EPA Region 5 Records Ctr.

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SECOND FIVE-YEAR REVIEW REPORT

THERMO CHEM INC. SUPERFUND SITE MUSKEGON, MICHIGAN

Egelston Township Muskegon County, Michigan

PREPARED BY:

u.S. Environmental Protection Agency Superfund Division

Region 5 Chicago, Illinois

Approved by: Date:

/)

~:U4[. ~IC~d C. Karl, Director

:. l' Superfund Division U.S. EPA, Region 5

Table of Contents Page

List of Acronyms.................................................................................................................................4 Executive Summary ...........................................................................................................................5 Five YE!ar Review Summary Form................................................................................................6

1.0 INTRODUCTION ..................................................................................................................8

2.0

3.0 3.1 3.2 3.3 3.4 3.5 3.6

4.0 4.1 4.2 4.3 4.4

5.0

6.0 6.1 6.2 6.3 6.4 6.5 6.6

7.0 7.1

7.2

7.3

SITE CHRONOLOGy..........................................................................................................8

BACKGROUND...................................................................................................................10 Physical Characteristics ....................................................................................................10 Land and Resource Use ...................................................................................................10 History of Contamination...................................................................................................11 Initial Response ...................................................................................................................12 Enforcement History ...........................................................................................................14 Basis for Taking Action ......................................................................................................15

REMEDIAL ACTIONS .......................................................................................................16 Remedy Selection ...............................................................................................................16 Remedy Implementation ...................................................................................................18 Institutional Controls ...........................................................................................................23 System Operations/Operation and Maintenance (O&ML.........................................33 A. Phase I (Source AreaL........................................................................................33 B. Phase II (Groundwater Extraction & Treatment SystemL...........................33 C. Phase III (In-situ Vapor Extraction System) .....................................................35 D Long-Term Ground Water Monitoring................................................................36 E. Remedy Costs .........................................................................................................37

PROGRESS SINCE THE LAST FIVE-YEAR REVIEW.............................................38

FIVE YEAR REVIEW PROCESS....................................................................................41 Administrative Components.............................................................................................41 Community Notification and Involvement .....................................................................41 [)ocument Review ...............................................................................................................41 Data Review .........................................................................................................................42 ~;ite Inspection.....................................................................................................................44 Interviews..............................................................................................................................45

TECHNICAL ASSESSMENT...........................................................................................45 Question A: Is the remedy functioning as intended by the decision documents? .........................................................................................................................45 C)uestion B: Are the assumptions used at the time of remedy selection still

valid? .....................................................................................................................................47 Question C: Has any other information come to light that could call into question the protectiveness of the remedy?................................................................49

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Page 8.0 ISSUES ................................................................................................................................. 50

9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS .............................................. 51

10.0 PROTECTIVENESS STATEMENT(SL........................................................................ 53

11 .0 NEXT REVI EW .................................................................................................................... 53

FigurE!S

FigurE! 1 Site Location Map - State of Michigan FigurE! 2 Site Location Map - Muskegon County FigurE! :3 Site Location Map - Local Location FigurE! 4 Site Layout - Groundwater Sampling and Extraction Locations FigurE! 5 Thermo Chern Site Contaminant Plume in Groundwater; 2005 Data Figure 6 Thermo Chern Site ISVE System Layout Figure 7 Thermo Chern Site Approximate Institutional Controls Area

Tables

Table 1* Chronology of Site Events Table 2 Groundwater Cleanup Standards and Single Well Chronology Table 3 Contaminant Removal Summary: ISVE System, 2005-2008 Table 4 Summary of Contaminant Concentrations at GWETS Table 5A Summary of Maintenance and Repair Activity - Phase II of Remedy Table 58 Summary of Maintenance and Repair Activity - Phase III of Remedy Table 6* Institutional Control Summary Table 7* Issues and Recommendations Identified in 2005 (First) Five-Year Review Table 8* Issues that Impact Protectiveness Table 9* Recommendations and Follow-up Actions

Appendices

Appendix A List of Documents Reviewed for the Five Year Review Report Appendix 8 Five Year Review Advertisement Appendix C Completed Site Inspection Checklist

* Tabl'8s marked with an asterisk are included in the text body of the Report. All other Tables are included at the end of the Report.

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~,OC

~,RARs

CAT-OX CERCLA CFR CD DMR ESD GWETS HOPE IA ISVE ICs LDRs LNAPL NCP MDEQ MDNR MDNRE. NPDES NPL O&M O.U. ppb

PRP PCOR ClA ClAPP PD/RA ~~O ~~CRA ~~I/FS

POD Site SRD SVOC T8C UAO ug/L USACE U.S. EPA VAS VOC

List of Acronyms

Administrative Order on Consent Applicable or Relevant and Appropriate Requirements Catalytic Oxidation Unit for Treatment of Off-Gas in ISVE Portion of Remedy. Comprehensive Environmental Response, Compensation and Liability Act Code of Federal Regulations Consent Decree Discharge Monitoring Report Explanation of Significant Differences Groundwater Extraction and Treatment System High Density Polyethylene Interagency Agreement In-situ Soil Vapor Extraction Institutional Controls Land Disposal Restrictions Light Non-aqueous Phase Liquid National Contingency Plan Michigan Department of Environmental Quality Michigan Department of Natural Resources Michigan Department of Natural Resources and Environment National Pollutant Discharge Elimination System National Priorities List Operation and Maintenance Operable Unit Parts per billion, or, micrograms of contaminant per Liter of groundwater. For contaminated soil, ppb is micrograms of contaminant per kilogram of soil. Potentially Responsible Party Preliminary Closeout Report Quality Assurance Quality Assurance Project Plan Remedial Design/Remedial Action Remedial Action Objective Resource Conservation and Recovery Act Remedial Investigation/Feasibility Study Record of DeciSion Thermo Chem Inc. Superfund Site in Muskegon, Michigan Substantive Requirements Document Semi-Volatile Organic Compound To-8e-Considered Unilateral Administrative Order micrograms of contaminant per liter of groundwater, or ppb. U.S. Army Corps of Engineers U.S. Environmental Protection Agency Vertical Aquifer Sampling Volatile Organic Compound

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Executive Summary

The Thermo Chem Inc. Site consists of approximately nine and a half acres of land that housed the Thomas Solvent Company and Thermo Chem, Inc. facilities, which operated as solvents reprocessing, recovery, storage, and distribution facilities. The remedy at the Thermo Chem Inc. Site currently protects human health and the environment in the short term. Based upon the review of annual groundwater monitoring data, historical Site documents, documents since 2004, other data reviews, and the April 21,2010 Site inspection conducted for this five-year review, there are no current exposures to human health and the environment. Use of the Site property is consistent with the objectives of the Site remedy in place, and there is no evidence of disrepair or discontinuation of the remedy systems at the Site. There is no evidence of unacceptable groundwater use in the ar,ea of the plume.

The remedy currently protects human health and the environment in the short term because the threat of direct human and environmental contact with contaminated soil and groundwater has been eliminated by the three phases of the Site remedy, which have been operational since 1999. The Phase I source control remedial action disposed of contaminated buildings, storage tanks, and excavated contaminated soils. Phase" is groundwater capture and extraction from shallow and deep aquifers, water treatment to substantive requirements of the National Pollutant Discharge Elimination System, and discharge to Black Creek at the southern boundary of the Site. Phase "I consists of in-situ vapor extraction (ISVE) of contaminants in Site soils with on-site vapor treatment to meet air emission standards. U. S. EPA approved the Remedial Implementation Reports for all three phases of the Site remedy on March 8, 2000, and the Site remedy is currently in the Operational and Maintenance phase of the RD/RA.

In order for the remedy to be protective in the long-term, the remedy must attain long­term achievement of cleanup standards, and effective institutional controls (ICs) must be implemented, monitored, maintained, and enforced. Long-term protectiveness also requires compliance with effective ICs. Required ICs include land and groundwater use restrictions that: prohibit use of land within the Site property boundary; prohibit residential, commercial, or any other use that would allow the continued presence of human exposure; assure integrity of all remedy components; limit well installation on­site to prevent breaches of Phase" and "I remedy components located underground; limit well installation to prevent groundwater use; prevent any other activity on-site that could disturb remedy components that are underground; and prohibit use of untreated groundwater that contains contaminants at levels above acceptable cleanup standards.

The review also confirms that no known exposure pathways exist that result in unacceptable health risks. The components of the remedies required by the 1991 Record of Decision and the 1994 and 2002 Explanations of Significant Differences have heen implemented and remain effective under the 1994 Unilateral Administrative Order for RD/HA, and will include Institutional Controls yet to be implemented. This is the sl3cond five year review for the Thermo Chem Inc. Site. The triggering action date for this five-year review is the signature date of the first five-year review of May 10, 2005.

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Five-Year Review Summary Form

: Thermo-Chern Inc.

NPL. status: X Final - Deleted ,- Other (specify)

: r Under Construction X

,.n''nftl..r'on date: 9/17/2002

r Tribe r Other Federal

Author affiliation: U.S. EPA

Date

Type of review: X Post-SARA L NPL-Removalonly

I ional Discretion

Review number: - 1

Triggering action: - Actual RA Onsite Construction - Actual RA Start - Construction Completion X Previous Five-Year Review Report - Other "" ""0"''''''

Tri 10 2005

10 2010

* 'au" refers to operable unit. On September 17, 2002, an Explanation of Significant Differences (ESD) was issued where U.S. EPA determined it was appropriate to modify the original Record of Decision to combine requirements of au #1 and au #2 into one remedy and no longer maintain operable unit designation at the Site.

** Review period corresponds to the actual start and end dates of the Five-Year Review in WasteLAN.

1. Groundwater sampling events and data may not be complete or representative of site conditions. Groundwater samplin~ events and data may not have adequate frequency, locations, or analytical parameters. Monitoring may not include adequate evaluation of the effectiveness of natural processes as a component of the remedy in the Black Creek floodplain. Statistical analyses may not be frequent enough or may not be using representative data for certification of groundwater capture by the GWETS. The Site conceptual! computer model must be updated with data merE' recent than 2004. The monitoring well network in the Black Creek floodplain may not be representative.

2 Deep aquifer sampling may not have adequately characterized the presence or extent of contaminants in deep gl·oundwater. Deep aquifer sampling events may not be providing representative monitoring data because of the samplin~'l1ethod used, inadequate locations, or inadequate sampling frequency.

3. Passive Diffusion Bag (PDB) samplers may not be providing representative groundwater samples. The PDB samplin~ method may not be an acceptable equivalent to traditional "lOW-flow" sampling. Data collected with PDB samplers may not be representative of site conditions.

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Five-Year Review Summary Form, cont'd.

4 Them is an observed increase in the level of methane gas concentration in the OU2-MW-2 monitoring well series.

5 Institutional Controls as required by the 1991 ROD have not yet been implemented and the existing ROD may not address les for groundwater contamination away from the source property.

Recommendations and Follow-up Actions:

1 Review the current annual monitoring program and possibly increase frequency, locations, and analytical parameters. Update U.S. EPA's 2004 computer model using recent accurate groundwater chemical and elevation data and possibly initiate bi-annual computer analyses of data.

2 Review previous deep aquifer data for adequacy, especially in the Black Creek and wetlands areas. Review and revise the current deep aquifer monitoring program based on the data adequacy review above.

3 Review technical references and policy to determine if PDB samplers can be used at the Site. Perform a field demonstration of the equivalency of PDB samplers to "low-flow" purging and sampling.

4. Determine the source of the high levels of methane gas in the OU2-MW-2 wells series and whether this presents a health/safety or contaminant issue. Develop/implement a plan to mitigate the health/safety issue or otherwise address this contaminant.

5. An Ie Study shall be conducted and an IC Work Plan shall be submitted by the PRPs for review and approval to plan for implementation and maintenance, monitoring and enforcement of ICs. U.S. EPA will determine whether an ESD may be needed to address ICs for groundwater contamination away from the source property.

Protectiveness Statement:

Tile remedy at the Thermo Chem Superfund Site currently protects human health and the environment in the short term because: the groundwater extraction and treatment and the in-situ soil vapor extraction systems are in place and operating properly; there is no evidence of any breaches of remedy systems or soil directly above those systems; the existing use of the Thermo Chem Site property is consistent with the objectives of the remedy systems in place and expected land use restrictions; and because there is no evidence of unacceptable levels of groundwater contaminants immediately adjacent to the Site property or unacceptable groundwater use in the area of the plume. In order for the remedy to be protective in the long-term however, the remedy must attain the cleanup standards specified in the 1991 ROD as modified by the 2002 Explanation of Significant Differences. Long term protectiveness also requires compliance with effective ICs. That includes the implementation, monitoring, maintenance, and enforcement of institutional controls for land and groundwater use restrictions that: (1) prohibit interference with the currently operating remedy systems; (2) prohibit residential, commercial, or any other use in specific Site areas that would a low human exposure; and (3) restrict use of groundwater until groundwater cleanup standards are achieved throughout the plume area.

Other Comments:

Date of Last Review of Human Exposure Indicators: December 5,2007. Human Exposure Survey Status: Human Exposure Under Control. Under current conditions at this Site, potential or actual human exposures are under control. S te-Wiele Ready for Anticipated Use: No

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1.0 INTRODUCTION

The United States Environmental Protection Agency (U.S. EPA) has conducted a five­year review of the remedial action implemented at the Thermo Chem, Inc. Superfund Site in Muskegon, Michigan. The review was conducted from October 1,2009 to May 3, 2010, with the results documented in this report. The purpose offive-year reviews is to determine whether the remedy at a site is protective of human health and the environment. Methods, findings, and conclusions of the review are documented in Five­Year I~eview Reports. In addition, Five-Year Review Reports identify any issues or problems found during the review and make recommendations to address them.

This review is required by statute. Five-year reviews must be implemented consistently with tllE~ Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (i'JCP). CERCLA 121(c), as amended, states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the Site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action.

The NCP Part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.

This is the second five-year review for the Thermo Chem Inc. Site, triggered by the first five-year review of May 10, 2005. Due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure, this five-year review is required.

2.0 SITE CHRONOLOGY

T bl a e 1 -Ch rona ogy 0fThermo Chem nco S'tIe Eyents-Event Date

Thel'mo (;hem is proposed for the National Priorities List (NPLt October 1984 MDNR bE:'9ins soil investigation at Thermo Chem property. December 10, 1984 MDt~R bE~ins soil investigation at Thomas Solvent pro~erty. April 3D, 1985 NPL Pate~ntially Responsible Party (PRP) Search is completed. September 1985 Listing of the Site on the National Priorities List. June 1986

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Event Date Cornmun ~I Relations Plan is approved. July 1987 Administrative Order on Consent for RifFS effective date. September 21, 1987 Removal ~ction for drums & other hazardous waste is completed. December 20, 1988 UAO is is sued for access to the Site property for RflFS work. January 9, 1989 PRPs be (in investigative activities. April 1989

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UAO is is sued for access to the Site property for RifFS work. July 12, 1989 Spe<:ial Notice Letters For Remedial Designl Remedial Action issued. January 2, 1990 UAO is is sued for access to the Site property for RI/FS work. January 16, 1990 UAO is is sued for access to the Site property for RifFS work. January 23, 1990 U.S. EPA's investigation at Thomas Solvent is completed. August 1990 UAO is is sued for a removal action on the Thomas Solvent property. February 19, 1991 RifFS Re port is completed. July 1991 End of pI. blic comment period for Record of Decision. July-September 1991 Removal Action for underground tanks is completed. September 26, 1991 Record 0 .' Decision is issued. September 30, 1991 UAO is issued for the RDfRA of O.U. #1. May 6,1992 U.S. EPA and USACE enter an IA for the O.U. #1 RD. September 1, 1992 UAO is is sued for access to the Site property for RD/RA work. March 25, 1993 First Expl anation of Significant Differences is signed. April 25, 1994 AOe is issued for settlement with approx. 300 PRPs who contributed

August 24, 1994 smallamoLints of waste (de minimis settlement). U. S. EP,l~ amends the May 1992 UAO whereby U.S. EPA is to

October 12, 1994 complete the RDs for Phases I and II of the remedy. PRP~ee to conduct RD for Phase III and RA for all three phases. October 27, 1994 UAO is issued for RD/RA to add two parties. December 1, 1994 A second AOC is issued for the remainder of deminimis respondents. September 27, 1995 Site PRP! ; mobilize to implement Phase IA of the RA. September 1995 Site PRP! ; award a contract for Phase III (ISVE) of the Site remedy. March 12, 1996 Site PRPs . and USACE perform a final Site inspection for Phase IA. May 6,1996 Cooperative Agreement Grant with the State of Michigan is issued. September 1996 Site PRP! ; mobilize for Phase IB of the Site remedy. April 25, 199.7 PRP Rem edial Design is started. August 1997 Construction of Phase III of the Site remedy starts. October 1997 Final appl 'oval of Phase II design documents and drawings. November 18, 1997 Site PRP! 5, U.S. EPA, MDEQ, and USACE perform a pre-final Site

April 7, 1998ins 13ction for Phase IB and Phase III of the Site remedy. Phase III 9J'the Site remedy is put into operation. August 7, 1998 A 3C-day continuous treatment operation test period is successfully

April 22, 1999 complete(Uor Phase II (the GWETS). Fina~ection to confirm comgletion of all construction work items. April 29, 1999 U.S. EPA Issues a Jetter confirming all phases of the O. U. #1 remedy

March 8, 2000 haVE~ achi~~Jed Operation and Maintenance (O&M) status.

April 2002 Second E xplanation of Significant Differences is signed. O.U. #2 (I~!ack Creek area) investigative work is completed.

September 17,2002 Preliminal1 Close Out Report is signed. September 17,2002 LNAPL s~~!nming operation (Phase III) is discontinued. September 2004

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Event Date Catc~Oxidation (CAT-OX) Operation (Phase III) is discontinued. November 2004 First Five Year Review Report is signed. May 10,2005 Second fivE~-year review process is started. October 2009 Five-Year. Heview Site inspection by PRPs, MDNRE and U.S. EPA. April 21, 2010

3. BACKGROUND

3.1 PHYSICAL CHARACTERISTICS

The Site consists of approximately nine and a half acres of land in the Northeast 1/4 of the SVV 1/4 of Section 31, T10N, R15W, Egelston Township, Muskegon County, Michigan. The Site is located at 4331 and 4321 Evanston Road, approximately five miles east of the City of Muskegon (see Figures 1 through 3). This land formally housed both the Thomas Solvent Company and Thermo Chem, Inc. facilities. Thomas Solvent operated a solvents reprocessing and recovery facility within approximately 1.5 acres in the northwest corner of the Site, while Thermo Chem, Inc. operated a bulk solvents storage and distribution facility on the remaining 8 acres.

The Site is located in the Glacial Lake Plain physiographic unit. The Site is nearly level from liorth to south with an average elevation of approximately 655 feet above sea IE!vel. Changes in the physical features of the Site are the result of clearing and construction activities. There is no natural surface drainage on the Site because the land surface is nearly level and sandy soil underneath allows water to seep through. Surface soil consists primarily of medium-to fine-grained sand. The only substantial surface water body in the area is Black Creek, a meandering creek within a broad and flat wetland with standing timber. Black Creek is located immediately south of a twenty eight foot steep slope on the Site's south end that defines the Black Creek flood plain valley. Black Creek flows west to Mona Lake which discharges into Lake Michigan. Some of the areas around Black Creek lie within the 1 OO-year flood plain area.

Two principal aquifers were identified during the Remedial Investigation and Technical Assistance Study at the Site. The upper unconsolidated, unconfined aquifer varies in thickness from 20 feet in the northeast area of the Site to 55 feet in the southwest portion of the Site. The groundwater table lies from 17 feet below the ground surface in the northeast to 32 feet below the surface in the southwest. The upper unconsolidated d'3posits are predominantly medium to fine grained sand. The upper and lower aquifers al-e separated by a discontinuous layer of clay. The deeper confined/semi-confined aquifer is located beneath the silty-clay layer and varies in thickness from 61 feet to 116 fE!et. The deepest penetrated sediments are glacial tills.

3.. 2 LAND AND RESOURCES USE

The area surrounding the Site is semi-rural and is comprised of residential areas, light manufacturing, commercial buildings and undeveloped woodland. A water supply well at a sil19le-family residence located immediately adjacent to the west of the Site has

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been sampled annually since 1986 by the Michigan Department of Natural Resources and Environment (MDNRE, formerly MDEQ). Fourteen residential water supply wells on Evanston Road and three residential wells on Mill Iron Road have been sampled for Volatile Organic Compounds (VOCs) with no organic contaminants observed. The largest number of residents closest to the Site is located about one-half mile west on Evanston Road in two mobile home parks (Arlington Estates) that have a total of 594 lots.

There is no designated State of Michigan Significant Habitat or historic landmark site directly or potentially affected by the Site. Although there is a potential for endangered speciE~s in close proximity to the Site, none have been documented. Black Creek is designated as a trout stream by the State of Michigan. Black Creek is used for recreational purposes.

Two other Superfund sites are located near the Site. The SCA Independent Landfill Superfund Site is located approximately 300 feet immediately south of Black Creek, and the Bofors Nobel Superfund Site is located approximately one and a quarter miles east of the Site. Both sites border Black Creek.

3.3 HISTORY OF CONTAMINATION

Thermo Chem, Inc. operated as a solvent and chemical waste reprocessing, refining, and incineration facility from 1969 until August 1980. Solvents, paint wastes, and antifreeze received at the Site were distilled to regenerate usable solvents. Unrecoverable materials reportedly were incinerated on-site, as were distillation still bottom sludge and residues. Wastewater generated from distillation and equipment cleaning processes was discharged into a series of three interconnected lagoons. The northernmost lagoon was lined with clay and the other two lagoons were unlined.

The Thomas Solvent Company operated from 1961 to October 1986 as a licensed industrial waste hauler and hauled hazardous waste to its subsidiary, Thermo Chem, Inc., for reprocessing. The Thomas Solvent Company also acquired recycled material from Thermo Chem, Inc. to return to its customers. Sixteen underground storage tanks with a capacity totaling 104,000 gallons were located on the Thomas Solvent Co. property and were used to store raw materials and these recycled materials. The Thomas Solvent Co. hauled over 200 different chemical blends to Thermo Chem, Inc. for reprocessing. Some of these chemicals were designated as hazardous waste according to the Resource Conservation and Recovery Act (40 CFR 261 Subpart C&D). At least 3,500 drums were stored on the Thermo Chem, Inc. and Thomas Solvent Co. properties during the time the two companies were in operation. No physical barriers separated these adjacent properties, whose ownership and operations were intertwined.

U.S. EPA identified a list of chemicals of concern for the Site. The risk assessment fOCUSE!d on health and environmental effects resulting from exposure to these chemicals, detected in both groundwater and soil at the Site:

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1,1-Dichloroethene Toluene Tetrachloroethene Total 1,2-Dichloroethene xylenes 4,4-DDT Chloroform bis (2-Ethylhexyl) phthalate Benzene 1,2-Dichloroethane Napthalene Chromium 1,1,1-Trichloroethane Arsenic Trichloroethene

3.4 INITIAL RESPONSE

On December 10, 1984, an investigation of soil at the Thermo Chem, Inc. property conducted by the Michigan Department of Natural Resources (MDNR, now known as MDNHE) indicated the presence of: 1,1, 1-trichloroethane, trichloroethene, tE~trachloroethene, 4,4' DDT, 1,2-dichloroethene, 1,2-dichloroethane, toluene, ethylbenzene, and xylenes. An investigation at the Thomas Solvent Co. property conducted by MDNR on April 30, 1985 indicated that the soil at that property was also contaminated with most of these contaminants. Similar compounds were also detected in the groundwater during the 1985 investigation.

Formelr Thomas Solvent Co. and Thermo Chem, Inc. employees indicated that chemical spills frequently occurred and sludge was occasionally buried at both properties. Based on historical documents and statements from former employees, it was determined that solvent wastes identified as F001-F005 hazardous wastes under U.S. EPA's federal mgulations (RCRA, 42 U.S.C. 6901, et. seq.) were disposed of at the Site. U.S. EPA determined that contamination in groundwater both beneath and downgradient of the Site was attributable to the contamination sources at both the Thermo Chem, Inc. and Thomas Solvent Co. properties. Operations at the two properties had contaminated groundwater in both shallow and deep aquifers. Suspected sources of contamination included: wastes in the three interconnected lagoons located in the central processing area, sludges disposed at the Thermo Chem, Inc. property, the underground storage tanks at the Thomas Solvent Co. property, and spills throughout the Site.

The Thermo Chem, Inc. property was proposed for inclusion on the National Priorities List (NPL) in October 1984 and placed on the NPL in June 1986. An Administrative Order on Consent (AOC) was signed on September 21, 1987 by U.S. EPA and parties identified by U.S. EPA as being potentially responsible for the contamination problems at the Site (Potentially Responsible Parties, or "PRPs"). In the AOC, the PRPs agreed to conduct a Remedial Investigation and Feasibility Study (RifFS) at the Thermo Chem, Inc. property to determine the nature and extent of contamination at the property and identify methods to correct these problems. The PRPs began investigative activities in April 1989.

The AOC provided that the PRPs would not be required to conduct a RifFS at the adjace!nt Thomas Solvent Co. property. However, during the RifFS at the Thermo Chem, Inc. portion of the Site, it was discovered that contamination was coming from the Thomas Solvent Co. property. Therefore, U.S. EPA conducted a Technical Assist.ance Study to determine the nature and extent of contamination on the Thomas Solvent Co. property. U.S. EPA's investigation of contamination at the Thomas Solvent

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Co. property was completed in August 1990 and the final report of U.S. EPA's conclusions was completed in March 1991. The results of the investigation at the Thomas Solvent Co. property and the Thermo Chem, Inc. property indicated that the contamination releases at Thomas Solvent Co. appeared to be one of the sources of groundwater contamination identified in the Thermo Chem NPL listing. Accordingly, the Thermo Chem Site includes both the Thomas Solvent Co. property and the Thermo Chern, Inc. property. The Remedial Investigation also indicated that Site groundwater flows south-southwest toward Black Creek.

From September to December 1988, concurrent with investigation activities at the Thermo Chem, Inc. and Thomas Solvent Co. properties, an emergency removal of drums and materials containing hazardous waste was conducted by U.S. EPA at the Thermo Chem, Inc. property. The removal action was taken to reduce the threats posed to public health by the presence of chemicals and drums at the Site. Chemicals were stored in the laboratory building on site and the drums were found in buildings throughout the Site. In addition, buildings at the Site were unsecured. U.S. EPA also sampled insulation in and on buildings and tanks for the presence of asbestos material. This insulation material did not contain asbestos.

Additional emergency removal activities were conducted by U.S. EPA from April to September 1991. During the investigation at the Thomas Solvent property, pure solvent Light Non-Aqueous Phase Liquids (LNAPL) were discovered approximately 100 feet downwadient of the underground Thomas Solvent storage tank farm. U.S. EPA inspected these underground storage tanks and discovered residual solvents were present and tank vent pipes could not be secured. U.S. EPA determined that these tanks posed an imminent and substantial endangerment to public health or welfare or environment because of the potential for explosion and the threat of release of contaminants from the tanks. The 16 underground storage tanks (and their contents) that were on the Thomas Solvent Co. property were removed and taken off-site by U.S. EPA for proper disposal.

Anticipated contamination problems in Black Creek, including sediment, surface water, biota, and groundwater south of Black Creek and associated risks were originally intended to comprise O.U. #2. U.S. EPA requested Site PRPs to conduct additional field work to define groundwater contamination problems around Black Creek and the impact of the contamination on the Creek. Field work included installing approximately ten monitoring wells north of Black Creek, six monitoring wells south of Black Creek, and collecting seven sediment and surface water samples from Black Creek. Additionally, groundwater data was obtained and evaluations were conducted for groundwater in the down gradient areas of O.U. #2. The field work for these additional activities was initiated in July 1991. O.U. #2 investigative work was completed in April 2002.

On September 3D, 1991, U.S. EPA signed a Record of Decision (ROD) with the concurrence of the MDNR selecting a remedy for the Site.

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3.5 ENFORCEMENT HISTORY

3.5.A Administrative Order on Consent (AOC) For RifFS

On November 17, 1986, the Potentially Responsible Parties (PRPs) were notified in writin9 of the opportunity to conduct a RifFS under U.S. EPA supervision. RifFS negotiations ended on September 21, 1987 when the AOe was signed by U.S. EPA after receipt of PRPs' signatures.

3.5.B Unilateral Administrative Orders (UAOs) for Investigative and Cleanup Work

UAOs were issued on January 9, 1989, July 12, 1989, January 10, 1990, and January 23, 1990 for U.S. EPA to gain access to the Site property to perform RifFS work. On February 19, 1991, U.S. EPA issued a UAO to PRPs for a removal action on the Thomas Solvent property. On May 6, 1992, U.S. EPA issued a UAO to the PRPs for the Remedial Design and Remedial Action (RDfRA) of Operable Unit (O.U.) #1. On March 26, 1993. a UAO was issued by U.S. EPA to obtain access to the Site property for U.S. EPA to perform RDfRA work.

3.5.C Administrative Order on Consent For De Minimis Respondents

Because approximately 300 PRPs contributed small amounts of waste representing a minor portion of past and future cleanup costs at the Site, it was determined that prompt settlement with those respondents was practicable and in the public interest. On August 24, 1994, U.S. EPA signed an AOe after receiving signatures from representatives of most of these PRPs. Funds from this agreement have been placed in a Special Account within the Superfund Trust Fund and are reserved for use at the Site. As of May 3,2010, these funds are being used by U.S. EPA Region 5 for site­specific costs such as payroll and travel expense. No other re-classification or transfer of Thermo ehem Special Account funds has occurred.

3.5.0 Second Administrative Order on Consent For De Minimis Respondents

On September 27, 1995, U.S. EPA signed a second AOe after receiving signatures from the remainder group of deminimis respondents.

3,.5.E Amendment to the RDfRA Unilateral Administrative Order

On October 12, 1994, U. S. EPA issued an amendment to the May 6, 1992 UAO. Under this amended UAO, U.S. EPA accepted responsibility for completing the remedial d'9signs for Phases I and II of the O.U. #1 remedy. On October 27,1994, the rE!sponclents to the amended RDfRA UAO agreed to conduct the Remedial Design for Phase III and the Remedial Action for all three phases of the O.U. #1 remedy under the UAO.

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3.S.F Unilateral Administrative Order for RD/RA

On OHcember 1, 1994, U. S. EPA issued another UAO directing additional parties to participate in RO/RA work conducted by the respondents to the October 12, 1994 amended UAO.

3.6 BASIS FOR TAKING ACTION

Hazardous substances that have been found at the Site in both groundwater and soil include:

1,1-0'chloroethene Toluene Napthalene Total 1 .2-0ichloroethene xylenes Arsenic Chloroform bis (2-Ethylhexyl) phthalate Chromium 1,2-0Ichloroethane Trichloroethene 4,4'-00T 1,1,1-Trichloroethane Benzene T etrachloroethene

u.S. EPA determined that hikers and hunters who might accidentally swallow Site soil, inhale blowing dust, or inhale evaporating vapors from the soil might experience an excess cancer risk of two additional cases for every 1,000 people exposed to the contamination. The Hazard Index associated with such exposure was 500, indicating a strong likelihood that exposure would cause harmful non-cancerous health effects as well. These effects might include nerve damage resulting from exposure to arsenic and central nervous system depression from exposure to tetrachloroethene.

As part of O.U. #2 investigative work, U.S. EPA requested that Site PRPs conduct additional field work to define groundwater contamination problems around Black Creek and the impact of the contamination on the Creek. Field work included installing appro)(imately ten monitoring wells north of Black Creek, six monitoring wells south of Black Creek, and collecting seven sediment and surface water samples from Black Creek. Additionally, groundwater data was obtained and evaluations were conducted for ground water in the down gradient areas of O.U. #2.

Results from O.U. #2 investigative work showed that the plume of contamination in groundwater extends approximately 1300 feet down gradient in the Black Creek flood plain. No human health or ecological risk associated with contamination known to be at the Site has been identified in the Black Creek or flood plain area. Evaluation of human h,ealth and ecological risks indicate that contaminant concentrations detected in groundwater, surface water, and sediment samples collected in the Black Creek flood plain would not affect recreational users or ecological receptors. The results of each exposure pathway are below U.S. EPA's acceptable cancer risk of 1 x 10-6 and below the acceptable hazard quotient and hazard index of 1 for non-carcinogenic contaminants.

For this five-year review, the potential risk from contaminant vapor intrusion to indoor air was e:<amined. Consistent with U.S. EPA document #EPA 530-0-02-004 entitled

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"OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (November 2002)," it was determined that currently or potentially inhabited buildings or areas of concern under future development scenarios located near the Site are not in close proximity to subsurface contaminants. Specifically, the closest properties to the Site are about one-quarter mile (approximately 1100 feet) west on Evanston Road at Arlington Estates. Analytical data has shown that no chemicals of sufficient volatility and toxicity are present in groundwater at this property. There is no potential for the vapor intrusion pathway to impact either currently inhabited buildings or areas of concern under future development scenarios away from the Site. Therefore, no further evaluation of this pathway is needed. As recommended in document #EPA 530-0-02-004, the vapor intrusion pathway will be re-assessed if Site monitoring data ever suggests the presence of known or interpolated soil gas or groundwater contaminants near any inhabited building within approximately 100 feet (laterally or v'3rtically) of the Site or groundwater affected by the Site.

4.0 REMEDIAL ACTIONS

As agreed upon with MDNRE during the RI, U.S. EPA separated the cleanup of the Site into MIO operable units (O.U.s). O.U. #1 encompasses contaminated soil, sludge and groundwater up to the point where groundwater discharges into the Black Creek floodplain. O.U. #2 addressed contamination in the surface water, sediment, plants and living organisms within Black Creek and groundwater south of Black Creek. On September 17, 2002, U.S. EPA issued an Explanation of Significant Differences (ESO) that modified the original O.U. #1 Record of Decision and cleanup approach to combine requirements of O.U. #2 into the O.U. #1 remedy.

4.1 REMEDY SELECTION

4" 1.A Record of Decision

The September 30, 1991 Record of Decision for O.U. #1 has the following remedial objectives for the Site cleanup based on data obtained during the RI:

- Reduce or minimize direct human and environmental contact with contaminated soil through inhalation and ingestion;

- Reduce or minimize release of contaminants in soil and sludge to the groundwater; and

- Restore groundwater so that contamination levels meet appropriate health standards, and stop the flow of contaminated groundwater to Black Creek.

The major components of the remedy selected by the O.U. #1 ROD are:

Phase I - Decontamination, demolition, and off-site disposal of all on-site buildings, including the

laboratory, process buildings, a warehouse, an incinerator, and all above ground storage tanks.

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- Excavation and off-site incineration of Group 1 and 2 soils with contamination above Michigan Act 307 Type A or B standards.

Phase II - Groundwater from the shallow and deep aquifers will be extracted and treated to

Michigan Act 307 Type A or B standards using filtration, air stripping, metal precipitation, and pH adjustment. The emitted gases will be carbon treated to meet State air quality standards. The carbon will be regenerated or disposed of off-site in accordance with Land Disposal Restrictions (LDRs). The treated groundwater will be discharged to Black Creek under the substantive requirements of the National Pollutant Discharge Elimination System (NPDES).

Phase III - In-situ vapor extraction (ISVE) for all Site soils to meet Michigan Act 307 Type A or B

standards, and the removal of the LNAPL source.

Additional O.U. #1 ROD requirements - Additional studies will be conducted at the Site to determine background soil

concentration, the ability of some contaminants to leach to the groundwater, and the existence of other contaminated soil. Based on the results of these additional studies, more excavation and/or treatment may be necessary to meet Michigan Act 307 Type A or B standards.

- Institutional controls will be implemented to restrict future development of the Site to the extent necessary to implement and protect the remedy, and to safeguard human health and the environment during implementation of the remedy. These include construction of a fence around the boundary of the Site and land use restrictions.

4.1.8 Explanation of Significant Differences

On April 25, 1994, U.S. EPA signed an Explanation of Significant Differences to update cleanup standards for the Site remedy, revise the volumetric estimate of contaminated soil to be treated, and explain the associated increase in remedy costs. Based on the Remedial Design, additional soil sampling and other new information, the significant differences to the remedy selected by the 1991 ROD were: a change in soil cleanup criteria affecting the volume of soils to be remediated; a change in the remediation technology to soil vapor extraction; and an increase of the remedy cost estimate from the $24 million estimated in the ROD to approximately $43.7 million.

4.1.C Second Explanation of Significant Differences

Anticipated contamination problems in Black Creek, including sediment, surface water, biota, and groundwater south of Black Creek and associated risks were originally il1tended to comprise O.U. #2. U.S. EPA requested Site PRPs to conduct additional field work to define groundwater contamination problems around Black Creek and the impact of the contamination on the Creek. Field work for these additional activities was

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initiated in July 1991. Results showed a plume of contamination in groundwater approximately 1300 feet down gradient in the Black Creek flood plain, but no human health or ecological risk was identified in the Black Creek or flood plain area. Contaminant concentrations detected in groundwater, surface water, and sediment samples collected in the Black Creek flood plain and the associated evaluation of human health and ecological risks indicated that this contamination would not affect mcreational users or ecological receptors. Results of each exposure pathway for O.U. #2 arE! below U.S. EPA's acceptable cancer risk of 1x10-6 and below the acceptable hazard quotient and hazard index of 1 for non-carcinogenic contaminants. Monitoring data showed that groundwater migrating from the Site to Black Creek does not degrade surface water beyond applicable water quality standards.

On SE!ptember 17, 2002, U.S. EPA issued an Explanation of Significant Differences (ESD) that modified the remedy selected in the 1991 ROD as follows:

- U.S. EPA determined it was appropriate to modify the original O.U. #1 ROD to combine requirements of O.U. #1 and O.U. #2 into one remedy and no longer maintain operable unit designation at the Site. Merging of O.U. #1 and O.U. #2 constituted a significant change to the remedy, but does not fundamentally alter the overall approach presented in the O.U. #1 ROD.

- Changes to the Site groundwater cleanup standards were appropriate based on new Michigan Part 201 Residential Drinking Water Criteria or current U. S. EPA Drinking Water Standards (the most stringent health based value was used). Groundwater cleanup standards in the 1991 ROD were based on Type B standards pursuant to the Michigan Environmental Response Act, PA 307 of 1982, as amended (Michigan Act 307), and Michigan Act 307 became Part 201, Act 451. Cleanup standards shown in the 1991 ROD were updated and added the contaminant vinyl chloride. This change did not fundamentally alter the overall approach intended by the remedy selected in the 1991 ROD.

4.2 REMEDY IMPLEMENTATION

As noted in the 1991 ROD, U.S. EPA has the following remedial objectives for the Site remedy: reduce or minimize direct human and environmental contact with contaminated soil through inhalation and ingestion; reduce or minimize the release of contaminants in soil and sludge to the groundwater; restore groundwater so that contamination levels meet appropriate health standards; and stop the flow of contaminated groundwater to Black Creek. Remedial Actions have been implemented at the Site: to capture contaminated groundwater before it reaches Black Creek; to reduce contamination in groundwater until the Drinking Water Standards listed in Table 2 are achieved; to rE!duce contamination at the Site until a cumulative excess cancer risk below 10-4 is achieved; and to reduce contamination at the Site until a cumulative Hazard Index b'910w one is achieved. Further, restrictions on use of the Site property and use of contaminated groundwater wi" be implemented and maintained until health based cleanup goals have been met. Appropriate quality assurance and quality control was

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performed during all phases of remedy construction. Throughout the construction activities for all operable units, the parties have monitored of contaminated media.

4.2.A Remedial Design

On SE!ptember 1, 1992, U.S. EPA and the U.S. Army Gorps of Engineers (USAGE) enterE!d into an Interagency Agreement (IA) for the RD for Phase I of the O.U. #1 Hemedial Action. In February 1994, USAGE submitted drawings and specifications for: decontamination, demolition, and off-site disposal of all on-site structures; excavation and off-site incineration of Group 1 and 2 soils; and installation and maintenance of a site sElcurity fence. In September 1995, the PRPs mobilized to implement the USAGE design and Phase IA of the Remedial Action commenced. U.S. EPA provided final approval of the USAGE O.U. #1 RD on January 29, 1997. On or about April 25, 1997, the PHPs received a notice to proceed to mobilize and implement Phase IB of the Remedial Action.

In November 1997, U.S. EPA approved RD documents submitted by the PRPs for Phase II of the O.U. #1 remedy. Phase II is a Groundwater Extraction and Treatment System (GWETS) consisting of extraction wells to capture groundwater from shallow and deep aquifers and a treatment facility that includes filtration, air stripping, metals precipitation, pH adjustment, and treatment of gases before emission. During the period of September 1997 to March 1998, the GWETS (Phase II of the Remedial Action) was constructed.

On May 29, 1996, U.S. EPA approved plans submitted by Site PRPs outlining an approach for the RD of Phase III of the O.U. #1 remedy. On February 18, 1997, after pilot tests were completed, U.S. EPA provided final approval to the PRPs to develop the RD for Phase III; the In-Situ Vapor Extraction (ISVE) system. Phase III consisted of installation of ISVE wells, installation of Air Sparging (AS) points to introduce clean air into contaminated soil, construction of associated ISVE/AS piping and control systems, al1d construction of the main facility where system equipment is housed and where extracted gases are treated before emission. On August 14, 1997, the PRPs awarded a contract for construction of Phase III.

4.2.8 Remedial Action: Phase I of the Site Remedy (Demolition/Excavation)

In September 1995, the PRPs mobilized to implement the USAGE design and Phase IA of the Remedial Action was started. At that time, the PRPs implemented portions of the RD that included: decontamination, demolition, and disposal of all on-site structures, talnks, drums, process equipment and piping, pallets, and miscellaneous debris; dl3molition and crushing of concrete slabs at six building sites and a (former) transfer pump station; replacement of concrete pads with High Density Polyethylene (HDPE) liners at four building sites; disposal of tanks and drums and their contents; asbestos abatement; and installation of a security fence and access road. On April 22, 1996 and April 30, 1996, representatives of the Site PRPs and USAGE performed pre-final Site inspections. Deficient items identified in the pre-final Site inspections were addressed

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by thE~ PRPs prior to a final Site inspection on May 6, 1996. In a letter dated March 8, 2000, U.S. EPA confirmed that all phases of the O.U. #1 remedy achieved Operation and Maintenance (O&M) status.

On or about April 25, 1997, the PRPs mobilized to implement Phase IB of the O.U. #1 remecly. Phase IB of the USACE O.U. #1 Remedial Design (RD) included the following major elements: demolition and crushing of concrete slabs and associated concrete sumps at three buildings; removal of HOPE liners at four buildings; and excavation, treatment and removal for off-site disposal of specific contaminated soils containing inorganics at concentrations that were not protective of groundwater. On April 7, 1998, repre8E~ntatives of the PRPs, U.S. EPA, MDNRE, and USACE performed a pre-final Site inspection. Deficient items identified in the pre-final Site inspections were subsequently addressed by the PRPs. In a letter dated March 8, 2000, U.S. EPA confirmed that all phasE's of the O.U. #1 remedy achieved Operation and Maintenance (O&M) status.

4.2.C Remedial Action: Phase II of the Site Remedy (GWETS System)

Contractors for the PRPs mobilized on September 23, 1997 to begin clearing vegetation after U.S. EPA approved health and safety documents. U.S. EPA provided final approval of all Phase II design documents and drawings on November 18, 1997. Extrac:tion wells. GWETS structures, treatment vessels, piping, pumps, valving, electrical, and control systems were in place by January 1998. At that time, a leak test was performed whereby the GWETS re-circulated clean water with no clean water discharge to Black Creek. From January to October 1998, problems with the GWETS were identified and corrected. In October 1998, the GWETS was again tested and successfully treated contaminated water for a continuous 72-hour test period. From March 22, 1999 to April 22, 1999, the GWETS achieved a successful 30-day continuous treatment operation test period. Since that time, the GWETS has been successfully operating and treating contaminated water.

On April 7, 1998, representatives of the PRPs, U.S. EPA, MDNRE, and USACE performed a pre-final Site inspection. Deficient items identified in the pre-final Site inspections were subsequently addressed by the PRPs. In a letter dated March 8, 2000, U.S. EPA confirmed that all phases of the O.U. #1 remedy achieved Operation and Maintenance (O&M) status.

In November 2000, scientists at the U.S. EPA Robert S. Kerr Environmental Research Laboratory in Ada, Oklahoma (the" Kerr Lab") analyzed Site data to better define the boundary of the groundwater contaminant plume and executed a computer model for groundwater flow to define the effects of the Phase" system. In July 2002, a groundwater "capture zone" analysis of the Phase" system was conducted using the Kerr Lab computer model. This analysis was updated in 2004. To ensure that the PhasE~ II GWETS system continues to provide adequate capture of Site groundwater, this analysis will be reviewed and updated again in 2010 to reflect current Site conditions.

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4.2.0 Remedial Action: Phase III of the Site Remedy (ISVE System)

On March 12, 1996, the PRPs awarded a contract for pilot testing, design, construction and start-up operation of the Phase III (In-Situ Vapor Extraction, or "ISVE") portion of the Site remedy. From June to August 1996, pilot-scale tests were conducted in order to obtain site-specific engineering data to design and build the ISVE system. These tE~sts consisted of small-scale installation and operation of wells through which clean air is introduced into contaminated soil (air sparging, or "AS" wells), and through which the resultant air/vapor mixture is extracted under vacuum (ISVE wells). Locations of pilot­test ISVE and AS wells were selected based on Site soils most impacted by contaminants. Small-scale air production and extracted vapor treatment equipment mounted on mobile trailers was used to produce air for AS wells and for cleaning extractE~d gases before emission.

Design of the ISVE/AS system using pilot test data was started after U.S. EPA approval in February 1997 and was completed in August 1997. In October 1997, construction of the Phase III portion of the remedy commenced. Construction tasks included: drilling and completion of all ISVE and AS wells; installation of all ISVE/AS piping, appurtenances, well vaults and process connections; disposal of any tanks, debris or matenals left behind during previous Phases or tasks; and operation and maintenance of the ISVE/AS system for a startup/shakedown period of one year.

A pre-final inspection occurred on April 7, 1998, whereby incomplete work items were identified. On April 29, 1999, U.S. EPA participated in a final inspection to confirm that these items were completed. All incomplete work items were certified as completed in a final inspection report dated May 29, 1999. The Phase III system was formally put into operation on August 7, 1998. In a letter dated March 8, 2000, U.S. EPA confirmed that all phases of the O.U. #1 remedy achieved Operation and Maintenance (O&M) status.

To improve the contaminant removal effectiveness of the Phase III system (and consequently achievement of cleanup standards), the Site PRP group plans to rE~configure and optimize the ISVE/AS piping in 2010. U.S. EPA and MDNRE will participate in discussions and review/approve the design drawings and specifications for these modifications.

4.2.E Preliminary Close Out Report (PCOR)

On April 22, 1996 and April 30, 1996, pre-final Site inspections were performed for Phase IA of the Site remedy. A final Phase IA Site inspection was performed on May 6, 1996. On April 7, 1998, a pre-final Site inspection for Phase IB of the Site remedy occLlrred at the same time as pre-final Site inspections for Phases II and III. Incomplete work i1:ems were identified for Phases II and III during the 1998 inspections. On April 22, 1999, it was determined that the GWETS (Phase II) had been successfully ooerating and treating contaminated water for 30 days. On April 29, 1999, U.S. EPA participated in a final inspection to confirm that all incomplete work items for Phases II and III were completed. All incomplete work items for Phase III were certified as

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completed in a final inspection report dated May 29, 1999. In a letter dated March 8, 2000, U.S. EPA confirmed that all phases of the O.U. #1 remedy achieved Operation and Maintenance (O&M) status. On September 17, 2002, U.S. EPA issued a Preliminary Close Out Report (PCOR) that documented all construction activity had been completed at the Site.

4.2.F Achievement of Remedy Cleanup Goals

Table 2 compares contaminants found in Site groundwater and cited in the O.U. #1 ROD (as modified by the ESD) against sampling data at one monitoring well and against cleanup standards required by the ROD. Table 3 compares contaminant concentrations in gas extracted from contaminated soil at the time of Phase III start-up in 1999 against sampling results from 2008. Table 4 compares concentrations of contaminants in groundwater going into the GWETS treatment building at the time of s:~art-up in 1998 against sampling results from 2008. Tables 2, 3, and 4 generally show a decline in concentrations of contaminants at the Site. As of the date of this Five Year Review Report, contaminant concentrations across the Site remain above cleanup goals for the remedy, but are generally lower than the concentrations cited in the Record of Decision.

Drinking water wells at 17 private residences to the north and west of the Site are sampled annually for VOCs. Historically, contaminants from the Site that correspond to unacceptable risks have not been a concern at the residential wells closest to the Site. Since 2000 there have been no detections of the contaminants that posed the greatest risk at tile time of the remedy decision at these wells. Figure 5 shows an approximate general outline of the plume of contamination in groundwater attributable to the Site. The closest wells are located on the northern portion of the Black Creek bluff, about 430 feet west of the southwest-flowing plume. Although modeling and well sampling have shown no impact to these residential wells, there was a detection of a contaminant at a very low level in an Arlington Estate production well near the bluff in 2000. Continued monitoring in the flood plain ensures that contaminants do not impact this well. Since 2000, Arlington Estates has been sampling their water production wells for inorganic and biological contaminants and results have shown no unacceptable exceedances of contaminants.

There is a potential issue regarding contamination in the deeper, confined/semi­confined aquifer (see Section 3.1). Although this groundwater is sampled annually at monitoring wells at the Site along Black Creek that have screens at deeper depths, tl"'ere is some uncertainty as to whether contamination at these depths has migrated away from the Site toward the west. Annual laboratory analyses of the Site groundwater at the deep wells at the Site from 2004 to 2008 show no exceedances of cleanvp standards for Volatile Organic Compounds identified as contaminants.

For this five-year review, the potential risk from contaminant vapor intrusion to indoor air was examined. Consistent with U.S. EPA document #EPA 530-0-02-004 entitled "OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from

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Groundwater and Soils (November 2002)," it was determined that currently or potentially inhabited buildings or areas of concern under future development scenarios located near the Site are not in close proximity to subsurface contaminants. Specifically, the closest properties to the Site are about one-quarter mile (approximately 1100 feet) west on Evanston Road at Arlington Estates. Analytical data has shown that no chemicals of suffici·ent volatility and toxicity are present in groundwater at this property. There is no potential for the vapor intrusion pathway to impact either currently inhabited buildings or areas of concern under future development scenarios away from the Site. Therefore, no further evaluation of this pathway is needed. As recommended in document #EPA 530-0-02-004, the vapor intrusion pathway will be re-assessed if Site monitoring data ever suggests the presence of known or interpolated soil gas or groundwater contaminants near any inhabited building within approximately 100 feet (laterally or v,ertically) of the Site or groundwater affected by the Site.

The rE~medy goal is to restore the groundwater aquifer to the cleanup standards shown in Table 2. The remedy has not yet been operating long enough to realize this goal. It is anticipated, based on the contaminant reduction to date, that the remedy goal can eventually be achieved.

4.3 INSTITUTIONAL CONTROLS

Institutional controls (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 (lJU/UE), and are required also to maintain the integrity of the remedy.

The 1991 ROD said that institutional controls would be implemented to restrict future development of the Site to the extent necessary to implement and protect the remedy and to safeguard human health and the environment during implementation of the rE~medy. Use restrictions are needed to prohibit: excavation of soils, unacceptable construction on-site, groundwater extraction (other than that required for the remedy), and any other interference with the remedy. ICs for the Thermo Chem Inc. Site are rE~quired to be protective, effective and in place (as in the form of a restrictive covenant), and in good standing with the integrity of the remedy.

The Thermo Chem and Thomas Solvents properties are privately held by the Thermo Chem Site Trust formed by the Site PRPs. A Warranty Deed was recorded with the Muskegon County Register of Deeds on January 3, 2000, for four parcels that comprise the Site and extend from Evanston Road to Black Creek. Control of the Site is overseen by the PRPs to ensure that there shall be no use of the groundwater, no residential or commercial use of the Site, and no installation or construction of structures, wells, or pipes that will interfere with installed remedy components. Compliance with these restrictions is necessary for the remedy to remain protective of human health and the environment.

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Table 6 and Figure 7 summarize and show the areas of the Thermo Chem Site that currently do not support unlimited use and unrestricted exposure. As part of the ongoing remedy implementation, the PRPs plan to implement ICs, including establishing the legal descriptions of real estate parcels that comprise the Site, delineating the property lines, identifying areas that do not allow unlimited use or unrestricted exposure, and recording enforceable use restrictions.

4.3.A Groundwater Use and Restrictions

Groundwater use restrictions ar~ necessary to prohibit use of the groundwater that may interfeH3 with the remedy. As confirmed by the Site inspection made by U.S. EPA, MDNHE, and the Site PRPs, there is no current groundwater use at the Site; thus, the use restrictions will prevent any potential future on-site groundwater use. The restrictive covenant that will be recorded for the Site property with the Muskegon County Register of DeE~ds will include a declaration that it runs with the land; will prohibit use of the property that may cause exposure to contaminated groundwater that may present a health risk; will prohibit interference with the remedy; and will prohibit residential or commercial property use of the Site. The recorded restrictive covenants must run with the land and be enforceable. According to the Site inspection made by U.S. EPA, MDNRE, and the Site PRPs, the current use of the Site is consistent with such restrictions. If land ownership and/or delineation research shows potential problems with the use of such restrictive covenants or inconsistent prior recorded land interests, other institutional control options will also be considered.

At this point in time, analytical data has shown that no chemicals of sufficient volatility and toxicity are present in groundwater for the vapor intrusion pathway to impact either currently inhabited buildings or areas of concern under future development scenarios away from the Site. Where it is determined that inhabited buildings or areas of concern under future development scenarios are or will be present on property where gmundwater use restrictions are needed, such restrictions shall also prevent activity that could result in a vapor intrusion pathway. The vapor intrusion pathway and ICs will be re-assessed if Site monitoring data ever suggests the presence of known or interpolated soil gas or groundwater at currently inhabited buildings or areas of concern under future development scenarios at and near the Site.

Groundwater underneath the Site property contains contaminants at levels that exceed the cleanup standards shown in Table 2. Any restrictive covenant to be recorded for a pmperty affected by groundwater that is contaminated above cleanup standards will run with the land. If needed, the Site PRP Group will conduct current title searches or obtain title commitments to confirm that there are not any recorded encumbrances that may aI/ow potential uses of the Site inconsistent with the restrictions to be recorded. Procedures such as regular inspection of ICs at the Site, and annual certification that ICs arl9 in place and effective, will be developed. Restrictions for the Site will prevent d,3velopment and use of the Site property and prevent use of groundwater on and near t~le Site property. Such access restrictions for the Site help to prevent development and use of the Site property and prevent use of land and groundwater on and near the Site

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property. The access restrictions to be implemented will also help to assure the integrity of the Site remedy and other components of the remedial action.

As discussed below, an IC Plan will be prepared by the Site PRPs and reviewed and approved by U.S. EPA with consultation by MDNRE. The IC Plan will require various IC activities such as updates on the status of Thermo Chem ICs (provided to U.S. EPA by the Site PRP Group) referenced in monitoring and progress reports for the Site. ICs, updatHd ICs, and future IC analysis memos will be provided by the Site PRPs and reviewed by U.S. EPA Region 5 with consultation by MDNRE.

4.3.8 Land Use Restrictions

The Site is fenced and the gate to the Thermo Chem Site remains locked at all times. Other access is restricted by topography. The gate is checked by contractors hired by the Site PRPs as part of their maintenance and monitoring activity. The IC Plan will discuss obtaining Site boundary maps that outline the Site land and groundwater use restriction boundaries for the Thermo Chem Site. These maps may include global positioning system (GPS) and metes and bounds maps that depict and describe areas where LIse restrictions are appropriate until the Site remedy performance standards are met. A restrictive covenant on the Site property will be implemented and recorded with the Muskegon County Register of Deeds and will run with the land. Restrictions for the Site will prevent development and use of Site real estate for purposes prohibited by State regulations; will prevent use of groundwater within the boundary of the Site property; and will assure the integrity of the Phase II and III systems and other components of the remedial action. The covenants must run with the land and be enforceable. Site PRPs will obtain current title searches or commitments to confirm that there are not any recorded encumbrances that may allow potential uses of the Site inconsistent with the restrictions to be recorded. If land ownership and/or delineation rE!search shows potential problems with the use of such restrictive covenants or inconsistent prior recorded land interests, other institutional control options will also be considered.

Restrictions for the Site will prevent development and use of the Site property and pI-event use of groundwater on and near the Site property. These access restrictions for the Si1e will help to prevent development and use of the Site property and prevent use of land and groundwater on and near the Site property. The access restrictions to be implemented will also help to assure the integrity of the Site remedy.

As discussed below, an IC Plan will be prepared by the Site PRPs and reviewed and appro'lE!d by U.S. EPA with consultation by MDNRE. The IC Plan will require various IC activities such as recording of ICs, and updates on the status of Thermo Chem ICs (provided to U.S. EPA by the Site PRPs) referenced in monitoring and progress reports for the Site. As needed, updated ICs and future IC analysis memos will be provided by the Si1e PRPs and reviewed by U.S. EPA Region 5 with consultation by MDNRE.

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4.3.C Current and Anticipated Institutional Controls

Zoning established by Egelston Township requires that if Thermo Chern Site properties are re-developed, it can only be for industrial use. The properties are currently zoned for industrial use. Groundwater at the Site is not anticipated to reach cleanup standards for many years. Within 6 months of the signing of this Five Year Review Report, the Site PRPs will develop an IC Plan to evaluate the effectiveness of institutional controls, and investigate and identify options for adding ICs on-site and on off-site properties potentially affected by contaminated groundwater. Although residences nearest the Site have been shown not to have unacceptable levels of contaminants in their drinking water, and other residences are connected to a safe drinking water source (the MuskE~~lon County public water system), there is a local ordinance that requires approval from the Muskegon County Department of Public Health for any new drinking water wells in the area. In addition, for the remedy at the Thermo Chern Site, ICs must be re!;.earched and investigated, and a strategy developed for implementation.

ICs for the Thermo Chern Site will need to prohibit activity on, or use of, any part of the real estate that interferes or may interfere with any element of the Remedial Action, including construction and operation and maintenance activities, including soil and groundwater monitoring, or other measures necessary to ensure the effectiveness and integrity of the Remedial Action. The following activities at, and uses of, the Site property will be expressly prohibited: - excavation or other intrusive activity at, on, or under the Site property unless such excavation or other intrusive activity is necessary or appropriate for implementing, performing, or monitoring the Remedial Action; - the drilling or installation of any future groundwater wells on the Site property for drinking water or any other purpose, except for groundwater wells necessary or appropriate to implement, perform, or monitor the Remedial Action; - the use, operation, or expansion of any existing groundwater wells on the Site property or the extraction by any means of groundwater at the Site property for drinking water or any other purpose, unless such use, operation, expansion, or extraction of groundwater is necessary or appropriate to implement, perform, or monitor the Remedial Action; - any construction, installation, or placement of any temporary or permanent structure or improvement on Site property without approval by the Site PRPs and U.S. EPA (with consultation by MDNRE). - disposal of any waste material in, at, on or under the Site property; - any improvements to or alterations at the Site property that would increase the volume or velocity of storm water runoff at or onto the property.

Table 6 summarizes the ICs that will be implemented in order to protect the integrity of the remedy and assure that no inconsistent uses will occur. The proprietary controls will run with the land and be enforceable. Figure 7 shows the approximate IC areas. The Site's boundary is the area that will be covered by restrictive covenants that will be rHcorded with the Muskegon County Register of Deeds as required by the UAO for the Site. Tile restrictions will state that there shall be no use of the groundwater, no rHsidential or commercial use of the Site, and no installation or construction of new

26

structures, wells, or pipes unless approved by U.S. EPA with consultation by MDNRE. Compliance with these restrictions is necessary for the remedy to remain protective of human health and the environment. Site PRPs are currently pursuing the implementation (development and recording) of these types of use restrictions.

4.3.0 Institutional Controls Study and Work Plan

An IC Work Plan is required for the Site and will be developed by the Site PRPs in accordance with the schedule included in this report as Table 9. That IC Work Plan will contain a schedule of regular reviews of ICs implemented and maintained by the Site PRP Group as required by the 1994 Unilateral Administrative Order. In developing the Ie Work Plan, the Site PRPs will review the implementation, maintenance, monitoring and enforcement of Thermo Chem ICs. The IC Work Plan would include consideration of implementing new ICs on the property using the updated model Restrictive Covenant. In recl~nt months, U.S. EPA and the State of Michigan have been working on new model language for restrictive covenants to ensure that the restrictive covenants are enforceable and run with the land under state law. Once language is agreed upon between U.S. EPA and the State of Michigan, the Restrictive Covenants will be presented to the PRPs who will work with the property owners to execute the Restrictive Covenants. The IC Work Plan will discuss obtaining a Site boundary map that outlines the Site land and groundwater use restriction boundaries for the Site. Groundwater use restrictions may include existing or potential new off-site users of groundwater. An annual update on the status of the Thermo Chem ICs will be included with the annual or semi-annual reports for the Site. The report will include compliance information rE~garding implementation of Site ICs. The IC Work Plan, ICs, and future IC analysis memos will be reviewed by attorneys for the PRPs and U.S. EPA Region 5 (with consultation by MDNRE) and will become part of the Thermo Chem Site Administrative Record Restrictions will be appropriately communicated to the public as part of IC implementation.

The Ie Work Plan will contain (at a minimum) an IC Study and strategy to obtain the following information:

- An evaluation of the effectiveness of any current restrictive covenants for the Site and consideration of updating them using the new model as discussed above.

- An evaluation of the effectiveness of the current local ordinance that prevents the installation of groundwater wells in the vicinity of the Site property without prior approval of the Muskegon County Department of Public Health to prevent the use of contaminated groundwater for drinking water purposes.

- An evaluation of current zoning restrictions that may limit the use of groundwater at the Site pmperty and off-site properties potentially affected by groundwater contamination.

- A map identifying: current boundaries of restricted areas associated with the Site (including the Site property boundary), property ownership boundaries, nearby streets,

27

any easements or encumbrances, and assessor's parcel numbers or other recorded plat or survey information.

- Legal descriptions of each property that needs to be restricted, according to current A.merican Land Title Association (ALTA) guidelines.

- Ge09raphic Information System (GIS) coordinates (accuracy of at least 0.01 of a foot) showillg the current boundaries of: restricted areas associated with the Site (including the Site property boundary), property ownership boundaries, any easements or encumbrances, and other recorded plat or survey information. A licensed surveyor will c'9rtify GIS coordinates.

- Draft restrictive covenants, easements, or servitudes in their substantial form, enforceable under the laws of the State of Michigan for the restricted areas.

- A current title insurance commitment in the form of ALTA Commitment Form-1982 (as amended) from a title company, showing title to the restricted areas to be free and clear of all prior liens and encumbrances.

- Copies of encumbrances referenced in any Title Commitments, including the identification of encumbrances that negatively impact restricted areas and copies of requests for subrogation agreements for such encumbrances. Encumbrances will be shown on paper and GIS maps depicting parcel numbers and the areas impacted by the encumbrances.

- If necessary and feasible, a schedule for implementation of the Institutional Controls.

- As noted below, to ensure long-term stewardship, any monitoring plans for the Site and affected areas to ensure that ICs are maintained and remain in place as an amendment to the Operation and Maintenance Plan.

28

Table 6 - Institutional Controls Summary Table Thermo Chern Superfund Site; Muskegon, Michigan

eII~I -M~ed-i-a-,-E-n-g-in-e-e-r-ed~C-o-n-t-ro-l-s-a--n-d-A-r-e-a-s -I i, - - IC

that do not support UUiUE* for Current IC Instrument ImplementedObjective

ii Conditions i I

I I

Thermo Chem Site property (approx. 9.5 acres; includes former Thomas Solvent property).

On-site contaminated soil.

Phase II Remedy system. - Groundwater Extraction Wells. - Underground piping that conveys contaminated groundwater and piping that carries clean treated effluent water. - Groundwater Treatment Building.

Phase III Remedy system. - ISVE and AS underground piping. - CAT-OX equipment and concrete pads. - Distribution Center Buildings AlB/C. - LNAPL Recovery Tank and Concrete Pad. - ISVE/AS Wells.

Groundwater monitoring wells, regular sampling and analysis.

Property ownership: Thermo Chem PRP Group Trust; Chicago IL.

There are no indicators of breaches of areas where remedy components are installed and operating. There is no evidence of exposure.

- Prohibits use of land within the Site property boundary and assures integrity of all remedy components.

- ICs to prohibit the use of contaminated groundwater or soil, and prohibition of any activities that may damage any remedial action component or otherwise impair the effectiveness of any work to be performed.

- Limit well installation on-site to prevent breaches of Phase II and III remedy components located underground.

- Prevent breaches of clean layers installed on top of underground Phase II and III remedy components. Prevent any other activity on-site that could cause erosion, cracking, sliding, or settlement of clean layers installed on top of Phase II and III components located underground.

Planned:

Deed Restriction: Restrictive Covenants to restrict current and future use (to be implemented). These may include an owner's Declaration of Restrictions on Current & Future Uses. Restrictive Covenants may require the owner to:

- restrict uses of the Site property to those uses compatible with the appropriate limited land use categories defined in State of Michigan environmental statutes such as Section 20120a( 1) of Part 201 of NREPA.

- restrict activities that may interfere with response activities, operation and maintenance, monitoring, or other measures necessary to assure the effectiveness and integrity of the remedial action.

- manage surface and subsurface soils in accordance with applicable state and federal laws.

- maintain the Site property fence, with reconfiguration only with approval by U.S. EPA with consultation by MDNRE.

- engineer, construct, and maintain any new structures to prevent volatile emissions from hazardous substances in solid and/or groundwater from entering the structures. All buildings constructed on the Site property after the date of filing of the restrictive covenants shall be constructed as slab on grade and shall not allow for habitable spaces below grade, unless approved by U.S. EPA with consultation by MDNRE.

- monitor and/or manage indoor air, groundwater, and/or the soils underlying buildings to assure compliance with applicable state and federal laws.

- provide adequate notice to U.S. EPA of the Owner's intent to convey any interest in the Site prior to consummating the conveyance. No conveyance of title, an easement, or other interest in the Site property shall be consummated without provision for

29

II

Table 6 - Institutional Controls Summary Table Thermo Chern Superfund Site; Muskegon, Michigan

I~M-e-d-i-a-.-E-n-g-in-e-e-r-e-d-c~o-n-tr-o-Is~a-n-d-A-r-e-a-s-'~~~--~~ i~ - !

that do not support UU/UE* for Current I I IC InsLfument Implemented Conditions Objective

On-site contaminated soil. (continued) compliance with the terms and conditions of the Restrictive Covenants.

- grant the right to U.S. EPA and/or MDNRE and their designated representatives to enter the Site property at reasonable times for the purpose of response activities.

Because the Site property is currently zoned for industrial use, any change in the use of Site property would require an application to Egleston Township and/or Muskegon County. Section 7.0 of Chapter III of the Sanitary Regulations of Muskegon County is enforced by the Board of Health of Muskegon County under the authority of Act 368 of the Public Acts of 1978, as amended. These regulations provide for penalties for their violation and require that no person shall begin construction of a new potable water supply, or make significant change to an existing water supply, without first obtaining a water supply construction permit from the Muskegon County Health Department. The Sanitary Regulations of Muskegon County are attached to this report as Appendix E.

An IC implementation and monitoring plan will be developed within six months to address the long term protectiveness of the remedy and prevent exposure to contaminants.

Thermo Chem Site property (approx. 9.5 - Prohibits use of land within the Site Planned: acres; includes former Thomas Solvent property boundary and assures integrity of property). all remedy components. Deed Restriction: Restrictive Covenants to restrict current and future

use (to be implemented). Restrictive Covenants will require the Groundwater that exceeds - Limit well installation on-site to prevent owner to: groundwater cleanup standards. breaches of Phase II and III remedy

components located underground. - restrict use of the groundwater including prohibition of wells, which Phase II Remedy system. shall not be installed or used by the owner for any purpose on the - Groundwater Extraction Wells. - Limit well installation to prevent Site property, unless approved by U.S. EPA with MDNRE - Underground piping that conveys groundwater use. consultation. contaminated groundwater and piping that - ensure any subsurface activity employs safety precautions to carries clean treated effluent water. - Prevent breaches of clean layers installed prevent unacceptable exposure to hazardous substances in or - Groundwater Treatment Building. on top of underground Phase II and III emanating from groundwater.

remedy components. Prevent any other I activity on-site that could cause erOSion,I _

30

L~ Table 6 - Institutional Controls Summary Table Thermo Chem Superfund Site; Muskegon, Michigan

IMedia, Engineered Controls and Areas IC - I that do not support UUlUE* for Current Objective ! IC Instrument Implemented

1.0 ___I'I ConoOtions I - - -- I

cracking, sliding, or settlement of clean Section 7.0 of Chapter III of the Sanitary Regulations of Muskegon - ISVE and AS underground piping. Phase III Remedy system.

layers installed on top of Phase II and III County is enforced by the Board of Health of Muskegon County - CAT-OX equipment and concrete pads. components located underground. under the authority of Act 368 of the Public Acts of 1978, as - Distribution Center Buildings A, B, C. amended These regulations provide for penalties for their violation - LNAPL Recovery Tank and Concrete - ICs to prohibit the use of contaminated and require that no person shall begin construction of a new potable Pad. groundwater or soil, and prohibition of any water supply, or make significant change to an existing water supply, - ISVE/AS Wells. activities that may damage any remedial without first obtaining a water supply construction permit from the

action component or otherwise impair the Muskegon County Health Department. Groundwater monitoring wells, regular effectiveness of any work to be performed. sampling and analysis.

- Water use restrictions will be implemented Property ownership: with these use restrictions, so that contact Thermo Chem PRP Group Trust; with Site related contamination would be Chicago IL. restricted as a supplement to physical

constraints. There are no indicators of breaches of areas where remedy components are - Prohibits use of untreated off-site installed and operating. The lateral extent groundwater that contains contaminants at of the plume appears to be stable. levels above acceptable cleanup standards. Contaminant levels have been slowly decreasing. There is no evidence of exposure.

...

Thermo Chem Site property (approx. 9.5 - Prohibits use of land within the Site Planned: acres; includes former Thomas Solvent property boundary and assures integrity of property). Black Creek and Black Creek all remedy components. Deed Restriction: Restrictive Covenants to restrict current and future floodplain areas. (approx. 20 acres). use (to be implemented). Restrictive Covenants will require the

- Limit well installation on-site to prevent owner to restrict use of the groundwater including prohibition of wells, Groundwater aquifer that may breaches of Phase II and III remedy which shall not be installed or used for any purpose on the Site potentially discharge into Big Black components located underground. property, unless approved by U.S. EPA with MDNRE consultation. Creek (south end of the Site property).

- Prevent breaches of clean layers installed Section 7.0 of Chapter III of the Sanitary Regulations of Muskegon Phase II Remedy system. on top of underground Phase II and III County is enforced by the Board of Health of Muskegon County - Groundwater Extraction Wells. remedy components. Prevent any other under the authority of Act 368 of the Public Acts of 1978, as - Underground piping that conveys activity on-site that could cause erosion, amended. These regulations provide for penalties for their violation contaminated groundwater and piping that cracking, sliding, or settlement of clean and require that no person shall begin construction of a new potable carries clean treated effluent water. layers installed on top of Phase II and III water supply, or make significant change to an existing water supply, - Groundwater Treatment Building. components located underground. without first obtaining a water supply construction permit from the

, ! Muskegon County Health Department. IIII -

31

11- Table 6 - Institutional Controls Summary Table Thermo Chern Superfund Site; Muskegon, Michigan - ---------jll

II - i~ Media, Engineered Controls and Areas

II rt I II III I E* f r t iC : I'C'InSLrument • Imp emen e t d n II

II that de not suppc. .or .... urren"""''''"','"'"' ObjectiveConditions

Groundwater monitoring wells, regular - ICs to prohibit the use of contaminated sampling and analysis. groundwater or soil, and prohibition of any

activities that may damage any remedial Property ownership: action component or otherwise impair the Thermo Chem PRP Group Trust; effectiveness of any work to be performed. Chicago IL.

- Water use restrictions will be implemented There are no indicators of breaches of with these use restrictions, so that contact areas where remedy components are with Site related contamination would be installed and operating. The lateral extent restricted as a supplement to physical of the plume appears to be stable. constraints. Contaminant levels have been slowly decreasing. There is no evidence of - Prohibits use of untreated off-site exposure. groundwater that contains contaminants at

levels above acceptable cleanup standards. --- . ­

* Unlimited Use / Unlimited Exposure. Maps depicting the current conditions of the Site and areas that do not allow for UUlUE will be developed as part of an IC Plan discussed in Section 4.3.0. A preliminary and approximate map is attached as Figure 7. At this time, initiallC evaluation activities suggest governmental controls have been implemented which, in the area where the Site is located, help to assure the protectiveness of the remedy. However, additional steps must be taken to assure long-term protectiveness. For example, 1) the use restrictions at the Site have not been implemented; and 2) existing ordinances and zoning will be further evaluated to assure long-term protectiveness.

32

!:urrent Compliance: Based on the Site inspection and interviews with on-site personnel, U.S. EPA and MDNRE are not aware of site or media uses which are inconsistent with the stated objectives of the ICs. The remedy appears to be functioning as intended by remedy decision documents .

.!-ong Term Stewardship: Long term protectiveness at the Site requires compliance with use restrictions to assure the remedy continues to function as intended. To assure proper maintenance and monitoring of effective ICs, long term stewardship (L TS) procedures will be reviewed and a plan developed. The plan would include recording and regular inspection of ICs at the Site and annual certification to U.S. EPA that ICs are in place and effective. Additionally, use of a communications plan and use of one­call system may be explored for long term stewardship. The L TS Plan shall be included in the IC Work Plan.

~"4 OPERA TION AND MAINTENANCE (O&M) REQUIREMENTS

4.4.A Phase I of the Site Remedy (Demolition/Excavation)

In a letter dated March 8, 2000, U.S. EPA confirmed that all phases of the Site remedy achieved Operation and Maintenance (O&M) status. O&M requirements for the Phase I work are generally managed within the O&M tasks of Phases II and III. In general, operation and maintenance of Phase I areas consists of confirmation that Site security measures have not been violated, confirmation that soils in Phase I areas have not been disturbed. general Site housekeeping and cleanliness, and confirmation that there is no unacceptable exposures by receptors to contamination remaining on the Site. General Site housekeeping and maintenance is performed within Phase II and Phase I II operation and maintenance tasks. The Site PRP Group or their representatives are present at the Thermo Chem Site at least every 3 months throughout the year. The Site is fenced and the gate to the Thermo Chem Site remains locked at all times. Other access is restricted by topography. The gate is checked by contractors hired by the Site PRPs as part of their maintenance and monitoring activity.

No signs of damage, vandalism, or unauthorized entry were observed during the inspection. Perimeter fencing, gates and locks appeared intact and functional. There was no evidence of unauthorized access to the Site or violation of Site areas where remedy components are present and operating. There was no evidence of any disturbance of any remedy component. In general, the condition of the Site property was ~Iood.

Cluarterly inspections should continue to monitor the condition of the Site and remedy systems. Inspections assess the condition of Phases I, II, and III of the Site remedy.

4.4.8 Phase II of the Site Remedy (GWETS System)

Phase II of the Site remedy is the Groundwater Extraction and Treatment System (GWETS). The GWETS consists of six groundwater extraction wells, groundwater well pumping equipment, valves, meters, and controls, protective housing at each well head, underground piping from each extraction well to the treatment building, and

33

!~roundwater treatment system equipment enclosed in a building. Contaminated !Jroundwater is extracted by the wells and pumped to the Groundwater Treatment 13uilding (GTB), where it is cleaned using a liquid-phase granular activated carbon adsorption (GAC) unit. After treatment, clean water then discharges by gravity flow to Black Creek in compliance with a Substantive Requirements Document (SRD) that is issued and administered by MDNRE.

Groundwater treatment system equipment includes individual flow metering and control devices, pipe header, cartridge filters, carbon filters, storage tanks, and effluent metering devices. In addition, a motor control panel (MCP) and motor control center {MCC) are used to control the influent flow from the groundwater extraction system. This treatment equipment is enclosed in a building that also includes an office area, a bathroom, and a work space.

The GWETS operates at a pumping rate of approximately between 89 and 91 gpm. As noted in the first five-year review for the Site, it was determined that the minimum ~lroundwater extraction rate needed to provide capture is 71 gallons per minute (gpm). Since late 2002, the GWETS has averaged an extraction rate between approximately 80 to 100 gpm.

In a letter dated March 8, 2000, U.S. EPA confirmed that all phases of the Site remedy achieved Operation and Maintenance (O&M) status. O&M requirements for the Phase II work are managed by contractors for the Site PRP Group. In general, operation and maintenance of Phase II of the Site remedy consists of: -. inspection, cleaning, and flushing of process vessels and piping; - repair of process vessels; - sampling of influent and effluent; and - preparation of monthly Discharge Monitoring Reports (DMRs) to certify compliance with the Substantive Requirements Document (SRD).

Hegular inspections monitor the remedy's integrity and allow for operating adjustments as necessary to ensure continued satisfactory operation of the remedy systems. O&M contractors for the Site PRPs monitor the operation of the GWETS systems at least three times per week remotely by telephone lines and physically visit the Site every week. Weekly O&M tasks include a walk through of the Site property and inspection of: the property, fencing and signs, the treatment system, the extraction wells, and the discharge (outfall) to Black Creek. Maintenance issues are identified and samples are collected. In addition, general housekeeping, snow removal, and landscape maintenance is performed.

In November 2000, scientists at the U.S. EPA Robert S. Kerr Environmental Research Laboratory in Ada, Oklahoma (the" Kerr Lab") analyzed Site data to better define the boundary of the groundwater contaminant plume and executed a computer model for nroundwater flow to define the effects of the Phase II system. In July 2002, a woundwater "capture zone" analysis of the Phase II system was conducted using the Kerr I_.ab computer model. This analysis was updated in 2004. To ensure that the Phase II GWETS system continues to provide adequate capture of Site groundwater,

34

this analysis will be reviewed and updated again in 2010 to reflect current Site cond itions.

4.4.C. Phase III of the Site Remedy (ISVE System)

Phase III of the remedy provides continuous removal of residual VOCs in unsaturated zone soils and impacted groundwater using In-Situ Soil Vapor Extraction (ISVE) and Air Spaq~ing (AS) technology. Air is sparged through Site soils and the resulting air/contaminant vapor mixture is extracted, treated, and discharged to the atmosphere in compliance with a Substantive Requirements Document for emissions administered by MDNRE. Phase III was started on August 15, 1998 and consists of 47 SVE wells and EiO AS points positioned in three separate treatment zones as follows: - Zone A (17 SVE wells and 20 AS points). - Zone B (20 SVE wells and 27 AS points). - Zone C (10 SVE wells and 13 AS Points).

During the ISVE/AS pilot test activity in 1996, a light non-aqueous phase liquid (LNAPL) was identified in Zone A and a vacuum enhanced LNAPL skimming system was installed. A pneumatic skimmer pump operating on an adjustable, timed cycle was installed in each ISVE well. LNAPL material was pumped through underground piping to a L~.OOO gallon aboveground storage tank immediately adjacent to the ISVE air distribution building, or "Building A" In September 2004, it was determined that the LNAPL source at the groundwater interface was removed by the skimmer system, and operation of the skimmer system was discontinued.

The Phase III system was designed to treat gases extracted from Site soils using a catalytic oxidation unit (CAT-OX) or a vapor phase granulated activated carbon unit (VPGAC) before release to the atmosphere. By November 2004, Phase III had effectively removed a large portion of contaminants. Because the concentrations of remnant contaminants were low enough, it was decided that operation of the CAT-OX unit could be discontinued. Representatives of the Site PRPs worked with the MDNRE to ensure continued compliance with air emission limits.

Hemoval of the LNAPL contamination reduced the concentrations of contaminants in the extracted air/contaminant vapor gases. This has allowed the Phase III system to be operated on a pulsed, cycle mode since April 2005. The extraction flow rates for the components of the Phase III system are:

Zone fl.: between approximately 600 and 700 cubic feet per minute Zone B: between approximately 1000 and 1100 cubic feet per minute. Zone C: between approximately 400 and 500 cubic feet per minute.

In a letter dated March 8, 2000, U.S. EPA confirmed that all phases of the Site remedy achieved Operation and Maintenance (O&M) status. O&M requirements for the Phase II work are managed by contractors for the Site PRP Group. In general, operation and maintenance of Phase II of the Site remedy consists of:

35

.. inspection of process vessels and piping;

.. repair of process vessels;

.. emptying of the condensate sump for the air compressor;

.. sampling of influent and effluent; and

.. preparation of reports to certify compliance with the Substantive Requirements Document (SRD).

Quarterly inspections ensure regular monitoring of the remedy's integrity and allow for operating adjustments as necessary to ensure continued satisfactory operation of the remedy systems. O&M contractors for the Site PRPs make quarterly visits to the Site to: ch€~ck systems' status, perform minor repairs, and identify any repairs that may be more significant. Prior to 2005, O&M activities were conducted more frequently to addmss system start-up problems and refine the operating parameters. Maintenance activities conducted on the Phase III system are generally minor and infrequent. Cleaning of the air sparge and ISVE well screens and piping has not been necessary since start-up of the system. In addition, general housekeeping, snow removal, and landscape maintenance is performed in concert and consistent with Phase II O&M work. Since 2005, there have been no major instances of vandalism or weather-related damage to the Phase III system other than electrical service interruptions due to storm Hvents.

To improve the contaminant removal effectiveness of the Phase III system (and consequently the achievement of cleanup standards), the Site PRP group plans to reconfigure and optimize the ISVE/AS piping in 2010. U.S. EPA and MDNRE will participate in discussions and review/approve the design drawings and specifications for these modifications.

4.4.0 Long-Term Ground Water Monitoring

Since 2004, groundwater monitoring has been performed on an annual basis at the Site. Quality assurance procedures are closely followed during annual groundwater sampling events. Groundwater levels are measured across the Site for mapping of wound water flow and determination of the effectiveness of the groundwater extraction wells. Annual groundwater monitoring typically occurs near the end of the calendar year. For this Five Year Review Report, data generated at the time of the 1991 ROD, during the design of the Site remedy, and over the past five years were reviewed.

Since 2005, monitoring wells have been sampled using the passive diffusion bag (PDB) method due to the difficult topography at the Site along Black Creek and cost E~ffectiveness. Passive diffusion bag sampling uses semi-permeable membrane technology to gather contaminants from water. The PDB sampler is an equilibrium sampler that contains reagent-grade organic-free water in a semi-permeable membrane. The sampler is placed inside the well in contact with contaminated water and contaminants diffuse across the semi-permeable membrane into the reagent-grade organiG-free water. After a few weeks the bag is retrieved and the water inside constitutes the sample that is analyzed.

36

u.s. EPA (with consultation by MDNRE) is currently reviewing the validity of data collected using the PDB method. A potential problem may be whether PDB sampling provides groundwater samples that are representative of the water moving in the aquifer, in the contaminant plume, or in the target zone where contaminants are expec1ed to be located (or are migrating). Another potential problem is whether PDB !~rounclwater samples represent accurate contaminant concentrations, including dissolved and naturally suspended particles. Sample collection using PDBs may be representative of stagnant water in monitor well casings, which may not be truly representative of the groundwater. U.S. EPA is reviewing the POB method against sampling methodologies that may better account for the effects of aquifer heterogeneities while minimizing alterations in water chemistry that could result from sampling disturbances. Another potential problem with POB sampling is the presence of non-aqueous phase liquids at the Site. These substances may be stratified in the monitoring well and the POB method may not provide representative samples. I n thE~ event POB sampling is not acceptable, it may need to be replaced by purging methods designed to minimize drawdown by controlling the flow from the well while monitoring stabilization indicator parameters (commonly referred to as low-flow methods). Alternatively, it may be possible to provide an equivalency demonstration whereby the use of POBs can be shown to provide samples that are as representative of aquifer conditions as samples collected using low-flow methodologies.

In addition, U.S. EPA (with consultation by MONRE) is currently reviewing the monitoring programs for the Site for adequacy of other parameters such as inorganic contaminants and field parameters such as dissolved oxygen, oxidation/reduction potential, conductivity, temperature, pH, and turbidity.

4.4.E Remedy Costs

The 1991 Record of Decision estimated the cost for the Site remedy as approximately $24,000,000 net present worth. This amount covered all three phases of the Site remedy and included a present worth allowance of approximately $1,091,000 in annual O&M cost. Design documents for the Site remedy revised and updated estimates of implementation costs. The 1994 ESD increased the estimated cost for the Site remedy to approximately $60,500,000 (comprised of $41,300,000 capital cost and $19,200,000 present worth costs of operation and maintenance) without modification to the ROD. All phases of the Site remedy were included in these estimates.

Based on the U. S. EPA modifications to provide a more protective remedy, the 1994 cost (3stimate in the ESO was reduced to $43,700,000. The estimated present worth of Phase I of the Site remedy (including both IA and IB) was approximately $8,500,000. The E~stimate in the Remedial Design of the present worth of Phase II of the Site remedy was approximately $33,210,000, which included the present worth for annual O&M. The Hstimate in the Remedial Design of the present worth of Phase III of the Site remedy was approximately $1,954,000, which included the present worth for annual O&M.

37

Actual capital costs for all three Phases of the Site remedy are expected to be lower than the design estimates by approximately 40 to 60 percent. The remedial cost was reduced further by the Site PRP Group after modification of the design with U. S. EPA's approval. Operation and maintenance tasks for Phase I of the Site remedy are handled as part of the O&M for Phases II and III. The annual cost range for operation and maintenance of Phase II of the Site remedy averaged over the years 2004 to 2009 is approximately $250,000 to $400,000. This average cost includes the types of maintenance and repair tasks summarized in Table 5A as well as sampling and analysis to assess GWETS operation and assess overall Site groundwater quality. The annual cost range for operation and maintenance of Phase III of the Site remedy averaged over the years 2004 to 2009 is approximately $125,000 to $175,000. This average cost includes the types of maintenance and repair tasks summarized in Table 58 as well as air sampling and analysis to assess the operational effectiveness of the system.

5.0 PROGRESS SINCE THE LAST FIVE-YEAR REVIEW

This is the second five-year review for this Site. On May 10, 2005, U.S. EPA Region 5 completed the first five-year review. That five-year review indicated that the remedy had achieved O&M status on March 8, 2000, and noted that:

"Results of the monitoring data, although not conclusive, indicate progress toward achieving groundwater clean-up goals."

Also, the 2005 Five Year Review Report noted:

"Data also suggests that the residual contamination in the wetlands, down gradient of the GWETS, is being reduced by natural processes."

The 2005 Five Year Review Report for the Thermo Chem Site certified that:

"The remedy is currently protective of human health and the environment, and was constructed in accordance with the ROD and ESD. The remedial actions have eliminated human contact and exposure. However, in order for the remedy to be protective in the long-term, groundwater must be restored to clean-up standards."

The 2005 Five Year Review Report identified issues within the report text and not in table format. For this second Five Year Review Report, 2005 issues have been paraphrased and summarized in Table 7.

38

TABLE 7 -ISSUES IDENTIFIED IN 2005 (FIRST) FIVE-YEAR REVIEW Issues fron , Previous Recommendationsl Responsible Milestone Action Taken (YIN) and Date of ReviE!W Follow-up Actions Organization Date Outcome Action

Upper aqu ifer - Improved preventative Thermo None Yes Oct. 1999. extraGtion <3nd maintenance of the identified.Chem Site GWETS screens and treatrnent ~;ystem pumps. PRP Group pumps, and pipes are continued (GWETS) Ilot capturing - Periodic flushing of the cleaned and repaired as noted in the plume. extraction pumps and as needed. Table SA.

process lines.

- Continued hydraulic No and chemical sampling to Sampling since 2004 monitor GWETS occurs annually with no effectiveness, including quarterly evaluations or quarterly evaluations and analyses. interpretation of observed water levels, analysis of groundwater flow directions and rates, and update of the groundwater computer Yes model. Extraction rate is at or Oct. 2002

above the volumetric - Adjust extraction rates flow rate required by as required to maintain U.S. EPA's 2004 capture of the groundwater capture contamination plume. computer model.

Residual c( mtamination This observation needs None YesThermo March in wetlands down identified. Sampling since 2004 2002, and gradiEmt of the GWETS

to be supported by Chem Site occurs annually. annually.

is being red uced by continued hydraulic and PRP Group chemical monitoring.

natural pro( ;esses.

There is some concern Install an additional Thermo None Yes March (based on t he distance monitoring well cluster in identified. Mon. Well Clusters Chem Site 2002 between th.:>_ monitoring the Black Creek PRP Group OU2-MW-1 through wells in the wetlands) floodplain and add it to OU2-MW-4 were

. that the lea ::ling edge of the monitoring program installed in the Creek : the wetland s plume to improve the monitoring floodplain including may not be adequately at the down gradient VAS sampling with monitored. western edge of the GeoProbe equipment.

Black Creek floodplain All contaminants of plume. concern were below

analytical detection levels for the VAS phase of the well installation.

I Monitoring ::lata NoneHydraulic and chemical Thermo Yes March , collected dlJring 1998 monitoring at the Site will Chem Site identified. Sampling since 2004 2002, and and 1999 s 3rnpling continue in both the PRP Group occurs annually. annually events and during upper and lower aquifers supplement:al studies until the groundwater

j by EPA KE ~R lab meets the clean up

39

TABLE 7 - ISSUES IDENTIFIED IN 2005 (FIRST) FIVE-YEAR REVIEW -

Issues from Previous Responsible Milestone Action Taken (YIN) and Date of ReviEw

Recom mendationsl Organization DateFollow-up Actions Outcome Action

perscnnel from Ada, standards shown in OK indicatE! that there Table 1 throughout the may be deE~p aquifer plume. (Table 1 of the contamination which is 2005 Five Year Review not bt:ing captured by Report). the GWETS.

The monitoring schedule for the lower aquifer may be revised downward if the results of chemical monitoring in the lower aquifer indicates that the VOC content is below risk based values. -.

TherE! are residential None identified. Thermo None Yes 2004, and wells in the vicinity of Chem Site identified. Sampling since 2004 annually. the Site that have the PRP Group occurs annually. potential of being impacted by the plume, No Ongoing. which are only being Monitoring Program is Review

I monitored tor VaGs on Under Review Will Be an annual basis. Complete I

in 2010.

i In the past, sampling U.S. EPA requested the Thermo None Ongoing. I has been conducted PRPs to initiate Low- Chem Site identified. Sampling Method Review

with bailers, and Flow sampling for all PRP Group Under Review Will Be laboratory detection •. Complete limits set above typical

future sampling and establish laboratory I in 2010. I

trace contaminant detection limits to detect levels. This was done trace contaminants, to characterize total namely vinyl chloride, Detection Limits For 2004, VOC sample content, Trace Contaminants TCE and benzene. and rather than trace Have Been Re-Set annually. chemical content.

Monitoring data will be U.S. EPA None No. Ongoing. capturing the plume.

I GWETS may not be Identified. Not Completed.

when data becomes statistically analyzed

Thermo Historical monitoring Residual contamination Chem Site available to show the data was being in wellands down PRP Group progress I lack of consolidated as a gradiemt of the GWETS. progress toward starting point for this

I Igroundwater clean-up analysis. goals.

I Deep aquift:r In order to insure that the In Process. To Be I contamination may not GWETS continues to The groundwater Completed

operate as designed ... extraction and capture Before GWETS.

I be captured by the more monitoring wells analysis of 2004 will be 2015. and additional remedial reviewed and updated.

II The I".ding edge of the activity will be considered I wetlands plume may if the results from a ; not be adequately Istatistical evaluation at

40

TABLE 7 - ISSUES IDENTIFIED IN 2005 (FIRST) FIVE-YEAR REVIEW --

Issues fron Revie~w

1 Previous Recommendationsl Follow-up Actions

Responsible Organization

Milestone Date

Action Taken (YIN) and Outcome

Date of Action

monilored. any monitoring well downgradient of the GWETS does not indicate a "Significant better" or "Significantly Decreasing Trend".

I nstitutiona were part c ROD reme, unknown if controls an binding.

I controls f the 1991 j),. It is these ~ legally

An evaluation of the status of ICs at the Site needs to be conducted. This analysis, complete with recommendations to guide future IC activity if required, will be conducted by EPA and completed by the end of the 2005 fiscal year.

Thermo Chem Site PRP Group

12/2005 No In Process

Ongoing.

Ii. 0 FIVE-YEAR REVIEW PROCESS

Ii. 1 Administrative Components

The U.S. EPA is the lead agency for this five-year review. The support agency is the MDNRE. Representatives of the Site PRPs were notified in late 2009 of the start of the five-year review. The Thermo Chem Superfund Site second Five Year Review Report was prepared by John V. Fagiolo, Remedial Project Manager with the U.S. EPA Region ~) SupE!rfund Division. Walelign Wagaw, Project Manager for the Michigan Department of Natural Resources and Environment also assisted in the review. The five-year review consisted of a Site inspection and review of relevant documents. The completed report will be made available in the Site information repository for public view.

6.2 Community Notification and Involvement

A notice was published in the Muskegon Chronicle on March 23, 2010, stating that a five-year review was being conducted. The notice invited the public to submit comments to the U.S. EPA by April 26, 2010. No comments from the community were received by the U.S. EPA. The results of the review and this Five-Year Review Report will be placed in the Site repository located at the Hackley Library, 316 W. Webster Street, the Egelston Township Hall, 5382 E. Apple Ave., and in the Superfund Records CentE~r at the U.S. EPA Region 5 Office located at 77 W. Jackson Street, Chicago, Illinois 60604. A copy of the published notice can be found as Appendix B.

Ei.3 Document Review

The list of the documents that were reviewed for this five-year review can be found as J\ppencJix A.

41

16.4 Data Review

An annual groundwater sampling program has been implemented at the Site since :2004. Representatives of the Site PRP Group performed quality assurance (QA) procE~clures during each of the sampling events since 2004. Annual reports since 2005 were reviewed and each year's data compared against historical sampling data collected at the Site since 1991. Table 2 compares contaminants found in Site qroundwater and cited in the O.U. #1 ROD (as modified by the ESD) against sampling data at one monitoring well and against cleanup standards required by the ROD. The data review that was performed for the Site confirmed in general that there has been a decline in concentrations of contaminants at the Site since the last five-year review and since the ROD in 1991. Contaminant concentrations documented in the annual reports from 2004 through 2008 are generally similar. A comprehensive data comparison across the Site was not performed for this five-year review because contaminant concentrations at the Site still remain at high enough levels to prevent unlimited use or unlimited exposure. It has been generally concluded at this time that cessation of Site remedy operation is not likely before the next five-year review.

Long-term maintenance and regular inspection of the Site remedy is required and is implemented to ensure that the remedy remains effective, and ensures containment and removal of Site contaminants. The operation and maintenance monitoring program that is implemented at the Thermo Chem Site allows assessment of the operational effectiveness of the Phase II and Phase III systems. Contractors for the Site PRP Group report on the weekly, monthly, quarterly, and annual inspections and O&M monitoring activities. These reports indicate no major malfunctions or disrepair over the past 5 years of operations. Contaminants continue to be removed each year by both the Phase II and Phase III portions of the Site remedy. Levels of organic contaminants E~ntering the treatment portions of the GWETS (Phase II) and the ISVE (Phase III) systems have decreased as shown in Tables 3 and 4.

In general and according to available data, the area of contamination at the Site appears to not have increased in lateral extent or depth over the past 5 years. Contaminant concentrations at regular sampling locations remain stable or are (iecreasing, but levels of some contaminants are still present at unacceptable levels at and near the Site.

6.4.A Wells Sampled and Annual Monitoring Data

\Nells sampled during the annual monitoring events are shown in the following list:

~)ite V~lIs

TCMW··3S TCMW-3M TCMW-4S TCMW-4M TCMW-10S TCM\lV··10M TCMW-11S TCMW-11M TCMW-12S TCMW-12M TCMW··13S TCMW-13M TCMW-14S TCMW-14M TCMW-15S TCMW··15M TCMW-151 TCMW-16S TCMW-161 TCMW-17S TCMW··17M TCMW-171 TCMW-17IR TCMW-18S TCMW-18M TCMW··181 TCMW-19M TCMW-191 TCMW-20S TCMW-201

42

;Site 'vyells TCMW-21S TCMW-21I TCMW-24 MW-22 MW-23 IVIW-~~5 MW-26 MW-27 MW-28 MW-29 IVIW-30 MW-31 MW-32 MW-33

peep_~ells

TCMW-11D TCMW-12D TCMW-13D TCMW-14D TCMW-1SD TCMW-16D TCMW-17D

Northern Transect Wells GMMW-1A,B,C GMMW-2A,B,C GMMW-3A,B,C,D GMMW-4A,B,C,D GMMW-SA,B,C,D GMMW-6A,B,C,D GMMW-7A,B,C,D GMMW-8A,B,C,D GMMW-9A, B, C, 0

J31ack Creek Monitoring Wells OU2-MW-1S OU2-MW-1M OU2-MW-11 OU2-MW-2S OU2-MW-2M OU2-MW-21 OU2-MW-3S OU2-MW-3M OU2-MW-31 OU2-MW-4S OU2-MW-4M OU2-MW-41 EL-202 IL-202A IL-202B PVAS99-1 PVAS99-2 PVAS99-3 PVAS99-4 OU2-MW-SS OU2-MW-SM OU2-MW-SI

~3roundwater Extraction Wells and Piezometers EW-1 EW-2 EW-3 EW-4 EW-S EW-6 PZ-1 PZ-2 PZ-3 PZ-4 PZ-S PZ-6 PZ-7 PZ-8 PZ-9

'Neils are installed at four: shallow (S), medium (M), intermediate (I), and deep (0). Groundwater data is examined on an annual basis for persistent contaminants to ensure that no unacceptable migration is occurring. In general, the concentration levels of the contaminants in these wells have not significantly increased since the last five­year review. Result of annual groundwater reports since 2004 show decreasing or ~lenerally stable concentrations of contaminants. The reduction of organic contaminants in groundwater and at the ISVE treatment building supports the expectation that the Phase II and Phase III systems are pulling out contaminants.

6.4.8 Private Wells Data

Three properties immediately to the west of the Site are sampled for VOCs by the Site PRP Group as part of the annual groundwater sampling program. The private wells sampled are located on three properties immediately west of the Site. MDNRE and the local health department also sample 17 nearby residential wells for VOCs. The results from 2006, 2007, and 2008 show no detections of the contaminants that posed the weatest risk at the time of the remedy decision.

SinCE! 2000, Arlington Estates (located approximately 1100 feet to the west of the Thermo Chem Site property) has been sampling their water production wells for inorganic and biological contaminants. These analyses have shown that there are no unacceptable contaminants in well water.

43

For the deeper, confined/semi-confined aquifer noted in Section 4.2.F, MDNRE sampled ten (10) residences to the west of the Site in 2009. There were no detections of the contaminants that posed the greatest risk at the time of the remedy decision. Also, analyses of the Site groundwater in the deep wells at the Site from 2004 to 2008 show no exceedances of cleanup standards for those Volatile Organic Compounds identified as contaminants.

6.4.C Phase II (GWETS) Operational and Hydraulic Data

Reports on operation, maintenance, and repair of the Phase II (GWETS) system from .2004 to 2009 were reviewed. There were no catastrophic fault or disrepair events noted. Table 5A summarizes some of the maintenance and repair events since 2004. No unacceptable violations of the SRD permit occurred during this time. The GWETS operates at a pumping rate of approximately between 89 and 91 gpm. As noted in the "first five-year review for the Site, it was determined that the minimum groundwater ,extraction rate needed to provide capture is 71 gallons per minute (gpm). Operational documents from 2004 to the present have been reviewed and confirm that the GWETS has averaged an extraction rate between approximately 80 to 100 gpm. Recent maintenance activity has increased this rate to approximately 110 to 115 gpm. Results of watl3r sampling at the GWETS influent show decreasing or generally stable Goncentrations of contaminants.

6.4.0 Phase III (ISVE) System Operational Data

Reports on operation, maintenance, and repair of the Phase II (GWETS) system from 2004 to 2009 were reviewed. There were no catastrophic fault or disrepair events noted. Table 5B summarizes some of the maintenance and repair events since 2004. No unacceptable violations of the SRD permit for air emissions occurred during this time. Operational documents from 2004 to the present have been reviewed and confirm that the Phase III system has reduced the concentrations of contaminants in soil at the Site.

6.5 Site Inspection

A Site inspection for this five-year review was completed on April 21,2010 by U.S. EPA, MDNRE, and contractors representing the Site PRP Group (ARCADIS, Kerrigan Associates, and Conestoga-Rovers and Associates). Site access is available through a locked gate which encloses the Site landfill and the treatment building. The five-year review Site inspection checklist was used as a guideline for the Thermo Chem Site inspection. Each topic in the checklist was reviewed verbally with opportunities for comments or concerns from the other parties in attendance. The overall Site property, areas where underground remedy components are installed, all extraction well heads and houses, interiors and exteriors of all Phase II and Phase III buildings, and the Black Creel< area were visually inspected. The Site perimeter (fence line) was also visually inspected. Contractors representing the Site PRP Group were present to clarify any issues identified by the Agencies. During the Site walk-through, there was a review of the five-year review process with the PRPs' contractors and MDNRE by the U.S. EPA.

44

The Site was found to be in good condition during the inspection with no evidence of breaches of the remedy systems in place. The Site showed no signs of any vandalism or other disturbances. There were no breaches of clean layers installed on top of under~lround Phase II and III remedy components and no erosion, cracking, sliding, or settlement of clean layers installed on top of Phase II and II I components located under~lround. The access fence was properly in place, with the Phase II and Phase III SyStE!/TIS operating properly. All Site areas were clean and free of debris. All extraction and monitoring well locations appeared intact, including vehicular barriers and padlocks.

The completed Site Inspection Checklist is included as Appendix C. Issues discovered during the five-year review inspection are included in Section 8.0 of this report.

15.6 Interviews

I~rom '1991 through 1999, during the remedy decision, design, and construction activity of the remedy, the community surrounding the Site was given adequate opportunity to provide input into development of the remedy and express any concerns or questions about the Site. Since the achievement of construction completion in 2002, there have been no major problems communicated to the regulatory agencies by the community and the need has not arisen for any community involvement events. Consistent with U.S. EPA Document # EPA 540-R-01-007: Comprehensive Five- Year Review Guidance fdated June 2001), because there were no problems communicated to the regulatory agencies since the first five-year review, it was determined that no formal interviews with the community were necessary for this five-year review.

For this five-year review, informal interviews and communications between the agencies and the PRPs took place starting in September 2009. As stated above in Section 6.5, all attendees at the Site inspection were free to comment or raise concerns throughout the five-year checklist review and during the Site walk-over. Communication has been maintained between the Site PRP Group, U.S. EPA, and MDNRE. Electronic mail communication pertinent to the five-year review between U.S. EPA and the Site PRP Group occurred from September 2009 until April 2010, prior to the Site inspection.

"l.O TECHNICAL ASSESSMENT

7.1 Question A: Is The Remedy Functioning As Intended By The Decision Documents? No.

gemBdial Action Performance: The review of documents, ARARs, risk assumptions, and the results of the Site inspection indicate that Phase II and Phase III of the Site remedy are operating as intended by the ROD (as modified by the ESDs), but ICs are not in place and cleanup standards have not been achieved.

~)ystem Operations/O&M: Based on regular inspections and monitoring performed to date at the Site, the remedy systems in place are functioning as intended by the ROD and other decision documents. When small problems arise the problems are identified durin!~ weekly inspections and corrected in a timely manner. No catastrophic events

45

have been documented since the last five-year review. No significant problems were observed with the Site remedy. As a result, except for the planned Phase III modifications to expedite Site cleanup, no significant future modifications are I-ecornmended at this time for the remedy systems in place.

!:ost of System Operations/O&M: As discussed in Section 4.4.E, the current annual O&M cost for Phase II is approximately $180,000 to $400,000, averaged over the years :2004 to 2009. The annual cost range for O&M of Phase III of the Site remedy averaged over the years 2004 to 2009 is approximately $70,000 to $120,000. Operation and maintenance tasks for Phase I of the Site remedy are handled as part of the O&M for Phases II and III.

!~Irtunities for Optimization: As part of this five-year review, opportunities for optimization have been assessed by U.S. EPA. As noted in Section 4.2.0, the Site PRP group plans to reconfigure and expand the ISVE/AS piping in 2010 to improve the contaminant removal effectiveness of the Phase III system, and consequently the achievement of cleanup standards. U.S. EPA and MDNRE will participate in discussions, review, and approval of design drawings and specifications for these mod ifications.

Other than the Phase III modification, there were no opportunities for system optimization identified during this review. The continued presence of contaminants precludes any reduction of Site sampling frequency or locations at this time. Opportunities for optimization will be re-assessed no later than the next five-year review in 20'15,

I=arly Indicators of Potential Remedy Failure: No early indicators of potential remedy failure were noted during this five-year review. Maintenance activities have been consistent with expectations and current Site work by the Site PRP Group is proceeding consistent with the land use restrictions expected to be implemented for this Site.

Implementation of Institutional Controls and Other Measures: No formal legal use restrictions have been implemented at the Site as of the date of this Five Year Review Heport. Discussions between interested parties continue and any decisions and implementation will be made by the next Five Year Review Report to be issued in 2015. The 1991 ROD requires implementation of deed/access restrictions and/or other Institutional Controls to prevent future development of the Site and to assure the ir"ltegrity of the remedial action. In order for the remedy to remain protective in the long term, les that prevent disturbance of remedy systems in place or the clean layers on top of underground Phase /I and III remedy components must be put in place. An IC implementation and monitoring plan will be developed within six months to address the long term protectiveness of the remedy and prevent exposure to existing contaminant 113vels.

Site access is restricted preventing disturbance of Phase II and Phase III remedy components or any other activities or actions that might interfere with the implemented remedy. Security fencing with locked gates and posted signs is intact and entrance is

46

prohibited. No evidence was observed that suggested any violation of Site security measures. Weekly activity and personnel at the Site prevent unauthorized access. Residential development on this Site is prohibited without a change in zoning and is not consistent with current or projected land use patterns. Site property has been zoned as 'industrial" by Egleston Township and any change in the use of the parcels within the Site boundary requires a specific application .

. Long-Term Monitoring: The Site PRP Group has performed annual long-term monitoring of the Site and private wells since 2004. In general and according to available data, the area of contamination at the Site appears not to have increased in lateral extent or depth over the past 5 years. Contaminant concentrations at regular sampling locations remain stable or are decreasing, but levels of some contaminants are still present at unacceptable levels at and near the Site.

~:;urrent Use Compatibility with Land and Groundwater Use Restriction: As noted in Section 4.3, ICs have not been implemented at the Site. The Site inspection confirmed that the current land use is compliant with anticipated land and groundwater use restrictions, and weekly inspections by contractors for the Site PRP Group help to t3nSure that there are no unacceptable uses of the Site property or outside interference with remedy components or operation. Land use on adjacent parcels does not impact the Site remedy. The property is currently zoned for industrial use, but State of Michigan soil cleanup standards for a future industrial use scenario have not yet been achieved. Because of the completed remediation work and weekly inspections, trespassers would not be subjected to any unacceptable acute exposure. Contractor personnel visit the Site weekly, discouraging trespass on the Thermo Chem Site and thereby reducing the opportunities for improper dumping, vandalism, illegal residency, or even the installation of wells.

7.2 Question B: Are the Exposure Assumptions, Toxicity Data, Cleanup Levels, and Remedial Action Objectives (RAOs) Used at the Time of Remedy Selection Still Valid? Yes.

There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy.

!~han9.es in Standards and To-Be-Considereds (TBCs): As remedial work has been completed and O&M work continues, most ARARs for groundwater cited in the ROD and [80s have been met. There have been no changes in most ARARs and except for three contaminants, no new standards or TBCs affecting the protectiveness of the reme,jy since the last five-year review in 2005.

As nob3d in Table 2, cleanup standards for groundwater are the most restrictive of the following: National Primary Drinking Water Regulations as of May 31,2001 (MCLs); MDECl Part 201, Act 451, Health Based Residential Drinking Water Standards as of ~'une 7. 2000; or the Part 31, Act 451, Water Quality Values established under Rule R ~~23.1 057 as of June 10, 2002. A more stringent standard for arsenic in groundwater mandated by U.S. EPA became effective in 2006. The revised standard lowered the limit from 50 parts per billion (ppb) to 10 ppb. The current, most stringent Part 201

47

drinking water standards for chloroform and 1,1-dichloroethane are 80 and 740 ppb, respectively.

These changes in cleanup standard affect only the long-term protectiveness of the reme,dy, relative to the demonstration of permanent achievement of cleanup goals. High concentrations of other contaminants in groundwater indicate that it is still necessary to operate the remedy for an indefinite period. Because the GWETS provides capture of groundwater and pollutants (including arsenic and other contaminants), the constructed remedy remains protective in the short term.

~:hanges in Exposure Pathways, Toxicity, and Other Contaminant Characteristics: Neither the toxicity factors for the contaminants of concern nor other contaminant characteristics have changed in a way that could affect the protectiveness of the I'emedy. The exposure assumptions used to develop the Human Health Risk Assessment included both current exposures and potential future exposures for the I-ecreational (child and adult), residential (child and adult), and occupational (adult only) populations. There have been no changes in the toxicity factors for the contaminants of COnCl91"n that could affect the protectiveness of the remedy. These assumptions are considered to be conservative and reasonable in evaluating risk, and no changes are warranted. Institutional controls such as Site access control, Site security, and deed and land use restrictions will ensure that exposure pathways at the Site will remain protective of human health and the environment.

~:;han.ges in Risk Assessment Methods: There has been no change to the standardized risk assessment methodology that could affect the protectiveness of the remedy.

J=xpected Progress Towards Meeting RAOs: The Record of Decision generally Hstimates the total remedy time period needed to achieve cleanup goals as 30 years. A more precise estimate of the time needed for achievement of cleanup standards has not been estimated.

This remedy has the following remedial objectives: reduce or minimize direct human and environmental contact with contaminated soil through inhalation and ingestion; reduce or minimize the release of contaminants in soil and sludge to the groundwater; restore groundwater so that contamination levels meet appropriate health standards; and stop the flow of contaminated groundwater to Black Creek. Remedial Actions have been implemented at the Site: to capture contaminated groundwater before it reaches Black Creek; to reduce contamination in groundwater until the Drinking Water Standards listed in Table 2 are achieved; to reduce contamination at the Site until a cumulative excess cancer risk below 10-4 is achieved; and to reduce contamination at the Site until a cumulative Hazard Index below one is achieved. Further, restrictions on use of the Site property and use of contaminated groundwater will be implemented and maintained until health-based cleanup goals have been met. Appropriate quality assurance and quality control was performed during all phases of remedy construction and monitoring. Throughout the activity for all phases of the Site remedy, the parties have monitored contaminated media.

48

7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? No.

Tecr!..oicai Assessment Summary: Except for Institutional Controls and achievement of cleanup standards, according to the data reviewed and the Site inspection, the Site remedy is substantially functioning as intended by the 1991 ROD (as modified by the 1994 and 2002 ESDs) and the 1994 Unilateral Administrative Order for RDfRA. There have been no changes in the physical conditions at the Site, standards, contaminant toxicity or exposure pathways that would affect the protectiveness of the remedy. There is no additional information that has been identified that would call into question the protectiveness of the remedy selected for this Site .

.As indicated in the ROD, the Baseline Risk Assessment conducted during the RifFS documents that releases of hazardous substances from the Site, if not addressed by the reme!dy. present an imminent and substantial endangerment to public health, welfare, and the environment. The Baseline Risk Assessment concluded that all of the remedial alternatives considered in the FS (except the "No Action" alternative) addressed the !risks to public health. U.S. EPA risk assessment procedure and calculation has not changed since the Record of Decision, and because there has been no change in the population of residents near the Site, the exposure assumptions for this Site have not changed.

For this five-year review, the potential risk from contaminant vapor intrusion to indoor air was examined. Consistent with U.S. EPA document #EPA 530-D-02-004 entitled "OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (November 2002)," it was determined that currently or potentially inhabited buildings or areas of concern under future development scenarios located near the Site are not in close proximity to subsurface contaminants. Specifically, the closest properties to the Site are about one-quarter mile (approximately 1100 feet) west on Evanston Road at Arlington Estates. Analytical data has shown that no chemicals of sufficient volatility and toxicity are present in groundwater at this property. There is no potential for the vapor intrusion pathway to impact either currently inhabited buildings or areas of concern under future development scenarios away from the Site. Therefore, no further evaluation of this pathway is needed. As recommended in document #EPA !530-D-·02-004, the vapor intrusion pathway will be re-assessed if Site monitoring data ever suggests the presence of known or interpolated soil gas or groundwater contaminants near any inhabited building within approximately 100 feet (laterally or vertically) of the Site or groundwater affected by the Site.

'Nithin the past 5 years of O&M activity, no issues or information have arisen that question the remedy's effectiveness. In this time period, there have not been any chan!~es to the Site since the Record of Decision. No other events have affected the protectiveness of the remedy and, other than the updated groundwater cleanup standards noted in Section 7.2 and the Issues listed in Section 8.0, there is no other information that calls into question the short term and long term protectiveness of the remedy.

49

8.0 ISSUES

Table 8 lists the Issues that Impact Protectiveness.

TABLE 8 -ISSUES THAT IMPACT PROTECTIVENESS

Affects Current Affects Future Issues Protectiveness Protectiveness

(YIN) (YIN)

1. Groundwater sampling events and data may not N Y be cclmplete or representative of site conditions. Gmundwater sampling events and data may not have adequate frequency, locations, or analytical pararneters. Monitoring may not include adequate evaluation of the effectiveness of natural processes as a component of the remedy in the Black Creek floodplain. Statistical analyses may not be frequent enough or may not be using representative data for certifIcation of groundwater capture by the GWETS. The, ~,ite conceptual/computer model must be updated with data more recent than 2004. The moni1:oring well network in the Black Creek floodplain may not be representative.

ep aquifer sampling may not have adequately 2. De N Y cterized the presence or extent of contaminantschara ~p groundwater. Deep aquifer sampling events in dee lot be providing representative monitoring data may r Jse of the sampling method used, inadequate becal ons, or inadequate sampling frequency. locati

3. Pa ssive Diffusion Bag (PDB) samplers may not be N Y , provid ing representative groundwater samples. The PDB sampling method may not be an acceptable

I

:equiv alent to traditional "low-flow" sampling. Data .ted with PDB samplers may not be icollec sentative of site conditions. : repre

~re is an observed increase in the level of4. The N Y methane gas concentration in the OU2-MW-2 monitoring well series.

i 5. Institutional Controls as required by the 1991 ROD N Y Ihavt:! not yet been implemented and the existing ROD may r lot address ICs for groundwater contamination

Iaway from the source property.

50

9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Tabh~ 9 summarizes the Recommendations and Follow-Up Actions needed to adequately address the issues shown in Section 8.0, with a schedule for implementation.

TABLE 9 - RECOMMENDATIONS AND FOLLOW-UP ACTIONS Recommendations Affects

Issue and Follow-up

Party ResponsiblE

Oversight Agency

Milestone Date

Protectiveness (YIN)

Actions Current Future undwater sampling 1. Gro Review the current Site PRP U.S. EPA Sep. 2010 N Y ot represent site rnay n annual monitoring Group with

conditions. Events and program and MDNRE clata ITlay not have possibly increase consulting adequate frequency, frequency, locations, locations, or analytical and analytical parameters. parameters.

Monitoring may not include. adequate

tion of natural .E'valua ses in the Black ~foces

floodplain.Creek The !twork in thewell nE ain may not be floodpl

representative.

Statistical analyses may Site PRP U.S. EPA Oct. 2010 N Y not be frequent enough or Update U.S. EPA's Group with adequately representative 2004 computer and MDNRE for celt.i~{ing groundwater model using recent U.S. EPA consulting capture_by the GWETS. accurate

groundwater te conceptual The Si chemical and

/complIter model must be elevation data and updated with data more possibly initiate bi­mcent than 2004. annual computer ,

analyses of data. i

:) aquifer sampling 2. Dee Review previous Site PRP Oct. 2010 N Y may nc)t have adequately deep aquifer data for Group characterized the adequacy, especially and presence or extent of in the Black Creek U.S. EPA c:>ntalTlinants in deep and wetlands areas. U.S. EPA groundwater. with

MDNRE quifer sampling Deep a Review and revise Site PRP consulting lTIay be using anevents the current deep Group uate sampling inadeq aquifer monitoring and

metho(j and may have program based on U.S. EPA inadeq uate locations or the data adequacy samplil~~I frequency. review above.

51

--

TABLE 9 - RECOMMENDATIONS AND FOLLOW-UP ACTIONS Recommendations Affects

Party Oversight Milestoneand ProtectivenessIssue Responsible Agency DateFollow-up (YIN) Actions Current Future

Review technical ~;. Passille Diffusion Bag U.S. EPA Oct. 2010 N Y references and policy

representative of sampll~rs may not be

to determine if PDB ~IrouncIwater. samplers can be

U.S. EPAused at the Site.

with MDNRE

PDB s 3mpling method Perform a field Site PRP consultingnay n()t be equivalent to demonstration of the Group

equivalency of PDB sampli n~J.

tl-aditio nal "low-flow" samplers to "Iow­flow" purging and sampling.

4. TheI-e is an observed Determine the Site PRP Oct. 2010 N Y increa~;e in methane gas source of the high Group concerItrations in the levels of methane OU2-MW-2 monitoring gas in the OU2-MW­well se ries. 2 wells series and

U.S. EPAwhether this presents

witha health/safety or MDNRE

contaminant issue. consulting

Developlimplement a Site PRP Oct. 2010 plan to mitigate the Group health/safety issue or otherwise address this contaminant.

e,.ICs have not been An IC Study shall be Site PRP U.S. EPA Oct. 2010 N Y conducted and an IC with

! E,xistin9 ROD may not implenlen ted and the Group

Work Plan shall be MDNRE addressiCs for submitted for review consulting groundwater and approval to plan contanlination away from for implementation tile sOlJrce property. and maintenance of Implenlentation, ICs.

! maintenance, monitoring and enforcement of ICs N Y

, is requ ired. ICs shall U.S. EPA will U.S. EPA Oct. 2010 determine whether with an ESD may be MDNRE

groundwater use • consist. of land/

needed to address consulting restrictions. ICs for groundwater

contamination away from the source property

52

10.0 PROTECTIVENESS STATEMENT

Question A: No; Question B: Yes; Question C: No.

The remedy at the Thermo Chem Superfund Site currently protects human health and the environment in the short term because: the groundwater extraction and treatment and 1he in-situ soil vapor extraction systems are in place and operating properly; there is no evidence of any breaches of remedy systems or soil directly above those systems; the existing use of the Thermo Chem Site property is consistent with the objectives of the remedy systems in place and expected land use restrictions; and because there is no evidence of unacceptable levels of groundwater contaminants immediately adjacent to the Site property or unacceptable groundwater use in the area of the plume. In order for the remedy to be protective in the long-term however, the remedy must attain the cleanup standards specified in the 1991 ROD as modified by the 2002 Explanation of Significant Differences. Long term protectiveness also requires compliance with effective ICs. That includes the implementation, monitoring, maintenance, and I~nforcement of institutional controls for land and groundwater use restrictions that: (1) prohibit interference with the currently operating remedy systems; (2) prohibit residential, commercial, or any other use in specific Site areas that would allow human exposure; and (3) restrict use of groundwater until groundwater cleanup standards are achieved throughout the plume area.

11.0 NEXT REVIEW

The next five-year review for the Site is required by May 2015, five years from the approval signature date of this report.

53

N

~ NOTE: MAP IS NOT TO SCALE

MICHIGAN

MUSKEGON COUNTY

APPROXIMATE LOCATION OF SITE

FIGURE 1 - SITE LOCATION MAP THERMO CHEM SUPERFUND SITE;

MUSKEGON, MICHIGAN

NOTE: MAP IS NOT TO SCALE N

~ MUSKEGON

LAKE

aJ

BROADWAY RD

MARQUETTE AVE

APPLE AVE

00 0 0::0:: 0:: LU0

a: Z (J) ~ f-­UJ ...J 0 ~

(9 Q; 0 :5 o ~ LL.Z

<{ ....I 0 ....I....I 0::LU 0 0CCD.. ~ ~

LAKETON AVE

M~----+------------+----------~--~----~----~--~------------+------ri

MUSKEGON

SHERMAN BLVD

APPROXIMATE

SITE LOCATION

EVANSTON RD

FIGURE 2 - SITE LOCATION MAP THERMO CHEM SUPERFUND SITE; EGELSTON TOWNSHIP, MICHIGAN

--

THOMAS SOLVENT

PROPERTY ~ 10S ,

10M

j- r: CRID ORIGIN I 1~ .............. ~.. ~ ..::6":! /

... '.

, . :: . .:: :', ~ . ::"

NOTES:

1. NOT TO SCALE

2. ALL LOCATIONS ARE APPROXIMATE

'. . , ' . , . .

.: ... '...... , .. :.' ~_:J:. .:::: : .[ I .. ' ~ 9 I·

,..., . .' .. a.8M : : ~ ~, ~ ,

-, ".:' :.,. ..

,'SS; : ~

: 95 I' r:" I

:". J :.:.. I

.... .::.. :. ;::~:'::

THOMAS SOLVENT PROPERlY

"~":. l'~~ .-f7~:":'. r:M~~~ 0 ISVE/AS.... ' ~'"" 7S

. ":.

. iCr.'. ,--+~.-----.........-.. GS6~ . ' : ,' .. I BUILDIN L5M ;:. .J' i ~.:: 4M':::'I: i

. . . ;";." -: .. : i5S' ':~ 4S ...1: " .... I .. :"'" .,. lS... , . ; .. : ..: ..:..: . l!M .' .,. !40: .:.•.. ., ,>,,:T., .•.. :.J ,U

.. ,..... 135, " I J 1••.••. :,: I ':~i$ 1.1 WOODED AREA

GWETSTRLIT·:··:·, .. ·.[.LUA~~MRMO_~EMBUILDING ".; . . . , PROPERTY

..

: ....FIGURE 3 THERMOCHEM SITE LAYOUT ~

15 . : ': . : . " .. ~ . :

o o

~H:

~ --­--- ­ ~~'IIIIU. ........... -"...uT5

..,l(. ""'" ~ "'. "'"

EVANSTOt-I ROAO

MW9

NOT TO SCALE

+,tIONITOAIHG WELL

MW-l • PHASE II EXTRACllOH WEll.

... PIEZOME feR WEU.

• • •

•

G~GW-9o*o,8 C .D GMGW-'....e,c

GMG\'\I-2A.B.C

GMGW-3A.B C.O a..t(l'lUll\, B C,D

GMG~A,B.c..O

GMGw.5A.B,C,D

GMGW-8oI' ec.o

• ,.,.,..23

l'HfRMO-Cti(M PROPERTY

1:11'/1 MW-13PZ 7 f)Z-8 PZ.& MW-l<11

'" PZ-2 \ l>Z. t PZ·) PZ-I PZ-6 C'......... ~!.. ... •

M\fII.1eI MW-2!1 t.ftN.26 ' 1:\'\1-2 PZ<5 M-3

~ MW-~

I ~ FIGURE 4

GROUNDWATER d SAMPLING AND

--..../'EXTRACTION LOCATIONS NW19

FIGURE 5 APPROXIMATE PLUME OF CONTAMINATION IN

GROUNDWATER AT THE THERMO CHEM

SITE; 2005 DATA

NOT TO SCALE ~ I I I

I. I I

J, .. ' , I! ·5I

I. I

,I I

~r:,

T ~

r I

J ~J

-L! ,--!

I i

- j I i i I i I r

- -ll-r-,-t­ ! i --" 1 t I i , ~ iFIGURE 6

THERMO CHEM SITE ISVE I AS SYSTEM

LAYOUT NOT TO SCALE

, i L.___ ___________.__

r·-~f ~' !. • I

i !

\

II

II

", I J

II I

FIGURE 7 THERMO CHEM SITE

APPROXIMATE INSTITUTIONAL CONTROL

AREAS

TA8,LE 2: GROUNDWATER CLEANUP STANDARDS AND SINGLE WELL CHRONOLOGY

1991 ROD 2002 ESD 1991 ROD 2000-01 4 2008

CONTAMINANT 1 Cleanup Cleanup Monitoring

Concentration Concentration ConcentrationStandard Standard 2 Well (ug/L) * (ug/L) * TCMW-11 3

(ug/L) (ug/L) (ug/L)

~'OCs

Acetone 500 730 TCMW-11S < 10 < 50 85

TCMW-11M 230 < 5000 69

TCMW-11D < 10 < 25 5 78

Benzene 1 5 TCMW-11S 240 <5 < 1

TCMW-11M 1,100 810 46

TCMW-11D <5 < 1 < 1

Carbon T etracilloride 0.3 5 TCMW-11S <5 <5 < 1

TCMW-11M <5 < 500 < 1

TCMW-11D <5 < 1 < 1

Chloroform 6 6 100 TCMW-11S 13 <5 < 1

TCMW-11M 100 < 500 < 1

TCMW-11D <5 < 1 < 1

1, 1-Dichloroethane 6 700 880 TCMW-11S 25 <5 < 1

TCMW-11M 460 740 37

TCMW-11D <5 < 1 < 1 -1,2-Dichloroethene

70 (cis-DCE): 70

TCMW-11S 2,600 160 < 1 (t-DCE): 100

I

TCMW-11M 16,000 I

12,000 < 1

TCMW-11D 1 <2 < 1 -1,1-Dichloroethene 7 I 7 TCMW-11S 56 <5 < 1

TCMW-11M 380 < 500 < 1 :i I I

TCMW-11D <5 < 1 < 1 -1,2-Dichloroethane 0.4 I 5 TCMW-11S 16 <5 < 1

i

TCMW-11M 84 < 500 < 1

TCMW-11D <5 < 1 < 1 -2-Butanone 400 I 2,200 TCMW-11S NA < 25 4.6

TCMW-11M 2,900 < 2500 5.3

TCMW-11D < 10 < 10 9.6 -1,1,1-Trichloroethane 117 I 200 TCMW-11S 600 22 < 1

TCMW-11M 2,400 760 3.7

TCMW-11D <5 < 1 < 1 -1,1,2-TrichlorOE!tllane 0,6 I 5 TCMW-11S 3 <5 < 1

TCMW-11M 20 < 500 < 1

TCMW-11D <5 < 1 < 1

!Tetrachlo(oethane (1,1,2,2) 0.2 I 8.5 TCMW-11S <5 <5 < 1

TCMW-11M 5 < 500 < 1

TCMW-11D <5 < 1 < 1 I-

1991 ROD 2002 ESD 1991 ROD 2000-01 4 2008

CONTAMINANT 1 Cleanup Cleanup Monitoring

Concentration Concentration ConcentrationStandard Standard 2 Well (ug/L) * (ug/L) * TCMW-11 3

(ug/L) (ug/L) (ug/L)

Trichloroethene 3.0 5 TCMW-11S 21 12 < 1

TCMW-11M 8 < 500 < 1

TCMW-11D <5 < 1 < 1

Tetrachloroethene 0.7 5 TCMW-11S 6 6.6 < 1

TCMW-11M 10 < 500 < 1 -

TCMW-11D <5 < 1 < 1

Toluene 100 140 TCMW-11S 1,300 <5 < 1 -

TCMW-11M 26,000 1,200 0.67

TCMW-11D <5 < 1 < 1

=thylbenzene 30 18 TCMW-11S 190 59 < 1

TCMW-11M 1,200 1,100 35 -TCMW-11D <5 < 1 < 1 -

:3tyrene 1 80 TCMW-11S <5 <5 < 1

TCMW-11M <5 < 500 < 1

TCMW-11D <5 < 1 < 1

'/inyl chloride No value 2 TCMW-11S NA < 10 < 1 assigned

TCMW-11M NA < 1000 < 1

TCMW-11D NA < 1 < 1 -§EMI-'£.OCS

:'I ,2-Dichlorobenzene 7 16 TCMW-11S <10 <10 NA

TCMW-11M < 10 NA NA

TCMW-11D < 10 NA NA -2-Methylphenol 40 71 TCMW-11S 19 < 10 NA

TCMW-11M 38 NA NA

TCMW-11D <10 NA NA-Naphthal'3ne 29 13 TCMW-11S < 10 < 10 NA

TCMW-11M 6 NA NA

TCMW-11D < 10 NA NA-:;~-Methylnaphthalene 10 260 TCMW-11S < 10 < 10 NA

~liS (2~ettyhexyl )phthalate

TCMW-11M < 10 NA NA

TCMW-11D < 10 NA NA

2 6 TCMW-11S < 10 < 10 NA

I TCMW-11M <10 NA NA

TCMW-11D < 10 I NA NA -! Pentachlorophenol 0.3 1 TCMW-11S < 50 < 50 NA

l TCMW-11M < 50 j NA NA

TCMW-11D < 50 I NA NA

1991 ROD 2002 ESD 1991 ROD 2000-01 4 2008

CONTAMINANT 1 Cleanup Cleanup Monitoring

Concentration Concentration ConcentrationStandard Standard 2 Well (ug/L) * (ug/L) * TCMW-11 3

(ug/L) (ug/L) (ug/L)

!INORGANIC G.9MPOUNDS

Aluminum 50 - 200 300 TCMW-11S 56.4 800 NA

TCMW-11M 82 NA NA TCMW-11D 63.5 NA NA

,!\rsenic 6 0.02 50 TCMW-11S 20.9 29 NA TCMW-11M 62.2 NA NA TCMW-11D <2 NA NA

Cyanide 4 20 TCMW-11S < 10 NA NA TCMW-11M < 10 NA NA

I I TCMW-11D < 10 NA NA

,Ilron 300 2,000 TCMW-11S 112 20,000 NA TCMW-11M 5,640 8,800 NAI

I

:1

ITI·_Inc I I

II

TCMW-11D 19.7 NA NA 80 2,400 TCMW-11S 165 220 NA

TCMW-11M 288 NA NA TCMW-11D 121 NA NA

-

, ,

I

1I

J

* ug/L is micrograms of contaminant per liter of water, or parts per billion (ppb).

1 The list of contaminants analyzed for was reduced based on non-detections in previous site monitoring. Other contaminants and other wells are analyzed for annually but are not shown in this Table.

2. Most restrictive of the following: National Primary Drinking Water Regulations as of May 31, 2001 (MCLs); MDEQ Part 201, Act 451, Health Based Residential Drinking Water Standards as of June l. 2000; Part 31, Act 451, Water Quality Values established under Rule R 323.1057 as of June 10, 2002.

3. MW··11 was selected for this Table because data was available from 1991 through 2008. MW-11 is generally "centrally" located between contaminated soils to the north and Black Creek tc the south. This Table shows only one monitoring well as one example and is not completely rE!presentative of the entire site.

4. Values shown are from the report entitled "Operable Unit No.1 Annual Monitoring Report 2001, Thermo Chem Superfund Site" dated November 21,2001. Samples were collected either in late 2000 or early 2001. NA: Sample was Not Analyzed for that contaminant or information is Not Available.

5. Result is from year 2004 data.

6. A more stringent standard for arsenic in groundwater mandated by U.S. EPA became elfective in 2006. The revised standard lowered the limit from 50 parts per billion to 10 parts per billion. The current, most stringent Part 201 drinking water standards for chloroform and 1,1­dichloroethane are 80 and 740 ppb, respectively.

TABLE 3: THERMO CHEM PHASE III (lSVE) PORTION OF REMEDY; COMPARISON OF CONTAMINANTS: 1998 START-UP VS. YEAR 2008

Contaminant * 1998 Result **

ppbv 2008 Result ***

ppbv

cis 1,2-Dichloroethene 530 170

Carbon Tetrachloride 150 < 0.67

T rich loroethylene 27,000 69

Toluene 39,000 7.6

: Tetrachloroethylene 64,000 37

I

I Ethylbenzene 4,000 3.4

Xylenes ****

,

10,000 27

All values shown are parts per billion of vapor. That is, the number of particles of contaminant in every billion particles of collected vapor. Collected vapor is a mixture of gases that could include contaminant vapor, air, water, and other impurities. Gas temperature was approximately 97-98 degrees Fahrenheit at the time of sampling

* This is only a partial list of all the contaminants analyzed for. The Phase III system has operated in compliance with a Substantive Requirements Document that is similar to an operating permit issued under the Clean Air Act.

** Data collected from 1998 Phase III Remedial Action Report; Appendix A; Tables from pilot testing sampling. Maximum result from 10 rounds of 1998 sampling shown, and the value shown is the maximum from collection Zone A, 8, or C.

*** From 2008 Annual Report. Values shown are the maximum for that contaminant in three different sampling events during 2008. The value shown is the maximum of collection Zone A, 8, or C.

**** 1998 data for xylenes are for m,p-xylene and o-xylene. The maximum value discovered in 1998 for any of these three isomers is the value shown.

--

TABLE 4: THERMO CHEM PHASE II (GWETS) PORTION OF REMEDY; SUMMARY OF CONTAMINANT CONCENTRATIONS ENTERING THE

GWETS TREATMENT BUILDING

1999 2008** Contaminant * Concentration Concentration SRD***

Entering Entering Discharge Limit GWETS GWETS

(ppb) (ppb) (ppb)

cis 1,2-Dichloroethene <52,100 394

<5Benzene 91 29

Trichloroethylene <5280 11 I

<5 I

I Toluene 2,500 20 I

i ii­~ I

I

1.1 I

<582ITetrachloroethylene I

I <5I Ethylbenzene 470 I 33

I Vinyl Chloride 320 98 ! <5 i ,I,

All values shown are parts per billion, or micrograms of contaminant per liter of water.

* This is only a partial list of all the contaminants analyzed for.

** From 2008 Annual Report. Values shown are the maximum for that contaminant in two different sampling events. Sampling occurs monthly throughout the year, but the value shown in this Table is from December 2008.

*** A Substantive Requirements Document is equivalent to a National Pollutant Discharge Elimination System (NPDES) permit. The GWETS has operated since 1999 in compliance with the SRD.

__

___ ____

- -- ----

---------------------

--------

- -- -- ---

--------

------

- -----

------

- ------

- ------

~=.~~==~~~~==~==~~~~==~~~==~~======================~

TABLE SA - SUMMARYOF MAINTENANCE OR REPAIR EVENTS FOR PHASE II OF REMEDY

~ DATE

1/S/2004

I, '-~/26/2f;~~

2/12/2004

2/30/2004

.11/19/2004

.11/20/2004

e,/13/2004

1:/28/2004

e/13/2004

!3/1/2004 --.~----

10/13/2004

10/26/2004

11/30/2004 --.-------­

2/3/2005

4/27/20('5--"_._---­

!:;/4/2005

6/13/2005

?16/2005

13/1/2005

10/4/200S

'10/18/05

11/2/2005

1/4/2006

1/18/2006

2/28/2006 -_._----­

3/23/2006

4/27/2006 .. _------­

!j/8/200(3

AT THERMO CHEM SUPERFUND SITE: 2004 - 2009

DESCRIPTION

Four extraction wells cleaned: EW-3 thru EW-6.

EW-2 cleaning. Install new 3HP, 4", 460vt, 3 phase motor lead. Included waterproof splice a~~ulling and replacing motor.

EW-1.2,3,4,S (check/ clean),

EW-3 Motor and lead replacement. Cleaning with chlorinate .

GAC material changed out.

EW-3 Motor replacement! pull pump and replace motor.

EW-1 thru EW-6 cleaning and installation of flow inducers.

EW-3 rehab (check). ---------------------~

EW-4 --New Motor & lead, Pull and replace pump.

Re-hab all 6 wells. -------------~--------

New motor for EW-1, GAC material changed out.

EW-4 & EW-S rehab and replace pitless O-ring.

EW-1 ,-2,-3 & new motor and pump end for one well.

EW-1 ,-2,-3 - Clean wells and pumps.

EW-1 through 6. Clean, new riser and complete grundfos pump including motor lead,

GAC material changed out.

Purchase new pump and replace EW-2 pump end.

EW-3 cleaning and install new 1-1/2 HP motor.

PW- 1 and #2 cleaning,

PW-1,2 & 3 check/ clean.

GAC material changed out.

Check pumps at EW-1 & 3. Clean-out PW-5.

PW- 2,3, & 4 check/clean.

PW 5 pump installed and cleaning of PW1 & S,

PW-2 check/clean. -----------.---------~

GAC material changed out.

PW-1 bench test new pump & motor.

New bowl shaft,

: !j/3/20Q(3 Redevelop & chlorinate, power wash and exchange liquid end. PW-3 check/clean.

Exchanged pump ends PW-2 & PW-3, evaluateltest. Materials: Pump end & 2 motors (1 ,~I€>I9/200()

1 HP), _____________________ 6/27/2Cl06 Exchanged pump ends PW-1-4, evaluateltest, Materials: New Motor, drop pipe and pump for

PW-1.

B/1/200(3 PW-3 ---new 1.SHP Motor & liquid end exchange.

8/23/2006 EW-1,2 & 5 - exchange liquid pump end and bench test. GAC material changed out.

S:pt. 2,]06 Based on review of well performance data, wells EW-2, EW-3 and EW-4 were replaced. Condensate Knock-out! Lift Station; pump cycle counter are replaced.

9/13/2Cl06 EW-1 & EW-2; exchange liquid pump end,

10/S/2Cl06 Drilling services - boring EW-2A, -3A & -4A.

10/11/2006 Exchange liquid ends! bench test PW1 & PW2.

[~)~2~/20()6 Repair EW-11 replace motor.

-------- ---

----------

-----------

-----------

- --------- ----

--

---

----

----

----- ------ --

--

F""'= TABLE SA - SUMMARYOF MAINTENANCE OR REPAIR EVENTS FOR PHASE II OF REMEDY

AT THERMO CHEM SUPERFUND SITE: 2004 - 2009

-. DATE DESCRIPTION New extraction wells EW-2A, EW-3A and EW-4A are installed using existing piping, electrical

Nov 2006 system and pumps. EW-2A, EW-3A and EW-4A begin operating in Dec. 2006

.~~--~----- -,--- --­

11/22/2006 Chemical treatment, exchange liquid ends, bench test, EW-S & 6. ~-

12/13/2006 Power wash well pumps and drop pipe EW-2,-3,-4. ---.- ----- f---~ -­

1/8/2007 Cleaning EW-2A, 3A, 4A. ~~-- ------­ f----- -­

1/31/2:)07 GAC material changed out. f----~--- ._-­

2/14/2007 Cleaning EW-2a; pump cleaning and bench testingl 2 new 1.S HP motors. ~~--~------- -­f-- ­

3/8/2007 Chemical Cleaning of EW-1. ~-~-------- f----- ­ ~-

3/29/2007 Well cleaning on EW-1 & new pump end. ----_._----­~-- ~---

4/23/2:)07 EW-1- Clean & test Pump.

4/24/2007 Cleaning of Well EW-S. -~

5/2/2007 Cleaning of Well EW-2A. ~.-~-- -.- ----­

~i/24/2:)07 Cleaning of Well EW-2A. -- --~-. --- --­ ~---f-- ­

5/6/2007 Chemical Cleaning of EW-3A. ~-- '--

GAC material changed out. 6/2S/2'J07

6/28/2,J07 Cleaning of EW-1, EW-3A and EW-4A. c---- -----

Cleaning of EW-1, EW-2A and EW-3A. ~--

I .3/8/2007 --~~--~-----~-

6/28/2007 Pump cleaning services for EW-1, EW-2A, and EW-3A. .-~~------- ~-

E./29/2007 Cleaning of EW-S. ----~------ f---~ ~-----1

9/S/2007 Clean pump - EW-S. !

--~-~-- -12/S/2007 Cleaning EW-1, EW-2A and EW-4A.

-~-------

1:2/17/2007 - -------

GAC material changed out. ----J 1/24/2008 Cleaning EW-1 & EW-S.

---~-----~- ----,

2/29/2008 --~------

2/29/2008 -­-------

Clean pumps for EW-1 and EW-2A.

Cleaning wells EW-1 and EW-2A.

:

------j

---­

4/14/2008 Chemical cleaning EW-1. ----~ -----­~- ._­

3/28/2008 Clean pumps EW-1 and EW-2A. :-~ ~--~----- ~~

4/17/2008 Clean pump EW-2A. ! --~------- i-­

4/17/2008 Clean EW-2A.

:1 ~I

~-,----------­

4/2S/2008 Pump bench testing - EW-2A. -~~-- -----~- --=113/S/2008 ---~--

6/10/2008 ,-~~-'-~-----

7/7/2008 I-~-- ------ ­

7/28/2008

GAC material changed out.

Pump services EW-1, EW-2A and EW-3A.

Cleaning of EW-2A and EW-S. 1---- --

Cleaning of EW-1. 1---- ------1---­ ~----

8/29/2008-_.__. - ---­

8/29/2008 --~----

10/27/2008 I---~--'--

! 1'1/18/2008 ,----~-.--- --­

12/4/2008

, 12/1/2008 --~ --------

Pump services EW-1, EW-2A and EW-3A. ._---

Chemical cleaning EW-2A.

Cleaning EW-1. I-- , IGAC material changed out.

c---~ -­

EW-3A- drop pipe brokenl EW-S broken pump shaft. ~-

EW-5 broken pump shaft. -

---

-------

- - -- --- ----

------------

----------

-- ---

---------

---

-C==' TABLE SA - SUMMARYOF MAINTENANCE OR REPAIR EVENTS FOR PHASE II OF REMEDY

AT THERMO CHEM SUPERFUND SITE: 2004 - 2009

DATE DESCRIPTION r-'

Pump services. 12/16/2008 _._.- -----­

'1127/2009 Chemical redevelopment of EW-3A and replace bad wire at EW-S. --~-------

'1/29/2009 Cleaning pump shaftsl bench testing. -- -_.- ---­

:3/31/2009 Clean EW-2A & EW-3A, clean pumps #9 and #23.

-~

---~--

-~

4/10/2009 Clean EW-1 & EW-S & bench test #2 and #21. -~

!i/13/2009 GAC material changed out. --------f--­

!i/29/2009 Clean EW-2A & EW-3A _.­

.-~

7/7/2009 Repairs on EW-1 after a mouse nest clogged the well. r---' -~

B/11/2009 Finish repairs on EW-1 and rehab EW-2 & 5. .--~ ~------

W16/2009 Clean EW-1 and EW-2A

, 1/4/2009 GAC material changed out. ...- -------

Clean EW-1 and EW-2A11/10/2009 -_._---- - ._--­

12/14/~~O09 Clean EW-2A and EW-S.

APPENDIX A LIST OF DOCUMENTS REVIEWED FOR THE SECOND FIVE YEAR REVIEW:

THERMO CHEM INC. SUPERFUND SITE; MUSKEGON, MICHIGAN

1. Administrative Order by Consent. Remedial Investigation & Feasibility Study. Sept. 21, 1987.

2. Unilateral Administrative Order. January 9, 1989.

3. Environmental Resources Management Inc.-North Central. Technical Memorandum No.1; Remedial Investigation Task 1; Thermo-Chem Site, Muskegon, Michigan. June, 1989.

4. Unilateral Administrative Order. July 12, 1989.

5. Unilateral Administrative Order. January 10, 1990.

6. Unilate{~1 Administrative Order. January 23, 1990.

7. Metcalf & Eddy, Inc. Final Technical Assistance Report For Thomas Solvent Site; Muskegon, M~l2higan. March 1991

8. Environmental Resources Management Inc.-North Central. Remedial Investigation, Thermo-Chem Site,' Muskegon, Michigan. May 1991.

9. Unilatewl Administrative Order. Removal Action at Thomas Solvent. February 19, 1991.

10. U.S. EPA Region 5. Record of Decision. September 30, 1991.

11. Unilateral Administrative Order. Remedial Design/Remedial Action of O.U. #1. May 6, 1992.

12. lJnilateral Administrative Order. U.S. EPA Access to perform RD/RA work. March 26, 1993.

13. U.S. Army Corps of Engineers. Final Design Analysis; Phase 1 Demolition and Removal, Thermo Chf}m; Muskegon, Michigan. February 1994.

14. U.S. EPA Region 5. Explanation of Significant Differences. April 25, 1994.

15. ~~dministrative Order on Consent for De Minimis Respondents. August 24, 1994.

16. ~~mendment to the RDIRA Unilateral Administrative Order. October 12, 1994.

17. ~~dmirlJ~')trative Order on Consent for De Minimis Respondents. September 27, 1995.

18. Geraghty & Miller, Inc. ISVEIAS Pilot-Scale Test Report, Thermo Chem Site Phase III; Mld~;kegon, Michigan. August 1996.

19. GNB Environmental Services, Inc. and Advanced Geoservices Corp. Phase la Remedial Ac110n Implementation Report for Thermo Chem Superfund Site; Muskegon, Michigan. August 8, 1996.

20. Geraghty & Miller, Inc. Prefinal Design Report, Thermo Chem Site Phase III; Muskegon, MI~~higan. April 1997.

21. E:nvironmental Resources Management Inc.-North Central. Technical Memorandum No.4; o.u. NQ.;. 2 Ground Water Investigation. Thermo-Chem Site; Muskegon. MI. April 1997.

22. ARCi~DIS Geraghty & Miller. Inc. Remedial Action Implementation Report for Phase IB (Soil Eg:avation. Treatment and Removal). September 1998.

23. ARCi\DIS Geraghty & Miller. Inc. Final Operable Unit No.1 Monitoring Plan. Thermo Chem SI,!1)erfund Site; Muskegon. Michigan. January 22. 1999.

24. ARCADIS and Conestoga Rovers Associates. Thermo Chem Site Log Books. March 1999 to D,=cember 2007.

25. Conestoga Rovers Associates (CRA) Services. O&M Summaries (Phase /I). May 1999 to D,:cember 2007.

26. Conestoga Rovers Associates. Remedial Action Implementation Report. Phase /I Groundwater E)~traction and Treatment System. Thermo Chem Site. Muskegon. Michigan. August 1999.

27. ARCADIS Geraghty & Miller. Inc. Remedial Action Implementation Report. Phase //lIn Situ Soil V,u}or Extraction/Air Sparge System. Thermo Chem Site; Muskegon. Michigan. Aug. 9, 1999.

28. Environmental Resources Management, Inc. Field Sampling Plan. Addendum 8; Thermo-Chem Sit§:; Muskegon. Michigan. September 1999.

29. ARCADIS Geraghty & Miller, Inc. Operable Unit No. 1 Quarterly Monitoring Reports. Dec. 1999 through May 2000.

30. U.S. EPA Region 5. Letter. re: Administrative Order V-W-95-C-274: Remedial Implementation Rf>&.ort Approvals for Operable Unit 1 at Thermo-Chem Site. March 8, 2000.

31. ARCADIS Geraghty & Miller, Inc. Operable Unit No.1. Annual Monitoring Reports; Thermo Chem Superfund Site; Muskegon. Michigan. Nov. 21, 2001 through Oct. 5, 2009.

32. U.S. EPA Document # EPA 540-R-01-007 (OSWER No. 9355.7-03B-P). Comprehensive Five-Year Review Guidance. June 2001

33. U.S. EPA Region 5. Explanation of Significant Differences. September 17,2002.

34. U.S EPA Region 5. Preliminary Close Out Report. Thermo Chem Inc. Site. Muskegon. Michigan. September 17, 2002.

35. U.S. EPA Document # EPA 530-0-02-004. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils. November 2002.

36. U.S. EPA Region 5. Letter: 2004 Addendum to the Operable Unit 1 Monitoring Plan. Thermo Cfl~m Superfund Site; Muskegon. Michigan. August 12, 2004.

37. Kerrigan Associates Inc. 2004 Addendum to the Operable Unit No.1 Monitoring Plan; Thermo Chem Site; Muskegon. Michigan. November 4, 2004

38. Kerrigan Associates Inc. Letter: Supplemental Groundwater Sampling. 2004 Addendum to the Q1u~'rable Unit No. 1 Monitoring Plan; Thermo Chem Site; Muskegon. MI. November 4, 2004.

2

39. l<erri~lan Associates Inc. Semi-Annual Progress Reports; Operable Unit 1. Operational and M?jntenance Phase; Thermo Chem Site. Muskegon. Michigan. Nov. 2004 through Jan. 2009.

40. U.S. EPA Region 5. Five-Year Review Report. Thermo Chem Inc. Site; Muskegon County. E9~~/ston Township. Michigan. May 10, 2005.

41. ARCADIS and Conestoga Rovers Associates. Thermo Chem Site Log Books. December 2007 to March 2010.

3

Appendix B - Five Year Review Newspaper Advertisement

EPA Begins Review of Thermo Chern Superfund Site

Muskegon, Mi-chigan U.S. Environmental Protection Agency, with assistance from Michigan Department of Natural Resources and Environment, js conducting a f.v~year review of the Thermo Chern Superfund site, 4321 Evanston Road. The Superfund law requtres r'99u1ar checkups of s;tes that have been cleaned up - WIth waste managed on­site - to make sure the deanup continues to protect people and the environment. This is the second five­year review of thts srte. EPA's deanup of volatile organic compounds, semiv­olatile organic compounds and pesticides included re­movaJ of debris, as well as excavaUon, treatment and removal of conta.rntnated soil and sludge. Cleanup sys­tems still in operation are the ground-water extraction and treatment system, and the soil vapor extraction and air spargtng system. More information is availabfe at Hackley Ubrary, 316 W. Webster St.; Egeiston Township Hall, 5382 E. Apple Ave.; and at www.epa.gov/regjonSsuperlundlnpl/mlchi­gan/MID044567162.htm. The review should be com­pleted by the mtddte of May. The five.:year review is an opportunity for you to tell EPA about site oonditions and any concems you have. Contact: John Fagjok> - RemedtaJ Project Manager 312-88~0800 fagiolo. john@ epa.gov Cheryl Allen Community Involvement Coordinator 31 ~~-353-6196 You may call Reg;on 5 toU-free at 800-621-8431 t

9:30 a.m. to 5:30- p.m., weekdays. PubHsh: March 23, 2010

APPENDIXC Site Inspection Checklist, Five-Year Review

Thermo Chem Inco Superfund S·t I e; Muskezon, MI

I. SITE INFORMATION

Site name: THERMO CHEM INC.

Locatio n and Region:

MliSKI~GON COUNTY, EGELSTON TWP, MliSKI~GON, MICHIGAN. REGION 5

t\gency, office, or company leading the five-year review: U.S. EPA REGION 5

Remedy Includes: (Check all that apply)

Problem '. suggestions: NONE. Rep(~~ attached

Date of inspection: APRIL 21, 2010

EPA 10:

MID 044 567162

Weather/temperature:

CLEAR, SUNNY, 55-60 DEGREES F

,

Landfi iI cover/containment _ Monitored natural attenuation IRl Access controls

[~ Grollndwater containment IRl Institutional controls .. Vertical barrier walls

[~ Grollndwater pump and treatment Surface water collection and treatment

[~ Other IN-SITU VAPOR EXTRACTION AND AIR SPARGING SYSTEM.

t\ttach ntents: Inspection team roster attached IRl Site map attached: SEE FIGURES 1-3 OF FIVE YEAR REVIEW REPORT

II. INTERVIEWS (Check all that apply)

I. O&:\1 Site Manager:

'lame: MAUREEN KERRIGAN-FLAVIN; KERRIGAN ASSOCIATESl INC.

Address : 4720 LINDEN PLACE; DOWNERS GROVEl IL 60515

Title: CHAIRl TECHNICAL COMMITTEE; THERMO CHEM SITE GROUP

Date: April 21, 2010 Intervie\ved: IRl at site at office IRl by phone IRl bye-mail

Phone n(J. 630.493.9194 TEL.; 630.297.4850 FAX; E-MAIL: KerrFlavinlalaol.com

-.----.------------------------------------------------------------------------~

2. 0& 1\1 staff 2.a. Name: l. JACK KRATZMEYER, 2. ANDY PENNINGTON; ARCADIS U.S., INC.

Addn'ss: 35 EAST WACKER DRIVE; SUITE 1000 CHICAGO ILLINOIS 60601

ritle: l. PRINCIPAL ENGINEERIPROJECT MANAGER; 2. SCIENTIST

Date: April 21, 2010 [nterviewed: [E] at site [E] at office [E] by phone [E] bye-mail

Phone no. 1. 312.425.4114 TEL.; 312.263.7897 FAX; E-MAIL: Jack.Kratzmeyerfalarcadis-us.com

2.312-263-6703 TEL.; 312-263-7897 FAX; E-MAIL: apennington@arcadis-us.com; Report attached _____________________________________

.2.b. 'lame: BART BARTHOLOMEW AND JON VALENTINE;

CONESTOGA ROVERS AND ASSOC. (CRA) INC.

Addre~~: 4140 DAVIS CREEK CT.; KALAMAZOO, MI 49001

Title: SITE OPERATOR; GROUNDWATER EXTRACTION AND TREATMENT

Date: April 21, 2010 Interviewed: [E] at site at office by phone _ bye-mail

Phone 110. 269.344.1230 TEL.; 269.344.8558 FAX

Problems. suggestions; NONE. Repon attached _________________________________________

NOTE: eRA DOCUMENTS WERE PROVIDED THROUGH KERRIGAN AND ASSOCIATES.

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

a. Agency: Michigan Department of Natural Resources and Environment (MDNRE) Contact: Walelign Wagaw Senior Project Manager, RemediationlRedevelopment Div.

Name Title

4/2112010 and ONGOING 517-373-9896 Date Phone no.

Problems: suggestions: NONE. Report attached ____________________

-.---------------------------------------------------------------------------~ 4. Other interviews (optional) .. Report attached. ------.---------------------------------------------------------------------~

NOTE: PHIL HESTER OF STEELCASE, A MEMBER OF THE SITE PRP GROUP WAS PRESENT

FOR THIS INSPECTION. -.---------------------------------------------------------------------------~

2

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

----------------------------------------------------------~----------~ I. O&M Documents

IKI O&M manual IKI Readily available IKI Up to date NIA IKI As-built drawings IKI Readily available IKI Up to date _ N/A

IKI Maintenance logs IKI Readily available IKI Up to date~ NlA

Remarks:

O&M MANUAL FOR PHASE II OF THE REMEDY IS LOCATED BOTH ON-SITE AND AT CRA OFFICE AND IS UP TO DATE. THE ON-SITE COPY OF PHASE II MANUAL IS INSIDE THE GROUNDWATER TREATMENT BUILDING LOCATED AT THE SOUTHERN END OF THE SITE. AS-BUILT DRA WINGS ARE LOCATED AT THE PRP COORDINATOR'S OFFICE, THE CRA OFFICE, AND AT U.S. EPA. UP TO DATE MAINTE;\/ANCE LOGS FOR PHASE II HAVE BEEN PROVIDED IN ELECTRONIC FORMAT TO U.S. EPA.

THE O&M MANUAL FOR PHASE III OF THE REMEDY IS LOCATED BOTH ON-SITE AND AT ARCADIS CHICAGO OFFICE AND IS UP TO DATE. THE ON-SITE COPY OF THE PHASE III MANUAL IS LOCATED IN BUILDING B OF THE ISVE/AS SYSTEM. AS-BUILT

DRA WINGS ARE LOCATED AT THE PRP COORDINATOR'S OFFICE, ARCADIS' OFFICE, AND AT U.S. EPA. UP TO DATE MAINTENANCE LOGS FOR PHASE III HAVE BEEN PROVIDED IN ELECTRONIC FORMAT TO U.S. EPA, AND ARE A V AI LABLE AT ARCADIS' CHICAGO OFFICE.

----~======================================~--~ 2. Site-Specific Health and Safety Plan IKI Readily available IKI Up to date N/A

Contingency plan/emergency response plan - Readily available - Up to date N/A

Remarks THE HEALTH AND SAFETY PLAN FOR THE SITE INCLUDES BOTH THE PHASE II AND PHASE III PORTIONS OF THE SITE REMEDY. THE HASP IS LOCATED ON-SITE, AT TH E CRA OFFICE, AT ARCADIS' OFFICE, AT KERRIGAN AND ASSOCIATES, AND IS l'P TO DATE. THE ON-SITE COPY OF THE HASP IS LOCATED INSIDE BUILDING B OF THE ISVE/AS SYSTEM. A CONTINGENCY PLAN/EMERGENCY RESPONSE PLAN IS INCLUDED IN THE TEXT OF THE HASP.

----========================================~---I .3. O&M and OSHA Training Records IKI Readily available IKI Up to date - N/A

Remarks THE PERTINENT TRAINING RECORDS ARE ON FILE AT THE OFFICES OF CRA, ARCADIS, AND KERRIGAN AND ASSOCIATES. ALL PERSONNEL ADEQUATELY FOLLOW ALL APPLICABLE HEALTH AND SAFETY REQUIREMENTS.

----==================================~~ 4. Permits and Service Agreements IKI Air discharge permit IKI Readily available IKI Up to date • NIA IKI Effluent discharge IKI Readily available IKI Up to date _NIA

Waste disposal, POTW _. Readily available _ Up to date IKI NIA Other permits ________ - Readily available - Up to date IKIN/A

Remarks: AIR AND EFFLUENT DISCHARGE PERMITS ARE SUBSTANTIVE REQUIREMENTS DOCUMENTS (SRDs) ISSUED BY AND OVERSEEN BY MDNRE.

-----=====::::=::==~~::::::::::::::::::::::=~~==:::::::::::::::::::::::======----J :i. Gas Generation Records IKI Readily available IKI Up to date N/A

Remarks: RECORDS FOR "GAS GENERATION" ARE OPERATIONAL RECORDS FOR EXTRACTED VAPOR FROM CONTAMINATED SOIL (PHASE III; ISVE/AS SYSTEM).

----==========================~============~~ 6. Settlement Monument Records Readily available -- Up to date IKI N/A

Remarks

----===============================================-~ 3

------------------------------------------------------------

7.

8.

~.

10.

Groundwater Monitoring Records [8] Readily available [8] Up to date NIA

Remarks: ANNUAL GROUNDWATER MONITORING DATA FROM 2004 TO THE PRESENT DATE IS AVAILABLE AT THE OFFICES OF ARCADIS AND U.S. EPA.

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

Leachate Extraction Records Readily available - Up to date [8] N/A Remarks

Discharge Compliance Records [8] Air [8] Readily available [8] Up to date _N/A [8] Water (effluent) [8] Readily available [8] Up to date N/A

Remarks OPERATIONAL INFORMATION ON THE PHASE II (GWETS) AND PHASE III (lSVE/AS) PORTIONS OF THE REMEDY ARE AVAILABLE, UP TO DATE, AND COPIES ARE AT THE OFFICES OF KERRIGAN, ARCADIS, CRA, AND U.S. EPA.

---"':":":':':'======================--1

Daily Access/Security Logs Readily available Up to date [8] N/A

Remarks THE SITE FENCE AND GATES ARE LOCKED AND THE SITE IS ACCESSIBLE ONLY TO PHASE II AND PHASE III OPERATION AND MAINTENANCE CONTRACTORS. THERE ARE NO DAILY EVENTS AND WEEKLY EVENTS ARE LOGGED IN THE SITE OPERATIONAL LOGS.---"::::::::::==:::::::::::::::::=:::::::::::==============================================--'

~.------------------------------------------------------------------------~

IV. O&M COSTS r·------------------------------------------------------------------------~

I. O&M Organization State in-house Contractor for State PRP in-house [8] Contractor(S) for PRP Federal Facility in-house ~ Contractor for Federal Facility Other

') O&M Cost Records

[8] Readily available [8] Up to date [8] Funding mechanism/agreement in place

Original O&M cost estimate 1991 ROD ESTIMATE: $1,091,000 PER YEAR Breakdown attached

Total annual cost by year for review period if available PHASE II: From 2004 To 2009 $250,000 TO $400,000 Breakdown attached PHASE III: From 2004 To 2009 $125,000 TO $175,000 ~ Breakdown attached

NOTE: THE ANNUAL COST RANGE FOR OPERATION AND MAINTENANCE OF PHASE II PF THE SITE REMEDY AVERAGED OVER THE YEARS 2004 TO 2009 IS APPROXIMATELY ~250,000 TO $400,000. THIS AVERAGE COST INCLUDES THE TYPES OF MAINTENANCE ~ND REPAIR TASKS SUMMARIZED IN TABLE 5A AS WELL AS SAMPLING AND bNALYSIS TO ASSESS GWETS OPERATION AND ASSESS OVERALL SITE ~;ROUNDWATER QUALITY. THE ANNUAL COST RANGE FOR OPERATION AND ~AINTENANCE OF PHASE III OF THE SITE REMEDY AVERAGED OVER THE YEARS ~004 TO 2009 IS APPROXIMATELY $125,000 TO $175,000.

r·----------------------------------------------------------------------~ .'. Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons: --!..N~O~N~E~.:.....-_____________________________________

-.----------------------------------------------------------------------~ 4

V. ACCESS CONTROLS I INSTITUTIONAL CONTROLS [8] Applicable N/A

A. Fendng

I. Fencing damaged __ Location shown on site map [8] Gates secured [8] N/A

Remarks: NO FENCING IS DAMAGED2 THEREFORE "N/A."

B. Oth,·r Access Restrictions

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

Remarks ALL SIGNAGE IS IN PLACE AND IS IN GOOD CONDITION

C Inst itutional Controls (ICs)

I. Implementation and enforcement Site conditions imply ICs not properly implemented Yes No [8] N/A Site conditions imply ICs not being fully enforced Yes No [8] N/A

Type of monitoring (e.g., self-report, drive by) N/A: ICS HAVE NOT YET BEEN IMPLEMENTED. Frequency Responsible party/agency Contact

Name Title Date Phone no.

Reporting is up-to-date Reports are verified by the lead agency

. Yes Yes

No [8] N/A No [8] N/A

Specific requirements in deed or decision documents have beViolations have been reported Other problems or suggestions: Report attached

en met - Yes

. Yes No No

[8] N/A [8] N/A

FINAL INSTITUTIONAL CONTROLS HAVE NOT YET BEEN RECORDED. SITE SECURITY MEASURES2 PERIMETER FENCING AND LOCKED GATES PREVENT SITE ACCESS AND PROTECT THE INTEGRITY OF THE REMEDY. THE SITE PRP GROUP IS CURRENTLY PURSUING THE IMPLEMENTATlON {DEVELOPMENT & RECORDATION} OF LAND USE RESTRICTIONS SUCH AS RESTRICTIVE COVENANTS AND DEED NOTICES. THE SITE HAS BEEN ZONED AS INDUSTRIAL BY EGELSTON TOWNSHIP. SPECIAL APPLICATION MUST TAKE PLACE IF ANY EFFORT AT CHANGING THE INTENDED USE OF THE SITE PROPERTIES IS ATTEMPTED. THERE IS A LOCAL ORDINANCE THAT REQUIRES APPROVAL FROM THE MUSKEGON COUNTY DEPARTMENT OF PUBLIC HEALTH FOR ANY NEW DRINKING WATER WELLS.

" Adequacy . ICs are adequate - ICs are inadequate [8] N/A

Remarks FINAL INSTITUTIONAL CONTROLS HAVE NOT YET BEEN RECORDED.

D. Gen£ ral

I. Vandalism/trespassing _Location shown on site map [8] No vandalism evident Remarks

Land use changes on site - Changes in Land Use 1R1 No Changes in Land Use N/A Remarks

Land use changes off site ~ Changes in Land Use [8] No Changes in Land Use N/A

Remarks

5

Roads

VII. LANDFILL COVERS Applicable OON/A

<\. Landfill Surface --------------------------------------------------------------------------------~ I. Settlement (Low spots) Location shown on site map Settlement not evident

Areal extent ______ Depth_____

Remarks

Cracks Location shown on site map Cracking not evident

Lengths Widths Depths

A.

I.

B.

VI. GENERAL SITE CONDITIONS

00 Applicable N/A

Roads damaged

Remarks

Location shown on site map 00 Roads adequate ----------------------------------------------------------------------------~----

Ot

Remarks:______________________________________________________________

hl!r Site Conditions

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

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

Alternative Cover (armored rock, concrete, etc.)

s. Vegetative Cover -= Grass Cover properly established 00 No signs of stress Trees/Shrubs (indicate size and locations on a diagram)

Remarks

, 6. OON/A Remarks

Bulges Areal extent _______

Remarks

Location shown on site map Height_____

Bulges not evident

8. Wet AreaslWater Damage 00 Wet areas/water damage not evident Wet areas Ponding - Seeps -= Soft subgrade Location shown on site map Areal extent ______

Remarks

~)-.-----Slope Instability - Slides Location shown on site map - No evidence of slope instability Areal extent ______ Remarks----.:.=..:.=.:..:.:=======================----1

H. Benches Applicable 00 N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to slow down the velocity of surface runoff and intercept/convey runoff)

1. Flows Bypass Bench - Location shown on site map 00 N/ A or okay Remarks

----.::..:.=:::..:.:..:::===================~

6

-------

2.

3.

C.

I.

3.

5.

6.

Location shown on site map Areal extent Remarks

Bench Breached . Location shown on site map IRl NIA or okay Remarks

Bench Overtopped Location shown on site map IRl NIA or okay Remarks

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

Settlement Location shown on site map No evidence of settlement Areal extent Depth Remarks

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

Erosion Location shown on site map _ No evidence of erosion Areal extent Depth Remarks

t;ndercutting Location shown on site map .. No evidence of undercutting Areal extent Depth Remarks

()bstructions Type: Size IRl No obstructions Location shown on site map Areal extent

R'emarks

Excessive Vegetative Growth xIRl

Type

No eVidence of excessive growth VegetatIOn In channels does not obstruct flow

D. CO\ ('r Penetrations IRl Applicable N/A

I. Gas Vents IRl Active Passive

IRl Properly secured/locked IRl Functioning IRl Routinely sampled IRl Good condition Evidence of leakage at penetration . Needs Maintenance .. NIA

Remarks: ISVE/AIR SPARGING WELLS. PHASE III PORTION OF REMEDY.

-, Gas Monitoring Probes IRl Properly secured/locked IRl Functioning IRl Routinely sampled IRl Good condition

Evidence ofleakage at penetration - Needs Maintenance N/A

Remarks: ISVE/AIR SPARGING WELLS. PHASE III PORTION OF REMEDY.

Monitoring Wells (within surface area of laOOfi.U SITE) IRl Properly secured/locked IRl Functioning IRl Routinely sampled IRl Good condition

Evidence of leakage at penetration ::: Needs Maintenance ~ N/A Remarks:----.:..::.::::.:.:.::::.-========================================================---1

4. Leachate Extraction Wells Properly secured/locked Functioning .. Routinely sampled .. Good condition

Evidence of leakage at penetration _ Needs Maintenance IRl N/A Remarks

Settlement Monuments Located Routinely surveyed IRl N/A

Remarks

7

-6-.-- Purge Water Infiltration Well [8] Located Routinely surveyed - N/A Remarks: THERE IS AN INFILTRATION WELL NEAR ISVE BUILDING B THAT RECEIVES PURGED GROUNDWATER FROM THE SITE'S MONITORING WELLS AND RETURNS[

___...:T:::H::A:::T::::::W:::A:::T::E:::R=B=A::::C::K=IN:::T:::O=T:::H=:E::A=O=U=IF:::E::R::(=:T::O=B::E=C::O::L::L::E::C:::T::E::D=B:::Y=T::H:::E=G::::W:::E:::T::S=)::'=--_...J

'IS Collection and TreatmentE. G.

1.

[8] Applicable N/A PHASE III (lSVE/AS) OF REMEDY --

Gas Treatment Facilities Flaring Thennal destruction - Collection for reuse

[8] Good condition Needs Maintenance

Remarks: VAPOR PHASE GRANULATED ACTIVATED CARBON UNIT {VPGAC}

2. Gas Collection Wells, Manifolds and Piping [8] Good condition Needs Maintenance N/A

Remarks -­

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) Good condition Needs Maintenance [8] N/A

Remarks

F. Conr Drainage Layer. Applicable [8] N/A --

I. Outlet Pipes Inspected . Functioning N/A Remarks

2. Outlet Rock Inspected Functioning - N/A

Remarks

G, Detention/Sedimentation Ponds Applicable [8] N/A

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

Remarks

2. Erosion . Erosion not evident N/A

Areal extent Depth

Remarks

3. Outlet Works =- Functioning N/A

Remarks

4. Dam - Functioning N/A

Remarks

H. Re taining Walls Applicable [8] N/A

Deformations _ Location shown on site map Deformation not evident Horizontal displacement Vertical displacement Rotational displacement

Remarks

Degradation -:: Location shown on site map - Degradation not evident

Remarks

-­

8

I. Perimeter Ditches/Off-Site Discharge Applicable I1SJ N/ A

I. Siltation Location shown on site map Siltation not evident Areal extent______ Depth_____ Remarks

---.--=-:..:..:.:..:=.:..::======================-~ 2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow Areal extent Type_____ Remarks

3. Erosion Location shown on site map _ Erosion not evident Areal extent______ Depth_____ Remarks

4. Discharge Structure Functioning _ NIA Remarks ___....::....:...:~...::::::=====================-----l

--------------------------------------------------------------------------------~ VIII. VERTICAL BARRIER WALLS Applicable I1SJ N/A

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

---===========================================================-----1

I. Settlement Location shown on site map Settlement not evident Areal extent Depth_____

Remarks

2. Performance Monitoring

Type (If monitoring: _______________ _ Performance not monitored Frequency: Evidence of breaching Head differential: ____________

Remarks --.~========================================================-_---I

1.

IX. GROllNDWATER / SURFACE WATER REMEDIES I1SJ Applicable N/A

[8] Applicableundwater E'{traction Wells, Pumps. and Pipelines A. Gro N/A

Pumps, Wellhead Plumbing. and Electrical I1SJ Good condition I1SJ Wells properly operating Need Maintenance

Remarks:

Extraction System Pipelines. Valves, Valve Boxes, and Other Appurtenances [8] Good condition Need Maintenance NA

NA

Remarks: MAGNETIC FLOW METERS AT INFLUENT OF TREATMENT BUILDING. --- _

3. Leak Detection. Alarm and Notification Systems [8] Good condition I1SJ Functional Need Maintenance - NA

Remarks: GWETS SYSTEM INCLUDES AN "AUTO-DIALER" FOR NOTlFlCATlON OF1, SYSTEM OPERATORS DURING "OFF" HOURS.

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

4. Spare Parts and Equipment I]J Readily available [8] Good condition Require upgrade Resource is Absent Remarks: LOCAL WELL DRILLING CONTRACTOR (STEARNS DRILLING) IS ,<\VAILABLE "ON CALL" AND HAS ALL THE RESOURCES NEEDED FOR REPAIR.

L_________________--' 9

B. Surf:Ice Water Collection Structures, Pumps. and Pipelines Applicable [8] N/A

I. Collection Structures, Pumps, and Electrical

Good condition =- Functional Remarks:

Need Maintenance [8] NA

. 2.

I--

Surface Water Collection System Pipelines. Valves. Valve Boxes. and Other Appurtenances Good condition Functional Need Maintenance [8] NA

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Require upgrade _ Resource is Absent Remarks:

C. Trea tment System [8] Applicable N/A

I. Treatment Train (Check components that apply) ; removal [8] Oil/water separation * Ippmg [8] Carbon adsorbers

rs: ** PALL CARTRIDGE FILTERS (4 FILTERS}

Metal~

A ir SIT

[8] Fil:e Addili Othf'l'~

ve (e.g. chelation agent. flocculent)

~ Bioremediation

1:Rl GOCi(I condition Needs Maintenance

1:Rl SaInrlling ports properly marked and functional

1:Rl SaInrlling/maintenance log displayed and up to date * PROVIDED UNDER SEPARATE COVER 1:Rl Equil)ment properly identified

1:Rl Quantity of groundwater treated annually: BETWEEN 85 AND 95 GALLONS PER MINUTEI RECENTLY IMPROVED TO 110 -115 GPM.

Quanti'ty of surface water treated annually: NOT APPLICABLE Remarks : * SEPARATOR WAS AN LNAPL SKIMMERI WHICH WAS DISCONTINUED IN 2004.

** PALL FILTERS WERE DISCONTINUED IN 1999.

Electrical Enclosures and Panels (properly rated and functional) Good ( :ondition Needs Maintenance N/A

Remarks: ELECTRICAL INSPECTIONS AND PREVENTIVE MAINTENANCE IS DONE ON AN "AS

NEEDED" BASIS.

Tanks, Vaults, Storage Vessels [8] Good condition Proper secondary containment * Needs Maintenance: NIA Remarks : BACKWASH STORAGE TANKI EFFLUENT STORAGE TANKI SUMP PITI CARBON

VESSELS. *SECONDARY CONTAINMENT IS NOT REQUIRED.

.;. Discharge Structure and Appurtenances [[I Good condition Needs Maintenance: N/A Remark~ OUTFALL STRUCTURE AT BLACK CREEK IS IN GOOD CONDITION.

Treatment BuiJding(s) [[I Good condition (esp. roof and doorways) Needs repair =- N/A [[I Chem icals and equipment properly stored * Remarks NO TREATMENT CHEMICALS ARE STORED ON SITE. A SMALL AMOUNT OF

FLAMMABLES ARE STORED IN AN ADEQUATE FLAMMABLES CABINET. OTHERWISE

VERY GOOD HOUSEKEEPING.

10

-----

-------------------------------------------------------------

----------------------------------------------------------------------------, 6. Monitoring Wells (pump and treatment remedy) [8] Pror·erly secured/locked [8] Functioning [8] Routinely sampled [8] Good condition [8] All required wells located* Needs Maintenance N/A Remark,: LOCATIONS AND MEASUREMENTS OF ALL REQUIRED WELLS WERE DOCUMENTED

IN THE ANNUAL GROUNDWATER MONITORING REPORTS FROM 2004 TO 2009.

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

-----------------------------------------------------------------------------,D. MOil ito ring Data

I. Monitoring Data [RJ Is J"tJutinely submitted on time [8] Is of acceptable quality *

Remarks: *CONSIDERATION OF AN EQUIVALENCE DEMONSTRATION BETWEEN LOW-FLOW PUR(~l'lG AND PASSIVE DIFFUSION BAG SAMPLING METHODS IS CURRENTLY UNDERWAY.

) Monitoring data suggests: IKI Groundwater plume is effectively contained * [RJ Contaminant concentrations are declining

Remarks: *CAPTURE ZONE ANALYSIS IS CURRENTLY UNDERWAY. GWETS OPERATIONS ARE .F0LL!]WING THE REQUIRED MINIMUM EXTRACTION RECOMMENDATION FROM 2002-03. ~COMPARISON OF GROUNDWATER CHEMICAL ANALYSIS DATA SINCE 1991 HAS SHOWN A ~~ENEBAL DECREASE IN THE CONCENTRATIONS OF CONTAMINANTS IN GROUNDWATER.

---------------------------------------------------------------------------, E. Monitored Natural Attenuation Applicable [8] N/A----------------------------------------------------------------------------4 I. Monitoring Wells (natural attenuation remedy)

Properly secured/locked _ Functioning .. Routinely sampled Good condition All required wells located ~ Needs Maintenance N/A

Remark~

X. OTHER REMEDIES_. Ifthere are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor {~xtraction.

r'

X. I'll-SITU VAPOR EXTRACTION AND AIR SPARGING SYSTEM [RJ Applicable N/A

r' A. Vapor Extraction and Air Sparging Wells and Pipelines [RJ Applicable _ N/A

r-' I. Pumps. Wellhead Plumbing. and Electrical

Extraction System Pipelines. Valves, Valve Boxes, and Other Appurtenances

[RJ Good condition [8] Wells properly operating Need Maintenance NA

Remarks: r- ­-~ .

[RJ Good condition Need Maintenance NA

Remarks: '--.----­

11

________ _

Leak Detection, Gas Flow Measurement, Alarm and Notification Systems [RJ Good condition [RJ Functional =- Need Maintenance NA

Remarks: THE ISVE SYSTEM IS CONTROLLED BY A PROCESS COMPUTER LOCATED IN A WEATHER PROOF CABINET INSIDE THE HEATED BUILDING B. THE OPERATIONS OF THE ISVE SYSTEM CAN BE MONITORED AND CONTROLLED REMOTELY BY DIGITAL SATELLITE.

4. Spare Parts and Equipment [RJ Readil) available [RJ Good condition Require upgrade Resource is Absent Remarks: VENDORS AND REPAIR CONTRACTORS' CONTACT INFORMATION IS LOCATED IN OPERATION AND MAINTENANCE DOCUMENTATION ON SITE.

B. Condensate Collection Structures, Pumps. and Pipelines Applicable [RJ N/A

Collection and Cleanout Structures, Pumps, and Electrical [RJ Good condition Functional Need Maintenance [RJ NA Remarks:

" Condensate Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances [RJ Good condition _ Functional =- Need Maintenance NA Remarks: ALL PIPING IS UNDERGROUND UNTIL IT REACHES THE HEATED BUILDING BI WHICH IS THE ONLY ABOVE-GROUND LOCATION. THEREFORE CONDENSATE ONLY OCCURS AT THE COLLECTION POINT INSIDE BUILDING B.

Spare Parts and Equipment

[RJ Readily available Good condition Require upgrade Resource is Absent Remarks: THE COMPONENT THAT NEEDS THE MOST MAINTENANCE IS THE AIR COMPRESSORI FOR WHICH A SERVICE CONTRACT EXISTS. ALL OTHER COMPONENTS HAVE REPAIR POINTS OF CONTACT AS NOTED IN X.A.4 ABOVE.

C. Trca tment System [&] Applicable N/A

I. Treatment Tram (Check components that apply) Metals removal - Oil/water separation . Bioremediation Air stripping [&] Carbon adsorbers Filters:

Additive (e.g, chelation agent, flocculent)

---------------~-------------------------~ I. Treatment Train (Continued)

[8] Othns: CAT-OX UNIT. UNIT'S OPERATION WAS DISCONTINUED IN 20041 BUT ALL CAT-OX E UlPMENT REMAINS IN GOOD CONDITION.

12

----

----

[8] Others: PARTICULATE AIR FILTER AF-IC; AIR COMPRESSOR AC-l; PARTICULATE AIR FILTER PAF-l; OIL COALESCING AIR FILTER OCF-l; AUTO DRAINS ADT-l, 2, 3; AIR RECEIVER RAC-l; PARTICULATE AIR FILTER (AMBIENT AIR) AF-IB, 2B, 3B;

BLOWERS; B-1, 2, 3; AIRIWATER SEPARATORS AWS-l, 2, 3; PARTICULATE AIR FILTERS; AF-l,2,3j VP-GAC UNIT GAC-lj CAT-OX UNIT CAT-OX-lj AIR DRYER DR-I.

[8] Good condition Needs Maintenance [8] Sampling ports properly marked and functional [8] Sampling/maintenance log displayed and up to date * PROVIDED UNDER SEPARATE COVER [8] Equipment properly identified [8] Quantity of soil vapor treated annually: APPROX. BETWEEN 1.5 AND 17 LBSI MONTH

Remarks: SYSTEM OPERATES AT THE FOLLOWING APPROXIMATE GAS FLOW RATES:

.ZONE A: APX. 600 TO 670 CU. FT. PER MINUTEj ZONE B: APX. 1000 TO 1100 CU. FT. PER MIN,j

.ZONE C: APX. 400 TO 460 CU. FT. PER MIN. THE ISVE/AS SYSTEM IS CURRENTLY Qf.[E..<\ TING IN PULSED MODE.

2. Electrical Enclosures and Panels (properly rated and functional) [R] Good condition Needs Maintenance N/A Remarks: ELECTRICAL INSPECTIONS AND PREVENTIVE MAINTENANCE IS DONE ON

AN "AS NEEDED" BASIS. ISVE BUILDINGS A, B, AND C ARE OF EXPLOSION PROOF

RATING WHERE EXTRACTED CONTAMINANT VAPOR IS COLLECTED, AND HAS

POSITIVE AIR PRESSURE WHEREVER PERSONNEL MAYBE WORKING INDOORS FOR

EXTENDED PERIODS.---..::::::::===:::::::::::===========================================--­.3. Tanks, Vaults, Storage Vessels

[R] Good condition Proper secondary containment * Needs Maintenance NIA Remarks: SEE ABOVE LIST. *SECONDARY CONTAINMENT IS NOT REQUIRED.

---..:.:.:::..::::..:::~===========:::::::::::==::::::::::::====:::::::::::=========~::::::::::====--4. Discharge Structure and Appurtenances

[8] Good condition _ Needs Maintenance N/A Remarks: TREATED VAPOR/AIR EMISSION DISCHARGE STACK.

s. Treatment Building(s) [R] Good condition (esp. roof and doorways) Needs repair - N/A

Chemicals and equipment properly stored * Remarks: NO TREATMENT CHEMICALS ARE STORED ON SITE. ISVE/AS BUILDINGS A,

B, AND C ARE ALL IN GOOD CONDITION.

6. ISVE/AS Wells [8] Properly secured/locked [8] Functioning [8] Routinely sampled * Good condition

All required wells located _ Needs Maintenance N/A Remarks: VAPOR IS SAMPLED AT INFLUENT POINTS IN BUILDINGS A BAND C. ~ D. Monitoring Data

I. Monitoring Data Is ro'Jtmely submitted on time [8] Is of acceptable quality *

. Remarks: AS MEASURED AT INFLUENT AND EMISSION POINTS IN ISVE BUILDING(S).

" Monitoring data suggests: Groundwater plume is effectively contained * [8] Contaminant concentrations are declining

Remarks: CONTAMINANT VAPOR HAS BEEN SUCCESSFULLY EXTRACTED BY THE PHASE III ~;YSTI~~, AS DEMONSTRATED BY THE DECREASES SHOWN IN THE PAST 10 YEARS' DATA.

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XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describt~ issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a b rief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.).

SEE SECTIONS 4.224.4272 AND 8 OF THE FIVE YEAR REVIEW REPORT.

B. Adequacy of O&M

Descrih(! issues and observations related to the implementation and scope ofO&M procedures. In particular. discuss t heir relationship to the current and long-term protectiveness of the remedy.

CTIONS 4.42 72 AND 8 OF THE FIVE YEAR REVIEW REPORT.

c. Early Indicators of Potential Remedy Problems

Describ(~ issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of Jnschf"d Llled repairs that suggest that the protectiveness of the remedy may be compromised in the future.

CTiON 7 OF THE FIVE YEAR REVIEW REPORT.

.. 11). OpportuDltles for OptimizatIOn

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

~;;EE SECTION 7 OF THE FIVE YEAR REVIEW REPORT.

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