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PB94-964139 '
EP AiROD/R05-94/266
April 1995
EP A Superfund
Record of Decision:
. I
Kent City Mobile Home'
Park, Kent City, MI' '
9/43/1994
o
Hazardous Waste Collection
Information Resource Cente
US EP A Region 3
Philadelphia, PA 19107
EP A Report Collection
Information Resource Center
US EPA Regi~n 3' -' ~ ." ~
Philadelphia,PA 19107
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(C(Q)b9J')f
KENT CITY MOBILE HOME PARK
KENT CITY, KENT COUNTY, MICHIGAN
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
AUGUST '5, '994
Prepared by:
U.S. Environmental Protection Agency
Region V
Chicago, Illinois

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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND lOCATION
Kent City Mobile Home Park. Kent City. Kent County. Michigan.
STATEMENT OF BASIS
This decision document presents the selected remedial action for the Kent City
Mobile Home Park Site in Kent City. Michigan. which was chosen in accordance
wnth the Comprehensive Environmental Response. Compensation. and Liability Act
of 1980 (CERCLA). as amended by the Superfund Amendments and
RE!8Umonzatlon Act of 1986 (SARA). and. to the extent practicable. the National
Oil ano Hazaraous Substances Pollution Contingency Plan (NCPL This decision is
based on the administrative record for the site.
The State of Michigan concurs with selection of the No Action remedy.
DESCRIPTION OF THE SELECTED REMEDY
The United States Environmental Protection Agency (U.S. EPA) has selected 8No
Action. "
DIECLARA TJON
U.S. EPA has determined that no further remedial action is necessary at this site.
Therefore. the site now qualifies for inclusion in the "sites awaiting deletion" .
subcategory of the Construction Completion category of the National Priorities list.
As this is a decision for "No Action". the statutory requirements of CERCLA
Section 121 for remedial actions are not applicable and no five year review will be
undertaken.
7' /:,-/;If

Date / ./
Z-~.J~76

Valdas V. Adamkus
Regional Administrator

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"A rURAL RESOURCES
COMMISSION
.oqJ'lV C e'&J'lrNlk
-"~J'lV DEvUv<;r
~'Ul EISE~E
,AMES P ""'l:'"
"';AVIO MOLl!
..:EV U SPA"!)
...:.~OA.N B i A ~EQ
Oi
--
--
RI02I
8/113
,-:'XiE OF MICHIGAN
1$
.JOHN ENGLER. Governor
DEPARTMENT OF NATURAL RESOURCES
'518V8N r ~ason 8u-lClna. PO 80. JOO28. ~. ...4.8909
J'lOLAND HAIIMES. Dor.."",
Mr. Valdas V. Adamkus, R-19J
Administrator, Region 5
U.S. Environmental Protection
77 West Jackson Boulevard
Chicago, IL 60604-3590
Agency
Dear Mr. Adamkus:
SUBJECT:
September 6. 1994
Kent City Mobile Home Park - Concurrence with "No Action" Remedy
The Michigan Department of Natural Resources (MDNR) has reviewed the U.S.
Environmental Protection Agency's (EPA) proposed Record of Decision (ROO) for
the Kent County Mobile Home Park site located in Kent City, Michigan.

Although the source of contamination has been removed and the water supply at
the mobile home park replaced, remaining contamination above the maximum
contaminant levels in the old water supply well warrants additional
downgradient monitoring. As long as the ROO contains provisions for
downgradient monitoring, the MDNR concurs with the "No Action" alternative
selected by the EPA.
If you have any questions, please feel free to contact Ms. Claudia Kerbawy,
Superfund Section, Environmental Response Division, at 517-335-3438, or you
may contact me.
,!!B
cc:
Ms. Rose Freeman, EPA
Ms. Betty Lavis, EPA
Mr. Rick Falardeau, MDPH
Mr. Mike lee, MDPH
Mr. Alan J. Howard, MDNR
Mr. Mike Baranoski, MDNR
Ms. Claudia Kerbawy, MDNR
Kent City Mobile Home Park file
Sincerely,

_/~ .P~
Russell J. Harding
Deputy Director
517-373-7917

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DECISION SUMMARY
I. SITE NAME. LOCATION. AND DESCRIPTION
The Kent City Mobile Home Park Site (the Site) is locatee at 135 Main Street. Kent
City, Kent County, Michigan (see Figure 1). About 75 mODIle homes are located
on the two-acre site. Approximately 3,000 people live within a three-mile radius ot
trle site. Land use to the north. west ana south at the site is mlxea agricultural
and residential; land use to the east is commercial. There are tour scnools within a
tr\ree-mile radius, though none in the immediate vicinity at the site. There is no
municipal water supply within the city limits; approximately ninety percent of the
rE!sidents use groundwater as a source of drinking water. Ball Creek drain, the
closest surface water, crosses the northeast corner of the site and flows
southeast.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
In December of 1982. the Michigan Department of Public Health (MDPH) sampled
the 65-foot deep drinking water supply well located in the mobile home park;
analysis of the samples revealed contamination with volatile organic compounds.
Under the supervision of the State of Michigan. a contractor for the present owner
of the mobile home park, Mr. David Hough, replaced the contaminated well with a
new 130-100t well five hundred feet west and upgradient of the contaminated
well. The contractor also installed four monitoring wells in the shallow aQuifer.
two of which are d~wngradient from the contaminated supply well. In October of
1983. a second on-site water supply well, 120 feet deep and with a separate
pumping system, was installed seventy-five feet west of the first replacement well
(see Figure 2 for schematic of well placement). In November of 1983, the State of
Michigan placed the Site on the Michigan Act 307 List.
As the investigation continued, the Michigan Department of Natural Resources
(MDNR) examined surface water samples from Ball Creek Drain. Contaminants
were detected, but since the contaminants, benzene. toluene. ethyl benzene and
xylene, differed from those found in the contaminated well. investigators
suspected another source off-site. A nearby gas station, Kent City Body Shop,
was implicated as the source of the creek's contaminants.
In April of 1984, investigators discovered the probable source of the groundwater
contamination at the site - a buried 55-gallon storage drum. Located approximately
20 feet from the mobile home park well and beside the park's service building (see
F:igure 2), the storage drum collected floor drainage from a dry cleaning facility that
formerly operated at the site. Samples of liQuid from the drum revealed some of
1

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~ne same cnemlC81S fauna In me contamlnatea well. Solvents Tram me arum
3Doarentlv mlgratea down tne well casmg contamInatmg me well. LJter tnat
'T1ontn. me drum ana surrounamg 5011 (which contamea trace amounts of
:etracnlorOetnylenel were removea by the oark owner under me sUDervlsion of
MONA. MONA reoons Indicate tne remaming 5011 was free of color ana odor. The
excavi3tlon Site was filled with clean sOil.
In April and May of 1984, MOPH sampled the four mOnitoring wells and twenty-
nme nearay pnvate wells. No contamination was detected in any of these wells.
The new water supply wells are sampled every three years by MDPH; results have
consistently shown no detectable contaminants.
Once the source was removed and groundwater sampling showed no evidence of
contamination, the MONR and the MDPH decided no further action was necessary
and delisted the site from their Michigan Act 307 list in November of 1985. The
U.S. Environmental Protection Agency (U.S. EPA) however. scored the site based
on contaminant levels and routes of exposure present before the removal and, on
July 21. 1987, placed it on the National Priorities List (NPL). No further activities
were undertaken by U.S. EPA until April 20. 1994, when U.S. EPA performed
another round of groundwater sampling to verify previous results.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
At this point community interest is at a minimum. No community health concerns
have been expressed to .the local health department or mobile home park
management by residents of the mobile home park or adjacent areas. No
concerns, other than the desire to have the site delisted, have been expressed to
MONR or to U.S. EPA. An information repository containing the administrative
record (AR) for the site has been established at the Kent City Library located at 43
South Main Street. in Kent City, Michigan. The AR is also available on the 7th
floor of the U.S. EPA Region 5 offices located at 77 West Jackson Boulevard in
Chicago, Illinois.
The Proposed Plan was distributed and placed in the repository on July 1, 1994.
A brief analysis of the Proposed Plan was advertised in The Soana/Kent Advance
on July 5, 1994, The Muskeoon Chronicle on July 4, 1994, and The Grand Raoids
f!nI on July 6, 1994. These publications also provided notice of the period for
submission of comments. The public comment period began July 1, 1994 and
ended August 1, 1994. A response to comments received during the comment
period is included in the Responsiveness Summary.
The public participation requirements of CERCLA sections 113 (k) (2) (B) (i-vi and
'17 have been met in the remedy seleCtion process. This decision document
2
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-20resents me seleCted remedial action Tor the r
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./
\/1. SUMMARY OF SITE RISKS
--'e o:..;roose or the riSK assessment IS to estimate me magnltL;oe aT DotennaJ riSK
. J DUDIIC ~ealtn anc the environment wnlch may De cue to eXDosure to
;:mtamlnants Icentltied at tne Site. Such assessment involves laentltVlng
:ontamlnams OT DOtentl!L concern. routes Ov which sucn contaminants may
i1lgrate. ana Dopulatlonswnicn may come Into contact with tne contaminants.
The assessment IS based on me premise that no further actions wlil be taken at the
site ana takes IntO account current site conditions.
1) Contaminants of Potentral Concern
Sampling of the old water supply weil at the Kent City Mobile Home Park
performea in December of 1982 by the Michigan Department of Public Health.
'evealed the presence of voiatile organic compounds (VOCs), These results are
snown In Table 1 in parts per Dillion (ppb):
Tab~e 1
Old Water Supply fiell SlUIp~iz1q Resul.ts
Dec8Jllber 1982
COMPOUNDS
Carbon tetrachloride
Cbloroform
Methylene chloride
Toluene
Trichloroetbylene
Results
23
1
41
19
2
M~Ll
5
80
5
1000
5
MI TVDe B2
0.27
5.6
4.6
1500.0
2.2
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IFederally mandated maximum contaminant levels for drinking
water.
2~ichigan Type B standards tor drinking water.
Samples of liquid from a storage drum found in April of 1984 aajacent to the dry
cleaning/laundry building, revealed some of the same contaminants found in the
contaminated well. These results are shown in Table 2 in ppb. Samples of the
excavated soil contained trace amounts of tetrachloroethylene.
Tab~e 2
Storaqe DZ'1III SlUIpl.iz1q RellUl ts
April 1984
COMPOUNDS
Carbon tetrachloride
Trichloroetbylene
Results
10,000
3,600
4
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_. P'Jtent!al H~altn Effects
~Ooel1alX A or the Site aammlsUatlve recora containS potential healtn effect
nformatlon for cnemlcal~t concern founa in the oast at the site.
3. Exoosure Assessment
The potential oathwavs of human exposure to the contaminated groundwater were
dermal absorotlon. ingestion. and inhalation secondary to household use. Each of
these pathways was eliminated however. by removal activities completed in 1984.
These removal activities included removal of the source material (drum and soil)
and installation of an alternative water supply.
The contaminated well was shut off and replaced with a new well upgradient of
the contaminatea well which draws from a aeeper aauifer with no nydraulic
connection to the shallow aQuifer. A secona on-site supply well with a separate
pumpmg system was Installed west of the first replacement well also in the deeper
aQuIfer. The aiternative water supply from the uncontaminated deep aQuifer
completely replaces the original supply well and prevents any contact with the
contaminated source.
4. Bisk Summarv
Previous removal activities and construction of an alternative water supply at the
site have eliminated existing and potential risks to human health and the
environment such that no further action is required. Historical and recent sampling
events indicate that the contamination was localized and there are no longer any
health risks from site-related contaminants present in the groundwater. soil. or in
8all Creek.
The four monitoring wells and twentY-nine nearby private wells were sampled in
April and Mav of 1984. No contaminants were detected in any of these wells.
The new water suppty weils are sampled and tested every three years: resultS have
consistently shown no detectable contaminants. Ball Creek Drain was sampled by
MDNR on May 20. 1993: no contaminants were detected. All sampling results are
available in the AR.
U.S. EPA performed a new round of sampling April 20, 1994 that included MW
(monitoring wetl) #1 and MW #2. the two new water supply wells. and the original
supply well. MW #3 and MW #4 have been damaged and were not available for
sampling. Samples were tested for VQCs. Sampling results for the monitoring
weils and the twO new water supply wells indicated that no VOCs exceeding MCls
were present. Samples taken from the original water supply well indicate that low
levels of carbon tetrachloride (8 ppb) are still present. This well. which is not
5
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JVallaOle as a ',!\later source. ana monitoring wellS ,13 ana ,r;4. .'.111 De D~aoerrv
JDanoonea ana groutea, 7':-,e Aorri 20. 1994. samollnq results are also InCluaea In
:;"1e AR,
The Agencv for ToxIc Substances ana Disease Registry IATSDRI at the U.S.
Jeoanmem at Health ana Human Services nas evaluatea avallaole aata for the Site
-
ana recommenas In Its Site Review ana Ucdate oatea 9/10/93 that "no funher
DUblic health actIons are indicated at this time."
VII. STATUTORY AUTHORITY FINDING
U.S. EPA has determined that conditions at the site pose no current or cotential
threat to human health or the environment. therefore no remeaial action is
necessary to ensure protection of human nealth or the environment. As this is a
aeclsion tor No Action. the reqUirements ot CERClA Section 121 for remedial
actions are not applicable and a statutory five year review IS not reqUired.
VIII. EXPLANATION OF SIGNIFICANT CHANGES
There are no significant changes from the recommended alternative described in
the proposed plan.
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RESPONSIVENESS SUMMARY
KENT CITY MOBilE HOME PARK SITE
This Resoonslveness Summary IRS) has been oreoarea to meet tne requirements of
Secnons 11 3(kH 2)(B)(ivl and 11 7(b) of the Camorenenslve Envlronmentat
Response. Comcensatio~ and liability Act at 1980 (CERCLA). as amended by the
SUPE!rtund Amendments and Reauthorization Act at 1986 (SARA). which requires
U.S. EPA to respond to significant comments. criticisms. and new data submined
in wrlnen or oral presentations on a proposed plan tor remedial action. The
purpose of the RS is to address concerns expressed by the public. POtentially
responsible parties. and governmental bodies in the wrinen and oral comments
received bV the U.S. EPA regarding the proposed remedy for the Kent City Mobile
Home Park site (the Sitel. All of the comments summarized in this document were
considered prior to U.S. EPA's final decision on the selected alternative for the Site
and have been clacea in the administrative record (AR) for the Site.
I. RESPONSIVENESS SUMMARY OVERVIEW
U.S. EPA has determined that conditions at the Site pose no current or potential
threat to human health or the environment. therefore no remedial action is
necessary to ensure protection of human health or the environment. The source of
the contamination was removed: subsequent groundwater and surface water
sampling events that included the monitoring wells. the two new water supply
wells. and Ball Creek Drain. have not revealed the presence of contaminants that
exceed any state or federal drinking water standards or criteria. Carbon.
tetrachloride above federal maximum contaminant levels for drinking water is still
present in the old water supply well but appears to be having no impact on the
ground water or surface water. An appropriate monitoring well will be placed. or
another well that can function as a monitoring will be identified. down gradient of
the old water supply well and in the same aquifer. If future sampling events of this
well or other sampling events routinely performed by MCPH indicate the No Action
alternative is no longer protective of human health or the environment. U.S. EPA
will reevaluate this decision.
There ere no significant changes from the recommended alternative described in
the proposed plan.
II. I~ACKGROUNC ON COMMUNITY INVOLVEMENT
Community interest appears to have peaked before U.S. EPA placed the Site on the
National Priorities List in 1987. Once removal activities completed by the State of
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'.1ichlqan Ir 1985 haa provlaea tne reslaents OT the moade home oarK Wltn a saTe
: ~lnklnq water SUPply. ana assurea the community tnat the source of the
;ontamlnatlon naa been removeo ana that the contamlnatea ""..ell was not
~Dactlng me groundwatef or surface water. communitY interest declineo. Prior to
:ne puohc comment period in July of 1994. no communitY health concerns had
:Jean expressea to the local health department or mobile home park management
'::Iy residents of the mobile home park or adjacent areas. No concerns. other than
:ne desire to have the site delisted. have been expressed to MDNR or to U.S. EPA.
An AR for the Site was established in April of 1994 with documents being made
available to the public at the Kent CountY Library in Kent City. Michigan and at the
U.S. EPA offices In Chicago, Illinois. The file includes general information
concerning site background and history as well as documents such as sampling
-esuits. correspondence. health assessments. and site inspection results. The AR
.vas uodated prior to the commencement of the public comment period in July of
'994. The upaate Included the oraft proposea plan and additional sampling
'esults.
A notice of availability of the AR and proposed plan was advertised in The
Soana/Kent Advance on July 5, 1994, The Muskeoon Chronicle on July 4. 1994,
and The Grand RaDids Press on July 6, 1994. This notice served to initiate a
public comment period from July 1, 1994 to August 1. 1994 on the proposed
plan. The notice also included U.S. EPA's offer to hold a public meeting on the
proposed plan if reQuested: no reQuests were received.
III. SUMMARY OF COMMENTS RECEIVED AND U.S. EPA'S RESPONSE TO
COMMENTS
One phone call and one wrinen comment were received during the public comment
period. Comments and responses are listed below:
COMMENT: A resident of the mobile home park wanted to know if the "area was
sate." referring to the mobile home park.
RESPONSE: Conditions at the mobile home park appear to pose no current or
potential threat to human health or the environment. The source of the
contamination was removed. Subsequent groundwater and surface water
sampling events that included the monitoring wells, the two new water supply
wells and Ball Creek Drain, have not revealed the presence of contaminants that
exceed any state or federal drinking water standards or criteria.
The low levels of carbon tetrachloride still present in the old water supply well
appear to be localized and are not impacting the ground water or surface water.
8
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j
Thl~ well IS nor c~rrentlY avaliaDle as a DUDIIC warer S~DOIY ano Will be orooerly
Joanaonea as aescr:Dea In me Recore aT DeCISion.
COMMENT: A resloent of rhe mODIle nome parK stateo rhat me warer smells bad.
material Settles out If the water IS ieft standing In a container. ana that the Site
should not oe delistea~ntll sOmething IS done about It.
RESPONSE: The oejectlonal odor and deposits in the water supply at the mobile
home parK are consistent with problems associated with iron and "hard water."
Iron leyels in drinking water in excess 0.5 milligrams tmg) per liter often become
aesthetically ocjectlonable in that they may result in staining, turbidity, and poor
taste ana odor. A sample taken from the park's supply well in 1989 by the MDPH
showea 1.6 mg per titer of iron in the water. The problems descrrbed in the
comment are, accoraing to the Michigan Department of Public Health (MDPH),
typically associated with the naturallv occurring iron found in the deep aquifer of
this region and freauently described bY Kent City residents whose wells also tap
.hEl ceee aauifer usea bv the mobile home park. In aadition to the high levels of
iron, the calcium carbonate levels in tnlS aquifer cause "haraness" which creates
scaling and scum deposits.
These problems, while unpleasant, are not associated with any human health or
environmental risks. Neither U.S. EPA nor MDNR are authorized to address
aesthetic drinking water problems associated with naturally occurring iron and
calcium carbonate. Installatian of a water tower would not improve the water
Quality of the underground source. There are, however, commercially available
pmducts that can improve aesthetic Qualities of the water supply. The homeowner
and the mobile park owner are free to explore and install these products.
9
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