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