated exposures to soils in a particular sub area of the site.
If the IC evaluation indicates that the 1999-2000 restrictive covenants should be re-issued to comport with MDEQ's model language, the groundwater restrictions should be incorporated into the new restrictive covenant.
Current Compliance: Based on the Site inspection and data reviewed, EPA is not aware of Site or media uses which are inconsistent with the objectives of the ICs and cleanup goals. Therefore, at this time, the remedy appears to be functioning as intended. However, long-term protectiveness requires compliance with effective ICs.
Long-Term Stewardship: Long-term protectiveness at the site requires compliance with ICs to assure the remedy continues to function as intended. To assure proper maintenance, monitoring and enforcement of effective ICs, long-term stewardship procedures will be reviewed and the O&M plan will be revised. The plan will include a provision for regular inspection of ICs at the
15 Site and annual certification to U.S. EPA that the required ICs are in place and effective. Additionally, development of a communications plan and a one-call system should be explored for long-term stewardship.
v. Progress Since the Last Review
rrotectiveness Statement from the Last Five Year Review
While CERCLA remedial activities have been performed pursuant to the two Consent Decrees, no CERCLA removal actions or non-CERCLA removal actions have been performed since the signature of either ROD. The second five year review determined:
"The remedy is protective of human health and the environment in the short term and measures are in place to ensure protectiveness in the long-term. There are no current exposure pathways and the remedy appears to be functioning as designed."
§tatus of Re(~ommendationsfrom the Last Five Year Review
The s~:cond five-year review identified two specific issues. Table 6 below provides a summary of the issues and follow up actions identified in the last five-year review. Additional narrative text follows Table 6 to expand on the current status of these issues.
Table 6: Actions Taken Since the Last Five-Year Review Issues from Second Five-Year Recommendationsl Party Milestone Action Taken and Date of Review Follow-up Actions Responsible Date Outcome Action Work with Work with potential EPAlMDEQ ASAP • Site purchased by 11/06 MDEQto developers to new owner see that the redevelop the Site. • EPA finishes 1/08 Site is Situation Report to redeveloped support reuse
Work with Work with MDEQ EPAlMDEQI ASAP • Review of semi Ongoing MDEQ to on this issue. PRP annual and annual see if monitoring results additional COCs are required for the APC.
EPA and MDEQ were approached in October 2006 by the owner of4J Trucking asking about the consequences ofpurchasing the Site for use as a truck parking area. The Agencies and the groundwater PRPs corresponded via email and letters, and had calls with the prospective
16 purchaser to discuss liability under CERCLA, and what restrictions would need to be in place on the property to comply with the requirements of the selected remedy. In November 2006, the owner of 4J trucking purchased the OCI Site property. The Site is currently being used for truck parking, which is consistent with the future uses allowed by the ROD. There is no use of the on site building by the current owner.
With funding from EPA, environmental consulting company P Inc. conducted a situation assessment in the City of Grandville, Michigan in July 2007 to gather information to support EPA's efforts to help ensure the long-term effectiveness and permanence ofthe remedies implemented at the OCI Site. The proper consideration of future Site uses can help enable communities to safely return sites to protective, sustainable, and productive uses, a national goal outlined in the Agency's 2006-20 II Strategic Plan. The Superfund Redevelopment Initiative (SRI) was created by EPA in 1999 to help communities and stakeholders in their efforts to return environmentally impaired sites to beneficial use. SRI provides a range of tools and information resources for EPA staff and stakeholders interested in Superfund site reuse. The situation assessment is provided as Attachment 3.
Regarding the issue of whether additional COCs are required, EPA and MDEQ have been routinely reviewing the results of the PSGM sampling. The sampling has periodically indicated exceedances of the performance levels for vinyl chloride of2 ug/L, particularly in APC monitoring wells MW-46 and MW-47 (see Attachment 2). The vinyl chloride is likely a result of breakdown of parent compounds that are undergoing monitored natural attenuation (MNA).
As a result of these exceedances, the groundwater PRP group has proposed a pilot study to be implemented in the source area of the plume. As part of the September 25,2008 PSGM Program Report, the PRPs proposed to conduct an in-situ enhanced bioremediation pilot study that would include injections into the source area groundwater. The PRPs believe that this could speed the ongoing MNA and cut down remediation time to less than 10 years. They also believe that this would eliminate the vinyl chloride problem. All parties agree that a pilot study would be beneficial. However, EPA and MDEQ raised some concern to the PRPs about their proposal, and expected responses are due with the September 2009 PSGM Program Report. After EPA and MDEQ review the responses, EPA will determine how to proceed. Monitoring requirements, including appropriate COCs, will be addressed as part of any future pilot study.
Results of Other Implemented Actions
There was an existing wastewater pre-treatment system, including several in-ground concrete tanks remaining on Site. The pre-treatment system is located in the northwest comer of the Site, near the former lagoon area. The pre-treatment system was comprised of two 12 by 24 foot detention tanks and one 30 by 30 foot aeration tank (see Attachment 1). Wastewater from the Site was sent through the pre-treatment system prior to discharge to the City of Grandville's Wastewater Treatment Plant located northeast of the Site.
Cleanup of the pre-treatment tanks was not required by the RODs. MDEQ sampled sediment and water from the tanks in 2002 and found elevated levels of several contaminants, including tetrachloroethene, methylene chloride, and trichloroethylene. The groundwater PRP
17 ~;roup identified that water was building up within the abandoned concrete tanks and conducted additional sampling. On a voluntary basis, the groundwater PRP Group offered to remove contaminated sludge and water from the existing pre-treatment tanks and to close the tanks. In October 2003, the groundwater PRP group submitted a Pre-Treatment System Closure Work Plan. After extensive review and comment by EPA and MDEQ, EPA authorized the PRPs to proceed with the Pre-Treatment System Closure Work Plan on April 24, 2006.
The groundwater PRP group proceeded to implement the voluntary Pre-Treatment System Closure Work Plan in 2006 and removed water and sediment from the tanks. They also power-v.-ashed the tanks and removed and disposed of the wash water. Before the PRPs could finish closure of the tanks, the new owner ofthe site, 4-1 Trucking, Inc., broke up the sides of the tanks, pushed the debris back into the excavation, and placed soil and gravel above the tanks. The approved closure plan called for leaving the tanks in place, filling them with inert material, and then capping them with clay. The PRPs have raised concerns that the owner's actions were not consisten1 with the closure plan and that 4-1 has made it difficult, if not impossible for the PRPs to complete the voluntary closure that EPA approved. The debris, soil, and gravel is mounded above the surface of the ground and cannot be capped with clay. It was reported that the bases ofthe tanks were not disturbed, but current conditions do not allow that to be verified. EPA will continue to work with MDEQ, the PRP group, and the Site owner to evaluate what additional actions, if any, will be required.
VI. Five-Year Review Process
Administrative Components
Potentially interested parties, including the MDEQ, the new Site owner, and the PRPs for the Site, were consulted during the preparation of the five-year review. The members ofthe review team included:
Mary Logan, RPM, EPA Jerome Kujawa, Associate Regional Counsel, EPA Scott Cornelius, Kristi Zakrewski, and Barb Vetort-Tiffany, MDEQ
Community Involvement
A notice regarding the review was placed in the local newspaper, the Grand Rapids Press. No comments were received from the public. The completed report will be available in the information n:pository and from US EPA Region 5. No community interviews were conducted as part of the five-year review because there has been very little community interest in the Site.
Document Review
This five-year review consisted of a review of relevant site documents including, but not limited to: the RODs and ESD; the consent decrees; the APC Demonstration Report, all PSGM Reports, the Pre-Treatment System Closure Work Plan and reports on implementation of the work, the groundwater pilot study proposal, and the Soil Remedial Action Report.
18 Data Review
This five-year review consisted of a review of all of the PSGM Program groundwater data, historic data from the APC demonstration, and soil data from the Completion of Remedial Action Report. During the APC demonstration, 17 groundwater monitoring wells were sampled for a minimum of eight sample rounds apiece. Each well was assessed for a broad array of contaminants. Based on the results ofthe APC demonstration, the PSGM Program was approved. It required monitoring of 16 wells for a sub-set of contaminants identified by the results of the APC Demonstration. The PSGM Program required seven rounds of sampling over five years: two semi-annual events; followed by three annual events. The final round of the PSGM Program was taken in 2009, and the results reported in September 2009.
The soil data from the Completion of Remedial Action Report demonstrated compliance with the soil cleanup goals. Additionally, a risk assessment was conducted to ensure that the remaining residuals in soils were within EPA's acceptable risk range for the Site, based on industrial use exposure scenarios.
In each PSGM Program report, the groundwater PRP group has assessed the chemical contamination and the conditions that indicate whether MNA is occurring. Attachment 4 shows the most recent 2009 groundwater VOC data. The chemical and geochemical parameters indicate that breakdown and dechlorination is occurring throughout the plume. However, breakdown of parent compounds has occasionally resulted in detections of vinyl chloride at some of the APC boundary wells. Attachment 5 shows select VOCs and distance from the source, indicating a clear decrease in VOCs with distance. Attachment 6 shows isopleths for the performance standards and indicates wells in 2009 that exceeded one or more standards. These results are discussed more fully below. Also, the rate at which MNA is occurring needs to be evaluated as additional groundwater data and trend analysis becomes available.
Site Inspection
A Site inspection was conducted on July 16,2009. The purpose of the inspection was to determine current Site conditions. The EPA RPM conducted the inspection. Also in attendance were representatives from the groundwater settling PRPs, a consultant for the groundwater settling PRPs, and the new Site owner. In addition to inspecting the Site, the new owner's ideas for Site reuse were discussed. Attachment 7 shows photographs of the Site taken during the inspection. The situation report provided as Attachment 3 provides additional photographs.
Conditions during the inspection were favorable with temperatures in the 80s and no precipitation. As shown in the site photos, a portion of the perimeter fencing had been damaged. It should be noted that a fence to prevent access is not required by the selected remedy. However, the fence will be repaired and maintained to minimize vandalism and to protect the integrity of the monitoring wells. The monitoring wells also appeared to be in good condition, with locked and intact caps.
19 VII. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Yes. The conclusion drawn from this third five-year review, including the review of documents, ARARs, risk assumptions, cleanup goals, and the results of the Site inspection, is that the remedy is functioning as intended by the OU2 ROD, as modified by the ESD.
The removal and off-site disposal of soils eliminated the principal threat at the Site. The rl~maining component of the remedy is cleanup of the groundwater by MNA. Continued groundwater monitoring of the Site to see that the requirements of the APC are complied with \vill ensure that the remedy is protective for groundwater. The ROD (as amended) and the consent decree for groundwater provide that if the contaminant concentration in the groundwater exceeds performance standards at or beyond the APC (unless the exceedance is benzene alone), the PRP's will be required to submit a written explanation of the cause for the exceedance and submit a plan that proposes additional actions to establish compliance. If the plan is to restart the groundwater treatment plant, the PRP's will be directed to repair and upgrade the system.
Review of the groundwater data indicates that MNA is occurring, but the time to achieve the groundwater goals is unclear. The chemical and geochemical parameters indicate that breakdown and dechlorination is occurring throughout the plume. However, breakdown of parent compounds has occasionally resulted in detections of vinyl chloride at the APC boundary wells. As shown in Attachment 6, in 2009 there were exceedances of benzene in some wells, and benzene and vinyl chloride in others. All such exceedances have been followed up in accordance with the approved APC Plan (i.e., immediate resampling and assessment of the cause of exceedances). The groundwater exceedances do not call the remedy protectiveness into question because the levels usually have dropped below acceptable standards upon resampling of the wells, and especially because the groundwater is not being used and ICs for groundwater are in place.
As discussed above, the groundwater PRP group has proposed a pilot study to be implemented in the source area of the plume. The proposal is to conduct an in-situ enhanced bioremediation pilot study that would include injections into the source area groundwater. The PRPs believe that this could speed the ongoing MNA and cut down remediation time to less than 10 years. They also believe that this would eliminate the vinyl chloride problem. The proposed pilot study is intended to explore options that will reduce the production of harmful breakdown products, decrease contaminant mass in the source area, and decrease time until the groundwater cleanup standards are attained. The pilot study, once implemented, could lead to optimization of the groundwmer remedy and a faster, cheaper cleanup.
As discussed above, ICs are in place for the groundwater, and these ICs are currently effective at preventing the use of, and exposure to contaminated groundwater. ICs are required, but not yet in place for the residual soil contamination. An IC Plan will be developed, and ICs will be placed for the soil by the current owner in cooperation with EPA. Although the soil ICs are not in place, current use of the Site for truck parking is consistent with the allowable Site uses and poses no unacceptable risks. The current owner is not using the building that remains on the Site, so there is no current risk for exposure to indoor vapors. Placement of extensive
20 gravel and asphalt by the new Site owner has further isolated areas of potential residual soil contamination, preventing direct contact and runoff. However, placement ofthis material has made it very difficult to determine the condition of the existing slabs, so this issue must be addressed in the IC Work Plan.
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?
Yes, the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy selection are still valid, except as discussed below. Land and groundwater use at the Site is still consistent with the assumptions used to determine where cleanup would be performed. There have been no changes in the physical conditions of the OCI Site that would affect the protectiveness of the remedy.
Standards, ARARs and/or TBCs were not the basis for the soil cleanup goals at the OCI Site. The soil goals were site-specific and risk-based, considering the mix of COCs and appropriate exposure pathways. The risk-based cleanup goals for soil established in the OU2 ROD were met as a result of construction that included removal and off-site disposal of contaminated soil. No new information has called into question the risk-based soil goals.
ARARs were the basis for the groundwater cleanup goals. ARARs that were identified in the OU2 ROD and that still must be met at this time, and that have been evaluated include the Safe Drinking Water Act (SDWA)(40 CFR 141.11-141.16). There have been no changes in these ARARs and no new standards or TBCs affecting the protectiveness ofthe remedy except for arsenic. Since the last five-year review, the MCL for arsenic was changed from 50 ppb to 10 ppb. During the APC demonstration, 17 groundwater monitoring wells were sampled for a minimum of eight sample rounds. Each well was assessed for a broad array of contaminants, including arsenic. Upon completion of the APC demonstration, none of the wells had ever exceeded the arsenic standard of 50 ppb. Therefore, arsenic was excluded from the monitoring program that has been in place for the last five years. Based on a review of the APC, five of the wells had detections that exceeded the current standard of 10 ppb. These wells include:
o MW-4, arsenic exceeded 10 ppb in 8/8 rounds, ranged from 11 - 22 ppb; o D-6, arsenic exceeded 10 ppb in 8/8 rounds, ranged from 19 - 33 ppb; o MW-45, arsenic exceeded 10 ppb in 2/8 rounds, ranged from 4.5 - 15 ppb; o MW-46, arsenic exceeded 10 ppb in 7/9 rounds, ranged from 8.2 - 19 ppb; and o MW-47, arsenic exceeded 10 ppb in 5/9 rounds, ranged from 5.8 - 15 ppb.
The arsenic data were taken between 2001 and 2003. No newer arsenic data for the monitoring wells is available. The historical presence of arsenic above what is now the MCL does not call the current remedy protectiveness into question, because the groundwater is not currently being used, and the groundwater ICs are in place. However, the monitoring program must be adjusted to ensure that arsenic is included in future monitoring to determine future protectiveness of the remedy.
The exposure assumptions used to develop the Human Health Risk Assessment included
21 exposure to contaminated groundwater for future residents through ingestion, dermal contact, and dermal contact pathways, and exposure to contaminated soils from a possible future worker through surface and subsurface soil contaminants (0-10 feet below groundwater surface) through incidental ingestion, inhalation, and dermal contact pathways. There is no new information that \'IIould support a change to the exposure assumptions.
There have been no changes in the toxicity factors for the COCs that were used in the baseline risk assessment. The assumptions used in the risk assessment are considered to be conservative :md reasonable in evaluating risk and developing risk-based cleanup levels. The vapor intrusion pathway was not commonly evaluated when the original risk assessment was completed for the Site. Evaluation of the vapor intrusion pathway (e.g., in the consent decrees and previous Five-Year Review Reports) has subsequently led to the determination that the Site f1~quires a restriction against building construction, without regulatory approval and/or vapor mitigation, in areas where subsurface VOC contamination is present at concentrations that may pose an indoor air inhalation risk. No other change to these assumptions, or the cleanup levels developed from them is warranted. There has been no change to the standardized risk assessment methodology that could affect the protectiveness of the remedy.
The remedy is progressing as expected. However, the groundwater still has a number of compounds that exceed the cleanup goals. Also, the rate at which MNA is occurring and the expected time period to attain the groundwater cleanup goals is uncertain. As discussed above, the proposed groundwater pilot study would be very useful in assessing whether the RAOs could be attained SO'Jner.
Question C: Has any other information come to light that could call into question the protectiveness of the remedy?
No other events have affected the protectiveness of the remedy, and there is no other information that calls into question the short-term protectiveness of the remedy. The Site soil was cleaned to industrial use goals, and the Site is being used for industrial purposes. There are no newly identified ecological risks. Natural or man-made disasters have not affected the Site. The discussion below will highlight some issues that may affect the protectiveness in the long tf:rm.
Technical Assessment Summary
According to the documents and data reviewed, and the Site inspection, the remedy is functioning as intended by the OU2 ROD, as modified by the ESD. While the new Site owner hlS made changes to the Site to allow reuse of the property for truck parking, these changes in the physical conditions of the Site do not affect the protectiveness of the remedy. No ARARs for soil were cited in the ROD because the remediation was risk-based. There have been no changes in the toxicity factors for the contaminants of concern that were used in the baseline risk a~;sessment, and there have been no changes to the standardized risk assessment methodology that could affect the protectiveness of the remedy. Ongoing monitoring of the groundwater will ensure that the groundwater is attaining the cleanup goals and that it remains protective to human health and the environment. ICs need to be in place to ensure long-term protectiveness.
22 VIII. Issues
As discussed above, there are several issues that must be addressed to ensure the long term effectiveness and protectiveness of the remedy at the Site. Table 7 summarizes these Issues.
Table 7: Issues Identified in this Third Five-Year Review Affects Current Affects Future Issues Protectiveness Protectiveness (YIN) (YIN) ICs not in place for soil. Also, effectiveness of existing N Y groundwater ICs must be reviewed along with long term stewardship procedures. Occasional exceedance of groundwater standards at the N Y APC boundary. Arsenic MCL has changed since last FYR. N Y Approved groundwater monitoring plan was completed N Y in 2009 - new monitoring program needed.
IX. Recommendations and Follow-up Actions
The following recommendations have been developed, considering the findings of this third five-year review, the current Site conditions, and the issues summarized in Table 7 above.
T abl e 8. Recommen da t"Ions and F 0 II ow-up At"c Ions Affects Protectiveness? Recommendations/ Party Oversight Milestone (YIN) Follow-up Actions Responsible Agency Date Current Future An IC work plan will be submitted by IC Work the PRPs to EPA for review and Plan by approval for IC activities including 12/15/1 0 implementation of soil ICs and reviewing the effectiveness of groundwater ICs. The IC work plan EPA/PRP EPA N Y shall also include other IC evaluation activities including a review of the long term stewardship procedures to ensure that the ICs are monitored, maintained and enforced. Work with PRPs to implement a Approve EPA/MDEQ/ groundwater pilot study, including EPA work plan N PRP Y acceptable monitoring. by 10/30110
23 Affects Protectiveness? Recommendationsl Party Oversight Milestone (YIN) Follow-up Actions Responsible Agency Date Current Future Sample for arsenic EPAlMDEQI 2010 EPA N Y PRP sampling Cpdate O&M Plan for groundwater 2010 plan monitoring: by 4/30110; 2010 work Evaluate Evaluate need for additional constituents constituents EPA/MDEQ/ by 12/15/10; EPA y Post-pilot monitoring PRP Post-pilot N plan after pilot study work completed I
X. Protectiveness Statement
The remedy at the OCI Site currently protects human health and the environment in the short-term. There are no current exposure pathways and the remedy appears to be functioning as dl~signed. The removal of soils to eliminate the source of contamination has achieved the remedial objectives to minimize the migration of contaminants to groundwater and surface water, and prevent direct contact with, or ingestion of, contaminants in soils which were remediated. There is no current groundwater use and ICs for groundwater have been placed to prevent unacceptable future use or exposures. However, long-term protectiveness requires compliance with effective ICs. To that end, soil ICs must be implemented to address the residual soil contamination and restrictions on the construction of new buildings over the groundwater plume without vapor abatement systems, and the effectiveness of the groundwater ICs must be reviewed. Also, the ICs must be monitored, maintained and enforced. The ongoing MNA of groundwater is expected to meet the groundwater cleanup standards in the long-term, but continued evaluation of groundwater contaminants is necessary, and additional assessment of the expected timeframe and additional trend analysis would be helpful to track progress of MNA.
XI. Next Review
The next five-year review for the OCI Site is required by September 2014, five years from the date of this review.
24 ,---.~---_...._--.-
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-18 Attachment 2 Site Monitoring Wells MW-20 MW 1 C: - 9
• MW-3
LEGEND
• EW-' EXTRACTION WEll LOCAnON
• MW-11 MONITORING WEll LOCATION
-- - APe BOUNDARY figure 1 c=:> GROUNDWATER SAMPLING LOCATION PSGM WELL LOCATIONS OCI SITE ~ Grandville, Michigan 004151-70(l.OGAOO8)GN-SPOO1 Aug 11/2009 Attachment 3 Situation Assessment Report El Inc. Situation Assessment Grandville, MI: Organic Chemicals, Inc. (OCI) Superfund Site January 2008
Introduction
EPA's primary responsibility at Superfund sites is to ensure the protection of human health and the environment. Consideration of a site's potential future use is an important part of this responsibility under the National Contingency Plan (NCP), because it is a part of two of the nine criteria for remedy selection. The first is the threshold criterion of overall protection of human health and the environment. EPA uses its evaluation of reasonably anticipated future land use to establish remedial goals and to select remedies that will allow for those uses whenever possible. Collaboration among EPA, communities, and site stakeholders in the evaluation of future uses establishes realistic expectations for how a site can be used after cleanup. This collaborative process can also help implement appropriate institutional controls, which are a necessary component of protectiveness at sites where waste is left in place.
Consideration of future land use also plays a central role in addressing the modifying community acceptance criterion of the NCP. It has been demonstrated at many Superfund sites that, when EPA works closely with communities and site stakeholders to determine a site's reasonably anticipated future land use, a high degree of community acceptance of the remedy is likely.
Finally, the proper consideration of future site uses can help enable communities to safely return sites to protective, sustainable, and productive uses, a national goal outlined in the Agency's 2006-2011 Strategic Plan. The Superfund Redevelopment Initiative (SRI) was created by EPA in 1999 to help communities and stakeholders in their efforts to return environmentally impaired sites to beneficial use. SRI provides a range of tools and information resources for EPA staff and stakeholders interested in Superfund site reuse.
Situation Assessment Overview
With funding from EPA Region 5, environmental consulting company P Inc. conducted a situation assessment in the City of Grandville, Michigan in July 2007 to gather information to inform EPA's efforts to help ensure the long-term effectiveness and permanence of remedies implemented at the Organic Chemicals, Inc. Superfund site (OCI site).
The situation assessment was conducted following the information collection guidelines outlined in EPA's 2001 Reuse Assessment Guidance (OSWER 9355.7-06P).1 Information gathered and reviewed included local stakeholders, site features and environmental considerations, site ownership, land use considerations and environmental regulations, community input, public initiatives, and likely future uses.
Activities conducted during the situation assessment included:
• Conference calls with EPA site staff and representatives from site owner 4-J Trucking Company;
• Information gathering and review of site owner planning materials and EPA site reports; and
I Reuse Assessments: A Tool to Implement the Superfund Land Use Directive (OSWER 9355.7-06P, 2001): WW\\ .epa.gov/oerrpage.superfllnd/programs reeve Ie. pd t, rellsefinal.pd f • July 2007 site visit with EPA Region 5 Regional Reuse Coordinator Tom Bloom and site owner representatives.
This summary memo provides an overview of the key findings identified during the project's situation assessment as well as a set of potential next steps for incorporating long-term stewardship considerations as part of the reuse of the OCI site.
I. Findings
A. Site Location and Overview
• The City of Grandville (pop. 16,263) is located in Kent County, ten miles southwest of Grand Rapids in southwest lower Michigan. The approximately five-acre OCI site property is located at 3291 Chicago Drive in an industrial area of northeast Grandville.
• The OCI site is surrounded by several active industrial facilities - Tenneco Packaging, Inc. to the east, Htrans Holdings to the west, and Developers Inc. to the north. Residential areas are located approximately 200 feet southeast of the site and 1700 feet to the southwest. Interstate 196 is located less than one mile northwest of the site property (see Figure I on page 3).
• Petroleum refining, solvent reclamation, and chemical manufacturing activities at the OCI site between the 1930s and 1991 resulted in the contamination of site soils, surface water, and groundwater with volatile organic compounds, semi-volatile organic compounds, polychlorinated biphenyls, and inorganic compounds. EPA listed the site on the National Priorities List in September 1983.
• Contaminated lagoons were excavated and disposed of off-site in 1981 and between 1994 and 1997, EPA worked with two groups of PRPs to address the site's soil and groundwater contamination.2 Remedial activities included the excavation and off-site disposal of site soils and the construction of a groundwater extraction and treatment system. This system operated until 1997, when it was shut down following groundwater monitoring compliance with an alternate point of compliance.
• The OCI site property is fenced. Substantial portions of the site's surface are covered by concrete slabs from former facility operations. One former facility building and the building that houses the site's inactive groundwater extraction and treatment system are located along the eastern edge of the site (see site photographs section on pages 6. 7, and 8 and Figure 2 on page 4).
• Grandville-based 4-J Trucking Company purchased the OCI site property in November 2006 via county tax sale, following implementation of the site's cleanup, which remediated the site to industrial use standards. In 2007, following a baseline environmental assessment and additional site sampling, cleanup, and building removal by the site owner, 4-J Trucking Company has returned the site to use as a truck storage and transportation facility.
2 Information summarized from the site's 1991 and 1997 Records of Decision, 1999 and 2004 Five-Year Review reports, 2000 Groundwater Consent Decree, and 2001 Soil Consent Decree.
2 Northt
B. Site Characteristics and Future Land Use Considerations
• The approximate 5-acre OCI site is located in an industrial corridor and is accessed via Viaduct Drive SW, a service road for Chicago Drive SW. Site infrastructure includes access to all major utilities and a utility power pole is located near the center of the site. The site's topography is generally flat with the northern portion of the site sloping downward to a lower area of the site. A chain-link fence surrounds a majority of the property. The eastern edge of the property lies outside the fence and is covered in trees and tall grasses. Otherwise, the site is generally open with a few trees scattered in the southern portion of the site.
• Remnants of former site activities are located throughout the site and most of the central portion of the site is covered with concrete slabs. A recessed loading bay remains in front of the large former solvent building located on the eastern portion of the site. The groundwater extraction and treatment system is housed in the building adjacent the former solvent building. A large pile of debris from on-site demolition is located towards the rear of the property. Monitoring wells are located throughout the site.
• Existing site characteristics are shown on Figure 2 on the following page; letters on the map correspond to site photographs in Section D. Site Photograph Overview.
3 Existing Site Cbaracteristics Letter corresponds to photograph onphotographpages ofreport ------...-'"'--.! :: [
J Sloped area separates lower L..-.__~~ lower ponioll ofsIte portion ofthe site from upper area
I Existing chain link fence is well ---~ ~t_r:/o:p.~i ... within property boundary I I H Pile ofdebris created from site clearing and removal -t-fI debur pl. I G Monitoring wells located on site, "'-_--J those near truck traffic are protected by mounds and bollards
F Building housing inactive pump and =~ treat system -0 =:t§ -cc- .. E Former solvent building in fair ::'0 ::~ condition, roofrepairs needed beforL -0 building could be reused I 2P ::: C Remnant structure - B Former loading bay ------ A Existing site access- +- ~# C E.,~sting vegetation OCI Superfund Site ISite Characteristics I t 3291 Chicago Drive, Grandville Michigan o so 100 North Figure 2. Site Characteristics 4 C. Current Site Use Status and Site Owner Plans and Priorities • 4-J Trucking Company (the company) acquired the OCI site property in November 2006 for $65,000 at a county tax sale and will pay an additional $15,000 to pay off the delinquent 2006 summer taxes, plus $20,000 for 2005 road improvements (special assessments). The site property's current assessed value is $32,500. The company has paid property taxes on the site property since acquisition in 2006. Due to liability concerns, the owners of 4-J Trucking Company are in the process of transferring the company's ownership to a limited liability corporation, 2-J Trucking, LLC. • The company has coordinated with Kent County's planning department and local elected officials to enable the site's reuse. The county has granted a temporary site plan approval and stipulated that the site must have a detailed site use and due care plan and asphalt paving must be in place by May 2008; the company has placed gravel on the site in the interim to support its trucking operations. • The company's owners stated that the company undertook additional sampling and cleanup activities prior to moving forward with the site's reuse in 2007. The company listed its December 2006 Baseline Environmental Assessment and the removal of storage tanks and waste drums, wood and debris piles, on-site vegetation, miscellaneous containers, and the demolition and removal of several on-site buildings as examples of these activities. The company estimates that these activities have cost approximately $50,000. The company also brought in gravel to raise the grade of portions of the site to the level of the concrete pads remaining on-site and prepare the site for asphalt paving. • The company employs nine people and provides truck hauling services within a 100-mile radius of Grandville. The company typically hauls gravel, asphalt, and recyclables for public and private sector clients. The OCI site property provides a central storage and coordination location for the company's vehicles. The company's owners stated that they are hopeful that the company's reuse of the site will benefit the City of Grandville and the community, providing new jobs and increased tax revenues. • The company's shorter-term (6-12 months) site plans include additional gravelling of the site's northern areas, stabilizing the site's remaining building, conducting an engineering study for stormwater management, submitting a site plan to Kent County's planning department, installing stormwater infrastructure, and paving the central and southern portions of the site with asphalt. The company estimates that the paving of each acre of the site will cost approximately $100,000 (see Figure 3 on page 9). • The company's longer-term (12+ months) site plans include access enhancements to the site's southern edge and the construction of an additional, 2,000 sq. foot site building to provide office space and store vehicles and equipment. This building would likely be located adjacent to the existing structure located on the eastern edge of the site. The company also plans to relocate and align the site's eastern fence with the site property boundary and backfill the site's former loading docking areas, which would enable additional paving and the extension of a loop road at the site for improved circulation. Finally, the company may also provide access or transfer ownership of the northern, undeveloped part of the site to an adjacent property owner (see Figure 3 on page 9). EPA site staff indicated that a transfer of owner hip for either the parcel or a portion of the parcel would need to be consistent with in titutional controls implemented at the site. 5 • The company's owners indicated that they have had minimal contact with EPA or state agency staff and are in occasional contact with the site's two PRP groups. The company's owners stated that they were not expecting the significant scale of site preparation activities required to reuse the site following its remediation. The owners indicated that while the site's PRP groups are currently responsible for the operations and maintenance of the site's remedy, they may be interested in transferring some of these responsibilities. The company's owners indicated that they would need additional information before determining whether they would be able or willing to take on these responsibilities. EPA ite taff indicated that the PRP groups would need to continue to meet their obligations and could work with the site owner to make sure they are met. • The company's owners reque ted ongoing guidance from EPA in ensuring their compliance with the rea onable steps criteria outlined in EPA's November 2006 correspondence. The site"s Record of Deci ion included in titutional control as part of the elected remedy. To date, institutional controls have not been fully implemented at the site. D. Site Photograph Overview • The photographs below capture eXistIng site conditions; the letter with each photograph corresponds to the letters on Figure 2, page 4 and Figure 3, page 9. A. Entrance to the site B. Former loading dock and solvent building C. Site vegetation and structures in background D. Former concrete slabs located throughout site 6 E. Former treatment building F Striped building houses treatment system G. Monitoring wells protected by earth berms H Pile ofconcrete debris l View towards eastern edge ofproperty J Lower level, northern portion ofsite 7 K. Possible expansion oftruck parking area L. Eastern edge ofproperty, outside offence M Possible location for building expansion N. Truck parking area, future plans include paving 8 = Potential Reuse Considerations Letter corresponds to photograph onphotographpages ofreport :: [ -- - -=-=.-.:- -- J Possible transfer ofsite area to neighboring truck school pOlmliaf "use K Possible expansion ofasphalt by lruck schoof paving, gravel needed to bring area up to grade ----t---;::==~-~=--- :: L Potential fence relocation to _ _lIJ :: maximize use ofproperty EJ ~ :: del"" F Water treatment building must be P·. retained in case treatment facility needed in the future, building may be able to be reused after treatment system is no longer needed M Once repaired, building may be reused for storage; possible I expansion may include an additional I building to the west {:: D Gravel has been brought in to level I pc>te1l/lafl,uck parkmgand site grade with concrete pads and to 'torag" O1~as prepare area for asphalt paving I ____ ~II N Possible paved truck parking area, =0 loop drive for easier ingress/egress fit B FormerlOadingbaYwillneedtobe~ ~ , filled in to accommodate proposed I ./ vehicular circulation / ,J A Possible site access improvements --~--_---.::------.~ may include widening and repaving ~ OCI S'uperfund Site I Potential Future Use Considerations,r------." I 3291 Chicago Drive, Grandville Michigan 0 s~O::------:-'l00 North Figure 3. Potential Future Use Considerations 9 E. Findings: Key Future Land Use Considerations • The Organic Chemicals, Inc. Superfund site has been returned to use by a site owner willing to invest time and resources in preparing the site to serve as a truck storage and transportation facility, which is an industrial land use consistent with the site's remedy. The company's future site plans provide for an extension of the existing facility. If the site's ownership was transferred, the site's existing and planned infrastructure, similar surrounding land uses, and industrial zoning all suggest that similar operations would be located at the site in the future. • Based on the situation assessment's information gathering, stakeholder interviews, and site visit, there appear to be no Superfund-related obstacles standing in the way of the OCI site property's continued reuse. In addition to site documents in EPA's Administrative Record, EPA's reasonable steps letter and the site owner's baseline environmental assessment also provide guidance for both current site activities and future uses or facility expansions planned for the site. However, EPA will likely need to coordinate with the site's owners and two PRP groups regarding the site remedy's ongoing operation and maintenance as well as implementation of the site's institutional controls. 10 Appendix A City of Grandville OCI Site Parcel Summary ')accE'"K..nt - Mozilla FIf..fox '_ ': 5< fM idol !!'OW ...,., foc"mwtJ 1- l!O'P ~//wWV' aecaJlUnLconl/?rOpI IPn>po LJ CullOlT'lU Unb '" ...• ~1~'~JiI "I "Al,"'!\. "'~II'~' ...... !\ I'" t'1ol.l ~~ _ .. M.U.Md value. end bl. v.lu•• dlspl.yed on .cctlluK.nt.re compiled (.-om leK.1 clly .nd town.Mp nd.re current al of ""rch. 1007. J 1Jb c"nur 'Dun p, Tin C." tjI1 '-act 2OCl1 S24UOO 11'1561 1OC1 n'l.5GO 1111,2'3 MgnthIy A'Ezypt $ubWA'''1M Qaler,,-mcM Oone www.ecclStt nLcorn Source: www.accesskent.com State equalized value and taxable value In the 1990s to address rising property taxes, Michigan created a second, local valuation measure (taxable value) that is limited in how much it can increase each year. When a property changes hands, however, the two values are realigned, with the taxable value reset to match the state equalized value. "The state equalized value and taxable value of land in Michigan are measures used by state agencies and local governments, respectively, to assess personal and real property. The taxable value of a parcel may differ from the state equalized value as a result of limits on increases placed in the Michigan Constitution by Proposal A of 1994. Taxable value may not rise by more than the lesser of the increase in the consumer price index or five percent. When ownership of a parcel is transferred, the parcel's taxable value and the parcel's state equalized value are realigned." 11 Attachment 4 2009 Groundwater VOC Data D-4 MW-<13 ve <1.0 VC <1.0 I Tee <1.0 Tee <1.0 MW-47 5109 7/Q9 120CA <1.0 12DCA <1.0 I ve 7.4 <1.0 B <1.0 B 9.1 Tee <1.0 NM T <1.0 T 2.0 5.3 I 12DCA <1.0 NM E 12 E B 17 NM X 11 X 18 T 2.9 NM l11T <1.0 111T 1.6 I V E <1.0 NM ~ X <3.0 NM 0 so 1001I ll1T <1.0 NM !-W I \ I PARKltJG A:~EA I I MW-1 ve 7.6 TeE 3.1 12DCA <1.0 ~ \~ B 3.7 T 1.8 E 3.1 \ I X <3.0 I \ i l11T <1.0 .~tv-:1C \' I I ~::~ MW-46 ve Tee 12DCA B T E X ll1T A~EA o MW-19 MW-48 ve <1.0 'll"'W';; Tee <1.0 12DCA <1.0 B 3.0 MW-22 T <1.0 VC E 42 Tee x 160 120CA MW·17 ll1T <1.0 B ve <1.0 U «1.0) T Tee <1.0 U «1.0) E 12DCA <1.0 U «1.0) X B <1.0 U «1.0) ll1T T <1.0 U «1.0) <1.0 E <1.0 <1.0 U «1.0) X <3.0 U «3.0) <1.0 ll1T <1.0 U «1.0) <1.0 <1.0 <1.0 <3.0 <1.0 • EW·' EXTRACTION WEll LOCATION 1& MW-l1 MONITORING WEU LOCAnON 82 VOC CONCENTRAnON IN 19'L figure 4 NM NOT MEASURED SELECTED vac RESULTS () OUPUCATE RUSUl.T (MAY AND JULY 2009) U NOT OETECTED AT OR ABOVE THE ASSOCIATED QUANTITATION UMIT aCISITE GrandVl7le, Michigan 004151·70(l0GA006)GN-SPOO4 AUG 0712009 Attachment 5 Select VOCs in Groundwater versus Distance FIGURE 2 Select VOCs versus Distance 1000000 -.-----~------..., MW-1 =0 ft. MW-43 =100 ft MW-44 =140 ft. MW-46 =290 ft. MW-47 = 300 ft. 100000 .....0;;;::------1 0 10000 ~ ::l ::::..= 10 -1------.-----=-...------1 1 -t------,.------r------r------.,.------"'"'T"""---- -....-----~ o 50 100 150 200 250 300 350 Distance from MW-l (in feet) 1-+-9/25/2001 ---6/19/2003 11/29/2005 5/21/081 CRA 004151LOGA7-F2 Attachment 6 Isopleths for Total Performance Standard Compounds (2009) I r::=::" ~ 10 [).O I ~ __134 "~iJ~- II D-4~ f 23 il ~t I w • EW-l EXTRACTION WEll LOCATiON ~ MW-11 MONITORING WELL LOCATION --- -- APe BOUNDARY 189 TOTAL CONCENTRATION Of PERFORMANCE STANDARD COMPOUNDS IN ugIL NO NOT DETECTED EXCEEDANCE Of BENZENE PERFORMANCE STANDARD AND EXCEEDANCE OF AJof'( PERFORMANCE STANDARD(S) - OTHER THAN BENZENE EXCEEDANCE OF ANY PERFORMANCE STANDARD(S) OTHER THAN BENZENE figure 5 EXCEEDANCE OF BENZENE ISOPLETHS FOR TOTAL PERFORMANCE - PERFORMANCE STANDARD ONLY STANDARD COMPUNDS (MAY 2009) ND(NO) DUPLICATE RESULT OC1 SITE Grandville, Michigan 004151-70ILOGAOO8)GN-SPOO6 AUG 2712009 Attachment 7 Photos Documenting Site Conditions Attachment 7: Photos Documenting Site Conditions The folowing photographs were taken during the July 16, 2009 Site inspection. Additional photographs can be found in Attachment 3 to the third five-year review report. South facing. Existing building housing off-line Northeast facing. Leveled area for truck turn treatment system. around. Southwest facing. Debris and leveled roadway. North facing. Debris and fill piled over pre treatment tank area. West facing. Debris and leveled roadway. South facing. Trucks parked at south end of Site. North facing. Damaged fence at northern Site West facing. Debris and fill piled over pre boundary. treatment tank area.