u s EPA RECORDS CENTER REGIONUS EPA RECORDS CENTER REGION 55

111111111111 11111 11111 11111 1111111111111 442034442034

FIVE-YEAR REVIEW REPORT FORFIVE-YEAR REVIEW REPORT FOR SPARTAN CHEMICAL COMPANY SUPERFUND SITESPARTAN CHEMICAL COMPANY SUPERFUND SITE

WYOMING, KENT COUNTY, MICHIGANWYOMING, KENT COUNTY, MICHIGAN

^^L PRO^^"^

Prepared byPrepared by

U.S. Environmental Protection AgencyU.S. Environmental Protection Agency Region 55Region

Chicago, IllinoisChicago, Illinois

Date:Approved by:Approved by: Date:

c ~Q3B,?r mi iz^ ETchardU. Karl, Director

Superfund DivisionSuperfund Division

TABLE OF CONTENTSTABLE OF CONTENTS

List of Abbreviations 44

Executive Summary 55

List of Abbreviations

Executive Summary

Five-Year Review Summary Form 66Five-Year Review Summary Form

I.I. IntroductionIntroduction 88

II.II. Site ChronologySite Chronology 99

III.III. BackgroundBackground 1010 Physical CharacteristicsPhysical Characteristics 1010 Land and Resource UseLand and Resource Use 1010 History of ContaminationHistory of Contamination 1010 Initial ResponseInitial Response 1111 Basis for Taking ActionBasis for Taking Action '" 1212

IV.IV. RemedialRemedial ActionsActions 1212 Remedy SelectionRemedy Selection 1212 Remedy ImplementationRemedy Implementation 1414 Institutional ControlsInstitutional Controls 1414 System and MaintenanceSystem Operations/OperationOperations/Operation and Maintenance 1515

V.V. Progress Since Last ReviewProgress Since Last Review 1616

VI.VI. Five-Year Review ProcessFive-Year Review Process 1616 Administrative ComponentsAdministrative Components 1616 Community Notification and Involvement.Community Notification and Involvement 1616 Document ReviewDocument Review 1616 Data ReviewData Review 1717 Site InspectionSite inspection 1717

VII.VII. Technical AssessmentTechnical Assessment 1717 QuestionQuestion A; Is the remedy functioning as intended by tfie decision documents ?A: Is the remedy functioning as intended by the decision documents? 1717 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives usedaction objectives used at the time of the remedy selection still valid?at the time of the remedy selection still valid? 1818 Question B: Are ttie exposure assumptions, toxicity data, cleanup levels, and remedial

Question C: Has any other information come to light that could call into questionQuestion C: Has any other Information come to light that could call into question the protectiveness of the remedy?the protectiveness of the remedy? 1818 Technical Assessment SummaryTechnical Assessment Summary 1818

VIII.VIII. IssuesIssues 1818

IX.IX. RecommendationsRecommendations and Follow-Up Actionsand Follow-Up Actions 1919

X.X. Protectiveness Statement(Protectiveness Statement(s)s) 1919

22

XI.XI. Next ReviewNext Review 1919

FiguresFigures

Figure Spartan Chemical Company site location Figure Spartan Chemical Company property and surrounding area Figure Southeastern portion of the Spartan Chemical Company Site, adjacent school

property to the east, site fence, and excavation plans Figure Spartan Chemical Company Site, groundwater contamination

Figure 11 -- Spartan Chemical Company site location Figure 22 -- Spartan Chemical Company property and surrounding area Figure 33 -- Southeastern portion of the Spartan Chemical Company Site, adjacent school

property to the east, site fence, and excavation plans Figure 44 -- Spartan Chemical Company Site, groundwater contamination

TablesTables

Table Chronology of Site Events Table Institutional Controls SummaryTable IssuesTable Recommendations and Follow-Up Actions

Table 11 -- Chronology of Site Events Table 22 -- Institutional Controls Summary Table 33 -- Issues Table 44 -- Recommendations and Follow-Up Actions

15 18 19

99 15 18 19

AttachmentsAttachments

Attachment Site Inspection ChecklistAttachment 11 -- Site Inspection Checklist

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ASAS

ASfSVEAS/SVE

BTEX BTEX

CERCLA CERCLA

C.F.R.C.F.R.

FSFS

EPAEPA

ESD ESD

ICsICs

MDEQ MDEQ

MDNRMDNR

NCPNCP

RI/FS RifFS

ROD ROD

SVE SVE

USTsUSTs

UUfUEUU/UE

VOCsVOCs

LIST OF ABBREVIATIONS LIST OF ABBREVIATIONS

Air Sparging Air Sparging

Air SpargingfSoil Vapor Extraction Air Sparging/Soil Vapor Extraction

Benzene, Toluene, Ethylbenzene, and Xylene (collectively) Benzene, Toluene, Ethylbenzene, and Xylene (collectively)

Comprehensive Environmental Response, Compensation, and Liability Comprehensive Environmental Response, Compensation, and Liability Act of 1980Act of 1980

Code of Federal Regulations Code of Federal Regulations

Feasibility Study Feasibility Study

U.S. Environmental Protection Agency u.S. Environmental Protection Agency

Explanation of Significant Differences Explanation of Significant Differences

Institutional Controls Institutional Controls

Michigan Department of Environmental Quality Michigan Department of Environmental Quality

Michigan Department of Natural Resources Michigan Department of Natural Resources

National Contingency Plan National Contingency Plan

RemediallnvestigationfFeasibility Study Remedial Investigation/Feasibility Study

Record of Decision Record of Decision

Soil Vapor Extraction Soil Vapor Extraction

Underground storage tanks Underground storage tanks

Unlimited Use/Unrestricted Exposure Unlimited Use/Unrestricted Exposure

Volatile Organic Compounds Volatile Organic Compounds

4

EXECUTIVE SUMMARYEXECUTIVE SUMMARY

The Michigan Department of Environmental Quality (MDEQ) is the lead technical agencyThe Michigan Department of Environmental Quality (MDEQ) is the lead technical agency at the Spartan Chemical Company Site. The U.S. Environmental Protection Agency (EPA) isat the Spartan Chemical Company Site. The U.S. Environmental Protection Agency (EPA) is the support agency for this project. An interim Record of Decision (ROD) was issued in 1993 forthe support agency for this project. An interim Record of Decision (ROD) was issued in 1993 for groundwater, designated in this report as the groundwater operable unit or operable unitgroundwater, designated in this report as the groundwater operable unit or operable unit 22 (0U2). second interim ROD was issued in 1998 for soils, designated in this report as the soils(OU2). AA second interim ROD was issued in 1998 for soils, designated in this report as the soils operable unit or operable unit 11 (OU1). AA ROD addressing both soils and groundwater wasoperable unit or operable unit (0U1). ROD addressing both soils and groundwater was subsequently issued in 2007. The remedy selected in the 2007 ROD is expected to be the finalsubsequently issued in 2007. The remedy selected in the 2007 ROD is expected to be the final remedial action at the site.remedial action at the site.

The interim groundwater remedy selected in the 1993 ROD was never implemented dueThe interim groundwater remedy selected in the 1993 ROD was never implemented due to the disposal location for treated groundwater not being accepted by the local municipality,to the disposal location for treated groundwater not being accepted by the local municipality, and no other viable disposal location was available. Construction of soil vapor extractionand no other viable disposal location was available. Construction of aa soil vapor extraction (SVE) system pursuant to the 1998 ROD began in September 1999. However, operation of the(SVE) system pursuant to the 1998 ROD began in September 1999. However, operation of the SVE system was terminated in 2005, as removal efficiency had declined until contaminantsSVE system was terminated in 2005, as removal efficiency had declined until contaminants were no longer being removed. Although actions taken pursuant to the 1993 and 1998 RODs,were no longer being removed. Although actions taken pursuant to the 1993 and 1998 RODs, did not fully remediate the site, more than 20,000 pounds of volatile organic compounds (VOCs)did not fUlly remediate the site, more than 20,000 pounds of volatile organic compounds (VOCs) were removed by the SVE system under the 1998 ROD.were removed by the SVE system under the 1998 ROD.

The final site-wide remedy for soils and groundwater selected by the 2007 ROD, whichThe final site-wide remedy for soils and groundwater selected by the 2007 ROD, which effectively replaced the remedies selected in the two interim RODs, is currently being designed.effectively replaced the remedies selected in the two interim RODs, is currently being designed. Completion of the design is expected by December 2012. Both the remedial design and theCompletion of the design is expected by December 2012. Both the remedial design and the remedial action at the Spartan Chemical Site are state-lead, fund-financed actions. The start ofremedial action at the Spartan Chemical Site are state-lead, fund-financed actions. The start of the remedial action is dependent upon the availability of federal funding.the remedial action is dependent upon the availability of federal funding.

AA protectiveness determination for the site cannot be made until further information isprotectiveness determination for the site cannot be made until further information is obtained. There are no current human exposures to contaminated soils or groundwater, butobtained. There are no current human exposures to contaminated soils or groundwater, but vapor intrusion has not been fully investigated. MDEQ is currently evaluating the potential forvapor intrusion has not been fully investigated. MDEQ is currently evaluating the potential for vapor intrusion at nearby businesses and residences. protectiveness determination will bevapor intrusion at nearby businesses and residences. AA protectiveness determination will be made after those investigations are complete. MDEQ's vapor intrusion investigations aremade after those investigations are complete. MDEQ's vapor intrusion investigations are expected to be completed by December 2012, and EPA expects to make protectivenessexpected to be completed by December 2012, and EPA expects to make aa protectiveness determination in five-year review addendum by June 2013.determination in aa five-year review addendum by June 2013.

Long-term protectiveness of the remedy will require implementation of the remedyLong-term protectiveness of the remedy will require implementation of the remedy selected in the 2007 ROD, including compliance with effective ICs. full evaluation of ICs willselected in the 2007 ROD, including compliance with effective ICs. AA full evaluation of ICs will be conducted during design and implementation of the remedy and an IC Plan will be prepared.be conducted during design and implementation of the remedy and an IC Plan will be prepared.

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Five-Year Review Summary Form Five-Year Review Summary Form

SITE IDENTIFICATION SITE IDENTIFICATION

Site Name: Site Name: Spartan Chemical Co. Spartan Chemical Co.

EPA ID: EPA 10: MID079300125 MID079300125

Region: 5 State: Ml City/County: Wyoming / Kent

NPL Status: Final NPL Status: Final

MultipleMultiple OUs? aUs? Has the site achieved construction completion? Has the site achieved construction completion?

Yes Yes No No

REVIEW STATUS

Lead agency: MDEQLead agency: MDEQ

Author name (Federal or State Project Manager): James Hahnenberg Author name (Federal or State Project Manager): James Hahnenberg

Author affiliation:Author affiliation: EPA EPA

Review period: December 12, 2011 to September 2012 Review period: December 12,2011 to September 2012

Date of site inspection: May 1,2012 Date of site inspection: May 1, 2012

Type of review: Statutory Type of review: Statutory

ReviewReview number:number: First First

Triggering action date: September 27,1999Triggering action date: September 27, 1999

Due date (five years after triggering action date): September 27, 2004 Due date (five years after triggering action date): September 27, 2004

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Five-Year Review Summary Form (continued)Five-Year Review Summary Form (continued)

Issues/RecommendationsIssues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:DU(s) without Issues/Recommendations Identified in the Five-Year Review:

NoneNone

Issues and Recommendations Identified in the Five-Year Review:Issues and Recommendations Identified in the Five-Year Review:

DU(s): 11 && 22 Issue Category: Remedy Performance

Issue: Unknown whether vapor intrusion is an issue at nearby businesses

OU(s): Issue Category: Remedy Performance

Issue: Unknown whether vapor intrusion is an issue at nearby businesses and residencesand residences

Recommendation: Complete vapor intrusion investigations at nearbyRecommendation: Complete vapor intrusion investigations at nearby businesses and residences.businesses and residences.

Affect CurrentAffect Current Affect FutureAffect Future ImplementingImplementing OversightOversight Milestone DateMilestone Date ProtectivenessProtectiveness ProtectivenessProtectiveness PartyParty PartyParty

NoNo YesYes MDEQMDEQ EPAEPA December 2012December 2012

Protectiveness Statement(s)Protectiveness Statement(s)

Addendum Due Date:Operable Units:Operable Units: Protectiveness Determination:Protectiveness Determination: Addendum Due Date: 1&21 &2 Protectiveness DeferredProtectiveness Deferred June 30, 2013June 30, 2013

Protectiveness Statement:Protectiveness Statement: AA protectiveness determination for the site cannot be made further informationprotectiveness determination for the site cannot be made untiluntil further information isis obtained.obtained. There are no current human exposures to contaminated soils or groundwater, butThere are no current human exposures to contaminated soils or groundwater, but vapor intrusion has not been fully investigated. MDEQ is currently evaluating the potential forvapor intrusion has not been fully investigated. MDEQ is currently evaluating the potential for vapor intrusion at nearby businesses and residences. protectiveness determination will bevapor intrusion at nearby businesses and residences. AA protectiveness determination will be made after those investigations are complete. MDEQ's vapor intrusion investigations aremade after those investigations are complete. MDEQ's vapor intrusion investigations are expected to be completed by December 2012, and EPA expects to make protectivenessexpected to be completed by December 2012, and EPA expects to make aa protectiveness determination in five-year review addendum by June 2013.determination in aa five-year review addendum by June 2013.

Long-term protectiveness of the remedy will require implementation of the remedy selected in the 2007 ROD, including compliance with effective ICs. AA full evaluation of ICs will be Long-term protectiveness of the remedy will require implementation of the remedy selected in the 2007 ROD, including compliance with effective ICs. full evaluation of ICs will be conducted during design and implementation of the remedy and an IC Plan will be prepared.conducted during design and implementation of the remedy and an IC Plan will be prepared.

7

Five-Year Review ReportFive-Year Review Report

I.I. IntroductionIntroduction

The purpose of aa five-year review is to determine whether the remedy at aa site isThe purpose of five-year review is to determine whether the remedy at site is protective of human health and the environment. The methods, findings, and conclusions ofprotective of human health and the environment. The methods, findings, and conclusions of reviews are documented in five-year review reports. In addition, five-year review reports identifyreviews are documented in five-year review reports. In addition, five-year review reports identify issues found during the review, if any, and recommendations to address them.issues found during the review, if any, and recommendations to address them.

EPA prepared this five-year review pursuant to the Comprehensive EnvironmentalEPA prepared this five-year review pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) 121 and the NationalResponse, Compensation, and Liability Act of 1980 (CERCLA) §§ 121 and the National Contingency Plan (NCP). CERCLA 121 states:Contingency Plan (NCP). CERCLA §§ 121 states:

If the President selects aa remedial action that results in any hazardousIf the President selects remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the Presidentsubstances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after theshall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and theinitiation of such remedial action to assure that human health and the environment are being protectedenvironment are being protected by the remedial action being implemented.by the remedial action being implemented. InIn addition, if upon such review it is the judgment of the President that action isaddition, if upon such review it is the judgment of the President that action is appropriate at such site in with section [104] or [106], the Presidentappropriate at such site in accordanceaccordance with section [104J or [1 06J, the President shall take or require such action. The President shall report to the Congressshall take or require such action. The President shall report to the Congress aa list of facilities for which such review is required, the results of all such reviews,list of facilities for which such review is required, the results of all such reviews, and any actions taken as result of such reviews.and any actions taken as aa result of such reviews.

EPA interpreted this requirement further in the NCP at 40 C.F.R. §§ 300.430(f)(4)(ii),EPA interpreted this requirement further in the NCP at 40 C.F.R. 300.430(f)(4)(ii), which states:which states:

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

EPA Region 55 conducted aa five-year review of the remedial actions at the SpartanEPA Region conducted five-year review of the remedial actions at the Spartan Chemical Company Site in Kent County, Michigan. This statutory review was conducted fromChemical Company Site in Kent County, Michigan. This statutory review was conducted from December 9, 2011 through September 2012. This report documents the results of the review.December 9, 2011 through September 2012. This report documents the results of the review.

This is the first five-year review for the site. The triggering action for this review is theThis is the first five-year review for the site. The triggering action for this review is the start date of the interim remedial action on September 27, 1999. Statutory five-year reviews arestart date of the interim remedial action on September 27, 1999. Statutory five-year reviews are required due to the fact that hazardous substances, or contaminants remain at therequired due to the fact that hazardous substances, pollutants,pollutants, or contaminants remain at the site and are above levels that allow for unlimited use and unrestricted exposure (UUlUE).site and are above levels that allow for unlimited use and unrestricted exposure (UU/UE).

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Site ChronologyII.II. Site Chronology

Table 1: Chronology of Site EventsTable 1: Chronology of Site Events

EventEvent

Spartan Chemical operated as bulk chemical transfer, blending andSpartan Chemical operated as aa bulk chemical transfer, blending and repackaging plantrepackaging plant

Discharge of process water to groundwater by Spartan Chemical.Discharge of process water to groundwater by Spartan Chemical. Michigan Department of Natural Resources (MDNR) also reportedMichigan Department of Natural Resources (MDNR) also reported three minor chemical spills.three minor chemical spills.

Initial discovery of ground contaminationInitial discovery of ground contamination

Kent County conducts street survey to determine usage of privateKent County conducts street survey to determine usage of private residential wellswells north of areas with ground contaminationresidential north of areas with ground contamination

Spartan Chemical Company retains STS Consultants to conductSpartan Chemical Company retains STS Consultants to conduct hydrogeological investigationhydrogeoiogical investigation

Site placed on the National Priorities ListSite placed on the National Priorities List

Chemical spill (no information is available on the chemical spilled)Chemical spill (no information is available on the chemical spilled)

Groundwater treatment system installed by MDNRGroundwater treatment system installed by MDNR

Spartan Chemical Company removes underground storageSpartan Chemical Company removes 55 underground storage tankstanks (USTs) containing acetone, methyl ethyl ketone, isopropyl alcohol, and(USTs) containing acetone, methyl ethyl ketone, isopropyl alcohol, and toluenetoluene

Bankruptcy filed by Spartan Chemical CompanyBankruptcy filed by Spartan Chemical Company

Remedial investigation/feasibility study (RI/FS) released by MDNRRemedial investigation/feasibility study (RI/FS) released by MDNR

Groundwater treatment system installed in 1988 is shutdownGroundwater treatment system installed in 1988 is shutdown

Interim action ROD for groundwater remediation (OU2) issued byInterim action ROD for groundwater remediation (0U2) issued by MDNR and EPAMDNR and EPA

Explanation of Significant Differences (ESD) issued by MDNR and EPAExplanation of Significant Differences (ESD) issued by MDNR and EPA to postpone design of groundwater treatment system modificationsto postpone design of groundwater treatment system modifications

Follow-up RI issued by MDNRFollow-up Rl issued by MDNR

Focused FS for soils issued by MDNRFocused FS for soils issued by MDNR

Interim ROD for soils (OU1) issued by MDEQ and EPAInterim ROD for soils (0U1) issued by MDEQ and EPA

Construction of SVE system began pursuant to 1998 interim RODConstruction of SVE system began pursuant to 1998 interim ROD

Kent County (owner of property through tax reversion) places restrictiveKent County (owner of property through tax reversion) places restrictive covenant on the Spartan Chemical Company propertycovenant on the Spartan Chemical Company property

SVE system was shut downSVE system was shut down

ROD for final remedial action to address soils and groundwater (OU1ROD for final remedial action to address soils and groundwater (0U1 and 0U2) issued by MDEQ and EPAand OU2) issued by MDEQ and EPA

Remedial design starts for remedy selected in 2007 RODRemedial design starts for remedy selected in 2007 ROD

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DateDate

1952 to 19921952 to 1992

Prior to 1963Prior to 1963

19751975

19811981

19811981

Septembers, 1983September 8, 1983

19871987

19881988

October 11, 1989October 11, 1989

February 1992February 1992

October 1992October 1992

January 1993January 1993

June 29, 1993June 29, 1993

July 11,1995July 11, 1995

October 1996October 1996

October 1997October 1997

April 9, 1998April 9, 1998

September 27, 1999September 27,1999

October 2003October 2003

20052005

September 26, 2007September 26, 2007

Februarys, 2010February 3, 2010

BackgroundIII.III. Background

Physical CharacteristicsPhysical Characteristics

The site is aa 5-acre industrial property located at 2539 28th Street in the City ofThe site is 5-acre industrial property located at 2539 28th Street in the City of Wyoming, Michigan, approximately one block northwest of the intersection of Byron CenterWyoming, Michigan, approximately one block northwest of the intersection of Byron Center Avenue and 28" Street. The Spartan Chemical Company property is in the Grand RiverAvenue and 28th Street. The Spartan Chemical Company property is in the Grand River drainage basin and exhibits approximately 13 feet of topographic relief across the site. Sitedrainage basin and exhibits approximately 13 feet of topographic relief across the site. Site elevations range from 615 to 628 feet above mean sea level north to south across the property.elevations range from 615 to 628 feet above mean sea level north to south across the property. Local surface drainage likely drains to the low-lying area on-site with possible drainage to theLocal surface drainage likely drains to the low-lying area on-site with possible drainage to the nearby storm sewer. Roy's Creek is located approximately 800 feet west of the site. Thenearby storm sewer. Roy's Creek is located approximately 800 feet west of the site. The general site location is shown in Figure 1.general site location is shown in Figure 1.

The Michigan Department of Environmental Quality is the lead agency for this state-lead,The Michigan Department of Environmental Quality is the lead agency for this state-lead, fund-financed project. EPA is the support agency.fund-financed project. EPA is the support agency.

Land and Resource UseLand and Resource Use

The site property is comprised of approximately five acres and is bordered by schoolThe site property is comprised of approximately five acres and is bordered by aa school and residential area to the east, commercial properties to the south, and industrial properties toand residential area to the east, commercial properties to the south, and industrial properties to the north and west.the north and west. Nearby businesses/industries include metal stamping and finishing plants,Nearby businesses/industries include metal stamping and finishing plants, construction industry suppliers, former plating facility, and former paper/packaging plant.construction industry suppliers, aa former plating facility, and aa former paper/packaging plant. Figure shows the general site area and Figure shows the proximity of the school to theFigure 22 shows the general site area and Figure 33 shows the proximity of the school to the southeastern portion of the site.southeastern portion of the site.

The local area is serviced by the City of Wyoming municipal water supply and sanitaryThe local area is serviced by the City of Wyoming municipal water supply and sanitary sewer system. The municipal water supply system draws its water from Lake Michigan. Nosewer system. The municipal water supply system draws its water from Lake Michigan. No private wells are known to exist in the general vicinity of the site. Therefore, the use ofprivate wells are known to exist in the general vicinity of the site. Therefore, the use of groundwater as drinking water source is not anticipated in the future, even though the aquifergroundwater as aa drinking water source is not anticipated in the future, even though the aquifer is classified as potential drinking water aquifer.is classified as aa potential drinking water aquifer.

Based upon current zoning, nearby land use, and MDEQ discussions with countyBased upon current zoning, nearby land use, and MDEQ discussions with county officials, the anticipated future land use of the site is commerciallindustrial and the areaofficials, the anticipated future land use of the site is commercial/industrial and the area surrounding the site is anticipated to remain aa mixture of residential, commercial, and industrialsurrounding the site is anticipated to remain mixture of residential, commercial, and industrial land use.land use.

History of ContaminationHistory of Contamination

From 1952 to 1992, the Spartan Chemical Company operated as aa bulk chemicalFrom 1952 to 1992, the Spartan Chemical Company operated as bulk chemical transfer, blending, and repackaging plant. During its operation, Spartan Chemical Companytransfer, blending, and repackaging plant. During its operation, Spartan Chemical Company handled aa variety of chemicals, including aromatic solvents, naphthas, alcohols, ketones,handled variety of chemicals, including aromatic solvents, naphthas, alcohols, ketones, ethers, chlorinated solvents, and lacquer thinners. The Spartan Chemical Company filed forethers, chlorinated solvents, and lacquer thinners. The Spartan Chemical Company filed for bankruptcy in 1992, and the site has been vacant since that time.bankruptcy in 1992, and the site has been vacant since that time.

The MDEQ (formerly known as MDNR) reported that the Spartan Chemical CompanyThe MDEQ (formerly known as MDNR) reported that the Spartan Chemical Company discharged its wastewater to the groundwater prior to 1963. Groundwater contaminationdischarged its wastewater to the groundwater prior to 1963. Groundwater contamination consisting of various solvents was detected in December 1975 during dewatering operations atconsisting of various solvents was detected in December 1975 during dewatering operations at

1010

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an acijacent facility (the former Slagboom Tool && Die facility, currently Ambassador Steel,an adjacent facility (the former Slagboom Tool Die facility, currently Ambassador Steel, located immediately west of the site; see Figure 2). At that time. Spartan Chemical Companylocated immediately west of the site; see Figure 2). At that time, Spartan Chemical Company was the only known handler of solvents in the area. Specifically, the contamination includedwas the only known handler of solvents in the area. Specifically, the contamination included VOCs such as benzene, toluene, ethylbenzene, and xylene, (collectively referred to as BTEXVOCs such as benzene, toluene, ethylbenzene, and xylene, (collectively referred to as BTEX compounds), as well as various ketones and alcohols. The MDEQ also reported that plantcompounds), as well as various ketones and alcohols. The MDEQ also reported that plant personnel documented three minor chemical spills before 1963.personnel documented three minor chemical spills before 1963.

In 1981, the Spartan Chemical Company retained STS Consultants to conduct aaIn 1981, the Spartan Chemical Company retained STS Consultants to conduct hydrogeologic investigation at the site. From available information, 14 monitoring wells (OW-1hydrogeologic investigation at the site. From available information, 14 monitoring wells (OW-1 through OW-14) were installed on or north of the site and sampled in August 1981. Thethrough OW-14) were installed on or north of the site and sampled in August 1981. The analyses identified VOC contaminants, specifically methylene chloride, acetone, 1,1,1­analyses identified VOC contaminants, specifically methylene chloride, acetone, 1,1,1­trichloroethane, trichloroethylene, toluene, methyl ethyl ketone, and xylene.trichloroethane, trichloroethylene, toluene, methyl ethyl ketone, and xylene.

Initial ResponseInitial Response

On September 8, 1983, EPA added the site to the National Priorities List, making the siteOn September 8, 1983, EPA added the site to the National Priorities List, making the site eligible for further study and remediation under the federal Superfund program. The Spartaneligible for further study and remediation under the federal Superfund program. The Spartan Chemical Company signed Consent Order with the MDNR on September 20, 1984, to conductChemical Company signed aa Consent Order with the MDNR on September 20, 1984, to conduct an investigation and cleanup of contaminated groundwater originating from activities that hadan investigation and cleanup of contaminated groundwater originating from activities that had occurred at the site.occurred at the site.

The Spartan Chemical Company conducted additional investigations in 1986 as requiredThe Spartan Chemical Company conducted additional investigations in 1986 as required by the Consent Order. Nineteen new monitoring wells (OW-15 through OW-28 and MW-29by the Consent Order. Nineteen new monitoring wells (OW-15 through OW-28 and MW-29 through MW-33) and four replacement monitoring wells (MW-10, MW-11, MW-13, and MW-14)through MW-33) and four replacement monitoring wells (MW-10, MW-11, MW-13, and MW-14) were installed as part of these investigations.were installed as part of these investigations.

According to the MDNR, chemical spills were reported in 1987 and 1990. Both wereAccording to the MDNR, chemical spills were reported in 1987 and 1990. Both were aa result of overfilling of trucks. The 1987 spill was reportedly contained within secondaryresult of overfilling of tankertanker trucks. The 1987 spill was reportedly contained within secondary containment walls, and the 1990 spill (estimated at 50 gallons of solvent blend containingcontainment walls, and the 1990 spill (estimated at 50 gallons of aa solvent blend containing acetone, toluene, methyl isobutyl ketone, and cyclohexanone) was absorbed by sand andacetone, toluene, methyl isobutyl ketone, and cyclohexanone) was absorbed by sand and absorbent pads, which were removed by licensed hazardous waste hauler.absorbent pads, which were removed by aa licensed hazardous waste hauler.

An air stripping groundwater treatment system was installed at the site in 1988, but theAn air stripping groundwater treatment system was installed at the site in 1988, but the system was shut down in January 1993 because of concerns with the impact of dischargingsystem was shut down in January 1993 because of concerns with the impact of discharging treated site water to the City of Wyoming Wastewater Treatment Plant.treated site water to the City of Wyoming Wastewater Treatment Plant.

In October 1989, five underground storage tanks at the site were removed. The MDNRIn October 1989, five underground storage tanks at the site were removed. The MDNR advised Spartan Chemical Company that the soils at the UST locations needed to be addressed.addressed. However, due to company's financial constraints, no soils were removed. advised Spartan Chemical Company that the soils at the UST locations needed to be

However, due to company's financial constraints, no soils were removed.

In May 1992, EPA conducted site assessment, inclusive of groundwater sampling andIn May 1992, EPA conducted aa site assessment, inclusive of groundwater sampling and analyses, to evaluate the need for an emergency response action at the site. EPA determinedanalyses, to evaluate the need for an emergency response action at the site. EPA determined that an emergency response action was not necessary.that an emergency response action was not necessary.

1111

Basis for Taking Act ionBasis for Taking Action

The MDNR released Final Remedial Investigation/Feasibility Study SummaryThe MDNR released aa Final Remedial Investigation/Feasibility Study Summary document in October 1992. This document summarized work performed in the various previousdocument in October 1992. This document summarized work performed in the various previous investigations and provided summary of the proposed remedial action plan. This summaryinvestigations and provided aa summary of the proposed remedial action plan. This summary also indicated that the extent of soil contamination at the site was difficult to determine becausealso indicated that the extent of soil contamination at the site was difficult to determine because of limited soil sampling. It also stated that additional investigations were necessary to betterof limited soil sampling. It also stated that additional investigations were necessary to better define the boundaries of soil contamination and evaluate the potential source areas.define the boundaries of soil contamination and evaluate the potential source areas. EPA andEPA and MDNR issued an interim ROD in June 1993 to address contaminated groundwater at the site.MDNR issued an interim ROD in June 1993 to address contaminated groundwater at the site. The 1993 ROD did not address soils for the reasons described above, but required additionalThe 1993 ROD did not address soils for the reasons described above, but required additional investigations to better characterize the site, particularly focusing on potential source areas.investigations to better characterize the site, particularly focusing on potential source areas.

The additional investigation to better characterize the site was initiated in 1994, withThe additional investigation to better characterize the site was initiated in 1994, with MDNR conducting the RifFS. An RI Report was finalized in October 1996. This reportMDNR conducting the RI/FS. An Rl Report was finalized in October 1996. This report summarized investigation activities, the nature and extent of soil and groundwater contamination, and the potential risks associated with exposure to the contamination.contamination, and the potential risks associated with exposure to the contamination. MDNR summarized investigation activities, the nature and extent of soil and groundwater

MDNR completed Focused Feasibility Study Report in October 1997 that evaluated remedialcompleted aa Focused Feasibility Study Report in October 1997 that evaluated remedial alternatives for the cleanup of the contaminated soil.alternatives for the cleanup of the contaminated soil.

IV.IV. Remedial ActionsRemedial Actions

Remedy SelectionRemedy Selection

1993 Interim Record of Decision for Groundwater (OU 2)1993 Interim Record of Decision for Groundwater (OU 2)

On June 29, 1993, EPA and MDNR issued an interim ROD for remediation ofOn June 29, 1993, EPA and MDNR issued an interim ROD for remediation of groundwater at the site. The primary objectives of the interim action were to control the furthergroundwater at the site. The primary objectives of the interim action were to control the further migration of groundwater contamination off-site and to treat on-site groundwater contamination.migration of groundwater contamination off-site and to treat on-site groundwater contamination. The major components of the selected interim action included:The major components of the selected interim action included:

Evaluation of the existing groundwater collection and treatment system and of discharge•• Evaluation of the existing groundwater collection and treatment system and of discharge options available for the treated groundwater. The ROD stated that this evaluationoptions available for the treated groundwater. The ROD stated that this evaluation process may result in modifications to the existing treatment system and/or relocation ofprocess may result in modifications to the existing treatment system and/or relocation of the discharge point;the discharge point;

•• Restart of the existing groundwater collection and treatment system; andRestart of the existing groundwater collection and treatment system; and

•• Groundwater monitoring to evaluate the effectiveness of the groundwater collection andGroundwater monitoring to evaluate the effectiveness of the groundwater collection and treatment system.treatment system.

The groundwater treatment system ceased operation because the City of WyomingThe groundwater treatment system ceased operation because the City of Wyoming determined it was not acceptable for site water to be processed by its wastewater treatment system.system. Restarting the groundwater treatment system did not occur. Because the 1993 ROD determined it was not acceptable for site water to be processed by its wastewater treatment

Restarting the groundwater treatment system did not occur. Because the 1993 ROD was an interim remedial action decision document, it did not specify groundwater cleanupwas an interim remedial action decision document, it did not specify groundwater cleanup standards.standards.

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

1995 Explanation of Significant Differences (aU 2)1995 Explanation of Significant Differences (OU 2)

On July 11, 1995, EPA and MDNR issued an ESD was issued to postpone the design ofOn July 11, 1995, EPA and MDNR issued an ESD was issued to postpone the design of the groundwater treatment system modifications called for in the 1993 ROD until all source areathe groundwater treatment system modifications called for in the 1993 ROD until all source area and groundwater data could be evaluated. The 1995 ESD was issued because data collectedand groundwater data could be evaluated. The 1995 ESD was issued because data collected during the source area Rl indicated the following: the treatment system was not effective induring the source area Rl indicated the following: the treatment system was not effective in reducing the migration of contaminants and the interim action alone would not likely improve thereducing the migration of contaminants and the interim action alone would not likely improve the effectiveness of the existing treatment system nor meet this primary objective of the 1993 ROD;effectiveness of the existing treatment system nor meet this primary objective of the 1993 ROD; total capture of the plume by the system was likely not possible; aa discharge facility for thetotal capture of the plume by the system was likely not possible; discharge facility for the treated groundwater could not be found; and secondary treatment would be necessary to meettreated groundwater could not be found; and secondary treatment would be necessary to meet discharge limits. The ESD stated that the time and expense associated with completing thedischarge limits. The ESD stated that the time and expense associated with completing the design and construction work to simply return the system to operation was not warranted.design and construction work to simply return the system to operation was not warranted.

The source area data and configuration of the confining clay layer indicated that theThe source area data and configuration of the confining clay layer indicated that the existing treatment system would not sufficiently capture or contain the contaminant plume,existing treatment system would not sufficiently capture or contain the contaminant plume, based on the extent and concentrations of contamination being greater than previously known.based on the extent and concentrations of contamination being greater than previously known. Therefore, more substantial groundwater and source control measures than the systemTherefore, more substantial groundwater and source control measures than the system described in the 1993 ROD would be needed.described in the 1993 ROD would be needed.

1998 Interim Record of Decision for Soils (aU 1)1998 Interim Record of Decision for Soils (OU 1)

On April 9, 1998, EPA and MDEQ issued an interim ROD for remediation of VOC-On April 9, 1998, EPA and MDEQ issued an interim ROD for remediation of VOC­contaminated soils at the site. The selected remedy was designed to remediate soils to statecontaminated soils at the site. The selected remedy was designed to remediate soils to state generic residential cleanup criteria using the soil criteria protective of groundwater as drinkinggeneric residential cleanup criteria using the soil criteria protective of groundwater as aa drinking water source. The primary components of the remedy included the following:water source. The primary components of the remedy included the following:

•• SVE technology for remediation of the VOCs in soil; andSVE technology for remediation of the VOCs in soil; and

•• Treatment of the off-gases generated from the SVE process to meet acceptable airTreatment of the off-gases generated from the SVE process to meet acceptable air quality standards.quality standards.

As described in further detail in the "Remedy Implementation" section of this report, theAs described in further detail in the "Remedy Implementation" section of this report, the interim remedy selected in the 1998 ROD was implemented, and the SVE system operated forinterim remedy selected in the 1998 ROD was implemented, and the SVE system operated for aa few years before it was shut down in 2005.few years before it was shut down in 2005.

2007 Record of Decision Site-wide Remedy (OUs and 2)2007 Record of Decision -- Site-wide Remedy (OUs 11 and 2)

On September 26, 2007, EPA and MDEQ issued final ROD to address soils andOn September 26,2007, EPA and MDEQ issued aa final ROD to address soils and groundwater contamination at the site. The major components of the selected remedy are asgroundwater contamination at the site. The major components of the selected remedy are as follows:follows:

1. Excavation and off-site disposal of highly-contaminated soils;1. Excavation and off-site disposal of highly-contaminated soils; 2.2. ExpansionExpansion of the SVE system for mitigation of vapors from soils;of the SVE system for mitigation of vapors from soils; 3.3. AirAir sparging/SVE;sparging/SVE; 4.4. In-situ chemical oxidation;In-situ chemical oxidation; 5.5. ContingencyContingency for enhanced in-situ bioremediation (if necessary);for enhanced in-situ bioremediation (if necessary); 6.6. InstitutionalInstitutional controls restricting groundwater use and land use; andcontrols restricting groundwater use and land use; and 7. Monitored natural attenuation.7. Monitored natural attenuation.

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Remedy ImplementationRemedy Implementation

As noted earlier, the interim groundwater remedy selected in the 1993 ROD was neverAs noted earlier, the interim groundwater remedy selected in the 1993 ROD was never implemented.implemented.

Construction of the SVE system called for in the 1998 ROD for soils began onConstruction of the SVE system called for in the 1998 ROD for soils began on September 27, 1999, and was completed in the spring of 2001. The SVE system began full-September 27, 1999, and was completed in the spring of 2001. The SVE system began full­time operation in April 2003 following lengthy wastewater permit approval process. Betweentime operation in April 2003 following aa lengthy wastewater permit approval process. Between April 2003 and November 2005, the system removed more than 20,000 pounds of VOCs fromApril 2003 and November 2005, the system removed more than 20,000 pounds of VOCs from the site. Replacement of the SVE system was determined to be necessary, as the majority ofthe site. Replacement of the SVE system was determined to be necessary, as the majority of the VOC mass was removed during the first year of operation and the system efficiencythe VOC mass was removed during the first year of operation and the system efficiency decreased substantially after November 2005. Total VOC concentrations from the individualdecreased substantially after November 2005. Total VOC concentrations from the individual vapor extraction wells, based on sampling performed in November 2005, confirmed that cleanupvapor extraction wells, based on sampling performed in November 2005, confirmed that cleanup goals in the 1998 ROD were not met and would probably not be met by continued operation ofgoals in the 1998 ROD were not met and would probably not be met by continued operation of the existing system. Based on the individual well head sampling results and the VOC massthe existing system. Based on the individual well head sampling results and the vac mass removal, SVE was found to still be viable technology for the site, although adjustments wereremoval, SVE was found to still be aa viable technology for the site, although adjustments were determined to be necessary and the system would need to be replaced to be fully effective,determined to be necessary and the system would need to be replaced to be fully effective, implementable, and cost effective. The subsequent ROD in 2007 called for such improvementsimplementable, and cost effective. The subsequent ROD in 2007 called for such improvements to the SVE system, including substantially increasing the capacity of the system, and utilizing airto the SVE system, including substantially increasing the capacity of the system, and utilizing air sparging of groundwater and other technologies to meet cleanup goals at the site.sparging of groundwater and other technologies to meet cleanup goals at the site.

MDEQ is conducting the remedial design for the final remedy selected in the 2007 ROD,MDEQ is conducting the remedial design for the final remedy selected in the 2007 ROD, and completion of the remedial design is expected by December 2012. Following completion ofand completion of the remedial design is expected by December 2012. Following completion of the design, implementation of the remedial action is dependent on the availability of federalthe design, implementation of the remedial action is dependent on the availability of federal funding. Once initiated, construction of the remedy is expected to take approximately 22 years tofunding. Once initiated, construction of the remedy is expected to take approximately years to complete. Operation of the AS/SVE system will likely continue for at least five years. Thecomplete. Operation of the AS/SVE system will likely continue for at least five years. The remedy is expected to be protective upon completion.remedy is expected to be protective upon completion.

MDEQ is currently evaluating the potential for vapor intrusion at nearby businesses andMDEQ is currently evaluating the potential for vapor intrusion at nearby businesses and residences to determine whether the vapor intrusion pathway is causing people to be exposedresidences to determine whether the vapor intrusion pathway is causing people to be exposed to site-related contaminants.to site-related contaminants.

Institutional ControlsInstitutional Controls

Institutional controls (ICs) are required to ensure the protectiveness of the remedy asInstitutional controls (ICs) are required to ensure the protectiveness of the remedy as described in the 2007 ROD. ICS are non-engineered instruments, such as administrativedescribed in the 2007 ROD. ICS are non-engineered instruments, such as administrative and/or legal controls, that help minimize the potential for exposure to contamination and protectand/or legal controls, that help minimize the potential for exposure to contamination and protect the integrity of the remedy. Compliance with ICs is required to assure long-term protectivenessthe integrity of the remedy. Compliance with ICs is required to assure long-term protectiveness for any area that does not allow for unlimited use or unrestricted exposure.for any area that does not allow for unlimited use or unrestricted exposure.

owner of the Spartan Chemical Company site propertyIn October 2003, Kent County --In October 2003, Kent County owner of the Spartan Chemical Company site property through tax reversion -- implemented aa Declaration of Restrictive Covenant to restrict land andthrough tax reversion implemented Declaration of Restrictive Covenant to restrict land and groundwater use at the property. The 2007 ROD includes ICs as aa component of the site-widegroundwater use at the property. The 2007 ROD includes ICs as component of the site-wide remedy, and states that the remedy includes the continuation of the IC currently in place at theremedy, and states that the remedy includes the continuation of the IC currently in place at the site property. Additionally, the ROD states that an institutional controls plan will be preparedsite property. Additionally, the ROD states that an institutional controls plan will be prepared

1414

during remedial design for both the site and nearby impacted properties, in order to preventduring remedial design for both the site and nearby impacted properties, in order to prevent direct contact with or ingestion of contaminated soil and/or groundwater.direct contact with or ingestion of contaminated soil and/or groundwater.

Table 22 summarizes the current status of ICs at the site. As noted in the table, MDEQTable summarizes the current status of ICs at the site. As noted in the table, MDEQ and EPA are evaluating the need for ICs at the Ambassador Steel facility and other nearbyand EPA are evaluating the need for ICs at the Ambassador Steel facility and other nearby properties. As part of the implementation of the site-wide remedy, the need for additionallCsproperties. As part of the implementation of the site-wide remedy, the need for additional ICs will be determined. In accordance with the ROD, an IC Plan will be developed that will specifywill be determined. In accordance with the ROD, an IC Plan will be developed that will specify the types and details of the necessary ICs.the types and details of the necessary ICs.

Table 2.Table 2. InstitutionalInstitutional Inst i tut ional Control (IC) ObjectiveInstitutional Control (IC) Objective Title of ICTitle of IC Controls SummaryMedia, Engineered Controls, & Areas that Do Not

Controls SummaryMedia, Engineered Controls, & Areas that Do Not

Instrument Implemented or Planned

Instrument Implemented or Planned

Support UU/UE Based onSupport UUlUE Based on Current ConditionsCurrent Conditions Spartan Chemical CompanySpartan Chemical Company Prohibit unrestricted exposure to hazardous•• Prohibit unrestricted exposure to hazardous Declaration ofDeclaration of propertyproperty substances;substances; RestrictiveRestrictive

Restrict on-site groundwater use;•• Restrict on-site groundwater use; Covenant,Covenant, Restrict construction and demolition of existing•• Restrict construction and demolition of existing implemented onimplemented on

structures unless plans are submitted and approved bystructures unless plans are submitted and approved by October 7, 2003October 7,2003 MDEQ;MDEQ;

Prohibit negative impact on monitoring wells;•• Prohibit negative impact on monitoring wells; Restrict excavation or disturtsance of soils, unless•• Restrict excavation or disturbance of soils, unless

approved by MDEQ;approved by MDEQ; Indoor inhalation criteria of Part 201 should be satisfied;•• Indoor inhalation criteria of Part 201 should be satisfied;

andand Restrict activities that may interfere with response•• Restrict activities that may interfere with response

activities, including interim response, remedial action,activities, including interim response, remedial action, I

I operation and maintenance, monitoring, or otheroperation and maintenance, monitoring, or other : I

measures necessary to ensure the effectiveness andI measures necessary to ensure the effectiveness and integrity of the remedial action.integrity of the remedial action. ,

i Ambassador Steel propertyAmbassador Steel property Restrict soil excavations and building or slab demolition, ifRestrict soil excavations and building or slab demolition, if I EnvironmentalEnvironmental I and other properties (underand other properties (under requiredrequired CovenantCovenant -under- under

investigation). investigation) investigation/investigation! consideration asconsideration as

I part of site-widepart of site-wide remedyremedy

Areas of off-site groundwaterAreas of off-site groundwater Restrict off-site groundwater use. Restrict off-site groundwater use EnvironmentalEnvironmental contamination (undercontamination (under

, Covenant ­ underCovenant -- under

investigation)investigation) investigation/investigation! consideration asconsideration as

1 I part of site-widepart of site-wide

remedyremedy

System Operations/Operation and MaintenanceSystem Operations/Operation and Maintenance

The SVE system that was installed pursuant to the 1998 ROD operated for yearsThe SVE system that was installed pursuant to the 1998 ROD operated for aa fewfew years but then was shut down in 2005. There are no current systems operating at the site, and therebut then was shut down in 2005. There are no current systems operating at the site, and there are no ongoing operation and maintenance activities.are no ongoing operation and maintenance activities.

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Progress Since the Last ReviewV.V. Progress Since the Last Review

This is the first five-year review for the site, although the triggering action for this reviewThis is the first five-year review for the site, although the triggering action for this review was the initiation of the interim remedial action on September 27, 1999. From April 2003 towas the initiation of the interim remedial action on September 27, 1999. From April 2003 to November 2005, 20,070 pounds of contaminants were removed from soils at the site.November 2005, 20,070 pounds of contaminants were removed from soils at the site. Operation of the interim SVE system was terminated after November 2005 when the systemOperation of the interim SVE system was terminated after November 2005 when the system was no longer removing contamination in significant quantities. Further investigations andwas no longer removing contamination in significant quantities. Further investigations and evaluations led to the selection of final remedy for the site in 2007 ROD that addressed bothevaluations led to the selection of aa final remedy for the site in aa 2007 ROD that addressed both soils and groundwater. MDEQ began the remedial design in February 2010 is expected tosoils and groundwater. MDEQ began the remedial design in February 2010 is expected to complete the RD by December 2012.complete the RD by December 2012.

VI.VI. Five-Year Review ProcessFive-Year Review Process

Administrative ComponentsAdministrat ive Components

During December 2011, after discovering that five-year review should have beenDuring December 2011, after discovering that aa five-year review should have been conducted within five years of the initiation of the 1999 remedial action work, EPA notifiedconducted within five years of the initiation of the 1999 remedial action work, EPA notified MDEQ that it was undertaking five-year review at the site.MDEQ that it was undertaking aa five-year review at the site.

Community Notif ication and InvolvementCommunity Notification and Involvement

EPA intended to place an advertisement notice regarding the initiation of the five year­EPA intended to place an advertisement notice regarding the initiation of the five year­review process in the newspaper for public review, but due to an administrative error, the publicreview process in the newspaper for public review, but due to an administrative error, the public notice advertisement was not placed. Following the signature of this report, EPA will place aanotice advertisement was not placed. Following the signature of this report, EPA will place public notice advertisement in the newspaper regarding the completion of the five-year review.public notice advertisement in the newspaper regarding the completion of the five-year review.

Document ReviewDocument Review

EPA reviewed historical reports and recent remedial design evaluations developed byEPA reviewed historical reports and recent remedial design evaluations developed by MDEQ. The complete list of documents reviewed is as follows:MDEQ. The complete list of documents reviewed is as follows:

MACTEC Engineering and Consulting of Michigan, Inc., prepared for MDEQ,a.a. MACTEC Engineering and Consulting of Michigan, Inc., prepared for MDEQ, Spartan Chemical Company Superfund Site, AS/SVE Pilot Study Work Plan, AugustSpartan Chemical Company Superfund Site, AS/SVE Pilot Study Work Plan, August 2010.2010.

b.b. MACTECMACTEC Engineering and Consulting of Michigan, Inc., prepared for MDNR,Engineering and Consulting of Michigan, Inc., prepared for MDNR, Spartan Chemical Company Superfund Site, In-Situ Chemical Oxidation, TreatabilitySpartan Chemical Company Superfund Site, In-Situ Chemical Oxidation, Treatability Study and Pilot Test Work Plan, August 2010.Study and Pilot Test Work Plan, August 2010.

c.c. MACTECMACTEC Engineering and Consulting of Michigan, Inc., prepared for MDNR,Engineering and Consulting of Michigan, Inc., prepared for MDNR, Spartan Chemical Company Superfund Site, Remedial Design Work Plan, AugustSpartan Chemical Company Superfund Site, Remedial Design Work Plan, August 2010.2010.

MACTEC Engineering and Consulting of Michigan, Inc., prepared for MDNR,d.d. MACTEC Engineering and Consulting of Michigan, Inc., prepared for MDNR, Spartan Chemical Company Superfund Site, Vapor Intrusion Assessment Work Plan,Spartan Chemical Company Superfund Site, Vapor Intrusion Assessment Work Plan, August 2010.August 2010.

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e.e. Record of Decision, Spartan Chemical Company Superfund Site, September 26,Record of Decision, Spartan Chemical Company Superfund Site, September 26, 2007 (issued by MDEQ and EPA).2007 (issued by MDEQ and EPA).

f.f. InterimInterim Action Record of Decision for the Spartan Chemical Company SuperfundAction Record of Decision for the Spartan Chemical Company Superfund Site, Kent County, Michigan, April 9, 1998 (issued by MDEQ and EPA).Site, Kent County, Michigan, April 9, 1998 (issued by MDEQ and EPA).

Explanation of Significant Differences, Spartan Chemical Superfund Site, Wyoming,g.g. Explanation of Significant Differences, Spartan Chemical Superfund Site, Wyoming, Kent County, Michigan, July 11, 1995 (issued by MDNR and EPA).Kent County, Michigan, July 11, 1995 (issued by MDNR and EPA).

h.h. Record of Decision, Spartan Chemical, June 29, 1993 (issued by MDNR and EPA).Record of Decision, Spartan Chemical, June 29, 1993 (issued by MDNR and EPA).

Data ReviewData Review

During the five-year review, EPA reviewed pre-design data and historical data from theDuring the five-year review, EPA reviewed pre-design data and historical data from the site.site. Information reviewed was contained in the 1993 ROD, the 1998 ROD, the 2007 ROD, andInformation reviewed was contained in the 1993 ROD, the 1998 ROD, the 2007 ROD, and other documents citedother documents cited in the "Document Review" section of this report.in the "Document Review" section of this report. It should be noted thatIt should be noted that the data review conducted during this five-year review was not for the purpose ofthe data review conducted during this five-year review was not donedone for the purpose of evaluating the effectiveness of the remedy, since the remedy selected in the 2007 ROD - whichevaluating the effectiveness of the remedy, since the remedy selected in the 2007 ROD - which replaced the remedies selected in the two interim RODs - has not yet been implemented.replaced the remedies selected in the two interim RODs - has not yet been implemented.

Site InspectionSite Inspection

James Hahnenberg, EPA remedial project manager, conducted aa site inspection on MayJames Hahnenberg, EPA remedial project manager, conducted site inspection on May 1, 2012. representative of MACTEC (MDEQ contractor) accompanied Mr. Hahnenberg.1,2012. AA representative of MACTEC (MDEQ contractor) accompanied Mr. Hahnenberg. Observations were made of site conditions and measures in place to mitigate risks (i.e., toObservations were made of site conditions and measures in place to mitigate risks (Le., to prevent public access to the site). The fencing around the site appeared secure and well­prevent public access to the site). The fencing around the site appeared secure and well­maintained. Roads on the Spartan Chemical site property are in fair condition and adequate formaintained. Roads on the Spartan Chemical site property are in fair condition and adequate for purposes of accessing different portions of the site.purposes of accessing different portions of the site.

VII.VII. Technical AssessmentTechnical Assessment

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

No. The interim groundwater remedy selected in the 1993 ROD was neverNo. The interim groundwater remedy selected in the 1993 ROD was never implemented, and the interim remedy for soils selected in the 1998 ROD operated for just fewimplemented, and the interim remedy for soils selected in the 1998 ROD operated for just aa few years before it was shut down. The site remedy selected in the 2007 ROD is currently beingyears before it was shut down. The site remedy selected in the 2007 ROD is currently being designed and will be constructed in accordance with the requirements of the ROD and designdesigned and will be constructed in accordance with the requirements of the ROD and design specifications. The remedy is expected to be protective upon completion. MDEQ is currentlyspecifications. The remedy is expected to be protective upon completion. MDEQ is currently evaluating the potential for vapor intrusion at nearby businesses and residences, and additionalevaluating the potential for vapor intrusion at nearby businesses and residences, and additional actions may be needed to address vapor intrusion, if it is occurring.actions may be needed to address vapor intrusion, if it is occurring.

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Question B: Are the exposure assumptions, toxicity data, cleanup levels,•• Question B: Are the exposure assumptions, toxici ty data, cleanup levels, and remedial act ion objectives used at the t ime o f remedy select ion s t i l land remedial action objectives used at the time of remedy selection still valid?valid?

Yes. The exposure assumptions, toxicity data, cleanup levels, and remedial actionYes. The exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of remedy selection are still valid. Site conditions are essentiallyobjectives used at the time of remedy selection are still valid. Site conditions are essentially unchanged since the 2007 ROD. More than 20,000 pounds of VOCs were removed by theunchanged since the 2007 ROD. More than 20,000 pounds of VOCs were removed by the interim SVE system installed pursuant to the 1998 ROD.interim SVE system installed pursuant to the 1998 ROD.

Question C: Has any other information come to light that could call into•• Question C: Has any other informat ion come to l ight that cou ld cal l into quest ion the protect iveness o f the remedy?question the protectiveness of the remedy?

No. At this time, nothing has come to light that would call into question theNo. At this time, nothing has come to light that would call into question the protectiveness of the planned remedy.protectiveness of the planned remedy.

Technical Assessment SummaryTechnical Assessment Summary

The final remedy is currently being designed, and will be constructed in accordance withThe final remedy is currently being designed, and will be constructed in accordance with the requirements of the 2007 ROD. The remedy is expected to be protective upon completionthe requirements of the 2007 ROD. The remedy is expected to be protective upon completion and is expected to meet the 2007 ROD cleanup standards. MDEQ is currently assessing areasand is expected to meet the 2007 ROD cleanup standards. MDEQ is currently assessing areas overlying groundwater contamination for possible vapor intrusion in nearby businesses andoverlying groundwater contamination for possible vapor intrusion in nearby businesses and residences (see Figure 4). The exposure assumptions, toxicity data, cleanup levels, andresidences (see Figure 4). The exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of remedy selection are still valid, and there is noremedial action objectives used at the time of remedy selection are still valid, and there is no other information that calls into question the expected protectiveness of the remedy.other information that calls into question the expected protectiveness of the remedy.

VIM. IssuesVIII. Issues

The final site-wide remedy selected in the 2007 ROD has not yet been implementedimplemented butThe final site-wide remedy selected in the 2007 ROD has not yet been but is expected to be protective when it is complete. As part of the design and implementation ofis expected to be protective when it is complete. As part of the design and implementation of the remedy selected in the 2007 ROD, ICs for the site property as well as all impacted off-sitethe remedy selected in the 2007 ROD, ICs for the site property as well as all impacted off-site areas will be evaluated and an IC Plan prepared.areas will be evaluated and an IC Plan prepared.

An investigation regarding possible vapor intrusion at nearby businesses and residencesAn investigation regarding possible vapor intrusion at nearby businesses and residences is currently underway. Pending the outcome of that investigation, vapor intrusion mitigationis currently underway. Pending the outcome of that investigation, vapor intrusion mitigation measures at those properties may be required.measures at those properties may be required.

Table 33 below lists the issues that were identified during this five-year review that affectTable below lists the issues that were identified during this five-year review that affect the protectiveness of the remedy.the protectiveness of the remedy.

Table 3.Table 3. IssuesIssues

IssueIssue Affects Current Protectiveness Affects Current Protectiveness

Affects Future Protectiveness Affects Future Protectiveness

Unknown whether vapor intrusion isnearby businesses and residences Unknown whether vapor intrusion is nearby businesses and residences

anan issue atissue at NoNo YesYes

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Recommendations and Follow-Up ActionsIX.IX. Recommendations and Follow-Up Actions

ecommen dd F IIT bl Recommendations o fTabla ee 44.. R dafIons anan Follow-Up actionsow-u'p ac Ions AffectsAffectsRecommendationsRecommendations Party MilestoneParty OversightOversight Milestone ProtectivenessProtectivenessIssueIssue andand DateResponsibleResponsible AgencyAgency Date

FOllow-up ActionsFollow-up Actions FutureCurrentCurrent Future

Unknown whetherUnknown whether Complete vaporComplete vapor MDEQMDEQ EPAEPA DecemberDecember NoNo YesYes vapor intrusionvapor intrusion isis intrusionintrusion 20122012 anan issue atissue at investigations atinvestigations at nearby nearby businessesnearby nearby businesses businessesbusinesses andand and residencesand residences residencesresidences

Protectiveness Statement(s)X.X. Protectiveness Statement(s)

protectiveness determination for the site cannot be made until further information isAA protectiveness determination for the site cannot be made until further information is obtained. There are no current human exposures to contaminated soils or groundwater, butobtained. There are no current human exposures to contaminated soils or groundwater, but vapor intrusion has not been fully investigated. MDEQ is currently evaluating the potential forvapor intrusion has not been fully investigated. MDEQ is currently evaluating the potential for vapor intrusion at nearby businesses and residences. protectiveness determination will bevapor intrusion at nearby businesses and residences. AA protectiveness determination will be made after those investigations are complete. MDEQ's vapor intrusion investigations aremade after those investigations are complete. MDEQ's vapor intrusion investigations are expected to be completed by December 2012, and EPA expects to make protectivenessexpected to be completed by December 2012, and EPA expects to make aa protectiveness determination in five-year review addendum by June 2013.determination in aa five-year review addendum by June 2013.

Long-term protectiveness of the remedy will require implementation of the remedyLong-term protectiveness of the remedy will require implementation of the remedy selectedselected in the 2007 ROD, including compliance with effective ICs.in the 2007 ROD, including compliance with effective ICs. full evaluation of ICs willAA full evaluation of ICs will be conducted during design and implementation of the remedy and an IC Plan will be prepared.be conducted during design and implementation of the remedy and an IC Plan will be prepared.

Next ReviewXI.XI. Next Review

The next five-year review for the Spartan Chemical Company Site is required within fiveThe next five-year review for the Spartan Chemical Company Site is required within five years of the signature date of this review.years of the signature date of this review.

1919

Figures Figures

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Figure 1. Spartan Chemical Company site location Figure 1. Spartan Chemical Company site location

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Figure 2. Spartan Chemical Company property and surrounding area Figure 2. Spartan Chemical Company property and surrounding area

Figure 3. Southeastern portion of the Spartan Chemical Company Site, adjacentFigure 3. Southeastern portion of the Spartan Chemical Company Site, adjacent school property to the east, site fence, and excavation plansschool property to the east, site fence, and excavation plans

-----IlllTE: ~lI_JN_,,",UTm. AIJ. OIEDIl._

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Figure 4. Spartan Chemical Company Site, groundwater Figure 4. Spartan Chemical Company Site, groundwater contamination contamination

AttachmentAttachment 11

Site Inspection ChecklistSite Inspection Checklist

as/fER /1'0. 9355.7-03B-POSli'ER No. 9355.7-03B-P

Please note that "O&M~' is referred to throughout this checklist. At sites where Long-TermPlease note that "O&M" is referred to throughout this checklist. At sites where Long-Term Response Actions are in progress, O&M activities may be referred to as "system operations" sinceResponse Actions are in progress, O&M activities may be referred to as "system operations'" since these sites are not considered to be in the O&M phase while being remediated under the Superfundthese sites are not considered to be in the O&M phase while being remediated under the Superfund program.program.

Five-Year Review Site Inspection Checklist (Template)Five-Year Review Site Inspection Checklist (Template)

(Working document for site inspection. Information may be completed by hand and attached to the(Working document for site inspection. Information may be completed by hand and attached to the Five-Year Review report as supporting documentation ofsite status. "NIA" refers to "not applicable.")Five-Year Review report as supporting documentation of site status. "N/A" refers to "not applicable.")

1. SITE INFORMATIONI. SITE INFORMATION

Site name: Cht ..... ,( c... \\ Date of inspection: ^Site name: <..,^ | 7 A 4 . - V A KOtut--\ et" C J ^ e ^ \ c c ^ Date of inspection: 5-/-IJ-^ " ' f JL

Location and Region: l^y£;,^-.v.v^ _ -<3 — S5 ,",-1"t>6t ^ l ' h O l ' ^ ^ O C n ^7Cj'"3 0 Oi1-SLocation and Region: Wyo....,,·.~ • tAJ" - EPAEPA10:ID:

Agency, office.Agency, office, or company leading theor company leading the five-yearfive-year Weather/temperature:Weather/temperature: C ^ . ^ ^ A '~A '(<ireview:review: U(^ <.", ~ - ~eA"t Z g . , , , ^,.... COe' \ - G loud L{,.-J f-

Remedy Includes: (Check all that apply)Remedy Includes: (Check all that apply) Landfill cover/containmentLandfill cover/containment Monitored natural attenuationMonitored natural attenuation Access controlsAccess controls Groundwater containmentGroundwater containment Institutional controlsInstitutional controls Vertical barrier wallsVertical barrier walls Groundwater pump and treatmentGroundwater pump and treatment Surface water collection and treatment Other S ^ • N( - U (il/....--f 'C ^ £. A SOEdcJ ,t>~/~ ~ I l/~-^ ^ ' P ^ l fIX y Surface water collection and treatment

~ A ,'{ G rffad teo.-, ,l.k'-~t" ."-Iu. e,A-.; ...... ( ~ I OJ.. i d u~ I'C'", Lt vV::? Q..."1L A VI' re.{ h~?! t4e ""'l'd I',;.. -+1' Other~ 6 ;c/ <5 i ^ H i^t ... ^p^< ^ ' j ' - V S ^ • t g / r /^ / ig<rf /«rc^

f/AJ(u~ LU.ft^

Attachments: Inspection team roster attached ( Site map attachea -;\Attachments: Inspection team roster attached ^Si te map attached

II. INTERVIEWS (Check all that apply)II. INTERVIEWS (Check all that apply)

1. O&M site manager A</A ;J/A WitjJ//^ NameName TitleTitle Date

I. O&M site manager N/,A / J /A Date

InterviewedInterviewed at siteat site at office by phoneby phone Phone no.Phone no.at office Problems, suggestions; Report attachedProblems, suggestions; Report attached

2.2. O&M0«&M staffstaff M/AN/A A//A ,vIA NameName TitleTitle Date

fJlA A///] Date

InterviewedInterviewed at siteat site at office by phoneby phone Phone no.Phone no.at office Problems, suggestions;Problems, suggestions; Report attachedReport attached

D-7D-7

3.

4.4.

OSWER /1'0. 9355.7-03B-POSIVER No. 9355.7-03B-P

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

et c;(. 1;4 '( recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

CYlJ: i r..;V\ ....., ......""*',AgencyAgency hh..:i..J.l· -.,. t ':2f'" \>e{)t^A ^-c^A cf ^ U\ c^^ DeVc...'f"\ ......f'• ..\ ^ContactContact ^ ^ ^ ) U edj u, ~ <>~ J / ^ . ^ / 1·, l->-V^Ao^.'tsT~~~ ^ / - ' •^ST' T) 3 / ? - " ^ / t-''''"'"'I.... U/ ^ \\,-1» >^ VV<I?&I\ 1.- t, ....... 0- J -( 1{s·, Rc 373-91.;11

Title $ f « , x j r t - f P Pnoneno. Name , Title Sft'(.~ Date Date one no. Name ,~~-+-

Problems; suggestions; Report attached Report attached N/A-Problems; suggestions; l ^ /A^

AgencyAgency Contact

NameName Title Date Phone no. Contact

Title Date Phone no. Problems; suggestions; Report attached Problems; suggestions; Report attached

AgencyAgency Contact

NameName Title Date Phone no. Contact

Title Date Phone no. Problems; suggestions; Problems; suggestions; Report attached Report attached

AgencyAgency Contact

NameName Title Date Phone no. Contact

Title Date Phone no. Problems: suggestions; Problems: suggestions; Report attached Report attached

Otber Other interviews (optional)interviews (optional) Report attached. Report attached.

h^/A IJ/A

D-8D-8

I.

2.2.

3.

4.

5.5.

6.

7.

8.

9.9.

10.JO.

OSWER IVO. 9355.7-03B-POSfVER No. 9355.7-03B-P

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

O&M Documents0<&M Documents O&M manualO&M manual Readily availableReadily available Up to dateUp to date As-built drawingsAs-built drawings Readily availableReadily available Up to dateUp to date ~ Maintenance logs

Remarks Maintenance logs

Remarks A//^¥A Readily availableReadily available Up to dateUp to date

Site-SpecificSite-Specific Health and Safety PlanHealtb and Safety Plan Readily availableReadily available Up to dateUp to date Contingency plan/emergency response planContingency plan/emergency response plan Readily availableReadily available Up to date ~Up to date

RemarksRemarks

O&M and OSHA Training Records Readily available Up to date ( W A JO&M and OSHA Training Records Readily available Up to date @ RemarksRemarks

Permits and Service Agreements Air discharge permitAir discharge permit Readily availableReadily available Up to date

Permits and Service Agreements Up to date

Eftluent dischargeEffluent discharge Readily availableReadily available Up to date ~ Up to date Waste disposal, POTW Readily available Up to dateUp to dateWaste disposal, POTW Readily available OtherOther permitspermits Readily availableReadily available Up to dateUp to date F~t)

RemarksRemarks

GasGas GenerationGeneration RecordsRecords Readily availableReadily available Up to date G0Up to date < ^ RemarksRemarks

Settlement Monument Records Readily available Up to dateSettlement Monument Records Readily available Up to date /N / ,V~ RemarksRemarks

GroundwaterGroundwater Monitoring RecordsMonitoring Records Readily availableReadily available Up to dateUp to date BRemarksRemarks

LeacbateLeacbate EitractionExtraction RecordsRecords Readily availableReadily available Up to dateUp to date 8RemarksRemarks

Discharge Compliance RecordsDiscbarge Compliance Records AirAir Readily availableReadily available Up to dateUp to date Water (eftluent)Water (effluent) Readily availableReadily available Up to date (Up to date N/^~ RemarksRemarks

Daily Access/Security Logs Readily available Up to dateDaily Access/Security Logs Readily available Up to date / N / A(3YRemarksRemarks

D-9D-9

I.I. 0&1\11 O&jyLOcgajii^tion or~n~ization

^tate in-house^~e.in-ho~ r IU"

Federal Facility in-housefederal facility in-house Other Other

., O&M Cost RecordsO&M Cost RecordsUp to date Readily available Readily available Up to date

Funding mechanism/agreement in place Funding mechanism/agreement in place Original O&M cost esfimateOriginal O&M cost estimate

IV. O&M COSTSIV. O&M COSTS

^Contractor for State) <S:ntractor for ~ Contractor tor PH Contractor tor PRJ>

Contractor for Federal Facility Contractor for federal facility

/ / y d ,JIA t^ '

Breakdown attached Breakdown attached

OSWER No. 9355.7-03B-POSIVER No. 9355.7-03B-P

Total annual cost by year for review period if available Total annual cost by year for review period if available

FromFrom ToTo Date Date Date Date Total cost Total cost

From From _To__To Date Date Date Date Total cost Total cost

From From _ T o _ To Date Date Date Date Total cost Total cost

From From _ T o _ To Date Date Date Date Total cost Total cost

From From To To DateDate DateDate Total cost Total cost

Breakdown attached Breakdown attached

Breakdown attached Breakdown attached

Breakdown attached Breakdown attached

Breakdown attached Breakdown attached

Breakdown attached Breakdown attached

3.3. LJnanticipated Unanticipated or Unusually High O&M Costs During Review Period or Unusually Higb O&M Costs During Review Period Describe costs and reasons: p /piADescribe costs and reasons: ^

V.V. ACCESS ACCESS AND INSTITUTIONAL CONTROLSAND INSTITUTIONAL CONTROLS (Applicable) N/A ~pplicabl~ N/A

A.A. Fencing Fencing

I.I. Fencing Fencing damageddamaged Remarks Remarks

-,

Location shown on site map (Gates secured)@;~ssecur~ N/ALocation shown on site map N/A

B. Otber Access Restrictions B. Other Access Restrictions

1.I. Signs Signs and other security measuresand otber security measures Remarks yc/o l/l £.-Remarks lJo V\ e.

Location shown on site map N/A Location shown on site map N/A

D-IOD-IO

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Institutional Controls (ICs)C.C. Institutional Controls (ICs)

1.1. ImplementationImplementation and enforcementand enforcement Site conditions imply ICs not properly implementedSite conditions imply ICs not properly implemented Site conditions imply ICs being fully enforcedSite conditions imply ICs notnot being fully enforced

TypeType of monitoring (e.g., self-reporting, drive by)of monitoring (e.g., self-reporting, drive by) Ci •y\ CJO) i-tc0:3 O~~~J Frequency Responsible party/agencyResponsible party/agency MM DeRFrequency Y"'-fV ()e 4,>-^-^-Wl't ^

i^C ContactContact f'-'-.f ^ a a+\ wvt^v\\,vQvw<^\ \\ \,a~& ^^t^^^^^X^M^L~~

Name .. '^/1 TitleTitleName p., lIv- tv A,

h'r"'" \ ~{date ^^&A.^O...V.*=' '<Reporting is up-to 1~ P-I •Reporting is up-to-date ~ et. ,"v Reports are verified byv the lead agencyaeencvReports are verifie dd bby ththee lealeadd agency S '

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

Report attached

2. AdequacyAdequacy RemarksRemarks

D. GeneralD. General

<6areadeq~ ICs are inadequate(iCs are adequate ICs are inadequate

Vandalism/trespassing Location shown on site map Remarks

1.I. Vandalism/trespassing Location shown on site map Remarks

.., Land use changes on site ( N / A )Land use changes on site § RemarksRemarks

3.3. Land use changes off site(^ N/ALand use changes offsit®j

OSWER No. 9355.7-03B-POSfVER No. 9355.7-03B-P

&3 N/A YesYes N/A YesYes N/A

N/A

5-/ ~/'J..<^'\-l^ DateDate

No Ye No

No No~

Qr £?) No@ No NoYesYes No

( N O vandalism evident^(No vandalism eVid~

^ilrTZ^ii '^/5 (1 "31~ "'t~~1 Phone no.Phone no.

N/AN/A N/AN/A

N/AN/A @)

N/AN/A

RemarksRemarks

A.A. RoadsRoads ApplicableApplicable

I.1. RoadsRoads damageddamaged RemarksRemarks

VI.VI. GENERAL SITE CONDITIONSGENERAL SITE CONDITIONS

N/A

Location shown on Roads adeq"3 N/A

N/A

Location shown on sitesite mapmap ^ o a d s adequat^ N/A

0-11D-11

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OSWER No. 9355.7-03B-POSWER No. 9355.7-03B-P

B. Other Site ConditionsB. Other Site Conditions

RemarksP p m a r V s

^ ^ ^ ~

VII. LANDFILL COVERS (( N / A JVIL LANDFILL COVERS ApplicableApplicable ^ N/A)

A. Landfill SurfaceA. Landfill Surface

Settlement (Low spots) Location shown on sitesite map evident 1 ^•

Areal extentAreal extent Depth 1. Settlement (Low spots) Locafion shown on map SettlementSettlement notnot evident

Depth

RemarksRemarks

2. Cracks Location shown on site map

Lengths Widths DepthsDepths

2. Cracks Location shown on site map CrackingCracking notnot evidentevident Lengths Widths

RemarksRemarks

Erosion Locafion shown on Erosion not evidentErosion not evident Areal extent Depth

3.3. Erosion Location shown on sitesite mapmapAreal extent Depth RemarksRemarks

4. HolesHoles Location shown on site map Holes not evidentHoles not evident4. Location shown on site map Areal extentAreal extent DepthDepth RemarksRemarks

5.5. Vegetative Cover Grass Cover properly established No signs of stressVegetative Cover Grass Cover properly established No signs of stress Trees/Shrubs (indicate size and locations on diagram)Trees/Shrubs (indicate size and locations on aa diagram)

RemarksRemarks

6.6. Alternative Cover (armored rock, concrete, etc.)Alternative Cover (armored rock, concrete, etc.) N/AN/A RemarksRemarks

7. BulgesBulges Location shown on map BulgesBulges notnot evidentevident7. Location shown on sitesite map Areal extentAreal extent HeightHeight RemarksRemarks

D-120-12

8.8. Wet Areas/Water DamageWet AreaslWater Damage Wet areasWet areas PondingPondineSeepsSeeps Soft subgradeSoft subgrade

RemarksRemarks

Slope Instability9.9. Slope InstabilityAreal extentAreal extent RemarksRemarks

SlidesSlides

OSWER No. 9355.7-03B-POSIVER No. 9355.7-03B-P

Wet areas/water damage not evidentWet areas/water damage not evident Location shown on site mapLocation shown on site map Location shown on sitesite mapLocafion shown on map

Location shown on site mapLocation shown on site map Location shown on site mapLocation shown on site map

Location shown on site mapLocation shown on site map

Areal extentAreal extent Areal extentAreal extent Areal extentAreal extent Areal extentAreal extent

No evidence of slope instabilityNo evidence of slope instability

B. Applicable N / A )B. BenchesBenches Applicable / N/A)~l(Horizontally constructed mounds 0 placed across aa steep landfill side slope to interrupt the slope(Horizontally constructed mounds oreafm placed across steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to aa linedin order to slow down the velocity of surface runoff and intercept and convey the runoff to lined channel.)channel.)

I.1. Flows Bypass BenchFlows Bypass Bench RemarksRemarks

2. Bench Breached2. Bench Breached RemarksRemarks

3.3. Bench OvertoppedBench Overtopped RemarksRemarks

Location shown on sitesite mapLocation shown on map

Location shown on site mapLocation shown on site map

Location shown on mapLocation shown on sitesite map

N/A or okayN/A or okay

N/A or okayN/A or okay

N/A or okayN/A or okay

C. Letdown Channels Applicable / ^ N / A \C. Letdown Channels Applicable ~ (Channel lined with erosion control matsTTiprap, grout bags, or gabions that descend down the steep(Channel lined with erosion control , nprap, 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 theside 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.)landfill cover without creating erosion gullies.)

I.I. SettlementSettlement Areal extentAreal extent RemarksRemarks

2.2. Material DegradationMaterial Degradation Material type_Material typeRemarksRemarks

3.3. ErosionErosionAreal extentAreal extent RemarksRemarks

Location shown on site mapLocation shown on site map DepthDepth

Location shown on site mapLocation shown on site map Areal extentAreal extent

Location shown on site mapLocation shown on site map DepthDepth

D-I3D-13

No evidence of settlementNo evidence of settlement

No evidence of degradationNo evidence of degradation

1

No evidence of erosionNo evidence of erosion

I

aSJFER No. 9355.7-03B-POSIVER No. 9355.7-03B-P

4. No evidence of undercuttingUndercuttingUndercutting Location shown on sitesite mapLocation shown on map No evidence of undercutting Areal extent DepthAreal extent Depth RemarksRemarks

5. Obstructions Type No obstructionsObstructions Type No obstructions Location shown on site map Areal extentLocation shown on site map Areal extent

SizeSize RemarksRemarks

Excessive Vegetative Growth Type No evidence of excessive growth

6.6. Excessive Vegetative Growth Type No evidence of excessive growth Vegetation in channels does not obstruct flowflow Location shown on sitesite mapLocation shown on map Areal _ Vegetation in channels does not obstruct

Areal extentextent RemarksRemarks

D. Cover Penetrations Applicable (N/A)D. Cover Penetrations Applicable

\. GasGas VentsVents Active ------ PassivePassive1. Active Properly secured/lockedProperly secured/locked Functioning Routinely sampled Good conditionFunctioning Routinely sampled Good condition EvidenceEvidence of leakage at penetrationof leakage at penetration Needs MaintenanceNeeds Maintenance N/AN/A

RemarksRemarks

2. Gas Monitoring ProbesGas Monitoring Probes Properly secured/lockedProperly secured/locked Functioning Routinely sampled Good conditionFunctioning Routinely sampled Good condition EvidenceEvidence of leakage at penetrationof leakage at penetration Needs MaintenanceNeeds Maintenance N/AN/A

RemarksRemarks

Monitoring Wells (within surface area oflandfill) Properly secured/lockedProperly secured/locked Funcfioning Routinely sampled Good condition

3. Monitoring Wells (within surface area of landfill) Functioning Routinely sampled Good condition

EvidenceEvidence of leakage at penetrationof leakage at penetration Needs MaintenanceNeeds Maintenance N/AN/A RemarksRemarks

4. Leachate Extraction WellsLeachate Extraction Wells Properly secured/lockedProperiy secured/locked Functioning Routinely sampled Good conditionFunctioning Routinely sampled Good condition EvidenceEvidence of leakage at penetrationof leakage at penetration Needs MaintenanceNeeds Maintenance N/AN/A

RemarksRemarks

Settlement Monuments Located Routinely surveyed N/A Remarks

5.5. Settlement Monuments Located Routinely surveyed N/A Remarks

0-14D-14

t - - ^ ;

t

| H Spartan Chemical facility

LEGEND 0 ISO 3oa 600

'MT/MCHCMCM.SITC • Feet

i n C H O M CCfMTMEMT Of NA7U«WL

f«MC»A7CM W40 f<£C)e\lLC««l£.NT CfVISlON ^MACTEC P S w . . ^ , . . . . . . » . . .

Figure 2. Spartan Chemical Company property and surrounding area Figure 2. Spartan Chemical Company property and surrounding area

1