Roto-finish Superfund Site

Interim Ground Water Extraction System During Phase HI of the RI/FS, the PRP installed a temporary ground water extraction system to remove the most contaminated ground water from the site and prevent the highest chemical concentrations from spreading. The extraction system consists of two wells pumping at 30 and 60 gallons per minute. The pumped ground water is discharged to a storm sewer and is treated at the Kalamazoo wastewater treatment plant. The ground water extraction system was installed under the oversight of U.S. EPA and MDEQ as a voluntary Non-Time Critical Removal Action. The system began operating in June 1995 and will operate until a final remedy for the site is selected and implemented. Data collected since the system began operating indicates that the two wells are pumping the ground water with highest chemical concentrations at and approximately 800 feet northwest of the Roto-Finish property. SUMMARY OF SITE RISKS The RI included a risk assessment and a ecological assessment to determine whether the chemicals detected in the ground water and the remaining soils could affect human health or the environment. The risks were evaluated considering land use and ground water use under current and potential future exposure scenarios. Soil Exposures evaluated for soil include current groundskeeper exposure to surface soil, future construction worker exposure to subsurface soil, and future industrial worker exposure to surface and subsurface soil. The results of the risk assessment indicate that none of these exposures are expected to result in any unacceptable noncancer health effects or pose any unacceptable cancer risks. Because the site is located at the end of a no-outlet street in an industrial area, is completely fenced, and is approximately 0.3 mile from the nearest residential area (located on the other side of a major street), exposure to site soils by trespassers was not considered to be as significant as the other exposures scenarios and was not evaluated separately. Ground Water The risks from ground water were calculated using data collected from the area of highest chemical concentrations, prior to the operation of the temporary ground water extraction system. Current Risks The contaminated ground water at and in a downgradient direction of the Roto-Finish site is not currently used as a drinking water supply. Therefore, the contaminated ground water does not pose any current risks to human health. Potential Future Risks Existing Wells: Although the ground water does not pose any current risks to human health, ground water modeling was used to predict contaminant concentrations and potential future risks to users of existing downgradient wells. These wells include wells that may still exist in the Fairfield residential area (currently served by the municipal water supply) and at Kalamazoo Municipal Well No. 18 (the nearest downgradient municipal well). The results of the modeling indicate that ground water contaminants would never reach Municipal Well No. 18. This is due to the process of dilution. The model did not consider additional reductions in the chemical concentrations from the microorganisms in the ground water. The modeling also indicates that, under these same assumptions, the niMinmipi risk to possible wells in the Fairfield residential area would be reached only after 65 years and would result in a maximum risk of 1 additional case of cancer for every 100,000 people similarly exposed. This risk does not exceed U.S. EPA's general risk range of 1 additional case of cancer for every 10,000 to 1 million people similarly exposed. No noncancer health effects were identified for this scenario. New Wells: The risk assessment evaluated whether the installation of new wells within the area of ground water impacts could pose a future health risk. To evaluate this future risk, the risks were calculated assuming that new municipal or industrial wells could be installed anywhere within the area of ground water impacts. Exposure was evaluated for potential future residential and industrial exposure scenarios. The results of the risk assessment indicate that exposure to impacted ground water under potential future residential and industrial exposure scenarios.

if new wells were installed, would result in noncancer health effects, and an estimated cancer risk ranging from 2 to 5 additional cases of cancer for every 100 people similarly exposed. These risks exceed U.S. EPA's general risk range. At the present time, it is unlikely that new wells would actually be installed in the area of ground water impacts, based on the availability of the existing municipal water supply and the adjacent operations of the Kalamazoo/Battle Creek International Airport, which currently limit land use and development downgradient of the site. The airport is connected to the municipal water supply, and current airport policy prohibits the installation of water wells on airport property. Ecological Soil - The ecological assessment indicates that the chemicals detected in the soils at the site are not expected to pose a significant threat to the environment. The seven-acre site is industrial and is surrounded by other industrial properties. The site is a low-quality habitat and no threatened or endangered plants or annuals were identified as likely to be present. The site is fenced and approximately 60% is covered by buildings and pavement. The remaining portions are covered with gravel, weeds and a 1/2 acre « jp i!«y lawn. While there is a potential for individual plants and animals to be exposed to the chemicals at the site, the potential for significant ecological effects to result from this exposure is limited. Ground Water - Shallow ground water may discharge to Olmstead Dram/Davis Creek or Portage Creek; however, deeper ground water is expected to flow north toward the Kalamazoo River. At the Roto-Fmish site, ground water conditions cause most of the contaminants to move into the deep ground water at the ground water flows away from the site. Because of these conditions, any ground water contaminants from the Roto-Fmish site would likely pass beneath Olmstead Drain/Davis Creek and Portage Creek, and flow toward the Kalamazoo River. If any contaminants actually did reach the Kalamazoo River, however, the concentration of the contaminants in the ground water would be so diluted that they would meet the MDEQ criteria considered to be safe for riven. YOUR OPINION COUNTS! U.S. EPA and MDEQ welcome your comments about me recommended alternative, as well as the other alternatives evaluated. Public input on the alternatives and the information that supports these alternatives is an important contribution to the remedy selection process. Based on. new information or public comment, UJS. EPA and MDEQ may preferred alternative or select another response action presented in this plan and/or the FS Report. U.& EPA will respond tCcoouneats in a document called a Responsiveness Summary, which wit be part of me final decision, called a Record Of Dectfioa (ROD). The ROD, with the reaponsryeness summary wffl be available located at the Portage Public Library. CLEANUP ALTERNATIVES The Feasibility Study (FS) identified and evaluated alternatives that could be used to address the threats and potential threats to human health posed by the contaminated ground water at the Roto-Fmish site The alternatives evaluated to address the contaminated ground water and to restore the ground water to its potential future use as a supply of municqMl and industrial drinking water are: Alternative NA - No Action Ertfanated Cost: 0 * ** " * «* Time to AcUere Cleanup Levels (Michigan Residential and Industrial Drinking Water Criteria and U.S. EPA Maximum Contaminant Levels "MCLs"): Oeanup levels would be achieved in 15 to 20 yean, but could take 50 to 60 yean depending on the rate of natural bkxtegradatkm. In the Superfund program, the no action alternative is not required to meet cleanup standards. Cleanup levels would not be met if biodegradation does not continue

The no action alternative involves no cleanup action or cleanup requirements for ground water, although site data indicate that chemical concentrations in the ground water will naturally decrease, or attenuate. and improve ground water quality over time. This is based on data that was collected before the interim ground water extraction system was installed. The actual rate of attenuation will depend upon the rate of biodegradation, the rate at which the chemicals are broken down by the microorganisms in the ground water. She-specific estimates indicate that, at current rates of biodegradation, cleanup levels would be achieved hi 15 to 20 years. At a lower rate of biodegradation, cleanup levels would be achieved in SO to 60 yean. Oeanup levels would not be achieved if biodegradation does not continue. This alternative does not include institutional controls, ground water monitoring or contingency planning. Existing institutional controls may be effective in preventing or potential future exposure to ground water, although these controls would not be required or monitored. Existing controls include the availability of the current municipal water supply; the Kalamazoo County Environmental Health Department wellpermitting process, which does not allow new wells to be installed in areas of environmental degradation; and informal airport management policy which currently prohibits the installation of water wells on airport property. The inclusion of a no action alternative is required by CERCLA to give U.S. EPA a basis for comparison. Alternative A - Hydraulic Containment of Highest Ground Water Impacts/OnSite Pumping/Ground Water Restoration (Recommended Contingency Alternative see box on page 11) Estimated Co*: 1.5 to 2.1 million Estimated Time to Achieve Cleanup Levels (Michigan Drinldnf Water Criteria and MCLs): 15 to 20 yean. May take 40 to 50 yean at lower a rate of biodegradation, or if biodegradation does not continue. Alternative A is essentially the same as the current interim ground water extraction system that was installed during Phase DI of the RI (see page 4), and includes two on-site wells to pump and contain ground water with the highest chemical concentrations at, and approximately 800 feet northwest of, the Roto-Finish property. Outside the pumped area, natural processes including biodegradation and dilution will reduce chemical concentrations to cleanup levels. Although the extraction system currently discharges the ground water to the Kalamazoo wastewater treatment plant, the final treatment and discharge options for this alternative would be developed during the remedial design based on recent cost and ground water monitoring data. Ground water modeling indicates that the cleanup time for the on-site pumping alternative will be affected by the biodegradation processes that are also occurring in the ground water. Site-specific estimates indicate that, at current rates of biodegradation, cleanup levels for the on-site pumping alternative would be achieved in 15 to 20 yean. At a lower rate of biodegradation, or if biodegradation does not continue, cleanup levels would be achieved in approximately 40 to 50 yean. The exact timeframe is wrertfin If the actual rate of biodegradation decreases, or if biodegradation does not continue, the on-site pumping system would still remove the highest levels of ground water contamination from the ground water, prevent the highest levels of ground water contamination from spreading, and achieve cleanup levels. This alternative includes institutional controls to prevent exposure to contaminated ground water until cleanup levels are achieved, monitoring programs to track and evaluate the performance of the alternative, and contingency plans that would be implemented in the event that the monitoring programs identified the need for modifications. Alternative B - Hydraulk Containment of All Ground Water Impacts/On-Site and Off-Site Pumping/Ground Water Restoration Cost: 2.0 to 3.5 million Eiirhnafrd Thne to Achieve Cleanup Levels (Michigan Drinldnf Water Criteria and MCLs): 15 to 20 yean. May take 40 to 50 yean at a lower rate of biodegradation, or if biodegradation does not continue.

Use This Space to Write Your Comments Your comments on U.S. EPA's recommended cleanup plan for the Roto-Finish site are important. Public comments assist U.S. EPA and MDEQ in selecting a final cleanup plan. You may use the space below to write your comments then fold and mail or fax to (312) 353-1155. Comments must be postmarked by November 23, 1996. If you have any questions, contact Bri Bill at (312) 353-6646 or toll free at (800) 621-8431. Comments may also be sent via Email to the following address: bill.briana@epamail.epa.gov Name Address City State Zip

ROTO-FINISH SUPERFUND SITE PUBLIC COMMENT SHEET Fold on Dashed lines, Staple, Stamp, and Mail Name. Address. City . Zap First Class BriBill Community Involvement Coordinator Office of Publk Affairs (P-19J) U.S. EPA Region 5 77 W. Jackson Blvd. Chicago, EL 60604-3590

This alternative includes ill the components of Alternative A, but adds an additional off-she well to pump and contain all ground water contaminated above cleanup levels. This alternative would pump ground water with the highest levels of contamination and extend approximately 1800 to 2500 feet northwest of the Roto-Finish property to contain all ground water contaminants. The final treatment and discharge options would be developed during the remedial design. The time to achieve cleanup levels for the on-site/off-site pumping alternative is affected by the natural biodegradation processes occurring in the ground water, and is not significantly different from estimates for the on-site pumping alternative (15 to 20 yean at current rates of biodegradation; 40 to 50 yean at a lower rate of biodegradation, or if biodegradation does not continue). If the actual rate of biodegradation decreases, or if biodegradation does not continue, the on-site/off-site pumping system would still remove all ground water contaminants with concentrations above cleanup levels from the ground water, prevent all ground water contamination from spreading, and achieve cleanup levels. Alternative B also includes institutional controls, monitoring programs and contingency plans. Alternative C - Natural Attenuation/ Ground Water Restoration (Recommended Alternative - see box on page 11) Estimated Cost: 500,000 "frfr"***** Tune to Achieve Cleanup Lerdt (Michigan Drinking Water Criteria and MCLi: 15 to 20 yean; may take 50 to 60 yean depending on the rate of natural biodegradation. If biodegradation did not continue, cleanup levels would not be achieved and a contingency cleanup plan, such as Alternative A, would be implemented. Alternative C relies on natural processes including recharge, dilution, dispersion and natural biodegradation to reduce chemical concentrations in he ground water to established cleanup levels. At the Roto-Finish site, the most significant processes are considered to be dilution and natural biodegradation. The actual rate of attenuation will depend on the rate of biodegradation. Site-specific estimates indicate that, at current rates of biodegradation, cleanup levels would be achieved in 15 to 20 yean. At a lower rate of biodegradation, cleanup levels would be achieved in 50 to 60 yean. Cleanup levels would not be met if biodegradation does not continue. Because the future rates of biodegradation may be uncertain, this alternative would require a contingency cleanup plan (such as Alternative A) to be implemented in the event that site conditions changed to the extent that natural attenuation is no longer protective. This alternative includes institutional controls to prevent exposure to contaminated ground water until the cleanup levels are achieved, monitoring programs to track and evaluate the performance of the alternative, and contingency plans that would be implemented in the event that the monitoring programs identified the need for modifications or a change in the cleanup plan. Alternative D - Physical Barriers/Ground Water Containment/Restoration Cost: 41 million Time to Achieve Cleanup Levels (Michigan Drinking Water Criteria and MCLs): 6 to 18 months to construct barrier; 10 to 15 yean to achieve cleanup levels in ground water outside containment area, depending on rate of natural biodegradation. Alternative D involves construction of a subsurface barrier to physically contain ground water with the highest chemical concentrations at and approximately 800 feet northwest of the Roto-Finish property. Natural processes including biodegradation and dilution would reduce chemical concentrations to cleanup levels outside the barrier. The physical barrier would be installed using jet grouting technology and take approximately 6 to 18 months to construct. The time to achieve cleanup levels for the ground water outside the barrier depends on the rate of natural biodegradation. Sitespecific estimates indicate that, at current rates of biodegradation, cleanup levels for ground water outside the barrier would be achieved in approximately 10 to 15 yean. At a lower rate of biodegradation, or if biodegradation does not continue, cleanup levels would be achieved in approximately 40 to 50 yean. Ground water

contaminants within the containment area may eventually attenuate to cleanup levels, depending on the rate of natural biodegradation. Institutional controls, monitoring programs and contingency plans are included with this alternative. EVALUATION OF ALTERNATIVES U.S. EPA use* the nine criteria described below to evaluate all the alternatives. An Evaluation Table comparing each alternative against these criteria is provided » page 9, Alternative E - Enhanced Biodegradation/Ground Water Restoration Prrt«tfQB of Human Health and addresses whether a remedy provides adequate protection and describes bow risks are fUiuiuatfil, reduced* or controlled "T ith treatment, engineering controls or insthotiooal controls. Estimated Cost: 4.2 million Estimated Time to Achieve Cleanup Lereb (Michigan Drinking Water Criteria and MCLs): 15 to 20 years area, depending on rate of natural biodegradation. whether a remedy will meet an other Federal and State caviwuaenuil «mote» and/or provide grounds for tavddjpg a waiver. ': -\- :,':. - This alternative is a variation of Alternative A (Hydraulic Containment of Highest Ground Water Impacts/On-Site Pumping), but adds chemical enhancements to the pumped ground water to promote the accelerated biodegradation of contaminants. After the enhancements are added, the ground water is then pumped back into the ground, not discharged into the sewer system. The chemical enhancements include nutrients and oxygen, and could even include additional microorganisms. Although this technology has been applied successfully to sites with other types of chemicals, this treatment is considered to be innovative for the chemicals at the Roto-Finish site. This alternative would require additional testing to ensure that the system is properly built and operated. theaawjMOj?risk fcaabing at a 4o» and the ability ota reawry %inalBtala of eunun ; heaulr n»lB cuiuetf over tfinc -once dopup vsjpiil ; * " : - ;; ;;; "' 45fM : - ;::v- ;t;--' wtilcb rae itaioty acokves jpcotecUoo, at wefl as the njBcdy*i poteotial to create sdvefse luiparis biring dki cuusuucDQp aoo n'nii * ! iifi !! art if ' is the lecticucat "fad fc«ibflity of a rernrdy, indodio* uwwtflabilky of ' Estimates indicate that the time

concentrations in the wells at the Roto-Finish site. This indicates that ground water beneath the airport is not as contaminated as ground water beneath, and closer to, the Roto-Finish property. Additional Phase m work to evaluate the full horizontal and vertical extent of the ground water contamination was conducted in April and May 1994.