&EPA
United States
Environmental Protection
Agency
Want more information?
To learn more about the Tecumseh
Products site cleanup, please contact
one of these team members:
Community Involvement
Coordinator
Rafael P. Gonzalez
EPA Public Affairs Specialist
312-886-0269
gonzalez .rafaelp@epa. gov
For site information and cleanup
progress
Joseph Kelly
EPA Project Manager
312-353-2111
kellv.ioseph@epa.gov
For site vapor intrusion questions
Bhooma Sundar
EPA Vapor Intrusion Toxicologist
312-886-1660
sundar.bhooma@epa.gov
EPA toll-free: 800-621-8431.
9:30 a.m. - 5:30 p.m., weekdays
Vapors Rise
Through Soil
Contaminated
Groundwater
Vapor intrusion into a home
Public Comment for
Proposed Remedy
Former Tecumseh Products Site
Tecumseh, Michigan	October 2018
The U.S. Environmental Protection Agency (EPA) Region 5 invites the
public to comment on the Proposed Remedy for the former Tecumseh
Products Company (TPC) Facility in Tecumseh, Michigan. The Proposed
Remedy includes groundwater treatment, soil treatment and excavation,
and institutional controls to prevent future exposures.
The public comment period runs from October 25, 2018, through
November 25, 2018. A Public Meeting will be held Nov. 7, 2018 from
6:00 to 7:30 pm at the Tecumseh Fire Station at 101 E. Russell Road.
Written comments on the Proposed Remedy must be submitted no later
than November 25, 2018, and must be sent to:
Joseph Kelly
EPA Region 5 (RRB/CAS1)
77 W. Jackson Blvd. (Mail Code LU-16J)
Chicago, IL 60602
Email: kellv.ioseph@epa.gov
Background
The former TPC Facility once occupied approximately 750,000 square feet
of buildings on approximately 53 acres of land. TPC has used the Facility
since 1934 for the manufacturing of automotive parts, refrigeration
systems, small tools and toys, and reconditioning of compressors and
condensing units for refrigeration. Manufacturing processes conducted at
the Facility included parts degreasing, unit assembly, paint preparation,
unit painting, unit reconditioning and shipping and receiving, which
continued until operations ceased at the Facility in June 2008.
The use of solvents in degreasing, and the storage of hazardous waste
solvents and paints under the Resource Conservation and Recovery Act
(RCRA) resulted in releases of contamination to the property and some of
the surrounding area. Under an EPA legal order, TPC has been testing the
groundwater (underground water), soil gas (underground air), soil, and
indoor air at and around the property on Patterson Street since 2009.
Initial work identified that contaminated groundwater extended off-site
and TPC undertook efforts to locate and decommission water wells within
the area of contamination, and connected affected residents to the
municipal water supply. TPC also helped the City of Tecumseh develop a
Groundwater Use Ordinance to prevent the use of groundwater in the
affected area. Further work focused on "vapor intrusion", which occurs
when contaminated underground water gives off gases that can rise
through the soil and into buildings through foundation cracks, possibly
causing unsafe indoor air quality. Chemicals called "volatile organic
compounds," or VOCs, are especially prone to vapor intrusion, and were
the main chemicals used at the TPC site. After addressing these concerns,
efforts focused on options for cleanup.

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TPC has been evaluating the conditions to prepare a
cleanup plan that eliminates the risks from potential
exposure to contamination. The investigation was
conducted in the multiple phases, resulting in the
following:
288 temporary soil borings
•	66 Membrane Interface Probe borings
76 permanent groundwater monitoring wells
26 soil gas locations
•	19 Permeable Reactive Barrier wells
A conceptual site model (CSM) was developed based
on the nature and extent of contamination and
investigation data. The CSM evaluated potential
exposure pathways, and identified potential receptors.
As concerns were identified, they were addressed
through Interim Remedial Measures, including:
A Groundwater Ordinance
Well Decommissioning/Municipal Hookup
7 Off-site Sub Slab Depressurization Systems
2 On-site Permeable Reactive Barriers
2 On-site Soil Vapor Extraction Systems
Soil Source Excavation
Facility Restrictive Covenant
Purpose of cleanup
The EPA legal order requires TPC to demonstrate that
pollution from its facility related to contaminated soil,
contaminated groundwater, and contaminated air is not
a health risk. People can be exposed to contamination
by ingesting, inhaling, contacting the contamination
directly, and the purpose of the cleanup is to prevent
those exposures from happening.
Soil: Trichloroethene and other VOCs were detected
above EPA Regional Screening Levels (RSLs) in on-
site soil samples. Soil will be remediated to site-
specific levels using soil vapor extraction (along with
excavation) in four areas, to supplement two prior
cleanup areas. The goal is to reduce contamination to
levels that prevent additional off-site migration of
groundwater contamination, and eliminate the off-site
vapor intrusion potential. Residual contamination will
be managed on-site with a restrictive covenant, a soil
management plan, impermeable surfaces, and vapor
mitigation controls for buildings used in the future to
protect visitors and site workers following
redevelopment.
Groundwater: Groundwater sampling shows two
narrow bands of contamination coming from the
property. The City Groundwater Ordinance eliminates
the ingestion risk by preventing people from drinking
contaminated groundwater. However, since
contaminated groundwater also extends under some
houses in the community, TPC proposes enhanced in-
situ bioremediation of the groundwater to reduce
contamination to levels that eliminate the threat of
vapor intrusion into buildings above the off-site
groundwater plume, followed by monitored natural
attenuation. The short-term goal is to eliminate off-site
vapor intrusion concerns; the long-term goals are to
protect the wetland to the east, and restore the aquifer.
Cleanup Goals
Cleanup levels for individual chemicals in soil and
groundwater are the site-specific, pathway-specific
cleanup objectives shown in the Statement of Basis.
Contaminant Risks
A site-specific TPC risk assessment for the Facility
identified unacceptable risks, and the cleanup proposal
is designed to eliminate all unacceptable risks.
Proposed Remedies
5 On-site Groundwater EISB Treatment Cells.
On-site SVE System Expansion in 3-4 Areas
Soil Excavation/Disposal from 4th Soil Area.
Existing Building Sub Slab Depressurization
Vapor Intrusion Controls on New Buildings
Contaminated Soil Management
Site Use Restrictions
Monitored Natural Attenuation Off-site
For More Information
The public is encouraged to review the Administrative
Record and comment on the Proposed Remedy. The
Administrative Record is available during normal
business hours at the Tecumseh District Library, at the
EPA Region 5 Records Center, and at
https://www.epa.gov/hwcorrectiveactionsites/hazardous
-waste-cleanuptecumseh-products-companv-facilitv-
tccumsch-michigan.
EPA will make a Final Decision on the Proposed
Remedy after the public comment period ends and all
comments are reviewed. EPA may modify the Proposed
Remedy based on any new information and comments
from the public.
Comments or requests for information must be
submitted prior to the expiration of the public
comment period, which ends November 25, 2018.
Guidelines for Commenting:
•	Explain your views.
•	Tell us if you support or disagree with the
Proposed Remedy. Please be specific.
•	Provide potential alternatives to the Proposed
Remedy.
Individuals may write to EPA contacts to join a mailing
list to receive any updated information directly
throughout the process.

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