PB97-964117
EPA/541/R-97/155
January 1998
EPA Superfund
Record of Decision:
Roto-Finish Co., Inc.
Kalamazoo, MI
3/31/1997

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DECLARATION FOR THE RECORD OF DECISION
Sit* NamP 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 CSARA) 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 fee 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 endangennent to public health, welfare, or the environment.
Description of the Selected Remedy
The purpose of this remedy is to eliminate or redrce the risks posed by potential future exposure
to contaminated groundwater, and to restore the contaminated aquifer 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 aquifer 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 i.O for noncancer
risks. The primary attenuation process occurring at the Roto-Finish site is intrinsic
biodegradation.
•	Institutional controls to limit groundwater use until the aquifer 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.

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•	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.
Statutory Dfttorminatinns
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.
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.
Date

±L
William E. Muno
Superfund Division Director
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U.S. EPA Superfund
Record of Decision
Roto-Finish Site
Portage, Michigan
March, 1997

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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 oi the property is industrial..
n. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Former Operations and Disposal Areas
The Roto-Finish Company (Figure 2) manufactured specialized equipment to debur and polish
metal castings, mechanical parts, and similar objects that required 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 equipment manufacturing, testing and storage. The
chip and compound building was used for the production and storage of the polishing media used
with the manufactured equipment.
Roto-Finish used two systems for waste disposal. The waste from the rest rooms and other non-
p cessing 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
'Formerly known as the Michigan Department of Natural Resources until reorganization in October, 1995.

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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.
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 areas of groundwater contamination at the site
until the RI/FS was completed 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 199S.
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 199S 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.
ffl. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Availability Sessions
Public participation requirements 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
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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 quality, possible sources of environmental impacts, soil quality
and groundwater quality. In addition, background reports and other published documents were
reviewed to collect information about surface features, meteorology, geology, hydrogeology,
hydrology, land use and demography.
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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 Rl/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 include 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 gene rail) 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,
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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 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 infrequent 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 or 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 aquifer 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-
dichloroethene 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.
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Phase III: Following Phase I and II, a third phase of field work was initiated to provide
additional information about aquifer characteristics and to further characterize the off-site extent
of the groundwater contamination. The Phase III investigation began in September 1992 with an
aquifer 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 in work was conducted to further define the
vertical and horizontal extent of the off-site groundwater contamination. Additional vertical
aquifer 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 approximate 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 199S, 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 compound and the distribution of groundwater
quality 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 aquifer.
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
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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
quantitative 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 i 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
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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 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
carrent 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
concentration of chemicals to users of possible wells located in the Fairfield residential area
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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.SS 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) requires 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 well, 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 additional case of cancer for every 1 million individuals
similarly exposed (1E-06). This risk, however, :s at the low end of U.S. EPA's acceptable
risk range of 1 additional case of cancer for evuy 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
Cher 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
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of 1 additional case of cancer for every 100,000 individuals similarly exposed (1E-05). 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).
VI. 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-quality 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 eo. logical 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 aquifer 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).
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YE. 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 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.
Vm. 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 aquifer 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 Aquifer to Cleanup Levels (Lower of U.S. EPA
Maximum Contaminant Levels (MCLs) or Michigan ( neric Residential Drinking
Water Criteria): At current rates of biodegradation, the aquifer would be restored to
cleanup levels in 15 to 20 years, although the no action alternative is not required to meet
any cleanup requirements. 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 requirements 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 aquifer 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 aquifer. Site-specific estimates indicate that, at current rates of biodegradation
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(0.0008/day), the aquifer would be restored in 15 to 20 years2. At a lower rate of
biodegradation (0.0002/day), the aquifer would be restored in 50 to 60 years. The aquifer
would not be restored at a zero rate of biodegradation.
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 aquifer is restored, although
these controls would not be required or monitored. Existing controls include the availability
of the current municipal water supply; Kalamazoo County local ordinance which requires 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 required by CERCLA and the NCP to give U.S. EPA a basis for comparison.
Alternative A - Aquifer Restoration through Hydraulic Extraction of
Highest Groundwater Impacts, with Natural Attenuation
to Restore the Aquifer Outside the Capture Zone to
Cleanup Levels (O'n-Site Pumping Alternative)
•	Estimated Cost: $1.5 to $2.1 million
•	Estimated Time to Restore the Aquifer to Cleanup Levels (Lower of MCLs or
Michigan Generic Residential 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 aquifer with the highest chemical concentrations, and
natural attenuation to restore the aquifer 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 aquifer 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 aquifer to cleanup levels for this alternative depends upon the rate of
intrinsic biodegradation, even for the portion of the aquifer within the capture zone.
However, even without biodegradation, the groundwater with the highest levels of
2The 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 0.0G02/day represents a half-life of 3,465 days.
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contamination would be hydraulically contained and restored to cleanup levels through
pumping, and the groundwater in the aquifer 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 aquifer within the capture
zone would be restored to cleanup levels in 15 to 20 years (through pumping and
biodegradation), and the portion of the aquifer 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 aquifer
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 aquifer 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 aquifer 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 - Aquifer 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 Aquifer to Cleanup Levels (Lower of MCLs or Michigan
Generic 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 aquifer with groundwater impacts
above cleanup levels. The capture zone for this alternative would include the groundwater in
the most impacted portion of the aquifer 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 aquifer to cleanup levels for this alternative is affected by the rate of intrinsic
biodegradation within the capture zone. The time to restore aquifer 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 aquifer 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 Aquifer to Cleanup Levels (Lower of MCLs or Michigan
Generic Residential Drinking Water Criteria): IS 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 require 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 aquifer 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
aquifer 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 aquifer 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 aquifer 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 track 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 plume 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 aquifer 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 processes for which future rates are uncertain, and
institutional controls to prevent exposure to impacted groundwater until the aquifer 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 aquifer 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.
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Alternative D - Subsurface Barriers to Physically Contain Highest
Groundwater Impacts, with Natural Attenuation to
Restore Aquifer 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 aquifer 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. Aquifer restoration for the groundwater outside
the barrier would be achieved through natural fate and transport processes including intrinsic
biodegradation and dispersion.
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 IS years to restore the aquifer outside the
barrier to cleanup levels. At lower rates of biodegradation (0.0002/day), or a zero rate of
biodegradatioo, the aquifer 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 - Aquifer Restoration through Enhanced Biodegradation
•	Estimated Cost: $4.2 million
•	Estimated Time to Restore the Aquifer 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 aquifer. Although this technology
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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 require treatability testing.
Estimates indicate that the time required 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 Requirements
(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 requirement 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 aquifer to
cleanup levels. Alternative A combines on-site pumping with natural attenuation (intrinsic
biodegradation and/or dispersion), to restore the aquifer; while Alternative B restores the
aquifer through hydraulic pumping without natural attenuation.
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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.
Alternative D (physical barriers) provides protection to human health and the environment by
constructing a barrier to physically contain the groundwater in the most contaminated portion
of the aquifer, and using natural attenuation (intrinsic biodegradation and/or dispersion) to
restore the aquifer outside of the containment area to cleanup levels. Long-term institutional
controls would be required to prevent exposure to the groundwater within the containment
area, although the groundwater inside the containment area may eventually attenuate to
cleanup levels through intrinsic biodegradation.
Alternative E (enhanced biodegradation) protects human health and the environment by using
enhanced in-situ biodegradation, combined with natural attenuation (intrinsic biodegradation
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
stringent state, environmental standards pertaining to the Site or proposed actions. The
ARARs that were identified as being 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 conducting 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 Michigan 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) regulations. All alternatives involve construction or other
sampling activities and would be expected to comply with the Occupational Safety and Health
Act (OSHA). All alternatives involve engineered or natural processes to address
groundwater contamination and are expected to comply with the Safe Drinking Water Act
(SDWA) and Michigan Act 451 Part 201 (Environmental Response). All Alternatives have
the potential to generate 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 regulations for solid waste disposal and Michigan Act 451 Part 115 (Solid
Waste Management).
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Additionally, Alternatives A and B (on-site and on-site and off-site pumping) 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. 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
Michigan Act 451 Part 111 (Hazardous Waste Management), 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
Michigan Act 451 Part 55 (Air Resources Protection) and Part 91 (Soil Erosion and Control).
Alternative E (enhanced biodegradation) may also involve excavation activities, and would
also be expected to comply with the Clean Air Act and Michigan Act 451 Part 55 (Air
Resources Protection) and Part 91 (Soil Erosion nd Control).
Primary Balancing Criteria
3. Long-Term Effectiveness and Permanence
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 a*e uncertain and may not continue. No
cleanup levels are required, 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 aquifer outside of the containment area to cleanup levels. Because the
primary component of this alternative is containment, long-term institutional controls would
be required 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 aquifer and/or to permanently disperse or
transform groundwater contaminants into non-toxic chemicals. These alternatives restore the
entire aquifer 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.
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4. Reduction of Toxicity. Mobility, or Volume through Treatment
Thjs 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 aquifer 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 aquifer 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.
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.
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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 aquifer 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 aquifer 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. Implementabilitv
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)
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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
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 SELECTED 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.
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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 throughout 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 approximate 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 exiting on-site pumping system)
will be implemented as a contingency remedy (see Contingency Remedy).
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
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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.
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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 SO 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 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.
Xn. 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 costs, and use permanent solutions and alternative treatment
technologies, or resource 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.
24

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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
25

-------
requirements 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 acquiring a waiver of Rule 299.5705(5)
have also been met. Therefore, U.S. EPA has also met the substantive requirement of Rule
299.5705(5) by determining that a waiver of this requirement 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 (Liquid 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
26

-------
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 aquifer 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 Alterative 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 to the 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
27

-------
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
aquifer and by treating the groundwater as necessary.
Xffl. 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.
28

-------
KALAMAZOO
COUNTY ^
SITE LOCATION
Figure 1 1 Site Location

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-------
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Figure 5 - Soil Borings and Groundwater Monitoring Wells
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Figure 6 - Groundwater Contamination
-------
TABLE 1: CHEMICALS DETECTED IN SOILS AND GROUNDWATER

SOIL
GROUNDWATER
CHEMICAL
Frequency of
Range of Detected
Frequency of
Range of Detected

Detection
Concentrations
Detection
Concentrations
VOLATILES

(»g/*g)

roediane
-
-
- 49/90
1 - 270
1 1,2-Dichloroetbene
2/5
1
33/90
1 - 150
Chloroform
-
-
1/90
44
1,2-Dichloroethane
-
-
1/90
1
1.1,1-Trichloroethane
-
-
45/90
1 - 2.700
Bro mod ichloro methane
-
-
1/90
4
Trichloroethene
-
-
36/90
1 - 170
1,1,2-T richloroethaiie
-
-
3/90
2-5
Benzene
-
-
1/90
14
4-Methy l-2-pentanooe
-
-
1/90
12
Tetrachioroethene
-
-
15/90
1 - 25
1,1,2,2-Tetrachloroethane
1/50
7
-
-
Toluene
3/50
2- 18
7/90
1 - 40
Chlorobenzene
-
-
14/90
4 - 270
Ethylbenzene
-
-
3/90
2 - 17
1 Tool Xylenes
-
-
2/90
2 - 24
SEMVQUHLES

(ug/kg)

(tg/f)
B Phenol
•

9/46
2 - 40
R 1,4-Dichlorobenzene
-

1/46
2
1 1,2-Dichlorobenzene
2/(2
230-480
3/46
2 - 27
H Napthalene
3/62
45 - 56
-
-
H 2-Methylnapthalene .
-

1/46
3
U Acenapthene
1/(2
250
-
-
| 4-Nitroohenoi
-
-
1/46
1
Dibenzoriran
1/62
95
-

Fluorene
1/62
230
-
-
Pentachloropheaot
-
-
1/46
2
Phenanthrene
2/62
96 - 4.200
2/46
1 - 4
Anthracene
1/62
420
-
-
Carbazole
1/62
490
-
-
Fluoranthene
4/(2
39 - 7.300
1/46
3
Pyrene
4/62
40 - 6.800
-
•
Benzo(a)anthracene
1/62
2.700
1/46
6
Chrysene
1/62
2.400
1/46
6
Bis(2-ethylhexyl)phthalate
3/62
<*4
O
8
2/46
43-47
Di-n-octylphthalate
-
-
2/46
15 - 17
Benzo(b)fluoranthene
1/62
5.100
1/46
5
Beiuo
-------
TABLE 1 (continued): CHEMICALS DETECTED IN SOILS AND GROUNDWATER
CHEMICAL
SOIL
GROUNDWATER
Frequency of
Detection
Range of Detected
Concentrations
Frequency of
Detection
Range of Detected
Concentrations
INORGANICS

(mg/kg)

(ugfl)
Aluminum
63/63
898 - 15,400
7/81
31.6 - 892
Antimony
1/63
16.2
4/81
19.4 - 32.5
Arsenic
61/63
0.56 - 61.2
21/81
1.5 - 41.6
Barium
63/63
4.3 - 145
81/81
6.4 - 279
Beryllium
12/63
0.25 - 1.4


Cadmium
2/63
0.97 - 53.2


Calcium
61/61
347 - 98,500
81/81
4,500 - 2d9.000
Chromium
63/63
2.3 - 20.6
13/81
1.2 - 5.5
Cobalt
37/63
1.4 - 16
16/81
1.7 - 23.2
Copper
61/63
2.4 - 55.1
19/81
3.1 - 16.7
Iron
63/63
2,570 - 48,600
58/81
18 - 3,320
Lead
63/63
1 - 162
9/81
1.1 - 3.1
Magnesium
61/63
514 - 61,000
81/81
1,900 - 66,200
Manganese
63/63
35.7 - 2,590
81/81
4.8 - 1,490
Mercury
4/63
0.1 -0.37
1/81
0.24
Nickel
50/63
2.9 - 33.3
32/81
1.5 - 95.8
Potassium
26/63
242 - 2,520
69/81
748 - 40,800
Selenium
2/63
0.95 - 1.6


Sodium
27/63
113-235
80/81
2,840 - 246,000
Thallium
-
-
1/81
6.4
Vanadium
50/63
3.3 - 97.4
5/81
0.44 - 6
Zinc
62/63
).2 - 370
50/81
3.3 - 3.930
Cyanide
-
-
2/69
15.3 - 15.9
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TABLE 2: CHEMICALS OF POTENTIAL CONCERN
SOIL
1,2-Dichloroethene
Fluoranthene
MOCA
Iron
1,1,2,2-Tetrachloroethane
Pyrene
Aluminum
Lead
Toluene
Benzo(a)anthracene
Antimony
Magnesium
1,2-Dichlorobenzene
Chrysene
Arsenic
Manganese
Nap thai ene
Bis(2-ethylhexyl)phthalate
Barium
Mercury
Acenapthene
Benzo(b)fluoranthene
Beryllium
Nickel
Dibenzofuran
Benzo(k)fluoranthene
Cadmium
Potassium
Fluorene
Benzo(a)pyrene
Calcium
Selenium
Phenanthrene
Indeno(l ,2,3-cd)pyrene
Chromium
Sodium
Anthracene
Bibenzo(a,h)anthracene
Cobalt
Vanadium
Carbazole
Benzo(g,h,i)perylene
Copper
Zinc
GROUNDWATER



Vinyl chloride
4-Methyl-2-pentanone
Chrysene
Copper
Chloroethane
Tetrachloroethene
Bis(2-ethylhexyl)phthalate
Iron
Methylene Chloride
Toluene
Di-n-octylphthalate
Lead
Acetone
Chlorobenzene
Benzo(b)fluoranthene
Magnesium
Carbon Disulfide
Ethylbenzene
Benzo(k)fluoranthene
Manganese
1,1-Dichloroethene
Totid Xylenes
Benzo(a)pyrene
Mercury
1,1-Dichloroethane
Phenol
Indeno( 1,2,3-cd)pyrene
Nickel
1,2-Dichloroethene
1,4-Dichlorobenzene
MOCA
Potassium
Chloroform
1,2-Dichlorobenzene
Aluminum
Sodium
1,2-Dichloroethane
2-Mcthylnapthalcnc
Antimony
Thallium
1,1,1 -Trichloroethane
4-Nitrophenol
Arsenic
Vanadium
Bromodichloromethane
Pentachlorophenol
Barium
Zinc
Trichloroethene
Phenanthrene
Calcium
Cyanide
1,1,2-Trichloroethane
Fluoranthene
Chromium

Benzene
Benzo(a)anthracene
Cobalt

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TABLE 3: RISK SUMMARY
Risk
Exposure Pathway
Noncancer
Hazard Index
Excess Lifetime
Cancer Risk per
Individuals Exposed
Current Risks



Soil
Groundskeeper/
Industrial Worker
(surface soil)
0.01
2 in 10,000,000
Groundwater
None
--
-
Potential Future Risks



Soil
Construction Worker
(subsurface soil)
0.11
5 in 100,000,000

Industrial Worker
(surface and subsurface
soils)
0.20
6 in 1,000,000
Groundwater



Existing Weils
Fairfield
0.00
1 in 100,000

Municipal
Well No. 18
0.00
0
New Wells
Industrial
16.55
2 in 100

Residential
54.23
5 in 100
Underlined values indicate i potential for noncancer health risks (hazard index > 1) or unacceptable cancer risk (risk
exceeds U.S. EPA's risk iage of 1 additional case of cancer for every 10,000 to 1,000,000 individuals similarly
exposed).
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TABLE 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)
Liquid 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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TABLE 5: CAPITAL, O&M AND PRESENT WORTH COSTS
ALTERNATIVE
COST
Capital Costs
Annual O&M
Present Worth
Alternative NA
No-Action
SO
SO
$0
Alternative A
On-site Pumping
$0 - $700,000
$100,000 - $170,000
$1,500,000 - $2,200,000
Alternative B
Oil-Site and Off-Site
Pumping
$360,000 - $860,000
$130,000 - $310,000
$2,000,000 - $3,500,000
Alternative C
Natural Attenuation
$30,000
$50,000
$500,000
Alternative D
Physical Barriers
$40,300,000
$70,000
$41,000,000
Alternative £
Enhanced Btodegradatioa
$1,600,000
$260,000
$4,200,000
Note: Costs for Alternative A md Alternative B vary depending on final treatment and discharge options.
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TABLE 6: PERFORMANCE STANDARDS FOR GROUNDWATER CLEANUP





PERFORMANCE

GROUNDWATER
ARARj
STANDARDS FOR
CHEMICAL




GROUNDWATER1"








Federal Safe
Michigan Act 451
Lower of Either

Frequency
Range of
Drinking Water
Part 201
MCLs or Michigan Part

of
Detected
Maximum
Residential
201 Residential Drinking

Detection
Concentrations
Contaminant
Drinking Water
Water Criteria



Levels (MCLsp
Criteria™

VOLATILES

(ug/l)



Vinyl chloride
18/90
4 - 120
2
2
2
Chloroe thane
5/90
5-79
-
220
220
Methylene Chloride
1/90
3
5
5
5
Acetone
7/90
4-27
-
730
730
Carbon Disulfide
1/90
2
-
800
800
1,1-Dichloroethene
39/90
1 -480
7
7
7
1,1-DichJoroe thane
49/90
1 - 270
5
5
5
1,2-Dichloroethene
33/90
1 - 150
170
170
170
Chloroform
1/90
44
100"1
100
100
1,2-Dichloroethane
1/90
1
5
5
5
1,1,1-Trichloroe thane
45/90
1 - 2,700
200
200
200
Bromodichlorome thane
1/90
4
100,4)
100
100
Trichloroethene
36/90
1 - 170
5
5
5
1.1,2-T richloroethane
3/90
2-5
3[JI
5
3
Benzene
1/90
14
5
5
5
4-Methyl-2-pentanone
1/90
12
-
370
370
Tetrachloroethene
15/90
1 -25
5
5
5
Toluene
7/90
1 - 40
1,000
1,000
1,000
Chloro benzene
14/90
4-270
100
100
100
Ethyl benzene
3/90
2 - 17
700
700
700
Total Xylenes ""
2/90
2-24
10,000
10,000
10,000
SEMIVOLATILES

(ug/l)



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-Methy Inapthalene
1/46
3
-
ID
-
4-Nitrophenol
1/46
1
-
-
-
Pentachlorophenol
1/46
2
1
1
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
B is(2-ethy lhe xy l)phthalate
2/46
43-47
6
6
6
Di-n-octy Iphthalate
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
lndeno(l ,2,3-cd)pyrene
1/46
. 2
-
1.2
1.2
Benzo(g,h.i)perylerte
1/46
3
'
26
26
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TABLE 6 (continued): PERFORMANCE STANDARDS FOR GROUNDWATER CLEANUP

GROUNDWATER
ARARs
PERFORMANCE





STANDARDS FOR





GROUNDWATER"1
CHEMICAL
Frequency
Range of
Federal Safe
Michigan Act 451
Lower of Either

of
Detected
Drinking Water
Part 201
MCLa or Michigan Part

Detection
Concentrations
Maximum
Residential
201 Residential Drinking



Contaminant
Drinking Water
Water Criteria



Leveta (MCLs)
Criteria

INORGANICS

(ug/l)



. Aluminum
7/81
31.6-892
.
ID
-
Antimony
4/81
19.4 - 32.5
6
6>«
6
Arsenic
21/81
1.5 - 41.6
5C71
5C41
50
Barium
81/81
6.4 - 279
2000
2000«
2000
Calcium
81/81
4,500 - 259,000

-
-
Chromium
13/81
1.2 - 5.5
100
IOC"
100
Cobalt
16/81
1.7-23.2
-
37
37
Copper
19/81
3.1 - 16.7
1,300*51
1.400"
1,300
Iron
58/81
18 - 3,320
-
300"*
-
Lead
9/81
1.1 - 3.1
1511
410
4
Magnesium
81/81
1,900 - 66,200
-
420,000
420,000
Manganese
81/81
4.8 - 1,490
-
860^
860
Mercury
1/81
0.24
2
2i«
2
Nickel
32/81
1.5 - 95.8
100"1
lOO1"
100
Potassium
69/81
748 - 40,800
-
-
-
Sodium
80/81
2,840 - 246,000
-
160,000
160,000
Thallium
1/81
6.4
0.5"1
2"
0.5
Vanadium
5/81
0.44 - 6
-
641*
64
Zinc
50/81
3.3 - 3,930
-
2,400w
2,400
Cyanide
2/69
15.3 - 15.9
200
200
200
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 aquifer.
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 1993. 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 Contamant 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
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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 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.
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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
Cnmnwnt 1; The executive director of the Michigan Chemical Council headquartered 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.
rnmnwnt 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 Roto-
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
2
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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 I-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 ii. 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 200feet 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 biodegrudation 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.
3
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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 1,800feet
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 growtdwater flow direction reported 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 required 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 onty 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
4
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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 Rl/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 dawn, 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 aquifer characteristics or groundwater conditions, such as
increases or decreases in Upjohn pumping.
If the results of the monitoring indicate that the aquifer 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.
5
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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 Rota-Finish site have been carefully evaluated and considered during
the decision-making process.
fnmmpnt 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 to the 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
6
-------
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.
7
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ATTACHMENT TO RESPONSIVENESS SUMMARY
Figures
Figure 3-1:	Regional Topographic Map
Figure 4-4:	Chlorinated Alkanes Detected in Groundwater Samples
Figure 4-5:	Chlorinated Alkenes Detected in Groundwater Samples
Figure 1-25:	Model Initial Condition for VOC Concentrations
Figures I-27(a,b,c,d): Model Calculation of VOC Concentration Contours After 5, 10, 20
and 30 Years with No Biodegradation
Figure I-28(a,b,c): Model Calculations of VOC Concentration Contours After 5, 10 and
15 Years with Biodegradation at Current Estimate Rate (0.0008/day)
Figure I-29(a,b,c): Model Calculations of VOC Concentration Contours After 5,10 and
15 Years with Biodegradation at a Lower Rate (0,0002/day)
-------

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After 5 Years for Natural
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Roto-Finish Site
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APPENDIX B
STATE LETTER OF NON-CONCURRENCE
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STATE OF MICHIGAN
JOHN ENGLER. Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOUISTER BUILDING PO BOX 30473 LANSING Ml 48909-7973
INTERNET hitp //www deq state mi
RUSSELL J. HARDING, Director
July 21, 1997
D) i 0 '& i! »' i " T
Ju JUL 28 1997 L-'
SUPERrUND D.V!3 CN
OFFICE CF THE D!::ir '
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 requirements were not adequately 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 required 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 required 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.
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
Sincerely,
Russell J. Harding
Director
517-373-7917
EQP 0100®
(Rev 10/96)
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APPENDIX C
ADMINISTRATIVE RECORD
-------
0ige Mo.'
05703/88
FIOC/F8RIC PAGES OATE TITlf
FILE MPY
ADMINISTRATIS REM) IMQ
Rotofinitit, Michigan
AUTHOR
RECIPIENT
DOCUMENT TYPE
2 AOS	1
2 A01	1
2 A04	1
2 AOS	1
2 AOS	1
JUM	2
2 AOS	2
2A10	2
I
2A12
21
2B11
6 E07
• E0«
iFOI
83/08/29 Telcon «ith R.Prryfcyw
-	MM rt Statm of
Groundwater Monitoring
at RotoFiniah
M/oe/21 Talcon nit* IPaelan
-	MM rt extra lagoon
excavation
84/02/22 Talcan Mitb Ll(i«e
-	Portage Hilar Dapt
ra Portage Uatar Sifply
M/02/22 Talcoa witb LKiialay
-	Kalaaazoo City Matar
Dapt ra KalaMiaa
Uatar Supply
77/08/15 Not in to
burning
79/07/02 Un of coring agent
(M0CA) in operation
EDettaam - Ecolofy I
Enviroraant
81/00/12 Actions MM raqaires
AotoFinitii to tate
82/09/22 Notification by totofiniah
of coaptation of rwadial
11 87/03/2&
2 87/04/10
for Infection
to
for Infonution
376 87/06/17 >iipoaaa on Mulf of
RotoFiiiiah to EPA1«
First Sat of Infonution
Requests
1 87/06/18 Response to
Reqtest for Infonution
7 87/08/17 Notice Latter and
Request for Inforeation
7 87/09/18 Notice Letter and
Request for Infonution
Co—unication fhcort
Co—«ication Recorr
Coamnication Racort
Coanunication ftacort
Maldaf -
RPrtybysz -
RAHayea -MM
HEngal - lotofiai* Correspondence
JXittradge - lotoFinidi Correspondence
GLeraon - Atty for Roto Correspondence
UBTi end> - Willuna I tfiaaton RPrzybyat - MM
Correspondwce
BGCoratanteloa • USEPA	JKittridga - Roto-Finirt Correspondence
Cltalton ~ lawbifi Corp LSaitb - UGEPA	Corrr.oondence
Botofiniifc
USEPA
CUUalton - Ranaoni Corp LSeith - USEPA
Corresponoence
Correspondence
BGConstanteloa - IEEPA	CUUalton - Ramfcirf Corp Corrtsponocrce
BGConstantelo* - l££PA
GNSalz
Cormponoence
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%
'Ptqi NoCi
03/0,1/88
FID€/FIW€ PAGES DATE TITLE
AON1NISTMT1VE RECORD INDEX
RotoFinish, Nidugan
AUTHOR
RECIPIENT
DGCUCXT TYPE
• FM 1
6FM
6F11
7 A14
h 010
7 F07
2
3
• F14 6
• OOt 4
• 012 3
7A01 1
\02 9
7 A07 7
17/09/18 Supplemental Response to
Raq ant for Information
•7/10/09 RespouM to Notice Letter
87/10/08 tapra to
hqwt for Inforation
79/06/20 Roto-Finisl. Investigation
of 5/14/79
79/07/20 RotoFinish Investigation
No. 1
79/07/30 RotoFinisii Investigation
•2
CUUalton - Iwbr] Corp SSylvestar - USEPA
SI/07/06 RotoFini* Statu
Curene Followip
13/08/10 Ecology t Enviroc—nt
FIT Sit* Safety Plan
87/12/07 Notice of Violation
and cover letter
37 88/01/04 Administrative Order by
Consent re: Rl/FS
21 00/00/00 Scope of Uorfc for
a RI/FS{ Roto-Finitii
79/03/00 MM Staff
loto-fini*
OBalz
GUhlz
PSchl
PSchli
PSachli
SSylvecter - USEPA
SSylvestar - USB*
Filt
Report Vrzyfaysz - MMI
KGKra.ger - Ecology I
Envirownt
AJHoMrd t DUana - MM Mqir - Roto-Finisb
7 G03 180 80/03/23 llpdrogaologic Investigation
9G01 12 83/04/01 Preliminary Asiessaant
9G13 19 83/08/16 Sit* Impaction Report
10 B04 73 84/02/00 Addendum to the
Hydrogeologic InvMtigation
for RotorFinish
lialton-Aoto I
Constaateloe-USEPA
Mack - MM
tOTreich - Milkine I Uheaton Roto-Fimifc
Engr
Ecology I Enviroraent
USEPA
UilkiM I llieatoa Tasting Labs
Correspondence
Correspondence
Corraspondanca
Nnorandue
Nnorandia
teaorandia
Other
Pleadings/Orders
Pleadings/Q-ders
Reports/Studies
Reports/Studies
Reports/Studies
Reports/Studits
Reports/Studies
Reports/Studies
006 24 84/07/11 HSS Scoring Package
HHcLeod
Reports/Studies
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5/M
t rim ruts urt
uuiismrin neon inu - irun n
ISIfi Itattfiil ietin Jipirfiatf lit*
lito-flaiii
firtifi, liehfu
rim
mioi
ucintit
FILE COPY^
Mcniir tin locisuu
O	H	U/IJ/II
'8	m	U/IJ/II
-4	47	ll/lj/ll
)
>4	J	ll/IJ/21
1 11/14/(7
2 11/17/21
( ll/ll/lf
311 41 19/12/11
33 5 U/IJ/II
=>8 7 19/14/11
314 I !9/«4/2l
Si to Jmitifitiii
fir tit fkstt 111
CuttU ItrtrouttUl Uifi
Ciilltf Isiariaci frojoct Cmiii liririiatitil
flu tor tit Hm JII
liiJt* i fifitf flu Cunii laririiMiul
/or Ui Nut III
Iittir iiiuriiiif lilijeul, Oil
¦iitiif titriu
Oil dilofiit
u< loto-fiiiti
firm iiflirn
rn natia knit! ti
II Irian liadfill
Ciarirutiiail loeori rot Coin, ISIfi
flit* lulliif prietieu
oaiiti
ISifi lifi liiiiiit ISIfi
ISifi ul luiiirf Corp.
Sift ifrimit
IIIPI
ISIfi
Cttti, ISifi
Ull
lifirtiW fiet Sluti
liti-fiaiat liti
ISIfi
fiul Ciuuitr liiitiiai Jicoit lifliiiriaf (rtip
fiaa
Iriiiaiaarr luitl IfIII
lamina t
luifii' ilnti fir Ull
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tatn ia Ipril I)
Iittir rifiutiaf	luti, Ull
dipiicitt
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ptr tit iluaiitritiri
Or
-------
it' Is. 2
nm
mmmmn mm urn • mm u
KIH Ititiul iccios Siptrfnd Site
Iste-liiifl
hruyi, liciifii
nas itn rmi	arm	iiciwnr	mmtt mi mimn
prejtet
uiiftr for tic Utt
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/4R
U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
ROTO—FINISH SITE
PORTAGE, MICHIGAN
UPDATE #2
03/25/97
DOC* DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PA6ES
1 10/00/88 U.S. EPA/OPA
2 01/16/92 Tan, L. and P.
Schutte; U.S. EPA
Public
Portage Residents
Fact Sheet re: (1) the Superfund Process; (2)
the RI/FS; and (3) Site History
Saaple Letter re: Announcement of January 28,
1992 Public Meeting Concerning the
Contaaination Study and Hork Scheduled for
1992
3 09/00/94 U.S. EPA/OPA
4 09/30/94 U.S. EPA
5 11/29/94 U.S. EPA
6 01/24/95 U.S. EPA
7 01/30/95 Runo, U.S. EPA
Public
Public
Public
Public
Dallosto, P.,
Illinois Tool Works
Inc.
Fact Sheet: "U.S. EPA to Address 6round Mater
Contaaination at the Roto Finish Superfund
Site' M/Announceaent of October 13, 1994
Public Meeting and October 1 -31, 1994 Public
Coaaent Period
U.S. EPA Adainistrative Record Index for
Reaoval Action: Original (2 Voluaes)
[DOCUMENTS INCORPORATED BY REFERENCE INTO THE
REMEDIAL ADMINISTRATIVE RECORD]
U.S. EPA Adainistrative Record Index for
Reaoval Action: Update II (1 Voluae)
[DOCUMENTS INCORPORATED BY REFERENCE INTO THE
REMEDIAL ADMINISTRATIVE RECORD]
U.S. EPA Adainistrative Record Index for
Reaoval Action: Update 12 (1 Voluae)
[DOCUMENTS INCORPORATED BY REFERENCE INTO THE
REMEDIAL ADMINISTRATIVE RECORD]
Unilateral Adainistrative Order w/Attached
Cover Letter
78
8	09/00/96 LTI Environaental U.S. EPA
Engineering
9	09/00/96 LTI Environaental U.S. EPA
Engineering
10	09/00/96 LTI Environaental U.S. EPA
Engineering
11	09'00/96 LTI Environaental U.S. EPA
Engineering
Reaedial Investigation/Feasibility Study	411
Report: Voluae 1 of 8 (Text and Tables)
Reaedial Investigation/Feasibility Study	47
Report: Voiuae 2 of 8 (Figures)
Reaedial Investigation/Feasibility Study	287
Report: Voluie 3 of 8 (Appendices A-B)
Reaedial Investigation/Feasibility Study	182
Report: Voluae 4 of 3 (Appendix C)
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DOC* DATE AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PASES
12 09/00/96 LTI Environaental
Engineering
U.S. EPA
Reaedial Investigation/Feasibility Study
Report: Volute 5 of 8 (Appendix D)
142
1J 09/00/96 LTI Environmental
Engineering
U.S. EPA
Reaedial Investigation/Feasibility Study
Report: Volute 6 of 8 (Appendix E)
2J4
14 09/00/96 LTI Environmental
Engineering
U.S. EPA
Reaedial Investigation/Feasibility Study
Report: Voluae 7 of 8 (Appendices F-H)
242
15	09/00/96 LTI Environaental U.S. EPA
Engineering
16	09/17/96 Sikora, K., U.S. EPA Peterson, 6.,
Liano-Tecti
Reaedial Investigation/Feasibility Study	192
Report: Voluae 8 of 8 (Appendices I-N)
Letter re: U.S. EPA Approval of Final	32
Reaedial Investigation Feasibility Study
Report a/Attached Modifications
17 10/00/96 U.S. EPA/0PA	Public
Fact Sheet: 'U.S. EPA Proposes Final Plan for 14
6round Mater Contaaination at the Roto Finish
Superfund Site' a/Announceaent of Noveaber
13, 1996 Public fleeting and October 24"
Noveaber 23, 1996 Public Coaaent Period
18 10/00/96 U.S. EPA	Public
Public Notice re: (1) Proposed Final	Cleanup 1
Reaedy; (2) Announceaent of Noveaber 13, 1996
Public Meeting; and (3) Announceaent	of
October 24- Noveaber 23, 1996 Public	Coaaent
Period
19 10/28/96 U.S. EPA	Public
20 11/00/96 Portage Resident U.S. EPA
News Release: 'EPA Seeks Coaaents on	2
Roto-Finish Cleanup Plan; Public Hearing
Noveaber 13'
Public Coaaent Letter re: U.S. EPA's	1
Recoaaended Clear - Plan for the Roto-Finish
Site (PORTIONS 01- .HIS DOCUMENT HAVE BEEN
REDACTED)
21	11/11/96 Hoffaar, H.,	Bill, B., U.S.
Environaental	EPA/0PA
Science ( Engineer-
ing, Inc.
22	11/12/96 Such, A., Michigan	Bill, B., U.S.
Cheaical Council	EPA/0PA
Letter re: Illinois Tool Korlcs' Coaaents on 1
the October 1996 Final Plan for Broundaater
Contaaination
Letter re: HCC's Coaaents on U.S. EPA's	1
Proposed F:nal Plan for Groundwater
Contaaination
1
11/13/96 Upton, F., U.S. Adaakus, V., U.S. Letter re: Selection of Reaedy for
Congress	EPA	Grounditater Contaaination
2
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TITLE/DESCRIPTION
PASES
24	11/13/96 fierger-Horetti	U.S. EPA
Reporting
25	03/07/97 Howard, A., KDEQ	Sikora, K., U.S.
26	03/13/97 Sikora, K., U.S.	EPA Larsen, D., KDEQ
Transcript of Noveaber 13, 1996 Public	29
Meeting re: U.S. EPA's Preferred Alternative
for Final Cleanup Reaedy
EPA Letter re: KDEQ's Coaaents on the Draft	4
Record of Decision for the Roto-Finish Site
Letter re: U.S. EPA's Response to NDEQ	13
Coaaents on the Draft Record of Decision for
the RotO'Finish Site
j
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36
•16
46
37
33
53
22
4
11
3
0
L
15
24
3
3
U.S. EPA ADMINISTRATIVE RECORD
REMOVAL ACTION
ROTO—FINISH SITE
PORTAGE, MICHIGAN
ORIGINAL
09/30/94
AUTHOR
RECIPIENT
TITLE/DESCRIPTIOK
U.S. EPA
Recipients
Administrative Order by Consent
Canonie Environment- U.S. EPA
al
Project Work Plans: Site Investigation Plan,
QAPP, Health and Safety Plan, Phase I RI
Jacobs Engineering U.S. EPA
Group Inc.
Coaaunity Relations Plan, Final
LTI-Liano-Tech, Inc. U.S. EPA
RI Phase II Site Investigation Work Plan,
Final
LTI-Liano-Tech, Inc. U.S. EPA	Phase II RI Field Saapling Plan
Peterson, 6. and Sikora, K., U.S.	EPA Letter Foraarding Attached Phase I and Phase
Betz, R., LTI-Liano-	II Data Validation Tables
-Tech, Inc.
LTI-Liano-Tech, Inc. U.S. EPA	RI Phase III Site Investigation Hark Plan
Peterson, 6., Sikora, K., U.S.	EPA Letter re: Additional Field Investigations
LTI-Lnno-Tech, Inc.	Proposed in Technical Neaorandua III.2
Peterson, G. and Sikora, K., U.S.	EPA Letter re: Revision to the Additional Field
Betz, R., LTI-Liano-	Investigations Proposed in Technical
-Tech, Inc.	Heaorandua III.2
Sikora, K., U.S. EPA Dallosto, P.,	Letter re: Proposed Extraction Nell Systea
Illinois Tool Wor-., for Groundwater Containaent n/FAX Cover Sheet
Inc.
Peterson, 6.. Sikora, K., U.S.	EPA Letter re: Proposed Interia Extraction Wei 1
LTI-Liano-Tech, Inc.	Systea
Sikora, K., U.S. EPA Dallosto, P.,	Letter re: U.S. EPA/HDNR's Reviea and
Illinois Tool Works, Approval a/Modifications of the Phase III
Inc.	Work Plan Addendua
Illinois Tool Works U.S. EPA	Engineering Evaluation/Cost Analysis (EE/CA)
Inc.
U.S. EPA Public	Fact Sheet: 'U.S. EPA to Address Ground Water
Cortaaination"
Adaakus. v., U.S. U.S. EPA
EPA
EE/CA Approval Ileaorandua
-------
DOC# DATE AUTHOR	RECIPIENT	TITLE/DESCRIPTION	PAGES
16 09/29/94 Sikori, K., U.S. EPA Dillosto, P.,	Letter re: U.S. EPA's Review and Approval of
Illinois Tool Works the Modified EE/CA
Inc.

2
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U.S. EPA ADMINISTRATIVE
REMOVAL ACTION
ROTO—FINISH SUPERFUND
PORTAGE, KALAMAZOO COUNTY,
UPDATE #1
11/29/94
RECORD	*3
SITE
MICHIGAN
DOCI DATE AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PASES
1 00/00/90 Michigan Department U.S. EPA
of Public Health
Private Hater Hells Identified in Vicinity of S3
Roto-Finish Superfund Site
2	10/19/94 Kleiian. R..	Valetkevitch. H.,
(alaaazoo County U.S. EPA
Board of Coaaission-
ers
3	10/21/94 Serqer-Horetti	U.S. EPA
Reporting
Letter re: Public Coaaent on the Proposed
EE/CA
Transcript of October 13, 1994 Public Meeting 19
4 10/27/94 Hadden, C., Michigan U.S. EPA
Manufacturers
Association
Letter re: Public Coaaent on Cleanup
Alternatives
5 10/28/94 Nankin, L.,	U.S. EPA
Kalaaazoo County
Chaaber of Coaacrce
Latter re: Public Coaaent on the EE/CA
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U.S. EPA ADMINISTRATIVE RECORD
REMOVAL ACTION
ROTO-FINISH SUPERFUND SITE
PORTAGE, KALAMAZOO COUNTY, MICHIGAN
UPDATE #2
01/24/95
DOCI DATE AUTHOR	RECIPIENT	TITLE/DESCRIPTION	PAGES
1	11/30/94 Sikora, C., U.S. EPA Huno, K., U.S. EPA Action Heaorandua: Detereination 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' Haiver of	1
Gardner, Carton I	Right to Seek Reimbursement Under CERCLA
Douglas	Section 106
i
\
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