SIXTH FIVE-YEAR REVIEW REPORT FOR
BOFORS NOBEL, INC. SUPERFUND SITE
MUSKEGON COUNTY, MICHIGAN
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Prepared by
U.S. Environmental Protection Agency
Region 5
Chicago, Illinois
9/28/2023
X Douglas Ballotti
Douglas Ballotti, Director
Superfund & Emergency Management Division
Signed by: DOUGLAS BALLOTTI
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Table of Contents
LIST 01 ABBREVIATIONS & ACRONYMS 3
I. INTRODUCTION 5
FIVE-YEAR REVIEW SUMMARY FORM 6
II. RESPONSE ACTION SUMMARY 6
Basis for Taking Action 6
Response Actions 7
Status of Implementation 8
Institutional Controls 9
Systems Operations/Operation & Maintenance 11
III. PROGRESS SINCE THE LAST REVIEW 13
IV. FIVE-YEAR REVIEW PROCESS 16
Community Notification, Involvement & Site Interviews 16
Data Review 16
Site Inspection 18
V. TECHNICAL ASSESSMENT 18
QUESTION A: Is the remedy functioning as intended by the decision documents? 18
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? 20
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 22
VI. ISSUES/RECOMMENDATIONS 22
OTHER FINDINGS 24
VII. PROTECTIVENESS STATEMENT 25
VIII. NEXT REVIEW 25
APPENDIX A - REFERENCE LIST 26
APPENDIX B - FIGURES AND TABLES
APPENDIX C - SITE INSPECTION
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LIST OF ABBREVIATIONS & ACRONYMS
ARAR
Applicable or Relevant and Appropriate Requirement
Black Creek
Referred in past documents as Big Black Creek
CD
Consent Decree
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
COC
Contaminant of Concern
CRA
Contingent Remedial Action
DCB
3,3 -di chl orob enzidi ne
EGLE
Michigan Department of Environment, Great Lakes, and Energy
EPA
United States Environmental Protection Agency
FAVs
Final Acute Values
FCVs
Final Chronic Values
FFS
Focused Feasibility Study
FYR
Five-Year Review
gpm
Gallons per minute
GSI
Groundwater/Surface Water Interface
GWES
Groundwater Extraction System
GWTP
Groundwater Treatment Plant
ICs
Institutional Controls
ICIAP
Institutional Controls Implementation and Assurance Plan
IDW
industrial drinking water
IMP
Interim Monitoring Plan
IRAP
Interim Remedial Action Plan
LTS
Long-term Stewardship
MBA
Meander Bend Area of Black Creek
MCRRC
Muskegon County Resource Recovery Center
MDEQ
Michigan Department of Environmental Quality, currently known as EGLE
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
ng/L
Nanograms per liter
NPL
National Priorities List
NRRB
National Remedy Review Board
O&M
Operation and Maintenance
OU
Operable Unit
PFAS
polyfluoroalkyl substances
PFOS
perfluorooctanesulfonic acid
6-PPD
6P-phenylenediamine
PRP
Potentially Responsible Party
PSDs
Performing Settling Defendants
RAO
Remedial Action Objective
RD/RA
Remedial Design/Remedial Action
RI/FS
Remedial Investigation/Feasibility Study
ROD
Record of Decision
RPM
Remedial Project Manager
SAP
Sampling and Analysis Plan
Site
Bofors Nobel, Inc. Superfund Site
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SRD Substantive Requirements Document
SRI Supplemental RI
TBC To be considered
TIC Total In-Situ Containment
US ACE United States Army Corps of Engineers
UU/UE Unlimited Use and Unrestricted Exposure
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a
remedy to determine if the remedy is and will continue to be protective of human health and the
environment. The methods, findings, and conclusions of reviews are documented in FYR reports such as
this one. In addition, FYR reports identify issues found during the review, if any, and document
recommendations to address them.
The United States Environmental Protection Agency (EPA), after consultation with the Michigan
Department of Environment, Great Lakes, and Energy (EGLE), is preparing this FYR pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121,
consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)(40 CFR
Section 300.430(f)(4)(ii)), and considering EPA policy.
This is the sixth FYR for the Bofors Nobel, Inc. Superfund Site (Site). The triggering action for this
statutory review is the July 23, 2018, completion date of the previous FYR. The FYR has been prepared
because hazardous substances, pollutants, or contaminants remain at the site above levels that allow for
unlimited use and unrestricted exposure (UU/UE).
The Site consists of two operable units (OUs) (See Figure 1 in Appendix B), one of which OU1, will be
addressed in this FYR. OU1 addresses soil and waste disposal units on the southern half of the Site
(approximately 46 acres), and sitewide groundwater. Major features found in the OU1 footprint are 10
unlined, soil-covered lagoons (formerly used for chemical manufacturing waste disposal), and a
groundwater remedy system that includes a barrier wall, a treatment wetland, and several extraction
wells. OU2, which includes the 39-acre former operating plant area located on the northern part of the
Site, is not addressed in this FYR because OU2 does not have a Record of Decision (ROD). However,
OU2 has an Interim Remedial Action Plan (IRAP) that mitigates exposures, pending development of an
OU2 ROD (Appendix A, Document #2). Therefore, the current conditions at OU2 are briefly discussed
herein.
The Bofors Nobel, Inc. Superfund Site FYR was led by Daniel Rodriguez, Remedial Project Manager
(RPM) for EPA. Participants included Jeffrey Thomas, former EPA RPM for the Site; Amy Gahala,
hydrogeologist for EPA; Caitlin Mclntyre, Community Involvement Coordinator for EPA; Mark
Reimann, Project Manager for EGLE; and Charles Graff, Geologist for EGLE. The Performing Settling
Defendants (PSDs), a group of potentially responsible parties (PRPs) who are implementing the OU1
remedy, were notified of the initiation of the FYR. The review began on August 22, 2022.
Site Background
The Site is an 85-acre site comprised of a former specialty chemical production facility, that has been
closed and its buildings demolished. The Site also contains an associated waste disposal area, and an on-
site groundwater treatment plant (GWTP). Throughout the 1960s and mid-1970s, ten on-site unlined
lagoons were used for disposal of sludge, wastewater, and various waste liquids generated by specialty
chemical production. This practice resulted in contamination of soil, the groundwater underneath the
Site, and subsequently Black Creek. The Site was placed on the National Priorities List (NPL) in 1989.
The Site is located east of Muskegon, MI (see Figures 2 and 3 in Appendix B). The Site and surrounding
area are currently zoned as industrial, with no land use changes anticipated. The northern portion of the
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Site is currently owned by the Sun Chemical Corporation, which operates an active Sun Chemical plant
immediately to the west of the Site. Black Creek runs through the southern portion of the Site. Most of
the remaining area surrounding the Site is undeveloped forest, with some industrial and commercial
facilities interspersed. Residential areas nearby are semi-rural with approximately 500 residents in a one-
mile radius of the Site. Residences in the immediate area of the Site are connected to the local public
water system and groundwater near the Site is not used as potable water.
FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name: Bofors Nobel, Inc.
EPA ID: MID006030373
Region: 5
State: MI
City/County: Muskegon, Muskegon County
SITE STATUS
NPL Status: Final
Multiple OUs?
Yes
Has the site achieved construction completion?
No
Lead agency: EPA
[If "Other Federal Agency", enter Agency name]'.
Author name (Federal or State Project Manager): Daniel Rodriguez
Author affiliation: EPA
Review period: 8/22/2022 - 6/6/2023
Date of site inspection: 12/2/2022
Type of review: Statutory
Review number: 6
Triggering action date: 7/23/2018
Due date (five years after triggering action date): 7/23/2023
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
In 1989, a risk assessment was completed and identified human health hazards posed by current as well
as potential future exposures to Site-related contamination (Appendix A, Document #1). The
contaminants that are the main concern and driving the Site's remedy include: azobenzene, benzidine,
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3,3-dichlorobenzidine (DCB), toluene, aniline, and vinyl chloride. The highest excess cancer risks
developed were associated with the groundwater potential exposure pathway. Groundwater ingestion
risk cited in the 1990 ROD ranged from 9.9 x 10 -1 to 3.4 x 10 -5 (Appendix A, Document #2). Risk
associated with ingestion of and/or contact with surface water cited in the 1990 ROD ranged from 1x10
-2 to 3.4 x 10 -7, depending upon exposure to contaminated groundwater that discharged to Black
Creek. Risk associated with surface water pathways are being addressed in the 1999 ROD Amendment
by the requirement for compliance with State of Michigan GSI cleanup criteria (Appendix A, Document
#6). There were also unacceptable risks from potential soil and air exposures. Table B-3 in Appendix B
is taken from the 1990 ROD and subsequent amendments, and lists risks for potential future residential
exposure. There were numerous contaminants of concern (COCs) identified in the 1999 ROD
Amendment, as follows: Table B-l in Appendix B lists site COCs in groundwater and Table B-2 in
Appendix B lists site COCs in sludge and soil.
Response Actions
QUI: In 1976, because of enforcement action taken by the State of Michigan, extraction wells were
installed to capture and contain contaminated groundwater before it reached Black Creek. This system
of extraction wells has been upgraded and modified and has continued in operation since 1976.
In 1985 Bofors Nobel, Inc. filed for bankruptcy and in 1987, Lomac Inc. purchased the operating plant
area (OU2) out of bankruptcy. Proceeds of this sale and other Bofors Nobel, Inc. assets were paid to the
United States (who placed this resource into a Special Account) and Michigan, who used the money for
Site response actions including continued groundwater extraction and treatment, as well as control of
Site access and security.
On September 17, 1990, EPA signed a ROD for the OU1 selected remedy. On July 22, 1992, EPA
issued a ROD Amendment amending the selected remedy from the 1990 ROD for the first time
(Appendix A, Document #4). On April 30, 1996, EPA issued an Explanation of Significant Differences
(ESD) modifying just the groundwater treatment portion of the OU1 remedy (Appendix A, Document
#6). On July 16, 1999, EPA issued a second ROD Amendment to amend the selected remedy for OU1.
The major components of the selected remedy from the 1990 ROD, 1992 ROD Amendment, 1996 ESD,
and 1999 ROD Amendment that are still applicable to the Site currently include:
• a b el ow grade b arri er wal 1;
• a soil cover over contaminated soil and sludge;
• installation of vegetative species;
• containment and collection of contaminated groundwater using the barrier wall and extraction
wells;
• a treatment wetland;
• treatment of extracted groundwater at the GWTP;
• monitoring containment effectiveness; institutional controls (ICs); long-term operation and
maintenance (O&M); and
• Contingent Remedial Actions, if needed (see Figure 4 in Appendix B).
The Remedial Action Objectives (RAOs) listed in the 1999 ROD Amendment are:
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1. Containment of lagoon sludge and soils to prevent on-site exposure to hazardous
substances at concentrations that pose an unacceptable risk to human receptors under
industrial land use scenarios via the following routes of exposure: (a) direct contact; (b)
inhalation from volatilization to indoor air; (c) inhalation from volatilization to ambient
air; (d) drinking water use of aquifer; (e) groundwater contact; and (f) surface water
contact. Containment of lagoon sludge and soils to prevent on-site exposure to hazardous
substances at concentrations that pose an unacceptable risk to environmental receptors
via the following routes of exposure and migration pathways: (a) contact with
contaminants present in surface soils, plants, water, or air on-site; (b) groundwater
impacts on surface water; and (c) soil runoff impacts on surface water.
2. Containment of lagoon sludge and soils to prevent off-site migration of contaminants
to air, soil or groundwater at concentrations that would pose an unacceptable risk to
human and/or environmental receptors; and
3. Containment of groundwater to prevent migration of contaminants at concentrations
that would pose an unacceptable risk to human and/or environmental receptors off-site
including to Black Creek and to the on-site wetlands between Black Creek and the barrier
wall.
OU2: The former operating facility is now owned by Sun Chemical and is to be addressed as OU2.
However, the 1999 OU1 ROD Amendment addressed OU2 as follows:
To address soils contamination within O. U. #2, Lomac will submit an Interim Remedial Action
Plan to the MDEQ (now EGLE) for the plant area soils during Lomac's continued operations.
The Interim Remedial Action Plan will be reviewed and approved by the MDEQ in consultation
with the U.S. EPA. The U.S. EPA will issue a final O. U. #2 ROD to address a final cleanup
action to be implemented at the time when manufacturing in the plant area ceases.
Table B-l in Appendix B lists site COCs in groundwater and the groundwater cleanup criteria
(performance standards) and Table B-2 in Appendix B lists site COCs in sludge and soil and soil
cleanup criteria (performance standards).
Status of Implementation
QUI: In 1990, EPA and EGLE had the United States Army Corps of Engineers (US ACE) begin design
of the groundwater pump and treat remedies. US ACE completed the GWTP design and started its
construction in 1992. The GWTP commenced operation in 1994. Design of the landfill remedy was
completed by US ACE in 1993, however construction was not completed because of new information
about barrier wall performance brought to the attention of EPA and the State by the PSDs. The remedy
was modified to replace excavation and disposal of contaminated source areas in on-site cells with cover
and barrier wall containment of the source areas. In 2000, the PSDs and Lomac assumed responsibility
for O&M of the GWTP and control of Site access. Sun Chemical took over these obligations when it
purchased the Site in 2002. EPA entered into a Consent Decree (CD) with the PSDs for implementation
of a Remedial Design and Remedial Action (RD/RA) that included a Total In-Situ Containment (TIC)
Remedy, which was expected to provide protection that is similar to the landfill remedy. Physical
construction of the barrier wall was completed in late 2005 and installation of the other elements of the
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TIC remedy was completed in late 2007. Ongoing operation of the TIC remedy is discussed below in the
sub-section on Systems Operations/Operation and Maintenance.
OU2: An explosion in April 2000 (after the 1990 RI/FS was completed by EGLE) at the Lomac facility
contributed to the cessation of production operations in the OU2 area. In late 2002, Sun Chemical
purchased the property and did not re-start production. EPA has not yet issued a ROD for OU2. In the
meantime, and as required by the 1999 OU1 ROD Amendment and the associated RD/RA CD, an IRAP
was developed (June 1999) to provide an interim remedy for the OU2 soils contamination area near the
former building # 12 where DCB was manufactured. The PSDs and the State of Michigan entered into a
CD for the IRAP. The OU2 IRAP required asphalt cover of areas of contaminated surface soil to prevent
human exposure and continued limited sampling and analysis of groundwater within the OU2 area to
ensure consistency with the work being performed for OU1. IRAP work was completed by June 2000.
Additional safety procedures and restrictions on operations and activity in the OU2 area were
implemented for the IRAP. Limited groundwater sampling and inspection of covered OU2 areas are still
performed annually under IRAP requirements.
Because conditions in OU2 may have changed since the 1990 RI/FS, EPA initiated a Supplemental RI
(SRI) and Focused Feasibility Study (FFS). The purpose of the SRI was to investigate and characterize
the nature and extent of contamination and potential risks to human health and the environment posed by
chemicals of potential concern at OU2 of the Site. The SRI field activities were conducted in two
phases. Phase 1 SRI field activities were completed from May through August 2012. The Phase 2 SRI
field activities were completed from August through October 2014. Both phases included additional soil
and groundwater assessments in the former production area. The Final SRI Report was issued in April
2016 (Appendix A, Document #9). The FFS is still underway.
In September 2015, Sun Chemical voluntarily demolished the former operating plant buildings, process
vessels, above-ground storage tanks, and other aboveground features (i.e., piping runs and containment
walls), and relocated parked truck tankers/trailers at OU2. Several raised concrete slabs that comprised
building floors remain intact and prevent direct contact with underlying contaminated soil and isolates
remainders of product piping/distribution lines, identified as potential source areas. The tops of the
concrete slab floors are situated approximately 3 to 4 feet above ground surface. Sun Chemical
compacted clean clay fill around each raised concrete floor slab that remained following demolition as
an added measure for IRAP compliance and to provide a control for potential fall hazards as site
personnel continue to work in OU2.
On January 2023 EGLE requested additional characterization of OU2. EGLE requested to extend the
soil investigation underneath the former buildings and surrounding areas where access was not available
because of the existing structures. The Agencies have recently re-initiated discussion to address EGLE's
additional sampling request. Also, OU2 was nominated to EPA's National Remedy Review Board
(NRRB) to assist with the completion of the SRI and FFS.
Institutional Controls
Table 1 below provides a summary of implemented ICs for the Site.
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Table 1: Summary of Implemented ICs
Mcdi;i. engineered
controls. iiml iiiviis
lliiil do mil support
I 1 /I 1. h.iscd on
ciiitciH conditions
ICs
Veiled
ICs C;il led
lor in llie
Decision
Documents
lmp;iclcd
P;ircel(s)
IC
()h.jecli\e
TillcoNC
Instrument
Implcmcnlcd iind
Diilc (or pliinned)
Former Waste Lagoon area.
Soil cover, site fencing, and
posted warnings
Yes
Yes
OU1
ICs to prohibit interfering
with remedy components,
including components that
ensure prevention of
contact with contaminated
soil and sludge and
associated emissions and
prohibition of any
activities that may impair
the integrity or
effectiveness of the
remedy.
"Declaration of
Restrictive
Covenant and
Grant of
Environmental
Protection
Easement",
recorded on May 4,
2012.
Covered and below-grade
chemical sludge and
contaminated soil.
Yes
Yes
OU1
ICs to prohibit the use of
and unacceptable exposure
to contaminated
groundwater or soil.
Same
Below grade barrier wall
and exterior extraction wells
to contain and direct
contaminated groundwater;
and associated piping,
pumping and treatment
systems.
Yes
Yes
OU1
ICs to prohibit interfering
with remedy components,
including components of
the barrier wall and the
extraction and treatment
systems for contaminated
groundwater and
prohibition of any
activities that may impair
the integrity or
effectiveness of the
remedy.
Same
Contaminated groundwater
sitewide.
Yes
Yes
Sitewide
ICs to prohibit the use of
and unacceptable exposure
to contaminated
groundwater or soil.
Same
The 0U1 1990 ROD, as well as the 1992 and 1999 ROD Amendments require implementation of
deed/access restrictions and/or other ICs to control future development of the Site, assure the
integrity of the remedial action, and carry out land and groundwater use restrictions, as summarized
above. A map showing the area in which the ICs apply is included as Figure 4 in Appendix B.
Status of Access Restrictions and ICs: As noted in Table 1, the IC in the form of a Declaration of
Restrictive Covenant and Grant of Environmental Protection Easement for the Bofors Nobel
property was recorded on May 4, 2012. The PSDs conducted a title search in 2022 and submitted
by email on March 13, 2023, documentation showing that this IC was recorded on May 4, 2012, as
Liber 3912 Page 942, in the Office of the Register of Deeds and remains on the title (see Appendix
A, document # 8). The Restrictive Covenant put in place by the PSDs pursuant to the CD is still
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effective. The only subsequent activities on the title are two commercial liens placed on the Site by
the State that are not believed to affect the ICs; however, EPA will continue to review the liens to
ensure they do not affect future cleanup, particularly with respect to OU2.
On June 8, 2018, the PSDs submitted an Institutional Control Implementation and Assurance Plan
(ICIAP) (Appendix A, Document #12). The ICIAP addresses the ICs in accordance with the 1999 OU1
ROD, as referenced in the CD. EPA is the lead Agency responsible for oversight of the RD/RA,
including ICs, for the Site. EGLE is the state agency involved at the Site on behalf of the State of
Michigan. The PSDs are to implement the procedures documented in the ICIAP to ensure that effective
ICs are in place and are properly maintained, monitored, and enforced. The ICIAP includes Long Term
Stewardship (LTS) components, including mechanisms and procedures for inspecting and monitoring
compliance with the ICs. Therefore, the site ICs are regularly inspected and monitored to ensure no
inconsistent uses have occurred, that ICs remain in place and are effective, and that any necessary
contingency actions have been executed.
Current Compliance: The ICs are currently in place and effective, and the Site is in compliance
with the IC requirements. Additionally, the December 2, 2022 FYR Site inspection confirmed that
access restrictions are intact, and signage is appropriately displayed on all access gates.
Systems Operations/Operation & Maintenance
QUI: The Long-Term Management Plan for OU1 was submitted on June 12, 2018, and approved
by EPA on August 8, 2018 (Appendix A, Document #13). O&M of the TIC Remedy in OU1 is the
responsibility of the PSDs, who have agreed pursuant to the OU1 CD to a long-term commitment
ensuring O&M continues as long as necessary until all performance standards are met and
maintained. EPA and EGLE will also continue to monitor the Site's activities to make sure that
RD/RA CD requirements are being satisfied.
The protective soil cover, vegetative components, and treatment wetland must be monitored, and
maintained, as needed. The PSDs routinely perform the following for those components of the TIC
Remedy:
• regular inspections and upkeep, as needed, of the OU1 lagoon area cover to assure the
continued protectiveness of the cover and to prevent disturbance and exposure to
contaminated soil and waste remaining beneath the cover;
• upkeep, monitoring, and routine inspection of the vegetative portion of the TIC
Remedy, including introduction of nutrients and irrigation and/or removal or
replacement of vegetation, as needed;
• inspection and maintenance, as needed, of the Site fencing; and
• maintenance of Site drainage and roadways.
The groundwater containment components of the remedy require routine O&M. As the barrier wall
is a below grade containment structure, there is minimal maintenance required for that remedy
component. Extraction wells exterior to the barrier wall continue to operate and serve to capture
groundwater between the barrier wall and Black Creek.
Originally, treated water from the GWTP was sent to either Sun Chemical or the Muskegon County
Resource Recovery Center (MCRRC, wastewater treatment facility). As of 2022, Sun Chemical is
no longer using the treated groundwater, and all treated groundwater is being sent to the MCRRC.
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In addition to operating the extraction and treatment processes, O&M tasks for the GWTP and
currently operating extraction wells and groundwater collection system include:
• procurement of utilities such as gas, water, communications, and electricity;
• upkeep of extraction system components installed to augment groundwater
containment provided by the barrier wall, including extraction well cleaning,
rehabilitation, and preventive maintenance and/or re-development of wells as needed;
• upkeep of the weir and pumping at the treatment wetland;
• continued groundwater sampling and analysis;
• general repair, maintenance, and minor improvements to the system(s) and GWTP; and
• repair and upgrade of groundwater collection piping and valving, emission control
equipment, residuals handling equipment, monitoring wells, and extraction well
vaults and associated equipment.
There were a few system modifications since the last FYR. As discussed in the Protectiveness
Statement and Issue 1 from the 2018 FYR, there were concerns that the groundwater extraction
wells between the barrier wall and Black Creek were not demonstrating consistent groundwater
capture. In March 2020, the Groundwater Extraction System (GWES) in the Meander Bend
Area (MBA) was modified. Six shallow groundwater extraction wells (EW-1 through EW-6)
were added. Also, the pumping rate was increased in the GWES wells subsequent to their initial
operation. Four additional piezometers (PT-8 through PT-11) located between the shallow
extraction wells were also added to supplement existing hydraulic capture monitoring points.
Since the fifth FYR groundwater and surface water sampling frequency was changed from quarterly to
bi-annual, in accordance with the Revised Technical Memorandum, Interim Monitoring Program (IMP)
for Operable Unit 1 of the Bofors Nobel Superfund Site, dated November 2, 2020 (Appendix A,
Document #21). Semi-annual groundwater and surface water sampling has been conducted by the PSDs
in accordance with Quality Assurance Project Plan (QAPP) Revision 3, dated March 2019 (Appendix A,
Document #18). Currently, Revision 4 of the QAPP is under review. In total, chemical samples are taken
from 25 groundwater monitoring wells and the treatment wetland outlet (WT-1). Monitoring is
performed semi-annual (April & September) for monitoring wells indicative of groundwater-surface
water interaction in the MBA and of the treatment wetland effluent, and annually (September) of
peripheral wells screened at multiple intervals (see Table B-4 and Figure 5 in Appendix B).
The GWTP was also modified to return the backwash water to the treatment wetland. The
primary processes at the GWTP consist of gravity filters and granular activated carbon units.
Both processes require daily backwashing to maintain their effectiveness and the labor and
equipment required to manage the resulting backwash flows and associated solids represent a
large proportion of the overall effort to run the GWTP. A large clarifier, a sludge thickener, and
multiple pumps are required and generate around 30 cubic yards per year of non-hazardous
solids that are disposed off-site. These solids are part of the flow from the treatment wetland that
is necessary to manage water levels within the barrier wall. To improve the operational
efficiency and reduce the energy used by the GWTP, the PSDs modified the backwash flows by
recycling them to treatment wetland, thereby returning the solids to their source within the
barrier wall, rather than sending them off-site for disposal.
OU2: The annual inspection of asphalt cover over contaminated soil areas occurs under the
requirements of the IRAP, approved and overseen by EGLE. During the FYR site inspection,
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conducted on December 2, 2022, it was observed that the asphalt cover is in good condition. Sun
Chemical's current storage activities within OU2 pose no threat of interference with the work
completed for the IRAP. Groundwater used for the supply of hygienic water is sampled as part of
the IRAP. No exceedances of Michigan Generic Industrial Health Based Drinking Water or
Michigan Drinking Water Standards have been detected. Land use in OU2 by Sun Chemical
presents no threat of causing any unacceptable exposure pathways. EPA has not yet issued a
remedy decision for OU2; therefore, there are no formal review requirements or remedy O&M
considerations for this portion of the Site.
III. PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last FYR as well
as the recommendations from the last FYR and the current status of those recommendations.
Table 2: Protectiveness Determinations/Statements from the 2018 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
1
Short-term
Protective
The remedy at OU1 of the Bofors Nobel, Inc. Site is currently protective of
human health and the environment. Exposure pathways that could result in
unacceptable risks are being controlled. No one is drinking groundwater.
Unacceptable levels of contamination have not been observed in surface water.
There is no direct contact with the covered waste and contaminated soil, and the
soil cover is undamaged. ICs and access restrictions are in place and effective.
Continued monitoring and O&M of the Site will help confirm protectiveness.
The containment RAOs are generally being met. However, in order for the
remedy to be protective in the long term, the following actions need to be taken
to ensure protectiveness: design, implement, and monitor a Contingent Remedial
Action (CRA) generally proposed in the OU1 Long-Term Site Management
Plan which was submitted on June 12, 2018 that will include modifications to
groundwater extraction in the MBA to achieve complete containment; and once
developed and approved, implement the Performance Standards Verification
Plan for the TIC Remedy.
Table 3: Status of Recommendations from the 2018 FYR
OU
#
Issue
Recommendations
Current
Status
Current
Implementation
Status Description
Completion
Date (if
applicable)
1
1. The containment effectiveness
of the groundwater extraction
wells outside the barrier wall
must be consistent and
confirmed.
Design, implement, and
monitor a CRA generally
proposed in the PSDs'
OU1 Long-Term Site
Management Plan that will
include modifications to
groundwater extraction in
the MBA to achieve
complete containment.
Completed
See below.
4/1/2022
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1
2. A plan is needed for long-
Once the newly proposed
Addressed
A Performance
term Site monitoring.
CRA identified in
in Next
Standards
Recommendation # 1 is
implemented and evaluated,
develop and implement a
Performance Standards
Verification Plan for the
OU1 TIC Remedy.
Review
Verification
Plan was
submitted to the
Agencies in
August 2023
and is under
review.
Recommendation #1: The PSDs in an effort to address Recommendation #1 submitted various
documents (See documents #15, 17, 19, 21, and 23 in the Reference List, Appendix A). These
documents presented the MBA extraction wells design, testing, and capture monitoring program. The
results of the evaluation of the MBA GWES, led to six shallow groundwater extraction wells being
added to the GWES (EW-1 through EW-6) and the pumping rate being modified for the purpose of
attaining complete containment (see Table 4 below). Four additional piezometers (PT-8 through PT-11)
located between the shallow extraction wells were also added to supplement existing hydraulic capture
monitoring points.
Table 4: GWES Wells and Pumping Rates
Pumping
Rate
Shallow Wells (GPM)
Deep Wells (GPM)
Total
(GPM)
Dates
EW-1
EW-2
EW-3
EW-4
EW-5
EW-6
PW-46
PW-43
PW-47
Nov. 1 -
May 31
5.0
5.0
5.0
7.5
7.5
7.5
5.0
10
25
77.5
June 1 -
October
31
7.5
7.5
7.5
7.5
7.5
7.5
5.0
10
25
85.0
The containment and effectiveness of the barrier wall and the capture effectiveness of the extraction
wells outside the barrier wall was improved with the addition of the shallow groundwater extraction
wells and pumping rate modification. However, there continues to be levels of COCs exceeding EGLE
Rule 57 final chronic values (FCVs) and final acute values (FAVs) in the GSI groundwater monitoring
wells. GSI sampling data from the last 6 years of interim monitoring reports are showing exceedances of
the FAV and FCV which could pose a risk to aquatic wildlife and ecological receptors in Black Creek
(see Data Review).
OTHER FINDINGS
In addition, the following are recommendations that were identified during the 2018 FYR and may
improve performance of the remedy, reduce costs, improve management of O&M, and/or promote
sustainability, but do not affect current or future protectiveness. A status update for each is provided
below.
Other Finding A: Ensure that beavers or other biota do not interfere with the functioning of the
weir/sump at the treatment wetland so there is no standing water. This will improve the performance of
the remedy and will prevent attraction of wildlife and other potential ecological receptors.
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Status update: During the FYR site inspection, no sign of biota interfering with the treatment wetland
area was observed. Inspections are conducted at the treatment wetland and observed conditions are
recorded and in the monthly O&M reports. No issues have been reported to EPA.
Other Finding B: Continue to monitor for toluene and other contaminants along the exterior of the
western side of the barrier wall. These contaminants have not been detected since 2014. When toluene
was detected, exposure pathways were controlled and the contaminants did not threaten Black Creek.
The source may be within the OU2 area, so it is anticipated that EPA's ROD for OU2 will evaluate this
issue.
Status update: The source area at OU2 is still awaiting evaluation. EPA has not completed the SRI
work. EGLE has requested additional characterization of OU2. The Agencies have recently re-initiated
discussion to address EGLE's additional sampling request. Also, OU2 was nominated to EPA's NRRB
to assist with the completion of the SRI and FFS.
Other Finding C: Consider reactivation of direct discharge from the GWTP to Black Creek. Treated
groundwater was previously discharged directly to the creek in accordance with the Bofors Nobel
Substantive Requirements Document (SRD) for the Site. If direct discharge could be reactivated to meet
the Substantive Requirements Document, it could reduce costs, improve management of O&M, and
promote sustainability by maintaining a better water balance in the creek/groundwater system.
Status update: On July 29, 2021, the PSDs submitted an SRD to EGLE for approval to resume the
discharge of treated effluent from the GWTP into Black Creek. The document is still under review at
EGLE.
Other Finding D: There is a family of man-made compounds known as polyfluoroalkyl substances
(PFAS) that are emerging contaminants of concern to EPA and EGLE. They are not found naturally and
are very persistent in the environment. Use and disposal patterns of PFAS generally result in a variety of
release mechanisms. They are widespread in part because they are used in production of a wide variety
of products. On February 13, 2018, EPA issued a draft PFAS usage document that helps to identify
possible contamination sources at sites with known or suspected PFAS releases (Document #10 in
Appendix A). The document also helps identify types of sites that may warrant further investigation for
possible PFAS contamination. EPA has identified certain sites as having a high probability of PFAS
(e.g., electroplating, fire training, landfills). Records indicate that specialty chemicals were
manufactured at the Site, including alcohol-based detergents, saccharin, pesticides, herbicides, and dye
intermediates. The products and processes from Bofors/Lakeway/Lomac are not currently identified as
having a high likelihood of PFAS association, but PFAS cannot be completely ruled out. Additionally,
the GWTP uses carbon in the treatment train, which would be expected to address PFAS, if present. As
appropriate, EPA recommends that PFAS be further evaluated at the Site as the Agencies' knowledge
base evolves.
Status update: Limited PFAS sampling has been conducted at the Site. On July, 29, 2021, the PSDs
submitted an SRD to EGLE for resuming the discharge of treated effluent from the GWTP into Black
Creek (Appendix A, Document # 23). Included in the SRD is an analytical report, attachment D, which
analyzes PFAS compounds in two samples collected from the GWTP influent. In the PFAS analytical
report, results indicated the presence of Perfluorooctanesulfonic acid (PFOS), a PFAS compound, (a
member of the PFAS chemical group), at 22 nanograms per liter (ng/L) and 23 ng/L in the GWTP
influent. PFOS concentrations are above the Surface Water Criteria for Human (non-drink) standard of
14
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12 ng/L. The GWTP influent combines the groundwater from the extraction wells and the wetland
treatment lagoon outfall. There is no PFAS analytical data from the monitoring groundwater wells in the
MBA. It is unknown from where the PFAS is getting into the influent to the GWTP. Historic operations
on the Site involved discharging detergent waste into unlined lagoons and depositing incinerated
materials into the landfill area which may be a source for these contaminants. EPA recommends that the
PSDs develop a sampling plan for PFAS and conduct sampling to accurately represent the PFAS
contamination present at the site, and to help determine if it is site related.
Additionally, the GWTP uses granular activated carbon in the treatment train, which would be expected
to address PFAS and PFOS in the influent of the GWTP. EPA recommends that PFAS be further
evaluated at the Site.
IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Involvement & Site Interviews
A public notice was made available by posting on the EPA's Bofors Nobel, Inc website on March 30,
2023, stating that there was a FYR and inviting the public to submit any comments to EPA. No public
comments have been received. No site interviews were conducted during this FYR. The results of the
review and the report will be made available at the Site information repository located at the Egelston
Township Hall, 5428 E. Apple Ave., Muskegon; the Hackley Library, 3 16 W. Webster St., Muskegon;
or online at: https://www.epa.gov/mi/bofors-nobel-inc-site-sixth-five-vear-review-process.
Data Review
This FYR included a review of relevant documents including O&M records and monitoring data.
Applicable groundwater, surface water, and soil cleanup standards, as listed in the July 1999 second
amendment to the 0U1 ROD were also reviewed. Appendix A provides a list of the documents that
were reviewed. Since 2013, the primary focus of sampling has been the effectiveness of the groundwater
extraction wells exterior to the barrier wall in their protection of Black Creek and effectiveness of the
groundwater containment provided by the barrier wall.
Groundwater Capture Between Barrier Wall and Black Creek:
Summaries of groundwater data for the two key COCs (3,3'dichlorobenzidine and benzidine) over the
past 5 years are in the same format as presented in the last FYR (See Table B-5 in Appendix B). The
tables reflect updates to the remedy and the monitoring program over the past five years including the
addition of shallow groundwater extraction wells (EW-1 through 6) to capture groundwater that would
otherwise potentially discharge to Black Creek, and the addition of monitoring wells MW-129A, 130A,
131A and 131C to the monitoring program along the barrier wall furthest from the creek. A few wells
and surface water sampling locations that had shown non-detect results for several years were also
deleted from the program with the agreement of EPA.
There are nine extraction wells. Six shallow extraction (EW1 through EW6) and three deeper wells
(PW-43, PW-46, and PW-47) in the MBA downgradient of the barrier wall that are intended to capture
contaminated groundwater that would otherwise reach Black Creek.
15
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For this FYR, monitoring data were examined for hydraulic control (containment) and groundwater
quality of selected organic and inorganic parameters.
Data since 2018 shows the continued presence of contaminants in groundwater above GSI criteria in
some areas between the barrier wall and Black Creek, particularly at shallow GSI wells in the MBA. In
the September 2022 sampling event, analytes reported above performance standards in monitoring
locations outside of the barrier wall included the following: 3,3-DCB; ammonia; benzidine;
chlorobenzene; and total and dissolved iron. Other analytes (e.g., benzene, toluene) were not reported at
concentrations above performance standards at any monitored location outside the barrier wall. Table B-
5 in Appendix B provides a limited summary of data collected from the wells outside the barrier wall
and highlights exceedances of the FAVs, FCVs, and Industrial Drinking Water concentrations. EPA has
not yet determined if there are any distinct trends of the presence and locations of contamination in
groundwater around and outside of the barrier wall and along Black Creek.
The groundwater extraction wells influence water elevations in the area between the barrier wall and
Black Creek (Table B-6 of Appendix B). Evaluation of water level data indicates that the network of
extraction wells, which was expanded to include six additional shallow extraction wells in March 2020,
provides increased capture, particularly in the shallow zone where groundwater previously discharged to
surface water. However, sampling results show continuing contamination within the GSI monitoring
wells exceeding EGLE Rule 57 FCVs and FAVs despite the addition of the shallow extraction wells and
the increase of the pumping rate. This could question the capture effectiveness of the system for
effectively reducing COCs in the GSI well as expected. Therefore, to address this issue, further
investigation is needed of the COC exceedances of FAVs and FVCs in the GSI wells to determine the
reason why COC concentrations are not decreasing. Further, investigations are needed to determine if
these exceedances are reaching Black Creek to affect ecological receptors and if additional actions, and
what actions, may need to be taken to meet the EGLE standards.
Barrier Wall Containment: In general, the containment effectiveness of the barrier wall has been
documented by hydraulic groundwater data. The biannual monitoring conducted by the PSDs includes
water level monitoring at over 100 wells, including several paired wells on the inside and outside of the
barrier wall (Figure 5 in Appendix B). Since the last FYR, the data consistently shows that water table
elevations are several feet higher inside the barrier wall than outside. This data indicates that the wall is
constraining the flow of groundwater and channeling it towards the treatment wetland.
Functioning of Treatment Wetland: The water accumulation location inside the treatment wetlands (the
weir) is sampled biannually. Groundwater flowing through the OU1 area from the north is forced
upward to ground level by the effect of the barrier wall and is sampled at location WT-1 (location shown
on Figure 6 in Appendix B). The effectiveness of the treatment wetland is questioned because
contaminant levels measured at the weir consistently exceed those planned for in the RD. Because water
in the treatment wetland is contained and pumped to the GWTP, EPA determined that this was not an
issue considered to affect short- or long-term protectiveness. However, the standing water in the
treatment wetlands is uncovered and is an attractive nuisance for waterfowl and other potential
ecological receptors. In addition, the PSDs inserted 4,000 to 5,000 cubic yards of shredded tire material
into the treatment wetland in 2006 to increase hydraulic conductivity. One major concern about these
tire chips is they were not tested for chemical inertness before they were used in the treatment wetland.
There is the potential that harmful chemicals from the tires, in particular 6P-phenylenediamine (6-PPD)
quinone, may be migrating into the wetland to cause current exposures to aquatic wildlife. This FYR
16
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includes an Other Finding B recommendation to determine whether the standing water poses an
unacceptable risk to waterfowl and other potential ecological receptors.
Site Inspection
The inspection of the Site was conducted on 12/2/2022. In attendance were Jeffrey Thomas, EPA; Mark
Reimann and Chuck Graff of EGLE; Steven Finn, Golder (a consultant for the PSDs); Zach Cain, U.S.
Water Services Corporation Industrial Group (U.S. Water) (hired by the PSDs); and Stephen Luke,
(hired by the PSDs). The purpose of the inspection was to assess the protectiveness of the remedy.
The FYR Site inspection checklist was completed and is included in Appendix C. The inspection group
drove the site access roads, exiting vehicles in many spots. The treatment wetland and its weir/sump
building, certain monitoring wells, an extraction well pump house, the protective soil cover over the
(former) lagoon area surface, and the Site perimeter (fence line) and access gates were visually
inspected. The OU1 area was found to be in good condition during the inspection. There are no signs of
erosion and access roads are in good condition. The Site showed no signs of any vandalism or other
disturbances. Inappropriate Site or media uses were not identified from the Site inspection or other
project information. The access fence, gates, and signage were properly in place. There was no visual
evidence that the barrier wall was damaged. Extraction and monitoring well locations that were
observed appeared intact. A few monitoring wells were observed unlocked, missing the padlock. Most
were observed inside the fenced area, one monitoring well (GSI-20) was outside the fenced area.
During the site inspection the PSDs representatives indicated that an inventory of all locks will be made
and replace locks that are not in good working condition. This FYR includes Other Finding A
recommendation to address this problem.
The GWTP was inspected. The GWTP was clean throughout and the treatment components currently in
use were in good shape.
The OU2 area was also inspected. Fencing and access controls are in place and functioning. The asphalt
cover component of the IRAP is in good condition. That cover, along with intact remaining building
slabs, mitigates direct contact exposures to workers.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
The OU1 remedy is partly functioning as intended by the 1999 ROD Amendment but further
investigations and/or actions may be needed with some parts of selected remedy in order to fully
function as intended. The constructed remedy has substantially achieved the RAOs of containing
lagoon sludge and soils to prevent on-site exposure to hazardous substances through placement of a
vegetated soil cover, and to prevent migration of these contaminants at concentrations that would pose
an unacceptable risk to human and/or environmental receptors off-site. While progress is being made
towards the groundwater containment RAOs through a combination of the barrier wall and extraction
wells and improvements made to these systems, groundwater contaminant concentrations on Site still
remain above performance standards particularly in the GSI monitoring wells. The remedy is
17
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considered protective to human health in the short-term since no one is drinking contaminated
groundwater and direct contact threats have been mitigated, however the contaminated groundwater
could pose a threat to aquatic wildlife and ecological receptors in Black Creek and the wetland
treatment area per COC exceedances of the FAVs and FCVs in the GSI wells and sampling results at
Wetland treatment outlet, WT-1.
Remedial Action Performance
There are several major components of the TIC Remedy that are generally operating and
functioning as designed. The remedy goals discussed in section I.E of the 1999 ROD
Amendment identify containment of sludge, soils, and groundwater as the primary component,
with reduction of soil and groundwater contamination levels through treatment as a secondary
objective. The three RAOs in section I.F of the 1999 ROD Amendment all focus on
containment of soil, sludge, and groundwater to prevent unacceptable exposures and risks; there
is no treatment RAO. With the exception discussed below, containment appears to be effective.
Isolation of the contaminated soil and buried waste is achieved by a permeable soil cover with
native vegetative species. Recent inspections show no evidence of anything affecting the
integrity of this remedy component that could result in current exposures. There is no cracking,
sliding, and settlement of the protective cover or other indicators of cover breaches. Monitoring
indicates that the barrier wall appears to be containing the upgradient groundwater and directing
it to the treatment wetland. With continued maintenance and monitoring of the lagoon area
protective cover, wetlands and vegetative remedy components, groundwater extraction, and
groundwater treatment systems inside the security perimeter fences, the source area remedies
should generally contain any contamination and ensure protectiveness.
Contaminants in some monitoring wells between the barrier wall and Black Creek are at
concentrations above GSI FCVs and FAVs. Recent data, including monitoring since the
implementation of a CRA in late 2015, shows that the extraction system hydraulically contains
the majority of the plume south of the barrier wall, but at times provides inconsistent capture.
The PSDs have taken actions to mitigate the concern of incomplete groundwater capture. These
actions have included the addition of extraction wells and adjustment in the pumping rate of the
GWES. However, there continues to be levels of COCs exceeding FCVs and FAVs outside of
the barrier wall, questioning the effectiveness of the remedy. Further investigation is needed of
the COC exceedances of FAVs and FCVs in the GSI wells to determine the reason why COC
concentrations are not decreasing. These investigations could consist of evaluation of the barrier
wall integrity and investigation of the MBA area to determine if there is still a COC source
impacting the MBA groundwater. Further, investigations are needed to determine if these
exceedances are reaching Black Creek to affect ecological receptors and if additional actions,
and what actions, may need to be taken to meet the EGLE standards.
Although containment is the primary objective of the remedy, the 1999 ROD Amendment also
provided for reduction of soil and groundwater contamination levels through treatment provided
by groundwater extraction and treatment, phytoremediation, and attenuation and
biodegradation. It also specified groundwater and soil/sludge cleanup goals (performance
standards) that would allow for the termination of containment, if and when they are met
(Tables B-l and B-2 in Appendix B). Until those performance standards are met and
maintained, the PSDs must continue to operate the containment components of the OU1
remedy. The permeable lagoon area cover is continuing to allow contaminants to flush into
groundwater. Various native vegetative species were planted in the lagoon area to primarily
18
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assist in immobilization of soils, and potentially provide enhancement of natural mechanisms
for reduction of contaminant concentrations. Collected Site groundwater is adequately treated at
the GWTP and disposed of to the MCRRC. The treatment wetland is not attaining levels that
would allow for direct discharge.
Since the last FYR, the PSDs have identified optimization opportunities and implemented
performance improvements and cost reductions, for example, the return of the backwash water
to the treatment wetland.
System Operations/O&M
Except for the need to modify the groundwater capture between the barrier wall and Black
Creek, the established O&M procedures are expected to continue to maintain the effectiveness
of the remedy. Review of monthly GWTP reports reveal that there has been no major disrepair
or substantial breakdowns or repairs. Equipment breakdowns have been infrequent, have been
repaired promptly, and have not affected either short- or long-term remedy protectiveness.
Implementation of Institutional Controls and Other Measures
The 1990 ROD, as well as the 1992 and 1999 ROD Amendments require implementation of
deed/access restrictions and/or other ICs to control future development of the Site and assure
the integrity of the remedial action. Inappropriate Site or media uses were not identified from
the Site inspection or other project information, and access controls are in place and are
effective in preventing exposure. Since May 4, 2012, effective ICs that prevent use of
groundwater and disturbance of the protective cover, wetlands/ vegetative components,
groundwater collection systems, and the groundwater treatment system have been implemented.
Consistent with the requirements of the 1999 CD and the Site's ICIAP, the PSDs will continue
to monitor and maintain ICs under the oversight of EPA. IC maintenance will help ensure the
long-term protectiveness of the remedy and prevent exposure to existing contaminants.
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?
Question B Summary:
No, the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy
selection are not still valid.
Changes in Standards and TBCs
No relevant changes in standards or TBCs have occurred since the last FYR. However, there
have been updates to EGLE Part 201 GSI Cleanup Standards (i.e., FAVs and FCVs) for the
COCs presented in the 1999 ROD amendment. EPA and EGLE need to conduct a review of the
current GSI groundwater cleanup criteria, and document any changes.
Changes in Toxicity and Other Contaminant Characteristics
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Toxicity factors and contaminant characteristics for COCs have not changed in any way that
could affect the protectiveness of the remedy.
Changes in Risk Assessment Methods
EPA's standardized risk assessment methodologies and guidance have not changed in a way that
could affect the protectiveness of the remedy. The State of Michigan regularly updates cleanup
standards as human health risk data is acquired. However, methodologies used to establish State
of Michigan health-based standards and assess risk at the Site since the last FYR have not
changed.
Changes in Exposure Pathways
No changes in the Site conditions that affect exposure pathways were identified as part of the
FYR. There are no current or known planned changes in the Site land use, which is zoned
industrial. ICs are in place and effective. Groundwater is not being used, and monitoring
programs implemented and currently being developed are or will adequately assess the Site
groundwater plume. No unanticipated toxic byproducts of the remedy were identified in this
FYR, nor were there any changes in physical site conditions identified.
However, an emerging contaminant, per- and polyfluoroalkyl substances (PFAS), needs to be
evaluated to determine its presence at the Site and whether is a site-related COC. Historic
operations on the Site involved discharging detergent waste into unlined lagoons and depositing
incinerated materials into the landfill area which may be a source for these contaminants.
Limited PFAS sampling has been conducted at the Site. Included in the 2021 SRD is an
analytical report which analyzes PFAS compounds in two samples collected from the GWTP
influent. In the PFAS analytical report, results indicated the presence of PFOS at 22 nanograms
per liter (ng/L) and 23 ng/L in the GWTP influent. PFOS concentrations are above the Surface
Water Criteria for Human (non-drink) standard of 12 ng/L. As a result, the historical uses and
waste disposal practices taken place on the Site suggest PFAS to be potentially present and may
pose a threat to Black Creek. (See Section III - Progress Since Last Review, Other Findings,
Other finding D, Status update). This FYR includes an issue and recommendation to address this
problem.
Additional emerging contaminants that should be considered for further evaluation are 6PPD and
6PPD-quinone. 6PPD is a chemical that prevents tires from degrading known as "anti-tire
degradants" and breaks down into 6-PPD quinone which is toxic to aquatic wildlife. The PSDs
inserted 4,000 to 5,000 cubic yards of shredded tire material into the treatment wetland in 2006
to increase hydraulic conductivity. One major concern about these tire chips is they were not
tested for chemical inertness before they were used in the treatment wetland. There is the
potential that 6PPD-quinone may be migrating into the wetland and/or Black Creek beyond the
barrier wall to cause current exposures to aquatic wildlife. This FYR includes Other Finding B to
address this problem.
Expected Progress Towards Meeting RAOs
The three RAOs in the 1999 ROD Amendment focus on containment to prevent unacceptable
exposures and risks, and to prevent off-site migration. As discussed above, the barrier wall,
treatment wetland and vegetated soil cover appear to be containing lagoon area contaminants.
20
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However, the extraction wells in the MBA may not be consistently capturing the groundwater
plume, as COCs are detected in the MBA.
In addition to the RAOs, the 1999 ROD Amendment also included groundwater and soil cleanup
criteria (performance standards) (Tables B-l and B-2) that, if met and maintained, would mean
the containment portion of the remedy would no longer be necessary. The cleanup criteria are not
expected to be achieved in the timeframes originally estimated by the current remedy, even with
CRAs. However, the PSDs have a long-term commitment to continue containment and other
work at the Site until all cleanup criteria are met and maintained.
The 1999 ROD Amendment called for monitoring programs to assess the containment
effectiveness of the barrier wall and groundwater collection and extraction system, and to assess
the reduction of contaminant concentrations in soil, sludge and groundwater. The current interim
O&M Plan is sufficient to assess short-term attainment of the RAOs. However, the Performance
Standards Verification Plan should be developed and implemented to ensure long-term
protectiveness of the OU1 TIC Remedy.
QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy?
No other information has been identified as part of the FYR that would call into question the
protectiveness of the remedy. There have been no newly identified natural disasters or weather events
adversely impacted the OU1 remedy.
VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
C)l'(s) wilhoiil Issues/Recommendations Idoulillecl in (lie Five-Year Review:
No remedy has been selected for OU2. Therefore, protectiveness of OU2 is not being
evaluated in this FYR, and no issues or recommendations can be made for that OU.
Issues and Recommendations Identified in the Five-Year Review:
OU(s): 1
Issue Category: Remedy Performance
Issue #1: Despite additional shallow groundwater extraction wells and
pumping rate modifications made in 2022, there continues to be levels of
COCs exceeding EGLE Rule 57 FCVs and FAVs in the GSI groundwater
monitoring wells.
Recommendation #1: Further investigate the reasons for COC
exceedances of FAVs and FVCs in the GSI wells.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/30/2025
21
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OU(s): 1
Issue Category: Remedy Performance
Issue #2: Contaminated groundwater could pose a threat to aquatic
wildlife and ecological receptors in Black Creek per COC exceedances of
the FAVs and FCVs in the GSI wells.
Recommendation #2: Conduct investigations including an ecological risk
assessment to determine if the COCs causing the GSI well exceedances are
reaching Black Creek to affect ecological receptors and if additional
actions, and what actions, may need to be taken to meet the EGLE
standards and protect ecological receptors.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
Yes
Yes
PRP
EPA/State
9/30/2024
OU(s): 1
Issue Category: Remedy Performance
Issue #3: Contaminated standing water in the treatment wetlands could
pose a threat to aquatic wildlife and ecological receptors per COC
exceedances of the FAVs and FCVs in sampling results at wetland
treatment outlet, WT-1.
Recommendation #3: Conduct an investigation including an ecological
risk assessment to determine whether the standing water in the treatment
wetland poses an unacceptable risk to waterfowl and other potential
ecological receptors and if additional actions, and what actions, may need
to be taken to meet the EGLE standards and protect ecological receptors.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
Yes
Yes
PRP
EPA/State
9/30/2025
OU(s): 1
Issue Category: Monitoring.
Issue #4: A plan is needed for long-term Site monitoring.
Recommendation #4: Finalize and implement the Performance Standards
Verification Plan for the OU1 TIC Remedy.
Affect
Current
Protectivene
ss
Affect Future
Protectiveness
Party
Responsibl
e
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
1/30/2024
22
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OU(s): 1
Issue Category: Remedy Performance
Issue #5: It is unknown from where the PFAS is getting into the influent to the
GWTP.
Recommendation #5: Develop a sampling plan for PFAS compounds and
sample for PFAS compounds to determine where they are present at the Site, such as
in the groundwater monitoring wells, and the GTWP effluent, whether they are Site-
related, and if further action is necessary.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone Date
No
Yes
PRP
EPA/State
9/30/2024
OU(s): 1
Issue Category: Other
Issue #6: Levels of COCs exceeding EGLE Rule 57 FCVs and FAVs in
the GSI groundwater monitoring wells.
Recommendation #6: Perform a review of the Part 201 GSI cleanup
standards included in the 1999 ROD amendment and document
updates/changes to the standards as appropriate.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
Yes
Yes
EPA/State
EPA/State
9/30/2024
OTHER FINDINGS
In addition, the following are recommendations that were identified during the FYR and may improve
performance of the remedy, reduce costs, improve management of O&M, and/or promote sustainability,
but do not affect current or future protectiveness:
Other Finding A: Groundwater monitoring wells were observed unlocked during the FYR Site
inspection. The PSDs will implement an inventory of all monitoring wells locked, locks are to be
inspected and unserviceable locks will be replaced.
Other Finding B: 6PPD and 6PPD-quinone may be emerging contaminants at the Site since shredded
tire material was used during the construction of the treatment wetland to increase hydraulic
conductivity. The tire chips used were not tested for chemical inertness before they were placed in the
treatment wetland, but 6-PPD quinone is known to be toxic to aquatic wildlife and may potentially be
migrating into Black Creek and/or affecting wildlife in the wetland treatment area. EPA recommends
that 6PPD and 6PPD-quinone be further evaluated at the Site as the Agencies' knowledge base evolves.
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VII. PROTECTIVENESS STATEMENT
Operable Unit:
Protectiveness Determination:
Protectiveness Deferred
Planned Addendum
Completion Date:
0U1
10/31/2025
Protectiveness Statement: A protectiveness determination of the remedy at OU1 cannot be made at
this time until further information is obtained. Further information will be obtained by taking the
following actions:
• Conduct investigations including an ecological risk assessment to determine if the
COC exceedances in the GSI wells are reaching Black Creek to affect ecological
receptors and if additional actions, and what actions, may need to be taken to meet the
EGLE standards and protect ecological receptors;
• Perform a review of the Part 201 GSI cleanup standards included in the 1999 ROD
amendment and document updates/changes to the standards as appropriate;
• Conduct an investigation including an ecological risk assessment to determine whether
the standing water in the treatment wetland poses an unacceptable risk to waterfowl
and other potential ecological receptors and if additional actions, and what actions,
may need to be taken to meet the EGLE standards and protect ecological receptors.
It is expected that these actions will take approximately two years to complete, at which time
a protectiveness determination will be made.
VIII. NEXT REVIEW
The next FYR report for the Bofors Nobel, Inc. Superfund Site is required five years from the
completion date of this review.
24
-------
APPENDIX A - REFERENCE LIST
Title aiicl Author
Dale
1
Remedial Investigation Report for the Bofors Site, Michigan; EGLE
Feb. 1990
2
Record of Decision (OU1); EPA
9/17/1990
3
Draft Public Comment Feasibility Study Report for the Groundwater/Plant
Area Operable Unit, Bofors Site, Muskegon, Michigan,
Nov. 1991
4
Amendment to the Record of Decision (OU1); EPA
7/22/1992
5
Explanation of Significant Differences; EPA (OU1)
4/30/1996
6
Final Interim Response Activity Plan (IRAP), Lomac Plant, Muskegon,
Michigan; PSD
June 1999
7
Second Amendment to the Record of Decision (OU1); EPA
7/16/1999
8
Memorandum, Entry of Bofors Nobel CERCLA RD/RA Consent Decree;
EPA
12/13/1999
9
Declaration of Restrictive Covenant and Grant of Environmental
Protection Easement, Bofors-Nobel Superfund Site, Muskegon County,
Michigan; PSDs
5/4/2012
10
Final Supplemental Remedial Investigation Report, Bofors Nobel
Superfund Site, Operable Unit 2, Muskegon, Michigan: EPA
April 2016
11
Draft PFAS Usage Document; EPA
2/13/2018
11
Letter providing a summary of the proposed OU1 Long-term Site
Management Plan and schedule; Golder for PSDs
4/27/2018
12
Institutional Controls Implementation and Assurance Plan, Operable Unit
1, Bofors Nobel Superfund Site, Muskegon, Michigan; Golder for PSDs
6/8/2018
13
Long Term Site Management Plan, Operable Unit 1 Bofors Nobel Superfund
Site, Muskegon, Michigan; Golder for PSDs
6/12/2018
14
Fifth FYR Report, Bofors Nobel Superfund Site; EPA
7/23/2018
15
Meander Bend Area Groundwater Extraction System Design, Operable Unit
1, Bofors Nobel Superfund Site, Muskegon, MI: Golder for PSDs
Oct. 2018
16
Bofors Nobel GWTP Monthly Reports; Camus LLC for PSDs
July 2018 -
June 2023
17
MBA Shallow Groundwater Extraction Well Installation and Testing Report,
Bofors Nobel Superfund Site, Muskegon, MI; Golder for PSDs
March 2019
18
Quality Assurance Project Plan, Revision 3, Bofors Nobel Superfund Site
(OU-1) Muskegon, Michigan; Golder for PSDs
March 2019
19
MBA Shallow Groundwater Conveyance System Design Report, Bofors
Nobel Superfund Site, Muskegon, MI; Golder for PSDs
July 2019
20
MBA Shallow Groundwater Conveyance System Construction Completion
Report, Bofors Nobel Superfund Site, Muskegon, MI; Golder for PSDs
June 2020
21
Technical Memorandum, Revisions to Interim Monitoring Program, Bofors
Nobel Site, Muskegon, MI; Golder for PSDs
11/2/2020
22
MBA GWES Start-up Monitoring and Optimization Testing Report, Bofors
Nobel Superfund Site, Muskegon, MI, Golder for PSDs
July 2021
23
Letter regarding SRD Reactivation and Associated Appendix that provides
the PFAS sampling results, submitted to EGLE; Golder Associates USA Inc.;
PSDs
7/29/2021
25
-------
24
MBA Groundwater Extraction System Verification Monitoring Report (Rev
1), Bofors Nobel Superfund Site, Muskegon, MI; Golder for PSDs
Jan. 2022
25
Technical Memorandum, Bofors Nobel Design for GWTP Backwash return to
Wetland; PSDs
4/4/2022
26
Quality Assurance Project Plan, Revision 4
July 2022
27
Issues Recommended for Inclusion in the Upcoming Five-Year Review
Report for the Bofors Nobel Inc., Superfund Site; EGLE
11/15/2022
28
Letter Approving Design for GWTP Backwash Return to Wetland, Bofors
Nobel Site, Muskegon, MI; EPA
10/12/2022
29
Backwash Return to Wetland Construction Completion Report, Bofors Nobel
Superfund Site, Muskegon, MI; Golder for PSDs
Nov. 2022
30
Bofors Nobel Institutional Controls: Title Search Results; Golder for PSDs
12/29/2022
31
Review of Bofors Nobel Substantive Requirements Document NO.
MIU990006V 1.0, Attachment D: Per- and Polyfluoroalkyl Substances
(PFAS) Testing Results; EGLE
2/22/2023
32
Letter providing comments on the Quality Assurance Project Plan, dated July
2022 for Bofors Nobel Superfund Site, Operable Unit 1, Muskegon, MI; EPA
3/16/2023
26
-------
APPENDIX B - FIGURES AND TABLES
27
-------
-ON AVE
-SUMMIT AVE
1F -cy*
L !f*3>
b u.
at
SUMMIT AVE
CO RD 72
Egelston
Township
Cem
O
Se
ce
5
g
T1!
'St
•K(.
dyke
RUTHIE LN
i 0U1 (LAGOONS AREA AND SITE-WIDE GROUNDWATER BOUNDARY) (SEE REFERENCE 1)
i OU2 (FORMER OPERATING PLANT) (SEE REFERENCE 1)
REFERENCE(S)
1. OU1 AND OU2 BOUNDARIES TAKEN FROM FIGURE 1-1 FROM REPORT ENTITLED
"SUPPLEMENTAL REMEDIAL INVESTIGATION REPORT," DATED APRIL 2016, BYSULTRAC.
2. BASE MAP TAKEN FROM USGS 7.5 MINUTE QUADRANGLES OF SULLIVAN, MICHIGAN DATED
2017, AND MUSKEGON EAST, MICHIGAN, DATED 2017
CLIENT
BOFORS NOBEL PERFORMING SETTLING DEFENDANTS
PROJECT
BOFORS NOBEL SUPERFUND SITE
MUSKEGON, MICHIGAN
YYYY-MM-DD
2018-06-07
DESIGNED
KT
PREPARED
GLS
REVIEWED
PSF
TITLE
SITE LOCATION
PROJECT NC
1772241
CONTROL
MISC001
REV.
0
FIGURE
1
-------
Figure 2 - County Location of
Bofors Nobel, Inc. Site
-------
NOTE: MAP IS NOT TO SCALE
FIGURE 3 - SITE LOCATION MAP
BOFORS NOBEL, INC. SUPERFUND SITE;
EGELSTON TOWNSHIP, MICHIGAN
-------
i APPROXIMATE LOCATION OF EXISTING BARRIER WALL
¦ PROPERTY COVERED BY INSTITUTIONAL CONTROL (SEE REFERENCE 2)
APPROXIMATE LOCATION OF BLACK CREEK
! APPROXIMATEEXTENTOF TREATMENT WETLAND
REFERENCE(S)
1 BARRIER WALL LOCATION TAKEN FROM FIGURE 1-2 FROM REPORT ENTITLED "SUPPLEMENTAL
REMEDIAL INVESTIGATION REPORT," DATED APRIL 2016. BY SULTRAC.
2. PROPERTY DESCRIPTION BASED ON LEGAL DESCRIPTION AND SURVEY BY MOORE &
BRUGGINK INC. FEBRUARY 9,2012.
3 AERIAL SHOWN AERIAL COURTESY OF © 2018 MICROSOFT CORPORATION © 2018
DIGITALGLOBE © CNES (2018) DISTRUBUTION AIRBUS DS BING.
BOFORS NOBEL PERFORMING SETTLING DEFENDANTS
PROJECT
BOFORS NOBEL SUPERFUND SITE
MUSKEGON, MICHIGAN
YYYY-MM-DD
title PROPERTY COVERED BY INSTITUTIONAL CONTROLS
>COLDER
PREPARED
REVIEWED PSF
APPROVED PSF
PROJECT NO
FIGURE
4
-------
- -x. ^.-i ij^Ss. .-. ¦; v*-:•¦*'¦ ' ---'¦ .
"' - ' *• ••,.£,•••. r.jfeg
¦'-' ¦ ,; V: j •"' ,: • • "
k ^• ::v;;:- "" •"* •;>"•'>:¦' ~
LEGEND
*
IX
*
O
~
~
*
i PROPERTY COVERED BY INSTITUTIONAL CONTROL (SEE REFERENCE 2)
IM- MONITORING WELL
PUMPING WELL
SURFACE WATER LOCATION
SHALLOW MONITORING WELL
INTERMEDIATE MONITORING WELL
DEEP MONITORING WELL
SHALLOW EXTRACTION WELL
REFERENCE(S)
1. AERIAL IMAGE LICENSED FROM GOOGLE EARTH PRO., DATE OF IMAGE 09-09-2017.
2. PROPERTY DESCRIPTION BASED ON LEGAL DESCRIPTION AND SURVEY BY MOORE &
BRUGGINK INC. FEBRUARY 9, 2012.
PROJECT
INTERIM MONITORING REPORT
BOFORS NOBEL SUPERFUND SITE
MUSKEGON, MICHIGAN
TITLE
ANALYTICAL SAMPLING LOCATIONS SEPTEMBER 2022
CONSULTANT
] APPROXIMATE LOCATION OF BLACK CREEK
WSI1
YYYY-MM-DD
2023-03-30
DESIGNED
KT
PREPARED
AM
REVIEWED
PSF
PROJECT NO.
1772241
CONTROL
0009-002
REV.
0
FIGURE
5
-------
n- *¦ <4?
>v<
CLIENT
BOFORS NOBEL PERFORMING SETTLING DEFENDANTS
IM - MONITORING WELL
H, SURFACE WATER LOCATION
-£ SHALLOW EXTRACTION WELL
~| APPROXIMATE LOCATION OF BLACK CREEK
—620 GROUNDWATER CONTOUR
(616 66) GROUNDWATER ELEVATION(FEETMSL)
REFERENCE(S)
1 AERIAL IMAGE© 2021 MICROSOFT CORPORATION© 2021 MAXAR © CNES (2021)
DISTRIBUTION AIRBUS BING MAPS
PROJECT
INTERIM MONITORING REPORT
BOFORS NOBEL SUPERFUND SITE
MUSKEGON, MICHIGAN
IbPlFACE WATER AND SHALLOW GROUNDWATER ELEVATION
MAP: SEPTEMBER 2022
CONSULTANT
WNIl
PROJECT NO CONTROL
1772241 0009-001
YYYY-MM-DD 2023-03-30
REVIEWED
APPROVED
FIGURE
6
-------
TABLE B-l - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS):
1999 ROD AMENDMENT; O.U. #1 AREA; BOFORS-NOBEL SITE
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (ppb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA3 (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA4 (ppb)
PART 201
GROUNDWATER
CONTACT
CRITERIA5 (ppb)
BACKGROUND6
(ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yr)1
Acenaphthene
3,800
1,300
19
4200 S7
ND9
20
Acenaphthylene 17
75
26
ID12
3900 S7
ND
21
Acetone
2,100
730
1,700
31,000,000
ND
5,100; 81,000 E
Aniline (cc)
610
150
ip 14
370,000
ND
10,000
Anthracene
43 S 7
43 S 7
ID12
43 S 7
ND
14 J
Azobenzene (cc)
32
7.7
NA5
410
ND
420 @ PW-40 (7/93)
Benzene (cc)
5 A8
5 A8
200 X13
9,400
8,000
65,000
Benzeneacetic acid17
N/L11
NOT LISTED
ND
140 J
Benzidine (cc)
0.3 M 10
0.3 M 10
ID12
6.8
ND
12,000 @MW-106 (6/92)
Benzo(a)anthracene
5 M 10
5 M 10
NA5
5 M 10
ND
19 J
Benzo(a)pyrene 17
5 M 10
5 M10
ID12
5 M 10
ND
230
1,2,3-Benzothiadiazole 17
N/L11
NOT LISTED
ND
1,300 J
Benzyl Alcohol
29,000
10,000
NA5
44,000,000 S7
ND
310 @PW-39 (6/92)
Bis(2-ethylhexyl)phthalate
6 A8
6 A8
32
47
ND
4,000 J
Carbon Disulfide
2,300
800
ID12
1,100,000
ND
1,000
2-Chloroaniline
N/L11
NOT LISTED
ND
63,000
4-Chloroaniline
N/L11
NOT LISTED
ND
62 @ MW-62 (7/93)
Chlorobenzene
100 A8
100 A8
47
68,000
ND
920
Chloroform
100 A,W8-15
100 A,W8-15
170 X13
96,000
ND
4.8 @ MW-60 (6/94)
-------
TABLE B-l - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS);
1999 ROD AMENDMENT; O.LJ. #1 AREA; BOFORS-NOBEL SHE
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (ppb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA3 (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA4 (ppb)
PART 201
GROUNDWATER
CONTACT
CRITERIA5 (ppb)
BACKGROUND6
(ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yr)1
(3-chlorophenyl)(4-chlorophenyl) -
methanone
N/L11
NOT LISTED
ND
700 J
Chrysene
5 M 10
5 M 10
ID12
5 M 10
ND
19 J
Dibenzofuran17
ID12
ID12
4
ID12
ND
18 J
3,3'-Dichlorobenzidine (and
isomers) (cc)
7.7
1.9
0.3 M,X 10-13
270
ND
2,600
1,2-Dichlorobenzene
600 A8
600 A8
16
160,000 S 7
ND
400
1,2-Dichloroethane
5 A8
5 A8
360 X13
11,000
ND
110
1,1-Dichloroethylene (ethene)
7 A8
7 A8
65 X13
9000
ND
34 J @ PW-33 (6/94)
1,2-Dichloroethylene (ethene)
70 A8
70 A8
ID12
170,000
ND
2,400 @ PW-33 (6/94)
N,N - Dimethylformamide
2,000
700
NA5
130,000,000
ND
450 J
Dimethyl phthalate
210,000
73,000
NA5
4,200,000 S 7
ND
120 J
Dimethylbenzenamine 17
N/L11
NOT LISTED
ND
780 J
Dimethylnapthalene 17
N/L11
NOT LISTED
ND
52 J
Di-n-Butylphthalate
2,500
880
9.7
11,000 S 7
ND
180 @PW-40 (11/93)
Di-n-Octylphthalate
380
130
ID12
250
ND
459 @ PW-40 (6/92)
l,l'-Diphenyl- 2,2-Diamine
N/L11
NOT LISTED
ND
3,200 J
2,3-Dihydrodimethyl-lH-Indene
N/L11
NOT LISTED
ND
42 J
Ethylbenzene
74 E 14
74 E 14
18
170,000 S 7
ND
340 @PW-41 (9/92)
-------
TABLE B-l - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS);
1999 ROD AMENDMENT: O.LJ. #1 AREA: BOHORS-INOBLL"STTE
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (ppb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA3 (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA4 (ppb)
PART 201
GROUNDWATER
CONTACT
CRITERIA5 (ppb)
BACKGROUND6
(ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yr)1
Fluoranthene
210 S 7
210 S7
1.6
210 S 7
ND
16 J
Fluorine 17
2,000 AE8
2,000 A E 8
NA5
13,000,000
ND
16 J
2-Hydroxybenzonitrile 17
N/L11
NOT LISTED
ND
44 J
4-hydroxy-4-methyl-2-pentanone17
N/L11
NOT LISTED
ND
190 J
Isophorone
3,700
900
570 X 13
1,100,000
ND
1,400
2-Methylnapthalane
750
260
ID12
32,000
ND
480
2-Methylphenol
1,000
370
82
710,000
ND
470
4-Methylphenol
100
37
ID12
75,000
ND
170
1-Methoxy nitrobenzene 17
N/L11
NOT LISTED
ND
22,000 J
1-Methylnaphthalene 17
N/L11
NOT LISTED
ND
490 J
Methoxybenzeneamine 17
N/L11
NOT LISTED
ND
21,000 J
Methylene Chloride
5 A8
5 A8
940 X13
110,000
ND
5,820 @PW-38 (6/92)
N-nitroso-Di-n-Propylamine
5 M 10
5 M 10
NA5
220
ND
30 @ PW-34 (12/92)
Naphthalene
750
260
13
31,000 S 7
ND
650
Nitrobenzene
9.6
5 M 10
180 X 13
9,600
ND
6,600
Phenanthrene
75
26
5 M 10
1,000 S 7
ND
19 J
Phenol
13,000
4,400
210
28,000,000
ND
140;170 J
Pyrene
140 S 7
140 S 7
ID12
140 S 7
ND
27
Sulfur17
N/L11
NOT LISTED
ND
1,800 J
-------
TABLE B-l - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS);
1999 ROD AMENDMENT: O.LJ. #1 AREA: BOHORS-INOBLL"STTE
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (ppb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA3 (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA4 (ppb)
PART 201
GROUNDWATER
CONTACT
CRITERIA5 (ppb)
BACKGROUND6
(ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yr)1
Tetrachloroethylene
5 A8
5 A8
45 X13
5,100
ND
18,000
Toluene
790 E 8
790 E 8
140
530,000 S 7
3,000 J
280,000
1,2,4-Trichlorobenzene
70 A8
70 A8
30
15,000
ND
56 J
Trichloro-l-propene isomer 17
N/L11
NOT LISTED
ND
36 J
T richloroethy lene
5 A8
5 A8
200 X13
11,000
ND
2,100 @PW-33 (6/94)
3,3,5-Trimethylcyclohexanone
N/L11
NOT LISTED
ND
31,000 J
Trimp (trimethylphenols)
N/L11
NOT LISTED
ND
2,000 J
1,2,4-TritMolane 17
N/L11
NOT LISTED
ND
420 J
1,3,5-Trithlane 17
N/L11
NOT LISTED
ND
100 J
Unknowns ****
N/L11
NOT LISTED
ND
100,500
Vinyl chloride
2 A8
2 A8
15
290
ND
1,000
Xylenes (total)
280 E 8
280 E 8
35
190,000 S 7
8,000
580 @ PW-41 (5/91)
Aluminum
50
50
NA5
70,000,000
192
23,200
Antimony17
6 A8
6 A8
ID12
75,000
61.3
61
Arsenic
50 A8
50 A8
150 X 13
4,700
4.8 J
74
Barium
2,000 A8
2,000 A8
190
15,000,000
23.2 J
174 J
Beryllium
4 A8
4 A8
G18
1,100,000
ND
14 @ MW-72 (12/92)
Cadmium
5 A8
5 A8
G18, X13
210,000
5.3
120,000 @IL-01 (3/93)
-------
TABLE B-l - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS);
1999 ROD AMENDMENT: O.LJ. #1 AREA: BOHORS-INOBLL"STTE
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (ppb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA3 (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA4 (ppb)
PART 201
GROUNDWATER
CONTACT
CRITERIA5 (ppb)
BACKGROUND6
(ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yr)1
Calcium17
(no threat to human health and the environment)
43,700
345,800 @PW-41 (10/91)
Chromium (VI)
100 A8
100 A8
11
1,000,000
28.2
74 @ MW-72 (12/92)
Cobalt
100
50 M 10
100
1,100,000
10
38 @MW-72 (12/92)
Copper
1,000 E8
1,000 E 8
G18
8,100,000
64.7
120 @ MW-72 (12/92)
Iron17
300 E 8
300 E 8
NA5
ID12
768
35,400
Lead
4 L 19
4 L 19
G,X13-18
ID12
7.3
8,800 @MW-110 (9/92)
Magnesium17
1,200,000
420,000
NA5
1,000,000,000 D20
13,200
85,000 @MW-106 (9/92)
Manganese
50 E 8
50 E8
G,X13-18
10,000,000
34
5,390
Mercury
2 A8
2 A8
0.2 M 15
56 S7
0.2
1.3
Nickel17
100 A8
100 A8
G18
16,000,000
22.9 J
810 @MW-110 (9/92)
Potassium17
(no threat to human health and the environment)
1930 J
16,500
Selenium
50 A8
50 A8
5
1,100,000
3.6 J
14.7
Silver
98
34
0.2 M15
1,000,000
12.9
16,000 @ MW-72 (12/92)
Sodium17
450,000
160,000
NA5
1,000,000,000 D20
1430
1,610,000
Thallium
2 A8
2 A8
3.7 X 13
14,000
ND
30 @ MW-110 (9/92)
Vanadium
180
64
12
1,900,000
12.7 J
412
Zinc
5,000 E 8
2,400
G18
70,000,000
88.7
210,000 @ MW-72 (12/92)
-------
FOOTNOTES AND LEGEND FOR TABLE 1
(cc) Baseline risk assessment identified this contaminant as presenting a major Site risk. Baseline risk assessment did not identify any inorganic contaminants as contaminants of
concern.
1 Data taken from Record of Decision and Landfill Remedy Remedial Design. Maximums represent either the maximum shown in the ROD, or the maximum concentration
discovered during RD quarterly groundwater monitoring from mid-1992 to mid-1994. Maximum concentrations that have been noted with location and (month/year) are 1991-94
RD data. All other maximums are 1990 ROD and RI data.
2 Industrial Drinking Water Standard is the cleanup criteria that are applicable to groundwater unless appropriate deed restrictions cannot be obtained for future industrial land use, in
which case criteria for future residential land use would apply for groundwater.
3 Residential Drinking Water Standard is the cleanup criteria that are applicable to groundwater for future residential land use.
4 Groundwater - Surface Water Interface (GSI) Criteria are contaminant concentrations in groundwater which, if not exceeded, are protective of a surface water body that receives
such contaminated groundwater discharge. These GSI limits must be maintained to insure protection of Big Black Creek.
5 Groundwater Contact Criteria are contaminant concentrations in groundwater which, if not exceeded, are protective of human health in the event of inadvertent human direct
contact with such contaminated groundwater.
6 BACKGROUND - Background concentration taken from sample in relatively "clean" Site area as shown in the February 1990 Remedial Investigation (RI) report. For
cleanup standards noted by a 'B', background concentrations may be used instead of the value shown.
7 S - Criterion is based on the chemical specific water solubility limit.
8 A - State of Michigan Drinking Water Criterion established pursuant to Section 5 of the Safe Drinking Water Act, Act No. 399 of the Public Acts of
1976; E - Criterion is the aesthetic drinking water value, as required by Sec. 20120(1)(5).
9 ND - Compound Not Detected in laboratory analysis.
10 M - Criterion is below the Method Detection Limit, therefore, the criterion defaults to the MDL. The Method Detection Limit is the lowest value accepted by the State of
Michigan that laboratory equipment can measure. If the Part 201 cleanup criterion is lower than what the laboratory can detect, then the MDL becomes the cleanup criterion.
11 N/L - Not Listed in Michigan Part 201 Generic Industrial and Commercial Cleanup Criteria.
12 ID - Inadequate Data. The State of Michigan does not have enough health risk data to develop criterion for this contaminant.
13 X - The GSI criterion shown is not protective for surface water that is used as a drinking water source.
14 IP - Development of generic GSI value in process but not yet complete.
15 W - Concentrations of trihalomethanes in groundwater must be added together to determine compliance with the Drinking Water Standard of 100 ppb.
16 NA - Not Available.
17 Contaminant discovered at the time of the 1990 ROD, but subsequently shown (by subsequent sampling and analysis) as not present, naturally occurring, or well below soil,
air, groundwater, or surface water cleanup standard after appropriate U.S. EPA and MDEQ review and approval.
18 H - Standard is dependent on "hardness" of groundwater; G - GSI cleanup criterion is dependent upon water hardness in the area.
19 L - For Lead, higher concentrations may be acceptable and criteria may be modified based on an acceptable site-specific demonstration subject to U.S. EPA/MDEQ review
and approval.
20 D - Calculated groundwater criterion exceeds 100 % and is reduced to 100 %. Site - specific evaluation of contaminant status and adverse impacts subject to U.S. EPA/MDEQ
review and approval may be required.
DATA QUALIFIER LEGEND
When chemical analysis data is submitted to U.S. EPA, limitations of analytical equipment must be noted with results so an accurate scrutiny can be performed. These limitations are
shown as qualifiers, noted as letters next to numerical values. Explanations of these qualifiers are as follows:
**** Compound is noted as "unknown" because there were detections of organic chemicals, but specific identification of specific compound or isomer detected is unknown.
J - Signifies a value that was estimated. This means that the compound was detected by the analytical equipment, but the value shown may not be able to be reproduced exactly if the
analysis were repeated.
B - Signifies a compound that was also detected in a blank. A blank is a 'clean' sample prepared in the laboratory, carried with field samples, transported, and stored. If contamination is
found in a blank, there is a possibility that contamination may be from a source other than what was sampled (such as through faulty sampling, storage, transportation, or laboratory
procedures).
D - Signifies that the sample shown had to be diluted for the lab equipment to show results that are reproducible.
E - Estimated value due to deviations discovered in lab quality control (QC) procedure.
-------
TABLE B-2- CONTAMINANTS IN SLUDGE AND SOIL AND SOIL CLEANUP CRITERIA (PERFORMANCE STANDARDS):
1999 ROD AMENDMENT: O.U. #1 AREA: BOFORS-NOBEL SITE
CONTAMINANT
PART 201
RPGW 2
(ppb)
PART 201
IPGW 2
(ppb)
PART 201
GSIPGW 2
(ppb)
PART 201 IND.
DCV2 (ppb)
LAGOON NUMBER (Approximate Location); Contaminant Concentration in ppb
BACKGD3
1
2
3
4
5
6
7
8
9
10
Acetone
15000
42000
34000
7.40e+07
ND4
70
91
11
Alkyl benzene
isomers12
N/L5
N/L5
ND4
148000 J
123000 J
147000
148000000 J
4400
Aniline (cc)
3000
12000
IP 9
4.50e+06
C14
ND4
860
9200
1700
3900000
3400
Azobenzene (cc)
1400
5900
N/A5
1,40e+06
ND4
93 J
12000000
170000
680000
22000 J
33000 J
8200000
230000
Azoxybenzene
N/L5
N/L5
ND4
690000 J
36000
85000
Benzene (cc)
100
100
4000 X
13
400,000 C
ND4
980000
23
2800
120000
8 J
Benzidine (cc)
1000 M11
1000 M11
ID7
1,000 M11
ND4
3400000
2100 J
70000 J
13000
1300000
13000
2-Butanone (MEK)
260000
760000
44000
2.70e+07C14
ND4
25 J
2-Chloroaniline
N/L5
N/L5
ND4
260000
270000
540
22000 J;
21000
240
12000 J
2300000
24000 J
(3-Chlorophenyl)
(4-Chlorophenyl)
Methanone
N/L5
N/L5
ND4
300000 J
6100000 J
330000 J
1,300,000
520000 J
34000 J
6200000
190000 J
3,3'-Dichlorobenzidine
(and isomers) (cc)
2000 M11
2000 M11
2000
M11, X l:
55000
ND4
65000 J
2700000
930000;
950000 J
390000;
1000000 J
260000;
100000 J
1500000;
1700000 J
11,000,000
2900000;
3500000 J
Ethylbenzene
1500
1500
360
140,000 C u
ND4
51
9,200
1
Methylene Chloride
(cc)
100
100
19000
X13
2.30e+06
C 14
ND4
^ J sic**
2200 J **
Ig ***
1200 J
Sulfur -NP 10
N/L5
N/L5
ND4
5100 J
8300 J
1500
1,1' - Sulfonyl - bis (2-
N/L5
N/L5
ND4
82000 J
-------
TABLE B-2- CONTAMINANTS IN SLUDGE AND SOIL AND SOIL CLEANUP CRITERIA (PERFORMANCE STANDARDS):
1999 ROD AMENDMENT: O.U. #1 AREA: BOFORS-NOBEL SITE
CONTAMINANT
PART 201
RPGW 2
(ppb)
PART 201
IPGW 2
(ppb)
PART 201
GSIPGW 2
(ppb)
PART 201 IND.
DCV2 (ppb)
LAGOON NUMBER (Approximate Location); Contaminant Concentration in ppb
BACKGD3
1
2
3
4
5
6
7
8
9
10
Methyl) Benzene
T etrachloroethy lene
100
100
900 X 13
88000 C 14
ND4
82
680
Toluene
16000
16000
2800
250000 C 14
ND4
8,900
1,100,000
17
130,000
80,000
1600000
210
1,2,4 -
Trichlorobenzene
4200
4200
1800
l.le+06 C u
ND4
350
150
150
7,100
250000
Unknowns **** 10
NP 10
26 J
1400 J
5700 J
503000 J
19000 J
14400 J
Xylenes (total)
5600
5600
700
150,000 C h
ND4
120
14
58,000
Aluminum
1000
1000
N/A5
3.00e+08
3770000
250000
1110000
1740000
781000
7920000
4070000
1900000
6220000
1930000
3830000
Antimony 10
4300
4300
ID7
1.60e+06
ND4
25200
Arsenic
23000
23000
70000 X13
100000
ND4
43800 E
630 J
6100
600 J
3600
5100
780 J
3700 J
2700 J
3300 J
Barium
1.30e+06
1.30e+06
130000
3.20e+08
12600 J
9800 J
5700 J
40300 J
3400 J
48000 J
43400 J
18300 J
85000
18300 J
44700 J
Beryllium
51000
51000
G13
2.30e+07
ND4
670 J
540 J
2100
320
2400
Cadmium
6000
6000
G,X 13
2.30e+06
ND4
424000
21900
15100
Calcium - NO 10
G,X 13
4.5 e+06
109000 J
83000 J
242000 J
64600000
676000J
194000000
265000000
7350000
253000000
25900000
271000000
Chromium
30000
30000
3300
2.20e+07
2200
916000
2400
79500
22100
12100
17000
68000
45700
21200
Cobalt
1000
2000
2000
2.30e+07
2200 J
36700
3500 J
7700 J
3400 J
Copper
1.60e+08
1.60e+08
G13
1.70e+08
ND4
1640000
41200
226000
19100
14300
6400
2800
36700
27100
Iron -NO10
6000
6000
N/A5
ID7
2650000
5460000
2660000
11000000
1420000
3780000
2550000
3870000
2920000
13000000
1430000
Lead
1000 M 11
1000 M11
G,X13
900,000 L 8
3200
6040000
6200
887000
700 J
34700
20800
37400
29700 R
362000
12500 E
-------
TABLE B-2- CONTAMINANTS IN SLUDGE AND SOIL AND SOIL CLEANUP CRITERIA (PERFORMANCE STANDARDS):
1999 ROD AMENDMENT: O.U. #1 AREA: BOFORS-NOBEL SITE
CONTAMINANT
PART 201
RPGW 2
(ppb)
PART 201
IPGW 2
(ppb)
PART 201
GSIPGW 2
(ppb)
PART 201 IND.
DCV2 (ppb)
LAGOON NUMBER (Approximate Location); Contaminant Concentration in ppb
BACKGD3
1
2
3
4
5
6
7
8
9
10
M11
E
Magnesium - NO 10
8.40e+06
2.40e+07
N/A5
1.0e+09 D 6
342000 J
95000 J
368000 J
1840000
459000J
2870000
2350000
721000 J
3400000
3050000
2470000
Manganese
2000 M 11
2000 M11
G,X 13
2.10e+08
17300
2680000
41200
85200
23900
52000
46400
58600
71600
164000
32800 E
Mercury
1700
1700
170
1.40e+06
ND4
150 E
100
710
330
Nickel
100000
100000
G13
3.40e+08
ND4
460000
2100 J
21000
17500
10300 J
9300
3600 J
15100
4800 J
Potassium - NO 10
NO10
86400
71800 J
189000 J
106000 J
412000 J
245000 J
79300 J
394000 J R
104000 J
132000 J
Selenium
4000
4000
400
2.30e+07
ND4
680 J
3300
2400 J
Silver
4500
13000
500 M11
2.10e+07
ND4
15600
4600
1800 J
1200
Sodium 10
3.20e+06
9.00e+06
N/A5
1.0e+09 D6
ND4
26100 J
5920000
44000 J
191000 J
169000 J
49900 J
366000 J
3500000
318000 J
Thallium
2300
2300
4200 X13
300000
ND4
Vanadium
1.00e+06
2.90e+06
240
3.90e+07
4800
28,600
3000 J
4200 J
940 J
17700
10800 J
4600 J
9300 J
5400 J
6200 J
Zinc
2.40e+06
5.00e+06
G13
1.0e+09 D6
1240000
59,400
15,900
91,200,000
18,500
1,240,000
1,280,000
8,370,000
2,510,000
61,800,000
1,270,000
-------
FOOTNOTES AND LEGEND FOR TABLE 2
(cc) Baseline risk assessment identified this contaminant as presenting a major Site risk. Baseline risk assessment did not identify any inorganic contaminants as contaminants of concern.
1 Data taken from Record of Decision and February 1990 Remedial Investigation (RI) Report. Data represents maximum concentrations found in soils or sludge samples taken in lagoon area at an
average depth of 10 feet deep. (Soil samples - 2 to 6 ft.; Sludge 10 to 12 ft.). No PCBS or pesticides (other than those shown) were detected. Blank spaces in Table 4 signify that compound was
not detected in laboratory analysis. Values shown in format "1.0e+09" are scientific notation (i.e.,1.0e+09 = 1,000,000,000; 1.0e+06=l,000,000; 1.0e-03=0.001; 1.0 e-06=0.000001).
2 IPGW - Industrial Soil Cleanup Criteria Protective of Groundwater as of June 1999. This is the contaminant concentration in soil which, if not exceeded, insures that groundwater is protective for
human consumption under a future industrial land use scenario. RPGW - Residential Soil Cleanup Criteria Protective of Groundwater as of June 1999. This is the contaminant concentration in
soil which, if not exceeded, insures that groundwater is protective for human consumption under a future residential land use scenario. GS1PGW - Soil Cleanup Criteria Protective of GSI Criteria
for Groundwater as of June 1999. This is the contaminant concentration in soil which, if not exceeded, insures that groundwater is protective for Big Black Creek. DCV - Direct Contact Value -
Part 201 Industrial Direct Contact Value as of June 1999. This is the contaminant concentration in soil which, if exceeded, presents an unacceptable human risk by contact with the soil within a
typical industrial scenario. Any exposure to lagoon area soil would be to an individual working on the Site within a controlled work environment. The DCV criterion is the basis for the O.U. # 1
lagoon area cover component of the TIC remedy.
3 BACKGRD - Background concentration taken from sample in relatively "clean" site area.
4 ND - Compound Not Detected in laboratory analysis.
5 N/L - Not Listed in Michigan Part 201 Generic Industrial and Commercial Cleanup Criteria as of June 1999. N/A - Not
Available or Not Applicable, but contaminant has been listed as of June 1999.
6 D - Concentration constituting cleanup criteria exceeds 100 % in soil hence it is reduced to 100 %.
7 ID - Inadequate Data. There is not enough health risk data to develop criterion for this contaminant.
8 L - Criteria developed using the U.S. EPA integrated uptake Biokinetic Model for children. Higher level may be acceptable subject to U.S. EPA and State of Michigan review and approval
procedure.
9 IP - Development of generic GSI value in process but not yet complete.
10 NP, NO - Contaminant discovered at the time of the 1990 ROD but subsequently shown (by subsequent sampling and analysis) as Not Present, Naturally Occurring, or well below soil, air,
groundwater, or surface water cleanup criteria.
11 M - Method Detection Limit is cleanup criterion. The Method Detection Limit is the lowest value accepted by the State of Michigan that laboratory equipment can measure. If the Part 201
cleanup criterion is lower than what the laboratory can detect then the MDL becomes the cleanup standard.
12 Alkylbenzene isomers are compounds related to Toluene, Ethylbenzene, and Isopropylbenzene (all are "Alkyl benzenes").
13 G - Soil criteria for GSI protection is dependent on hardness of water in the area. X - The GSI criterion shown is not protective for surface water that is used as a drinking water source.
14 C - Soil criteria is based on contaminant-specific generic soil saturation concentration to insure a more protective cleanup goal. Soil criterion may be modified based on an acceptable site-
specific demonstration subject to U.S. EPA/MDEQ review and approval.
DATA QUALIFIER LEGEND
When chemical analysis data is submitted to U.S. EPA limitations of analytical equipment must be noted with results so an accurate scrutiny can be performed. These limitations are shown as qualifiers
noted as letters next to numerical values. Explanations of these qualifiers are as follows:
** Not found in duplicate analysis; *** Less than 10 times the concentration found in lab field or background blanks; **** Compound is unknown in the sense that there were detections of organic
chemicals but specific identification of a certain compound or isomer detected is unknown.
J - Signifies a value that was estimated. This means that the compound was detected by the analytical equipment but the value shown may not be able to be reproduced exactly if the analysis were
repeated.
B - Signifies a compound that was also detected in a blank. A blank is a 'clean' sample prepared in the laboratory carried with field samples transported and stored. If contamination is found in a
blank there is a possibility that contamination may be from a source other than what was sampled (such as through faulty sampling storage transportation or laboratory procedures).
D - Signifies that the sample shown had to be diluted for the lab equipment to show results that are reproducible.
E - Estimated value due to deviations discovered in lab quality control (QC) procedure.
-------
TABLE B-l - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS);
I'm ROD AMENDMENT: O.U. #1 AREA: HUlUKSMJHI.irSTTTT
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (ppb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA3 (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA 4 (ppb)
PART 201
GROUNDWATER
CONTACT
CRITERIA5 (ppb)
BACKGROUND6
(Ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yr)1
Fluoranthene
210 S 7
210 S7
1.6
210 S 7
ND
16 J
Fluorine 17
2,000 AE 8
2,000 AE 8
NA5
13,000,000
ND
16 J
2-Hydroxybenzonitrile 17
N/L11
NOT LISTED
ND
44 J
4-hydroxy-4-methyl-2-pentanone17
N/L11
NOT LISTED
ND
190 J
Isophorone
3,700
900
570 X 13
1,100,000
ND
1,400
2-Methylnapthalane
750
260
ID12
32,000
ND
480
2-Methylphenol
1,000
370
82
710,000
ND
470
4-Methylphenol
100
37
ID12
75,000
ND
170
1-Methoxynitrobenzene 17
N/L11
NOT LISTED
ND
22,000 J
1-Methylnaphthalene 17
N/L11
NOT LISTED
ND
490 J
Methoxybenzeneamine 17
N/L11
NOT LISTED
ND
21,000 J
Methylene Chloride
5 A8
5 A8
940 X13
110,000
ND
5,820 @ PW-38 (6/92)
N-nitroso-Di-n-Propylamine
5 M 10
5 M 10
NA5
220
ND
30 @ PW-34 (12/92)
Naphthalene
750
260
13
31,000 S 7
ND
650
Nitrobenzene
9.6
5 M 10
180 X 13
9,600
ND
6,600
Phenanthrene
75
26
5 M 10
1,000 S 7
ND
19 J
Phenol
13,000
4,400
210
28,000,000
ND
140; 170 J
Pyrene
140 S 7
140 S 7
ID 12
140 S 7
ND
27
Sulfur17
N/L11
NOT LISTED
ND
1,800 J
-------
TABLE B-l - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS);
I'm ROD AMENDMENT: O.U. #1 AREA: HUlUKSMJHI.irSTTTT
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (ppb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA3 (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA 4 (ppb)
PART 201
GROUNDWATER
CONTACT
CRITERIA5 (ppb)
BACKGROUND6
(Ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yr)1
Tetrachloroethylene
5 A8
5 A8
45 X13
5,100
ND
18,000
Toluene
790 E 8
790 E 8
140
530,000 S 7
3,000 J
280,000
1,2,4-Trichlorobenzene
70 A8
70 A8
30
15,000
ND
56 J
Trichloro-l-propene isomer 17
N/L11
NOT LISTED
ND
36 J
Trichloroethylene
5 A8
5 A8
200 X13
11,000
ND
2,100 @PW-33 (6/94)
3,3,5-Trimethylcyclohexanone
N/L11
NOT LISTED
ND
31,000 J
Trimp (trimethylphenols)
N/L11
NOT LISTED
ND
2,000 J
1,2,4-Trithiolane 17
N/L11
NOT LISTED
ND
420 J
1,3,5-Trithlane 17
N/L11
NOT LISTED
ND
100 J
Unknowns ****
N/L11
NOT LISTED
ND
100,500
Vinyl chloride
2 A8
2 A8
15
290
ND
1,000
Xylenes (total)
280 E 8
280 E 8
35
190,000 S 7
8,000
580 @ PW-41 (5/91)
Aluminum
50
50
NA5
70,000,000
192
23,200
Antimony17
6 A8
6 A8
ID 12
75,000
61.3
61
Arsenic
50 A8
50 A8
150 X 13
4,700
4.8 J
74
Barium
2,000 A8
2,000 A8
190
15,000,000
23.2 J
174 J
Beryllium
4 A8
4 A8
G18
1,100,000
ND
14 @MW-72 (12/92)
Cadmium
5 A8
5 A8
G18, X13
210,000
5.3
120,000 @IL-01 (3/93)
-------
TABLE B-l - CONTAMINANTS IN GROUNDWATER1 AND GROUNDWATER CLEANUP CRITERIA (PERFORMANCE STANDARDS);
I'm ROD AMENDMENT: O.U. #1 AREA: HUlUKSMJHI.irSTTTT
CONTAMINANT
PART 201
INDUSTRIAL
DRINKING
WATER
CRITERIA2 (ppb)
PART 201
RESIDENTIAL
DRINKING
WATER
CRITERIA3 (ppb)
PART 201
GENERIC GSI
CLEANUP
CRITERIA 4 (ppb)
PART 201
GROUNDWATER
CONTACT
CRITERIA5 (ppb)
BACKGROUND6
(Ppb)
MAX. CONTAMINANT
CONCENTRATION (ppb)
IN 1990 ROD OR
REMEDIAL DESIGN
(month/yr)1
Calcium 17
(no threat to human health and the environment)
43,700
345,800 @ PW-41 (10/91)
Chromium (VI)
100 A8
100 A8
11
1,000,000
28.2
74 @MW-72 (12/92)
Cobalt
100
50 M 10
100
1,100,000
10
38 @MW-72 (12/92)
Copper
1,000 E 8
1,000 E 8
G18
8,100,000
64.7
120 @ MW-72 (12/92)
Iron 17
300 E 8
300 E 8
NA5
ID12
768
35,400
Lead
4 L 19
4 L 19
G,X 13-18
ID12
7.3
8,800 @MW-110 (9/92)
Magnesium 17
1,200,000
420,000
NA5
1,000,000,000 D20
13,200
85,000 @MW-106 (9/92)
Manganese
50 E 8
50 E8
G,X 13-18
10,000,000
34
5,390
Mercury
2 A8
2 A8
0.2 M 15
56 S7
0.2
1.3
Nickel17
100 A8
100 A8
G18
16,000,000
22.9 J
810 @MW-110 (9/92)
Potassium 17
(no threat to human health and the environment)
1930 J
16,500
Selenium
50 A8
50 A8
5
1,100,000
3.6 J
14.7
Silver
98
34
0.2 M15
1,000,000
12.9
16,000 @ MW-72 (12/92)
Sodium17
450,000
160,000
NA5
1,000,000,000 D20
1430
1,610,000
Thallium
2 A8
2 A8
3.7 X 13
14,000
ND
30 @ MW-110 (9/92)
Vanadium
180
64
12
1,900,000
12.7 J
412
Zinc
5,000 E 8
2,400
G18
70,000,000
88.7
210,000 @ MW-72 (12/92)
-------
FOOTNOTES AND LEGEND FOR TABLE 1
(cc) Baseline risk assessment identified this contaminant as presenting a major Site risk. Baseline risk assessment did not identify any inorganic contaminants as contaminants of
concern.
1 Data taken from Record of Decision and Landfill Remedy Remedial Design. Maximums represent either the maximum shown in the ROD, or the maximum concentration
discovered during RD quarterly groundwater monitoring from mid-1992 to mid-1994. Maximum concentrations that have been noted with location and (month/year) are 1991-94
RD data. All other maximums are 1990 ROD and RI data.
2 Industrial Drinking Water Standard is the cleanup criteria that are applicable to groundwater unless appropriate deed restrictions cannot be obtained for future industrial land use, in
which case criteria for future residential land use would apply for groundwater.
3 Residential Drinking Water Standard is the cleanup criteria that are applicable to groundwater for future residential land use.
4 Groundwater - Surface Water Interface (GSI) Criteria are contaminant concentrations in groundwater which, if not exceeded, are protective of a surface water body that receives
such contaminated groundwater discharge. These GSI limits must be maintained to insure protection of Big Black Creek.
5 Groundwater Contact Criteria are contaminant concentrations in groundwater which, if not exceeded, are protective of human health in the event of inadvertent human direct
contact with such contaminated groundwater.
6 BACKGROUND - Background concentration taken from sample in relatively "clean" Site area as shown in the February 1990 Remedial Investigation (RI) report. For
cleanup standards noted by a 'B', background concentrations may be used instead of the value shown.
7 S - Criterion is based on the chemical specific water solubility limit.
8 A - State of Michigan Drinking Water Criterion established pursuant to Section 5 of the Safe Drinking Water Act, Act No. 399 of the Public Acts of
1976; E - Criterion is the aesthetic drinking water value, as required by Sec. 20120(1 )(5).
9 ND - Compound Not Detected in laboratory analysis.
10 M - Criterion is below the Method Detection Limit, therefore, the criterion defaults to the MDL. The Method Detection Limit is the lowest value accepted by the State of
Michigan that laboratory equipment can measure. If the Part 201 cleanup criterion is lower than what the laboratory can detect, then the MDL becomes the cleanup criterion.
11 N/L - Not Listed in Michigan Part 201 Generic Industrial and Commercial Cleanup Criteria.
12 ID - Inadequate Data. The State of Michigan does not have enough health risk data to develop criterion for this contaminant.
13 X - The GSI criterion shown is not protective for surface water that is used as a drinking water source.
14 IP - Development of generic GSI value in process but not yet complete.
15 W - Concentrations of trihalomethanes in groundwater must be added together to determine compliance with the Drinking Water Standard of 100 ppb.
16 NA - Not Available.
17 Contaminant discovered at the time of the 1990 ROD, but subsequently shown (by subsequent sampling and analysis) as not present, naturally occurring, or well below soil,
air, groundwater, or surface water cleanup standard after appropriate U.S. EPA and MDEQ review and approval.
18 H - Standard is dependent on "hardness" of groundwater; G - GSI cleanup criterion is dependent upon water hardness in the area.
19 L - For Lead, higher concentrations may be acceptable and criteria may be modified based on an acceptable site-specific demonstration subject to U.S. EPA/MDEQ review
and approval.
20 D - Calculated groundwater criterion exceeds 100 % and is reduced to 100 %. Site - specific evaluation of contaminant status and adverse impacts subject to U.S. EPA/MDEQ
review and approval may be required.
DATA QUALIFIER LEGEND
When chemical analysis data is submitted to U. S. EPA, limitations of analytical equipment must be noted with results so an accurate scrutiny can be performed. These limitations are
shown as qualifiers, noted as letters next to numerical values. Explanations of these qualifiers are as follows:
**** Compound is noted as "unknown" because there were detections of organic chemicals, but specific identification of specific compound or isomer detected is unknown.
J - Signifies a value that was estimated. This means that the compound was detected by the analytical equipment, but the value shown may not be able to be reproduced exactly if the
analysis were repeated.
B - Signifies a compound that was also detected in a blank. A blank is a 'clean' sample prepared in the laboratory, carried with field samples, transported, and stored. If contamination is
found in a blank, there is a possibility that contamination may be from a source other than what was sampled (such as through faulty sampling, storage, transportation, or laboratory
procedures).
D - Signifies that the sample shown had to be diluted for the lab equipment to show results that are reproducible.
E - Estimated value due to deviations discovered in lab quality control (QC) procedure.
-------
TABLE B-3 - SUMMARY OF RISK: O.U. #1 ROD AND 1999 SECOND ROD AMENDMENT:
BOFORS-NOBEL SITE
EXPOSURE PATHWAY
RESIDENTIAL CARCINOGENIC RISK IDENTIFIED IN 1990 ROD1
Groundwater
S^xlO^tog^xlO1 3
Soil Ingestion
2 x 10"10 to 2 x 10"3 4
Soil Direct (Dermal) Contact
7.9 x 10"9 to 1 x 10"5
Air
7.9 x 10"9 to 1.2 x 10"3 5
Surface Water (Computer Modeled)
3.4 x 10"7 to 1 x 10"2 6
CUMULATIVE (TOTAL) RISK
3.4 x 10"5 to 1.0x10 °
FOOTNOTES FOR TABLE 3
1 Information from September 1990 Record of Decision and February 1990 Remedial Investigation (RI)
Report (repeated in 1999 ROD amendment).
2 Risk uses a basis of a 70 year life time. A 1.0 x 10~6 cancer risk value corresponds to a 1 in 1,000,000
chance that an individual develops cancer as a result of exposure to these concentrations of contaminants
over a period of 70 years. Similarly, 1.0 x 10~5 corresponds to a 1 in 100,000 chance, 1.0 x 10~4, 1 in
10,000, and so on. U.S. EPA may perform a Remedial Action if cancer risks are greater than 1.0 x 10~4, or
a Hazard Index of 1.0 or greater.
3 Calculated in 1990 by computer models ("SeSOIL" and "AT123D") which simulated contaminant release
as leachate from soil and sludge.
4 Taken from February 1990 Remedial Investigation (RI) Report, Chapter 6. Original risk calculations based
on limited availability of carcinogenic potency information, and computer models noted in Footnote (3). A
fundamental requirement for this remedy is a lagoon area cover that must prevent all unacceptable contact
with contaminated sludge and/or soil.
5 Calculated in 1990 by a computer model ("ISCLT"), that assumed "worst-case" volatilization of organics
from lagoon area sludge.
6 Surface water risks calculated in 1990 by a computer model ("EXAMS-II") that simulated the fate of
contaminants in groundwater discharging to a surface water body. State of Michigan Groundwater-Surface
Water Interface (GSI) Standards will be the performance criteria for this remedy and will insure protection
of Big Black Creek. In addition, the continuation of adequate capture of contaminated groundwater before
discharge to the Creek (which has been in operation since the mid-1970s) is a fundamental requirement for
this remedy, and thus the surface water exposure pathway will continue to be eliminated.
-------
Table B-4: Interim Monitoring Program, Groundwater Monitoring Network
Annual Event (September)
Semi-Annual Event (March)
EW-1
EW-1
EW-2
EW-2
EW-3
EW-3
EW-4
EW-4
EW-5
EW-5
EW-6
EW-6
GSI-3-10
GSI-3-10
GSI-3-20
GSI-3-20
GSI-4-10
GSI-4-10
GSI-4-20
GSI-4-20
MW-124B
MW-125A
MW-125A
MW-125B
MW-125B
MW-131A
MW-128B
MW-18-1-10
MW-129A
MW-18-1-20
MW-130A
WT-1
MW-131A
MW-131C
MW-14-4A
MW-14-4B
MW-18-1-10
MW-18-1-20
MW18-1-81
PW-46
PZ-111A
WT-1
-------
Summary of Groundwater Data: Benzidine
Location
12/1/2017
3/1/2018
6/1/2018
9/1/2018
3/1/2019
1/1/2020
9/1/2020
4/1/2021
9/1/2021
4/1/2022
9/1/2022
EW-1
29.1
4
120
ND
ND
15.4
7
EW-2
25.8
4
417
130
140
18
140
EW-3
18.2
19
2
40
58
35
75
EW-4
23.6
6
60
40
23
ND
60
EW-5
24.2
8
86
41
3.7
13.5
86
EW-6
50.5
16
71
42
ND
1.2
58
GSI-3-10
36.8
36.5
36.1
62.6
4
26
60
19
32
52
69
GSI-3-20
3
ND
ND
ND
3.2
GSI-4-10
25.5
197
159
102
25
98
291
59
180
47.1
183
GSI-4-20
1 274
180
120
210
250
MW-124B
ND
ND
ND
ND
0.4
ND
ND
0.061
ND
MW-125A
20.5
121
146
141
59.1
186
96
18
11
1.4
33
MW-125B
ND
3.7
3
2.6
5.7
3
4
ND
ND
0.3
3.2
MW-128B
ND
ND
ND
ND
ND
0.03
ND
0.0408
0.8
MW-129A
1 153 1
161
00
Lf")
34
MW-130A
| 79.2
83
40
160
MW-131A
| 188
| 534 | 320
370
240
410
MW-131C
| 214
1 297 1
310
56
MW14-4A
ND
ND
1.6
ND
0.6
0.3
2
1
3.5
MW14-4B
ND
2.8
0.66
ND
1.5
3
25
ND
3.2
MW-18-1-10
ND
44
33
7.2
17
95
150
MW-18-1-20
1.2
0.41
1
ND
ND
ND
0.7
MW-18-1-81
0.8
6
9
ND
4
7.4
PW-46
0.95
1.8
1.8
ND
1.4
4
4
1
1
WT-1
81.3
87.9
188
144
ND
128
132
62
43
64
57
Not detected
Detected, below all performance standards
Above IDW and below FCV
Above FCV and below FAV
Above FAV
Table B-4: Summary of OU1 Groundwater Data - Benzidine
-------
Summary of Groundwater Data: 3,3 dichlorobenzidine
Location
12/1/2017
3/1/2018
6/1/2018
9/1/2018
3/1/2019
1/20/2020
9/1/2020
4/1/2021
9/1/2021
4/22/2022
9/1/2022
EW-1
18.2
29
18
ND
10
1.5
26
EW-2
17.4
27
25
22
15
11
4.7
EW-3
6.1
26
6
15
28
20
33
EW-4
6.1
10
11
14
8.9
ND
39
EW-5
27.3
10
42
26
5.2
31.3
43
EW-6
12.1
5
13
5.2
ND
6.84
4.7
GSI-3-10
47.1
61.4
61.3
65.7
32.2
35
31
22
55
38
76
GSI-3-20
ND
14
8.9
11
8.45
13.7
GSI-4-10
0.3
0.62
0.58
ND
4.5
0.18
0.59
ND
ND
ND
1.7
GSI-4-20
47
35
34
55
60
MW-124B
ND
ND
ND
ND
ND
ND
ND
ND
ND
MW-125A
ND
1.3
0.42
ND
13.6
0.15
0.59
ND
1.3
1.3
2.2
MW-125B
5.8
7.7
7.8
6.8
5.5
5
4
3.6
4
7.3
7.6
MW-128B
ND
ND
ND
ND
ND
ND
ND
ND
0.5
MW-129A
2.9
2
3.4
5.2
MW-130A
97.6 |
39
60
87
MW-131A
35
58
58
74
100
100
MW-131C
18
13
ND
1.9
MW14-4A
0.4
1.3
1.6
ND
1
0.5
1
1.2
2
MW14-4B
ND
0.64
0.66
ND
0.5
0.24
3
ND
0.7
MW-18-1-10
ND
9
8
4.9
7.9
8
18
MW-18-1-20
3.4
0.77
1
1.8
ND
2.4
2.3
MW-18-1-81
ND
0.07
ND
1.3
ND
0.5
PW-46
1.8
1.9
2.2
2.1
1.9
1
1
1.5
1.7
WT-1
54.8
5
43.5
19.4
23.5
70
65
9.1
67
84
31
Not detected
Detected, below all performance standards
Above IDW and below FCV
Above FCV and below FAV
Above FAV
Table B-4: Summary of OU1 Groundwater Data - 3,3 dichlorobenzidine
-------
Table B-6
Groundwater and Surface Water Levels
September 2022 Interim Monitoring Report
Bofors Nobel Superfund Site
ID
Reference Elevation (feet MSL)
Elevation of Staff
Staff Gauge
Top Of Casing
Depth to GW
Gauge at 6 ft
Reading
(ft MSL)
(ft BTOC)
(ft MSL)
BBC-2
9/26/2022
620.33
624.63
0.4
619.03
BBC-5
9/26/2022
626.54
0.02
620.56
BBC-6(GSI-4-SW)
9/26/2022
622.53
624.73
1.10
619.83
BBC-7
9/26/2022
622.28
625.65
1.26
620.91
GSI-1-10
9/26/2022
625.30
627.98
6.54
621.44
GSI-1-20
9/26/2022
625.19
627.9
6.37
621.53
GSI-1-30
9/26/2022
625.27
627.8
6.20
621.6
GSI-1-SW
9/26/2022
623.84
625.61
2.40
1.80
622.01
GSI-2-10
9/26/2022
623.82
627.01
5.84
621.17
GSI-2-20
9/26/2022
623.98
626.88
5.73
621.15
GSI-2-30
9/26/2022
624.02
626.63
5.50
621.13
BBC-4/GSI-2-SW
9/26/2022
622.17
626.17
1.37
1.10
621.54
GSI-3-10
9/26/2022
625.19
627.65
7.11
620.54
GSI-3-20
9/26/2022
625.33
628.33
7.75
620.58
GSI-3-30
9/26/2022
625.55
628.02
7.46
620.56
GSI-3-SW
9/26/2022
623.63
623.83
3.40
2.68
621.23
GSI-4-10
9/26/2022
623.10
625.66
5.29
620.37
GSI-4-20
9/26/2022
623.11
625.78
5.56
620.22
GSI-4-30
9/26/2022
623.34
625.82
5.30
620.52
GSI-5-10
9/26/2022
622.90
625.89
5.76
620.13
GSI-5-20
9/26/2022
622.88
625.71
5.34
620.37
GSI-5-30
9/26/2022
622.67
624.88
3.32
621.56
GSI-5-SW
9/26/2022
622.93
623.93
2.17
620.1
MW-122A
9/26/2022
623.34
625.57
4.02
621.55
MW-122B
9/26/2022
623.48
625.43
3.80
621.63
MW-123A
9/26/2022
623.71
624.72
3.66
621.06
MW-123B
9/26/2022
623.18
624.98
3.92
621.06
MW-124A
9/26/2022
621.54
624.6
4.62
619.98
MW-124B
9/26/2022
621.54
623.9
2.27
621.63
MW-125A
9/26/2022
623.46
625.78
5.39
620.39
MW-125B
9/26/2022
623.71
625.59
4.57
621.02
MW-126A
9/26/2022
623.17
626.02
5.81
620.21
MW-126B
9/26/2022
623.35
625.34
3.15
622.19
MW-127A
9/26/2022
627.09
629.71
CO
CO
621.23
MW-127B
9/26/2022
626.99
629.72
8.47
621.25
MW-128A
9/26/2022
644.71
647.42
24.24
623.18
MW-128B
9/26/2022
644.83
647.48
24.33
623.15
MW-128C
9/26/2022
644.82
647.44
24.32
623.12
MW-129A
9/26/2022
632.73
635.1
14.04
621.06
MW-129B
9/26/2022
632.88
635.6
14.46
621.14
MW-129C
9/26/2022
632.84
635.56
14.44
621.12
MW-130A
9/26/2022
629.59
632.41
11.94
620.47
MW-130B
9/26/2022
629.66
632.05
11.81
620.24
MW-130C
9/26/2022
629.64
631.82
11.39
620.43
MW-131A
9/26/2022
630.93
633.83
13.59
620.24
MW-131B
9/26/2022
630.90
633.51
13.15
620.36
MW-131C
9/26/2022
630.89
633.4
13.04
620.36
MW-132A
9/26/2022
638.62
641.01
19.13
621.88
MW-132B
9/26/2022
638.59
640.91
18.98
621.93
MW-132C
9/26/2022
638.67
641.11
19.12
621.99
MW-133A
9/26/2022
630.32
633.22
CO
CO
624.38
MW-133B
9/26/2022
630.44
633.35
8.87
624.48
MW-14-4A
9/26/2022
623.34
625.54
4.81
620.73
MW-14-4B
9/26/2022
623.20
625.3
4.43
620.87
MW-14-5A
9/26/2022
622.36
625.2
4.65
620.55
MW-14-5B
9/26/2022
622.35
625.25
4.08
621.17
MW-14-5C
9/26/2022
622.24
625.21
4.03
621.18
MW-16-01
9/26/2022
636.75
636.36
10.01
626.35
-------
Table B-6
Groundwater and Surface Water Levels
September 2022 Interim Monitoring Report
Bofors Nobel Superfund Site
ID
Date
Reference Elevation (feet MSL)
Elevation of Staff
Staff Gauge
Top Of Casing
Depth to GW
Gauge at 6 ft
Reading
(ft MSL)
(ft BTOC)
(ft MSL)
MW-16-02
9/26/2022
632.90
632.09
5.78
626.31
MW-85A
9/26/2022
653.55
655.47
31.67
623.8
MW-85B
9/26/2022
653.77
655.64
31.40
624.24
MW-85C
9/26/2022
654.77
656.56
31.77
624.79
MW-85D
9/26/2022
623.68
625.52
1.66
623.86
OW-103A
9/26/2022
624.38
627.44
7.11
620.33
OW-111A
9/26/2022
643.36
644.15
DRY
OW-E1
9/26/2022
623.04
1.86
621.18
OW-SW1
9/26/2022
620.34
NM
NM
P-103B
9/26/2022
622.60
627.43
5.75
621.68
P-103C
9/26/2022
622.60
627.95
6.23
621.72
P-103D
9/26/2022
623.91
627.43
6.12
621.31
PT-1
9/26/2022
624.41
627.69
7.13
620.56
PT-2
9/26/2022
624.15
627.24
6.84
620.4
PT-3
9/26/2022
625.16
628.26
7.87
620.39
PT-4
9/26/2022
628.50
631.74
11.55
620.19
PT-5
9/26/2022
627.02
630.07
9.76
620.31
PT-6
9/26/2022
626.18
629.31
9.04
620.27
PT-7
9/26/2022
622.62
625.81
5.19
620.62
PT-8
9/26/2022
623.28
626.09
5.76
620.33
PT-9
9/26/2022
623.71
626.39
6.18
620.21
PT-10
9/26/2022
628.11
630.95
10.66
620.29
PT-11
9/26/2022
623.41
626.24
5.70
620.54
PW-43
9/26/2022
629.76
630.56
16.85
613.71
PW-46
9/26/2022
623.34
629.31
17.15
612.16
PW-47
9/26/2022
622.95
629.69
30.51
599.18
PZ-111A
9/26/2022
651.55
653.12
24.49
628.63
PZ-111B
9/26/2022
651.25
653.63
25.03
628.6
PZ-112A
9/26/2022
649.66
652.84
27.57
625.27
PZ-112B
9/26/2022
649.44
652.44
27.25
625.19
PZ-116A
9/26/2022
632.80
635.43
8.99
626.44
PZ-116B
9/26/2022
633.06
635.48
CO
ix>
CO
626.5
PZ-117
9/26/2022
625.31
627.46
6.29
621.17
PZ-118
9/26/2022
624.98
627.53
7.22
620.31
PZ-119A
9/26/2022
638.79
641.01
13.88
627.13
PZ-119B
9/26/2022
638.82
641.11
13.86
627.25
WEIR/WT-1
9/26/2022
630.53
3.78
N/A
N/A
628.31
WL-1A
9/26/2022
631.09
633.51
8.10
625.41
WL-1B
9/26/2022
631.02
633.58
7.88
625.7
WL-2A
9/26/2022
629.95
632.43
7.27
625.16
WL-2B
9/26/2022
629.89
632.24
7.06
625.18
WL-3A
9/26/2022
629.80
632.64
7.73
624.91
WL-3B
9/26/2022
629.83
632.71
8.75
623.96
WL-6/DT-1
9/26/2022
626.7
3.36
624.06
EW-1
9/26/2022
623.26
625.05
5.96
619.09
EW-2
9/26/2022
623.47
625.39
6.58
618.81
EW-3
9/26/2022
626.19
627.67
8.77
618.90
EW-4
9/26/2022
626.76
628.74
8.63
620.11
EW-5
9/26/2022
625.23
627.14
7.34
619.80
EW-6
9/26/2022
623.27
625.41
6.55
618.86
MW-18-1-10
9/26/2022
623.32
626.25
5.67
620.58
MW-18-1-20
9/26/2022
623.19
625.93
5.38
620.55
MW-18-1-81
9/26/2022
623.22
625.84
5.19
620.65
DT-2
9/26/2022
DRY
624.09
WL-7
9/26/2022
625.18
2
621.18
Notes:
Water levels collected on September 26 & 27, 2022
ft BTOC = Feet below top of casing
ft MSL = Feet below mean sea level NM = Not Monitored
Made by: Kathleen Trowbridge Checked by: PSF
-------
APPENDIX C - SITE INSPECTION
28
-------
Site Inspection Checklist
1. SI I I. INFORMATION
Site name:
Bofors Nobel Inc
Date of inspection:
12/2/2022
Location and Region:
Muskegon, MI
EPA ID:
MID006030373
Agency, office, or company leading the FYR:
EPA
Weather/temperature:
40 F, Partly Cloudy
Remedy Includes: (Check all that apply)
El Landfill cover/containment
~ Monitored natural attenuation
El Access controls
El Groundwater containment
IEI Institutional controls
El Groundwater pump and treatment
~ Surface water collection and treatment
El Vertical barrier walls
~ Other: Click or tap here to enter text.
Attachments:
IEI Inspection team roster attached
~ Site map attached
1
-------
Site Inspection Checklist
II. INTERVIEWS (Chcc
k all thai apply)
1.
O&M Site Manager Steve Finn,
PSDs' project
coordinator, 111211012
Golder Associates
Inc,
Interviewed: M at site ~ at office ^ ^
phone
Phone Number: here to enter text.
Problems, suggestions:
~ Report attached
Site Generally in good condition. Modification to the capture system continue be adjusted
and are showing promise to provide hydraulic capture of GW before the creek. PSDs are
reactivating the direct discharge some time in 2023 and are continuniong to work on the
PSVP, first draft arriving to EPA and EGLE in 2023.
2.
O&M Staff Name ,
, Click or tap to
Title , . 1
enter a date.
Interviewed: ~ at site ~ at office ~ by phone Phone Number: ; here to enter text.
Problems, suggestions:
Click or tap here to enter text.
~ Report attached
3.
Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices, etc.) Fill in all that apply.
Agency: EGLE
Contact: Mark Reimann, PM, Click or tap to enter a c
.ate., P:
Problems, suggestions:
IEI Report attached
See FYR
Agency: EGLE
Contact: Chuck Graff, Geologist, or tap to ente
i" a date., P: Phone Number
Problems, suggestions:
f y 11 f 1." Ai" '("Qti n prp fTi An fpr fpYt
IEI Report attached
i., i J l'i\ U! l.cl|..l 11 CI C LU CI I LCI I.CAL
Agency: Click or tap here to enter text.
Contact: Name , Title , Click or tap to enter
i date., P: Phone Number
Problems, suggestions:
f y 11 f 1." Ai* '("Qti n prp fTi An fpr f'PYt
~ Report attached
i., i J l'i\ UI l.cl|..l 11 CI C LU CI I LCI LCAl.
Agency: Click or tap here to enter text.
Contact: Name , Title , Click or tap to enter
i date., P: Phone Number
Problems, suggestions:
2
-------
Site Inspection Checklist
COMMENTS PROVIDED BY EGLE AS SEPARATE CORRESPONDENCE, NOT INCLUDED
WITH THIS SITE INSPECTION FORM.
4. Other Interviews (optional): ~ Report attached
Click or tap here to enter text.
III. OVSITK IXXTMKNTS & RKCORDS \ MUM- IK 1) (Check all thai apply)
1.
O&M Documents
El O&M manual El Readily available
El Up to date ~ N/A
El As-built drawings El Readily available
El Up to date ~ N/A
IEI Maintenance logs El Readily available
El Up to date ~ N/A
Remarks: ALL SITE DOCUMENTS ARE UP TO DATE AND AVAILABLE ONSITE IN
THE GWTP OPERATIONS OFFICE
2.
Site-Specific Health and Safety Plan
El Readily available
IEI Contingency Plan/Emergency Response Plan
El Readily available
Remarks: ALL SITE DOCUMENTS ARE UP TO DATE AND AVAILABLE ONSITE IN THE
GWTP OPERATIONS OFFICE. ON-SITE DOCUMENTS INCLUDING A SITE SAFETY PLAN.
3.
O&M and OSHA Training Records
~ Readily available
~ Up to date ^ N/A
Remarks: O&M AND OSHA TRAINING RECORDS ARE UP TO DATE AND AVAILABLE
AT BOTH THE GWTP AND CAMUS OFFICES.
4.
Permits and Service Agreements
~ Air discharge permit ~ Readily available
~ Up to date ~ N/A
El Effluent discharge El Readily available
El Up to date ~ N/A
El Waste disposal, POTW El Readily available
El Up to date ~ N/A
~ Other permits: Click or tap here to enter text.
Remarks: They have been given approval to reactivate the discharge permit and they are making
some modification to the discharge system prior to resuming discharge to Black Creek
5.
Gas Generation Records
~ Readily available
~ Up to date El N/A
Remarks: Click or tap here to enter text.
6.
Settlement Monument Records
~ Readily available
~ Up to date El N/A
Remarks: Click or tap here to enter text.
3
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Site Inspection Checklist
7. Groundwater Monitoring Records
El Readily available ~ Up to date D N/A
Remarks: GROUNDWATER MONITORING REPORTS ARE UP TO DATE AND READILY
AVAILABLE AT THE PSDS' PROJECT COORDINATORS OFFICE, WITH COPIES AT EPA
AND EGLE OFFICES
8. Leachate Extraction Records
~ Readily available ~ Up to date IEI N/A
Remarks: Click or tap here to enter text.
9. Discharge Compliance Records
~ Air ~ Readily available ~ Up to date IEI N/A
~Water (effluent) El Readily available ~ Up to date d N/A
Remarks: COPIES OF ANY DISCHARGE PERMITS REQUIRED FOR ANY DISCHARGE TO
THE MUSKEGON COUNTY SYSTEM ARE ON FILE ATTHE PSDS' PROJECT
COORDINATORS OFFICE.
10. Daily Access/Security Logs
El Readily available ~ Up to date ~ N/A
Remarks: THERE IS NO PUBLIC ACCESS TO SITE. SITE IS COMPLETELY FENCED AND
LOCKED, AND REQUIRES CAMUS PERMISSION FOR ACCESS. SITE KEYS ARE ONLY
AVAILABLE TO CAMUS STAFF, PSDS' REPRESENTATIVES AND THEIR ASSOCIATED
CONTRACTOR PERSONNEL. SITE SIGN-IN LOGS ARE MAINTAINED AT THE GWTP. THE
EAST GATE IS KEPT LOCKED.
IV. O&M COSTS
1. O&M Organization
~ State in-house ~ Contractor for State
~ PRP in-house El Contractor for PRP
~ Federal Facility in-house ~ Contractor for Federal Facility
Remarks: Cost Generaly consistent year over year, No significant changes.
2. O&M Cost Records
4
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Site Inspection Checklist
E Readily available [X] Up to date El Funding mechanism/agreement in place
Original O&M cost estimate Original O&M cost estimate $604,800
(TABLE 6, 1999 ROD AMENDMENT)
Total annual cost by year for review period if available
~ Breakdown attached
From
Click or tap to e
date.
To
nter a Click or tap
enter a date.
Total cost
to Click or tap here to
enter text.
From
Click or tap to e
date.
To
nter a Click or tap
enter a date.
Total cost
to Click or tap here to
enter text.
From
Click or tap to e
date.
To
nter a Click or tap
enter a date.
Total cost
to Click or tap here to
enter text.
From
Click or tap to e
date.
To
nter a Click or tap
enter a date.
Total cost
to Click or tap here to
enter text.
From
To
Total cost
Click or tap to enter a Click or tap to
Click or tap here to
enter text.
~ Breakdown attached
~ Breakdown attached
~ Breakdown attached
~ Breakdown attached
~ Breakdown attached
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons:
No unanticipated or unusually high O&M costs
V. A( ( i:ss AM) INSTI I I TIOWI. CON
1 UOI.S
E Applicable
~ N/A
1.
Fencing Damaged ~ Location shown on site map
Remarks: No Fence Damage Observed
E Gates secured ~ N/A
2.
Other Access Restrictions ~ Location shown on site map
Remarks: Signage is inplace and in good condition.
~ Gates secured
3.
Institutional Controls (ICs)
A. Implementation and Enforcement
Site conditions imply ICs not properly implemented
~ Yes IE No ~ N/A
Site conditions imply ICs not being fully enforced
~ Yes IEI No ~ N/A
Type of monitoring {e.g., self-reporting, drive by)
Self Reporting and Inspections
Frequency
GW treatment staff onsite daily
Responsible party/agency
PSD Group
5
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Site Inspection Checklist
Contact: Steven Finn, PSDs' project coordinator, Golder Associates Inc, Click or tap to enter a date.,
P:6094409251
Reporting is up-to-date El Yes ~ No ~ N/A
Reports are verified by the lead agency ^ Yes ~ No ~ N/A
Specific requirements in deed or decision documents have been ^ yes ~ n0 ~
met
Violations have been reported D Yes El No ~ N/A
Other problems or suggestions:
None ICIAP approved 2018
B. Adequacy ^ ICs are adequate ~ ICs are inadequate ~ N/A
Remarks: Click or tap here to enter text.
4.
General
A. Vandalism/Trespassing ~ Location shown on site map El No vandalism evident
Remarks: Click or tap here to enter text.
B. Land use changes on site IEI N/A
Remarks: No land use changes noted
C. Land use changes off site IEI N/A
Remarks: None
vi. (;i:m:uai. sin: conditions
i.
Roads El Applicable ~ N/A
A. Roads damaged ~ Location shown on site map El Roads adequate ~ N/A
Remarks: Click or tap here to enter text.
B. Other Site Conditions
Remarks: GENERALY GOOD CONDITION
Ml. LANDI ILL (OM RS
1.
Landfill Surface El Applicable ~ N/A
A. Settlement (Low Spots) ~ Location Shown on Site Map El Settlement Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
B. Cracks ~ Location Shown on Site Map El Cracking Not Evident
Lengths: or tap here Widths: Click or tap here to enter text. Depths: Click or tap here to enter
6
-------
Site Inspection Checklist
to enter text.
text.
Remarks: Click or tap here to enter text.
C. Erosion ~ Location Shown on Site Map El Erosion Not Evident
Areal Extent: Click or tap here to enter text.
Depth: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
D. Holes ~ Location Shown on Site Map El Holes Not Evident
Areal Extent: Click or tap here to enter text.
Depth: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
E. Vegetative Cover El Grass
El Cover Properly Established
~ Tress/Shrubs (indicate size and locations on a diagram
El No Signs of Stress
Remarks: Click or tap here to enter text.
F. Alternative Cover (armored rock, concrete, etc.)
El N/A
Remarks: Click or tap here to enter text.
G. Bulges ~ Location Shown on Site Map IEI Bulges Not Evident
Areal Extent: Click or tap here to enter text.
Height: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
H. Wet Areas/Water Damage IEI Wet Areas/Water Damage Not Evident
~ Wet Areas ^ Location Shown on Site Map
Areal Extent: Click or tap here to enter
text.
~ Ponding D Location Shown on Site Map
Areal Extent: Click or tap here to enter
text.
~ Seeps n Location Shown on Site Map
Areal Extent: Click or tap here to enter
text.
~ Soft Subgrade ^ Location Shown on Site Map
Areal Extent: Click or tap here to enter
text.
Remarks: Click or tap here to enter text.
I. Slope Instability ~ Location Shown on Site Map
El Slope Instability Not Evident
~ Slides
Areal Extent: Click or tap here to enter
text.
Remarks: Click or tap here to enter text.
2. Benches ~ Applicable
El N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
7
-------
Site Inspection Checklist
A. Flows Bypass Bench ~ Location Shown on Site Map El N/A or Okay
Remarks: Click or tap here to enter text.
B. Bench Breached ~ Location Shown on Site Map El N/A or Okay
Remarks: Click or tap here to enter text.
C. Bench Overtopped ~ Location Shown on Site Map IEI N/A or Okay
Remarks: Click or tap here to enter text.
3. Letdown Channels IEI Applicable ~ N/A
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover
without creating erosion gullies.)
A. Settlement ~ Location Shown on Site Map El Settlement Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
B. Material Degradation ~ Location Shown on Site Map El Degradation Not Evident
A,r • 1 m r~.t- 1 -i ¦ ¦ ¦ Areal Extent: Click or tap here to enter
Material Type: Click or tap here to enter text.
J r ' text.
Remarks: Click or tap here to enter text.
C. Erosion ~ Location Shown on Site Map El Erosion Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
D. Undercutting ~ Location Shown on Site Map El Undercutting Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
E. Obstructions ~ Location Shown on Site Map El Undercutting Not Evident
Type: Click or tap here to enter text.
Areal Extent: Click or tap here to enter text. Size: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
F. Excessive Vegetative Growth ~ Location Shown on Site Map El Excessive Growth Not Evident
a 1 -|—i j * j , El Vegetation in channels does not obstruct
Areal Extent: Click or tap here to enter text.
flow
Remarks: INSTALLED VEGETATION ON SITE DOES NOT OBSTRUCT STORM WATER
RUNOFF CONTROLS.
8
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Site Inspection Checklist
4. Cover Penetrations
~ Applicable IEI N/A
A. Gas Vents
~ Active
~ Passive
~ Properly secured/locked
~ Functioning ~ Routinely sampled
~ Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
El N/A
Remarks: Click or tap here to
enter text.
B. Gas Monitoring Probes
~ Properly secured/locked
~ Functioning ~ Routinely sampled
~ Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
El N/A
Remarks: Click or tap here to
enter text.
C. Monitoring Wells
El Properly secured/locked
El Functioning El Routinely sampled
El Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
~ N/A
Remarks: Click or tap here to
enter text.
D. Leachate Extraction Wells
~ Properly secured/locked
~ Functioning ~ Routinely sampled
~ Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
El N/A
Remarks: Click or tap here to
enter text.
E. Settlement Monuments
~ Located
~ Routinely Surveyed El N/A
Remarks:
5. Gas Collection and Treatment
~ Applicable IEI N/A
A. Gas Treatment Facilities
~ Flaring
~ Thermal Destruction ~ Collection for Reuse
~ Good condition
~ Needs Maintenance
Remarks: No call out if system down. Checked regularly almost daily. If system down interlocked to
blower to stop. Staff can restart with LP. Methane will keep the flare going
B. Gas Collection Wells, Manifolds, and Piping
9
-------
Site Inspection Checklist
~ Good condition ~ Needs Maintenance
Remarks: Click or tap here to enter text.
~ N/A
C. Gas Monitoring Facilities (e.g. gas monitoring of adjacent homes or buildings)
~ Good condition ~ Needs Maintenance ~ N/A
Remarks: Click or tap here to enter text.
6. Cover Drainage Layer
~ Applicable
El N/A
A. Outlet Pipes Inspected ~ Functioning
Remarks: Click or tap here to enter text.
~ N/A
B. Outlet Rock Inspected ~ Functioning
Remarks: Click or tap here to enter text.
~ N/A
7. Detention/Sediment Ponds
El Applicable
~ N/A
A. Siltation IEI Siltation Not Evident ~ N/A
Areal Extent: Click or tap here to enter text. Depth: : or tap here to enter text.
Remarks: Click or tap here to enter text.
B. Erosion IEI Erosion Not Evident
Areal Extent: Click or tap here to enter text. Depth: : or tap here to enter text.
Remarks: Click or tap here to enter text.
C. Outlet Works El Functioning
Remarks: Click or tap here to enter text.
~ N/A
D. Dam El Functioning
Remarks: TREATMENT WETLAND Wier Funtioning
~ N/A
8. Retaining Walls
~ Applicable
El N/A
A. Deformations ~ Location Shown on Site Map
Horizontal Displacement: Click or tap here to enter text.
Vertical Displacement: Click or tap here to enter text.
Rotational Displacement: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
~ Deformation Not Evident
B. Degradation ~ Location Shown on Site Map
Remarks: Click or tap here to enter text.
El Deformation Not Evident
9. Perimeter Ditches/Off-Site Discharge
~ Applicable
10
El N/A
-------
Site Inspection Checklist
A. Siltation ~ Location Shown on Site Map
~ Siltation Not Evident
Areal Extent: Click or tap here to enter text.
Depth: Click
:»r tap here to enter text.
Remarks: Click or tap here to enter text.
B. Vegetative Growth ~ Location Shown on Site Map
~ N/A
~ Vegetation Does Not Impede Flow
Areal Extent: Click or tap here to enter text.
Type: Click o
" tap here to enter text.
Remarks: Click or tap here to enter text.
C. Erosion ~ Location Shown on Site Map
~ Erosion Not Evident
Areal Extent: Click or tap here to enter text.
Depth: Click
:»r tap here to enter text.
Remarks: Click or tap here to enter text.
D. Discharge Structure ~ Functioning
El N/A
Remarks: Will be put back in to Service in 2023
Mil. VERTICAL BARRIER WALLS
El Applicable
~ N/A
1.
Settlement ~ Location Shown on Site Map
El Settlement Not Evident
Areal Extent: Click or tap here to enter text.
Depth: CI
ck or tap here to enter text.
Remarks: Click or tap here to enter text.
2.
„ . ^ . Type of Monitoring: GROUNDWATER CHEMISTRY AND GROUND
Performance Mon.tor.ng w^reR ELEVA1?I0NS
~ Performance Not Monitored
~ Evidence of Breaching
Head Differential: 2022 GROUNDWATER
ELEVATION DATA COLLECTED SHOWED A
Frequency: Annually
GENERAL HEAD DIFFERENTIAL VARYING
FROM APPROXIMATELY 3 TO 5 FEET,
WITH THE HIGHER GROUNDWATER
ELEVATION INSIDE THE BARRIER WALL.
Remarks: Click or tap here to enter text.
I\. GROl \I>WATER/Sl Rl ACE WATER REMEDIES
IEI Applicable
~ N/A
1.
Groundwater Extraction Wells, Pumps, and Pipelines ~ Applicable ~ N/A
A. Pumps, Wellhead Plumbing, and Electrical
~ N/A
IEI Good Condition El All Required Wells Properly Operating ~ Needs Maintenance
-------
Site Inspection Checklist
Remarks: Click or tap here to enter text.
B. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
El Good Condition
~ Needs Maintenance
Remarks: Click or tap here to enter text.
C. Spare Parts and Equipment
~ Needs to be Provided
IEI Readily Available El Good Condition
~ Requires Upgrade
Remarks: Click or tap here to enter text.
2. Surface Water Collection Structures, Pumps, and Pipelines
~ Applicable El N/A
A. Collection Structures, Pumps, and Electrical
~ Good Condition ~ Needs Maintenance
Remarks: Click or tap here to enter text.
B. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good Condition ~ Needs Maintenance
Remarks: Click or tap here to enter text.
C. Spare Parts and Equipment
~ Needs to be Provided
~ Readily Available ~ Good Condition
~ Requires Upgrade
Remarks: Click or tap here to enter text.
3. Treatment System IEI Applicable
~ N/A
A. Treatment Train (Check components that apply)
El Metals removal ~ Oil/Water Separation
~ Bioremediation
El Air Stripping El Carbon Absorbers
El Filters Click or tap here to enter text.
El Additive (e.g. chelation agent, flocculent) SULFURIC ACID, FLOC POLYMER, SODIUM
HYDROXIDE, HYDROGEN PEROXIDE
~ Others UV/OZONE SYSTEM IS SHUT DOWN
El Good Condition
~ Needs Maintenance
El Sampling ports properly marked and functional
El Sampling/maintenance log displayed and up to date
El Equipment properly identified
El Quantity of groundwater treated annually 9,300,000 (2021)
12
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Site Inspection Checklist
~ Quantity of surface water treated annually Click or tap here to enter text.
Remarks: or tap here to enter text.
B. Electrical Enclosures and Panels (properly rated and functional)
~ N/A El Good Condition ~ Needs Maintenance
Remarks: or tap here to enter text.
C. Tanks, Vaults, Storage Vessels ~ N/A
~ Proper Secondary Containment IEI Good Condition ~ Needs Maintenance
Remarks: Some metal oxidation seen on piping, PSD indicated that they are in the process of repainting
piping.
D. Discharge Structure and Appurtenances
IEI N/A ~ Good Condition ~ Needs Maintenance
Remarks: GWTP WAS NOT DISCHARGING TO BLACK CREEK DURING THE INSPECTION
BUT MAY RESUME IN 2023
E. Treatment Building(s)
~ N/A
~ Needs repair
Remarks or tap here to enter text
F. Monitoring Wells (Pump and Treatment Remedy) ~ N/A
~ Properly secured/locked El Functioning
El Routinely sampled ~ All required wells located
El Good condition ~ Needs Maintenance
Remarks SOME MONITORIGN WELLS WERE OBSEREVED TO BE UNLOCKED. PSD
REPRESENTATIVES INDICATED THAT ALL UNLOOCKED WELLS WERE WITHIN THE
FENCED AREA HOWEVER J.THOMAS LOCATED ONE (GSI 20) THAT WAS OUTSIDE THE
FENCED AREA AND UNLOCKED. PSD REP SAID THEY WOULD INVENTORY ALL LOCKS
AND REPLACE ONES THAT ARE BROKEN
4. Monitoring Data
A. Monitoring Data:
El Is Routinely Submitted on Time
~ Is of Acceptable Quality
B. Monitoring Data Suggests:
El Groundwater plume is effectively contained
El Contaminant concentrations are declining
5. Monitored Natural Attenuation
El Good condition (esp. roof and doorways)
El Chemicals and equipment properly stored
13
-------
Site Inspection Checklist
A. Monitoring Wells (natural attenuation remedy)
~ Properly secured/locked ~ Functioning
~ All required wells located ~ Needs Maintenance
Remarks: Click or tap here to enter text.
X. Oil IKU KIM IM)I I S
If there are remedies applied at the site which are not covered above, attach an inspection sheet
describing the physical nature and condition of any facility associated with the remedy. An example
would be soil vapor extraction.
XI. OVKRAI.I. OliSKKYATIONS
1. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
ADDRESSED IN 2023 FYR DOCUMENT
2. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
ADDRESSED IN 2023 FYR DOCUMENT
3. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.
NONE NOTED DURING INSPECTION
4. Early Indicators of Potential Remedy Problems
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None
Other Notes ADDRESSED IN 2023 FYR DOCUMENT
M N/A
~ Routinely sampled
~ Good condition
14
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Site: Bofors Nobel Inc FYR Site Inspection, Muskegon, MI
Date: 12/2/2022
Start Time: 0900
End Time: 1200
Attendees:
Jeff Thomas - EPA Region 5
Stephen Finn - Golder
Mark Reimann - EGLE
Chuck Graff - EGLE
Zachary Cain - U.S. Water Services Corporation Industrial Group
Stephen Luke - Camus Water Technologies
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2, 2022
Photo
No.
1
Direction
Photo
Taken:
NE
¦^hhhi
Description:
Treatment
wetland
Site Name: Date:
Bofors Nobel Superfund Site December 2, 2022
Photo
No.
2
Direction
Photo
Taken:
NW
Description:
Treatment
wetland
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2, 2022
Photo
No.
3
Descrip
Treating
wetland
gate.
Direction
Photo
Taken:
N
(looking
down)
tion:
;nt
weir
^S^StSBgF
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
4
Direction
Photo
Taken:
SE
hmbbmmmbbbmmmmbbbbhbmbmmmimmbhmmhmbmhmmbbhmbhbbmhbhi
H^H
Description:
New backwash
system outfall.
-------
Site Name:
Bofors Nobel Superfund Site
Date:
December 2, 2022
Photo
No.
5
Direction
Photo
Taken:
w
Description:
View of
Treatment
Wetland from
the shore
adjacent to the
new backwash
outfall
¦ffaqllgls
—JMWi
atis
Site Name:
Bofors Nobel Superfund Site
Date:
December 2, 2022
Photo
No.
6
Direction
Photo
Taken:
s
Description:
General Meander
Bend Area
(MBA) photo
aMggKmgm«mM
MMML
—J—
¦
¦HI
gfpll«
in
i
lisi Willi
—
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
7
Descrip
MBA a(
road wi1
Direction
Photo
Taken:
SE
tion:
xess
.h wells.
WM
Site Name:
Bofors Nobel Superfund Site
Date:
December 2. 2022
Photo
No.
8
Direction
Photo
Taken:
N
Description:
PT 10 lock
unlocked (behind
fenced area)
—
Bii»M
|8gHn
wHim
¦¦H
¦WBHBpBBPwBre
——
¦H
mm
¦
MBBM
—>
WBBBWHBBL
^ip
•swan
¦¦iff mmBfflmm
mMSHI
¦¦JBHP™111
I
tfdw
-------
¦¦¦¦¦¦¦¦¦HI
H^H
nun—
J^raHBHi
pMfpMBPJJpWJBWMKjf f;
¦PMM1
gjj^
¦I
¦¦i
.M£*!b6J&:> V!
ggm
M:
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2,2022
Photo
No.
11
Direction
Photo
Taken:
In
Building
ui jMI
1 i i m
CT ¦! ¦ .-J, ' * "V—A_ 1|Jf
Description:
General pump
house valve
manifold
rT' ? f" i
Lu \ r /i
if* fTp | /
1 T Jv
Site Name: Date:
Bofors Nobel Superfund Site December 2,2022
Photo
No.
12
Direction
Photo
Taken:
In
Building
i iw^
V ••finl ¦ I A|| t "^<05
1
Description:
General pump
house control
panel
^gfj | :f
v fcLt -
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2, 2022
Photo
No.
13
Direction
Photo
Taken:
SE
-MBKBMBMlililBMHHBBiEHHBPBpKBMwiHPBKwHHHi
Description:
PW 47
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
14
Direction
Photo
Taken:
N
- Ktv • * > —
$. .....'- -"*•
Sfcwi^B
Description:
EW-6
-------
Description:
EW-5
HKyMBBMMMMMBI
MMMflBMMWi
B9HHPMI
^n
Site Name:
Bofors Nobel Superfund Site
Date:
December 2, 2022
Photo Direction
no. p^0
16 s," '
Description: BBBBBBBflBBBBBBBBBBBBBBBBBBBBBBBIBMBI
Wells on western
side of the MBA BI^^^^BBBBBIBBBBBBBUBMBi
WBMBWWi
¦HHHH^H^Hh
1^—^——
^»lBllliiMllllgi -1 Bill
¦^¦"¦THWlHra
Mm
m—
¦¦¦¦¦HNHHHHHHiHHHiH
¦¦
¦
,
¦I
Bam&MaMWgg
ysH|
9|pl
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2, 2022
Photo
No.
17
Direction
Photo
Taken:
s
¦¦HMK^—1
1 Y-r^BKa
< » ,'*\. »,' >. w
Description:
Wells outside the
gated area that
that were not
locked.
Site Name:
Bofors Nobel Superfund Site
.-¦J",
Date:
December 2. 2022
Photo
No.
18
Direction
Photo
Taken:
w
Description:
OU1 lagoon 4
—BBBBBMBBBwBi
bmmmbhi
WtKttBKKMtttKM
¦HSflHHIP^HH
Mbhh
IMMH1
-------
Site Name:
Bofors Nobel Superfund Site
Date:
December 2, 2022
Photo
No.
19
Direction
Photo
Taken:
E
Description:
Representative
picture of OU1
cap
- »•_ " * ( - , *. - - f , - J
Site Name:
Bofors Nobel Superfund Site
Date:
December 2, 2022
Photo
No.
20
Direction
Photo
Taken:
s
Description:
Representative
picture of OU1
cap
-------
Site Name:
Bofors Nobel Superfund Site
Date:
December 2,2022
Photo
No.
21
Direction
Photo
Taken:
In
Building
Description:
Treatment plant
process diagram
»
—
¦II
H
Site Name: Date:
Bofors Nobel Superfund Site December 2,2022
Photo
No.
22
Direction
Photo
Taken:
In
Building
Description:
Bult dry storage
-------
Site Name:
Bofors Nobel Superfund Site
Date:
December 2,2022
Photo
No.
23
Direction
Photo
Taken:
In
Building
Description:
Influent Piping
—
¦EHPBBi
¦
Site Name:
Bofors Nobel Superfund Site
Date:
December 2,2022
Photo
No.
24
Direction
Photo
Taken:
In
Building
Description:
Front of
treatment train.
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2,2022
Photo
No.
25
Direction
Photo
Taken:
In
Building
Description:
Sand Filters
Site Name: Date:
Bofors Nobel Superfund Site December 2,2022
Photo
No.
26
Direction
Photo
Taken:
In
Building
—M—
jjj|jj^^
Description:
Granular
activated carbon
units.
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2,2022
Photo
No.
27
Direction
Photo
Taken:
In
Building
Description:
Solid contact unit
2
%- ¦ ^ !i^§i
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
28
Direction
Photo
Taken:
In
Building
~
* *' * vi, -'''j&ik
Description:
Recycled water
manifold
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
29
Direction
Photo
Taken:
In
Building
: % ---: >^ ; ;. .-r-vv. llllll fHH
:!>l ^ ' :< - MBI
dillliiA?'*':*: - - : 1 «(Br
-y
Description:
Outfall from
treatment plant.
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
30
Direction
Photo
Taken:
N
'"' ''** - ...... ---¦¦' '¦
Description:
OU2 Process
water piping
infrastructure.
-------
Site Name:
Bofors Nobel Superfund Site
Date:
December 2, 2022
Photo
No.
31
Direction
Photo
Taken:
N
Description:
OU2 Process
water piping
infrastructure.
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
32
Descrip
OU2 an
highest
contami
Direction
Photo
Taken:
NE
tion:
ia of
surface
nation.
-------
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
33
Direction
Photo
Taken:
E
SSI
Description:
OU2 Paved area
maintained by
SUN and
overseen by the
state.
Site Name:
Bofors Nobel Superfund Site
Date:
December 2. 2022
Photo
No.
34
Direction
Photo
Taken:
s
Description:
OU2 Former
Tank Farm
Location
&MP
-------
Site Name:
Bofors Nobel Superfund Site
Date:
December 2, 2022
Photo
No.
35
Direction
Photo
Taken:
s
Description:
OU2 Process
water tank in use
when OU1 water
is used by SUN.
1111
Site Name: Date:
Bofors Nobel Superfund Site December 2. 2022
Photo
No.
36
Direction
Photo
Taken:
w
yV.*'- A-: ¦ - „ iJaMMBHWaBI
Description:
OU2 looking
west to Sun
Chemical
-------
Site Name:
Bofors Nobel Superfund Site
Date:
December 2, 2022
Photo
No.
37
Direction
Photo
Taken:
s
Description:
Warning Sign on
the Northern
Fence
•- WARNING »
a must be conducted pursuant I
i* Property commonly referred lo a!
tied Area are shown generally beto'
a plan approved by the U.S. EPA on
cover, the soil cover shall be restored within 72 hours. This Property is
MOEQ Site ID number 61000006 and contain* lam! use restrictions set t
Covenant and Easement found in the Muskegon County Register ot Deei
Page 942 (pagrc 1 ihrough 284).
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