Superfund Record of Decision Roto-finishing Co. Inc. Kalamazoo MI


                                     EPA/ROD/R05-97/155
                                     1997
EPA Superfund
     Record of Decision:
     ROTO-FINISH CO., INC.
     EPA ID: MID005340088
     OU01
     KALAMAZOO, MI
     03/31/1997

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          DECLARATION FOR THE RECORD OF DECISION


Site Name and Location

Roto-Finish site, Portage, Michigan

Statement of Basis and Purpose

This decision document presents the selected remedial action for the Roto-Finish Site in Portage, Michigan,
which was chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act (SARA)  of 1986, and is
consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)  to the extent
practicable.  This decision is based on the administrative record for this site.

Assessment of the Site

Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action in this Record of Decision (ROD),  may present an imminent and substantial endangerment to
public health, welfare, or the environment.

Description of the Selected Remedy

The purpose of this remedy is to eliminate or reduce the risks posed by potential future exposure to
contaminated groundwater, and to restore the contaminated aguifer to its potential future use as a supply of
municipal, residential and industrial drinking water.

The major components of the selected remedy include:

•       Natural attenuation to restore the contaminated aguifer to the lower of either Maximum Contaminant
       Levels (MCLs)  or Michigan Act 451 Part 201  Generic Residential Drinking Water Criteria.   Based upon
       the potential for exposure to multiple contaminants in the groundwater,  the cumulative risks from
       exposure to groundwater will also be reduced to 1E-04 or less for carcinogenic risks and a hazard
       index of less than 1.0 for noncancer risks.  The primary attenuation process occurring at the
       Roto-Finish site is intrinsic biodegradation.

•       Institutional controls to limit groundwater use until the aguifer is restored to cleanup levels.

•       Monitoring programs to track the progress  and the effectiveness of natural attenuation,  and to
       identify any changes in land and groundwater use, and any changes in groundwater conditions.

•       Maintain the existing groundwater extraction system in working condition and implement it as a
       contingency remedy, if necessary, to respond to any decreases in the actual rate of biodegradation,  or
       any unanticipated changes in site conditions to the extent that the remedy is not performing as
       anticipated or is no longer protective.

•       Develop contingency plans to respond to differences in the actual performance of the remedy and actual
       site conditions, as compared to the expected performance of the remedy and expected site conditions.
       This includes changes in land or groundwater use; differences between the predicted and the actual
       fate and transport of groundwater contaminants and contaminant concentrations; differences between the
       projected and the actual rate of intrinsic  biodegradation;  and changes in the protectiveness of the
       remedy. The contingency plans may include modifications to institutional controls,  modifications to
       the monitoring program,  and implementation  of the contingency remedy,  if necessary.

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Statutory Determinations

The selected remedy and the selected contingency remedy are protective of human health and the environment,
comply with Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and are cost effective.  The selected remedy and the selected continency remedy utilize
permanent solutions and alternative treatment or resource recovery technologies to the maximum extent
practicable.  The selected remedy and the selected contingency remedy satisfy the statutory preference for
remedies that employ  treatment that reduces the toxicity, mobility, or volume as a principal element.  This
statutory preference for treatment is satisfied through intrinsic biodegradation for the selected remedy, and
through groundwater extraction and treatment for the selected contingency remedy.

A review will be conducted within five year after commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment because this remedy will
result in hazardous substances remaining at the facility above health-based levels.

U.S. EPA has determined that its response at this site is complete.  Therefore, the site now qualifies for
inclusion on the Construction Completion List.

State Concurrence

The State of Michigan has indicated that it does not concur with the selected remedy.  The Letter of
Non-Concurrence will be attached to this ROD.

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                             U.S. EPA Superfund
                             Record of Decision

                              Roto-Finish Site

                              Portage, Michigan
                                 March, 1997

                           TABLE OF CONTENTS
I.      Site Location 	  1

II.     Site History and Enforcement Activities	  1

III.    Highlights of Community Participation	  3

IV.     Summary of Current Site Conditions	  4

V.      Health Risk Assessment	  7

VI.     Environmental Risk	10

VII.    Scope and Role of the Remedy	11

VIII.   Description of Alternatives	11

IX.     Summary of Comparative Analysis of Alternatives	16

X.      The Selected Remedy	21

XI.     Explanation of Significant Changes	24

XII.    Statutory Authority Finding	24

XIII.   Summary	27


FIGURES

TABLES

APPENDICES

Appendix A - Responsiveness Summary
Appendix B - State Letter of Non-Concurrence
Appendix C - Administrative Record

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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION

I. SITE LOCATION

The Roto-Finish site (Figure 1) is an inactive manufacturing facility located at 3700 E. Milham Road in the
northeast area of Portage, Michigan. The site covers approximately 7 acres and is located approximately 0.2
mile west of Sprinkle Road and is directly east of the Kalamazoo/Battle Creek International Airport. The
site is located in an industrial area zoned for current and future industrial use. Other industrial
activities in the area include plastic color pigment manufacturing, a building supply business, garment
retailing distribution, surgical supply manufacturing and warehousing, plastics manufacturing and
pharmaceutical research and manufacturing. The reasonably anticipated future land use of the property is
industrial.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

Former Operations and Disposal Areas

The Roto-Finish Company (Figure 2) manufactured specialized eguipment to debur and polish metal castings,
mechanical parts, and similar objects that reguired smooth finishes. Manufacturing operations at the site
began in the late 1940s to early 1950s and continued until 1988 when the business was sold and the facilities
were closed. There are two buildings at the site: the manufacturing building and the chip and compound
building. The manufacturing building housed offices and areas used for eguipment manufacturing, testing and
storage. The chip and compound building was used for the production and storage of the polishing media used
with the manufactured eguipment.

Roto-Finish used two systems for waste disposal. The waste from the rest rooms and other non-processing and
laboratory wastes were disposed of through a system of septic tanks, dry wells and a tile field. The
wastewater generated from the manufacturing and testing processes was discharged to three lagoons. The
lagoons were located near the eastern boundary of the property, along the east and north sides of the chip
and compound building. The wastewater was discharged to the lagoons until 1980, when the facility was
connected to the municipal sanitary sewer system. During this same time the facility was connected to the
municipal water supply, and the water supply wells at the site were disconnected and are inoperable.

Previous Investigations and Removal Actions for Lagoons and Soils

In 1979, the Michigan Department of Environmental Quality (MDEQ) 1 collected sediment and water samples from
the wastewater lagoons. The analytical results indicated elevated levels of chemicals including cadmium,
chromium, iron and 4,4'-methylene-bis-2-chloroaniline (MOCA). Between 1979 and 1984, the lagoons and areas of
visibly stained soils were excavated by the potentially responsible party (PRP) under the oversight of the
MDEQ, and were disposed in an off-site landfill. The excavated areas were backfilled with clean material.

1 Formerly known as the Michigan Department of Natural Resources until reorganization in October,
1995.

Enforcement Activities

In 1986, the Roto-Finish site was included on the National Priorities List (NPL). In December 1987, the PRP
agreed to perform a Remedial Investigation/Feasibility Study (RI/FS) to characterize any remaining
environmental impacts at the site and evaluate potential cleanup alternatives. A Consent Agreement was
signed in January 1988, and the RI/FS was initiated in 1989. The RI/FS was conducted under the oversight of
U.S. EPA and the MDEQ in three phases from 1989 to 1996.

Voluntary Non-Time-Critical Removal Action for Groundwater

In 1994, the PRP conducted a voluntary Engineering Evaluation/Cost Analysis (EE/CA) to evaluate removal
options to address the highest area of groundwater contamination at the site until the RI/FS was completed

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and a final remedy was selected and implemented.  The EE/CA was approved in October 1994, and an Action
Memorandum to implement the voluntary action was signed in November 1994.   The PRP submitted a waiver of the
right to seek reimbursement under CERCLA 106 in December 1994, and a Unilateral Administrative Order (UAO)  to
conduct the removal was issued in January 1995.

The voluntary action includes the installation and operation of an on-site groundwater extraction system
consisting of two wells pumping at 30 and 60 gallons per minute.  The extracted groundwater is discharged to
a storm sewer and treated at the Kalamazoo wastewater treatment plant.  The extraction system was installed
in June 1995 and will operate until the final remedy is implemented.  Data collected since the system began
operating indicates that the system is removing and containing groundwater with the highest detected chemical
concentrations at and approximately 800 feet downgradient of the Roto-Finish property.

The RI/FS was completed in September 1996.  The RI/FS documents were sent to the local information repository
on October 22, 1996, and were placed in the Administrative Record in March, 1997.

III.   HIGHLIGHTS OF COMMUNITY PARTICIPATION

Availability Sessions

Public participation reguirements under CERCLA Sections 113(k)(2)(B)(i-v)  and 117 were satisfied during the
RI/FS process.  Public availability sessions were conducted by U.S. EPA in Portage, Michigan in August 1988
and January 1992.  At the meetings, local residents were provided with information about the Superfund
process; the results of past investigations and studies conducted at the site; and the upcoming activities to
be performed during the RI/FS.  A fact sheet describing background information about the site and explaining
how the RI/FS would be conducted was issued in October 1988.   A site activities update letter summarizing
Phases I and II of the RI, and announcing a third phase of field work, was issued in January 1992.

Information Repository

An information repository for the site has been established at the Portage Public Library, 300 Library Lane,
Portage, Michigan.  U.S. EPA maintains a copy of the administrative record for the site at the information
repository.  Other site-related information, including the EE/CA and the administrative record for the
removal action, is provided at the information repository.

Fact Sheets and Public Meetings

Non-Time Critical Removal Action:  A fact-sheet summarizing the EE/CA and U.S. EPA's recommended removal
action plan was issued in September 1994.  A public meeting to discuss the EE/CA and accept public comments
on the recommended alternative was held in October 1994.  Available information about the RI/FS was also
discussed during the meeting.  Written comments on the EE/CA were accepted during a 30-day public comment
period from October 1, 1994 through October 31, 1994.  In general,  the public supported the proposed removal
action.

Proposed Remedial Alternative:  The RI was released to the public in October 1996.  A Proposed Plan was made
available on October 22, 1996.  A public meeting was held on November 13,  1996 to discuss the RI/FS and the
Proposed Plan.  An advertisement was placed in the Kalamazoo Gazette on October 23, 1996 to announce the
Proposed Plan, the public meeting and the public comment period.  The public comment period was established
from October 24, 1996 to November 23, 1996.  In general, the public supports the selected remedy and the
selected contingency remedy.  The responsiveness summary is contained in Appendix A.

IV.   SUMMARY OF CURRENT SITE CONDITIONS

Site Investigations

The RI included a series of field investigations to collect information concerning site characteristics,
background soil guality, possible sources of environmental impacts, soil guality and groundwater guality.  In
addition, background reports and other published documents were reviewed to collect information about surface

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features, meteorology, geology, hydrogeology, hydrology, land use and demography.

Current Site Conditions

The Roto-Finish site is located in an industrial area and is surrounded by other industrial properties. The
site is fenced and approximately 60% of the site is covered by buildings and pavement. The remaining
portions of the site are covered with gravel, weeds and a 1/2 acre maintained lawn. The ground surface of
the site is generally flat, with elevation variations of less than 10 feet.

The geology at the Roto-Finish site is primarily characterized by thick deposits of glacial outwash materials
consisting of stratified sands, silts, and gravels, with inconsistent layering of fine grained glacial drift
sediments including silts and clays. Regional mapping indicates that the glacial deposits in the vicinity of
the site are approximately 250 feet thick and are underlain by the Mississippian Coldwater Shale. All of the
soil borings drilled during the RI/FS (down to 185 feet below ground surface) terminated in unconsolidated
glacial sediments. Most of the groundwater supplies for Kalamazoo County are derived from glacial sand and
gravel deposits. Estimates indicate that industrial commercial withdrawals for the county range from 40 to 50
million gallons per day, and that domestic/municipal groundwater use is at approximately 20 million gallons
per day.

Rivers and creeks near the site included Olmstead Drain/Davis Creek, located approximately 0.75 mile
northeast of the site, and Portage Creek, located approximately 2 miles northwest of the site. Regional
groundwater flows north between Davis Creek and Portage Creek toward the Kalamazoo River, which is located
approximately 4 miles north of the site.

Groundwater at the Roto-Finish site flows generally toward the northwest, with significant downward vertical
gradients present in an east to west direction across the site. Shallow groundwater is characterized by a
radial flow pattern, and flows outward from the site toward the northwest, west and southwest. Prior to
1981, groundwater mounding was present around the north and south wastewater lagoons. After the lagoons were
closed, this mounding was no longer evident.

Groundwater modeling indicates that the direction of local groundwater flow has been significantly influenced
by industrial pumping by the Upjohn Company south of the site. Under non-stressed groundwater flow
conditions (i.e., no Upjohn pumping), the modeling indicates that site groundwater flows in a more northerly
direction. Increasing the Upjohn withdrawals (from 5.2 billion gallons per year in 1971 to 8.8 billion
gallons per year in 1990) shows an increasingly westward shift in the direction of groundwater flow from the
site. Current withdrawal rates for Upjohn are estimated at 9.9 billion gallons per year.

Residential Areas

Residential areas near the site (Figure 3) include the Colonial Acres mobile home park, 0.5 mile north of the
site, the Lexington Green residential development, 0.3 mile northeast of the site, and the Fairfield
residential development, 1 mile northwest of the site on the other side of the airport. The total estimated
population of these residential areas is approximately 4,000.

Area Water Supply

Prior to the development of the municipal water supply, businesses and residences obtained their water from
private wells. Well records indicate that approximately 92 private wells are installed in the vicinity of
the Roto-Finish site (Figure 4). These wells were installed within the glacial deposits and range in depth
from 25 to 200 feet below ground surface. Although this area is currently served by the municipal water
supply, there are no records to confirm that these private wells have been disconnected and properly closed
to prevent further use.

Portage and the nearby city of Kalamazoo obtain their municipal water from groundwater. Seven municipal wells
are located within 2 miles of the site. One well, Kalamazoo Municipal Well No. 18, is downgradient of the
site. Groundwater from the site currently flows toward this well, located 1.3 miles north of the site. Two
wells, Portage's Lexington Green Wells Nos. 1 and 2, are located 0.3 mile northeast of the site. Groundwater

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from the site does not currently flow toward these wells; however, under other conditions (e.g., less
groundwater withdrawals from other industry in the area), high rates and durations of pumping from these
wells could potentially cause site groundwater to flow more toward the northeast.

The Lexington Green wells have only operated on an infreguent and intermittent basis since 1972 and have only
been used to flush fire hydrants since 1989. Due to the high cost of treating high levels of iron in this
area, the City of Portage has indicated that it has no future plans to use these wells for any purpose other
than flushing. The other municipal wells located in the area are either upgradient of cross-gradient to
groundwater flow from the Roto-Finish site.

Contamination

Phase I and II: Phase I and II of the RI were conducted between 1989 and 1991, and focused primarily on
characterizing on-site conditions. These investigations included the sampling and analysis of soil and
groundwater samples from 41 boring locations to depths of 146 feet below ground surface, and the installation
of 17 permanent groundwater monitoring wells. Phase II also included vertical aguifer sampling of the
groundwater to define the vertical extent of the groundwater contamination.

The results of the Phase I and II investigations indicate that the primary sources of contamination (the
lagoons and drywells) have been removed from the site, and that there is no significant remaining soil
contamination. However, the groundwater is contaminated, primarily with volatile organic compounds (VOCs)
including trichloroethene, 1,1,1-trichloroethane, 1,1-dichlorethene and vinyl chloride. Other chemicals
detected in the groundwater samples include other VOCs, semivolatile organic compounds (SVOCs) and inorganic
compounds. MOCA was not detected in any of the groundwater samples.

Phase III: Following Phase I and II, a third phase of field work was initiated to provide additional
information about aguifer characteristics and to further characterize the off-site extent of the groundwater
contamination. The Phase III investigation began in September 1992 with an aguifer pumping test and the
installation and sampling of eight off-site groundwater monitoring wells downgradient of the site at the
Kalamazoo/Battle Creek International Airport. VOCs similar to those found in the wells at the Roto-Finish
site were detected in one of the wells installed at the airport, however, the chemical concentrations in the
airport well were approximately ten times lower than the chemical concentrations detected in the on-site
wells.

During April and May 1994, additional Phase III work was conducted to further define the vertical and
horizontal extent of the off-site groundwater contamination. Additional vertical aguifer sampling was
conducted, and five more groundwater monitoring wells were installed and sampled. The locations of all soil
borings and monitoring wells installed during the RI is provided in Figure 5. An approximately boundary of
the groundwater contamination is shown in Figure 6. The primary groundwater contaminants are
trichloroethene, 1,1,1-trichloroethane, 1,1,2-trichloroethane, 1,1-dichloroethene, 1,2-dichloroethane,
tetrachloroethene, chlorobenzene and vinyl chloride. Other VOCs, SVOCs and inorganic compounds were also
detected in the groundwater. A complete summary of the chemicals detected in the soils and groundwater at
the Roto-Finish site is provided in Table 1.

Intrinsic Biodegradation

Time series groundwater data collected from the site indicates that the chemical concentrations detected in
the groundwater are currently decreasing. From 1991 to 1995, total VOC concentrations for the most impacted
wells at the site located near the center of the plume (MWB2B and MW310) decreased from approximately 2,500
ug/1 in June 1991, to 500 to 1,000 ug/1 in November 1993, and to less than 500 ug/1 in April 1995. These
data represent groundwater conditions prior to the interim groundwater extraction system, which did not begin
to operate until June 1995.

The presence and distribution of decay product compounds and the distribution of groundwater guality
parameters such as chemical oxygen demand and iron indicate that these decreases in chemical concentrations
are due to intrinsic biodegradation by microorganisms naturally present in the aguifer.

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V. HEALTH RISK ASSESSMENT (See Glossary for definitions of terms used in this section)

Based on the analytical data collected during the RI, a risk assessment was performed to determine the
potential risks to human health posed by the contaminants detected in the soils and the groundwater at the
site. The risk assessment is a baseline risk assessment and assumes that no corrective action will take
place at the site, and that no site-use restrictions or institutional controls such as fencing, groundwater
use restrictions or construction restrictions will be imposed. The risk assessment for the Roto-Finish site
determines the actual or potential carcinogenic risks and/or toxic effects that the chemicals detected at the
site pose under current and future land use assumptions. Risk assessment is a four step process, and
includes: contaminant identification, health effects assessment, exposure assessment and risk assessment.

Contaminant Identification

The levels of contamination found in the soils and the groundwater at the Roto-Finish site can be found in
Chapter 4 and Appendix B of the RI Report. All chemicals that were detected at least once at the site were
considered chemicals of potential concern and were included in the guantitative risk evaluation. The
chemicals of potential concern for the site are listed in Table 2 of this document.

Human Health Effects

The health effects for the contaminants of concern may be found in Table 6-2 of the RI Report.

Exposure Assessment

The potential pathways of concern to human health were evaluated under current and future land use scenarios
for the immediate site property and the surrounding area.

Current Land Use Conditions

Soil: The pathways selected for detailed evaluation for exposure to soil under current land use conditions
include ingestion, direct contact and inhalation of airborne soil particulates from surface soils by
groundskeepers and industrial workers. 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 exposure scenarios and was not evaluated separately.

Groundwater: The contaminated groundwater at and downgradient of the Roto-Finish site is not currently used
as drinking water supply. No wells exist in the area of groundwater contamination, and existing wells
downgradient of the site have not been impacted. Exposure to groundwater is not an exposure pathway under
current land use conditions.

Future Land Use Conditions

Soil: The Roto-Finish site is located in an industrial area zoned for current and future industrial use.
The expected future use of the property is industrial. The pathways selected for exposure to soil under
future land use conditions include ingestion, direct contact and inhalation of airborne soil particulates
from surface and subsurface soils by future construction workers and future industrial workers.

Groundwater: Existing Wells - Although the contaminated groundwater is not currently used as a drinking
water supply, groundwater 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 (which is currently served by the municipal water supply) and at Kalamazoo Municipal Well
No. 18 (the nearest downgradient municipal well). The modeling was performed using groundwater data collected
before the operation of the interim groundwater extraction system. The model only considered chemical
reductions from the process of dispersion, and did not consider additional reductions in chemical
concentrations from intrinsic biodegradation. The exposure pathways include ingestion, dermal absorption of
groundwater while showering, and inhalation of chemical vapors from groundwater while showering under a

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residential scenario.

New Wells - The risk assessment evaluated whether the installation of new wells within the area of
groundwater impacts could pose a future health risk. The risks were evaluated assuming that new municipal or
industrial wells could be installed anywhere within the area of groundwater impacts. The risks were
calculated using groundwater data collected from the area of highest chemical concentrations, before the
operation of the interim groundwater extraction system. The exposure pathways included ingestion, dermal
absorption of groundwater while showering, and inhalation of chemical vapors from groundwater while showering
under an industrial worker and residential exposure scenario.

Risk Characterization

For each potential human receptor, site-specific contaminants from all relevant routes of exposure were
evaluated. Both non-carcinogenic health effects and carcinogenic risks were estimated. The risks for each
exposure scenario are summarized in Table 3.

Non-Carcinogenic Health Risks

Soil: No noncancer risks were identified for exposure to surface or subsurface soils under current or future
exposure scenarios. The hazard index for the current groundskeeper/industrial exposure scenario and the
future construction worker and future industrial worker exposure scenarios is less than 1.0. This indicates
that the calculated intake of chemicals under these scenarios is not expected to exceed established reference
doses for those chemicals. Exposure to contaminated soils is therefore not expected to result in any
noncancer health risks.

Groundwater: The contaminated groundwater at and downgradient of the Roto-Finish site is not used as a
current drinking water supply, and, therefore, does not pose any current noncancer risks to human health.
For existing wells, the groundwater modeling indicates that groundwater contaminants would never reach
Kalamazoo Municipal Well No. 18, and that the maximum concentrations of chemicals to users of possible wells
located in the Fairfield residential area would be reached after 65 years and would not result in any
noncancer health risks. The modeled decreases in chemical concentrations are based on the process of
dispersion. The modeling did not consider any additional reductions in chemical concentrations from
biodegradation.

Unacceptable noncancer risks would result, however, if new drinking wells were installed within the area of
groundwater impacts (hazard index > 1.0). The hazard index, if new wells were installed, is 16.55 for the
potential future industrial drinking water exposure scenario, and 54.23 for the future residential drinking
water exposure scenario.

Based on current land and groundwater use conditions, it is uncertain whether new wells would actually be
installed in the area of groundwater impacts. This is 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 informal airport policy prohibits the installation of water wells on airport
property. Additionally, Kalamazoo County local ordinance (Section 11.04 of the Kalamazoo County Human
Services Sewage Disposal and Water Supply Regulations) reguires the issuance of a well-permit prior to the
installation of any new wells in the county. Prior to issuing a permit for the installation of a new wells,
the Environmental Health Department must evaluate a set of criteria. Included in this criteria is a review
of any potential sources of contamination that could potentially contaminate a well, including the
contamination at the Roto-Finish Superfund site, and other sites administered under the State's environmental
response program.

Carcinogenic Health Risks

Soil: No unacceptable cancer risks were identified for exposure to soil under current or potential future
land use conditions. The greatest risk is posed by the future industrial worker exposure to surface and
subsurface soils. Exposure under this scenario would result in an excess lifetime cancer risk of 1

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additional case of cancer for every 1 million individuals similarly exposed (1E-06). This risk, however, is
at the low end of U.S. EPA's acceptable risk range of 1 additional case of cancer for every 10,000 to
1,000,000 individuals similarly exposed (1E-04 to 1E-06), with emphasis on the more protective end of the
risk range. The other risks for exposure to soil are 2 additional cases of cancer for every 10 million
individuals similarly exposed for current groundskeeper/industrial worker exposure to surface soil (2E-07),
and 5 additional cases of cancer for every 100 million individuals similarly exposed for future construction
worker scenario exposure to subsurface soils (5E-08).

Groundwater: The contaminated groundwater at and downgradient of the Roto-Finish site is not used as a
current drinking water supply, and, therefore, does not pose any current cancer risks to human health. For
existing wells, the groundwater modeling indicates that groundwater contaminants would never reach Kalamazoo
Municipal Well No. 18, and that the maximum concentration of chemicals to users of possible wells located in
the Fairfield residential area would be reached after 65 years and would result in a maximum cancer risk of 1
additional case of cancer for every 100,000 individuals similarly exposed (IE-OS). This risk falls within
the U.S. EPA's acceptable risk range of 1 additional case of cancer for
every 10,000 to 1,000,000 individuals similarly exposed (1E-04 to 1E-06), with emphasis on the more
protective end of the risk range. The modeled decreases in chemical concentrations are based on the process
of dispersion. The modeling did not consider any additional reductions in chemical concentrations from
biodegradation.

Unacceptable cancer risks would result, however, if new drinking wells were installed within the area of
groundwater impacts. The excess lifetime cancer risk, if new wells were installed, is 2 additional cases of
cancer for every 100 individuals similarly exposed for the potential future industrial drinking water
scenario (2E-02), and 5 additional cases of cancer for every 100 individuals similarly exposed for the future
residential drinking water scenario (5E-02). Based on current land and groundwater use conditions, however,
it is uncertain whether new wells would actually be installed in the area of groundwater impacts (see
discussion for noncarcinogenic groundwater risks).

IV. ENVIRONMENTAL RISK

An ecological screening assessment was conducted to characterize the biological resources at the Roto-Finish
site and adjacent habitats, and to identify any actual or potential impacts to these resources associated
with releases of hazardous substances from the site.

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-guality habitat and no threatened or endangered
plants or animals 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
maintained 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.

Groundwater: Shallow groundwater may discharge to Olmstead Drain/Davis Creek or Portage Creek; however,
deeper groundwater is expected to flow north with regional groundwater flow toward the Kalamazoo River. At
the Roto-Finish site, significant vertical gradients cause most of the groundwater contaminants to move deep
into the aguifer as the groundwater flows away from the site. As a result, any groundwater contaminants from
the Roto-Finish 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, dispersion would cause the
contaminant concentrations to be so diluted that they would meet the MDEQ criteria considered to be safe for
rivers (MDEQ Act 451 Part 201 criteria for protection at the groundwater/surface water interface).

VII. SCOPE AND ROLE OF THE REMEDY

This ROD addresses the final remedy for the site. The remaining threat at the site is posed by the
contaminated groundwater. The selected remedial alternative will address the threats posed by the
contaminated groundwater. The identified sources of the groundwater contamination (the lagoons and dry
wells) were remediated through removal actions conducted by the PRP under the oversight of the MDEQ from 1979

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to 1984.

The risk assessment indicates that the soils at the site do not pose any noncancer risks or unacceptable
cancer risks under current or expected future use scenarios. The ecological assessment indicates that the
site is not expected to pose any significant ecological impacts. These pathways do not need to be addressed
further.

VIII. DESCRIPTION OF ALTERNATIVES

The Feasibility Study (FS) identified and evaluated six remedial alternatives that could be used to address
the threats and/or potential threats to human health posed by the contaminated groundwater at the Roto-Finish
site. Exposure to soil did not pose any unacceptable risks, and the site is not expected to pose any
significant ecological impacts.

The alternatives that were evaluated to address the groundwater at the Roto-Finish site and to restore the
aguifer to its potential future use as a supply of municipal and industrial drinking water are:

Alternative NA - No Action

Estimated Cost: $0

• Estimated Time to Restore the Aguifer to Cleanup Levels (Lower of U.S. EPA Maximum Contaminant Levels
(MCLs) or Michigan Generic Residential Drinking Water Criteria): At current rates of biodegradation,
the aguifer would be restored to cleanup levels in 15 to 20 years, although the no action alternative
is not reguired to meet any cleanup reguirements. Restoration could take 50 to 60 years depending on
the rate of biodegradation. Restoration would not be achieved under a zero rate of biodegradation.

The no action alternative involves no cleanup action or cleanup reguirements for groundwater, although the
site data collected prior to the groundwater extraction system indicates that the chemical concentrations in
the groundwater will naturally decrease and restore the aguifer to drinking water levels over time. The
actual rate of attenuation will depend upon the rate of chemical biodegradation by the microorganisms
naturally present in the aguifer. Site-specific estimates indicate that, at current rates of biodegradation
(0.0008/day), the aguifer would be restored in 15 to 20 years*. At a lower rate of biodegradation
(0.0002/day), the aguifer would be restored in 50 to 60 years. The aguifer would not be restored at a zero
rate of biodegradation.

*The term 0.0008/day represents the first order decay rate constant, which is determined by
dividing 0.693 by the half-life of a contaminant in groundwater. A 0.0008/day rate represents a
half-life of 866 days, while a decay rate of 0.0002/day represents a half-life of 3,465 days.

The no action alternative does not include institutional controls, groundwater monitoring or contingency
planning. Existing institutional controls may be effective in preventing or minimizing potential future
exposure to groundwater until the aguifer is restored, although these controls would not be reguired or
monitored. Existing controls include the availability of the current municipal water supply; Kalamazoo
County local ordinance which reguires the issuance of a well permit and is intended to prevent the
installation of new drinking water wells in areas of environmental degradation; and informal airport policy
which currently prohibits the installation of water wells on airport property. The inclusion of a no action
alternative is reguired by CERCLA and the NCP to give U.S. EPA a basis for comparison.

Alternative A - Aguifer Restoration through Hydraulic Extraction of
Highest Groundwater Impacts, with Natural Attenuation
to Restore the Aguifer Outside the Capture Zone to
Cleanup Levels (On-Site Pumping Alternative)

Estimated Cost: $1.5 to 2.1 million

• Estimated Time to Restore the Aguifer to Cleanup Levels (Lower of MCLs or Michigan Generic Residential

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       Drinking Water Criteria):   15 to 20 years; may take 40 to 50 years with decreased or zero rate of
       biodegradation.

Alternative A is essentially the same as the current groundwater extraction system that was installed during
Phase III of the RI  (see Voluntary Non-Time-Critical Removal Action, page 2).   This alternative includes an
on-site groundwater extraction system to hydraulically contain and restore the portion of the aguifer with
the highest chemical concentrations, and natural attenuation to restore the aguifer outside of the capture
zone to cleanup levels.  At the Roto-Finish site, the primary natural attenuation processes are intrinsic
biodegradation and dispersion.  Currently, the most impacted portion of the aguifer is located beneath and
approximately 800 feet downgradient of the Roto-Finish property.  Although the existing extraction system
discharges extracted groundwater 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
groundwater monitoring data.

The time to restore the aguifer to cleanup levels for this alternative depends upon the rate of intrinsic
biodegradation, even for the portion of the aguifer within the capture zone. However, even without
biodegradation, the groundwater with the highest levels of contamination would be hydraulically contained and
restored to cleanup levels through pumping, and the groundwater in the aguifer outside of the capture zone
would be restored to cleanup levels through the process of dispersion.  Site-specific estimates indicate
that, at current rates of biodegradation  (0.0008/day),  the portion of the aguifer within the capture zone
would be restored to cleanup levels in 15 to 20 years (through pumping and biodegradation), and the portion
of the aguifer outside the capture zone would be restored to cleanup levels in 10 to 15 years (through
biodegradation and dispersion).   At a lower rate of biodegradation  (0.0002/day),  or a zero rate of
biodegradation, the portion of the aguifer within the capture zone would be restored to cleanup levels in 40
to 50 years (through pumping and biodegradation, or just pumping),  and the portion of the aguifer outside the
capture zone would be restored to cleanup levels in 40 to 50 years  (through biodegradation and dispersion, or
just dispersion).  The exact timeframe is uncertain.

The on-site pumping alternative includes institutional controls to prevent exposure to impacted groundwater
until the aguifer is restored to cleanup levels, 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 - Aguifer Restoration through Hydraulic Extraction of All
                Groundwater Impacts (On-Site and Off-Site Pumping Alternative)

       Estimated Cost:  $2.0 to $3.5 million

•      Estimated Time to Restore Aguifer to Cleanup Levels (Lower of MCLs or Michigan General Residential
       Drinking Water Criteria):   15 to 20 years; may take 40 to 50 years with decreased or zero rate of
       biodegradation.

This alternative includes all of the components of Alternative A,  but adds an additional off-site well to
hydraulically contain and restore the entire aguifer with groundwater impacts above cleanup levels.  The
capture zone for this alternative would include the groundwater in the most impacted portion of the aguifer
and extend approximately 1800 to 2500 feet downgradient of the Roto-Finish property to encompass and
hydraulically restore all groundwater impacts.  The final treatment and discharge options for this
alternative would be developed during the remedial design.

Although the main component of this alternative is hydraulic extraction,  the time to restore the aguifer to
cleanup levels for this alternative is affected by the rate of intrinsic biodegradation within the capture
zone.  The time to restore aguifer to cleanup levels for this alternative is not significantly different from
the estimates for the on-site pumping alternative:  15 to 20 years at current rates of biodegradation
(0.0008/day);  40 to 50 years at a decreased (0.0002/day) or a zero rate of biodegradation.   The exact
timeframe is uncertain. Even without biodegradation, the entire portion of the aguifer impacted above cleanup
levels would still be hydraulically contained and restored through extraction.  This alternative includes
institutional controls, monitoring programs and contingency plans.

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Alternative C - Aquifer Restoration through Intrinsic Biodegradation (Natural Attenuation Alternative)

       Estimated Cost:   $500,000

•      Estimated Time to Restore Aguifer to Cleanup Levels (Lower of MCLs or Michigan Generic Residential
       Drinking Water Criteria):  15 to 20 years; may take 50 to 60 years depending on the rate of
       biodegradation.   Cleanup levels would not be achieved under a zero rate of biodegradation and would
       reguire a contingency remedy.

This alternative relies on natural processes including recharge, dilution, dispersion and intrinsic
biodegradation to reduce chemical concentrations in the groundwater to established cleanup levels and to
restore the aguifer to its potential use as a drinking water supply.  At the Roto-Finish site, the most
significant attenuation process is intrinsic biodegradation.

Site-specific estimates indicate that, at current rates of biodegradation (0.0008/day),  the aguifer would be
restored to cleanup levels in 15 to 20 years.  The actual rate of attenuation will depend on the rate of
biodegradation.  At a lower rate of biodegradation (0.0002/day), the aguifer would be restored to cleanup
levels in 50 to 60 years.  At a zero rate of biodegradation, cleanup levels would not be achieved, and a
contingency remedy would be implemented.

Alternative C includes institutional controls to prevent exposure to impacted groundwater until the aguifer
is restored, and monitoring programs to monitor and evaluate the effectiveness and the performance of the
alternative.  The groundwater monitoring program would include monitoring to tract the horizontal and
vertical extent of the contaminated groundwater plume and to provide sufficient advance warning of any
expansion of the plume, including expansion beyond the original non-detect plum boundary  (see Figure 4-5 in
the RI/FS Report), and expansion toward any existing or new water supply wells.  The monitoring programs
would include monitoring to identify any changes in land use or groundwater use conditions, and any changes
in aguifer characteristics or groundwater conditions.  If any changes were identified, an evaluation would be
made as to how such changes might affect the performance and the effectiveness of the remedy.

Because Alternative C relies on natural process for which future rates are uncertain, and institutional
controls to prevent exposure to impacted groundwater until the aguifer is restored, contingency planning,
including plans for the implementation of a contingency remedy, if necessary, are required.  The existing
groundwater extraction system at the site  (Alternative A) could be easily implemented as a contingency
remedy.  As a contingency remedy, this system could immediately contain the highest levels of groundwater
contamination at the site and begin to restore the aquifer to cleanup levels through hydraulic pumping.  If
necessary, this system could also be modified to contain the entire plume.  As a contingency remedy,
Alternative A would have the same objectives as the natural attenuation alternative:  restore the aguifer to
Michigan Generic Drinking Water Criteria, MCLs, and an aggregate risk of 1E-04 to 1E-06 for cancer risks and
a hazard index less than 1.0.

Alternative D - Subsurface Barriers to Physically Contain Highest
                Groundwater Impacts, with Natural Attenuation to
                Restore Aguifer Outside Containment Area to Cleanup
                Levels (Physical Barriers Alternative)

       Estimated Cost:   $41 million

•      Estimated Time to Achieve Cleanup Objectives (Lower of MCLs or Michigan Generic Residential Drinking
       Water Criteria):  6 to 18 months to construct barrier; 10 to 15  years to restore aguifer outside of
       containment area to cleanup levels, depending on the rate of intrinsic biodegradation.  Groundwater
       inside the barrier may eventually be restored to health-based levels.

This alternative involves construction of a subsurface barrier to physically contain groundwater with the
highest chemical concentrations at and approximately 800 feet downgradient of the Roto-Finish property.
Aguifer restoration for the groundwater outside the barrier would be achieved through natural fate and
transport processes including intrinsic biodegradation and dispersion.

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The physical barrier would take approximately 6 to 18 months to construct. The time to restore the aquifer
outside the barrier to cleanup levels depends on the rate of intrinsic biodegradation. Site-specific
estimates indicate that, at current rates of biodegradation (0.0008/day), it would take approximately 10 to
15 years to restore the aguifer outside the barrier to cleanup levels. At lower rates of biodegradation
(0.0002/day), or a zero rate of biodegradation, the aguifer outside the barrier would be restored to cleanup
levels in approximately 40 to 50 years. The exact timeframe is uncertain. Although the primary component of
this alternative is containment, the groundwater within the barrier may eventually attenuate to cleanup
levels, depending on the rate of intrinsic biodegradation. As with all alternatives other than the no action
alternative, Alternative D also includes institutional controls, monitoring programs and contingency plans.

Alternative E - Aguifer Restoration through Enhanced Biodegradation

Estimated Cost: $4.2 million

• Estimated Time to Restore the Aguifer to Cleanup Levels (Lower of MCLs or Michigan Generic Residential
Drinking Water Criteria): 15 to 20 years.

This alternative is a variation of Alternative A (on-site pumping), and includes the addition of chemical
enhancements to the groundwater to promote the accelerated biodegradation of contaminants. The chemical
enhancements include nutrients and oxygen, and would be added to the extracted groundwater and reinjected
into the aguifer. Although this technology has been applied successfully to sites with petroleum
hydrocarbons and polynuclear aromatic hydrocarbons, enhanced bioremediation for the chlorinated hydrocarbons
present at the Roto-Finish site is an innovative technology. This alternative would reguire treatability
testing.
Estimates indicate that the time reguired to deliver the nutrients to the zone of impacted groundwater and
achieve cleanup levels would not vary significantly from the rates of biodegradation estimated at the site
under current conditions without chemical enhancements (15 to 20 years); although adding more groundwater
extraction wells and reinjection wells to the system would likely accelerate this rate. Because this
alternative promotes and enhances biodegradation by microorganisms naturally present or added to the
groundwater, the time to achieve cleanup levels for this alternative is not likely to be as affected by any
decreases in the rate of intrinsic biodegradation as would the other alternatives.

IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The relative performance of each remedial alternative was evaluated in the FS and below using the nine
criteria set forth in the NCP at 40 C.F.R. °300.430. An alternative providing the "best balance" of
trade-offs with respect to the nine criteria is determined from this evaluation.

Threshold Criteria

The following two threshold criteria, overall protection of human health and the environment, and compliance
with Applicable or Relevant and Appropriate Reguirements (ARARs) are criteria that must be met in order for
an alternative to be selected.

1. Overall Protection of Human Health and the Environment

Overall protection of human health and the environment addresses whether a remedy eliminates, reduces, or
controls threats to human health and to the environment.

The no-action alternative (Alternative NA) does not meet the reguirements for overall protection of human
health and the environment. Chemical concentrations in the groundwater are expected to naturally decrease
over time. However, the no-action alternative does not include institutional controls, monitoring programs
or contingency planning.

Alternatives A and B (on-site pumping and on-site and off-site pumping) provides protection to human health
and the environment by using hydraulic extraction to restore the aguifer to cleanup levels. Alternative A
combines on-site pumping with natural attenuation (intrinsic biodegradation and/or dispersion), to restore

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the aquifer; while Alternative B restores the aquifer throuqh hydraulic pumpinq without natural attenuation.

Alternative C  (natural attenuation) provides protection to human health and the environment by usinq natural
processes  (primarily intrinsic biodeqradation) to deqrade the chemicals present in the qroundwater and
restore the aquifer to cleanup levels, and includes qroundwater monitorinq to monitor and evaluate the
proqress and effectiveness of the alternatives institutional controls to prevent exposure to contaminated
qroundwater until cleanup levels are achieved, and continqency plans, includinq a continqency remedy, to be
implemented in the event that the remedy is not performinq as anticipated or site conditions chanqe to the
extent that the natural attenuation alternative is no lonqer protective.

Alternative D  (physical barriers) provides protection to human health and the environment by constructinq a
barrier to physically contain the qroundwater in the most contaminated portion of the aquifer, and usinq
natural attenuation (intrinsic biodeqradation and/or dispersion) to restore the aquifer outside of the
containment area to cleanup levels.  Lonq-term institutional controls would be required to prevent exposure
to the qroundwater within the containment area, althouqh the qroundwater inside the containment area may
eventually attenuate to cleanup levels throuqh intrinsic biodeqradation.

Alternative E  (enhanced biodeqradation) protects human health and the environment by usinq enhanced in-situ
biodeqradation, combined with natural attenuation  (intrinsic biodeqradation and/or dispersion) to restore the
aquifer to cleanup levels.

2.  Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

This criterion evaluates whether an alternative meets ARARs set forth in federal, or more strinqent state,
environmental standards pertaininq to the Site or proposed actions.  The ARARs that were identified as beinq
applicable or relevant and appropriate for the remedial action at the Roto-Finish site are summarized in
Table 4.  Because the No Action alternative does not involve conductinq any remedial action at the site, no
ARARs analysis is necessary for Alternative NA.

All alternatives other than the no-action alternative (Alternatives A, B,  C, D and E) are expected to be in
compliance with ARARs.  These alternatives all involve remediation activities and are expected to comply with
Michiqan Act 451 Part 201 (Environmental Response).  All of these alternatives may involve construction or
other work at the Kalamazoo/Battle Creek International Airport and would be expected to comply with Federal
Aviation Administration (FAA) requlations.  All alternatives involve construction or other samplinq
activities and would be expected to comply with the Occupational Safety and Health Act (OSHA).  All
alternatives involve enqineered or natural processes to address qroundwater contamination and are expected to
comply with the Safe Drinkinq Water Act  (SDWA) and Michiqan Act 451 Part 201 (Environmental Response).  All
Alternatives have the potential to qenerate non-hazardous solid waste (e.g., construction debris or
non-hazardous soil debris) and are expected to comply with the Resource Conservation and Recovery Act
requlations for solid waste disposal and Michiqan Act 451 Part 115 (Solid
Waste Manaqement).

Additionally, Alternatives A and B (on-site and on-site and off-site pumpinq) may also involve the qeneration
and storaqe of hazardous waste (e.g., spent carbon); the production of air emissions; discharges to a surface
water body or qroundwater; and construction involvinq excavation.  These alternatives are also expected to
comply with the Resource Conservation and Recovery Act (RCRA) ,  the Clean Air Act (CAA),  the Clean Water Act
(CWA) ,  and Michiqan Act 451 Part 111  (Hazardous Waste Manaqement), Part 121  (Liquid Industrial Waste), Part
31 (Water Resources Protection),  Part 55  (Air Resources Protection),  Part 625  (Mineral Wells) and Part 91
(Soil Erosion and control).   Alternative D (physical barriers),
which involves excavation, would also be expected to comply with the Clean Air Act and Michiqan Act 451 Part
55 (Air Resources Protection) and Part 91 (Soil Erosion and Control). Alternative E  (enhanced biodeqradation)
may also involve excavation activities, and would also be expected to comply with the Clean Air Act and
Michiqan Act 451 Part 55  (Air Resources Protection) and Part 91  (Soil Erosion and Control).

Primary Balancinq Criteria

3.  Lonq-Term Effectiveness and Permanence

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This criterion refers to expected residual risk and the ability of an alternative to maintain reliable
protection of human health and the environment over time once cleanup objectives have been achieved.

The no-action alternative (Alternative NA) does not provide long-term effectiveness and permanence. Chemical
concentrations in the groundwater are expected to degrade naturally over time. However, future rates of
degradation are uncertain and may not continue. No cleanup levels are reguired, and the no-action
alternative does not include any monitoring programs or contingency planning to ensure the effectiveness of
this alternative.

Alternative D (physical barriers) provides for long-term effectiveness and permanence by using barriers to
physically contain groundwater with the highest chemical concentrations, with natural attenuation (intrinsic
biodegradation and/or dispersion) to restore the groundwater in the aguifer outside of the containment area
to cleanup levels. Because the primary component of this alternative is containment, long-term institutional
controls would be reguired to protect the integrity of the barrier and to prevent exposure to the
contaminated groundwater inside the containment area. The groundwater within the containment area may
eventually attenuate to cleanup levels through intrinsic biodegradation.

All of the other alternatives (A, B, C and E) provide the highest degree of long-term effectiveness and
permanence by using hydraulic and/or natural processes to permanently remove groundwater contaminants from
the aguifer and/or to permanently disperse or transform groundwater contaminants into non-toxic chemicals.
These alternatives restore the entire aguifer to its potential future use as a supply of municipal and
industrial drinking water and offer the greatest degree of long-term effectiveness and permanence.

4. Reduction of Toxicity, Mobility, or Volume through Treatment

This criterion evaluates treatment technology performance in the reduction of chemical toxicity, mobility, or
volume. This criterion addresses the statutory preference for selecting remedial actions which include, as a
principal element, treatment that permanently and significantly reduces the volume, toxicity, or mobility of
the hazardous substances, pollutants, and contaminants.

At current rates of biodegradation, all alternatives (including the no-action alternative) would provide some
degree of a reduction of toxicity, mobility or volume through treatment from intrinsic biodegradation.
However, under the no-action alternative, this would not be verified through monitoring. At a zero rate of
biodegradation, Alternative NA (no-action), Alternative C (natural attenuation) and Alternative D (physical
barriers) would not provide for any reduction of toxicity, mobility or volume through treatment. However, if
there were a zero rate of biodegradation with Alternative C, the contingency remedy, Alternative A would be
implemented. Alternative A would then provide for reduction of toxicity, mobility and volume through
hydraulic extraction of the groundwater. At a zero rate of intrinsic biodegradation, Alternatives A and B
(on-site and on-site coupled with off-site pumping) would still provide for a reduction of toxicity, mobility
or volume through treatment by removing groundwater contaminants from the aguifer and by treating the
groundwater as necessary.

5. Short-Term Effectiveness

Short-term effectiveness considers the time to reach cleanup objectives and the risks an alternative may pose
to site workers, the community, and the environment during remedy implementation until cleanup goals are
achieved.

All alternatives (except the no-action alternative) pose some short-term risks to workers during
implementation and operation, but these risks are manageable through proper health and safety practices.
Short-term risks to the community for all alternatives except the no-action alternative would be minimized by
institutional controls to prevent exposure to contaminated groundwater until the aguifer is restored,
monitoring to track and evaluate the performance of the remedy, and contingency planning. Potential
environmental impacts for all alternatives except the no-action alternative would be minimized by compliance
with air emissions, water discharge limits and solid waste regulations. The no-action alternative does not
include any response actions and, therefore, does not pose any risks from implementation.

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The time to achieve response objectives is approximately 15 to 20 years for Alternative E (enhanced
biodegradation). The time to achieve response objectives for the other alternatives (except the no-action
alternative) is dependent upon the rate of intrinsic biodegradation. The no-action alternative does not have
cleanup objectives.

At current rates of biodegradation (0.0008/day), the groundwater outside the containment area for the
physical barrier alternative (Alternative D) would be restored to cleanup levels in approximately 10 to 15
years, and for the other alternatives the impacted aquifer would be restored to cleanup levels in
approximately 15 to 20 years. Groundwater within the physical barrier may also eventually be restored to
cleanup levels depending on the rate of intrinsic biodegradation (approximately 20 to 25 years based on the
current biodegradation rate of 0.0008/day).

At a decreased rate of biodegradation (0.0002/day), or a zero rate of biodegradation, the groundwater outside
the containment area for the physical barrier alternative (Alternative D) would be restored in approximately
40 to 50 years, and the impacted aguifer for the on-site and on-site with off-site pumping alternatives
(Alternatives A and B) would be restored in approximately 40 to 50 years. For the natural attenuation
alternative (Alternative C), the impacted aguifer would be restored to cleanup levels in approximately 50 to
60 years at a biodegradation rate of 0.0002/day, but would not be restored at a zero rate of biodegradation,
and would require the implementation of a contingency plan.

While the degradation rates for the no-action alternative are the same as for the natural attenuation
alternative, the no-action alternative (Alternative NA) does not provide for short-term effectiveness. The
no-action alternative does not include monitoring to track groundwater contaminants or to verify that
degradation is occurring, and does not include any contingency planning. No institutional controls would be
implemented under the no-action alternative, and existing institutional controls would not be monitored.

6. Implementability

This criterion addresses the technical and administrative feasibility of implementing an alternative, and the
availability of various services and materials required for its implementation.

The no-action alternative (Alternative NA) would be technically and administratively feasible because it
would only require cessation of current removal activities and monitoring. The on-site pumping alternative
(Alternative A) is the most technically and administratively feasible, as it is already in place, although
slight administrative delays could be encountered to obtain access and permits if a discharge option other
than the current discharge to the Kalamazoo wastewater treatment plant were implemented, or to install any
additional off-site groundwater monitoring wells.

Groundwater extraction through on-site and off-site wells (Alternative B) would be technically feasible, and
it involves the same technology as has already been implemented for the non-time critical removal action.
The administrative feasibility of this alternative would however, be limited because access to the airport
property would be required, which may delay implementation. This would apply to the natural attenuation
alternative (Alternative C) as well, because access to airport property would be required for the
installation of downgradient monitoring wells.

The physical barrier alternative (Alternative D) may have significant limitations to its technical
feasibility due to the lack of a competent underlying layer and limited post-construction quality assurance.
Enhanced biodegradation (Alternative E) uses conventional components, so it is technically feasible to
construct. However, the successful delivery of chemical enhancements to the affected aquifer may pose
problems for the implementation of this alternative.

The only alternative that may present some limitations with respect to goods and services is the physical
barrier alternative (Alternative D). This alternative would require a specialized geotechnical contractor.
There are relatively few such contractors in the country, which may limit the schedule for implementation.

7. Cost

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This criterion compares the capital, O&M, and present worth costs of implementing the alternatives at the
site. The Cost Summary is shown in Table 5.

Modifying Criteria

8 . State Acceptance

The State of Michigan has indicated that it does not concur with the selection of Alternative C, Natural
Attenuation for remediation of the Roto-Finish site, with Alternative A, On-Site Pumping as the selected
contingency remedy. The State of Michigan will provide U.S. EPA with a letter of non-concurrence, which will
be attached to this ROD.

9. Community Acceptance

Comments have been submitted by community members, local government officials, and the potentially
responsible party (PRP). The comments and the responses to those comments are described in the
Responsiveness Summary. In general, the public supports the selected remedy and the selected contingency
remedy.

X. THE SEIiECTED REMEDY

Based upon considerations for the requirements of CERCLA, the NCP and balancing of the nine criteria, the
U.S. EPA has determined that Alternative C, Natural Attenuation, is the most appropriate remedy for the site,
and that Alternative A, On-Site Pumping, is the most appropriate contingency remedy. The components of the
selected remedy and the selected contingency remedy are described below.

Natural Attenuation to Restore the Aquifer - Natural processes will be used to restore the groundwater to
performance standards throughout the aquifer. The primary attenuation process at the Roto-Finish site is
intrinsic biodegradation. The performance standards for the site are shown in Table 6, and are the lower of
either U.S. EPA MCLs or the Michigan Act 451 Part 201 Residential Drinking Water Standards. Based upon the
potential for exposure to multiple contaminants in the groundwater, the cumulative risks from exposure to
groundwater will also be reduced to 1E-04 or less for carcinogenic risks and a hazard index of less than 1.0
for noncancer risks. Using the assumptions in the baseline risk assessment, residential exposure to vinyl
chloride (one of the final degradation products of the contaminants in the groundwater) at the MCL and Part
201 Residential Criteria of 2.0 ug/1, corresponds to an excess lifetime cancer risk of 5E-05.

These performance standards and risk-based levels apply to all points throughout the aquifer. Performance
standards for groundwater contaminants attributable to background groundwater quality conditions will be
established based on the results of site-specific background monitoring.

Site-specific estimates indicate that, at current rates of degradation (0.0008/day), performance standards
would be achieved through the aquifer in approximately 15 to 20 years. At a lower rate of degradation
(0.0002/day), performance standards would be achieved throughout the aquifer in approximately 50 to 60 years.
Performance standards would not be achieved at a zero rate of degradation.

Based on current aquifer characteristics and current land and groundwater use conditions, it is anticipated
that a maximum aquifer restoration timeframe of approximately 50 to 60 years for the natural attenuation
alternative is reasonable for the site. If current site conditions change (i.e., changes in groundwater use,
groundwater flow direction, or data indicating that intrinsic biodegradation is not occurring as expected or
that restoration may not occur within a timeframe of approximately 50 to 60 years), the effectiveness of the
natural attenuation alternative will be reevaluated. If the evaluation indicates that the aquifer will not
be restored within an approximately timeframe of 50 to 60 years, or that potential risks to users at existing
or any new wells from site-related groundwater contaminants would exceed Michigan drinking water criteria,
MCLs, or an aggregate risk of 1E-04 for cancer risks or a
hazard index of 1.0 for noncancer risks, Alternative A (the existing on-site pumping system) will be
implemented as a contingency remedy (see Contingency Remedy).

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Institutional Controls - Institutional controls will be implemented to restrict exposure to contaminated
groundwater until the aquifer is restored.  Existing institutional controls that currently limit exposure to
contaminated groundwater include the availability of a municipal water supply; the adjacent operations of the
Kalamazoo/Battle Creek International Airport which currently limit land use and development downgradient of
the site; current airport management policy which does not permit the installation of drinking water wells on
airport property; and Kalamazoo County local ordinance (Section 11.04 of the Kalamazoo County Human Services
Sewage Disposal and Water Supply Regulations) which requires the issuance
of a well-permit and is intended to prohibit the installation of new drinking water wells in areas of
environmental degradation.  Additional institutional controls such as deed restrictions, deed notices and/or
deed covenants will also be implemented where feasible to provide additional assurances.

Groundwater Monitoring - A long-term groundwater monitoring program will be designed to track the horizontal
and vertical extent of the contaminated groundwater plume boundaries radially from the site and to monitor
changes in chemical constituents and chemical concentrations.  The groundwater monitoring program will be
designed to collect data to confirm that intrinsic biodegradation is occurring and, to the extent possible.
to quantify the observed rates over time.  The groundwater monitoring program will be designed to provide
sufficient advance warning of any expansion of the plume, including expansion beyond the original non-detect
plume boundary delineated in Figure 4-5 of the RI/FS Report, and expansion toward any existing or new water
supply wells.  The groundwater monitoring program will be designed to warn of potential risks to users of
existing wells, or any new wells that are installed in the area, and to verify that natural attenuation is
still projected to meet the remedial objectives within a timeframe of approximately 50 to 60 years.  The
groundwater monitoring program will also include monitoring to identify any changes in groundwater use
conditions (e.g., the installation of any new wells in the area), and any
changes in aquifer characteristics or groundwater conditions.  If any changes are identified, an evaluation
will be made to determine how such changes might affect the performance and the effectiveness of the remedy.

The groundwater monitoring program will include the monitoring of existing groundwater monitoring wells and
new additional groundwater monitoring wells.  The groundwater monitoring plan will also include monitoring to
determine whether the inorganic chemicals detected in the groundwater, and any other groundwater
contaminants, if necessary, are due to site-related conditions,  or are the result of background chemical
concentrations in groundwater.

Contingency Planning - Contingency plans will be developed as needed to respond to any differences in the
actual performance of the alternative and actual site conditions, compared to the expected performance of the
alternative and expected site conditions.  Implementation of the contingency plans will be based on data and
information collected during the monitoring programs.  The contingency plans will include modifications to
institutional controls, modifications to the monitoring programs, and implementation of Alternative A (the
existing on-site extraction system) as a contingency remedy, if necessary.

Modifications to institutional controls will include changes in the type(s) of institutional controls
implemented,  the implementation of additional institutional controls, and the implementation of institutional
controls over additional areas.  Modifications to the monitoring programs will include additional monitoring
elements, the installation of additional groundwater monitoring wells, if necessary, and modifications to
groundwater sampling locations and analytical parameters.

Contingency Remedy - If the information and the data collected during the monitoring indicates that the
aquifer will not be restored within a timeframe of approximately 50 to 60 years, or that potential risks to
users at existing or any new wells from site-related groundwater contaminants would exceed Michigan drinking
water criteria, MCLs, or an aggregate risk of 1E-04 for cancer risks or a hazard index of 1.0 for noncancer
risks, Alternative A (the existing on-site pumping system) will be implemented as a contingency
remedy.

As a contingency remedy, Alternative A will immediately contain the highest levels of groundwater
contamination at the site and begin to restore the aquifer to cleanup levels through hydraulic pumping.   If
necessary, Alternative A may be modified to contain a larger portion of the plume, or the entire plume,  to
prevent any unacceptable risks to existing or new wells if site conditions change.  The cleanup objectives
for Alternative A are the same as the cleanup objectives for the natural attenuation alternative:  restore

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the aquifer to the lower of either Michigan Generic Residential Drinking Water Criteria or MCLs. Based upon
the potential for exposure to multiple contaminants in the groundwater, the cumulative risks from exposure to
groundwater will also be reduced to 1E-04 or less for carcinogenic risks
and a hazard index of less than 1.0 for noncancer risks. Performance standards for groundwater contaminants
attributable to background groundwater quality conditions will be established based on the results of
site-specific background monitoring.

Alternative A also includes institutional controls to prevent exposure to contaminated groundwater until the
aquifer is restored to cleanup levels, monitoring programs and contingency planning.

XI. EXPLANATION OF SIGNIFICANT CHANGES

There are no significant changes from the recommended alternative and the recommended contingency alternative
described in the proposed plan.

XII. STATUTORY AUTHORITY FINDING

U.S. EPA's primary responsibility at Superfund Sites is to undertake remedial actions that protect human
health and the environment. Section 121 of CERCLA has established several statutory requirements and
preferences. These include the requirement that the selected remedy, when completed, must comply with all
applicable, relevant and appropriate requirements ("ARARs") imposed by Federal and State environmental laws,
unless the invocation of a waiver is justified. The selected remedy must also provide overall effectiveness
appropriate to its cost, and use permanent solutions and alternative treatment technologies, or resources
recovery technologies, to the maximum extent practicable. Finally, the statute establishes a preference for
remedies which employ treatment that significantly reduces the toxicity, mobility or volume of contaminants.

If the rate of natural attenuation as described in Alternative C decreases or there is an unanticipated
change in groundwater use or groundwater conditions to the extent that the natural attenuation remedy is no
longer protective, the contingency remedy, Alternative A (on-site pumping) will be implemented to achieve
these objectives. Therefore, this Statutory Determinations Section will discuss both Alternative C and
Alternative A.

1. Protection of Human Health and the Environment

Alternative C (natural attenuation) provides protection to human health and the environment by using natural
processes (primarily intrinsic biodegradation) to degrade the chemicals present in the groundwater and
restore the aquifer to cleanup levels, and includes groundwater monitoring to monitor and evaluate the
progress and effectiveness of the alternative, institutional controls to prevent exposure to contaminated
groundwater until cleanup levels are achieved, and contingency plans, including a contingency remedy, to be
implemented in the event that the remedy is not performing as anticipated or site conditions change to the
extent that the natural attenuation alternative is no longer protective. No unacceptable short-term risks
will be caused by implementation of Alternative C.

Alternative A also provides protection to human health and the environment by using hydraulic extraction to
restore the aquifer to cleanup levels. Alternative A combines on-site pumping with natural attenuation
(intrinsic biodegradation and/or dispersion) to restore the aquifer. Under Alternative A institutional
controls will be also be imposed to restrict use of the groundwater. No unacceptable short-term risks will
be caused by implementation of Alternative A.

2. Compliance with ARARs

The selected remedy will comply with all identified applicable or relevant and appropriate federal
requirements, and with those state requirements which are more stringent, unless a waiver is invoked pursuant
to Section 121(d)(4)(B) of CERCLA.

For a complete list of ARARs for the alternatives at this site, see Table 4 of this ROD. Both Alternative C
and Alternative A, the Contingency Remedy outlined in Alternative C, involve remediation activities and will

-------
comply with Michigan Act 451 Part 201 (Environmental Response).
Michigan Administrative Rule 299.5705(5) of Act 451 part 201 indicates that unless a waiver has been granted,
the horizontal and vertical extent of hazardous substances is not to increase after the initiation of
remedial activities. Part 201 of Act 451 at Section 324.20118(5) permits implementation of a remedy that
does not comply with Administrative Rule 299.5705(5) if there is "a finding that the remedial action is
protective of public health, safety, and welfare, and the environment." U.S. EPA has determined, and has
made a finding that both Alternative C and Alternative A are protective of public health, safety, welfare,
and the environment, and therefore U.S. EPA has complied with the substantive
reguirements of Part 201 of Act 451 at Section 324.20118(5). Similarly, this U.S. EPA finding is sufficient
to conclude that the grounds for acguiring a waiver of Rule 299.5705(5) have also been met. Therefore, U.S.
EPA has also met the substantive reguirement of Rule 299.5705(5) by determining that a waiver of this
reguirement should issue based on U.S. EPA's finding that public health, safety, welfare and the environment
are protected by both Alternative C and Alternative A.

Both Alternative C and Alternative A may involve construction or other work at the Kalamazoo/Battle Creek
International Airport and will comply with Federal Aviation Administration (FAA) regulations. Both
Alternative C and Alternative A involve construction or other sampling activities and will comply with the
Occupational Safety and Health Act (OSHA). Both Alternative A and Alternative C involve engineered or
natural processes to address groundwater contamination and will comply with the Safe Drinking Water Act
(SDWA) and Michigan Act 451 Part 201 (Environmental Response). Both Alternative A and Alternative C have the
potential to generate non-hazardous solid waste (e.g., construction debris or non-hazardous soil debris) and
will comply with the Resource Conservation and Recovery Act regulations for solid waste disposal and Michigan
Act 451 Part 115 (Solid Waste Management).

Additionally, Alternative A may also involve the generation and storage of hazardous waste (e.g., spent
carbon); the production of air emissions; discharges to a surface water body or groundwater; and construction
involving excavation. Alternative A will comply with the Resource Conservation and Recovery Act (RCRA), the
Clean Air Act (CAA), the Clean Water Act (CWA) , and Michigan Act 451 Part 111 (Hazardous Waste Management),
Part 121 (Liguid Industrial Waste), Part 31 (Water Resources Protection), Part 55 (Air Resources Protection),
Part 625 (Mineral Wells) and Part 91 (Soil Erosion and Control).

3. Cost Effectiveness

Cost effectiveness compares the effectiveness of an alternative in proportion to the cost of providing
environmental benefits. The costs associated with the implementation of Alternative C, the selected remedy,
and the contingency remedy Alternative A, are summarized below.

Alternative Total Capital Costs Total Annual O&M Total Present Worth

C $30,000 $50,000 $500,000

A $0-$700,000 $100,000-$170,000 $1.5M-$2.2M

Alternative C is cost effective because it provides the greatest overall effectiveness proportionate to its
costs when compared to the other alternatives evaluated, the present worth being $500,000. The estimated
cost of Alternative C is significantly less than the costs of Alternatives A, B, D & E, but still will reduce
the contamination in the groundwater in approximately the same length of time as the other alternatives.
Alternative C assures that the remedy will be effective in the long-term because it uses natural processes to
permanently disperse or transform groundwater contaminants into non-toxic chemicals, with groundwater
monitoring to assure that these natural processes are taking place. Alternative C also restores the entire
aguifer to its potential future use as a supply of municipal and industrial drinking water.

Similarly, in the event a contingency remedy needs to be implemented, Alternative A provides the greatest
overall effectiveness proportionate to its costs when compared to the other potential contingency
alternatives evaluated, the present worth being $1.5 million to $2.2 million, depending on the final
treatment and discharge options selected in the final design. It also will reduce the contamination in the

-------
groundwater in approximately the same length of time as the other alternatives. Alternative A assures that
the remedy will be effective in the long-term because it uses natural processes to permanently disperse or
transform groundwater contaminants into non-toxic chemicals. Alternative A also restores
the entire aquifer to its potential future use as a supply of municipal and industrial drinking water.

4. Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable

Alternative C represents the maximum extent to which permanent solutions and treatment technologies can be
used in a cost-effective manner at this site. Of those alternatives that are protective of human health and
the environment and that comply with ARARs, U.S. EPA has determined that Alternative C provides the best
balance in terms of long-term effectiveness and permanence, reduction of toxicity, mobility, or volume of
contaminants, short term effectiveness, implementability, and cost. If the contingency remedy Alternative A
needs to be implemented, U.S. EPA has determined that Alternative A provides the best balance in terms of
long-term effectiveness and permanence, reduction of toxicity, mobility, or volume
of contaminants, short term effectiveness, implementability, and cost of the remaining alternatives that
comply with ARARs and are protective of human health.

Groundwater monitoring to assure that the intrinsic biodegradation is continuing to take place, as well as
implementation of institutional controls will provide the most permanent solution practical, proportionate to
the cost. In the event the contingency remedy Alternative A needs to be implemented, the on-site groundwater
extraction system coupled with natural attenuation, and the implementation of institutional controls will
provide the most permanent solution practical, proportionate tot he cost, of the remaining alternatives.

5. Preference for Treatment as a Principal Element

Based on current information, U.S. EPA believes that Alternative C is protective of human health and the
environment and utilizes permanent solutions and alternative treatment technologies to the maximum extent
possible. Alternative C provides for a reduction of toxicity, mobility or volume through treatment from
biodegradation. If the contingency remedy Alternative A needs to be implemented, it provides for a reduction
of toxicity, mobility or volume through treatment by removing groundwater contaminants from the
aguifer and by treating the groundwater as necessary.

XIII. SUMMARY

The selected remedy and the selected contingency remedy are protective of human health and the environment,
comply with Federal and State Requirements that are legally applicable or relevant and appropriate to the
remedial action, and are cost effective. The selected remedy and the selected contingency remedy utilize
permanent solutions and alternative treatment or resource recovery technologies to the maximum extent
practicable. The selected remedy and the selected contingency remedy satisfy the statutory preference for
remedies that employ treatment that reduces the toxicity, mobility, or volume as a principal element. This
statutory preference for treatment is satisfied through intrinsic biodegradation for the selected remedy, and
through groundwater extraction and treatment for the selected contingency remedy.

A review will be conducted within five years after commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment because this remedy will
result in hazardous substances remaining at the facility above health-based levels.

U.S. EPA has determined that its response at this site is complete. Therefore, the site now qualifies for
inclusion on the Construction Completion List.

-------
          CHEMICALS  DETECTED IN SOILS AND GROUNDWATER
                                      SOIL
                                                                           SROUNDWATER
CHEMICAL
                          Frequency of
                            Detection
VOLATILES
Vi nyl chlori de
Chloroethane
Methylene Chloride
Acetone
Carbon Disulfide
1,1-Dichloroethene
1,1-Dichloroethane
1,2-Dichloroethene
Chloroform
1,2-Dichloroethane
1,1,1-Trichloroethane
Bromodichloromethane
Trichloroethene
1,1,2-Trichlorethane
Benzene
4-Methyl-2-pentanone
Tetrachloroethene
1,1,2,2-Tetrachlorethane
Toluene
Chlorobenzene
Ethylbenzene
Total Xylenes
SEMIVOLATILES
Phenol
1,4-Dichlorobenzene
1,2-Dichlorobenzene
Napthalene
2-Methylnapthalene
Acenapthene
4-Nitrophenol
Dibenzofuran
Fluorene
Pentachlorophenol
Phenanthrene
Anthracene
Carbazole
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Bis(2-ethylhexyl)phthalate
Di-n-octylphthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Bibenzo(a,h)anthracene
Benzo(g,h,i)perylene
MOCA
                  1-4
                     6
                 43-4^
1/46

-------
TABIiE 1  (continued)
CHEMICALS DETECTED IN SOILS AND GROUNDWATER
               SOIL
                                                                         GROUNDWATER
CHEMICAL
                         Frequency of
                           Detection
                   Range of Detected
                    Concentrations
Frequency of
  Detection
Ranqe of Detected
  Concentrations
INORGANICS

Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Thallium
Vanadium
Zinc
Cyanide
                         (ug/kg)
                     (ug/1)
63/63
1/63
61/63
63/63
12/63
2/63
61/61
63/63
37/63
61/63
63/63
63/63
61/63
63/63
4/63
50/63
26/63
2/63
27/63
-
50/63
62/63
-
898-15,400
16.2
0.56-61.2
4.3-145
0.25-1.4
0.97-53.2
347-98,500
2.3-20.6
1.4-16
2.4-55.1
2,570-48, 600
1-162
514-61,000
35.7-2,590
0.1-0.37
2.9-33.3
242-2,520
0.95-1.6
113-235
-
3.3-97.4
9.2-370
-
7/81
4/81
21/81
81/81


81/81
13/81
16/81
19/81
58/81
9/81
81/81
81/81
1/81
32/81
69/81

80/81
1/81
5/81
50/81
2/69
31.6-892
19.4-32.5
1.5-41.6
6.4-279


4,500-259,000
1.2-5.5
1.7-23.2
3.1-16.7
18-3,320
1.1-3.1
1,900-66,200
4.8-1,490
0.24
1.5-95.8
748-40,800

2,840-246,000
6.4
0.44-6
3.3-3,930
15.3-15.9

-------
TABIiE 2:  CHEMICALS OF POTENTIAL CONCERN
SOIL
1,2-Dichloroethene
1,1,2,2-Tetrachloroethane
Toluene
1,2-Dichlorobenzene
Naphthalene
Acenapthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Carbazole
Fluoranthene                   MOCA
Pyrene                         Aluminum
Benzo(a)anthracene             Antimony
Chrysene                       Arsenic
Bis(2-ethylhexyl)phthalate     Barium
Benzo(b)fluoranthene           Beryllium
Benzo(k)fluoranthene           Cadmium
Benzo(a)pyrene                 Calcium
Indeno(1,2,3-cd)pyrene         Chromium
Bibenzo(a,h)anthracene         Cobalt
Benzo(g,h,i)perylene           Copper
                                                              Iron
                                                              Lead
                                                              Magnesium
                                                              Manganese
                                                              Mercury
                                                              Nickel
                                                              Potassium
                                                              Selenium
                                                              Sodium
                                                              Vanadium
                                                              Zinc
GROUNDWATER
Vinyl chloride
Chloroethane
Methylene Chloride
Acetone
Carbon Bisulfide
1,1-Dichloroethene
1,1-Dichloroethane
1,2-Dichlorethene
Chloroform
1,2-Dichloroethane
1,1,1-Trichlorethane
Bromodichloromethane
Trichloroethene
1,1,2-Trichlorethane
Benzene
4-Methyl-2-pentanone
Tetrachlorethene
Toluene
Chlorobenzene
Ethylbenzene
Total Xylenes
Phenol
1,4-Dichlorobenzene
1,2-Dichlorobenzene
2-Methylnaphthalene
4-Nitrophenol
Pentachlorophenol
Phenanthrene
Fluoranthene
Benzo(a)anthracene
                               Chrysene                       Copper
                               Bis(2-ethylhexyl)phthalate     Iron
                               Di-n-octylphthalate            Lead
                               Benzo(b)fluoranthene           Magnesium
                               Benz o(k)fluoranthene           Mangane s e
                               Benzo(a)pyrene                 Mercury
                               Indeno(1,2,3-cd)pyrene         Nickel
                               MOCA                           Potassium
                               Aluminum                       Sodium
                               Antimony                       Thallium
                               Arsenic                        Vanadium
                               Barium                         Zinc
                               Calcium                        Cyanide
                               Chromium
                               Cobalt

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                    TABIiE 4
            FEDERAL AND STATE ARARs

Federal ARARs

Federal Aviation Administration Rules  (FAA)
Resource Conservation and Recovery Act  (RCRA)
Clean Air Act  (CAA)
Clean Water Act  (CWA)
Occupational Safety and Health Act  (OSHA)
Safe Drinking Water Act  (SWDA)
State ARARs

Michigan Natural Resources Environmental Protection Act  (Act  451),  including:

Hazardous Waste Management  (Part 111)
Solid Waste Management  (Part 115)
Liguid Industrial Waste  (Part 121)
Water Resources Protection  (Part 31)
Air Resources Protection  (Part 55)
Mineral Wells (Part 625)
Soil Erosion and Sedimentation Control  (Part 91)
Environmental Response  (Part 201)

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TABIiE 5:  CAPITAL, O&M AND PRESENT WORTH COSTS

ALTERNATIVE
Alternative NA
No-Action

Alternative A
On-Site Pumping

Alternative B
On-Site and Off-Site
Pumping

Alternative C
Natural Attenuation

Alternative D
Physical Barriers
  Capital Costs

        $0
      $30,000
    $40,300,000
Alternative E              $1,600,000
Enhanced Biodegradation
    COST

Annual O&M

      $0
    $50,000


    $70,000


   $260,000
Present Worth

      $0
    $0-$700,00         $100,000-$170,000      $1,500,000-$2,200,000


$360,000-$860,000      $130,000-$310,000      $2,000,000-$3,500,000
    $500,000
   $41,000,000
                                                     $4,200,000
Note:  Costs for Alternative A and Alternative B vary depending on final treatment and discharge options.

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TABIiE 6:  PERFORMANCE STANDARDS FOR GROUNDTCATER CIiEANUP
                                GROUNDWATER
                                                                       ARARs
                                                                                                   PERFORMANCE
                                                                                                  STANDARDS  FOR
                                                                                                  GROUNDWATER(1)
CHEMICAL
VOLATILES

Vinyl chloride
Chloroethane
Methylene Chloride
Acetone
Carbon Disulfide
1,1-Dichloroethene
1,1-Dichloroethane
1,2-Dichloroethene
Chloroform
1,2-Dichloroethane
1,1,1-Trichloroethane
Bromodichloromethane
Trichloroethene
1,1,2-Trichlorethane
Benzene
4-Methyl-2-pentanone
Tetrachloroethene
Toluene
Chlorobenzene
Ethylbenzene
Total Xylenes
                          Frequency
                              of
                          Detection
   Range of
   Detected
Concentrations
    (ug/1)
  Federal Safe
 Drinking Water
    Maximum
  Contaminant
Levels(MCLs)(2)
18/90
5/90
1/90
7/90
1/90
39/90
49/90
33/90
1/90
1/90
45/90
1/90
36/90
3/90
1/90
1/90
15/90
7/90
14/90
3/90
2/90
4-120
5-79
3
4-27
2
1-480
1-270
1-150
44
1
1-2,700
4
1-170
2-5
14
12
1-25
1-40
4-270
2-17
2-24
2
-
5
-
-
7
5
170
100 (5)
5
200
100 (4)
5
3 (5)
5
-
5
1,000
100
700
10,000
2
220
5
730
800
7
5
170
100
5
200
100
5
5
5
370
5
1,000
100
700
10,000
Michigan Act 451     Lower of Either
    Part 201      MCLs or Michigan Part
  Residential   201 Residential Drinking
Drinking Water       Water Criteria
  Criteria(S)
                                                                 2
                                                                220
                                                                 5
                                                                730
                                                                800
                                                                 7
                                                                 5
                                                                170
                                                                100
                                                                 5
                                                                200
                                                                100
                                                                 5
                                                                 3
                                                                 5
                                                                370
                                                                 5
                                                               1,000
                                                                100
                                                                700
                                                              10,000

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SEMIVOLATILES                               (ug/1)

Phenol                       9/46           2-40               -                4,400                 4,400
1,4-Dichlorobenzene          1/46            2                 75                 75                    75
1,2-Dichlorobenzene          3/46           2-27              600                600                   600
2-Methylnapthalene           1/46            3                 -                  ID
4-Nitrophenol                1/46            1                 -                   -
Pentachlorophenol            1/46            211                     1
Phenanthrene                 2/46           1-4                -                  26                    26
Fluoranthene                 1/46            3                 -                 880                   880
Benzo(a)anthracene           1/46            6                 -                 1.2                   1.2
Chrysene                     1/46            6                 -                 120                   120
Bis(2-ethylhexyl)phthalate   2/46          43-47               66                     6
Di-n-octylphthalate          2/46          15-17               -                 130                   130
Benzo(b)fluoranthene         1/46            5                 -                 1.2                   1.2
Benzo(k)fluoranthene         1/46            6-12                     12
Benzo(a)pyrene               1/46            4                 2                 0.2                   0.2
Indeno(l,2,3-cd)pyrene       1/46            2                 -                 1.2                   1.2
Benzo(g,h,i)perylene         1/46            3-26                    26

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TABIiE 6  (continued):  PERFORMANCE STANDARDS FOR GROUNDTCATER CLEANUP
                                GROUNDWATER
                                                                       ARARs
CHEMICAL
INORGANICS

Aluminum
Antimony
Arsenic
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Thallium
Vanadium
Zinc
Cyanide
                          Freguency
                              of
                          Detection
                                                                                                  PERFORMANCE
                                                                                                 STANDARDS  FOR
                                                                                                 GROUNDWATER(1)
   Range of
   Detected
Concentrations
    (ug/1)
 Federal Safe
Drinking Water
   Maximum
 Contaminant
 Levels(MCLs)
Michigan Act 451     Lower of Either
    Part 201      MCLs or Michigan Part
  Residential   201 Residential Drinking
Drinking Water       Water Criteria
   Criteria
7/81
4/81
21/81
81/81
81/81
13/81
16/81
19/81
58/81
9/81
81/81
81/81
1/81
32/81
69/81
80/81
1/81
5/81
50/81
2/69
31.6-892
19.4-32.5
1.5-41.6
6.4-279
4,500-259,000
1.2-5.5
1.7-23.2
3.1-16.7
18-3,320
1.1-3.1
1,900-66,200
4.8-1,490
0.24
1.5-95.8
748-40,800
2,840-246,000
6.4
0.44-6
3.3-3,930
15.3-15.9
-
6
50 (7)
2000
-
100
-
1,300 (5)
-
15 (8)
-
-
2
100 (9)
-
-
0.5 (5)
-
-
200
ID
6 (6)
50 (6)
2000 (6)
-
100 (6)
37
1,400 (6)
300 (6)
4 (6)
420,000
860 (6)
2 (6)
100 (6)
-
160,000
2 (6)
64 (6)
2,400 (6)
200
-
6
50
2000
-
100
37
1,300
-
4
420,000
860
2
100
-
160,000
0.5
64
2,400
200

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ID - Inadequate data to develop criterion.

1.  In addition to achieving MCLs and Michigan Drinking water criteria,  the groundwater must be restored to an aggregate risk of
    1E-04 or less for cancer risks and a hazard index less than 1.0 for noncancer risks at all points throughout the aguifer.
    Performance standards for groundwater contaminants attributable to background groundwater quality conditions will be
    established based on the results of site-specific background groundwater monitoring.

2.  Sources:  Code of Federal Regulations (CFR)  40 Part 141; "Drinking Water Regulations and Health Advisories" by U.S.
    EPA Office of Water, May 1995.  Non-zero Maximum Contaminant Level Goals (MCLGs)  apply when less than the MCL.

3.  Source:   MDEQ Environmental Response Division Operational Memoranda #8, Revision 4, and #14,  Revision 2.

4.  1994 proposed rule for disinfectants and disinfection by-products:  total for all trihalomethanes combined cannot exceed 80 ug/1.

5.  Non-Zero Maximum Contaminant Level Goal (MCLG).

6.  Background, as defined in Michigan Act 451 Part 201 Rule 701(c),  may be substituted if higher than the cleanup criteria.

7.  Under review.

8.  Action level.

9.  Being remanded.

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                        APPENDIX A

                  RESPONSIVENESS SUMMARY


The public participation requirements of CERCLA sections 113 (k) (2) (i-v) and 117 of CERCLA were met during the
remedy selection process.  These sections require U.S. EPA to respond "...to each of the significant
comments, criticisms, and new data submitted in written or oral presentations" on a proposed plan for a
remedial action.  The Responsiveness Summary addresses concerns expressed by the public, potentially
responsible parties  (PRPs),  and governmental bodies in written and oral comments received by U.S. EPA and the
State regarding the proposed remedy for the Roto-Finish site.

BACKGROUND

Availability Sessions

Public availability sessions were conducted by U.S. EPA in Portage, Michigan, in August 1988 and January
1992.  At the meetings, residents were provided with information about the Superfund process, results of past
investigations and studies conducted at the site, and upcoming activities to be performed during the Remedial
Investigation/Feasibility Study (RI/FS).   A fact sheet describing background information about the site and
explaining how the RI/FS would be conducted was issued in October 1988.  A site activities update letter
summarizing Phases I and II of the RI, and announcing a third phase of field work, was
issued in January 1992.

Information Repository

An information repository and an administrative record for the site have been established at the Portage
Public Library, 300 Library Lane,  Portage, Michigan.  Documents related to the "removal" phase of the
project, as well as documents related to the "remedial" phase are included here.  An administrative record
has also been established at U.S.  EPA, Region 5, in Chicago.

Fact Sheets and Public Meetings

Non-Time Critical and Removal Action:  A fact sheet summarizing the Engineering Evaluation/Cost Analysis
(EE/CA)  and U.S. EPA's recommended removal action plan was issued in September 1994.  A public meeting to
discuss the EE/CA and accept public comments on the recommended removal alternative was held in October 1994.
Available information about the RI/FS was also discussed during the meeting.  Oral comments on the
EE/CA were documented by a court reporter.  A verbatim transcript of the public meeting was placed in the
information repository and the administrative record for the removal action.  Written comments on the EE/CA
were accepted during a 30-day public comment period from October 1, 1994 through October 31, 1994.  In
general, the public supported the proposed removal action.

Proposed Remedial Alternative:  The RI/FS was completed in September 1996 and made available to the public in
October 1996.  A Proposed Plan was issued on October 22, 1996. An advertisement was placed in the Kalamazoo
Gazette on October 23, 1996 to announce the Proposed Plan, the public meeting and the public comment period.
A public meeting was held on November 13, 1996 to discuss the RI/FS and the Proposed Plan.  At the public
meeting, representatives from the U.S. EPA and the Michigan Department of Environmental Quality answered
questions about the site and the remedial alternatives under consideration.
Formal oral comments on the Proposed Plan were documented by a court reporter.  A verbatim transcript of the
public meeting has been placed in the information repository and the administrative record.  Written comments
were also accepted at this meeting.  The meeting was attended by approximately 30 persons, including local
residents and the potentially responsible party  (PRP).

The RI/FS and the Proposed Plan were available for public comment from October 24, 1996 through November 23,
1996.  During the comment period,  EPA received four written comments and four oral comments concerning the
Proposed Plan.  One written comment was a restatement of an oral comment submitted during the public meeting.
Comments received during the public comment period and U.S. EPA's responses to those comments are included

-------
below. In general, the public supports the selected remedy and the selected contingency
remedy.

SUMMARY OF PUBLIC COMMENTS

Comment 1: The executive director of the Michigan Chemical Council headguartered in Lansing, Michigan,
expressed support of U.S. EPA's Proposed Plan for groundwater contamination at the site. The director
commends U.S. EPA for its proactive approach in recognizing innovative ways to achieve cleanup and reuse
contaminated sites.

Response 1: U.S. EPA acknowledges support for the natural attenuation alternative.

Comment 2: Concern was expressed regarding the migration of groundwater contaminants and their potential to
impact uncontaminated groundwater during natural attenuation.

Response 2: Groundwater modeling indicates that any impacts to uncontaminated groundwater will be minimal.
Specifically, while the groundwater contaminants at the Rto-Finish site have the potential to migrate,
microorganisms naturally present in the groundwater are expected to break down the groundwater contaminants
into less toxic compounds through a process known as biodegradation. These less toxic compounds include
ethanol, carbon dioxide and water.

Diagrams produced by the modeling show that as a result of biodegradation, it is expected that groundwater
contaminants will stop migrating and will eventually start to recede as the chemicals in the groundwater
degrade and chemical concentrations decrease. This is illustrated by Figures 1-25, 1-27, 1-28 and 1-29 in
Appendix I of the Remedial Investigation/Feasibility Study Report (RI/FS). These figures are also included
at the end of this document, and are discussed below.

The initial estimated extent of the groundwater contamination is shown in Figure 1-25. Figure 1-25, and the
other figures, are based on groundwater data collected before the on-site groundwater extraction system began
to pump out the most contaminated groundwater at the site.

Figures 1-27(a,b,c,d) show the expected movement of groundwater contaminants over a 30 year period assuming
no biodegradation. As shown in the figure, after 30 years without biodegradation, the groundwater
contamination would migrate approximately 3,100 feet beyond its current extent.

The expected movement and changes in groundwater contaminants over a 15 year period assuming the process of
biodegradation is shown in Figures 1-28 and 1-29. Figure 1-28 is based on current estimated rates of
biodegradation and shows that after 5 years, the groundwater contamination is expected to migrate
approximately 200 feet beyond its current extent. However, during this same time, the highest chemical
concentrations are expected to decrease to below 100 parts per billion (ppb). After 10 years (Figure I-28b),
the total area of groundwater contamination has decreased, and the area of chemical concentrations above 10
ppb has also significantly decreased. By 15 years (Figure I-28c), the area of groundwater contamination has
been reduced to approximately one-sixth of its current size, and all chemical concentrations are at
acceptable drinking water standards.

Figures I-29(a,b,c) show the extent of migration at a lower rate of degradation than Figures 28(a,b,c). At
this rate of degradation, it would take approximately 50 to 60 years for groundwater contaminants to degrade
to drinking water standards. However, even at a decreased rate of biodegradation, the groundwater modeling
indicates that groundwater contaminants would not impact any existing drinking water wells, including
Kalamazoo Well No. 18, which is the nearest municipal well, and possible private wells located in the
Fairfield residential area, which is now served by the municipal water supply.

While the groundwater modeling indicates that contaminant migration to uncontaminated groundwater will be
minimal, the groundwater will be carefully monitored to track the movement of the groundwater contaminants
and to confirm that the biodegradation is occurring at an acceptable rate. If the monitoring indicates that
conditions have changed to the extent that existing or new wells would be impacted, the existing on-site
groundwater extraction system would be reactivated as a contingency remedy to immediately contain and start

-------
removing the highest levels of groundwater contamination.  If necessary, the on-site groundwater extraction
system would also be modified to contain the entire area of groundwater contamination.

Comment 3:  A resident of the Lexington Green residential development expressed concern about the potential
for health effects from drinking the water from the Lexington Green water supply wells prior to their
closure.  These wells were closed when the Roto-Finish site was first declared a Superfund site because it
was believed that the water table moved to the northeast, toward the Lexington Green wells.

Response 3:  Groundwater flow evaluations conducted in 1979 and during the RI/FS from 1990-1995 (see attached
Figures 4-4 and 4-5 from the RI/FS Report) indicate that the groundwater flow at the Roto-Finish site is to
the north-northwest.  This direction is opposite the direction of the Lexington Green wells, which are
located approximately 1,800 feet northeast of the site.  However, in 1983, it was reported that groundwater
flow was to the northeast.  Although the cause of the differences in the reported direction of groundwater
flow is uncertain  (see Section 3.8.1 on pages 3-17  and 3-18 of the RI/FS Report), it was noted that the
groundwater flow direction report in 1983 followed four months of sustained pumping at the Lexington Green
wells.  During the RI, groundwater modeling was conducted to evaluate whether the pumping of the Lexington
Green wells could have had a local influence on groundwater flow and have caused the reported shift in
groundwater flow direction (see Appendix I of the RI/FS Report).

Using the average rate pumped from the Lexington Green wells during the four-month period as an upper-bound
annual rate (226 gallons per minute), and simulating Upjohn pumping consistent with 1983 withdrawals, the
groundwater modeling indicates that the pumping at the Lexington Green wells would have pulled the
groundwater flow direction at the Roto-Finish site more towards the north, but not to the east.  According to
the model, a substantially higher pumping rate at the Lexington Green wells would have been reguired to shift
the direction of the groundwater flow to the northeast.  Based on the analytical data
collected during the RI, years of monthly groundwater flow evaluations, and the results of the groundwater
modeling, it is unlikely that any groundwater contaminants from the Roto-Finish site were ever transported to
the Lexington Green wells.

While low levels of some groundwater contaminants were detected in groundwater monitoring wells installed
north, northeast and east of the site in the general direction of the Lexington Green wells, the results
indicate that the groundwater contaminants have only spread to a limited extent in these directions.  If
significant levels of groundwater contaminants had migrated toward the Lexington Green wells, the levels of
contaminants detected in these groundwater monitoring wells would be expected to be significantly higher.

Comment 4:  One resident expressed concern regarding the influence of the Upjohn pumping on the groundwater
contaminants at the Roto-Finish site, and whether the groundwater contaminants could be pulled in by Upjohn's
wells and discharged into nearby lakes, and harm the ecology.  The resident also expressed concern as to the
effects of the current on-site groundwater extraction system on groundwater movement, and how groundwater
contaminants would be affected by Upjohn pumping when the system is turned off.  The
resident expressed that the groundwater should be continually monitored, and that the current on-site
extraction system should be ready to be reactivated, if necessary, to prevent contaminated groundwater from
being pulled into Upjohn's wells and impacting the environment.

Response 4:  The effect of Upjohn pumping on the groundwater at the Roto-Finish site and the different
cleanup alternatives was evaluated during the RI/FS through groundwater modeling.  The results of the
modeling indicate that Upjohn withdrawals, which began in 1971 at approximately 5.2 billion gallons per year,
and increased to approximately 8.8 billion gallons per year in 1990, have caused the groundwater flow at the
Roto-Finish site to shift from a northern direction toward more of a northwest direction.  All of the cleanup
alternatives,  including the natural attenuation alternative, were evaluated assuming that
Upjohn would continue to withdraw groundwater at an annual rate of approximately 8 billion gallons per year.
Additionally,  the natural attenuation alternative was evaluated with the assumption that the on-site
groundwater extraction system would be shut down, and did not consider any additional reductions in chemical
concentrations from the on-site extraction system during its course of operation.

The results of the groundwater modeling for the natural attenuation alternative are shown in the attached
Figures 1-28 and Figure 1-29 (natural attenuation at the current estimated rate of chemical degradation, and

-------
at a lower rate of degradation).   As shown in the figures, even with Upjohn pumping, and without the effects
of the on-site extraction system, the groundwater contamination is still projected to remain to the northwest
of the site, and is not expected to impact any existing wells, including Upjohn's wells, while the
groundwater contaminants are degrading and chemical concentrations are being reduced to acceptable levels.

Long-term groundwater monitoring will be conducted during natural attenuation to track the movement of the
groundwater contaminants and to monitor changes in chemical concentrations in the groundwater over time.  The
monitoring program will also include monitoring to identify any changes in groundwater use conditions which
may affect the protectiveness of the natural attenuation remedy, such as the installation of new wells in the
area, and any changes in aguifer characteristics or groundwater conditions, such as increases or decreases in
Upj ohn pumping.

If the results of the monitoring indicate that the aguifer will not be restored within a timeframe of
approximately 50 to 60 years, or that potential impacts to users at existing or new wells from site-related
groundwater contaminants would exceed health-based drinking water standards or pose an unacceptable risk, the
existing on-site pumping system will be reactivated and implemented as a contingency remedy.  In the event
that contaminated groundwater from the site is found to be impacting groundwater production wells in which
the pumped groundwater is discharged to a surface water body, U.S. EPA would also consider the potential for
any ecological risks from site-related groundwater contaminants.

Comment 5:  Congressman Fred Upton, U.S. Representative of the Michigan Sixth District, states that he has
been monitoring the status of the Roto-Finish effort for many years, as well as the status of Superfund sites
in other areas of southwest Michigan.  He states that he is pleased that U.S. EPA has approved the RI/FS and
is holding a public meeting in Portage regarding the recommended cleanup alternative.  Congressman Upton
expresses that public input and comment is a key factor in this type of project, and agrees that of the
cleanup alternatives that were considered, the natural attenuation alternative appears to be the most
suitable and cost-effective plan for the site.

Response 5:  U.S. EPA acknowledges Congressman Upton's support for the natural attenuation alternative, and
agrees that public input and comment is one of the key factors in selecting a final remedy for Superfund
sites.  All comments received during the public comment period for the Roto-Finish site have been carefully
evaluated and considered during the decision-making process.

Comment 6:  A resident living within one mile of the Roto-Finish site expresses concern regarding the site,
especially where health issues are concerned.  The resident states that he lives next to Davis Creek and has
been told that at one time a waste treatment plant was located near the Creek, in what is now Lexington Park.

Response 6:  The risk assessment indicates that there are no current risks from site-related chemicals.  The
contaminated sediments and soils were removed from the site and disposed of in an appropriate landfill from
1979-1983, and remaining soil contamination does not pose any unacceptable current or potential future risks.
Although the groundwater beneath the site and tot he northwest of the site is contaminated, this groundwater
is not used as a drinking water supply.

Institutional controls, such as deed restrictions, deed notices or deed covenants, will be implemented to
prevent the installation of new drinking water wells in the area of groundwater contamination until the
chemicals in the groundwater are degraded and reduced to acceptable drinking water levels, and long-term
groundwater monitoring will be conducted to track the movement of the groundwater contaminants and monitor
the changes in chemical concentrations over time to ensure that no existing or new drinking water wells
become impacted.  If current site conditions or groundwater use conditions change, and the data indicates
that the groundwater will not be restored within a maximum timeframe of approximately 50 to 60 years, or that
potential risks to users at existing or any new wells from site-related groundwater contaminants would exceed
drinking water standards or pose unacceptable health risks, the existing on-site pumping system will be
reactivated and implemented as a contingency remedy.

The comment is not clear about the exact location of the waste treatment plant.  A map of the area (United
States Geological Survey, Portage Quadrangle, Kalamazoo County, Michigan; last photoinspected in 1979),
however, shows a sewage disposal facility located along a branch of Davis Creek near the Lexington Green

-------
residential development (see attached Figure 3-1 from the RI/FS Report).   Any health concerns regarding the
past operation of a waste treatment facility at this location should be directed to the local city or county
health department for additional information.

Comment 7:  Support for the natural attenuation alternative was expressed on behalf of Illinois Tool Works
Inc., the company that currently owns the Roto-Finish property.  Illinois Tool Works Inc. was responsible for
conducting the RI/FS, and voluntarily installed the on-site groundwater extraction system at the site.

Response 7:  U.S. EPA acknowledges support for the natural attenuation alternative.

-------
ATTACHMENT TO RESPONSIVENESS SUMMARY

Figures

Figure 3-1:

Figure 4-4:

Figure 4-5:

Figure 1-25:

Figures 1-27(a,b,c,d)
Regional Topographic Map

Chlorinated Alkanes Detected in Groundwater Samples

Chlorinated Alkenes Detected in Groundwater Samples

Model Initial Condition for VOC Concentrations
Figure 1-28(a,b,c)


Figure 1-29(a,b,c)














Model Calculation of VOC Concentration Contours After 5, 10, 20
and 30 Years with No Biodegradation

Model Calculations of VOC Concentration Contours after 5, 10 and
15 Years with Biodegradation at Current Estimate Rate (0.0008/day)

Model Calculations of VOC Concentration Contours After 5, 10 and
15 Years with Biodegradation at a Lower Rate (0.0002/day)

-------
APPENDIX B

STATE IiETTER OF NON-CONCURRENCE

STATE OF MICHIGAN

JOHN ENGLER, Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOLLISTER BUILDING, PO BOX 30473, LANSING MI 48909-7973
INTERNET http//www.deq.state.mi.us
RUSSELL J. HARDING, Director

July 21, 1997

Mr. William E. Muno, Director
Superfund Division
United States Environmental Protection Agency
Region 5
77 West Jackson Boulevard S-6J
Chicago, Illinois 60604-3590

Dear Mr. Muno:

Two state law reguirements were not adeguately addressed at the time the United States Environmental
Protection Agency (EPA) signed the Record of Decision (ROD) for the Roto Finish Superfund site located in
Portage, Michigan. As a result, the Michigan Department of Environmental Quality (MDEQ) has no recourse
other than to not concur with the ROD. Specifically, appropriate institutional controls to prevent the use
of contaminated groundwater were not included as reguired by Section 20120b(5) of Part 201, Environmental
Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451);
and, a waiver from the MDEQ was not obtained to allow the contaminant plume to expand as reguired by Rule
299.5705(5) of the Michigan Administrative Code.

If the EPA is interested in obtaining MDEQ concurrence on the ROD, we believe both of these deficiencies can
be readily resolved. If the EPA is interested in pursuing this option, please contact Mr. Alan J. Howard,
Chief, Environmental Response Division, at 517-335-1104.

Sincerely,

Russell J. Harding
Director
517-373-7917

cc: Ms. Karen Sikora, EPA
Mr. Bruce Sypniewski, EPA
Ms. Wendy Carney, EPA
Mr. Alan Howard, MDEQ
Mr. Andy Hogarth, MDEQ
Ms. Lynelle Marolf, MDEQ

-------
                           APPENDIX C

                     ADMINISTRATIVE RECORD
Page No.   1
05/02/88

FICHE/FRAME  PAGES  DATE
      ADMINISTRATIVE RECORD INDEX
          RotoFinish,  Michigan

          TITLE
2 A03
2 A01
2 A04
2 A02
2 A05
2 A06
2 A08
83/08/29  Telcon with R.Przybysz
          - MDNR re Status of
          Groundwater monitoring
          at RotoFinish

84/02/21  Telcom with S.Paulen
          - MDNR re extra lagoon
          excavation

84/02/22  Telcom with D.Kimme
          - Portage Water Dept
          re Portage Water Supply

84/02/22  Telcom with B.Kinsley
          -Kalamazoo City Water
          Dept re Kalamazoo
          Water Supply

77/08/15  Notice to cease open
          burning

79/07/02  Use of curing agent
          (MOCA) in operations

81/05/12  Actions MDNR reguires
          RotoFinish to take
AUTHOR

EDettmann - Ecology &
Environment
RHays



RHays



RHays




MBalduf - MDNR


RPrzybysz - MDRN


RHayes - MDNR
                                                                RECIPIENT
WEngle - RotoFinish
DOCUMENT TYPE

Communication Record




 Communication Record



 Communication Record



 Communication Record




 Correspondence
JKittredge - RotoFinish   Correspondence
                                                                                          GLennon - Atty for Roto   Correspondence

-------
2 A10



2 A12

2 B09


2 Bll




6 E07


6 £08


6 F01


6 F08


6 F09

6 Fll


6 F14


6 G08


6 G12
2      82/09/22  Notification by RotoFinish
                 of completion of remedial
                 measures

11     87/03/26  Request for Information

2      87/04/10  Response to
                 Request for Information
376    87/06/17
       87/06/18
       87/08/17
       87/09/18
       87/09/18
Response on Behalf of
RotoFinish to EPA's
First Set of Information
Requests

Response to
Request for Information

Notice Letter and
Request for Information

Notice Letter and
Request for Information

Supplemental Response to
Request for Information
2      87/10/05  Response to Notice Letter

3      87/10/05  Response to
                 Request for Information

6      79/06/20  Roto-Finish Investiqation
                 of 5/14/79

4      79/07/20  RotoFinish Investiqation
                 No.  1

3      79/07/30  RotoFinish Investiqation
                 02
                             WBFrench - Wilkins & Wheaton
                             Labs
BGConstantelos - USEPA

CWWalton - Ransburq Corp


RotoFinish




CWWalton - Ransburq Corp


BGConstantelos - USEPA


BGConstantelos - USEPA


CWWalton - Ransburq Corp


GWBalz

GWBalz


PSchleusener - MDNR


PSchleusener - MDNR


PSchleusener - MDNR
                               RPrzybysz - MDNR
                          Correspondence
                                                            JKittridqe - Roto-Finish  Correspondence

                                                            LSmith - USEPA            Correspondence
                                                            USEPA
LSmith - USEPA
                          Correspondence
                          Correspondence
CWWalton - Ransburq Corp  Correspondence
GWBalz


SSylvester - USEPA


SSylvester - USEPA

SSylvester - USEPA


DVandeBunt - MDNR


File


DVandeBunt - MDNR
Correspondence


Correspondence


Correspondence

Correspondence


Memorandum


Memorandum


Memorandum

-------
7 A01


7 A02


7 A07


7 A14


7 D10


7 F07


7 G03


9 G01

9 G13

10 B04
1      81/07/06


5      83/08/10


7      87/12/07


37     88/01/04


21     00/00/00


8      79/05/00


160    80/03/25
12

19

73
          RotoFinish Status Report
          Curene Followup

          Ecology & Environment
          FIT Site Safety Plan

          Notice of Violation
          and cover letter

          Administrative Order by
          Consent re:   RI/FS

          Scope of Work for
          a RI/FS; Roto-Finish

          MDNR Staff Report
          Roto-Finish
                             RPrzybysz - MDNR
                             KGKrueger - Ecology &
                             Environment

                             AJHoward & DLInman - MDNR
                             Walton-Rote &
                             Constantelos-USEPA
                             MBeck - MDNR
                               JBohansky - MDNR
                               RMDagar - Roto-Finish
          Hydrogeologic Investigation  WBFrench - Wilkins & Wheaton   Roto-Finish
                                       Engr
83/04/01

83/08/16

83/02/00
Preliminary Assessment

Site Inspection Report

Addendum to the
Hydrogeologic Investigation
for Roto-Finish
Ecology & Environment

USEPA

Wilkins & Wheaton Testing Labs
Memorandum


Other


Pleadings/Orders


Pleadings/Orders


Reports/Studies


Reports/Studies


Reports/Studies


Reports/Studies

Reports/Studies

Reports/Studies
10 G08
24     84/07/11  HRS Scoring Package
                                                           MMcLeod
                                                                                                Reports/Studies

-------
Page No.
08/25/89
                              ADMINISTRATIVE RECORD INDEX - UPDATE #1
                                USEPA Remedial Action Superfund Site
                                             Roto-Finish
                                          Portage, Michigan
FICHE/FRAME  PAGES  DATE
DOCNUMBER
                 TITLE
Al
A8
C4
D4
Gl
99     88/03/00  Site Investigation
                 for the Phase I RI

188    88/03/00  Quality Assurance Project
                 Plan for the Phase I RI

47     88/03/00  Health & Safety Plan
                 for the Phase I RI

3      88/03/21  Letter summarizing
                 meeting between
                 MDNR Geologist
                 and Roto-Finish
                 former employee
                 re:  wastes hauled to
                 KL Avenue Landfill

1      88/04/07  Conversational Record re:
                 Waste handling practices
                 onsite
                                              AUTHOR
                                                           Canonie Environmental
                                                           Canonie Environmental
                                                           Canonie Environmental
Kilejczak,  MDNR
                                                           Cozza, USEPA
                                                                             RECIPIENT
                                                                                          USEPA
                                                                                          USEPA
                                                                                          USEPA
                                                                                          Cozza, USEPA
                                                                                          MDNR
DOCUMENT TYPE


Reports/Studies


Reports/Studies


Reports/Studies


Correspondence
                                                                                                                    Phone Record

-------
G3
Gil
D3
D8
D14
El
       88/07/21  USEPA News Release:           USEPA
                 USEPA and Ransburg Corp.
                 Sign Agreement

       88/10/00  Superfund Fact Sheet:         USEPA
                 Roto-Finish site
48     89/01/00  Final Community Relations
                 Plan

5      89/03/00  Preliminary Health
                 Assessment

7      89/04/00  Analysis sheets for
                 samples
                 taken in April 89

1      89/04/20  Letter reguesting
                 duplicate
                 water guality samples
                 per the Administrative
                 Order by Consent
       89/07/20  Letter re:   New state        Beebe,  MDNR
            project
                 manager for the site
Jacobs Engineering Corp.
                                                           ATSDR
                                                           MDNR
                                                           Beebe,  MDNR
                          Press Release



                          Fact Sheet


USEPA                     Reports/Studies


                          Reports/Studies


                          Sampling/Data



Ross, Ransburg Corp.      Correspondence
                                                                                          Gore,  USEPA
                                                         Correspondence
                                                                                                                                            10
                                                                                                                                            11
                                                                                                                                            12

-------

DOC#  DATE
                AUTHOR
                                U.S. EPA ADMINISTRATIVE RECORD
                                        REMEDIAL ACTION
                                        ROTO-FINISH SITE
                                       PORTAGE, MICHIGAN
                                           UPDATE #2
                                            03/25/97
      10/00/88  U.S. EPA/OPA
      01/16/92  Tan, L. and P.
                Schutte; U.S. EPA
                                    RECIPIENT
Pubic
Portage Residents
                    TITLE/DESCRIPTION
                    Fact Sheet re:
                    the RI/FS; and
                 (1) the Superfund Process;  (2)
                (3) Site History
Sample Letter re:  Announcement of January 28,
1992 Public Meeting Concerning the
Contamination Study and Work Scheduled for
1992
                                                 PAGES

                                                     6
  3   09/00/94  U.S. EPA/OPA
Public
                    Fact Sheet:  "U.S. EPA to Address Ground Water
                    Contamination at the Roto Finish Superfund
                    Site" w/Announcement of October 13, 1994
                    Public Meeting and October 1-31, 1994 Public
                    Comment Period
  4   09/30/94  U.S. EPA
Public
U.S. EPA Administrative Record Index for
  5   11/29/94  U.S. EPA
  6   01/24/95  U.S. EPA
Public
Public
Removal Action:  Original  (2 Volumes)
[DOCUMENTS INCORPORATED BY REFERENCE INTO THE
REMEDIAL ADMINISTRATIVE RECORD]

U.S. EPA Administrative Record Index for
Removal Action:  Update #1  (1 Volume)
[DOCUMENTS INCORPORATED BY REFERENCE INTO THE
REMEDIAL ADMINISTRATIVE RECORD]

U.S. EPA Administrative Record Index for
Removal Action:  Update #2  (1 Volume)
[DOCUMENTS INCORPORATED BY REFERENCE INTO THE
REMEDIAL ADMINISTRATIVE RECORD]

-------
 7   01/30/95



 8   09/00/96


 9   09/00/96


10   09/00/96


11   09/00/96


12   09/00/96


13   09/00/96


14   09/00/96


15   09/00/96


16   09/17/96
Muno, W.,  U.S. EPA  Dallosto, P.,
                    Illinois Tool Works
                    Inc.

LTI Environmental   U.S. EPA
Engineering

LTI Environmental   U.S. EPA
Engineering

LTI Environmental   U.S. EPA
Engineering

LTI Environmental   U.S. EPA
Engineering

LTI Environmental   U.S. EPA
Engineering

LTI Environmental   U.S. EPA
Engineering

LTI Environmental   U.S. EPA
Engineering

LTI Environmental   U.S. EPA
Engineering

Sikora, K.,  U.S. EPA Peterson, G.,
                     Lieno-Tech
Unilateral Administrative Order w/Attached         78
Cover Letter
17   10/00/96  U.S.  EPA/OPA
                    Public
Remedial Investigation/Feasibility Study          411
Report:  Volume 1 of 8 (Text and Tables)

Remedial Investigation/Feasibility Study           47
Report:  Volume 2 of 8 (Figures)

Remedial Investigation/Feasibility Study          287
Report:  Volume 3 of 8 (Appendices A-B)

Remedial Investigation/Feasibility Study          182
Report:  Volume 4 of 8 (Appendix C)

Remedial Investigation/Feasibility Study          142
Report:  Volume 5 of 8 (Appendix D)

Remedial Investigation/Feasibility Study          234
Report:  Volume 6 of 8 (Appendix E)

Remedial Investigation/Feasibility Study          242
Report:  Volume 7 of 8 (Appendices F-H)

Remedial Investigation/Feasibility Study          192
Report:  Volume 8 of 8 (Appendices I-N)

Letter re:  U.S. EPA Approval of Final             32
Remedial Investigation Feasibility Study
Report w/Attached Modifications

Fact Sheet:  "U.S. EPA Proposes Final Plan for     14
Ground Water Contamination at the Roto Finish
Superfund Site" w/Announcement of November
13, 1996 Public Meeting and October 24-
November 23, 1996 Public Comment Period

-------
18   10/00/96  U.S. EPA
                    Public
                    Public Notice re:  (1) Proposed Final Cleanup
                    Remedy; (2) Announcement of November 13, 1996
                    Public Meeting; and  (3) Announcement of
                    October 24-November 23, 1996 Public Comment
                    Period
19   10/28/96  U.S. EPA
                    Public
                                        News Release:  "EPA Seeks Comments on
                                        Roto-Finish Cleanup Plan; Public Hearing
                                        November 13"
20   11/00/96  Portage Resident    U.S. EPA
                                        Public Comment Letter re:  U.S. EPA's
                                        Recommended Cleanup Plan for the Roto-Finish
                                        Site  (PORTIONS OF THIS DOCUMENT HAVE BEEN
                                        REDACTED)
21   11/11/96
22   11/12/96
Hoffman, M.,         Bill, B., U.S.
Environmental       EPA/OPA
Science & Engineer-
ing, Inc.

Such, A., Michigan  Bill, B., U.S.
Chemical Council    EPA/OPA
                    Letter re:  Illinois Tool Works' Comments on
                    the October 1996 Final Plan for Groundwater
                    Contamination
                    Letter re:  MCC's Comments on U.S. EPA's
                    Proposed Final Plan for Groundwater
                    Contamination
23   11/13/96
24   11/13/96
Upton, F., U.S.     Adamkus, V.
Congress            EPA
Gerger-Moretti
Reporting
U.S. EPA
25   03/07/97  Howard,  A.,  MDEQ     Sikora, K.
U.S.   Letter re:  Selection of Remedy for
       Groundwater Contamination

         Transcript of November 13, 1996 Public
         Meeting re:  U.S. EPA's Preferred Alternative
         for Final Cleanup Remedy

U.S. EPA Letter re:  MDEQ's Comments on the Draft
         Record of Decision for the Roto-Finish Site
                                                                         29
26   03/13/97  Sikora,  K.,  U.S. EPA Larsen, D., MDEQ
                                          Letter re:  U.S. EPA's Response to MDEQ
                                          Comments on the Draft Record of Decision for
                                          the Roto-Finish Site
                                                                                             13

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-------
11   09/30/93  Peterson,  G.,         Sikora,  K.,  U.S. EPA Letter re:  Proposed Interim Extraction Well        2
               LTI-Lieno-Tech,  Inc.                      System

12   10/12/93  Sikora,  K.,  U.S.  EPA Dallosto,  P.,         Letter re:  U.S. EPA/MDNR's Review and             15
                                    Illinois Tool Works,  Approval w/Modifications of the Phase III
                                    Inc.                 Work Plan Addendum

13   09/00/94  Illinois Tool Works  U.S. EPA             Engineering Evaluation/Cost Analysis (EE/CA)      124
               Inc.

14   09/00/94  U.S.  EPA             Public               Fact Sheet:  "U.S. EPA to Address Ground Water      8
                                                         Contamination"

15   09/28/94  Adamkus, V.,  U.S.     U.S. EPA             EE/CA Approval Memorandum                           3
               EPA

16   09/29/94  Sikora,  K.,  U.S.  EPA Dallosto,  P.,        Letter re:  U.S. EPA's Review and Approval of       1
                                    Illinois Tool Works the Modified EE/CA
                                    Inc.
-------

                                U.S. EPA ADMINISTRATIVE RECORD
                                        REMOVAL ACTION
                                  ROTO-FINISH SUPERFUND SITE
                              PORTAGE, KALAMAZOO COUNTY, MICHIGAN
                                           UPDATE #1
                                            11/29/94
DOC#  DATE
                AUTHOR
                                     RECIPIENT
  1   00/00/90  Michigan Department  U.S. EPA
                of Public Health
                    TITLE/DESCRIPTION                                PAGES

                    Private Water Wells Identified in Vicinity of      53
                    Roto-Finish Superfund Site
  2   10/19/94  Kleiman, R.,
Valetkevitch, H.,   Letter re:  Public Comment on the Proposed
                Kalamazoo County     U.S. EPA
                Board of Commission-
                    EE/CA
  3   10/21/94  Gerger-Moretti
                Reporting
U.S. EPA
  4   10/27/94  Hadden, C., Michigan U.S. EPA
                Manufacturers
                Association
Transcript of October 13, 1994 Public Meeting
                    Letter re:  Public Comment on Cleanup
                    Alternatives
                                                                        19
  5   10/28/94  Mankin, L.,
                Kalamazoo County
                Chamber of Commerce
U.S. EPA
Letter re:  Public Comment on the EE/CA
-------


                                U.S. EPA ADMINISTRATIVE RECORD
                                        REMOVAL ACTION
                                  ROTO-FINISH SUPERFUND SITE
                              PORTAGE, KALAMAZOO COUNTY, MICHIGAN
                                           UPDATE #2
                                            01/24/95

DOC#  DATE      AUTHOR               RECIPIENT           TITLE/DESCRIPTION                                 PAGES

  1   11/30/94  Sikora, K.,  U.S. EPA Muno, W., U.S. EPA  Action Memorandum:  Determination of  Threat  to    203
                                                         Public Health or the Environment

  2   12/28/94  Franzetti, S.,       Prout, S., U.S. EPA Letter re:   Illinois Tool Works'  Waiver  of          1
                Gardner, Carton &                        Right to Seek Reimbursement Under CERCLA
                Douglas                                  Section 106
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