EPA Region 5 Records Ctr.

11111111

2638S0

Five-Year Review Report
Second Five-Year Review Report
for

G&H Landfill Site
Shelby Township
Macomb County, Michigan
September 2006
PREPARED BY:

United States Environmental Protection Agency
Region 5
Chicago, Illinois

Approvea by:

Richard C. Karl
Director

Superfund Division

Date:

y/w/


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Table of Contents

List of Acronyms	iii

Executive Summary	iv

Five-Year Review Summary Form	vi

I.	Introduction	1

II.	Site Chronology	2

III.	Background	3

Physical Characteristics	3

Land and Resource Use	4

History of Contamination	4

Initial Response	5

Basis for Taking Action	5

IV.	Remedial Actions	6
Remedy Selection	6
Remedy Implementation	8
System Operations/Operation and Maintenance (O&M)	8
Institutional Controls	9

V.	Progress Since the Last Five-Year Review	10

VI.	Five-Year Review Process	12
Administrative Components	12
Community Notification and Involvement	12
Document Review	12
Data Review	12
Site Inspection	12
Interviews	13

VII.	Technical Assessment	13
Question A: Is the remedy functioning as intended by the decision documents? 13
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and
remedial action objectives (RAOs) used at the time of the remedy selection still
valid?	14
Question C: Has any other information come to light that could call into question
the protectiveness of the remedy?	14
Technical Assessment Summary	14

VIII.	Issues	15

IX.	Recommendations and Follow-up Actions	16

X.	Protectiveness Statements	17

XI.	Next Review	17

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Attachments

1.	Site Index Map

2.	Site and Surroundings

3.	Site Areas

4.	Summary of Groundwater Sampling Results

5.	Federal Applicable or Relevant and Appropriate Requirements (ARARs)

6.	State Applicable or Relevant and Appropriate Requirements (ARARs)

7.	IC Map

8.	Deed Restrictions

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List of Acronyms

ARAR

Applicable or Relevant and Appropriate Requirement

BGS

Below Ground Surface

BTEX

Benzene, Toluene, Ethylbenzene, and Xylene

CD

Consent Decree

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

COC

Contaminants of Concern

CRA

Conestoga Rovers & Associates

DWSD

Detroit Water & Sewer Department

EPA

United States Environmental Protection Agency

ESD

Explanation of Significant Difference

FYR

Five-Year Review

IC

Institutional Control

ISVE/AS

In-situ Vapor Extraction/Air Sparge

MCHB

Macomb County Health Board

MCL

Maximum Contaminant Level

MCLG

Maximum Contaminant Level Goal

MDEQ

Michigan Department of Environmental Quality

MDNR

Michigan Department of Natural Resources

MWRC

Michigan Water Resource Commission

NCP

National Contingency Plan

NPL

National Priorities List

OCHD

Oakland County Health Department

O&M

Operation and Maintenance

PAH

Polyaromatic Hydrocarbon

PNA

Polynuclear Aromatics

PCB

Polychlorinated Biphenyl

PEAS

Pollution Emergency Alerting System

PPB

Parts per Billion

PRP

Potentially Responsible Party

RA

Remedial Action

RAO

Remedial Action Objective

RD

Remedial Design

RI/FS

Remedial Investigation/Feasibility Study

ROD

Record of Decision

RPM

Remedial Project Manager

SVE

Soil Vapor Extraction

SVOC

Semivolatile Organic Compound

VOC

Volatile Organic Compound

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Executive Summary

The G&H site is located in Shelby Township, Macomb County, Michigan, about 20 miles north
of Detroit (Attachment 1). The site comprises approximately 60 acres of a former landfill, 30
acres of adjacent wetlands, and other impacted areas including a former junkyard. The site is
bounded on the north by 23 Mile Road and on the east by Ryan Road. Residential areas are north
of 23 Mile Road and east of Ryan Road, and the Clinton River runs through the Rochester-Utica
State Recreational Area to the south and west

From 1955 until 1973 G&H Industrial Landfill, Inc. accepted industrial waste oil, solvents, and
municipal waste for disposal. State authorities noted groundwater contaminated with
polychlorinated biphenyls (PCBs) seeping out of the landfill in areas south of the site, and
prohibited further disposal of industrial solvents in the mid-1960's. The State of Michigan
referred the site to U.S. EPA in 1982. U.S. EPA performed a site inspection and proposed the
site for listing on the National Priorities List (NPL) in July 1982. The site's placement on the
NPL was published in the Federal Register on September 8.1983 (48 Fed. Reg. 40658).

U.S. EPA and Michigan Department of Environmental Quality (MDEQ) began a Remedial
Investigation and Feasibility Study ("RI/FS") in 1984. Based on the findings of the RI/FS, U.S.
EPA issued a Record of Decision ("ROD") on December 21,1990 that called for a remedy
comprising the following components:

Installation of a modified RCRA Subtitle C landfill cover to prevent direct contact and
reduce the rate of infiltration to the water table;

Excavation of impacted soils from areas outside of the landfill cover and placement of
these impacted soils beneath the landfill cover,

Installation of a slurry wall around the landfill areas to physically contain the contents
and a toe drain on the west side of the landfill to capture leachate for treatment;
Installation of a groundwater extraction and treatment system to capture and
hydraulically contain the landfill contaminants;

Implementation of a monitoring program to assess the efficacy and progress of the
groundwater cleanup;

Restoration of impacted wetlands and establishment of new wetlands to replace those lost
to contamination or remedy implementation;

Compliance standards for groundwater outside of the landfill based on Safe Drinking
Water Act Maximum Contaminant Levels (MCLs) and State of Michigan criteria for
protection of groundwater quality.

The remedy is currently protective of human health and the environment in the short term. The
landfill cover, groundwater extraction and treatment system, and access controls are functioning
as designed, and have achieved the remedial objectives, which include minimizing the migration
of contaminants to groundwater and surface water and preventing direct contact with
contaminants at the Site.

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Long-term protectiveness of the remedy is dependent upon the continued effectiveness of the
groundwater extraction and treatment system in maintaining an inward hydraulic gradient and
removing contaminants from the Site. Monitoring of the groundwater and surface water will
continue until the performance of the remedy can be demonstrated by the attainment of
groundwater cleanup standards. An institutional controls study and IC plan will be completed
within six months after the date of this Five-Year Review Report.

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Five-Year Review Summary Form

Site IDENTIFICATION

Site name {from Mto*LAM): G&H Landfill

EPA D (from Wbm&LAN): MID980410823

| Region: 05

State: Ml

City/County: Macomb County

Site STATUS

NPL Status: B final ~ Deleted ~ Other (specify)

Hemsdistton status (choose al thai apply): ~ Under Construction B Operating ~ Complete

1

~

CO

a no

Construction completion date: 08/26/1999

c

1

i

I

1
1

(use? 1

~ YES B NO

REVIEW STATUS

Load agency B EPA ~ Stale ~ Trije ~ Other Federal Agency

Author name: WBam J. Ryan

Author title: RemedeJ Protect Manager

Author affiliation: U.S. EPA, Region 5

10/30/2005 to 09/30/2006

DaMs) of SHe Inspection: 02/14/06, and 04/24/06

Type of review:

Bpost-SARA ~ Pre-SARA ~ NPLRemoval only

~	Non-NPL Remedial Action Site ~ NPLSttte/Tribe-kad

~	ReponaJ Discretion

Review number: ~ 1 (first) B 2 (second) ~ 3 (third) ~ Other (specify)

~	Actual RAOnSiteCoostnictioaxOU#		~ Actual RA Start M OUt	

~	Construction Completion	B Previous Five-Year Review Report

~	Other (speciy)	

Triggering action data (from WaataLANj: 09 / 05 / 2001

Due dale flhmy—na/lm-triggering action data): 09 / 05/2006
' rotr refers to operable unit.]

* {Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

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Five-Year Review Summary, continued

Issues:

Hydraulic containment along the south wall of Phase n
Hydraulic containment in the SW corner on Phase n
Groundwater mounding at GW7

Effectiveness of the leachate collection system at the toe of Phase HI

Adequacy of the current site survey

Monitoring and Reporting

Ensuring well integrity

Institutional Controls

Recommendations and Follow-up Actions:

Investigate the apparent hydraulic connection between GH78 and GH79 and ensure the
maintenance of an inward hydraulic gradient

Evaluate the effects of the discontinuity in the slurry wall in the southwest corner. Plan to
extend the slurry wall once the water main is abandoned and/or evaluate the potential of
additional extraction wells to contain the landfill contents
Determine the cause of the mounding at GW7

Develop a plan to evaluate the effectiveness of the leachate collection system at the toe of
Phase III

Re-survey the site

Reevaluate the list of analytical parameters and develop a system for regular electronic data
submission

Amend the O&M Plan to include a quality assurance process for determining when a well
needs rehabilitation and/or replacement

Complete an IC study for the Site within six months after the date of this Five-Year Review
Report
Protectiveness Statement:

The remedy is currently protective of human health and the environment in the short term. The
landfill cover, groundwater extraction and treatment system, and access controls are functioning
as designed, and have achieved the remedial objectives, which include minimizing the migration
of contaminants to groundwater and surface water and preventing direct contact with
contaminants at the Site.

Long-term protectiveness of the remedy is dependent upon the continued effectiveness of the
groundwater extraction and treatment system in maintaining an inward hydraulic gradient and
removing contaminants from the Site. Monitoring of the groundwater and surface water will
continue until the performance of the remedy can be demonstrated by the attainment of
groundwater cleanup standards. Long term protectiveness is dependent upon the implementation
of the institutional controls required by the ROD and listed in the Consent Decree, and will be
subject to an institutional controls study to ensure they are adequately implemented, maintained,
and monitored.

Other Comments:

None

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Five-Year Review Report

I. Introduction

The purpose of this five-year review is to determine whether the remedy at the G&H Landfill
Site (the Site) is protective of human health and the environment. The methods, findings, and
conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year
Review reports identify issues found during the review, if any, and identify recommendations to
address them.

The Agency is preparing this five-year review pursuant to CERCLA §121 and the National
Contingency Plan (NCP). CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the Site, the President shall review such remedial
action no less often than each five years after the initiation of such remedial action to assure
that human health and the environment are being protected by the remedial action being
implemented. In addition, if upon such review it is the judgment of the President that action
is appropriate at such Site in accordance with section [104] or [106], the President shall
take or require such action. The President shall report to the Congress a list offacilities for
which such review is required, the results of all such reviews, and any actions taken as a
result of such reviews.

The agency interpreted this requirement further in the National Contingency Plan (NCP); 40
CFR §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the Site above levels that allow for unlimited use and unrestricted
exposure, the lead agency shall review such action no less often than every five years after
the initiation of the selected remedial action.

The United States Environmental Protection Agency (EPA) Region 5 conducted this five-year
review of the remedial actions implemented at the G&H Landfill Site in Macomb County,
Michigan. This review was conducted from May 2005 through July 2006. This report
documents the results of the review. EPA was assisted in the review of the G&H Landfill Site by
the Michigan Department of Environmental Quality.

This statutory review is the second five-year review for the G&H Landfill Site. The triggering
action for this review is the date of the first five year review, as shown in EPA's WasteLAN
database: 09/05/01. This five-year review is required because hazardous substances, pollutants,
or contaminants remain at the Site above levels that allow for unlimited use and unrestricted
exposure. This document will become part of the G&H Landfill Site file and it will be placed
into the Site information repository located at the Shelby Township Library, 51680 Van Dyke
Avenue / Shelby Township, MI 48316 / (586) 739-7414.

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II. Site Chronology

Event

Date

Initial discovery of problem or
contamination

Early 1960s

Pre-NPL responses

•	Michigan Water Resource Commission
(MWRC) conducts a groundwater and
surface water investigation in July 1965

•	The State investigates the site several
more times between 1973 and 1979

NFL listing

September 8, 1983

Removal actions

The U.S. EPA conducted four removal

actions at the G&H landfill:

•	July 1982: a fence is constructed around
the oil seep area, and dams are built to
direct surface water flow around the seeps

•	July 1983: the fence is extended around
the perimeter of the oil seeps, an oil
skimmer is installed to prevent the
migration of floating oil, and clay barriers
are placed in the path of the oil seeps

•	May 1986: recreational area trails are
blocked with earthen berms, a gate is
installed to restrict public access, a
collector trench is excavated to connect
isolated oil seeps, and sheetpile is
installed to prevent oil from migrating
beyond the collector trench

•	July 1987: a chain-link fence is installed
around the perimeter of the entire site

Remedial Investigation/Feasibility
Study complete

December 21 , 1990

ROD signature

December 21, 1990

ESD

March 13, 1992

Enforcement documents (CD, AOC,
Unilateral Administrative Order)

CD for Access/Cost Recovery, April 3, 1992
CD for Cost Recovery, September 2, 1992
CD for RD/RA, June 30, 1992

Remedial design start

September 10, 1992

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Event

Date

Remedial design complete

June 2, 1995

Actual remedial action start

August 19, 1996

Construction completion date

August 24, 1999

1st five-year review

September 5, 2001

III. Background

Physical Characteristics The 90-acre site is divided into three phases (See Attachment 2). An
abandoned Conrail railroad right-of-way bisects the site, running from the southeast comer of the
site to the northwest corner, separating the Phase I landfill area to the north from the Phase n
landfill area to the south. The main site access road, with a gate located on 23-Mile Road, runs
north-south on the site and separates the Phase m landfill area on the west from Phases I and n
on the east A portion of the former Clinton-Kalamazoo Canal, an abandoned navigational
project, runs east-west through the northern portion of the site.

Current site topography is defined by three capped mounds that comprise the three phases of the
former landfilling operation. While the site access road and railroad right-of-way are located at
grade, each of the capped landfill mounds rise approximately 10-15 feet above the grade.

Structures on the site include a pumping/treatment facility located in the southwest comer of the
Phase D landfill area, which treats effluent from the landfill and releases treated water into an
adjacent wetland area. Operations at the treatment facility are currently managed by the PRP's
technical consultants, Conestoga Rovers & Associates (CRA). CRA was also the engineering
firm that implemented the G&H Landfill site remedy. The site includes a system of
approximately 80 above-ground vents and monitoring wells distributed across the site.

A 200-acre preserve located immediately south of the G&H Landfill site, now known as Holland
Ponds, was deeded to Shelby Township by the Michigan Department of Natural Resources in
1993. The area includes seven ponds whose source water includes the treated water that leaves
the pumping/treatment station at the G&H Landfill site. Two of the seven ponds at the preserve
were constructed by CRA to replace wetlands that had previously existed on the site. The
Holland Ponds area provides habitat for migrating birds, box turtles, and painted turtles. A heron
rookery is located adjacent to me site.

The Detroit Water & Sewer Department (DWSD) easement that runs through the western portion
of the site contains a 96-inch water supply pipeline and a 24-inch interceptor sewer. The water
supply line was constructed in 1967 and serves as the main distribution line from Lake Huron to
the Detroit Municipal Water System. The 24-inch interceptor sewer, which serves Shelby
Township, is connected to a 96-inch regional interceptor sewer which runs beneath portions of
the Phase n and Phase in landfill areas.

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Land and Resource Use The 90-acre G&H Landfill site is located at the junction of 23 Mile
Road and Ryan Road (Attachment 1). It is surrounded by a mix of uses, including Spring Lake
and Clear Spring Lake, two high-end residential developments to the north, an older residential
subdivision of approximately 80 homes to the east, and several light industrial facilities located
to the southeast. The Clinton River runs near the western and southern site boundaries, and the
Holland Ponds Natural Area, part of the former Rochester-Utica State Recreational Area, is
located south of the site. A temporary indoor soccer structure is located west of the site.

A study is currently underway to determine whether portions of the site can be returned to
productive use by the surrounding community. EPA's primary responsibility at the site is to
ensure the continued protection of human health and the environment. However, with effective
planning communities can return sites to productive use without jeopardizing the effectiveness of
the remedy. The local community and local government agencies have ongoing interests in the
G&H Landfill Superfund site and have indicated strong interest in exploring reuse opportunities
for the site.

EPA has engaged a consultant team to provide specialized reuse planning skills. In the spring of
2006, the team met with officials from Shelby Township, EPA Region 5, the Michigan
Department of Environmental Quality (MDEQ), and PRP representatives. The team is
conducting community research, mapping, and analysis to inform the reuse planning process.
The outcome will support a community-based evaluation of the site and surroundings to identify
site reuse challenges and opportunities, develop a conceptual site reuse framework and project
report, and identify potential resources and partnerships to plan the site's future use.

History of Contamination The G&H site was a sand and gravel quarry until the early 1950s.
After quarry operations ceased, the landowner leased the property to the G&H Industrial Fill
Company. Waste disposal operations at the site began in the mid-1950s and ended in 1973. The
site accepted municipal refuse and liquid and solid industrial wastes including oils, solvents,
paint residues, and industrial process muds. The site contains three distinct landfill areas
(Attachment 3):

Phase I Landfill - 44 acres
Phase II Landfill -17 acres
Phase III Landfill - 8 acres

Separate areas in the Phase I Landfill were identified as receiving solid and liquid wastes, in bulk
and in drums. These areas, which are now covered with fill, include:

•	Oil Pond No. 1

•	Oil Pond No. 2

Rubbish Area (referred to as the Co-disposal Area)

Paint, Varnish, and Solvent Ponds

From approximately 1955 to 1967, the G&H Industrial Fill Company operated a waste oil
disposal system at the site. Bulk waste oil from various industrial sources was transported to the
site in railroad tanker cars or tanker trucks. Records indicate that an estimated 600,000 gallons of

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waste oil was accepted monthly at the site, although the time period over which this volume was
accepted is not known. Initially, the operators attempted to reclaim oil by pumping mixtures to
settling ponds and skimming off the recoverable oil for resale. Several attempts were made to
reclaim the oil, but none were commercially successful. Thereafter, the oil was reportedly left to
settle and the volatile components allowed to evaporate. The resulting sludge was periodically
removed from the settling ponds and buried in the landfill.

Initial Response In the early 1960s, local residents lodged complaints with the Macomb County
Health Board (MCHB) regarding chemical odors coming from the Clinton-Kalamazoo canal
south of the landfill. An initial inspection by the MCHB did not locate the source of the odors,
however a joint site surveillance by the MCHB and the Michigan Water Resource Commission
(MWRQ discovered that groundwater seeps south of the railroad tracks emitted a strong
chemical odor. MWRC noted that the landfill operation accepted waste oils and municipal trash,
along with solvents, paints, etc., which were delivered in 55-gallon drums, and identified three
areas in the Phase I landfill into which the contents of the drums were dumped. As a result, the
MWRC conducted a groundwater and surface water investigation in July 1965.

The MWRC investigation determined that groundwater in the upper aquifer flowed generally to
the south and that liquid waste operations were responsible for contamination in the groundwater
south of the railroad tracks. As a result of this investigation, a Consent Order was issued by the
Macomb County Circuit Court in May 1966 prohibiting the disposal of paints, varnishes, paint
thinners, and lacquers in the G&H landfill. Waste oils were not addressed by this Consent Order.

A second MWRC investigation in November 1966 concluded that the waste oil disposal/
reclamation activities at the landfill were also contributing to groundwater contamination. Based
upon these findings, the Macomb County Circuit Court issued a second Consent Order in 1967
banning the disposal of any liquid industrial wastes at the landfill.

The State investigated the site several more times between 1973 and 1979. These sampling
events documented potential contamination of the Clinton River by leachate seeps west of the
Phase in landfill area and by oil seeps south of the Phase I landfill area.

Basis for Taking Action Prior to the remedial action an assessment of the sites risks concluded
that onsite chemical exposure could occur by direct contact with contaminated media, or by
release of volatile compounds and inhalation. Potential exposure pathways included transport
offsite, release of contaminants to the groundwater and exposure through the use of groundwater
as a water supply source, release of volatile compounds from the site and, exposure to people
engaged in recreational activities in areas adjacent to the site through direct contact with
contaminated surface water and sediments, and exposure of people that consume contaminated
wildlife. Risks to the environment included exposure of terrestrial wildlife through direct contact
with contaminated media at the site, and exposure of aquatic organisms in the Clinton River or
Clinton-Kalamazoo Canal to contaminants released from the site to those water bodies by way of
groundwater discharge or site runoff.

The exposures of greatest concern based on the quantitative risk characterization included:

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Direct contact with surface soil on the Phase I Landfill
Direct contact with sediments in the Oil Seep Area
Direct exposure to the oil seep water
Use of groundwater as a drinking water source

Soil Contamination The areas of the highest chemical contamination in the soil were in the
Phase I Landfill, primarily near the oil ponds and the suspected Co-disposal Area. Soils in or
near the Phase II and III Landfills also showed contamination but to a lesser extent. Soils in the
industrial area to the east showed that contamination extends offsite. Many organic contaminants
were detected in the soil. BTEX compounds showed the greatest area! extent of contamination.
Polynuclear aromatic hydrocarbons (PAHs) and PCBs were the other organic compounds most
often detected and at the highest concentrations. Many inorganic compounds were detected
above background concentrations in or near the three landfill areas.

Groundwater Contamination The vertical extent of groundwater contamination for BTEX,
PNA, and chlorinated VOCs appeared to be limited to the base of the refuse and top of the upper
sand unit. The horizontal extent of BTEX and chlorinated VOC contamination extended from the
north boundary of the site southward to the south side of the Clinton Kalamazoo Canal. The
highest concentrations of chlorinated VOCs were adjacent to the old solvent pond. Chlorinated
VOCs were detected around the sheet pile wall in the Oil Seep Area and near the Oil Storage
Building. The chlorinated VOCs extended to the south side of the Clinton Kalamazoo Canal.
PNA contamination in the groundwater appeared to follow the same trends as BTEX
contamination but to a lesser extent and at lower levels. A till layer isolates the upper aquifer
from the lower aquifer. No contamination was detected in the lower aquifer.

Well Sampling BTEX and chlorinated VOCs were detected in residential and commercial well
water in the vicinity of the site. These waste types were consistent with wastes detected onsite.
Contamination in the industrial area appeared to be site related because the waste types were
consistent with wastes detected onsite and the contamination was detected upgradient in the auto
disposal yard. Because the types of contaminants found east of Ryan Road were consistent with
those found onsite, it was thought that the contamination east of Ryan Road may be site related.
However, no contamination was detected upgradient of this area.

Surface Water and Sediment Contamination Separate phase liquids and contaminated
groundwater from the original Phase I Landfill area were the sources of the sediment and surface
water contamination in the Oil Seep Area and the contamination of surface runoff which in turn
contaminated the groundwater south and southwest of the Oil Seep Area. BTEX and PNA
compounds were detected in surface water upgradient of the Oil Seep Area.

IV. Remedial Actions

Remedy Selection EPA issued a Record of Decision ("ROD") on December 21,1990 that called
for a remedy comprising the following elements:

Installation of a modified RCRA Subtitle C landfill cover to prevent direct contact and
reduce the rate of infiltration to the water table

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Excavation of impacted soils from areas outside of the landfill cover placement of the
impacted soils beneath the landfill cover

Installation of a slurry wall around the landfill areas to physically contain the landfill
contents and a toe drain on the west side of the landfill to capture leachate for treatment
Installation of a groundwater extraction and treatment system to capture and hydraulically
contain the landfill contaminants

Implementation of a monitoring program to ensure the adequacy of the groundwater cleanup
Mitigation of impacted wetlands and creation of new wetlands to replace those lost to
contamination or remedial construction

Establishment of cleanup standards for groundwater outside of the landfill based on Safe
Drinking Water Act Maximum Contaminant Levels (MCLs) and State of Michigan criteria
for protection of groundwater quality

Final cleanup goals for the Site are as follows:

Groundwater Cleanup Standards from ROD

Contaminant	Cleanup Standard

Benzene	1 ppb

Xylene	20 ppb

Ethylbenzene	30 ppb

Arsenic	0.02 ppb*

Lead	5 ppb

Trichloroethene	3 ppb

Tetradoroethene	0.7 ppb

cis-l,2-Dichloroethene	1 ppb

trans-l,2-Dichloroethene	100 ppb

Vinyl chloride	0.02 ppb

1,1-Dichloroethane	0.4 ppb

*Naturally occurring (background) levels found at the G&H site may be higher than
the Cleanup Standard. In that event, background levels will become the Cleanup
Standard.

EPA issued an Explanation of Significant Differences (ESD) on March 13, 1992. In the ESD,
the Agency determined that:

The Frost Protection Layer of the Landfill Cap could be reduced from the 42 inches to 30
inches

The slurry wall did not need to completely encircle the landfill, as placing a slurry wall along
the upgradient edge of the landfill may cause groundwater to back up behind the slurry wall
and perhaps enter basements in the homes north of the landfill.

EPA, in consultation with MDNR, also changed the groundwater cleanup standards for three
chemical contaminants, shown in the table below:

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Groundwater Cleanup Standards Modified by the ESP

Chemical

ROD Cleanup Standard

ESD Cleanup Standard

T etrachloroethene
Vinyl chloride
1,1 -Dichloroethane

0.7 ppb
0.02 ppb
0.4 ppb

1.0 ppb
1.0 ppb
1.0 ppb

Remedy Implementation In a Consent Decree (CD) signed with EPA on June 30,1992, the
PRPs agreed to perform the remedial design/remedial action (RD/RA). The Remedial Design
(RD) was conducted in conformance with the ROD as modified by the ESD. The RD started on
September 10,1992, and was completed on June 2,1995. The RA started on August 19,1996,
and was completed on August 24,1999.

The RD had two parts: 1) the groundwater and leachate treatment system, and 2) the landfill cap
and slurry wall. EPA, in consultation with MDEQ, approved one major design change involving
the substitution of a combination of 1 foot of clay and a bentonite-containing geotextile liner for
the required 3 feet of clay in a Subtitle C landfill cap. The PRPs were able to demonstrate
equivalent performance of the clay/geotextile liner versus the thicker clay layer to support the
design change.

The major components the RA included:

Installation of a modified RCRA Subtitle C landfill cover to prevent direct contact and
reduce the rate of infiltration to the water table;

Excavation of impacted soils from areas outside of the landfill cover placement of the
impacted soils beneath the landfill cover;

Installation of a slurry wall around the landfill areas to physically contain the landfill
contents and a toe drain on the west side of the landfill to capture leachate for treatment;
Installation of a groundwater extraction and treatment system to capture and hydraulically
contain the landfill contaminants;

Implementation of a monitoring program to ensure the adequacy of the groundwater cleanup;
Mitigation of impacted wetlands and creation of new wetlands to replace those lost to
contamination or the cleanup

System Operation and Maintenance The PRPs are conducting long-term monitoring and
maintenance activities according to the EPA approved operation and maintenance (O&M) plan.
The primary activities associated with O&M include:

Bi-weekly and monthly inspections are conducted in the landfill cap, groundwater/1 eachate
collection systems, slurry wall, wetlands areas, access roads, and perimeter security fence. In
addition, the cap is scheduled to be mowed semi-annually;

Groundwater samples and water level measurements are obtained quarterly from 71
monitoring wells

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Dates

Total Cost rounded to nearest $1,000

From

To

9/2005

9/2006

$451,000

9/2004

9/2005

$492,000

9/2003

9/2004

$506,000

9/2002

9/2003

$588,000

9/2001

9/2002

$716,000

Institutional Controls ICs are non-engineered instruments, such as administrative and legal
controls, that help to minimize the potential exposure to contamination and protect the integrity
of the remedy. ICs are required to ensure long-term protectiveness for any areas that do not
allow unlimited use or unrestricted exposure (UU/UE).

The ROD stipulates that ICs will be relied upon to provide additional effectiveness to the
remedy. Deed restrictions shall be placed on the landfill area property to regulate the
development of the landfill. An aerial photograph of the Site, showing the area to be subject to
the deed restrictions, can be found in Attachment 7. Groundwater-use restrictions shall be
maintained in the off-site areas to the east of Ryan Road until Groundwater Cleanup Standards
are met

The Consent Decree requires the PRPs to record a fully executed copy of the Consent Decree
and the Deed Restrictions (Attachment 8) with the Register of Deeds Office, Macomb County,
State of Michigan, to ensure that future use of the Site will not impair or defeat any response
actions on, under, or adjacent to the Site.

Consistent with the ROD, the Consent Decree requires that the following restrictions be imposed
upon the Site for the purposes of protecting public health and the environment, and preventing
interference with the remedy:

•	No consumptive or other use of the groundwater that could cause exposure of humans or
animals to the groundwater underlying the Site

•	No residential, commercial, or agricultural use of the Forster property considered pan of the
Site, including, but not limited to, any filling, grading, excavating, building, drilling, mining,
farming, or other development, or placing of waste material at any portion of the Site,
including, but not limited to, the Auto Disposal Yard for any purpose, including residential,
commercial, or agricultural purposes, except as approved in writing, by U.S. EPA

•	No use of the Site that would allow the continued presence of humans at the Site, other than
the presence necessary for implementation of any response actions selected and/or
undertaken by U.S. EPA pursuant to Section 104 of CERCLA, including such response
actions taken by other responsible parties under a judicial or administrative order. A
prohibited use of the Site includes, but is not limited to, recreational use

9


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•	No installation, removal, construction or use of any buildings, wells, pipes, roads, ditches or
any other structures or materials at the Site except as approved, in writing, by U.S. EPA, and
in consultation with the State of Michigan

•	No tampering with, or removal of, the containment or monitoring systems that remain on the
Site as a result of implementation of any response action by U.S. EPA, or any party acting as
agent for U.S. EPA, and which is selected and/or undertaken by U.S. EPA pursuant to
Section 104 of CERCLA

•	No use of, or activity at, the Site that may interfere with, damage, or otherwise impair the
effectiveness of any response action (or any component thereof) selected and/or undertaken
by U.S. EPA, or any party acting as agent for U.S. EPA, pursuant to Section 104 of
CERCLA, except with the written approval of U.S. EPA, in consultation with the State of
Michigan, and consistent with all statutory and regulatory requirements.

The obligation to implement and maintain the above restrictions shall run with the land and shall
remain in effect until such time as U.S. EPA files with the Court a written certification stating:

The response action required at, under or adjacent to the Site by any Consent Decree or
judicial or administrative order, entered pursuant to CERCLA, has been fully implemented;

•	No other response actions are planned for the Site; and

The above restrictions are no longer necessary to meet the purposes of the remedy.

An institutional controls study will be completed for the Site within six months after the date of
this Five-Year Review Report. Among other things, the institutional controls study should
investigate whether the deed restrictions were actually put in place for the Site and were
conveyed by a person with authority to make the conveyance; whether the deed restrictions are
currently valid, in place, and have not been lifted or superceded; whether the terms of the deed
restrictions create rights that can be enforced by U.S. EPA or MDEQ in the event that the deed
restrictions are violated; and whether the deed restrictions are, in fact still being complied with.

U.S. EPA will create an IC Plan that includes steps necessary to ensure effective ICs are
implemented and maintained. As part of the plan, U.S. EPA will request that the PRPs undertake
an IC Study to ensure that effective ICs have been implemented. Also, EPA will request
assurances for long-term stewardship including regular inspections of the Site and an annual
certification to EPA that ICs are effective and that IC maps are completed. The IC maps will be
made available to the public on EPA's Superfund Data Management System (SDMS).

V. Progress Since the Last Review

Protectiveness statements from the last review: "Should the Group (PRPs) continue to operate
and maintain the final remedial action components pursuant to the ROD and ESD, as designed,
and make the recommended improvements listed above, the remedy selected for the G&H site is
protective of human health and the environment."

10


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Issues and status of recommendations for follow-up actions from last review:

1.	Leachate is discharging into the wetland area known as Wetland/Pond 3, creating periodic
low-level chronic toxicity problems.

Recommendation: Install a new pumping well to mitigate the discharge to Wetland/Pond 3.

Status: A new collection well (EW6) was installed upgradient of mitigated Wetland/Pond 3
in June 2002. EW6 has effectively eliminated the observed seep into Wetland/Pond 3.

2.	The landfill cap drainage layer along the Phase ID landfill area is leaking water during high
rain events.

Recommendation: Sample the water for leachate and investigate further if leachate is found
in the water samples.

Status: These discharges or outbreaks were sampled on May 9,2000, by CRA and the
MDEQ. The sampling of the iron stained discharges from the toe of Phase in detected
inorganic and organic contamination. The detection of VOCs indicates that the discharges
were more than simply iron bacteria precipitating out of the cap tiles as precipitation
infiltrated the cap. A groundwater investigation was performed, and eleven wells, designated
GW, were installed.

3.	Groundwater capture along the west side of the water main (where the slurry wall was not
installed) may not be entirely successful at this time.

Recommendation: Increase pumping rates to ensure hydraulic containment

Status: Extraction wells (EW1-EW5) were installed along the west side of the DWSD water
main to de-water it However, the performance of this system has been affected by the
ongoing operational interruptions from iron precipitation in Sump S-4. To reduce the
operational interruptions in Sump S-4, a peristaltic pump was installed in Sump S-4. This
pump should result in less interruption to the system's operation and its performance is being
evaluated.

4.	Monitoring wells MW 4A and MW 4B are no longer functioning as designed.
• Recommendation: Abandon and replace MW 4A and MW 4B.

Status: MW 4A and MW 4B have been replaced.

5.	Several new monitoring wells have been installed at the site area (wells GW 1, GW2, GW3,
GW10, and GW11).

Recommendation: Include these MW in the site groundwater monitoring program.

11


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Status: Some of the monitoring wells have been added to the groundwater monitoring
program.

VI. Five-Year Review Process

Administrative Components For the current report the Remedial Project Manager (RPM)
established a review schedule, which included:

• Community Notification
Document Review
Data Review
Site Inspections

Five-Year Review Report Development and Review

A letter notifying the State that U.S. EPA would be conducting a FYR (Five-Year Review) in
2006 was sent to the State Project Manager in December 2005. Members of the review team
included:

Bill Ryan, U.S. EPA, Remedial Project Manager

Lisa Summerfield, MDEQ, State Project Manager (Note: Ms Summerfield was replaced by

Mary Schaffer in May, 2006)

Barb Vetort-Tiffany, MDEQ, State Project Geologist

Community Notification Activities to involve the community in the five-year review process
were initiated in April 2006 with a call to the Community Involvement Coordinator (CIC) for the
G&H site. A notice was published in a weekly Macomb County newspaper, The Source, on
April 16, 2006. No one in the community has voiced any interest or opinion concerning the
five-year review process since the notice was issued.

Document Review This five-year review included a review of the following documents:

Enforcement documents (Consent Decrees and Administrative Orders)

Design documents (RI/FS Reports)

Decision documents (ROD)

O&M records and monitoring data

Data Review EPA reviewed the electronic data submitted pursuant to Regional policy in the
preparation of this FYR. These include monitoring results for 71 groundwater and 9 surface
water monitoring points. The data reveal that while exceedances of cleanup goals remain at
various monitoring points, the potential for exposure is controlled or below the threshold for
unacceptable risk. Tables summarizing the monitoring and sampling data can be found in
Attachment 4.

Site Inspections The RPM inspected the Site on 02/14/2006. He was accompanied by the Site
Site Geologist from MDEQ, the Remediation Specialist from Daimler Chrysler (a PRP), and the
PRP's Project Manager in charge of the Site. The group reviewed the Site history and examined

12


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the landfill cap, adjacent wetlands, and the groundwater extraction and treatment system,
confirming that the installations were functioning as designed and mat the cover and fencing
were intact Specific observations include:

Fence - the main part of the fence, which isolates the landfill and treatment plant from public
access, is intact and well maintained.

Roads - the access roads into the site, around the perimeter of the capped area, to the
treatment plant, and through the wetlands area were properly graded and well maintained.
Landfill Cap - the cap appears intact and well maintained. No signs of settlement, cracks,
erosion, holes, penetrating vegetation, bulges, or slope instability were observed.

Wetlands - the wetlands associated with the treatment plant and Holland Ponds area appear
to be thriving, however Wetland Area 1, in the ME comer of the Site, was substantively dry,
because this wetland sits above the local water table and is dependent on precipitation.
Treatment Plant - the treatment plant discharge reports were reviewed with the plant operator
and no substantive deficiencies were noted.

Interviews Interviews with individuals beyond the five-year review project team and treatment
plant operator were not conducted. Since the newspaper notice, no member of the community or
any other individual voiced any interest in conducting an interview related to the five-year
review.

VII Technical Assessment

Question A: Is the remedy functioning as intended by the decision documents?

The review of documents, ARARs, risk assumptions, and the results of the site inspection
indicate that the remedy is functioning as intended by the ROD, as modified by the ESD. The
removal, stabilization, and capping of contaminated soils and sediments has achieved the
remedial objectives to minimize the migration of contaminants and prevent direct contact with,
or ingestion of, contaminants in soil and sediments.

Operation and maintenance of the cap and drainage structures has, on the whole, been effective.
Maintenance on the cap is sufficient to maintain its integrity. O&M annual costs are consistent
with original estimates and there are no indications of any substantive difficulties with the
remedy. However, there are questions regarding whether the monitoring well network currently
provides sufficient data to assess the overall effectiveness of the remedy, and whether hydraulic
containment of leachate within the boundary of the capped areas needs further evaluation.

The institutional controls that are required by the Consent Decree include prohibitions on the
groundwater use, prohibitions on excavation or disturbance of the cap, and any other activities
that might interfere with the remedy. However, it remains necessary to verify that the
institutional controls are in place and effective. No activities were observed that would have
violated the institutional controls. The cap remains undisturbed, no new uses of groundwater
were observed, and the fence around the site is in good repair.

13


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Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial
action objectives (RAOs) used at the time of the remedy selection still valid?

The exposure assumptions used to develop the Human Health Risk Assessment included both
current exposures (older child trespasser, adult trespasser) and potential future exposures (young
and older future child resident, future adult resident and future adult worker). There have been
no changes in the toxicity factors for the contaminants of concern that were used in the baseline
risk assessment. These assumptions are considered to be conservative and reasonable in
evaluating risk and developing risk-based cleanup levels. No change to these assumptions, or the
cleanup levels developed from them is warranted. There has been no change to the standardized
risk assessment methodology that could affect the protectiveness of the remedy.

MDEQ has raised the issue that the selected remedy may not conform to the standards of
Michigan's generic Groundwater Surface Water Interface (GSI) criteria. EPA will continue to
discuss the issue with the State.

Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?

There is some concern that the slurry wall may be compromised along the southern edge of
Phase II, and containment at the southwest end of the slurry wall near the DWSD water main is
uncertain. These issues need further evaluation. Plans to extend the slurry wall once DWSD
abandons the water main, or install additional extraction wells to ensure hydraulic containment
of the landfill contents, should be developed.

Technical Assessment Summary

According to the data reviewed and the site inspection, the remedy is functioning as intended by
the ROD, as modified by the ESD. There have been no changes in the physical conditions of the
site that would affect the protectiveness of the remedy. There have been no changes in the
toxicity factors for the contaminants of concern that were used in the baseline risk assessment,
and there have been no change to the standardized risk assessment methodology that could affect
the protectiveness of the remedy. However, hydraulic containment of leachate within the
boundary of the capped areas needs further evaluation to determine if further engineering
controls will be necessary.

14


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VIII. Issues

Issues

Affects
Current
Protectiveness
(Y/N)

Affects
Future
Protectiveness
(Y/N)

There is evidence that the hydraulic containment along the
south wall of Phase D may be compromised.

N

Y

Hydraulic containment in the SW comer on Phase II is
affected by a discontinuity in the slurry wall due to the
presence of the DWSD waterline.

N

Y

Groundwater mounding at GW7 remains unexplained. A 7
ft hydraulic head difference was recorded between the
water level in GW7 and the surrounding source area.

N

Y

Effectiveness of the leachate collection system at the toe of
Phase in has been questioned, and there have been
problems in maintaining adequate flow to the treatment
plant

N

Y

MDEQ has questioned the adequacy of the monitoring
network and list of analytical parameters for ensuring the
continued protectiveness of the Site.

N

Y

Institutional Controls and deed restrictions are outlined in
the CD, however their implementation is uncertain and
needs review.

N

Y

Long-term stewardship of the Site must be ensured.

N

Y

15


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IX. Recommendations and Follow-up Actions

Issue

Recommendations and
Follow-up Actions

Party
Responsible

Oversight
Agency

Milestone
Date

Affects
Protectiveness
(Y/N)

Current

Future

South wall of
Phase II

Investigate the apparent
hydraulic connection
between GH78 and GH79
and ensure that an inward
hydraulic gradient is

maintained.

PRP

State/EPA

9/30/07

N

Y

SW corner of
Phase II

Evaluate the effects of the
discontinuity in the slurry
wall in the southwest
corner. Plan to extend the
slurry wall once the water
main is abandoned and/or
evaluate the potential of
additional extraction wells
to contain the landfill
contents.

PRP

State/EPA

9/30/07

N

Y

Mounding at
GW7

Determine the cause of the
mounding at GW7.

PRP

State/EPA

6/30/07

N

Y

Toe of Phase
III

Develop a plan to evaluate
the effectiveness and
maintain flow in the
leachate collection system
at the toe of Phase III.

PRP

State/EPA

6/30/07

N

Y

Monitoring
and

Reporting

Reevaluate the monitoring
well network and the list of
analytical parameters.
Develop a system for
regular electronic data
submission.

PRP

State/EPA

3/30/07

N

Y

Institutional
controls

An IC plan will be
completed within six
months of the date of this
Five-Year Review Report.

PRP

State/EPA

3/30/07

N

Y

Long-term
stewardship

Develop an IC Action
Plan1

EPA

EPA

3/30/07

N

Y

1 The IC Plan will include provisions for a) completing an IC study to evaluate whether effective ICs have been
implemented; b) implementing corrective measures; c) developing IC maps; and ensuring that effective
procedures are in place for long-term stewardship. These procedures should include regular inspections of ICs at
the Site and certifications to EPA that ICs are in-place and effective, along with exploring the development of a
communications plan and exploring the use of the state's one-call system.

16


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The FYR has brought to light two additional issues that do not affect the protectiveness of the
Site, but that require attention, nonetheless.

Changes in the monitoring well network call into question the adequacy of the current site
survey. EPA recommends that the PRPs re-survey the site.

The Site currently lacks protocols for ensuring monitoring and extraction well integrity. EPA
recommends that the PRPs amend the O&M Plan to include a quality assurance process for
determining when a well needs rehabilitation and/or replacement

X.	Protectiveness Statements

Short-term Protectiveness The remedy is currently protective of human health and the
environment in the short term. The landfill cover, groundwater extraction and treatment system,
and access controls are functioning as designed, and have achieved the remedial objectives,
which include minimizing the migration of contaminants to groundwater and surface water and
preventing direct contact with contaminants at the Site.

Long-term Protectiveness Long-term protectiveness of the remedy is dependent upon the
continued effectiveness of the groundwater extraction and treatment system in maintaining an2
inward hydraulic gradient and removing contaminants from the Site. Monitoring of the
groundwater and surface water will continue until the performance of the remedy can be
demonstrated by the attainment of groundwater cleanup standards. Long term protectiveness is
dependent upon the implementation of the institutional controls listed in the Consent Decree, and
will be subject to an institutional controls study and IC Plan to ensure they are adequately
implemented, maintained, and monitored.

XI.	Next Review

The next five-year review for the G&H Landfill Site will be conducted in 2011, and that report
will be due five years from the signature of this report.

Attachments

1.	Site Index Map

2.	Site and Surroundings

3.	Site Areas

4.	Summary of Groundwater Sampling Results

5.	Federal Applicable or Relevant and Appropriate Requirements (ARARs)

6.	State Applicable or Relevant and Appropriate Requirements (ARARs)

7.	IC Map

8.	Deed Restrictions

17


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ATTACHMENTS


-------
Attachment 1 Site Map


-------
Attachment 2 Map of G & H Landfill
Superfund Site and Surroundings

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-------
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Attachment 5

Federal ARARs

The major ARARs that will be addressed and met by the selected remedy and whether the
ARARs are listed as follows:

Executive Order 11988 and 11990; 40 CFR 6, Subpart A which requires that remedial actions
must avoid adverse affects to floodplain or wetlands and evaluate potential impacts to these
areas.

The Clean Air Act and 40 CFR 50 and 52 which require that select types and quantities of air
emissions be in compliance with regional air pollution control programs; approved State
Implementation Plans and other appropriate federal air criteria.

40 CFR 141 which requires that ground water used as drinking water meet maximum
contaminant levels (MCLs) for pollutants of concern.

40 CFR 144 and 146 well plugging and abandonment and other requirements for the injection of
treated ground water under the Underground Injection Control Program.

40 CFR 268 Land Disposal Restrictions for the handling, treatment, and placement of hazardous
wastes.

49 CFR 107 requirements for transporting hazardous materials off-site.

40 CFR 761 TSCA regulations for the treatment, storage, and handling of PCBs.


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Attachment 6

State ARARs

Act 60 of 1976 (PCB Compounds) which prohibits the disposal of waste containing a
concentration equal or greater than 100 ppm of PCB s.

Act 64 of 1979 (The Hazardous Waste Management Act) which regulates the treatment,
transport and disposal of hazardous wastes from site restoration.

Act 98 of 1913 (The Waterworks and Sewerage Systems Act) which are rules for construction
and operation of sewerage systems, as applicable for discharge of ground water via new
sewer connection and certification of the operator.

Act 127 of 1970 (The Michigan Environmental Protection Act) which prohibits any action which
pollutes, impairs, or destroys the State's natural resources, due to any remedial action at the site.

Act 203 of 1979 (The Goemare-Anderson Wetland Protection Act) which regulates discharges to
wetlands.

Act 245 of 1929 (The Water Resources Commission Act), as amended, which establishes surface
water-quality standards to protect human health and the environment. The State administers the
NPDES program under Part 21 of Michigan Act 245; therefore, Part 21 of Act 245 would be
applicable to the direct discharge of treated water to the Clinton River or to a clean aquifer, to
the indirect discharge through groundwater movement to a surface water body, or to discharge to
a POTW.

Act 307 of 1990 (The Michigan Environmental Response Act) which provides for response
activity to eliminate environmental contamination as sites containing hazardous
substances and establishes cleanup standards.

Act 315 of 1969 (The Mineral Well Act) which establishes requirements for monitoring wells at
the site.

Act 346 of 1972 (The Inland Taking and Streams Act), as amended, which regulates inland lakes
and streams in the State.

Act 347 of 1972 (The Soil Erosion and Sedimentation control Act) which requires a soil erosion
control measures at the site consistent with locally approved soil sedimentation and
erosion control plans or rules.

Act 348 of 1965 (The Air Pollution Act) which requires air emissions to have 'non-injurious
effects."

Act 641 of 1978 (The Solid Waste Management Act) which establishes provisions governing the
regulation and management of solid waste.

Public Health Code Act 368 which establishes the procedures for well abandonment.


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Institutional Control (IC) Review

Required Institutional Controls

G&H Landfill
Macomb County, M

Superfurd

U.S. Environmental Protection Agency



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Attachment


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Attachment 8

DEED RESTRICTIONS ON G & H LANDFILL SITE

The Estate of Leonard Forster, owner in fee simple of the real estate described below, hereby
imposes restrictions on the described real estate, also known as the G & H Industrial Landfill
Site (hereafter "the Site") in Shelby Township, Macomb County, State of Michigan:

Beginning at Northeast corner Section 19, Town 3 North, Range 12 East, thence South 993.3
feet; thence South 89 degrees 55 minutes West 792 feet; thence South 220 feet; thence North 89
degrees 55 minutes East 396 feet; thence South 412.23 feet to R/W Michigan Central Railroad;
thence Northwesterly along Railroad to South line of North V2 of North V2; thence West along 1/8
line to center line of Clinton River thence Northwesterly along River to North line of Section;
thence East along Section line to point of beginning; except Michigan Central Railroad R/W.
Subject to a 12 foot watermain easement, the center line description as, beginning at a point
South 40 feet and West 30 feet from Northeast comer Section 19, thence West 1370 feet to the
point ending, along with a 20 foot watermain easement, the center line description as beginning
1370 feet West of Northeast corner Section 19; thence South 34 feet to point of ending.

The restrictions enumerated herein also apply to the specific portion of the Site known as the
Auto Disposal Yard, or Junkyard, bordered immediately to the northeast by the intersection of
23-Mile Road and Ryan in Shelby Township, Macomb County, Michigan. The legal description
of the Auto Disposal Yard is:

Beginning at the N.E. Corner of Section 19, T.3N., R.12E., Shelby Township, Macomb County,
Michigan; thence Due South 993.30 feet along the East line of Section 19 and the centerline of
Ryan Road; thence S.89°55'00"W., 400.00 feet; thence Due North, 990.51 feet to a point on the
North line of Section 19; thence N.89°3r01"E., 400.01 feet along the North line of Section 19
and the centerline of 23 Mile Road to the Point of Beginning and containing 9.11 acres.

The following restrictions are imposed upon the Site, its present and any future owners
(including the hairs to the Estate) their authorized agents, assigns, employees or persons acting
under their direction or control, for the purposes of protecting public health or welfare and the
environment, preventing interference with the performance, and the maintenance, of any
response actions selected and/or undertaken by the United States Environmental Protection
Agency ("U. S. EPA"), or any party acting as agent for U.S. EPA, pursuant to Section 104 of the
Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA").
Specifically, the following deed restrictions shall apply to the Site as provided for in paragraph
nine (9) of the Consent Decree:

1.	There shall be no consumptive or other use of the groundwater underlying the Site that could
cause exposure of humans or animals to the groundwater underlying the Site;

2.	There shall be no residential, commercial, or agricultural use of the Forster property
considered part of the Site, including, but not limited to, any filling, grading, excavating,
building, drilling, mining, farming, or other development, or placing of waste material at any
portion of the Site, including, but not limited to, the Auto Disposal Yard as described above,
for any purpose, including residential, commercial, or agricultural purposes, except as


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approved in writing, by U.S. EPA;

3.	There shall be no use of the Site that would allow the continued presence of humans at the
Site, other than the presence necessary for implementation of any response actions selected
and/or undertaken by U.S. EPA pursuant to Section 104 of CERCLA, including such
response actions taken by other responsible parties under a judicial or administrative order. A
prohibited use of the Site includes, but is not limited to, recreational use;

4.	There shall be no installation, removal, construction or use of any buildings, wells, pipes,
roads, ditches or any other structures or materials at the Site except as approved, in writing,
by U.S. EPA, and in consultation with the State of Michigan;

5.	There shall be no tampering with, or-removal of, the containment or monitoring systems that
remain on the Site as a result of implementation of any response action by U.S. EPA, or any
party acting as agent for U.S. EPA, and which is selected and/or undertaken by U.S. EPA
pursuant to Section 104 of CERCLA; and

6.	There shall be no use of, or activity at, the Site that may interfere with, damage, or otherwise
impair the effectiveness of any response action (or any component thereof) selected and/or
undertaken by U.S. EPA, or any party acting as agent for U.S. EPA, pursuant to Section 104
of CERCLA, except with the written approval of U.S. EPA, in consultation with the State of
Michigan, and consistent with all statutory and regulatory requirements.

The obligation to implement and maintain the above restrictions shall run with the land and shall

remain in effect until such time as U.S. EPA files with the Court a written certification stating:

1.	The response action required at, under or adjacent to the Site by any Consent Decree or
judicial or administrative order, entered pursuant to CERCLA, has been fully implemented;

2.	No other response actions are planned for the Site; and

3.	The above restrictions are no longer necessary to meet the purposes of this Decree.


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