994062
FIFTH FIVE-YEAR REVIEW REPORT FOR
BENDIX CORP./ALLIED AUTOMOTIVE SUPERFUND SITE
BERRIEN COUNTY, MICHIGAN
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Prepared by
U.S. Environmental Protection Agency
Region 5
CHICAGO, ILLINOIS
8/1/2024
X Douglas Ballotti
Douglas Ballotti, Director
Superfund & Emergency Management Division
Signed by: DOUGLAS BALLOTTI
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Table of Contents
LIST OF ABBREVIATIONS & ACRONYMS 2
I. INTRODUCTION 5
FIVE-YEAR REVIEW SUMMARY FORM 6
II. RESPONSE ACTION SUMMARY 7
Basis for Taking Action 7
Response Actions 8
Status of Implementation 9
Institutional Controls 12
Systems Operations/Operation & Maintenance 17
III. PROGRESS SINCE THE LAST REVIEW 18
IV. FIVE-YEAR REVIEW PROCESS 28
Community Notification, Involvement & Site Interviews 28
Data Review 28
Site Inspection 37
V. TECHNICAL ASSESSMENT 38
QUESTION A: Is the remedy functioning as intended by the decision documents? 38
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? 40
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 42
VI. ISSUES/RECOMMENDATIONS 43
OTHER FINDINGS 47
VII. PROTECTIVENESS STATEMENT 48
VIII. NEXT REVIEW 48
APPENDIX A - REFERENCE LIST 49
APPENDIX B - SITE LOCATION AND FEATURES 51
APPENDIX C - ALTERNATE CONCENTRATIONS LIMITS (ACLs) 52
APPENDIX D - MAP OF INSTITUTIONAL CONTROLS 53
APPENDIX E - JUNE 2007 ADVISORY LETTER FROM MDCH AND ATSDR 54
APPENDIX F - FORMER FOUNDRY AND COVER AREA 55
APPENDIX G - SUMMARY OF FOUNDRY/COVER DEMOLITION WASTES 56
APPENDIX H - SOIL EXCAVATION AREAS DURING FOUNDRY COVER REMOVAL 57
APPENDIX I - SURFACE WATER SAMPLING LOCATIONS 2020 58
APPENDIX J - PORE WATER SAMPLING LOCATIONS (2000-2004) 59
APPENDIX K - GROUNDWATER SAMPLING LOCATIONS & STATISTICS 60
APPENDIX L-TREND PLOTS FOR SELECTED MONITORING LOCATIONS 61
APPENDIX M - TOTAL VOCS REMOVED BY MRS AUGUST 2009 TO DECEMBER 2022 62
APPENDIX N - SOIL VAPOR SAMPLING LOCATIONS 63
APPENDIX O - SITE INSPECTION FORM 64
APPENDIX P - SITE PHOTOGRAPHS & PRP PRESENTATION 65
APPENDIX Q - FYR NOTIFICATION 66
APPENDIX R - REVISED PLUME MAPS 67
APPENDIX S - POTENTIAL SOURCE AREAS REQUIRING FURTHER INVESTIGATION 68
APPENDIX T - EGLE FYR RECOMMENDATIONS 69
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LIST OF ABBREVIATIONS & ACRONYMS
ACL Alternate Concentration Limit
ARAR Applicable or Relevant and Appropriate Requirement
ATSDR Agency for Toxic Substances and Disease Registry
BGWDCP Baseline Groundwater Data Collection Program
Bosch Robert Bosch LLC
CatOx Catalytic thermal oxidizer (for treatment of vapor-extracted organic contaminants)
CD Consent Decree
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CPC Compound of Potential Concern
cVOCs Chlorinated Volatile Organic Compounds
DCA Dichloroethane
DCE Dichloroethene
EGLE Environment, Great Lakes, and Energy (Department of, State of Michigan)
EPA United States Environmental Protection Agency
EPE/DRC Environmental Protection Easement and Declaration of Restrictive Covenant
ESD Explanation of Significant Differences
FYR Five-Year Review
gpm Gallons per Minute
ICIAP Institutional Control Implementation and Action Plan
ICs Institutional Controls
LTS Long-Term Stewardship
MCL Maximum Contaminant Level
MDCH Michigan Department of Community Health
MDEQ Michigan Department of Environmental Quality
MNA Monitored Natural Attenuation
MRS Mass Reduction System
NAPL Non-aqueous Phase Liquid
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
O&M Operation and Maintenance
PCBs Polychlorinated biphenyls
PCE Tetrachloroethene
PFAS Per-and Polyfluoroalkyl Substances
POC Point of Compliance
PRP Potentially Responsible Party
QAPP Quality Assurance Project Plan
RAO Remedial Action Objective
ROD Record of Decision
RPM Remedial Project Manager
Site Bendix Corp./Allied Automotive Superfund Site
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SLERA
Screening Level Ecological Risk Assessment
SVE
Soil Vapor Extraction
TBC
To be considered
TCA
Trichloroethane
TCE
Trichloroethene
UU/UE
Unlimited Use and Unrestricted Exposure
VC
Vinyl Chloride
VOC
Volatile Organic Compound
W&C
Woodard & Curran
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a
remedy in order 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 U.S. Environmental Protection Agency (EPA) 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 fifth FYR for the Bendix Corp./Allied Automotive Superfund Site (Bendix or Site). The
triggering action for this statutory review is the completion date of the previous FYR. The FYR has been
prepared due to the fact that 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 one sitewide operable unit (OU) encompassing contaminated soil, sediment,
surface water, and groundwater that will be addressed in this FYR.
The Bendix Corp./Allied Automotive Superfund Site FYR was led by Joseph Kelly of EPA. Participants
included:
Samantha Belisle, Superfund Project Manager, Michigan Department of Environment, Great
Lakes, and Energy (EGLE).
EGLE and representatives of the potentially responsible party (PRP), Robert Bosch LLC (Bosch) were
notified of the initiation of the five-year review, in addition to a Trustee of Lincoln Charter Township.
The review began on 8/11/2023.
Site Background
The Site is located at 3737 Red Arrow Highway, in Berrien County, Michigan, approximately four miles
south of the city of St. Joseph. The property consists of four parcels, including a 37.17-acre parcel with
factory buildings, two parcels containing a 7.93-acre parking lot, and a 7.10-acre former landfill used by
Bendix for disposal of foundry sand and asbestos, located adjacent to Hickory Creek, separate from and
East of the main parcels of the Site. The Site is located approximately one-half mile from the eastern
shore of Lake Michigan. Hickory Creek is located approximately 900 feet east of the Site's eastern
property boundary.
Land use in the vicinity of Site is a mixture of commercial, residential, and industrial. Several residential
areas, including the Churchill Farms and Lake Bluff Terrace subdivisions as well as other private
residences, are located between the Site and Lake Michigan. The area in the vicinity of the Site is
primarily supplied with municipal water from St. Joseph. The source of the municipal water is Lake
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Michigan, and the nearest surface water intake is 3.5 miles north of the Site, and northeast of the area
where contaminated groundwater from the Site discharges into the lake. It is anticipated that use of
the Site for industrial purposes will continue in the future.
The Site was first used for manufacturing by the Nylen Products Corporation in 1939, when it was the
location of an iron casting foundry and machine shop for the manufacturing of precision automotive
and refrigeration products, including heat-treated pistons. The Bendix Corporation (Bendix) purchased
the property from Nylen in approximately 1952 for continued automotive parts manufacturing. By
1967, the western 2/3 of the property was developed with a manufacturing building and the northeast
1/3 of the property was developed with a foundry, with one waste lagoon located between the two
buildings in the northern part of the site, and one located south of the foundry. In 1971, Bendix
acquired a permit to operate a landfill south of Maiden Lane and adjacent to Hickory Creek, for
disposal of foundry residues and asbestos brake materials and pellets. In the early 1970s, a machine
shop expansion and loading docks were added primarily to the eastern part of the main building,
covering one former lagoon, and a much larger lagoon system was installed over most of the southern
property boundary until the late 1970s, when the system was closed and capped. In 1979, the Maiden
Lane asbestos landfill was closed. In 1983, Bendix was acquired by Allied Chemical. Robert Bosch
Corporation purchased the property from Allied Chemical's successor, AlliedSignal, Inc. in 1996.
According to Bosch, the company has since converted to a limited liability corporation (Robert Bosch,
LLC). Currently, the facility at the Site is still operating as an automotive brake manufacturer under
Bosch, who is the current PRP. The foundry was later demolished in approximately 2008.
Additional background information may be found in the various documents identified in Appendix A -
Reference List, and a site figure depicting the major site features is included as Figure 1 in Appendix B.
FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name: Bendix Corp./Allied Automotive
EPA ID: MID005107222
Region: 5
State: Ml
City/County: St. Joseph, Berrien County
NPL Status: Final
Multiple OUs?
No
Lead agency: EPA
Has the site achieved construction completion?
Yes
Author name: Joseph Kelly
Author affiliation: EPA
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Review period: 8/11/2023 - 4/4/2024
Date of site inspection: 9/12/2023
Type of review: Statutory
Review number: 5
Triggering action date: 8/20/2019
Due date (five years after triggering action date): 8/20/2024
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
Hazardous substances have been released to soil and groundwater at the Site. These substances
include chlorinated solvents, including but not limited to trichloroethene (TCE) and 1,1,1-
trichloroethane (1,1,1-TCA) and their degradation products, cis-l,2-dichloroethene (cis-l,2-DCE), trans-
1,2-dichloroethene (trans-l,2-DCE), 1,1-dichloroethane (1,1-DCA), and vinyl chloride (VC). A source of
contamination to groundwater is thought to be non-aqueous phase liquid (NAPL), which refers to free-
phase product that is adsorbed to subsurface materials and slowly dissolves over time. Light non-
aqueous phase liquid (LNAPL) floats on top of groundwater, while dense non-aqueous phase liquid
(DNAPL) sinks through the subsurface and collects in low areas when a confining layer, such as clay, is
encountered.
Contaminated media identified in connection with the site include soil, sediment, surface water, and
groundwater. At the time of remedy selection (EPA, 1997), EPA evaluated the impacts in these media
and determined that no active remedial action was necessary under the conditions at that time to
protect human health for the following media and exposure scenarios:
• Site Soils, for Utility Worker exposures through soil contact/ingestion/inhalation.
• Sediments/Surface Water in Hickory Creek, for Children under Recreational scenarios, through
surface water contact/ingestion and sediment ingestion.
• Surface Water in Lake Michigan, for Children and Adults under Recreational scenarios, through
surface water contact/ingestion.
Contaminants of concern (COCs) detected in groundwater required the selection of a remedy to
address the Drinking Water Scenario via groundwater contact/ingestion/inhalation for the following
contaminants:
Western Groundwater Plume
• Vinyl chloride
• 1,2-DCE (total)
• TCE
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• 1,1-DCE
• 1,1,2-TCA
• Benzene
Eastern Groundwater Plume
• Vinyl chloride
• 1,1-DCE
• 1,2-DCE (total)
• TCE
• Arsenic
• Manganese
An Ecological Risk Assessment completed by the PRP prior to the remedy selection concluded that
contaminant concentrations in Hickory Creek and Lake Michigan surface water and sediments did not
pose a significant threat to the environment (EPA, 1997).
Response Actions
The earliest response action was in the 1980s, when TCE contamination was identified in a well on an
adjacent industrial property by the Berrien County Health Department, and the PRP connected several
residences to the St. Joseph municipal water supply, with several additional residential wells connected
later in 1997. The Bendix site was listed on the National Priorities List (NPL) on February 21, 1990.
EPA signed a Record of Decision (ROD) in 1997 (1997 ROD) with the following general remedial action
objective (RAO)s (EPA, 1997):
• Eliminate potential risks to human health associated with exposure to volatile organic
compounds (VOCs) in the Eastern Groundwater Plume and Western Groundwater Plume.
• Reduce VOCs in groundwater plumes to achieve drinking water standards.
• Control the VOC source of contaminants.
The components of the selected remedy included:
• Monitored natural attenuation (MNA) for the Eastern and Western Groundwater Plumes.
• Long-term monitoring of groundwater to evaluate the effectiveness of MNA.
• Institutional controls (ICs) to prevent exposure.
• Operation of a soil vapor extraction (SVE) system to address the inferred source of the Eastern
Groundwater Plume.
• Maintenance of the existing cover system, consisting of asphalt, concrete slab, and existing
buildings.
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• Requirement for a contingency remedial action if exceedances of criteria are observed in point
of compliance wells.
The cleanup levels selected for constituents considered to be the primary contaminants of concern
(COCs) in groundwater in the 1997 ROD in the Site's two plumes are shown in Table 1. Other
contaminants, such as arsenic, benzene, 1,1,2-TCA, 1,1,1-TCA and manganese, were not selected as
primary COCs based on the limited risk as determined in the Remedial Investigation-Final, Volumes 1 &
2 (1997a, W&C) and Feasibility Study-Final (1997b, W&C) (RI/FS). Cleanup objectives for groundwater
are the federal Safe Drinking Water Act Maximum Contaminant Levels (MCLs).
Table 1: Cleanup Levels for Groundwater, Eastern & Western Plumes
Contaminants of Concern
Cleanup Level
(ug/L)
Vinyl chloride
2
1,1-dichloroethylene
7
1,2-dichloroethylene (total)
70
Trichloroethylene
5
In a Consent Decree (CD) entered by the United States District Court for the Western District of
Michigan in October 1999 (EPA, 1999), Bosch agreed to perform the Remedial Design/Remedial Action
(RD/RA) for the Site as set forth in the 1997 ROD.
EPA later issued an Explanation of Significant Differences (ESD) in 2009 (2009 ESD) requiring the
installation of a limited groundwater extraction and treatment system to reduce contaminant loading
from the source of the Western Plume (EPA, 2009), following observed groundwater exceedances in
point of compliance wells. The 2009 ESD stated "[s]ubsurface conditions already support the biological
de-chlorination of organic compounds, but they are currently overwhelmed by high concentrations"
and that implementing the contingent remedial action "should allow the biological de-chlorination of
organic compounds to proceed to completion before reaching" Lake Michigan.
Status of Implementation
The 1997 ROD required operation of an SVE system, maintenance of the existing cover systems, long-
term monitoring of groundwater to evaluate the effectiveness of MNA, implementation of ICs, and for
the implementation of a contingency remedial action if exceedances of criteria are observed or
predicted in POC wells. As a result, the PRP currently conducts periodic monitoring, and operates
treatment systems to reduce/control VOC levels.
The SVE system, selected as part of the remedy for the Eastern Groundwater Plume in the 1997 ROD,
was installed in 1999 to capture and remove VOCs from the vadose zone beneath a loading dock
located on the east side of the plant building and has been operating since that time. The
contamination in this area was considered to be part of the source for the Eastern Plume. However,
the source of impacts was never conclusively identified, and was only inferred from shallow
groundwater concentrations downgradient from the former loading dock lagoon. Organic
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contaminants in the extracted vapor are treated via catalytic oxidation before oxidation products are
discharged to the atmosphere. It is estimated that the SVE system has removed approximately 3,108
pounds of VOCs since the time it started operating in 1999 through the end of 2022 (approximately 8
pounds of VOCs were removed from December 2017 through December 2022). Removal volumes are
documented in the 2022 Draft Annual Report dated April 30, 2023 (W&C, 2023b).
The PRP has also been conducting periodic groundwater monitoring since 2000 (W&C, 2000a), and
monitoring is ongoing. The monitoring network originally consisted of 49 Site monitoring wells. Six
additional monitoring wells were installed in 2014, bringing the total to 55 monitoring wells, but eight
monitoring wells were subsequently destroyed by storms or construction near the shore of Lake
Michigan in late 2019, leaving 47 monitoring wells in the current network.1 The monitoring wells are
currently sampled quarterly but were sampled at a reduced frequency during the Covid-19 pandemic
and triannual sampling events.2.
Surface water samples are also collected on a triannual basis from four locations along the Lake
Michigan shoreline near the western groundwater plume discharge point where contaminated
groundwater was found to discharge into the lake approximately 50 feet further offshore. Surface
water sampling has been conducted since 2004, though recent elevated water levels in Lake Michigan
have resulted in the original locations being submerged, and a beachfront collapse in 2019 resulted in
the wooden piers used as markers for sample points to no longer be present. Additional surface water
and beach and lake sediment sampling were recommended in EPA's 2014 and 2019 Five Year Reviews,
but the sampling program has not been expanded because of unusually high lake levels. The surface
water samples are collected to monitor lake water quality and to evaluate the potential human health
risk from exposure to the surface water. The samples are analyzed for seven chlorinated VOCs: 1,1,1-
TCA, 1,1-DCA, 1,1-DCE, cis-l,2-DCE and trans-l,2-DCE, TCE and VC.
Institutional controls were a requirement of the 1999 CD and have only partially been implemented as
discussed in the next section. In addition, a cover system composed of existing asphalt, concrete, and
buildings existed at the time of the 1997 ROD and was required to be maintained. The 1999 CD also
required that a deed restriction be implemented to control access to soils and prevent infiltration near
the inferred Eastern Source Area at the Eastern Loading Dock and former South Lagoon. The purpose
of maintaining the existing cover system was to minimize infiltration to the vadose zone, mitigate
contaminant leaching to groundwater, and restrict potential contact with contaminated soil. The deed
restriction was never recorded, and approximately 5.8 acres of existing site cover was removed by the
PRP in 2008 when the PRP made a business decision to close and demolish the former foundry and
adjacent maintenance building, and the building slabs were removed. The foundry was reportedly
demolished due to the substantial cost to modernize the foundry and its associated equipment with
new technology, and the operations were ultimately outsourced as a more economical option. The
cover removal, along with an associated remediation of TCE-impacted soils in the area, was neither
1 Seven beach bluff monitoring wells (BB-01A, BB-02A, BB-02B, BB-02C, BB-03A, BB-03B, and BB-04A) and one POC
monitoring well (POCW-6) were impacted by two severe storm events in 2019. Six beach bluff monitoring wells were
properly abandoned in December 2019. BB-04A and POCW-6 were still intact after the storms, but was covered with fill
during a construction project to rebuild and reinforce the shoreline that started in March 2020 and continued through
August 2020, and are consequently no longer available for sample collection.
2 Sampling was performed during 4 quarters in 2018 and 2022, 3 quarters during 2019 and 2021, and 2 quarters during
2020.
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approved nor overseen by EPA, and may have altered the migration of contamination in the Eastern
Plume. As a result, EPA's 2019 FYR (EPA, 2019) included recommendations to evaluate the removal of
the cover system (see Table 4).
Although the 1997 ROD identified that the cleanup objectives for groundwater are the federal MCLs,
the timeframe for achieving MCLs is 150-250 years, so the 1999 CD (EPA, 1999) included a requirement
that "point of compliance (POC) criteria...in the form of ACLs" (alternate concentration limits) would be
established by EPA, for use at the POC wells to determine whether compliance with groundwater
monitoring criteria were being achieved during the monitoring period. The remedy selected in the ROD
did not include ACLs, but they were developed by the PRP for EPA's consideration in its 2004 Final
Report for Baseline Groundwater Data Collection Program (W&C, 2004) for subsets of the COCs and
monitoring wells, including point of compliance wells, plume monitoring wells, sentinel wells and
boundary wells. The ACLs were based on statistical analyses of three years of data from quarterly
baseline groundwater sampling, referred to as the Baseline Groundwater Data Collection Program
(BGWDCP), and were developed on the assumption that MNA was occurring, that surface water was
not substantially impacted and that the plumes were stable, allowing the calculated concentrations to
be used as a baseline to determine if a statistically significant increase in contamination was occurring
at the POC. Revised ACLs were later developed for use as POC criteria by the PRP for POC wells in its
April 2005 Alternate Concentration Limits Groundwater Monitoring Work Plan (W&C, 2005), which also
proposed reductions in four ACL values for POC wells.
Exceedances of the ACLs at POC wells were a trigger for contingent remedial actions under Paragraph
14 in Section VI of the 1999 CD. EPA's determination of a predicted or detected exceedances at the
POC required the PRP to propose a "Contingent Remedial Action Plan". Due to exceedances in the
early 2000s of the revised ACLs developed by the PRP in its April 2005 Alternate Concentration Limits
Groundwater Monitoring Work Plan (W&C, 2005), EPA issued a Notice of Exceedances letter to the PRP
in August 2007. The exceedances of the PRP's proposed ACLs in POC monitoring wells triggered the
requirement to develop and implement a contingent remedial action. Appendix C includes a list of the
draft ACLs from 2004 and the 2005 revised draft ACLs. The 2009 FYR (EPA, 2009) and additional
documents by PRP indicated that draft ACLs had been proposed but not formally adopted, despite
being a trigger for contingent remedial actions. The method used to calculate the ACLs assumes that
the data are stationary (i.e., no temporal trends) and homoscedastic (i.e., equal variance). Many of the
well-COC pairs in the dataset used to calculate the draft ACLs violate these underlying assumptions of
the method. In addition, the draft ACLs were calculated on log-transformed data which were then
back-transformed to obtain the reported ACLs. Violation of the calculation's underlying assumptions
and the back-transformation of calculated values ultimately resulted in inflated ACLs, and as such, the
draft ACLs are not currently considered valid. In addition, while the 1999 CD allowed for the calculation
and use of ACLs as a means of demonstrating compliance, at that time there was a presumption that
the plume was stable and that discharges from the groundwater were not having an adverse effect on
surface water and/or sediments and related receptors, and these are no longer the presumed
conditions. Despite this, the 2019 FYR documented continued exceedances of the proposed ACLs at
POC wells and throughout the plumes since those exceedances triggered the prior contingent
remediation action, and those exceedances have persisted since the 2007 Notification of Exceedances
(EPA, 2007).
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The contingent action undertaken as a result of the August 2007 notice was the installation of the mass
reduction system (MRS). The MRS is a groundwater extraction and treatment system which was
installed near one of the suspected source areas. The purpose was to enhance the natural attenuation
of chlorinated solvents in the Western Plume by reducing contaminant loading. The installation of the
MRS was completed in September 2009. Six monitoring wells were installed in 2014 to monitor the
effectiveness of the MRS (MWW-101A, MWW-101B, MWW-101C, MWW-102A, MWW-102B, and
MWW-102C), and the system has been operating since that time.
The MRS consists of three extraction wells, which were installed after EPA issued the PRP a Notice of
Exceedance for the Western Plume on August 30, 2007 (EPA, 2007). Extracted groundwater from the
MRS is treated using an air stripper and a catalytic thermal oxidation unit (CatOx). The three extraction
wells were designed to extract groundwater at a rate between 5 and 20 gallons per minute. The rate
has been around 13 gallons per minute (gpm) since 2013 but increased to approximately 16 gpm in
June 2022 with the addition of replacement flowmeters. Treated air is discharged to the atmosphere,
and treated groundwater is routed to Hickory Creek via the storm sewer under a National Pollutant
Discharge Elimination System (NPDES) permit.
The MRS was anticipated to remove 36,000 to 46,000 pounds of VOCs within a 12- to 14-year period.
Since it started operating in 2009 through the end of 2022, only about 1,894 pounds of VOCs have
been removed by the MRS system, with only 411 pounds of VOCs removed from December 2017
through December 2022. Removal volumes are documented in the April 30, 2023, 2022 Draft Annual
Report (W&C, 2023b).
Institutional Controls
Table 2: Summary of Planned and/or Implemented ICs
Media,
engineered
ICs
controls, and
Called
areas that do
ICs
for in the
Impacted
IC
Title of IC Instrument Implemented
not support
Needed
Decision
Parcel(s)
Objective
and Date or status*
UU/UE based
Docume
on current
nts
conditions
(1) Environmental Protection
Easement and Declaration of
Provide access
for
environmental
restoration,
restrict
groundwater
use and
protect the
remedial
action.
Restrictive Covenants (planned).
(2) Letter (or other) agreements
Groundwater
Yes
Yes
All property
overlying
contaminated
groundwater
(1994-1998).
(3) Letter agreements imposing
land/water use restrictions
(planned).
(4) Notice of CD filed with Berrien
County Recorder's Office
(11/15/1999).
(5) Berrien County Private and Type
III Public Ground Water Supply
Ordinance, Section 12703 of Part
127 of Act 368. (7/3/1997).
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Soil
Yes
Yes
Source areas
Prohibit access
to
vadose zone
soils
in source areas.
(1) Environmental Protection
Easement and Declaration of
Restrictive Covenants (planned).
(4) Notice of CD filed
with Berrien County Recorder's
Office (11/15/1999).
Surface
water/
sediment
Yes
No
Area in Lake
Michigan
where plume
is discharging
Informational
IC/
Advisory.
Michigan Department of
Community
Health (MDCH) and Agency for
Toxic Substances and Disease
Registry (ATSDR) Advisory letter
(6/22/2007)
^_see IC Instrument descriptions in text below
A map showing the area in which ICs are required is included as Figure 2 in Appendix D. Updates to the
ICs map will be made as needed, see the IC Follow up Actions Needed section below.
Description of Planned and Implemented ICs
(1) Environmental Protection Easement and Declaration of Restrictive Covenants
According to Section IX Access and Institutional Controls of the 1999 CD (page 31), the PRP was to
"refrain from using such property, in any manner that would interfere with or adversely affect the
integrity or protectiveness of the remedial measures" and that such measures included but were not
limited to restrictions on use of groundwater. The type of IC instrument that was to be used was an
Environmental Protection Easement and Declaration of Restrictive Covenant (EPE/DRC). The draft
easement attached as Appendix E to the 1999 CD stated that the PRP was to "impose on the Property
use restrictions as covenants that run with the land for the purpose of protecting human health and
the environment". The PRP could not confirm that the EPE/DRC had been filed and began making
efforts in April 2019 to prepare the draft EPE/DRC. The current version is being negotiated with EPA
and is consistent with EGLE's current model for Restrictive Covenants, and pertains to parcels owned
by the PRP, but is still not finally approved by EPA and consequently has not been filed.
(2) Letter (and/or Other) Agreements
Letter (or other) agreements with various property owners were recorded with Berrien County
Recorder's Office between 1994 and 1998, with the intent to impose land/water use restrictions on the
properties in question and/or maintain access to the properties. Properties with Access Agreements
and Deed Restrictions were recorded in Appendix F of the 1999 CD. In the draft Institutional Controls
Implementation and Action Plan (ICIAP) dated February 21, 2015, (W&C, 2015b) submitted by the PRP,
the instruments referred to as "Letter Agreements" relate in at least five cases to a letter agreement,
and in two cases to other agreements, provided to residents or other property owners. The letter,
along with an agreement signed by each of the seven property owners who agreed with the letter, was
recorded on the property title. The conditions referenced in the letter (or other agreement) included:
(1) "[p]ermission to record this agreement in the property records of the appropriate governmental
authority as a covenant to run with the land"; and (2) [a]ssurance that you will not install future wells
on your property without written permission of the Berrien County Health Department." A table
included in the draft ICIAP indicates that seven property owners had signed the letter agreement (or
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other agreement), and 16 residents or other property owners had not signed an agreement. A revised
ICIAP was submitted by the PRP on October 28, 2021 (W&C, 2021) with updated property information
depicting 50 properties with current access agreements or deed restrictions.
(3) Letter (And/or Other) Agreements (planned)
The 1999 CD required that "in the event that additional property where access and/or land/water use
restrictions are needed to implement this Consent Decree, Settling Defendant shall use Best Efforts to
secure from such persons: an agreement to provide access...[and] an agreement to refrain from using
such property in any manner that would interfere with or adversely affect the integrity or effectiveness
of the remedial measures". The 1999 CD required best effort to obtain access and implement
land/water use restrictions to ensure protectiveness of the remedy, either in the form of contractual
agreements or in the form of easements "running with the land". As mentioned, a revised ICIAP was
submitted by the PRP on October 28, 2021, and updated property information depicts approximately
23 properties within the estimated areal extent of the plumes who do not have access agreement or
deed restrictions in-place. The October 2021 ICIAP has not been approved as of the signing of this
document.
(4) Notice of CD filed with Berrien County Recorder's Office
In the 1999 CD, in Section V, Paragraph 9, with respect to PRP-owned property that was part of the
Site, it stated that the PRP was to file a notice with the Berrien County Recorder's Office to notify any
future owners that the property was part of the Site and that the PRP had entered into a CD with EPA
to implement a remedial action. This notice was filed on November 15,1999, and identified the four
parcels constituting the property at 3737 Red Arrow Highway as being owned by Bosch.
(5) Berrien County Public Ground Water Supply Ordinance
An ordinance was adopted by Berrien County on July 3, 1997, that stipulated that construction of a
new water supply well could not be initiated without first obtaining a permit from the Berrien County
Health Department. The ordinance restricts the use of groundwater by requiring a permit to drill some
(private and Type III) drinking water wells but does not apply to Type I and Type II water supply wells3
or to wells excluded under the State of Michigan Public Health Code (Section 12703 of Part 127 of Act
368).
Advisory Letter Sent to Residents by MDCH and ATSDR
In June 2007, MDCH and ATSDR issued a joint advisory letter (MDCH/ATSDR, 2007) to residents related
to the offshore area in Lake Michigan where the contaminated groundwater plume discharges. In the
letter (included in Appendix E), they referred to the plume discharge area as an "Advisory Area" (Figure
3) and stated that their assessment showed an "indeterminate hazard." They explained that this meant
they had "determined that children playing in the lake sediments may come into contact with vinyl
chloride in the Advisory Area but are not able to state with certainty what amount of risk children
would face from that contact. The reason for the indeterminate conclusion is that necessary
information is not available to reach a more definite conclusion."
3 Type I wells are those that provide year-round service to not less than 25 residents OR not less than 15 living units (such as
Municipalities, Apartments, Condominiums, Nursing Homes, Mobile Home Parks), and Type II wells are those that serve not
less than 25 people for at least six months per year OR not less than 15 connections for at least 60 days per year (such as
Schools, Industries, Places of Employment, Hotels and Restaurants with less than 25 employees, & Campgrounds).
13
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In the public health advisory statement in the letter, MDCH and ATSDR advised that: "Children of all
ages avoid playing and swimming in the groundwater contaminant discharge plume venting through
the lake sediments (i.e., lake sands) into the northern near-shore waters of the Churchill Farms beach.
This Advisory Area is offshore in the water and is shown on the map attached to this letter. MDCH and
ATSDR found all areas outside the Advisory Area are safe for recreational use by adults and children.
This includes the beach and all other near-shore swimming areas outside the defined Advisory Area."
Status of Access Restrictions and ICs:
The Notice of CD was filed in the Berrien County Recorder's Office in November 1999, identifying that
the property was the subject of a Superfund cleanup. The Berrien County groundwater ordinance
described above was adopted in 1997, but only restricts the use and installation of certain types of
wells. Figure 2 in Appendix D is the updated version from the Draft 2021ICIAP and shows 88
properties, 85 of which represent part of the area where ICs are necessary and three of which are
outside of the area interpreted by the PRP to be affected by groundwater impacts (depicted by the
area with diagonal shading in Figure 2 in Appendix D, identified as the "Interim Well Restriction Area").
The table in Appendix D shows the status for each property where an agreement has been recorded, as
summarized by the 2021 Draft ICIAP. Of the 85 properties shown on the figure, four are owned by the
PRP. These are the properties for which the 1999 CD (Section IX, par. 26) obligates the PRP to
implement the EPE/DRC (i.e., the EPE/DRC is currently being reviewed and negotiated with EPA). Of
the 81 remaining properties, the tables list 52 properties as having ICs or access agreements and 28 as
not having ICs. The ICs referred to in this table are the Letter (or Other) Agreements described above,
and the validity of these documents as ICs is not clear. The table also shows that the PRP's property has
an IC in-place despite the drafting of the IC not being initiated until 2019. During the time since the
original draft ICIAP was submitted in 2015, at least one property owner identified in the original Draft
ICIAP denied the PRP access to a property for which an access agreement had been obtained, calling
into question the long-term protectiveness of these documents as ICs.
While the Berrien County groundwater ordinance restricts the use of groundwater by requiring a
permit to drill private and Type III drinking water wells, it does not restrict the installation of Type I or
Type II wells and does not apply to wells excluded under the State of Michigan Public Health Code
(Section 12703 of Part 127 of Act 368). The County reports it is aware of the area of groundwater
contamination and monitors requests for well permits accordingly. The ordinance also does not apply
to private wells in use at the time the ordinance was developed, and some wells remain in-use East of
Hickory Creek.
The 1999 CD in Section IX, page 32, stated that the PRP had "obtained restrictive covenants from
substantially all such persons regarding substantially all such properties" and that the Berrien County
Private and Type III Public Groundwater Supply Ordinance provided "additional institutional control
restrictions over use of the groundwater on all other properties in the vicinity of the Site." In addition,
the 1999 CD (Section IX, par. 27) includes provisions in the event additional land/water use restrictions
are necessary.
14
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Current Compliance:
The required ICs have not yet been fully implemented at the Site, but EPA is not aware of uses of the
Site or media uses which are inconsistent with the stated objectives required in ICs, based on
inspections and interviews, except for the removal of the cover at the former foundry. EPA contacted
the Berrien County Health Department as part of the FYR process and confirmed that no requests had
been made during the period of review for well permits to be issued in are area of impacted
groundwater. During the FYR inspection conducted on September 12, 2023, EPA did not observe new
violations of existing/proposed ICs or breaches of site controls, as noted in the Site Inspection section
below.
IC Follow up Actions Needed:
EPA and EGLE conducted a preliminary review of the ICs that are in place and that are planned
for the Site, as presented in the Draft 2021ICIAP. While the draft ICIAP will require further input by
EGLE and EPA, EPA does not believe the letter agreements provided in the document meet the current
legal requirements for effective ICs or access agreements, at least, in part, since some agreements are
not being honored. The Letter (or Other) Agreements that are in place will need to be reviewed for
adequacy, effectiveness, and enforceability by the PRP, and must be updated or replaced. Effective ICs
must be implemented for all parcels in Appendix D overlying the groundwater plume, per the 1999 CD.
Since the area depicted in Figure 2 in Appendix D may not cover the entire area of the groundwater
plume, additional properties will require ICs once the plume is delineated. The Draft 2021 ICIAP will
need to be revised again once these issues are resolved and finalized, and long-term stewardship (LTS)
of ICs will need to be implemented. Long-term protectiveness requires effective ICs to be in-place, and
continued compliance with the land use and groundwater use restrictions to ensure that the remedy
continues to function as intended. LTS will ensure that the ICs are maintained, monitored and
enforced. The ICIAP should document LTS procedures, which at a minimum should include: (1)
monitoring activities and schedules; (2) responsibilities for performing each task; (3) reporting
requirements; and (4) a process for addressing any potential IC issues that may arise during the
reporting period.
The PRP must also implement an enforceable and effective EPE/DRC as required by the 1999 CD for the
PRP-owned property, and negotiations on the EPE/DRC for the Bosch property have been underway
since 2019 and are ongoing.
Additional IC follow-up actions that are needed include:
• Replace existing ineffective and unenforceable ICs with adequate, effective, and enforceable
ICs.
• Determine areas needing additional ICs through adequate delineation of plumes, and update IC
map.
• Implement effective ICs for all potentially impacted properties including PRP-owned properties.
• Finalize the ICIAP to ensure long-term stewardship.
15
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Systems Operations/Operation & Maintenance
The PRP performs operation & maintenance (O&M) of the MRS and SVE systems. O&M activities
include day-to-day operations and long-term maintenance of the MRS and SVE systems.
The SVE system consists of four extraction wells, six soil vapor sampling points, underground piping
and the CatOx unit. The original photocatalytic oxidation system was replaced with thermal catalytic
oxidizer in 2000 and that system, except for the influent process blower, filter, and control valve, was
replaced with a similar thermal catalytic oxidizer again in 2022. The SVE system has been operating
since the summer of 2000 and requires minimal maintenance. The PRP changes out the filters
periodically, cleans out sediment build-up from the SVE extraction wells once a year, and replaces
fuses when needed.
The MRS consists of three extraction wells, subsurface wiring and plumbing, an instrumentation and
Control system, a vertical air stripper (series of six-tray units), a heat exchanger and heater, and a
CatOx unit, which is shared with the SVE system. Groundwater extracted by the MRS is routed via
underground piping to the MRS treatment building. Anti-scalant and defoaming agents are added and
the influent is heated prior to being routed to the air stripper.
The 2009 ESD estimated that the MRS would operate for 12 to 14 years and would remove 36,000 to
46,000 pounds of VOC source material, at a rate of 400-500 pounds/month. Thus far, the MRS has
operated for almost 15 years and has removed only 1,894 pounds of total VOC mass.
According to the December 2022 Monthly Progress Report (W&C, 2023a) submitted by the PRP, target
reductions had been reached in the three extraction wells and in eight of nine monitoring wells.
However, downgradient wells located across Red Arrow Highway have shown increases in contaminant
levels, suggesting the plume has moved rather than that the system has been effective in reducing
mass flux. The MRS has been operating at a pumping rate much lower than the design rate of 20
gallons per minute for the duration of operation, and it is not clear from available information that the
Western Plume Source Area was accurately identified. The 2009 ESD predicted that in 12 to 15 years,
the effects of the MRS should be apparent along the lakefront, and this prediction is not consistent
with the concentration trends in POCW wells discussed in the sections that follow. The 2014 FYR
identified that a mass flux analysis was needed to provide a reliable estimate of mass flux leaving the
site, since concentration data do not demonstrate that the mass flux has been reduced since no clear
impact on down-gradient monitoring wells was seen, and improved monitoring was needed at that
time to avoid a "lost decade".
Vapors collected from the MRS air stripper and from the SVE system are both treated by the CatOx
unit. From 2000 to 2022, the unit consisted of a platinum palladium thermix system. In 2022, the
catalyst was switched to lithium titanite oxide. The catalyst operates at a temperature of 825-850° F
and is sampled quarterly. Removal efficiency for carcinogenic VOCs has been between 99-100% since
2022, Treated air is exhausted via a pipe at the roof line. Air samples are collected once per month to
ensure exit air meets permit requirements. The PRP replaced the catalyst in 2012 and replaced the
entire unit (including a new catalyst bed) in 2022.
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Treated groundwater from the MRS is tested to ensure it meets NPDES discharge requirements before
it is routed to discharge into Hickory Creek. Treated groundwater influent and effluent samples are
collected from extraction wells and sampling ports on the MRS treatment skid, analyzed for targeted
parameters under Ml EGLE NPDES permit number MI0058659 v2, and effluent results are reported to
EGLE via monthly electronic discharge monitoring reports (DMRs). Water that does not meet NPDES
requirements is sent to an outside pit tank (TankT-109) and then recirculated through the treatment
system. Off-spec water is sent to Tank T-109 which is monitored with a camera and telemetry, then run
through the treatment system.
Clogging of aeration trays in the air stripper and heat exchanger plates need to be addressed
periodically. Cleaning of the air stripper trays occurs every other week. If clogging occurs, the pressure
drop in the system triggers an alarm. The heat exchanger is cleaned once per month. The PRP installed
a new flowmeter in 2015 and replaced other flowmeters in 2022 to better monitor flow through the
system.
The PRP provides monthly summaries of the MRS and SVE operations and annual reports summarizing
the prior year's data.
Removal of Cover
The 2019 FYR identified that the removal of the (then) existing cover system required further
evaluation to determine if there was a detrimental effect on the remedy, and/or to evaluate whether
wastes removed during those activities had been released to the environment. Appendix F provides a
figure showing the cover area (Figure 4a), along with figures showing the foundry process areas (Figure
4b), proposed investigation borings (Figure 4c), former floor plan (Figure 4d), features (Figure 4e) and
prior sampling results from the foundry (Figure 4f). A summary of historical waste sampling and
disposal, and historical soil sampling related to the foundry demolition was included in the 2019 FYR.
Appendix G includes a summary prepared by EPA's contractor of the wastes disposed, along with the
10-page table from the associated report (O'Brien & Gere, 2008). Appendix H shows the areas where
the unauthorized excavation of TCE and PCE impacted soil was completed during demolition of the
former foundry (Figures 5a through 5c).
A draft work plan was submitted in May 2020 for investigation of the former foundry area. No further
progress was made with respect to removal of the cover beyond the review of subsequent submittals
made at the request of EPA to develop an appropriate scope of work for the investigation.
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.
17
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Table 3: Protectiveness Determinations/Statements from the 2019 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
1/Sitewide
Short-term Protective
The remedy at the Bendix site currently protects human
health and the environment because no known
exposures are occurring, and the Site is well-secured.
However, in order for the remedy to be
protective in the long-term, a number of actions need
to be taken to ensure protectiveness. These
actions involve conducting a series of evaluations to
assess the effectiveness of remedy components,
updating decision documents, evaluating ICs, and
implementing long-term plans. See the
Issues/Recommendations table in the previous section
for a complete list of actions required.
Table 4: Status of Recommendations from the 2019 FYR
OU#
Issue
Recommendations
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
1/Sitewide
Cover system was
removed.
1) Submit work
plan for conducting
investigation of
former foundry
and maintenance
building area.
Addressed in
Next FYR
A draft work plan for
investigation was submitted
5/29/2020, supplemented
with information on
2/10/2021 and 5/6/2021.
The submittals are deficient,
and EPA is preparing a scope
of work request. This issue
has been carried forward in
this FYR.
NA
1/Sitewide
Cover system was
removed.
2) Complete
investigation of
former foundry
and
maintenance
building area,
evaluate effects of
removal of cover,
and present a
report with the
findings and with
options for
additional remedial
actions to
address removal of
cover.
Considered
But Not
Implemented
See Recommendation #1,
NA
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1/Sitewide
Cover system was
3) Complete a
Considered
Not completed; need and
NA
removed.
decision document
to document the
change in the
remedy due to the
cover being
removed and to
document any
additional
remedial actions
that are necessary.
But Not
Implemented
scope of remedy change
contingent on results and
evaluation of data collected
following acceptable work
plan. See recommendation
#1.
1/Sitewide
Cover system was
4) Implement any
Considered
See recommendations #1
NA
removed.
additional remedial
actions related to
the removal of the
cover required by
the decision
document.
But Not
Implemented
and #3.
1/Sitewide
Remedy
5) Submit work
Considered
A mass flux analysis was not
NA
Performance,
plan for conducting
But Not
performed. The PRP
Effectiveness of
a comprehensive
Implemented
submitted an MNA
MRS has not been
mass flux analysis
Assessment to EPA on
fully evaluated.
to determine the
effectiveness of
the MRS.
1/25/2019 in place of the
max flux analysis, and EPA
concluded4 the PRP's
findings were not supported.
1/Sitewide
Effectiveness of
MRS has not been
fully evaluated.
6) Complete
comprehensive
mass flux analysis
of the MRS and
submit a report
presenting the
results.
Considered
But Not
Implemented
See Recommendation #5.
NA
1/Sitewide
Increasing
7) Evaluate the
Considered
The PRP submitted an MNA
NA
contamination
effectiveness of
But Not
Assessment to EPA on
trends in
the contingent
Implemented
1/25/2019, and EPA
4 EPA's December 2022 MNA memo (SSPA, 2022b) concluded: 1) the monitoring network is inadequate to support PRP
report conclusions; 2) the expansion of the Western Plume northeast past the current monitoring network negates the
analyses in PRP report; 3) PRP interpretation regarding mole fraction results is flawed because the plume is not stable; 4)
PRP's proposal for continued monitoring in response to lateral plume expansion is insufficient; 5) COC concentrations in
POC wells establish that MNA is not an effective remedy and additional response actions are needed to achieve MCLs,
contrary to PRP report conclusions; 6) plume maps presented in the PRP Report underrepresent or misrepresent the full
extent of contamination; 7) concentrations in wells along the shoreline of Lake Michigan are affected by the correlation
between surface water and groundwater levels and Mann-Kendall trend tests are too simplistic to evaluate concentration
trends in the aquifer; 8) spatial moments analysis used in PRP Report is unreliable because the full extent of the plume is
unknown; 9) it is not possible to verify the spatial moments analysis because key information is missing from the PRP
report, despite the analysis not being appropriate given Site conditions and the existing monitoring well network; 10) the
vertical extent of contamination and location of the plume cannot be defined at several key locations because the
monitoring wells have short (two-foot) screened intervals; and, 11) several statements in Section 4 of the PRP Report are
unsupported.
19
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groundwater,
continued
exceedances of
ACLs, and
underperformance
of the contingent
remedy
implemented in
2009 raise
questions about
the effectiveness
of MNA as the Site
remedy
remedy and the
overall
effectiveness of
MNA as the Site
remedy and
identify any
additional
remedial actions
that are necessary.
concluded the PRP's findings
were not supported. The
evaluation of additional
remedial actions necessary
will be considered if needed
in the future.
1/Sitewide
Increasing
contamination
trends in
groundwater,
continued
exceedances of
ACLs, and
underperformance
of the contingent
remedy
implemented in
2009 raise
questions about
the effectiveness
of MNA as the Site
remedy
8) Complete a
decision document
to document any
additional
remedial actions
that are necessary.
Considered
But Not
Implemented
See Recommendation #7.
NA
1/Sitewide
Increasing
contamination
trends in
groundwater,
continued
exceedances of
ACLs, and
underperformance
of the contingent
remedy
implemented in
2009 raise
questions about
the effectiveness
of MNA as the Site
remedy
9) Implement any
additional remedial
actions related to
groundwater and
overall Site remedy
required by the
decision
document.
Considered
But Not
Implemented
See Recommendation #7.
NA
1/Sitewide
Increasing
concentrations in
some monitoring
wells show that
10) Submit
proposal for
installation of
additional wells to
Addressed in
Next FYR
A proposal for replacement
Beach Bluff Well installations
was submitted to EPA and
EGLE on 9/16/2020, EPA and
NA
20
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the groundwater
define the extent
EGLE provided comments on
plume may have
of groundwater
10/5/2020, and a response
shifted to the
contamination and
to EPA comments submitted
north, and
to adequately
on 10/8/2020; however
detections in wells
monitor current
additional characterization is
that are
areas of
needed to optimize well
meant to define
contamination.
placement. Similarly, a
the edges of the
proposal for one well
Western Plume
installation for delineation of
indicate that the
the plume edges was
plume is not fully
submitted to EPA on
defined and the
7/1/2020, and a 2/21/2021
current
revised proposal from EPA's
monitoring
10/29/2020 comments was
network may not
considered insufficiently
be adequate.
developed with only 2
Definition of
additional wells. This issue is
extent of
being addressed in the
groundwater
Issues/Recommendations
contamination (in
section of this FYR.
both plumes) is
required to
determine areas
requiring ICs.
1/Sitewide
Increasing
11) Install
Addressed in
A proposal for replacement
NA
concentrations in
additional wells to
Next FYR
Beach Bluff Well installations
some monitoring
define the extent
was submitted to EPA and
wells show that
of
EGLE on 9/16/2020, EPA and
the groundwater
groundwater
EGLE provided comments on
plume may have
contamination and
10/5/2020 and a response to
shifted to the
to adequately
EPA comments submitted on
north, and
monitor current
10/8/2020; however
detections in wells
areas of
additional characterization is
that are
contamination.
needed to optimize well
meant to define
placement. Similarly, a
the edges of the
proposal for one well
Western Plume
installation for delineation of
indicate that the
the plume edges was
plume is not fully
submitted to EPA on
defined and the
7/1/2020, and a 2/21/2021
current
revised proposal from EPA's
monitoring
10/29/2020 comments was
network may not
considered insufficiently
be adequate.
developed with only 2
Definition of
additional wells. This issue is
extent of
being addressed in the
groundwater
Issues/Recommendations
contamination (in
section of this FYR.
both plumes) is
required to
21
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determine areas
requiring ICs.
1/Sitewide
A draft ICIAP is
under review.
12)Incorporate
comments from
EPA and EGLE into
the
draft ICIAP and
complete final
ICIAP.
Addressed in
Next FYR
EPA provided comments on
a 2015 ICIAP on 8/31/2020,
received a response to
comments on 2/10/2021,
and received a Revised Draft
ICIAP on 10/28/2021. The
ICIAP will require further
review by EPA and EGLE to
ensure the LTS of ICs after
the PRP evaluates the
adequacy, effectiveness, and
enforceability of ICs. This
issue is being addressed in
the
Issues/Recommendations
section of this FYR.
NA
1/Sitewide
A number of ICs
have not been
implemented, may
not be
enforceable,
and/or may no
longer be valid or
effective.
13) Review ICs,
update existing ICs,
implement
additional
ICs, and finalize
and record
EPE/DRC required
by CD.
Addressed in
Next FYR
A draft of the EPE/DRC for
the area of the site owned
by Bosch is currently being
negotiated. ICs for remaining
affected properties do not
appear to be enforceable
and do not meet current
requirements. This issue is
being addressed in the
Issues/Recommendations
section of this FYR.
NA
1/Sitewide
Procedures are
not in place to
ensure LTS of ICs
at the Site.
14) Develop and
implement LTS
procedures within
an LTS Plan for
monitoring and
tracking
compliance with
existing ICs,
communicating
with EPA and EGLE,
and providing an
annual certification
to EPA and EGLE
that the ICs remain
in place and are
effective.
Considered
But Not
Implemented
Part of ICIAP; See
Recommendation #12.
NA
1/Sitewide
Potential exposure
to contaminated
groundwater
discharging off-
15) Submit work
plan for conducting
pore water
sampling
Considered
But Not
Implemented
The beachfront was
stabilized and reconfigured
following multiple storm
events and the selection and
NA
22
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shore into Lake
Michigan and
potential impact
to Lake Michigan
have not been
fully evaluated.
and other sampling
as required to
characterize
discharge of
contaminated
groundwater to
Lake Michigan
sand and sediment
and to evaluate
potential risk to
human health and
the environment.
establishment of appropriate
pore water sampling
locations is contingent upon
establishment of properly
positioned replacement
wells; EPA completed a
SLERA5 identifying the need
for a Baseline Ecological
Risk Assessment (BERA) to
confirm that there are no
receptors or unacceptable
exposures occurring to
infaunal and benthic aquatic
receptors, and is evaluating
proposals to assess the
conditions.
1/Sitewide
Potential exposure
to contaminated
groundwater
discharging off-
shore into Lake
Michigan and
potential impact
to Lake Michigan
have not been
fully evaluated.
16) Conduct pore
water and other
required sampling
to
evaluate discharge
of contaminated
groundwater
plume into Lake
Michigan.
Considered
But Not
Implemented
See recommendation #15.
NA
1/Sitewide
Potential exposure
to contaminated
groundwater
discharging off-
shore into Lake
Michigan and
potential impact
to Lake Michigan
have not been
fully evaluated.
17) Use data from
pore water and
related sampling to
prepare
risk analysis to
evaluate potential
human heath
exposures and to
assess impact to
Lake Michigan.
Considered
But Not
Implemented
See Recommendation #15.
NA
1/Sitewide
An evaluation of
potential for 1,4-
dioxane and/or
per- and
polyfluoroalkyl
substances (PFAS)
in groundwater
has not been
completed.
18) Review
historical uses of
Site to evaluate the
possibility
of 1,4-dioxane
and/or PFAS in
groundwater,
present findings to
EPA for its review,
and, if determined
Completed
Bosch provided a Historical
Uses Memo on June 30,
2020, confirming the
potential for 1,4-dioxane to
be present. Sampling for 1,4-
dioxane was conducted only
in nearby residential wells.
Testing for 1,4-dioxane and
PFAS from site monitoring
wells will be completed after
6/30/2020
5 Screening Level Ecological Risk Assessment for Aquatic Populations at the Bendix Corporation/Allied Automotive
Superfund Site Located in St. Joseph, Michigan, EPA ERT, February 2024
23
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by EPA to be
necessary, add
these compound(s)
to groundwater
analyses.
updating the QAPP. A new
issue/recommendation has
been included in this FYR to
update the QAPP and sample
the monitor wells for 1,4-
dioxane and PFAS.
The current status of the implementation of recommendations has largely been delayed due to
insufficient characterization of the site and insufficient delineation of contamination. Many of the
supplemental remedial investigation, remedial actions, and issues/recommendations identified in the
last FYR have been carried forward in this FYR so that a comprehensive plan to address the problems
can be developed.
Recommendations 1 through 4: EPA requested the submittal of a work plan for investigation of the
former foundry area in connection with recommendations in the 2019 FYR (EPA, 2019) to address
removal of the existing cover system in that area. The goal was to evaluate the potential for releases of
the wastes disposed during 2008 foundry demolition; to evaluate residual impacts from prior
unauthorized TCE/PCE impacted soil remediation; and, to evaluate the effect of the removal of the
(then) existing cover system on the remedy. Limited testing was previously conducted at the time of
demolition, and approximately 4,400 pounds of PCE, 106,481 pounds of polychlorinated biphenyls
(PCBs), and 3,290 cubic yards of soil impacted with TCE was removed, among other wastes. The
TCE/PCE remediation was performed close to a former drum storage area, but an abandoned dry well6
was also located in the area. A draft work plan was submitted in May 2020 for investigation of the
former foundry area. Multiple comments and discussions between EPA and the PRP on the work plan
for investigation of the removal of the cover at the former foundry have not yielded an approved work
plan to date. No further progress was made with respect to evaluating the removal of the cover
beyond the review of subsequent submittals made at the request of EPA to assist the PRP with the
development an appropriate scope of work for the investigation. The initial work plan included a
proposal for soil sampling to prescribed depths, and installation of monitoring wells at predetermined
locations. It is EPA's intent to provide a response to the work plan that proposes a comprehensive,
incremental approach to delineate contamination in three dimensions, in all media, from all potential
sources, and establish appropriate permanent monitoring locations (see Issues/Recommendations).
Recommendations 5 through 9: The assessment of MNA, evaluation of increasing contaminant trends
and continuing exceedances, and the evaluation of the effectiveness of the MRS system are all
contingent upon a robust monitoring network that provides sufficient coverage for the plume and
associated fluctuations in hydraulic gradient, both laterally and vertically. An MNA report was
submitted by W&C in 2019 (W&C, 2019b) which concluded the MRS and MNA remedies at the Site are
performing as designed and expected. However, the lack of sufficient Boundary Wells, Plume Core
Wells, and replacement Beach Bluff Wells (see Recommendations 10,11, and 15 through 17),
6 A separate, former agricultural well was reported to have been used as a dry well for potential waste disposal, and was
suggested as a potential source for the Western Plume Source Area. A 1967 aerial photograph shows a small building at the
northwest corner of the parking lot, near borings completed during a USEPA's Kerr-Laboratory, Stanford University, &
Engineering-Science investigation in 1991-1992, which identified TCE in groundwater at levels exceeding 1% solubility
(NAPL) throughout the water column. The location of the agricultural well and the Western Source area were never
conclusively identified but data from this area suggest a much larger source area than depicted in project reports.
24
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combined with a lack of adequate characterization of sources, and lack of an incremental approach to
characterization prevents adequate assessment of site conditions and associated exposure pathways,
and prevents EPA from concurring with W&C's analysis of MNA. EPA recommended in the 2014 FYR
and 2019 FYR the completion of a comprehensive mass flux analysis to evaluate the underperformance
of the MRS system and compare apparent reductions in near-source wells to the persisting elevated
downgradient concentrations. While additional work was performed since that time, available
information indicates that to accurately evaluate the success of the remedy by measuring the mass of
contamination leaving the western plume source area, a substantial amount of additional information7
would need to be collected to confirm the PRP's interpretations. During the current FYR period EPA
completed its own site evaluations to assess the PRP's position on MNA (SSPA, 2022b), evaluate
hydraulic gradients (SSPA, 2022a) and the groundwater divide's effect on groundwater flow (SSPA,
2023a), reassess the PRP's the conceptual site model (SSPA, 2023c), evaluate the potential for vapor
intrusion at the site (SSPA, 2023d), establish data gaps (SSPA, 2023b) in the site assessment activities to
date, and evaluate the PRP's assessment of potential risks to ecological receptors (EPA ERT, 2024).
These evaluations were conducted to assist the PRP with the development of future proposals for
investigations and to address some of the PRP's questions regarding unapproved proposals to date,
and generally summarize similar deficiencies as those identified in preceding FYRs.
Recommendations 10 and 11: EPA requested proposals for the replacement of Beach Bluff Wells that
were destroyed in 2019, and for Boundary Wells to delineate the plume edges where contamination
had migrated beyond existing wells and/or where contamination had not previously been sufficiently
defined and received proposals from the PRP to complete those activities. The proposal for Beach Bluff
Well replacement was submitted to EPA and EGLE on September 16, 2020, and revised on October 8,
2020. The proposal generally contained a proposal for in-kind well replacements; however, since the
position of replacement wells would be benefitted by additional characterization to optimize well
placement, including the installation of additional Boundary Wells to determine the extent to which
the plume appears to have shifted, that work has not been completed. The proposal for Boundary Well
installation to delineate the plume edges, submitted on July 1,2020, contained a proposal for
installation of only one monitoring well. The proposal was revised on February 21, 2021, with two
additional well locations, however, the plume remains largely undefined across the entire northern
and southern boundaries of both plumes. Given the extent of the area where groundwater
contamination is currently undefined (there is approximately 3,400 linear feet between STE-1 and Lake
Michigan in the north where the plume is undefined, and 3,000 linear feet from MWE-2 and Lake
Michigan in the south where the plume is undefined), the proposal was considered deficient and
additional investigation was recommended.
Recommendation 12 through 14: A draft of the EPE/DRC for the PRP property is currently being
negotiated. ICs for remaining affected properties do not appear to be enforceable and do not meet
current requirements; ICs will need to be revised for existing properties and updated to include new
areas once additional investigation is completed. Assessment of ICs and long-term stewardship in the
form of an ICIAP to ensure the adequacy of controls and effective monitoring has not progressed and
7 Information on mass flux analysis (Guibeault et. al., 2005) identified that 75% of contaminant mass discharge occurs
through 5-10% of the plume cross sectional area, and that optimal spacing for collection of groundwater samples is 0.5m
throughout the entire cross-sectional area of the plume to accurately estimate the discharge.
25
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will require further review by EPA and EGLE despite the lack of adequate, effective, and enforceable
ICs.
Recommendations 15 through 17: Exposures to contaminated groundwater discharging to Lake
Michigan sediments and surface water also remain largely unevaluated, due to the destruction of
beachfront locations from storm events in 2019, elevated lake levels limiting accessibility, a lack of
establish permanent offshore sampling locations, and a lack of incremental characterization to affirm
appropriate permanent sampling locations. During the last monitoring period, EPA completed a
Screening Level Ecological Risk Assessment (SLERA) to highlight the potential for risks to ecological
receptors, if present, from discharges to Lake Michigan and/or Hickory Creek (EPA ERT, 2024). A
Baseline Ecological Risk Assessment (BERA) is necessary to confirm that there are no receptors or
unacceptable exposure occurring, and the impact of groundwater discharging to surface water can
only be accurately evaluated when there is confidence in the locations and positions of selected
monitoring locations. Since the incremental work has not been performed, no porewater sampling has
been completed.
Recommendation 18: The 2019 FYR identified the need to evaluate two emerging contaminants in
groundwater, 1,4-dioxane and per- and polyfluoroalkyl substances (PFAS), for the Bendix site. EPA
recommended that the PRP review the historical practices at the Site for the possibility of 1,4-dioxane
and/or PFAS to be present in groundwater, present the findings to EPA, and, if necessary, add these
compound(s) to groundwater analyses. The PRP submitted information indicating there was a potential
for 1-4 dioxane to be present in groundwater, due to its association with the types of solvents
previously used at the Site, and as a result, proposed sampling from residential wells identified East of
Hickory Creek to ensure there was no potential for immediate exposure in areas where groundwater
use has not been restricted. The PRP collected samples (for 1,4-dioxane, among other things) from
available residential wells located East of Hickory Creek beginning in 2022 (W&C, 2024), to evaluate
potential exposures. No samples were analyzed for PFAS, but subsequent consultation with EPA's
Regional PFAS Coordinator in January 2023 documented the potential for historical use of PFAS as
additives in brake and hydraulic fluids, in brake pad additives, in ABS brake lines, and in steel hydraulic
brake tubes8. As a result, testing for 1,4-dioxane and PFAS from site monitoring wells will be completed
after updating the QAPP.
Lastly, concerns related to vapor intrusion were raised in the 2009 FYR (EPA, 2009a), and initial steps to
assess the exposure pathway were taken by MDEQ (EGLE), as documented in the 2014 FYR. The PRP
later conducted soil gas sampling at several locations presumed to evaluate the plume core, and the
results were discussed in the 2019 FYR. No impacts were identified; however, an accurate assessment
for vapor intrusion requires additional identification and characterization of potential sources in the
vadose zone and delineation of the groundwater plume, to ensure the proper locations are being
targeted for assessment.
Following completion of the 2019 FYR (EPA, 2019), EPA requested vapor intrusion investigations at
several commercial properties in October 2020, and the PRP suggested limited investigations at their
property boundaries as an initial alternative on in November 2020. In December 2020, EPA indicated
8 Gliige et al., "An Overview of the uses of per- and polyfluoroalkyl substances (PFAS)" DOI: 10.1039/D0EM00291G (Paper)
Environ. Sci.: Processes Impacts, 2020, 22, 2345-2373
26
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the PRP's proposal would not adequately cover the properties identified by EPA for sampling and
requested contour maps to identify the full extent of groundwater impacts. Maps were provided in
January 2021, and in subsequent discussions, EPA indicated that they would provide direction on
sampling locations. EPA finalized a review of soil gas and potential vapor intrusion data in December
2023 (SSPA, 2023d), which is referenced herein to provide the requested direction.
Indoor air and sub slab testing was performed by PRP at their facility at their own discretion in the
interim in 2021, but EPA did not evaluate the report because: 1) the PRP did not complete the work
under an EPA-approved work plan and QAPP; 2) PRP did not request EPA's input on the selection of
sampling locations relative to potential sources, preferential pathways, and/or other site processes
that could affect the vapor intrusion pathway, and; 3) PRP did not obtain approval for the sampling
procedures or list of COCs, which should have included contaminants/wastes present in samples
collected during the foundry demolition. Vapor intrusion assessments were also performed in
connection with property acquisitions at two nearby properties during this FYR period. Both were
performed by consultants representing the purchaser or new owners, but not the PRP, and since the
assessments were relatively limited, the results are not summarized herein.
IV. FIVE-YEAR REVIEW PROCESS
Community Notification. Involvement & Site Interviews
A public notice was made available by a newspaper posting in the Herald Palladium, a daily newspaper
of general circulation, printed and published in St. Joseph, Berrien County, Michigan, on 8/19/2023,
stating that there was a FYR and inviting the public to submit any comments to EPA. No comments
were received, and no inquiries were made after the notice was published. The results of the review
and the report will be made available at the Site information repository at the Maud Preston Palenske
Memorial Library, located at 500 Market St., St. Joseph, Michigan, and the Lincoln Township Public
Library, located at 2099 W. John Beers Rd., Stevensville, Michigan.
No community members were interviewed because EPA was not contacted in the last five years
regarding the Site by any community members. However, EPA attended a meeting organized by W&C
and presented to nearby community residents on September 11, 2023. This information session was
conducted to present updates on the project status to residents living in the vicinity of the Western
Groundwater Plume, and no concerns were voiced to EPA regarding the site. The PRP and their
consultants were interviewed for this FYR in September 2023. EPA discussed the site with the State,
PRP and their consultant and no issues were identified other than those listed in Section IV of this FYR
(referenced further in Appendices O, P and T). EPA has also had regular communications with the State
and their recommendations are included in this FYR (see the Issues & Recommendations section of this
FYR and refer to Appendix T for State comments).
Data Review
Routine sampling (W&C, 2000a) at the Site includes quarterly collection of surface water samples at
four locations and quarterly collection of groundwater samples from approximately 47 current
monitoring wells. In addition to results from groundwater and surface water sampling, this section also
27
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summarizes data and information related to historical soil gas sampling performed in 2017 and 2018,
performance data from the MRS, comparison of current data from POC monitoring wells with the ACLs
previously calculated by the PRP, a discussion of the removal of the cover system, and emergent
contaminants.
Surface Water Sampling
Surface water samples from four locations9 are collected on a triannual basis from Lake Michigan. The
samples are analyzed for seven chlorinated VOCs: 1,1,1-TCA, 1,1-DCA, 1,1-DCE, cis-l,2-DCE and trans-
1,2-DCE, TCE and VC. During 2018, 2019 and 2021, three rounds of samples were collected, and during
2020, only two rounds were collected due to the Covid-19 pandemic. A figure showing the sampling
locations is provided as Figure 6 in Appendix I. The locations are located along the shoreline, and
approximately 50 feet east of the most-heavily impacted pore water sampling locations. Between 2018
and 2022, a total of 60 samples were collected. Detectable levels of VOCs were observed at all four
surface water sampling locations during this period. Three of the seven VOCs (1,1-DCA, 1,1-DCA, and
1,1-DCE) were not detected in any samples. A summary chlorinated VOC (cVOC) detections for these
four VOCs is shown in Table 4.
Table 4. cVOC in Surface Water (2018-2022
Contaminant
Number of
Detections
(%)
Maximum
Detection
(ug/L)
Location of
Maximum
Detection
AWQC from
1997 ROD
(NOAA
SQuiRTs,
acute/
chronic)
Surface
Water
Screening
Benchmarks
for Aquatic
Life
c/'s- 1,2-DCE
52/60
(86%)
13
SW-4
11,600/NC
620
trans- 1,2-
DCE
6/60
(10%)
0.32J
SW-4
11,600/NC
558
TCE
12/60
(20%)
0.7
SW-2
5,280/640
200
VC
53/60
(83%)
3.1
SW-4
11,600/NC
930
J = estimated value
NC = No Criteria
AWQCs from 1997 ROD are from U.S. EPA, 1986, Quality Criteria for Water and contain limited ecological values
for organic chemicals. EPA revised AWQCs under Clean Water Act Section 304(a), and the National Recommended
Water Quality Criteria - Human Health Criteria Table includes 2015 updates of Human Health Ambient Water
Quality Criteria (Water + Organism) for the three COCs listed. Current recommended values for water quality
standards, as screening values for comparison, are 100 ug/L for trans-1,2-DCE, 0.6 ug/L for TCE, and 0.022 ug/L for
VC.
9 Due to reconstruction of the shoreline west of the Churchill Farms subdivision in 2020 to repair the 2019 storm damage
the wooden piers used as markers for each of the sample points are no longer present and elevated water levels in Lake
Michigan have resulted in the original locations being submerged.
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Surface Water Screening Benchmarks for Aquatic Life from Great Lakes Initiative references in Table 4-1 of
February 2024 SLERA by EPA ERT.
Note that EGLE Rule 57 Surface Water Quality Values provides conservative screening values for
groundwater/surface water interface protective for surface water used as a drinking water source, or discharge to
the Great Lakes and connecting waters. Current Human Cancer Drink Values for COCs in surface water are: 470
ug/L for trans- 1,2-DCE; 29 ug/L for TCE; and 0.25 ug/L for VC.
The maximum detections of cis-l,2-DCE, trans-l,2-DCE, and VC were found at sample location SW-4,
and the maximum detection of TCE was found at SW-2. The location of SW-4 is to the northwest of
point of compliance monitoring well POCW-2A/B where the highest concentrations of total cVOCs have
been observed since 2005. In 2021, the maximum detection of TCE was observed at SW-2, where
maximum detections of cis-1,2-DCE and VC were previously observed in 2016.
Pore Water and Sediment Sampling
Figures 7a through 7d in Appendix J shows the sampling locations for historical pore water and
sediment samples, including a cross-section depicting the discharge of contaminants from
groundwater to pore/surface water in the lake. No pore water sampling was conducted between 2018
and 2022, though Table 5 compares the maximum concentrations of TCE, cis-l,2-DCE and VC in the
POC wells near Lake Michigan over the current monitoring period to concentrations in POC wells and
pore water samples from 2000 - 2004 (Table 5). At that time, VOCs in pore water were significantly
higher than concentrations being measured concurrently in POC groundwater, and maximum
concentrations of cis-l,2-DCE, and VC in POCW monitoring wells in recent years are currently higher.
The table also lists the current generic GSI criteria provided in the EGLE Part 201 regulations for
reference; site-specific values were developed by EGLE for comparison but have not yet been finalized
(EGLE, 2022a & EGLE, 2022b). The joint advisory letter issued in June 2007 by MDCH and ATSDR and
mentioned on page 13 of this report was in large part based on the pore water results. The continued
detections of VOCs in surface water and the continued, higher concentrations of some VOCs in POCW
wells serve as indicators that VOCs likely continue to discharge into Lake Michigan sand and sediment
which could present a potential risk to ecological receptors10.
10 EPA ERT's February 2024 SLERA identified TCE, cis-1,2-DCE and VC may pose a potential risk to ecological receptors in
close association with the nearshore sediments in Lake Michigan and potentially in Hickory Creek, but quantitative
evaluation of ecological risks in the PRP's 2002 Ecological Risk Assessment is limited by uncertainty regarding a number of
important data, exposure, and toxicity factors.
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Table 5. Maximum Concentrations of COCs in
POCW Monitoring Wells and in Pore Water (2000-2004 & 2018-2022)
Contaminant
2000-2004
Maximum
concentrations
2018-2022
Maximum
concentrations
Sediment
Porewater
Screening
Benchmark
(pg/L)
EGLE Part 201
Default GSI
Criteria (ug/L)
EGLE Surface
Water
Human
Drinking
Water
Values
(HDV)
(Pg/L)
POCW
wells
(ug/L)
Pore
water
(ug/L)
POCW
wells
(ug/L)
Pore
water
(ug/L)
TCE
8,600
15,000
49
-
200
200(X)
29
c/'s- 1,2-DCE
3,300
40,000
11,000
-
620
620
-
VC
2,200
9,100
10,000
-
930
13 (X)
1 (M); 0.25
(M) Calculated criterion is below the analytical target detection limit, therefore, the criterion defaults to the target
detection limit.
(X) The generic GSI criterion shown is not protective for surface water that is used as a drinking water source. For a
groundwater discharge to the Great Lakes and their connecting waters or discharge in close proximity to a water supply
intake in inland surface waters, the generic GSI criterion shall be the surface water human drinking water value (HDV)
listed.
Sediment Porewater Screening Benchmarks for Aquatic Life from Great Lakes Initiative references in Table 4-1 of February
2024 SLERA by EPAERT.
Groundwater Sampling
Groundwater samples were collected from approximately 55 well locations during each quarter from
2018 to 2019, and from approximately 47 locations from 2020 to 2022. Sampling was performed
during four quarters in 2018 and 2022, three quarters during 2019 and 2021, and two quarters during
2020. Appendix K includes a map (Figure 8) showing the current and past groundwater sampling
locations. In total, approximately 800 samples were collected. The samples were analyzed for seven
chlorinated VOCs: 1,1,1-TCA, 1,1-DCA, 1,1-DCE, cis-l,2-DCE and trans-l,2-DCE, TCE and VC. Data for
additional COCs detected during monitoring is reported in the PRP's quarterly reports, including PCE
which was detected in POCW-5A above the MCL.
Sampling results can be generally associated with two different groundwater plumes that emanate
from the source areas of the Site. The Eastern Plume migrates to the east and discharges into Hickory
Creek, while the Western Plume migrates to the west and discharges into Lake Michigan. The
distinction between the "Eastern" and "Western" groundwater plumes is based on a groundwater
divide that generally bisects the Site from north to south. Most of the identification names of Site
monitoring wells include an "E" or a "W" to designate which plume the well was intended to monitor.
Groundwater measurements from the past ten years, however, have shown that the divide was not as
static as was once thought and that at times monitoring wells designated with an "E" actually monitor
groundwater that flows West towards Lake Michigan. In particular, MWE-1, MWE-2, and MWE-3 may
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monitor either the Western Plume and Eastern Plume, depending on groundwater flow direction at
any given time (SSPA, 2022a and SSPA, 2023a), and these wells may be used for the Western Plume
evaluation.
Eastern Plume
COC concentrations in groundwater in the Eastern Plume are generally lower than in the Western
Plume, and the areal extent of the Eastern Plume is smaller. Table 6 presents data from the Eastern
Plume for the time period from 2018 to 2022. No exceedances of the MCL for 1,1-DCE were observed
in this period, but detection limits were exceeded the MCL for this COC 13 times, due to elevated levels
of other COCs. For the other three COCs in the table, 12.9 percent of the results exceeded the MCL for
TCE (the frequency above MCLs increased but maximum concentration decreased since the last FYR),
25.2 percent of the results exceeded the MCL for cis-l,2-DCE the (maximum concentration and
frequency above MCLs increased since the last FYR), and 32.5 percent of the results exceeded the MCL
for VC (maximum concentration and frequency above MCLs increased since the last FYR). For TCE, the
maximum concentration was approximately seven times the MCL, for cis-l,2-DCE the maximum
concentration was over 51 times the MCL, and for VC the maximum concentration was 260 times the
MCL. The exceedances were observed primarily in STE-2, STE-3, and POCE-6.
Table 6. Eastern Plume: MCL Exceedances and Maximum Detections (2018-2022)
Contaminant
Exceedances of
MCL (%)
MCL
(ug/L)
Maximum
Detection (ug/L)
1,1-DCE
0%
7
3.7
cis- 1,2-DCE
25.2%
*
70
3,600
TCE
12.9%
5
15
VC
32.5%
5
520
* The federal MCL of 70 ug/L is for total 1,2-DCE, including cis-l,2-DCE and trans-l,2-DCE.
Over the FYR review period, increasing concentrations of cVOCs were observed at BDE-1, POCE-6, STE-
1, STE-2, and STE-3 (see concentration trends in Charts 1-5, Appendix L), while decreasing
concentrations were observed at MWE-1 and POCE-3. The most-apparent trend increases were
associated with cis-1,2-DCE11. The cVOC concentrations in remaining monitoring wells were generally
stable. The cVOC concentrations in sentinel monitoring wells located along the northern and eastern
edges of the Eastern Plume exceeded the MCLs. EPA is evaluating the removal of the foundry cover,
11 EPA's SLERA states that cis-l,2-DCE is likely to move quickly through soil and sediment, and be more mobile in aquifer
materials than TCE due to its low calculated organic carbon-water partition coefficient (Koc) value. While it is more easily
degraded under anaerobic conditions, the necessary microbial species may not be present in some aquifers to support
degradation.
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and shifts in the groundwater divide relative to lake level elevations12, and the effect on groundwater
concentrations. There is no current evidence of exposures to groundwater contamination despite the
apparent expansion of the Eastern Groundwater Plume.
MWE-3 and STE-3 were installed with the intention of monitoring the Eastern Plume and positioned
downgradient from the former foundry, in the area where a cover system was in-place and preventing
infiltration at the time of the 1997 ROD and 1999 CD, but this cover system was removed in 2008.
While the FYR typically reports only the data over the prior five-year period, the trends for the entire
data sets for those two wells are mentioned due to the increases in groundwater contamination in
wells downgradient from the previously removed cover system at the former foundry. The trend plots
from the PRP's Draft 2022 Annual Report in Charts 6 and 7 in Appendix L show the apparent increases
in downgradient groundwater concentrations after cover removal, at MWE-3 beginning in 2010 and
continuing through the present, and at STE-3 beginning in 2018 and continuing through the present.
Western Plume
The levels of contaminants in groundwater in the Western Plume are generally higher than in the
Eastern Plume, and the areal extent of the Western Plume is larger. Table 7 presents the data from the
Western Plume for the time period from 2018 to 2022, and Table 8 separately presents the data from
the MWE wells. As shown in Table 7, 1,1-DCE exceeded the MCL in 12 percent of samples (the
frequency of exceedances increased but the maximum concentration decreased since the last FYR);
TCE exceeded the MCL in 37.8 percent of samples(the frequency exceedances increased but maximum
concentration decreased since the last FYR); cis-l,2-DCE exceeded the MCL in 44.2 percent of samples
(the frequency of exceedances and maximum concentration both decreased since the last FYR); and VC
exceeded the MCL in 68.8 percent of samples (the frequency of exceedances increased but maximum
concentration decreased since the last FYR). For 1,1-DCE the maximum concentration was over 5 times
the federal MCL; for cis-l,2-DCE the maximum concentration was almost 157 times the MCL; for TCE
the maximum concentration was over 820 times the MCL; and for VC the maximum concentration was
over 6,000 times the MCL. MWE wells are presented separately because of the fluctuating
groundwater divide.
Table 7. Western Plume: MCL Exceedances and Maximum Detections (2018-2021)
Contaminant
Exceedances of
MCL (%)
MCL
(Ug/L)
Maximum
Detection (ug/L)
1,1-DCE
12%
7
39
c/'s- 1,2-DCE
44.2%
70*
11,000
TCE
37.8%
5
4,100
12 Evaluation of Groundwater Flow and Hydraulic Gradients, Bendix Corp./Allied Automotive Superfund Site, SSPA,
December 2022, Evaluation of the Groundwater Divide, Bendix Superfund Site, SSPA, April 2023, and Conceptual Site
Model (CSM) Report, Bendix Corp./Allied Automotive St. Joseph, Michigan, SSPA, June 2023.
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vc
68.8%
2
12,000
*The federal MCL of 70 ug/L is for total 1,2-DCE, including cis-l,2-DCE and trans-l,2-DCE.
Table 8. MWE Wells: MCL Exceedances and Maximum Detections (2018-2021)
Contaminant
Exceedances of
MCL (%)
MCL
(Ug/L)
Maximum
Detection (ug/L)
1,1-DCE
11.9%
7
34
cis- 1,2-DCE
71.7%
70*
31,000
TCE
43.3%
5
300
VC
86.4%
2
4,500
* The federal MCL of 70 ug/L is for total 1,2-DCE, including cis-1,2-DCE and trans-1,2-DCE.
Table 9 shows the combined percentages for the Western Plume and MWE wells that exceeded the
MCLs, where concentrations were between 10 and 10,000 times greater than the MCL value.
Table 9. Western Plume: Exceedances Between 10 and 10,000 Times the MCL
Contaminant
Western Plume
Exceedances Between
10 and 10,000 Times the
MCL (%)
MWE Well Exceedances
Between 10 and 10,000
Times the MCL (%)
cis- 1,2-DCE
25.6%
70%
TCE
22.6%
55%
VC
51.8%
62.7%
Over the past five years, increasing general contaminant trends (see Charts 8 through 16 in Appendix L)
were observed at MW-101A, MW-102A, MWE-3, POCW-1A, POCW-2A, POC-4A, POC-4B, STW-1, and
STW-2A; the concentration of cis-l,2-DCE at MWE-3 increased significantly. Concentrations in Beach
Bluff wells had generally been stable before their destruction in 2019. Decreases in contaminant trends
were observed at BDW-1, MWW-1, MWW-1RA, MWW-3, MWW-101B, MWW-101C, MWW-102B,
MWW-102C, POCW-3A. Detections/non-detects in the remaining wells were generally consistent, with
the exception of a spike in vinyl chloride and cis-l,2-DCE at MWE-2 in 2021, and a spike in vinyl
chloride at MWW-2R in 2022. For wells near the inferred source area near the northern parking lot,
increasing concentrations in deeper wells (A-zone wells) appear to coincide with decreasing
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concentrations in shallower wells (B- or C-zone wells), which may indicate contaminant mass
redistribution to deeper intervals. Wells located along the northern and southern edges of the Western
Plume continue to show exceedances of the MCLs. There is no current evidence of exposures to
groundwater contamination despite the apparent expansion of the Western Groundwater Plume.
Mass Reduction System (MRS)
Thus far, the MRS has operated for almost 15 years and has removed only 1,894 pounds of total VOC
mass, potentially due to the insufficiently developed CSM (SSPA, 2023c) at the time of system design.
Appendix M includes charts showing total VOCs removed by the three extraction wells between August
2009 and December 2022, and identifies that only approximately 411 pounds of VOCs have been
removed over the last five years.
Point of Compliance (POC) Wells
Exceedances of the proposed ACLs persist at POCW-1A, POCW-2A, POCW-4A, POCW-4B, MWW-1,
MWW-21, MWW-3, BDW-1, STW-2A, STW-3 during the current monitoring period, despite an
expectation that the positive effects of the MRS would be apparent at POC wells by this time (13 years
following installation of the MRS). A brief comparison of data from the current FYR period with the
2005 proposed ACLs indicates:
• The ACL of 18 ug/L proposed for TCE at POCW-1A was exceeded during 9 of the 16 sampling
events during this review period, at concentrations up to two times the ACL;
• The ACL of 529 ug/L proposed for VC at POCW-2A was exceeded during 14 of the 16 sampling
events during this review period, at concentrations up to more than 18 times the ACL;
• The ACL of 4 ug/L proposed for VC at POCW-4A was exceeded during 15 of the 16 sampling
events during this review period, at concentrations up to 35 times the proposed ACL;
• The ACL of 4 ug/L proposed for VC at POCW-4B was exceeded during 15 of the 16 sampling
events during this review period, at concentrations up to more than 52 times the ACL;
• The ACL of 2 ug/L considered the default ACL13 for VC at POCW-5B was exceeded during 15 of
the 16 sampling events during this review period, at concentrations up to more than 4 times
the ACL (note, trends appear to be increasing upgradient from the points of compliance at
sentinel wells STW-1 and STW-2A).
• The ACL of 2 ug/L considered the default ACL13 for VC at POCE-7 was exceeded during 5 of the
16 sampling events during this review period (note, trends appear to be increasing upgradient
from the points of compliance at sentinel wells STE-1, STE-2, and STE-3).
Continuing exceedances of proposed ACLs combined with apparent increasing concentration trends at
the POC, and continuing surface water impacts indicate that the MRS remedy has not achieved the
proposed compliance concentrations along the lakefront within the 12- to 15-year timeframe it was
predicted to take before a beneficial improvement would be seen in that area, and MNA has not been
effective at addressing contaminants (SSPA, 2022b).
13 Since COC was not detected during the original evaluation period, no ACL was developed during baseline monitoring, and
MCL would be considered the default ACL, per the PRP's 2005 Work Plan.
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Soil Vapor Sampling
No soil vapor sampling occurred during the reporting period. As mentioned, indoor air and sub slab
testing was performed by PRP at their facility in 2021, and vapor intrusion assessments were
performed at two other nearby properties, but EPA did not evaluate those reports for the reasons
previously mentioned.
A summary of historical soil vapor sampling in the adjacent residential area was included in the 2019
FYR, which did not identify a vapor intrusion concern in the 10 areas sampled covering approximately
7.5 acres. The locations of PRP's historical soil vapor sampling in the residential area are included in
Figure 9a in Appendix N, and additional soil vapor sampling locations are shown in Figure 9b.
In December 202314, EPA completed a review of the available information and proposals and identified
several issues regarding site conditions and/or available data related to the potential for VI at the Site.
EPA concluded that:
1. VOC concentrations in groundwater at the Site substantially increase the potential for VI;
2. Very high concentrations of VOCs in groundwater have not been remediated and are moving
toward Lake Michigan;
3. There is insufficient information to assert that a clean layer of shallow groundwater overlies
contaminated groundwater as suggested in the PRP's CSM that would effectively eliminate the
VI potential;
4. Sandy soil conditions and related gradients may allow VOCs to diffuse to the water table
surface;
5. Interpretations about potential risks to residential buildings near Lake Michigan are valid only
for the short period during which samples were collected; and,
6. Increases in lake levels may slow the rate of groundwater discharge and increase the time when
impacted groundwater remains beneath the residence, allowing more time for VOCs to diffuse
to water table and/or soil gas.
EPA found significant investigation deficiencies due to the lack of contaminant delineation, including:
1. An insufficient monitoring network that leaves the horizontal and vertical extent of
contamination and the conditions at the water table unknown;
2. Lack of delineation of source zones and insufficient assessment of the potential for lateral
dispersion of contaminants in groundwater.
3. Limited aerial extent of soil gas/VI sampling relative to the plume footprints, cursory nature of
VI sampling efforts, and insufficient VI sampling efforts for those properties investigated,
among other things.
EPA's report (SSPA, 2023) recommends the:
1. Identification and delineation of all source areas.
14 Comments on Available Soil Gas and Potential Vapor Intrusion Data at the Bendix Corporation/Allied Automotive
Superfund Site, SSPA, December 2023
35
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2. Characterization of the full spatial extent of groundwater contamination (vertical and lateral)
for both the eastern and western plumes, including contaminant migration
3. Installation of shallow groundwater monitoring wells to screen VOC concentrations at the
water table
4. installation of shallow soil vapor probes in residential and commercial areas over the full extent
of the eastern and western plumes
5. Comprehensive vapor intrusion investigation in the Manufacturing Building and
commercial/industrial buildings that overlie the eastern and western plumes, as defined by
individual contaminants rather than total VOCs.
These issues, summarized in the EPA's evaluation of the vapor intrusion assessment (SSPA, 2023d) are
included in the Issues/Recommendations section of this FYR. Current data has not identified evidence
of unacceptable exposures to contamination via the vapor intrusion pathway, however, additional
information will need to be collected to support a conclusion that no exposures are occurring.
Emerging Contaminants in Groundwater
Two emerging contaminants in groundwater, 1,4-dioxane and/or per- and polyfluoroalkyl substances
(PFAS), were noted during the last FYR for the Bendix site as potential contaminants related to site
operations or processes. During the current FYR period, the PRP conducted sampling of three
residential wells that are currently in use, located East of Hickory Creek. The wells were sampled for
VOCs, 1,4-dioxane, SVOCs and target analyte list (TAL) metals in July 2022; wells with access were
sampled again in November 2022 or September 2023. Analyses from those wells indicated 1,4-dioxane
was not present15. PCE was detected below the MCL in one well, and lead was detected in a different
well above the recommended goal of zero ug/L but below the treatment technique action Level of 15
ug/L.
The PRP is currently updating the site-wide QAPP to include 1,4-dioxane and PFAS in a sampling effort
over the next five-year period, to conduct a more detailed analysis of emergent contaminants in on-
site groundwater monitoring wells before determining whether additional sampling is needed.
Site Inspection
The inspection of the Site was conducted on 9/12/2023. In attendance were Joseph Kelly of EPA,
Samantha Belisle of the EGLE, Jedd Steinglass and Connor OBrion of W&C (PRP Consultants), and John
Young of the PRP. The purpose of the inspection was to assess the protectiveness of the remedy.
The Site inspection included visual observations of:
General Site conditions (building exteriors, causeways, vegetation, debris, etc.)
Access control features.
SVE trailer housing the blower, knock-out tank, and controls.
CatOx unit.
15 Per Residential Well Sampling Analytical Results Memorandum, W&C, August 2022, and Draft Residential Well Sampling
Report, W&C, March 2024.
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MRS wells and system components inside the treatment building.
Location of the former cover system and former foundry;
A selection of extraction and monitoring wells.
In general, the building exterior and grounds appeared maintained and free of debris, with landscaped
areas along the western perimeter of the property. The Site is secured by fencing around the entire
property, which appeared to be in good condition, and a guard office located near the gated entrance
to the property along Maiden Lane is staffed 24 hours per day/seven days per week. There were no
signs or reports of trespassing or vandalism.
During the Site inspection, access was provided by the PRP to a locked SVE trailer, which was clean and
well-maintained, and contained SVE components and controls that were in good working order. The
CatOx system located adjacent to the SVE trailer was new and also in good working order. EPA also
observed the MRS wells to be secured with wells and instrumentation protected by bollards to prevent
damage from traffic. The treatment building containing the MRS system was also well maintained and
contained various extra parts and manuals for system operation.
The footprint of the former foundry and former maintenance building was observed to be covered
with crushed concrete/gravel, and there was no evidence of footings or concrete slabs remaining, and
no evidence of recent disturbances.
EPA observed that most of the monitoring wells on the property are flush mount with labels written
inside the road box. Monitoring wells that are not flush-mounted are locked. The PRP stated that they
were not aware of any issues with flooding of flush mount wells but reported periodic flooding of
manway 4 of the MRS system piping run and damage to the outer casing of POCE-5. EPA observed
most of the wells to be in good condition but noted a damaged protective cover on monitoring well
OW-19, which is no longer in the monitoring network.
See Appendix 0 for the inspection form and Appendix P for photographs from the Site inspection,
along with the PRP's desktop presentation for the inspection. The notification of the start of the FYR
and scheduled inspection is included in Appendix Q.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Answer: No. Many aspects of the remedy are not functioning as intended.
Question A Summary:
The ROD required implementation of ICs, operation of an SVE system, maintenance of the existing
cover system, long-term monitoring of groundwater to evaluate the effectiveness of MNA, and a
requirement for a contingency remedial action if exceedances of criteria are observed or predicted in
POC wells.
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The IC (EPE/DRC) for the property has not been implemented, the adequacy of access and letter
agreements is unclear and have not proven to be enforceable, and the Berrien Groundwater Ordinance
is only partially effective since it doesn't eliminate the potential for all use of groundwater. Despite
this, the subject property use is not inconsistent with the use restrictions that are being proposed in
the IC currently being drafted, and there are no private water wells in-use in the area of known
groundwater contamination. There is a potential that ICs may need to be implemented to address the
vapor intrusion pathway if additional investigation identifies an exposure concern, but there does not
appear to be an area-wide exposure concern based on available soil gas data. Despite ongoing
negotiations on the EPE/DRC for the Bendix/Bosch property, most of the other ICs have not been fully
implemented, or do not appear to be effective and/or enforceable; these will need to be
completed/revised to ensure long-term protections from potential exposure and will need to be
expanded if additional affected properties are identified during groundwater delineation efforts.
Although ICs have not been implemented as intended by the 1999 ROD, there is no current evidence
that exposures are occurring.
The SVE system has been operating since 1999, but the removal volume has diminished over the last
five years. The location of the source of VOC contamination for the Eastern Plume was never
conclusively identified, and TCE and PCE impacts were identified in shallow soils further east of the
inferred source/SVE area almost 10 years after the SVE system became operational, during an
unauthorized remediation for TCE-impacted soils performed by PRP in 2008. A much larger vapor
plume was documented16 in vadose zone soils during soil gas investigation in the Rl, but it was
concluded that those vadose zone impacts were not affecting groundwater quality, despite relatively
limited characterization of the soils and groundwater downgradient from the vapor plume(s)17.
The current monitoring network is insufficient to monitor the cVOC plume for natural attenuation. The
plumes were never well defined and/or have migrated past sentinel and/or boundary wells due to
insufficient source control and fluctuations in hydraulic gradient, among other things. Definition of the
extent of the plumes is required to ensure the monitoring well network is adequate and to determine
where ICs are required. Figures lOa-lOc in Appendix R depict the PRP's plume maps with overlays from
the interpreted plume maps developed by EPA's contractor, showing the uncertainty in the position of
the plumes. Impacts present in Eastern Plume groundwater at the time of the 1997 ROD were not
actively addressed by the remedy because the remedy presumed concentrations would naturally
degrade. Part of the cover system that was to be maintained as part of the selected remedy to prevent
infiltration was subsequently removed in 2008, in part, because an appropriate site restriction was
never recorded. Concentrations of cis-l,2-DCE have increased downgradient from the removed cover
since the time of the foundry demolition. A 2009 memo prepared by the PRP stated that their
modeling had shown that before the cover was removed, the cover had been serving as an effective
16 Phase IIA Technical Memorandum for Remedial Investigation and Feasibility Study, ES, October 1993 (SEMS Doc ID
207060).
17 The main phase of soil investigation in W&C's Remedial Investigation consisted of 22 cone-penetrometer borings and the
reported analysis of 51 subsurface soil samples on the approximately 52.12 acres of (former) Bendix Property (boring
numbers and soil samples summarized in table 4-1 of the Remedial Investigation Report are slightly different than
summarized in text). For comparison, an April 2009 Figure from the O'Brien & Gere Foundry Demolition Report identifies 24
soil sampling locations and 42 soil samples collected from an approximately 0.3-acre area during the TCE remediation. The
footprint of the vapor plume identified in ES's 10/93 Phase IIA Technical Memorandum for RI/FS is approximately 8.5 acres.
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cap for VOC-impacted soils thereby minimizing migration into groundwater18. Concentrations of cis-
1,2-DCE, which had been present in shallow groundwater in 1994 in the area inferred to be the Source
Area for the Eastern Plume (the Loading Dock), are now being observed in a well located approximately
800 feet to the north (MWE-3) 15 years after removal of the cover system, and it is unclear if
contamination has migrated to this location from the inferred source, or if it represents a separate
previously unidentified source, due to the insufficient characterization and sparse groundwater
monitoring network. Despite the lack of plume delineation and apparent plume expansion,
groundwater use is restricted by the county ordinance and the affected area is supplied water by the
municipality. Private wells known to be in use and in existence have been sampled and COCs are below
MCLs. Discharge of the plume(s) to lake sediments and surface water may be impacting ecological
environments; however, EPA does not know of any current unacceptable risks to human or ecological
receptors despite concentrations exceeding current screening values (i.e., EGLE Part 201 GSI criteria,
EGLE Rule 57 Surface Water Quality Values, and/or 2015 EPA Ambient Water Quality Criteria) because
it is not clear that the PRP's past evaluation of risk (W&C, 2002) was consistent with EPA guidance. A
BERA was recommended to confirm that there are no receptors or unacceptable exposure occurring to
potentially affected populations; recommendations for further work are provided in EPA's SLERA and
EPA will review these criteria to evaluate potential impacts.
The contingency remedial action (installation of the MRS) for the Western Plume groundwater was
completed in 2009 and has removed substantially less VOCs than the volume calculated to control the
dissolution of DNAPL from the presumed source and enhance natural degradation. The 2009 ESD
estimated that the MRS would remove 36,000 to 46,000 pounds of source material (400-500
pounds/month), with results being apparent in POCW wells near the beach within 12-15 years, but
after 15 years, the MRS has removed only 1,894 pounds of total mass and exceedances of PRP's
proposed ACLs persist in many of the POC wells with increasing trends apparent in several sentinel
wells. It is possible that an increase in the pumping rates and/or installation of additional extraction
wells may be beneficial, however, a reevaluation of the data also suggests the source location was
inaccurately identified at the time of design.
Exceedingly high levels of several COCs are still present above the MCLs, the ACLs proposed by the PRP,
and available default screening criteria, and increasing levels of VC and cis-l,2-DCE have been found in
some wells, including several wells close to Lake Michigan. The 2019 FYR identified over 300 instances
of draft ACL exceedances in POC wells between 2013 and 2017 and concentrations above the draft
ACLs persist and are increasing at some of the POC locations in the current five-year monitoring period.
It is anticipated that high levels of contaminants are continuing to discharge to Lake Michigan sand and
sediment as a result, though adequate monitoring locations have yet to be established. As a result, it
does not appear that MNA supplemented by the MRS is an effective remedy for achieving MCL cleanup
objectives.
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?
Answer: Yes.
18 Foundry Demolition and Soil Removal Memorandum, W&C, May 11, 2009
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Question B Summary:
Generally, the exposure assumptions have not changed substantially since the time of the remedy
selection and still appear to be valid, but our understanding of exposure pathways has changed. A
primary focus of the ROD was the prevention of human exposure to VOCs via ingestion of
contaminated groundwater. Risk assessment for residual impacts in the soil performed in connection
with Rl work focused primarily on construction worker exposure, and impacts to ecological receptors
appear to have been inaccurately evaluated (EPA ERT, 2024). At the time, the potential for exposure to
VOCs via the vapor intrusion pathway was also not considered, and the understanding of the pathway
of concern has increased significantly since that time. Despite potential routes of exposure for human
health and ecological receptors being identified subsequent to implementation of the ROD that could
affect the protectiveness of the remedy, the available data indicate there are no known exposures
occurring via vapor intrusion, and EPA is also unaware of any unacceptable levels of risk to ecological
receptors at this time, recommending a BERA to confirm a lack of receptors or unacceptable
exposures.
Certain screening levels have changed since the time of the 2009 ESD, including the toxicity value for
TCE, which dropped by half the prior screening level in 2015, though laboratory methodologies have
not changed since 2009 for TCE in soil or ground water. The change does not affect the protectiveness
of the remedy with respect to groundwater cleanup levels, but the change in toxicity level does affect a
pathway of exposure (vapor intrusion) that was not considered in the original ROD.
The MCL for arsenic was reduced from 50 ug/L to 10 ug/L and the standard took effect January 23,
2006, after the Rl and FS reports and 1997 ROD had been completed. The change does not affect the
protectiveness of the remedy because groundwater is generally not used in the area for potable
purposes, so the pathway is not complete.
MCLs were also recently developed for PFAS in 2023, but data is currently unavailable on the
groundwater or surface water conditions.
The surface water criteria identified in the 1997 ROD were the Federal Ambient Water Quality Criteria
(AWCS) that were available from the NOAA Screening Quick Reference Tables (SQuiRTs) at that time19.
The ROD identifies that those 1994 AWQCs were values established by EPA in 1986 to be protective of
aquatic organisms in surface water20 , which have been updated. The Clean Water Act AWQCs are
identified as an ARAR in the 1997 ROD.
In 1995, EPA subsequently issued the Final Water Quality Guidance for the Great Lakes System,
instructing states to establish criteria for long-term protection of water quality in the Great Lakes. In
2000, EPA issued the Methodology for Deriving Ambient Water Quality Criteria for the Protection of
Human Health to aid in the development of recommended criteria and as guidance for states. EGLE
updated Part 4 Rules, Water Quality Standards, promulgated under Part 31, Water Resources
Protection, of the Natural Resources and Environmental Protection Act, 1994 PA 451, and on August 2,
19 National Oceanic and Atmospheric Administration, 1994. NOAA Screening Guidelines Hazmat Report 94-8, U. S.
Department of Commerce, NOAA, Coastal Resources Coordination Branch, Seattle, WA
20 U.S. EPA, 1986. "Quality Criteria for Water", Office of Water Regulations and Standards; Washington, D.C.; May 1986.
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2000, EPA approved the revisions to Michigan's Part 4 Rules, including Rule 57 (R 323.1057), Toxic
Substances. EPA published updated water quality criteria for 158 pollutants in 2002, and developed a
criteria calculation matrix with cancer potency factors, reference doses, relative source contributions,
fish intake values, and equations used to derive the 2002 human health criteria. EPA subsequently
updated its national recommended water quality criteria for human health for 94 chemical pollutants
in 2015, to reflect the latest scientific information and EPA policies, including updated fish
consumption rate, body weight, drinking water intake, health toxicity values, bioaccumulation factors,
and relative source contributions. The specific Human Cancer Drink Values developed under EGLE's
rules were established for TCE in 1997 and VC in 2021, and the Human Non-Cancer Drink Value was
established for trans-l,2-DCE in 2018. The current AWQS used for screening are substantially lower
than the AWQCs listed in the ROD, as identified in Table 4. Since the CWA-AWQCs are frozen at the
time of the ROD, additional information is needed to determine if the apparent exceedances of the
2015 AWQS affect the protectiveness of the remedy.
The general RAOs of the 1997 ROD were to: 1) eliminate potential risks to human health associated
with exposure to VOCs in groundwater; 2) reduce VOCs in groundwater plumes to achieve drinking
water standards; and 3) control the VOC source of contaminants. The risk to human health associated
with exposure to VOCs in groundwater via vapor intrusion has not been fully evaluated but the data
collected to date has not identified a current exposure concern. Additionally, since VOC sources of
contaminants were never conclusively identified, it is not clear those sources are being sufficiently
controlled. However, these RAOs are still valid.
While prior soil gas sampling indicated there were no apparent vapor intrusion concerns in the off-
property areas tested, a re-evaluation of the data indicated a much larger apparent source area at the
northwest corner of the PRP parking lot, based on the documented historical presence of TCE NAPL at
shallower depths than the presumed source at depth, and this is considered a source that was never
remediated. This represents an understanding of conditions that have changed, and/or a newly
identified contaminant source. The associated potential pathway of concern (vapor intrusion) was not
previously completely addressed. The PRP is currently preparing a work plan to address this issue,
though there are no known exposures presently confirmed.
The remaining exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the
remedy selection still appear to be valid.
QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy?
Answer: No.
No other information has come to light that would impact the effectiveness of the remedy. However,
there may be a need in the future to address site changes potentially related to climate change impacts
that were not apparent during remedy selection or remedy implementation, such as significant
fluctuations in lake levels or changes in precipitation, which may affect groundwater gradients and
contribute to variability in groundwater concentrations at certain locations.
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VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
None
Issues and Recommendations Identified in the Five-Year Review:
OU(s): 1/Sitewide
Issue Category: Changed Site Conditions
Issue: Cover system removal may have exacerbated contaminant migration.
Recommendation #1: Finalize work plan for conducting investigation of former
foundry and maintenance building area incorporating EPA/EGLE comments, and
complete investigation to determine effect of cover removal and potential for
releases of contaminants from wastes.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/26/2025
OU(s): 1/Sitewide
Issue Category: Changed Site Conditions
Issue: Nature and extent of contamination is insufficiently characterized for
evaluation of potential exposures.
Recommendation #2: Develop proposal for incremental supplemental
investigation; characterize all potential source areas21 and pathways of migration
in 3-dimensions using Membrane Interface Probe with sampling from the ground
surface to basal clay; conduct confirmatory soil analyses and groundwater high
resolution site characterization (HRSC/vertical aquifer profile) sampling with
direction from EPA; and complete 3-D visualization of contamination.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/26/2025
21 Characterize: 1) process areas shown in Figure 11a in Appendix S, and soil gas impacts shown in Figures 11b-
llg in Appendix S(original Figures in Appendix S are Figures 1-7 from the October 1993, Phase IIA Technical
Memorandum for Remedial Investigation and Feasibility Study, by ES-Engineering Science); and, 2) areas
identified in EPA's April 2023 Data Gap Memo (SSPA, 2023b). Delineation of impacts and exposure pathways in
3-dimensions should be used to support proposed boundary well, plume core well, sentinel well, beach bluff well,
pore water sampling, and/or soil vapor sampling installations (previously) proposed.
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OU(s): 1/Sitewide
Issue Category: Monitoring
Issue: Extent of groundwater contamination is undefined at sources, plume
boundaries, plume cores, sentinel wells, points of compliance, and former
beach bluff wells, with increasing contaminant concentrations in both plumes,
and evidence of shifting plume positions; the current monitoring network is
inadequate.
Recommendation #3: Optimize well installation proposals for boundary, beach
bluff, point of compliance, plume core, and/or sentinel wells) and install wells to
characterize/confirm the magnitude and extent of groundwater impacts22. Also
add EGLE monitoring wells (DEQ-1, DEQ-2, and DEQ-3) and available Bendix wells
OW-13, OW-15, OW-19, OW-20, OW-22, OW-24 and OW-25 to routine quarterly
monitoring program by January 2025.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/25/2026
OU(s): 1/Sitewide
Issue Category: Changed Site Conditions
Issue: Evaluation of potential exposures is inadequate.
Recommendation #4: Develop proposals, update site-wide QAPP, and implement
quarterly sampling for: 1) vapor intrusion investigations at targeted properties
and throughout the plume; 2) pore water sampling; and 3) expanded surface
water sampling for off-shore locations at groundwater discharge points.
Implement quarterly monitoring for vapor intrusion/soil gas, pore water, and
additional surface water sampling before the first Quarter 2027.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
2/26/2027
22 Delineation of impacts in 3-dimensions should be used to support proposed boundary well, plume core well, sentinel
well, beach bluff well, pore water sampling, and/or soil vapor sampling installations (previously) proposed, to define the
magnitude and extent of groundwater impacts depicted in Figures 10a - 10c in Appendix R.
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OU(s): 1/Sitewide
Issue Category: Changed Site Conditions
Issue: Ecological risk from site-related contaminants in surface water (e.g.,
Lake Michigan and Hickory Creek) has not been accurately assessed.
Recommendation #5: Update the SLERA and complete a Baseline Ecological Risk
Assessment to further evaluate the ecological risks of receptors exposed to
porewater at the Bendix Site, following the recommendations outlined in EPA
ERT's February 2024 SLERA (EPA ERT, 2024). Implement surface water sampling
at offshore locations coinciding with areas of venting contaminated groundwater
in Lake Michigan and Hickory Creek identified in recommendation #4.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
10/29/2027
OU(s): 1/Sitewide
Issue Category: Remedy Performance
Issue: Known groundwater impacts are not being sufficiently controlled by
implemented remedies to prevent contaminant migration and control the
potential for impacts.
Recommendation #6: Improve MRS performance in the Western Plume by the 3rd
Quarter 2028 by obtaining: 1) EPA approval of a proposal for installation of
additional recovery wells, increasing recovery rates, and/or operating all existing
recovery wells simultaneously; and/or 2) collect data and submit a Focused
Feasibility Study that outlines an array of alternatives for alternate remedial
technologies to reduce increasing contaminant concentrations in the
groundwater in both plumes, reduce the potential for continuing migration of
contaminated groundwater, and mitigate ongoing discharges to surface water
bodies and related ecological environments, to be used as the basis for a ROD
Amendment if warranted.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
10/27/2028
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OU(s): 1/Sitewide
Issue Category: Institutional Controls
Issue: ICs and Ordinances used to prevent exposure to contamination are only
partially effective.
Recommendation #7: Implement enforceable Institutional Controls/Ordinances
for all properties affected by contaminated groundwater, soil, and/or soil gas.
Finalize the ICfor the site property and renegotiate ICs for existing "agreements"
within 12-18 months. Controls must meet State and Federal requirements, similar
requirements of the Uniform Environmental Covenants Act, and/or EGLE
requirements for the use of local ordinances to prohibit the use of contaminated
groundwater and ensure exposures via all pathways of concern are prevented,
and access to the impacted area is ensured.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
10/29/2027
OU(s): 1/Sitewide
Issue Category: Institutional Controls
Issue: Draft ICIAP needs to be finalized.
Recommendation #8: Prepare a new, effective Institutional Control
Implementation and Assurance Plan and implement Long-Term Stewardship to
establish and document the controls, activities, responsibilities, and monitoring
necessary to ensure ICs are in-place and remain effective for all exposure
pathways in perpetuity, following incremental investigations of potential sources
and exposure pathways.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
10/29/2027
45
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OU(s): 1/Sitewide
Issue Category: Monitoring
Issue: Emergent contaminants 1,4-dioxane and PFAS have the potential to have
historically been used on-site in connection with brake manufacturing and only
limited analyses have been performed for 1,4-dioxane in 3 off-property wells.
Recommendation #9: Add 1,4-dioxane and PFAS to site-wide QAPP and complete
a site-wide evaluation of these emergent contaminants in groundwater before
determining if permanent modifications to the list ofCOCsfor quarterly sampling
is needed.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
11/1/2024
OU(s): 1/Sitewide
Issue Category: Monitoring
Issue: Additional monitoring locations established for various media will need
to be incorporated into quarterly monitoring program, based on the results of
incremental supplemental investigations.
Recommendation #10: Update the Long-Term Monitoring Plan and Operations &
Maintenance Plan.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
10/29/2027
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, accelerate site close out,
conserve energy, promote sustainability, etc.), but do not affect current nor future protectiveness:
• An update to the Quality Assurance Project Plan (QAPP) submitted in October 2000 is in
progress that will include methodologies for vapor intrusion sampling and analyses of
groundwater for 1,4-dioxane and PFAS and must be completed before work proceeds. EPA
requires an annual review of the QAPP by the PRP with updates on a frequency no less than
every 5 years, in accordance with EPA Requirements for Quality Assurance Project Plans EPA
QA/R-5 (March 2001) and EPA CIO 2015-S-02.1 for EPA's Quality Assurance Project Plan
Standard, (QAPP, April 3, 2024).
• Quarterly groundwater sampling should include reporting for all VOCs included in the list of
CPOCs in the 1997 ROD, and should include tetrachloroethene/perchloroethylene/perclene
46
-------
(PCE) due to detections in MRS effluent samples (W&C, 2023b), detections reported in the June
2023 Monthly Progress Report at MWE-1 and POCW-5B (W&C, 2023c) and apparent discharges
at the former south lagoon, the sewer line located north of Maiden Lane, and the dry well
located north of the former foundry (Appendix S, Figure llg), until source characterization is
completed and the data can be evaluated.
Note that recommendations from the State are provided in Appendix T, and EPA concurs with the
state's recommendations which were included herein.
VII. PROTECTIVENESS STATEMENT
OUl/Sitewide Protectiveness Statement
Protectiveness Determination:
Short-term Protective
Protectiveness Statement:
The remedy at the Bendix Corp./Allied Automotive Superfund site currently protects human health and
the environment because there are no known exposures to contamination occurring. The Site is
secured, and a groundwater ordinance restricts exposure to contaminated groundwater. However, in
order for the remedy to be protective in the long-term, the following actions need to betaken to ensure
protectiveness. These actions involve conducting a series of evaluations to adequately assess sources,
related impacts, and migration pathways, to characterize the full extent of contamination in all media
(soil, soil vapor, porewater, surface water, and groundwater) in three-dimensions, evaluate associated
exposure pathways and required controls, evaluate contingent actions to improve the implemented
remedy components and prevent continuing contaminant migration and discharges to surface water
bodies, update decision documents, finalize and revise ICs to ensure enforceable documents are in-
place to eliminate all unacceptable exposures, and implement a long-term plan to ensure ICs and
related monitoring are protective of human health and the environment. See the
Issues/Recommendations table in the previous section for a complete list of actions required.
VIII. NEXT REVIEW
The next FYR report for the Bendix Corp./Allied Automotive Superfund Site is required five years from
the completion date of this review.
47
-------
APPENDIX A - REFERENCE LIST
1986 -Quality Criteria for Water, EPA Office of Water Regulations and Standards, May 1986.
1993 - Phase IIA Technical Memorandum for Remedial Investigation and Feasibility Study, ES, October
1993.
1994 - NOAA Screening Guidelines Hazmat Report 94-8, U. S. Department of Commerce, NOAA, Coastal
Resources Coordination Branch, Seattle, WA
1997a - Remedial Investigation-Final, Volumes 1 & 2, W&C, July 1997.
1997b - Feasibility Study-Final), W&C, July 1997.
1997 - Record of Decision, EPA, September 30, 1997.
1998 - MDCH and ATSDR Public Health Consultation, Bendix Corporation/Allied Automotive,
St. Joseph, Berrien County, Michigan. September 23, 1998.
1999 - CD for RD/RA, EPA and Robert Bosch Corporation, October 5, 1999.
2000a - BGWDCP Work Plan, W&C, October 2000.
2000b - RD/RA QAPP, W&C, October 2000.
2002 - Ecological Risk Assessment, W&C, April 2002
2004 - Final Report for BGWDCP, W&C, January 2004.
2005 - ACL Groundwater Monitoring Work Plan, W&C, April 2005.
2006 - MDEQTechnical Memorandum: Bendix Superfund Site.
2006 - Public Health Consultation, ATSDR, December 2, 2006.
2007 - MDCH and ATSDR, Public Health Advisory Statement, June 22, 2007.
2007 - Notice of Exceedances of POC Criteria, EPA, August 30, 2007.
2008 - Demolition Oversight and Documentation-Foundry and Maintenance Building, O'Brien
& Gere, September 2008.
2009a - Mass Reduction System 90% Remedial Design, W&C, March 2009.
2009b -Technical Memorandum: Foundry Demolition and Soil Removal, W&C, May 2009.
2009a - Five-Year Review Report, EPA, August 2009.
2009b - ESD, EPA, February 2009.
2012 - Institutional Controls: A Guide to Preparing Institutional Control Implementation and Assurance
Plans at Contaminated Sites, OSWER 9200.0-77, December 2012.
2013 - Technical Memorandum: Churchill Farms Subdivision-Environmental Conditions and
Risk Evaluation, Environmental Consulting and Technology, September 2013.
2014 - Five-Year Review Report, EPA, April 2014.
2015a - Vertical Aquifer Sampling and Monitoring Well Installation Report, W&C.
2015b - Draft ICIAP, W&C, June 2015.
2015 - Churchill Farms Subdivision: 2014 Groundwater Monitoring Report, Mannik Smith
Group, July 2015.
2019a - Soil Vapor Sampling Summary Report, W&C, January 10, 2019.
2019b - MNA Assessment, W&C, January 2019.
2019c - Technical Memorandum: Monitoring Well Sampling Reduction, W&C, February 2019.
2019 - Five Year Review Report, EPA, August 2019.
2018, 2019, 2020, and 2021 - (Draft) Annual Reports, W&C.
2018-2022 - Monthly MRS Progress Reports, W&C.
2020 - Draft Foundry Investigation Work Plan, W&C, May 2020.
48
-------
2021 - Revised Draft ICIAP, W&C
2022 - Residential Well Sampling Analytical Results Memorandum, W&C, August 2022.
2022a - Evaluation of Groundwater Flow and Hydraulic Gradients, Bendix Corp./Allied Automotive
Superfund Site, SSPA, December 2022.
2022a - Transmittal of Calculated Mixing Zone-Based Groundwater-Surface Water Interface Criteria for
the Bendix Corp./Allied Automotive Superfund Site - Hickory Creek, EGLE, December 2022.
2022b - Transmittal of Calculated Mixing Zone-Based Groundwater-Surface Water Interface Criteria for
the Bendix Corp./Allied Automotive Superfund Site - Lake Michigan, EGLE, December 2022.
2022b - Comments on Woodard & Curran 2019 MNA Report and Initial Review of MNA Progress at the
Bendix Corporation/Allied Automotive Superfund Site, SSPA, December 2022.
2023a - December 2022 Monthly Progress Report, W&C, January 2023.
2023b - Draft 2022 Annual Report, W&C, April 2023.
2023a - Evaluation of the Groundwater Divide, Bendix Superfund Site, SSPA, April 2023.
2023b - Proposal for Addressing Data Gaps for the Bendix Superfund Site, SSPA, April 2023.
2023c - Conceptual Site Model (CSM) Report, Bendix Corp./Allied Automotive St. Joseph, Michigan,
SSPA, June 2023.
2023c - June 2023 Monthly Progress Report, Bendix Superfund Site, W&C, July 2023.
2023 - Bendix FYR Start Notification Letter, EPA, August 2023.
2023d - Bendix Five Year Review Site Visit Presentation by Bosch, Rev. 1, W&C, September 2023.
2023d - Comments on Available Soil Gas and Potential Vapor Intrusion Data at the Bendix
Corporation/Allied Automotive Superfund Site, SSPA, December 2023
2024 - Screening Level Ecological Risk Assessment for Aquatic Populations at the Bendix
Corporation/Allied Automotive Superfund Site Located in St. Joseph, Michigan, EPA ERT,
February 2024.
2024 - Draft Residential Well Sampling Report, W&C, March 2024.
49
-------
APPENDIX B - SITE LOCATION AND FEATURES
50
-------
Figure 1: Bendix Corp./Allied Automotive
Site Location and Features
Lake Michigan
-PW -- 311
~ r ¦ I
¦
mm
W ii[
¦I
jU - * - »t
Kay Manufacturing Co
itAustin-Tr
4'"
Lake Bluff-Terrace
* ,-4^ | J| ,
(.cdgate,'B.'r—
/J i
v - ¦ • o '
_ MRS
Wells
Maiden* Sn«
CatOxJ6
— Lake-Pine 0r-
•1 •
bert
Former j.
Foundry I
H i I
SVE j.
Weill
f
. • 1 , '
--Pauimar Ave
I I
'Ligpor Locker South Lagoon
Data:
Googl
USGS Stevensville Topographic Quadrangle
iSt© raqeiF-erttaifTcffArierica
Bendix Parcels
il.
Stevensville
¦ »
I
i Shore Health & Racquet C(ub
i * i
M. *
Qj
,c
o
- I
I c
I cu c
I 5 IS
¦ ^ r\ \
E -
•g: Maiden Ln «¦»
-------
APPENDIX C-ALTERNATE CONCENTRATIONS LIMITS (ACLs)
51
-------
FINAL REPORT
FOR BASELINE GROUNDWATER DATA
COLLECTION PROGRAM
REMEDIAL DESIGN/REMEDIAL ACTION
INCLUDING
GROUNDWATER MONITORING RESULTS
FROM SEPTEMBER 2003
ROBERT BOSCH CORPORATION
St. Joseph, Michigan
JANUARY 2004
Prepared by;
WOODARD &CURRAN
Engineering ¦ Science > Operations
41 Hutchins Drive
EPA Region 5 Records Cti. I Portland, ME 04102
(207) 774-2112
www.woodardcurran.com
369121
-------
TABLE 6-11
ALTERNATE CONCENTRATION LIMITS
EASTERN PLUME
Well ID
Compound
ACL
POCE-1
1,1-Dichloroethane
1
POCE-2
1,1 -D icUoroethane
37
Vinyl chloride
136
POCE-3
1,1-Dichioroethane
69
c is-1,2-D ichloroe thylene
595
Vinyl chloride
2,187
POCE-4
1,1 -Dichloroethane
3
cis-1,2-Dichloroethylene
320
Vinyl chloride
110
POCE-5
1,1-Dichloroethane
1
POCB-6
1,1 -Dichloroethane
1
cis-1,2-Dichloroethylene
568
Vinyl chloride
7
MWE-1
1,1 -Dichloroethane
74
1 j 1 -Dichloroethylene
13
cis-1,2-Dichloroethylene
10,003
T richloroethylene
358
Vinyl chloride
2,451
BDF.-l
1,1-Dichloroethane
12
BDE-2
Vinyl chloride
4410002
STE-2
1,1 -Dichloroethane
31
cis-1,2-Dichloroethylene
2,535
T richloroethylene
29
Vinyl chloride
80
STE-3
1,1 -Dichloroethane
47
cis-1,2-D ichloroethylene
341
Trichloroethylene
52
Vinyl chloride
101
Note:
1. Proposed ACLs are shown for wells with ACLs higher
than the current MCLs,
2. This ACL will not be used for future comparison, as a
replacement well has been established for BDE-2.
page 73
-------
TABLE 6-12
ALTERNATE CONCENTRATION LIMITS
WESTERN PLUME
Well ID
Compound
ACL
POCW-1A
1,1 -Dichloroethane
3
Trichloroethylene
18
POCW-1B
1,1 -D ichloroethane
3
Trichloroethylene
18
POCW-2A
1,1-Dichloroethane
30
cis-1,2-Dichloroethylene
2,630
T richloroethylene
1,050
Vinyl chloride
529
POCW-2B
1,1 -Dichloroethane
1
Trichlorocthylcne
149
POCW-3A
3,1 -Dichloroethane
20
1,1 -Diehloroethylene
71 '
cis-1,2-Dichloroethylene
5,400
Trichlorocthylcne
7
Vinyl chloride
3,800
POCW-3B
1,1 Dichloroethane
127
1,1 -D ichloroethylene
285
cis-1,2-Dichloroethylene
12,000
Trichloroethylene
7,000
Vinyl chloride
11,000
POCW-3C
1,1 -Dichloroethane
1,500
1,1 -Diehloroethylene
46
cis-1,2-Dichloroethylene
38,000
trans-1,2-Dichloroethylene
2,000
Trichloroethylene
' 44,000
Vinyl chloride
14,000
POCW-4A
Vinyl chloride
4
POCW-4B
1,1 -Dichloroethane
1
Trichloroethylene
11
Vinyl chloride
4
POCW-4C
1,1 -Dichloroethane
1
Trichloroethylene
IE
Vinyl chloride
4
POCW-5B
1,1 -Dichloroethane
3
POCW-6
1,1-Dichloroethane
3
Vinyl chloride
39
page 74
-------
TABLE 6-12
ALTERNATE CONCENTRATION LIMITS
WESTERN PLUME
Well ID
Compound
ACL
MWW-l
1,1-Dichloroethane
70
cis-1,2-Dichloroethylene
76
Trichloroethylene
292
Vinyl chloride
941
MWW-2
1,1 -Diehloroethane
864
1,1 -Dichloroethylene
224
cis-l,2-Dichloroethylene
57,539
trans-1,2-Dichloroethylene
944
Trichloroethylene
997
Vinyl chloride
3,111
MWW-3
1,1 -Diehloroethane
26
1,1 -Dichloroethylene
12
cis-1,2-Dichloroethylene
3,953
Vinyl chloride
2,910
BDW-1
1,1 -Diehloroethane
77
cis-1,2-Dichloroethylene
380
Trichloroethylene
101
Vinyl chloride
274
BDW-2
1,1-Dichloroethane
46
Vinyl chloride
17
STW-1
1,1-Dichloroethane
1
STW-2A
1,1 -Diehloroethane
26
1,1 -Dichloroethylene
16
cis-1,2-Dichloroethylene
902
Trichloroethylene
20
Vinyl chloride
994
STW-2B
1,1 -Diehloroethane
138
1,1 -Dichloroethylene
15
cis-1,2-Dichloroethylene
4,648
Trichloroethylene
6,515
Vinyl chloride
1,337
STW-3
1,1-Dichloroethane
5
Trichloroethylene
59
Vinyl chloride
3
Note:
1. Proposed ACLs are shown for wells with ACLs higher
than the current MCLs.
page 75
-------
ALTERNATE CONCENTRATION LIMITS
GROUNDWATER MONITORING WORKPLAN
Bendix Superfund Site
St, Joseph, Michigan
April 2005
k
WOODARD & CURR AN
Engineering ¦ Science < Opetations
41 Hatching, Diive
Poitland, ME 04102
(20/1 7/4-21! 2
www. woods; dr.urran f-o;n
-------
Table 1; Western Plume ACLs
Well ID
CimipiMinil
AC I
POCW- i A
1,1 -PidilLMwfrunt.'
i
!
1 nclikmK'thylene
IS
Pi )CW-! p.
1.1 1 hdiloMi-'lhatR-
A
1 ui'ltlonicthylcno
IN
PO( "W 2 \
1,1-1 >tchli tixH Uiiint-
1: "
a.--lC Dichl'jnR'thvU'ni
,6 jU
I nrhloiiH'thvlctic
1 OMI
Vinyl chlontk*
l'i K'VV ,'H
IJ-IlichiiHiirtlmnr
i
11 u 'tkiXK'lhvleiU'
140
!'IH W * A
1 1- 1 >irtlloUH.'|]UllK'
C
1, l-l>icliliuooili\lnu-
]<¦'
cis M Diohlorm'rh>lenc
\41M>
l't fdilra'nethyk'm"
ViiiV 1 '/liloiiilt'
tson
P(K W-M
L! •! SichluHHnhaiir
12/
1,1 -I'lK'lilonii'thvHuic
1X •>
t is 1.2-1 iiclilouiiiiivlcsK'
12.«i0i
11 ifliloiocllivk'ni'
7,(«I0 i
\lmyl t hl(Hulc
1 1 ,1Mb
in »CWC» '
LCI K'lilnri itihylene
J 8,(10'
Intns. I.? niclikirucfhyii'iic
LlUK
TudiknurthytciH-
. i 4 J >' H'
Vmyl diitwuk-
I-1,01 V
Vinyl dilontic
4
pocw -;r
1 1 -DicMrtrocrhaiic
7"
Tnchtoroethylenc
ii
Vmyl ciik'tidc
4
P>) \\ 4C
IJ-liieWoiorthane
i
T nrfiloTuclliyla te
is
Vinyl chloride
1 4
P< iCWofl
1,1 ~D ichkmx-thane
3
I'OCW-6
1 J-Piclilotoeilmne
3
{ \''uiyl chloride
4*1
f\ »
1. Proposed ACLs are shown foi wells witli ACLs liigliei tliaw the anient MCI.;?.
2. The ACL presented is a revised AC!, based on the July 2t)CM Vulpe ACT review.
Koilwn Bo^'i t ('
-------
Table 2: Eastern Plume ACLs
Well ID
P! KT-1
poo :
IM HI- 3
Pt)( 'F 4
ciK'i:
PO< '!•
Compound
. [ DlcllllHUOtllJIit- _
.I ISnkK.uiti'th.mi:
Vuivl idc
,I Dichluioethutic
cis 1,2 ! >khl.j!LH:(livicuc
Vinvl i'isltit itlc
J -Diehk'rocllv.ne
in ¦ I¦Dh-hlomct)iy1c>is
'inyl chloride
. MVIiloroeltuiw _
,! l>u-liluineilu>sic
i.s-1 ,? •^^K•hhn^H•^livlc1R,
Vinyl chlonde
<\r
I
tl*}
:m s /
"i
\
I in
568
?
Nokv
g;
'ropo.scci AC 1 x ure shown I or wv\h with AVI s luntin than the current M(1,
Rr-htil Biv^ch G>rporaiit^ (?Co4117.02,1
;NAE. A5'. I, Wui ii"
Wi?od=irrl Afc ("urr.rn
April 20fJ5
-------
APPENDIX D - MAP OF INSTITUTIONAL CONTROLS
52
-------
Properties within modeled extent of groundwater plume,
subject to Berrien County Groundwater Use Restriction, taken
from 10/28/21 Draft ICIAP, Revision 1, by W&C
(note, addresses and PINs redacted as PI I)
Table 2-1: Properties within modeled extent of groundwater plume
Map
Historical
Parcel/Tax Map ID3 I Number Street
City
ID1
Map ID*
T ~1
X
Saint Joseph
1
w
Saint Joseph
i
u
Saint Joseph
V
Saint Joseph
40
New
Saint Joseph
"42 ~1
New
Saint Joseph
43
New
Saint Joseph
44
H
Saint Joseph
45
M
Saint Joseph
46
T 1
Saint Joseph
"47
J1
Saint Joseph
48
New
Saint Joseph
"49
New
Saint Joseph
50
New
Saint Joseph
-------
Map
»«
If".::! J- irti'v-rf
»w»icNn©wi
Map ID-
51
j:
52
i
53
*«...,.....
: s=; *»
Si
NcA
55
AA
56
fwl*
57
Nc*
58
0
59
R
60
S
81
e
62
D
o
N-?a
76
k:
77
k *
"3
LSN
79
f.ris
li
04 C
83
fi-r.v
84
'2
Chuitlw
m ¦ ¦¦
4
B
B
6
B
;
6
s
e
9
6
10
6
11
6
12
6
13
6
14
B
15
6
16
6
17
6
18
6
City
Saint Joseph
Se-.tvOteph
Sa'Koceph
€*** !i ~ ¦» *n . an. tL
n vOirpn
o3. t v«x?pn
SjntvOCfph
.**. v I f«. w .yfc few
o2 •' vO.trpn
Ssrt Joseph
m 1 gfy,rM*. -S&s Ihy
wScpfi
Sa^.tvoceph
Saint Joseph
&3*ucseph
Saint Jose ph
Sjrts^eph
,1 *
Saint Joieplt
Saint Joseph
Slilt Jittph
85 ",t „ DC-iph
Saint Joseph
. u *. Dc. pn
Sa'.UOttph
\jNora
Saint Joseph
Saint Joseph
$anUo-:epb
S='! vO^oh
ooNni «ft)Scpn
mhr joscpn
os "i % oicpn
fiatfll ,|fK*nh
%#¦%¦»» H WSMTfrli
Samt Joseph
SanUoceph
Saruottph
-------
Map
IP
iitlirteal
Map 10-
Parcel/Tax Map ID' Number 1 Street
cur !
'?
E
SantvOttch |
20
__|
Sar.Uoetph
21
T~~
52«vKeeh
22
6
Sifflt Joseph |
23
_
Saint Joseph |
2^
"e ~~"1
_____ —j
25
6
Sar;*ph
28
6
-Si't.c^ph |
29
B
Sa it .ocrph [
30
B
SaTtvDttph
31
B
Si nt .o-:?ph [
32
B
o&m %K)S€pn j
33
B
Saruoieph J
34
B
Sa 'X ,'Ktph
"35
8
_____
36
B
Sj-tvKeph J
37
B
| jfo. <*»¦%?>. 1
-^2""! vC^tpn j
38
_
3?
6
€***•*&Xaas-St' I^SfcjSte i
^HfH JO^pn |
41
B
Saw* Joseph |
If
6
Lake Breeze Estates 1
|j
C
OTRlrt ^O^pfS 1
14
c
5?. rkoceph |
15
c
Sa.'Uoceph ]
66
c
Sa'Lixeph
67
c
1^' misggJjf. 8 .a*, a.- f< 1
•^3 "i * B^r *«» C :urr> 0 S Lantf Demotion in ftAniwy 2021.
-------
Properties with Access Agreements within modeled plume
area used for purposes of draft Interim Well Restriction,
from DRAFT Rev. 1, Institutional Control Implementation
And Assurance Plan, dated October 29, 2021; indeterminate
adequacy of remaining institutional controls.
(note, addresses and PINs redacted as Pll)
Table 3-2: Properties Within the interim Weil Restriction Area with Access Agreements
Map
ID1
Historical
Map ID*
Parcel/Tax
Map IDJ
Deed
Restriction
Access
Agreement
Property
Address3
Restriction/Access Instrument Type
and Terms
52
I
¦
Yes
No
¦
"Property Access Agreement* and
"Registration of Restrictions" Recorded
9/2/98 Liber 1911, Page 759 Not install
future wells on property without the
written permission of the Berrien
County Health Department This
document runs with the land and is an
associated document m the BCRD for
this Parcel ID |
-------
m
ParcelfT«
Map ID2
Property
Property Access Ajrccfncrt And
"Regulation of iesfceions* Reewirf
22139 liberie Page 863. Not
irtstal fata® welt on property witjoBt
§1# writtsn pemissM of (he Berrien
^ ^ HT\ -* ^ |ffiA.^..>. r: ,11r -fc f
wjwtiy neaiin uepafunenL License w
allow Bosh, EPA, ccwtfuciws to cnlcf
property for nstahng fnonrtormcj kb8$
®»€l taking soil, cteefc wife? and
anc i tne fJare as 'ie:ev>3-v :c rstal"
and monitor wels and perform
sampfing that may Ik tti t>v E®A
Dc current snoEanajJOCiaied
document in fee BCRD for cc~ r, jm acccfQ rw !c Vast it
Deed recorded tf!#? in lite 102 of
Condo pages 1-o?" Sran'.s accer* to
MOEQ and its representatives and
f *c»k n »st 3i<3 cciSi"*sptraiol
pfQilftclifiltll?,.. Document does not
Sit above for ChurchX Farms
SttMifisiofi
-------
Map
D<
Htstoncal
Map ID-'
Parctffax
MapD>
Deed
Restriction
Access
Agreement
c
J
B
Yes
Yes
6
B
Yes
Yes
7
B
Yes
Yes
8
B
Yes
Yes
9
B
Yes
Yes
10
B
Yes
Yes
'2
B
Yes
Yes
*3
B
Yes
Yes
14
B
Yes
Yes
15
B
Yes
Yes
16
B
Yes
Yes
•7
B
Yes
Yes
18
B
Yes
Yes
19
B
Yes
Yes
20
B
Yes
Yes
21
B
Yes
Yes
22
B
Yes
Yes
-a
A- V
B
Yes
Yes
it
B
H
Yes
Yes
flL-..— ... mS*, #
Property
RestoictionfAcceM tnstnuiKnt Type
and Terms
above for Churchi Fans
SuWMsion
See above for ChurchM Farms
Subdivision
See atow for Churchi Farms
OUOQmSIOn
See above for Churchi Farms
SuMi*»w
Set atow for Qiwch.il
SiAcjiyisiofl
See above for Churchtfi fains
SuMwision
Se# ate* for Church 1 Fa—*
SuMifiswi
See above for Churchsi Fan
SiiWifisiofi
See above for Churdhi Farms
C,
See alow for Churchi Farms
Subdnmmt
See above for OhurchHill f arms
See above for Churchi f aram
„ .L **V ,«,L !C,,v%
mOVS Iw V^vHJrdlKKi r muM
SiMmskm
a.. nf....... |/H,r-^sk;ii r a,
OCC wBvVC «W » <3» >«*S>
SuMifim
See above for Churchiit Farms
SiiMiwswi
See above for Churchi Farms
Subdivision
See above for Churchi Farms
8«MMsof»
See alow for Churchi Farms
Subdivision
-------
lap
IP
u« _i
ntSlOiiCa
KtaplF
25
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26
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28
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29
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31
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32
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33
8
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35
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jS
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37
B
38
8
1£j
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41
B
Deed
ie%
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Yes
Ve>
¥#s
Yes
Yes
Property
See above for Cfcwchil Farms
See above for Churchcl Farms
See alow for ChurchiK Farms
A*r* • ^PM •* * • * "!••• ' 5 '•¦J'
See above for Giitchi Farms
SuMiwswt
Sac al«e for ChurcM = 8*"$
SubdwisiM
Ste above for Churchi Fwk
S«M«fSi©n
See above for ChurchM Farms
S«WMs»n
See above for ChurchM farms
SuMfwsicw
Ste alow for Churchi Farms
SaWMsw
See ate* for ChucW f am*
See above for Churchill f aw
Subdwwon
See above for Cht^duS F arms
See above fa Church 1 f arm
SuMitisttt
See above for ChurchM Finns
SuW«s«i
See above for Churchill Farms
-------
Map
IP
Hwtoncaf
Map IP
Deed
Restrict! on
Ajretrowt
f»rnnrfr
rfopcny
^^ sAc ciI'll!
andTenm
H
«.(0£d >V Sl8^*
Estates', Recc-*a637*BUber155,
Page 1 The Master Deed incoiT*>*a,.et
63
I
Yes
.. - J
i
Article V 0 Easerents •r fe
Condomrwm Property in General
^ errn. ¦& ^
RjG&lr>ctk)fis in (j^of ^
« Ib^Js.-.$£ *.t iUkn, Qjytiifiw f\Srn #
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Bute Coff|%i#Biti Division, it
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L-frer 194S, page 868.
tie Mac?' 3f?»d
C
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I
I
'Ajrecnot and Kbles* recorded
January- 21 195# at liber'94: Page
&S5 Are-1**"! ow.aes 3*4* Ow-**:
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ikj® ooniesl^ of convncfcri
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i*toita§ etplwiicft ofthenwersi
ectste Ait" Cv*. fit! sK-<#n<3 mot. ss c*
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fwaniipisltate Oncunal w:e: I1 has been
• ubor/-i^r^ 3ncJ **•* 0^5^*
64
Yes
Yes
«5 Or udKt C
CCfMfaWWIl!
IS
m
V
Yes
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See atcvs 'or iake B*«:e Es'Jtec
C«*«iri*i S^wa«
-------
IP
Map BP
Parceiffm
Map ID1
Deed
RestricSon
Access
Property
Aooress4
I;IriCfc0»JMCCtTi i iflSifJ2H£'li Tipe
71
Y«
¥es
72
Yet
Yet
73
Yes
Yes
74
Yes
Yes
Condty- * u*r) SufcQiv; c*i
See above fy Lake Brefce Erjie;
See SKve'of u!»e &te:e Estater
Ck>iiBiii*ii SuMiiwofi
•Se? accve 'or Breeze £:«'.«
u.».. ... i -- r>:- « -k 94a t^itn
r «. "»»w»vrt lite?Aw«-<£« JiM 0*.« *9*** Ci <•»** %*¦* CTiij IwdIv" •
fps,T..., ..r r. ,.»..... *«. ^ ,. ...,.» i» •* r .»*^ .V^A-
o%0 f%MJ ®* ecff*if iv*^ia« * y#
-------
reas Requiring Institutional Controls
October 2019: 100 ppb Total
VOC Interpretive Concentration
Contour
Bosch-Owned Parcels Requiring
Institutional Controls
Interim Well Restriction
Area
Properties Within the Interim Well
Restriction Area with Restrictive
Covenant
Bendix Superfund Site
St. Joseph, Michigan
WOODARD
&CURRAN
Project #: 205410.19
Map Created: October 2021
Map ID corresponds to
Table 2-1 and Appendix
B parcel information
Properties Outside the Interim
Well Restriction Area with
Restrictive Covenant
Third Party GIS Disclaimer: This map is for reference and graphical purposes only and should not be relied upon by third parties for any legal decisions.
Any reliance upon the map or data contained herein shall be at the users' sole risk. Data Sources: ESRI Wbrld Imagery, Berrien County GIS
-------
APPENDIX E - JUNE 2007 ADVISORY LETTER FROM MDCH AND ATSDR
53
-------
DESIGNED BY. DWP
DRAWN BY. DWP
BENDIX SUPERFUND SITE
ST. JOSEPH, MICHIGAN
Legend
ADVISORY AREA
BEACH AREA AT CHURCHILL FARMS
(AERIAL PHOTO - 2004)
Advisory Area
FIGURE 2
JOB NO. 205410.11
DATE: MAY 2007
0
40
80
160
240
Figure 3: MDCH Advisory Area
-------
State of Michigan
JENNIFER M. GRANHOLM DEPARTMENT OF COMMUNITY HEALTH JANET OLSZEWSKI
governor Lansing director
June 22, 2007
To Current Residents of Churchill Farms:
The Michigan Department of Community Health (MDCH) and the Agency for Toxic Substances and Disease
Registry (ATSDR) are writing to inform you of a recent public health evaluation of the Lake Michigan
swimming area associated with the Churchill Farms Subdivision in Shoreham, Michigan that was issued
December 22, 2006. This evaluation is related to off-site movement of chemically contaminated groundwater
from the Bendix Superfund Site (EPA ID# MID005107222) to the Churchill Farms (CF) beach area. A copy of
the report entitled Public Health Consultation-Groundwater Discharge to Lake Michigan-Bendix
Corporation/Allied Automotive can be obtained by contacting MDCH toll free at 800-648-6942, and are
available for review at two local libraries listed at the end of this letter. The document can be downloaded at:
http://www.michigan.gov/documents/mdch/BendixCorpHC122206 186070 7.pdf
MDCH and ATSDR Public Health Advisory Statement
MDCH and ATSDR advises that:
Children of all ages avoid playing and swimming in the groundwater contaminant discharge
plume venting through the lake sediments (i.e., lake sands) into the northern near-shore waters of
the Churchill Farms beach. This Advisory Area is off-shore in the water and is shown on the map
attached to this letter (Figures 1 & 2). MDCH and ATSDR find all areas outside the Advisory
Area are safe for recreational use by adults and children. This includes the beach and all other
near-shore swimming areas outside the defined Advisory Area.
Basis for the Public Health Concern
The Michigan Department of Environmental Quality (MDEQ) has identified the area (i.e., Advisory Area)
where chemically contaminated groundwater (i.e., pore water) is moving upward (i.e., venting) through lake
sands (i.e., sediment) into lake water (i.e., surface water) at the northern end of the Churchill Farms beach area
(see the attached maps Figures 1 and 2). Within the lake sands of the Advisory Area, a number of large stones
and slabs of reinforced-concrete exist. The Advisory Area is generally not thought to be used for recreational
purposes. However, the MDCH and ATSDR are concerned that children could play in the lake sediments of the
Advisory Area and may come into contact with high levels of vinyl chloride. Vinyl chloride contaminated
groundwater is found within the shallow sediment of the lake bottom. Vinyl chloride has also been found in the
surface water of the advisory area, but at much lower concentrations that are not a public health hazard.
Therefore MDCH and ATSDR assume that the vinyl chloride is diluted when the contaminated groundwater
mixes with the surface water as it moves upward out of the lake sediments.
The MDCH/ATSDR report identifies these concerns and concludes that there is an "indeterminate hazard" to
children who might play in the Advisory Area during the summer months. An indeterminate hazard conclusion
means that the MDCH and ATSDR have determined that children playing in the lake sediments may come into
3423 NORTH MARTIN LUTHER KING JR. BLVD. • P.O. BOX 30195 • LANSING, MICHIGAN 48909
www.michigan.gov • (517) 335-8024
-------
contact with vinyl chloride in the Advisory Area, but are not able to state with certainty what amount of risk
children would face from that contact. The reason for the indeterminate conclusion is that necessary information
is not available to reach a more definite conclusion.
U.S.EPA conducted a human health risk assessment in 1997 to support the Record of Decision (ROD).
Potential receptors considered in the assessment were adults and children using the lake for recreational
purposes. Potential exposure scenarios included surface water ingestion and dermal contact. A site-specific
quantification of potential risks was calculated, and the estimated carcinogenic and non-carcinogenic risks were
below the U.S. EPA target risk ranges.
Robert Bosch LLC conducted a human health risk assessment in 1999 at the direction of U.S. EPA. Bosch also
conducted additional human health risk assessments in 2004 and 2007 that focused on recreational use of the
Churchill Farms beach area by both children and adults. The most recent assessment included evaluation of the
risk to children wading in shallow lake water. The Bosch assessments all concluded that the beach area is safe
for recreational use by everyone.
The MDCH review of the sediment pore water data collected by MDEQ has identified some uncertainties about
the hazards of direct contact to waders in an isolated area of off-shore lake sands. However, it is the opinion of
U.S. EPA that the remedy selected in the ROD remains protective of human health and the environment.
At the time the U.S. EPA human health risk assessment was performed; it was not known that the groundwater
contamination was discharging in the near-shore waters at the Churchill Farms beach. U.S. EPA evaluation,
using the best available science in 1997, was based on surface water testing and did not evaluate contact with
the contaminated groundwater within the lake sediments. The additional human health risk assessments of 1999,
2004, and 2007 remained focused on surface water (i.e. swimming) and shallow beach groundwater (i.e.
digging in the sand at the beach) as the primary contact media and did not evaluate contact with the
contaminated groundwater within the lake sands (i.e., pore water), which is located approximately 20 feet from
the shoreline.
Therefore, the Public Health Consultation-Groundwater Discharge to Lake Michigan-Bendix
Corporation/Allied Automotive conducted by MDCH/ATSDR addresses a previously unevaluated human
exposure pathway, and considers the exposure of children to the vinyl chloride found in the water within the
lake sands of the Advisory Area. This MDCH/ATSDR health consultation is the basis for the Public Health
Advisory Statement issued in this document and remains in effect.
Continued Monitoring
The MDEQ will continue to monitor the contaminant discharge plume in this area and update MDCH as new
information becomes available. Bosch also continues to monitor the surface water and ground water in the
beach area on a quarterly basis to confirm that the beach and all other near-shore swimming areas outside the
defined Advisory Area are safe. Copies of monitoring reports and risk assessments conducted by Bosch in
consultation with U.S. EPA are maintained at the local Bendix Superfund Site document repositories at the St.
Joseph and Lincoln Township Public Libraries (addresses below).
Contact Information
For questions about the MDCH/ATSDR Public Health Consultation please contact Mr. Kory Groetsch,
Toxicologist of MDCH. For more information regarding the Bendix Superfund Site (EPA ID#
MID005107222), please contact Mr. Bill Ryan, Remedial Project Manager for the U.S. Environmental
Protection Agency or Mr. Mark Henry, Senior Environmental Engineer with the MDEQ.
-------
Bill Ryan
Remedial Project Manager
Superfund Division SR-6J
U.S. EPA, Region 5
77 West Jackson Blvd.
Chicago, IL 60604-3590
Phone (312)353-4374,
FAX (312) 353-8426
ryan. williami @epa. gov
Mark A. Henry
Senior Environmental Engineer
MDEQ-RRD, Superfund Section
Constitution Hall
PO Box 30426
Lansing, MI 48909
Phone (517) 335-3390
FAX (517) 335-4887
HenryM A@mi chi gan. gov
Kory J. Groetsch
Toxicologist
MDCH-DEH
Capital View Bid
201 Townsend St.
Lansing, MI 48913
Phone (517) 335-9935
FAX (517)335-9775
groetschk@mi chi gan. gov
Public Libraries:
Maud Preston Palenske Memorial Library
500 Market Street
St. Joseph, MI 49085
(269) 983-7167
Lincoln Township Public Library
2099 West John Beers Road
Stevensville, MI 49127
(269) 429-9575
Sincerely,
Kory J. Groetsch, Toxicologist
Michigan Department of Community Health
Division of Environmental Health
-------
DESIGNED BY. DWP
JOB NO .205410.11
DATE: MAY 2007
Figure 2 Inset!
Legend
Advisory Area
1 0
75
150
300
450
BENDIX SUPERFUND SITE
ST. JOSEPH. MICHIGAN
GROUNDWA TER DISCHARGE AREA
(AERIAL PHOTO - 2004)
FIGURE 1
Figure 1. Arial photo of the Churchill Farms neighborhood and beach with the green box showing the general location of the Advisory Area.
-------
DESIGNED BV. DWP
DRAWN BY. DWP
BENDIX SUPERFUND SITE
ST. JOSEPH, MICHIGAN
Legend
ADVISORY AREA
BEACH AREA AT CHURCHILL FARMS
(AERIAL PHOTO - 2004)
Advisory Area
FIGURE 2
JOB NO. 205410.11
DATE: MAY 2007
Figure 2. Close-up aerial photo of thq Advisory Area shown in Figure 1.
-------
APPENDIX F - FORMER FOUNDRY AND COVER AREA
54
-------
DRAWN BY: DRJ
March 2009
DOC: Demo .plan.MXD
BENDIX SUPERFUND SITE
ST. JOSEPH, MICHIGAN
Figure 4a - Cover
Removal Areas
WOODARD
&CURRAN
JOB NO.: 205410.15
SCALE: 1" = 100'
-------
North!
Parking Lot
Maiden Lane
Drywell
Cleaning &i
^Grinding
Department
Calcium
Oxide
Bunker
^Former J
Foundry^'
Lagoon i
Bosch
Manufacturing
Plant *..
Scrubber
Solvent
Storage
Sludge
Pit •
Drywell
Sludge /
_ Waste
Pit
Foundry
Maintenance
Building
Former
Loading Dock
Lagoon
Maintenance
Storage /
Drum Storage
.Outside Storage>j
Maintenance Area
Former South
Lagoon
Former Site Layout
Former Foundry and
Maintenance Building
3737 Red Arrow Highway
St. Joseph, Michigan
Figure 4b
Approximate Foundry Demolition Area
(2008)
Approximate Maintenance Building
Demolition and Soil Removal Area
(2008) 0 0005 0_01
0.02
¦ Miles
Third Party GIS Disclaimer: This map is for reference and graphical purposes only and should not be relied upon by third parties for any legal decisions.
Any reliance upon the map or data contained herein shall be at the users' sole risk. Data Sources:
-------
Former Foundry Floor
Plan with Utilities and
Proposed Sampling
Locations
Former Foundry
3737 Red Arrow Highway
St. Joseph, Michigan
T2
C
Q)
O)
0>
-J
All Utilities (1990)
Electric
Process Water
Sewer
Storm
Water
~ Septic Tanks (1974)
| Liquid Sumps (1977)
^^^¦kStorm/Sewer Pipe (1997)
Catch Basins (1997)
— MRS (2010) 0
120
¦ Feet
Proposed Soil Boring
4
Proposed Soil Boring/Monitoring Well
N
A
WOODARD
&CURRAN
Project#: 205410
Map Created: June 2021
Third Party GIS Disclaimer: This map is for reference and graphical purposes only and should not be relied upon by third parties for any legal decisions.
Any reliance upon the map or data contained herein shall be at the users' sole risk.
-------
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1 ;
1. Former Floor Plan
Former Foundry and
Maintenance Building
3737 Red Arrow Highway
St. Joseph, Michigan
T3
C
(b
O)
(U
—I
Figure 4d
0 0.004 0.008
0.016
I Miles
N
A
>
WOODARD
&CURRAN
Project #: 205410
Map Created: December 2020
Third Party GIS Disclaimer: This map is for reference and graphical purposes only and should not be relied upon by third parties for any legal decisions.
Any reliance upon the map or data contained herein shall be at the users' sole risk. Data Sources:
-------
Drywell
Truck Well/
Loading Dock £
Levelers
Sodium
Cleaner
(no known
tanks)
Hydraulic
Pump
toEPiV
MCLDINlf
Transformer
(mezzanine)
RAMP
INSPECTION
Furnace
Hopper Storage
1 Tea Gas
Isocure Tanks
Scrubber/ Tea (80 gal)
2 Acid Solution i
T"1 Bath Storage Calcium /
» fl V—Tank —r Oxide -W .
A Bunker /
-i DEPT. CORE ROOM Isocure
\ / Storage
^ / Tanks
|POURING IAIN!
DEP-rVrt V
A-Line
O.KUIM (\ |
pE1
A Cupola KfJ
| (mezzanine)
M L
I DieJ
Shop l±
Pattern
[Shop
17 Pit/
Punchout
Hoist
ICWet
Scrubbers
Underground
Section
Electrical
®l Sub-j^
., Station
Oxide &
Flourspar
Room
CRANE BAY
Hydraulics
m Dust - ... ^
M Collector with T.
-h Exterior
V> Diesel
\vTank
Dust '
Collectors with
Exterior
^ Drive
Units/ !
Dry Dust |
Collector
Baghouse
Furnace±
Elect Jj£-
r Room —A.
B Cupola ]
(mezzanine)"
Pre-Mix n
Bonder o
Tanks ^
Fuel -n
Oil ¦
Storage
Furnace
cB-Line; line 3
Waste/,
! Fuel |
Oil j
Storage
H HjH +-l-f gHHfl fi-
: Baghouse R
Drywell
Sludge'
I Pit
Baghouse
s Southern '
Baghouses
Waste
! Pit
:ompactoi
OXYGEN
I R&IEV.TNinl i I 1
Unknown Foundry Areas
t4~|
Steam
D10 [oil-filled machineiy]
Room
COKE BUNKER
D15 [pit adjacent to A-line pit; SW corner]
E3 [former hydraulic system location]
A-ea 9 [red tank]
Filter Room [room located NE ofN Bag House]
Outside Parts
Storage
Pits A through J
Pits uncovered during excavation
Locations where material was backfilled on-site
2. Former Features
Former Foundry and
Maintenance Building
3737 Red Arrow Highway
St. Joseph, Michigan
Approximate Foundry Demolition Area
Approximate Maintenance Building Demolition
and Soil Removal Area
Approximate Sub-Slab Soil Sample Location
(O'Brien & Gere, 2008)
Note: The location, dimensions, and descriptions of site features presented
on this plan are based on interviews and multiple historical plans prepared
by others. These details should be considered approximate.
0.016
I Miles
WOODARD
&CURRAN
Project #: 205410
Map Created: December 2020
Third Party GIS Disclaimer: This map is for reference and graphical purposes only and should not be relied upon by third parties for any legal decisions.
Any reliance upon the map or data contained herein shall be at the users' sole risk. Data Sources:
-------
A-Line,
Under
Hydraulic
Pump
FLR-FDRY-
01-002
PCBs Below
Allowable Limit
B4/MW4
FLR-FDRY-
01-006
PCBs Below
Allowable Limit
Belcw
Equipment
Throughout
A Line Pit
PCBs & Metals
Below .Allowable
Limit
DUS-FDRY-
01-009
RAMP
TCLP
Arsenic 0.02 mg/L
Barium 0.70 mg/L
Copper 0.01 mg/L
Lead 0.25mg/L
Zinc 7.91 mg/L
Pit "A"
Sludge,
NW
Section
PIT-204CNW
TCLP
Barium 0.49 mg/L
Copper 0.01 mg/L
Zinc 2.51 mg/L
Pit "A"
Sludge,
South
Section
Barium 0.13 ug/kg
Cadmium 0.006
ug/kg
•anve^mui2ug/Kg
Exterior Pit
Water
TCLP
Arsenic 0.02 mg/L
Barium 0.46 mg/L
Copper 0.01 mg/L
Lead 0.16mg/L
Zinc 3.48 mg/L
Pit "A"
Sludge,
NE
Section
PIT-204BNE
Chrome 320 ppm
Lead 620 ppm
TCLP Chromium 0.08 mg/L
TCLP Lead 0.05 mg/L
High Bay
Area
DUS-FDRY-
01-011
B2/MW2
High Bay FLR-FDRY-
Area 01-020
PCBs Below
Allowable Limit
Hydraulic
Pump Unit
FLR-FDRY-
01-010
PCBs Below
Alowable Limit
B1/MW1
B8 CRANE BAY
Under Two
Hydraulic
Pumps
FLR-FDRY-
PCBs Below
Alowable Limit
Under Two
Hydraulic
Pumps
FLR-FDRY-
01-013
PCBs Below
Alowable Limit
utri. i
"MOLDING
TCLP
Barium 0.31 mg/L
Lead 0.12 mg/L
Zinc 4.45 mg/L
Pit "B"
Sludge
COOLING LINE
TCLP
Barium 0.39 mg/L
Cadmium 0.012 mg/L
Copper 0.04 mg/L
Lead 0.11 mg/L
Zinc 3.53 mg/L
'iCOMPACTOljf
MWE-
TCLP
Barium 0.36 mg/L
Cadmium 0.012 mg/L
Copper 0.05 mg/L
Lead 0.08 mg/L
Zinc 2.60 mc^L
Abandoned
Rail Spur
r&ieving
INSPECTION
Dock
Levelers
Floor
FLR-FDRY-
01-003
PCB Total 2.4
ppm
Dock
Levelers
Floor
FLR-FDRY-
01-004
PCBs Below
Allowable Limit
Dock
Levelers
Floor
FLR-P1-001
FLR-P1-002
FLR-P1-003
PCBs Below
Detection Limit
(<330 ug/kg)
Hydraulic
Pump
-P"? 24
INSPEfcTION £"L™-
B-Line Pit;
Under
Drive Unit
FLR-FDRY-
01-014
PCBs Below
Allowable Limit
B-Line Pit;
Under Drive
Unit
DUS-FDRY-
01-006
PCBs & Metals
Below Allowable
Limit
North Side
of B-Line
FLR-FDRY-
01-015
PCBs Below
Alowable Limit
B-iine, East
Side OFM
OFM-FDRY-
01-001
PCBs Below
Alowable Limit
North Side
of B-Line
DUS-FDRY-
01-007
PCBs & Metals "
Below Alowable
Limit
I A-Line,
Under
Punchout
I Hoist
DUS-FDRY-
01-001
Metals Below
Allowable Limit
A-Line
Punchout
Hoist
FLR-FDRY-
01-005
PCBs Below
Allowable Limit
E17 Pit
DUS-FDRY-
01-003
PCBs & Metals
Below Allowable
Limit
> Rn,
Under"B-
Shaker" Unit
DUS-FDRY-
01-010-A
PCBs & Metals
Below Alowable
Limit
Under"B-
Shaker" Unit
DUS-FDRY-
01-010-B
PCBs & Metals
Below Alowable
Limit
Under"B-
Shaker" Unit
FLR-FDRY-
01-019-B
PCBs Below
Alowable Limit
[B3/MW3
Southern #
Baghouses
I
Sample ID Notes:
DUS = dust
FLR = floor
FDRY = foundry
OFM = oil-filled equipment
RRT = railroad tracks
BAL = railroad ballast
Southern
Bag House
DUS-FDRY-
01-008
Lead 550 ppm
TCLP Lead
0.05 mg/L
Southern
Bag House
FLR-FDRY-
01-016
PCBs & Metals
Below Allowable
Limit
Southern
Bag House
MIS-FDR Y-
01-001
Lead 300 ppm
Southern
Bag House
FLR-FDRY-
01-017
PCBs Below
Allowable Limit
Note: Locations of previous samples are approximate and
are based on available information.
Abandoned
Rail Spur
Anthracene 400 ug/kg
Benzo(a)anthracene 1,100 ug/kg
Benzo(b)fluoranthene 1,600 ug/kg
Benzo(k)fluoranthene 1,300 ug/kg
Benzo(ghi)perylene 900 ug/kg
Benzo(a)pyrene 1,200 ugdcg
Chrysene 1,900 ug/kg
Fluoranthene 4,200 ug/kg
lndeno(1,2,3-cd)pyrene 800 ug/kg
Naphthalene 300 ug/kg
Pentachlorophenol 400 ug/kg
Phenanthrene 2,500 ug/kg
Pyrene 3,300 ugd
-------
APPENDIX G - SUMMARY OF FOUNDRY/COVER DEMOLITION WASTES
55
-------
Table 1 Summary of Material Disposal during Foundry Demoliton (after Table 2. OBG, 2008}
Type
Container Type
Quantity
Units of
Measure
Name/Description
C & D
Trailer
39
Truck
Construction and Demolition Debris
C & D
Trailer
28
Ml Train
Construction and Demolition Debris
Hazardous
Cylinder
17
each
Ammonia, anhydrous
Hazardous
Cylinder
7
each
Compressed gas
Hazardous
Drum
4,400
lbs
Perclene impacted with trace PCB
Hazardous
Open Top Box
48,299
kg
Polychlorinated Biphenyls, Solid
Hazardous
Drum
1
each
Waste Aerosols, Flammable
Hazardous
Drum
1
each
Waste amines, flammable, corrosive
Hazardous
Drum
1
each
Waste corrosive liquid, acidic, inorganic
Hazardous
Drum
each
Waste corrosive liquid, acidic, organic
Hazardous
Drum
1
each
Waste corrosive liquid, basic, inorganic
Hazardous
Drum
2.400
lbs
Waste Diesel Fuel w/trace PCB
Hazardous
Drum
1
each
Waste Flammable liquids
Hazardous
Drum
1
each
Waste flammable liquids 2,2-dibromo-3-
nitrilopropionamide
Hazardous
Drum
1
each
Waste flammable liquids, Aluminum, petroleum
distillates
Hazardous
Drum
1
each
Waste Flammable liquids, toxic
Hazardous
Drum
1
each
Waste flammable solids, organic
Hazardous
Drum
1,200
lbs
Waste Gasoline
Hazardous
Drum
1
each
Waste Isocyanates, flammable, toxic
Hazardous
Drum
400
lbs
Waste Kerosene
Hazardous
Drum
1
each
Waste mercury
Hazardous
Drum
1
each
Waste oxidizing liquid
Hazardous
Box
1
each
Waste paint, petroleum distillates, alkyld resin
Hazardous
Drum
1
each
Waste paint, petroleum distillates, alkyld resin
Hazardous
Cylinder
1
each
Waste Propane
Hazardous
Drum
400
lbs
Waste Triethylamine
Non-Hazardous
Closed
80
yd3
ACM (Incl. Transite)
Non-Hazardous
Tanker
375
gal
Contaminated Liquids, Not Hazardous
Non-Hazardous
Drum
2
each
Ethylene Glycol, Mineral Oil
Non-Hazardous
Box
1
each
Ethylene Glycol, Mineral Oil
Non-Hazardous
Drum
1
each
Grease
Non-Hazardous
Drum
1.250
gal
Isocure Part I
Non-Hazardous
Drum
550
gal
Isocure Part II
Non-Hazardous
Drum
800
lbs
Non DOT Regulated Material Isocure Part I
Non-Hazardous
Drum
3,200
lbs
Non DOT Regulated Material Isocure Part I!
Non-Hazardous
Drum
800
lbs
Non DOT Regulated Material Limestone
Non-Hazardous
Drum
400
lbs
Non DOT Regulated Material Metal Cleaner
Non-Hazardous
Tote or Drum
700
Sbs
Non DOT Regulated Material Prevok
Non-Hazardous
Drum
4,800
lbs
Non DOT Regulated Material Scrubber Balls
Non-Hazardous
Drum
2,400
lbs
Non DOT Regulated Material Transformer Dust
Non-Hazardous
Drum
1,600
lbs
Non DOT Regulated Material Water and Resin
Non-Hazardous
Open Top Box
15
yd3
Non-DOT Regulated Material 75-11281 scrubber
balls RCI# A7511291N5
Non-Hazardous
Ml Train
3255
Yd3
Non-Hazardous Sand
Non-Hazardous
Ml Train or Open Top Box
1175
yd3
Non-Hazardous Special Waste
Non-Hazardous
Vac Box
30
yd3
Non-Hazardous Special Waste - Pre-Mix Binder
Non-Hazardous
Tanker
3,550
gal
Used Oil/water, Not Hazardous
Universal Waste
Box
24
Box
Fluorescent Tubes
Universal Waste
Drum
1
Drum
Ballast
Universal Waste
Drum
1
Drum
Batteries
Universal Waste
X
o
CO
1
Box
CRTs
Universal Waste
Box
2
Box
Electronic components, CRTs
Universal Waste
Drum
5
Drum
HID Lamps
Universal Waste
Bottles
2
Each
Mercury ampules from mercury switches
Table 2 Pages from 2008.09.24.OBrienGere_FosjndryDemo
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Hazardous
Drum
1,200
lbs
Waste Gasoline
Ashland, Inc., South Bend, IN
000333695
FLE
25-Apr-08
Drum
400
lbs
Waste Kerosene
Ashland, Inc., South Bend, IN
000333695
FLE
25-Apr-08
Drum
400
lbs
Waste Triethylamine
Ashland, Inc., South Bend, IN
000333695
FLE
25-Apr-08
Drum
2,400
lbs
Waste Diesel Fuel w/trace PCB
Pollution Control, East Chicago,
IL
000333698
FLE
25-Apr-08
Open Top Box
15,860
kg
Polychlorinated Biphenyls, Solid
Waste Management, Emelle,
AL
001808389
FLE
19-May-08
Open Top Box
16,039
kg
Polychlorinated Biphenyls, Solid
Waste Management, Emelle,
AL
001808390
FLE
19-May-08
Drum
4,400
lbs
Perclene impacted with trace PCB
Veolia ES Technical Solutions,
West Carrollton, OH
000333730
FLE
20-May-08
Open Top Box
16,400
kg
Polychlorinated Biphenyls, Solid
Waste Management, Emelle,
AL
000333729
FLE
21 -May-08
Drum
1
each
Waste Aerosols, Flammable
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Cylinder
1
each
Waste Propane
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Cylinder
7
each
Compressed gas
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Cylinder
17
each
Ammonia, anhydrous
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
File: Table2.xls
Page 1 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Hazardous
(Continued)
Drum
1
each
Waste flammable liquids, Aluminum, petroleum
distillates
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste flammable liquids 2,2-dibromo-3-
nltrlloproplonamlde
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Box
1
each
Waste paint, petroleum distillates, alkyld resin
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste paint, petroleum distillates, alkyld resin
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste Flammable liquids
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste Isocyanates, flammable, toxic
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste Flammable liquids, toxic
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste amines, flammable, corrosive
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste flammable solids, organic
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste oxidizing liquid
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste corrosive liquid, basic, inorganic
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste corrosive liquid, acidic, organic
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste corrosive liquid, acidic, inorganic
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Waste mercury
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
File: Table2.xls
Page 2 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Non-Hazardous
Vac Box
10
vd
Non-Hazardous Special Waste - Pre-Mix Binder
Orchard Hill, Watervliet, Ml
603
26-Mar-08
Vac Box
20
vd
Non-Hazardous Special Waste - Pre-Mix Binder
Orchard Hill, Watervliet, Ml
604
28-Mar-08
Open Top Box
20
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
601
28-Mar-08
Open Top Box
20
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
602
28-Mar-08
Open Top Box
20
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
605
28-Mar-08
Open Top Box
20
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
606
31 -Mar-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
607
31 -Mar-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
608
31-Mar-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
609
31-Mar-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
610
31-Mar-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
611
31-Mar-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
612
31-Mar-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
613
31-Mar-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
614
1 -Apr-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
615
1 -Apr-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
616
1-Apr-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
617
1-Apr-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
618
1-Apr-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
619
1-Apr-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
624
1-Apr-08
Open Top Box
20
yd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
625
1-Apr-08
Drum
1,250
gal
Isocure Part I
Pollution Control Industries,
East Chicago, IN
000333666
FLE
3-Apr-08
Drum
550
gal
Isocure Part II
Pollution Control Industries,
East Chicago, IN
000333666
FLE
3-Apr-08
Closed
40
yd
ACM (Incl. Transite)
Orchard Hill, Watervliet, Ml
515
4-Apr-08
Closed
40
yd
ACM
Orchard Hill, Watervliet, Ml
516
10-Apr-08
Open Top Box
20
yd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
620
10-Apr-08
Open Top Box
20
yd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
621
10-Apr-08
Open Top Box
20
yd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
622
10-Apr-08
Open Top Box
20
yd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
623
10-Apr-08
Tanker
3,400
gal
Tank cleaning rinse water
Industrial Water Services,
001935200
8-Apr-08
File: Table2.xls
Page 3 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Non-Hazardous
(Continued)
Truck
1,550
gal
Used oil/water - non-haz waste
Industrial Water Services,
Chicago, IL
4422202
JJK
14-Apr-08
Open Top Box
15
yd
Non-DOT Regulated Material 75-11281 scrubber balls
RCI# A7511291N5
Pollution Control Industries,
East Chicago, IN
333688
FLE
24-Apr-08
Drum
2,400
lbs
Non DOT Regulated Material Transformer Dust
Pollution Control Industries,
East Chicago, IN
000333698
FLE
25-Apr-08
Drum
400
lbs
Non DOT Regulated Material Metal Cleaner
Pollution Control Industries,
East Chicago, IN
000333696
FLE
25-Apr-08
Drum
4,800
lbs
Non DOT Regulated Material Scrubber Balls
Pollution Control Industries,
East Chicago, IN
000333696
FLE
25-Apr-08
Drum
500
lbs
Non DOT Regulated Material Prevok
Pollution Control Industries,
East Chicago, IN
000333694
FLE
25-Apr-08
Tote
200
lbs
Non DOT Regulated Material Prevok
Pollution Control Industries,
East Chicago, IN
000333694
FLE
25-Apr-08
Drum
800
lbs
Non DOT Regulated Material Isocure Part I
Pollution Control Industries,
East Chicago, IN
000333693
FLE
25-Apr-08
Drum
3,200
lbs
Non DOT Regulated Material Isocure Part II
Pollution Control Industries,
East Chicago, IN
000333693
FLE
25-Apr-08
Drum
1,600
lbs
Non DOT Regulated Material Water and Resin
Pollution Control Industries,
East Chicago, IN
000333693
FLE
25-Apr-08
Drum
800
lbs
Non DOT Regulated Material Limestone
Pollution Control Industries,
East Chicago, IN
000333693
FLE
25-Apr-08
Ml Train
35
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
632
15-May-08
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
633
15-May-08
File: Table2.xls
Page 4 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Non-Hazardous
(Continued)
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
634
15-May-08
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
635
15-May-08
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
636
15-May-08
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
637
16-May-08
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
638
16-May-08
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
639
16-May-08
Ml Train
35
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
640
16-May-08
Tanker
25
gal
Used Oil, Not Hazardous
RS Used Oil Services, Monee,
IL
004428252
JJK
19-May-08
Tanker
2,000
gal
Used Oil/water, Not Hazardous
Indsutrial Water Services,
Chicago, IL
004428499
JJK
29-May-08
Tanker
375
gal
Contaminated Liquids, Not Hazardous
Indsutrial Water Services,
Chicago, IL
004428533
JJK
5-Jun-08
Drum
2
each
Ethylene Glycol, Mineral Oil
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Box
1
each
Ethylene Glycol, Mineral Oil
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Drum
1
each
Grease
Ashland, Inc., South Bend, IN
004047216
JJK
6-Jun-08
Ml Train
35
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
641
11 -Jun-08
Ml Train
35
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
650
11 -Jun-08
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
651
11-Jun-08
Ml Train
35
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
652
11-Jun-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
629
11-Jun-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
630
11-Jun-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
631
11-Jun-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
654
12-Jun-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
655
12-Jun-08
Open Top Box
20
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
658
12-Jun-08
Ml Train
35
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
653
12-Jun-08
Ml Train
35
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
660
12-Jun-08
Ml Train
35
Vd
Non-Hazardous Special Waste
Orchard Hill, Watervliet, Ml
657
12-Jun-08
File: Table2.xls
Page 5 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Non-Hazardous
(Continued)
Ml Train
35
vd
Non-Hazardous Special Waste
Orchard H
II, Watervliet, Ml
658
12-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
661
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
662
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
663
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
664
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
665
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
666
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
667
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
668
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
669
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
901
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
902
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
903
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
904
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
905
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
906
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
907
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
908
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
909
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
910
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
911
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
912
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
913
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
914
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
915
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
916
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
917
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
918
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
919
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
920
18-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
921
18-Jun-08
File: Table2.xls
Page 6 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Non-Hazardous
(Continued)
Ml Train
35
vd
Non-Hazardous Concrete
Orchard H
II, Watervliet, Ml
922
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
923
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
924
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
925
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
926
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
927
18-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
928
19-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
929
19-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
930
19-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
931
19-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
932
19-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
933
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
934
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
935
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
936
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
937
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
938
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
939
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
940
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
941
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
942
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
943
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
944
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
945
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
946
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
947
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
948
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
949
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
950
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
951
20-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
952
19-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
953
20-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
954
20-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard H
II, Watervliet, Ml
955
20-Jun-08
File: Table2.xls
Page 7 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Non-Hazardous
(Continued)
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
956
20-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
957
20-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
958
20-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
959
20-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
960
20-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
961
20-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
963
20-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
967
24-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
968
24-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
969
24-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
970
24-Jun-08
Ml Train
35
vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
971
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
972
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
973
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
974
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
975
25-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
976
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
977
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
978
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
979
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
980
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
981
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
982
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
983
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
984
24-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
801
25-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
802
25-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
803
25-Jun-08
Ml Train
35
Vd
Non-Hazardous Sand
Orchard Hill, Watervliet, Ml
804
25-Jun-08
3,290
File: Table2.xls
Page 8 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Universal Waste
Box
19
Box
4' Fluorescent Tubes
Fluorecycle, Ingelside, IL
11072
1 -May-08
Box
5
Box
8' Fluorescent Tubes
Fluorecycle, Ingelside, IL
11072
1 -May-08
Drum
1
Drum
Ballast
Fluorecycle, Ingelside, IL
11072
1 -May-08
Drum
1
Drum
Batteries
Fluorecycle, Ingelside, IL
11072
1 -May-08
Drum
5
Drum
HID Lamps
Fluorecycle, Ingelside, IL
11072
1 -May-08
Bottles
2
Each
Mercury ampules from mercury switches
To plant for disposal with
normal waste stream
n/a
1 -May-08
Box
1
Box
CRTs
To plant for disposal with
normal waste stream
n/a
1 -May-08
Box
2
box
Electronic components, CRTs
Polution Control Industries,
East Chicago
000333749
FLE
6-Jun-08
C&D
Trailer
1
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
26-Mar-08
Trailer
4
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
27-Mar-08
Trailer
1
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
2-Apr-08
Trailer
2
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
4-Apr-08
Trailer
2
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
7-Apr-08
Trailer
12
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
9-Apr-08
Trailer
4
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
10-Apr-08
Trailer
7
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
18-Apr-08
Trailer
6
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
21 -Apr-08
Trailer
2
Ml Train
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
22-Apr-08
Trailer
5
Ml Train
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
30-Apr-08
Trailer
5
Ml Train
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
1-May-08
Trailer
4
Ml Train
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
8-May-08
Trailer
6
Ml Train
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
9-May-08
Trailer
6
Ml Train
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
12-May-08
Trailer
2
Truck
Construction and Demol
tion Debr
s
Orchard Hill, Watervliet, Ml
n/a
5-Jun-08
File: Table2.xls
Page 9 of 10
12/16/2008
-------
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST JOSEPH, MICHIGAN
TABLE 2 - WASTE LOG SUMMARY
Type
Container Type
Quantity
Units of
Measure
Name/Description
Disposal Location
Manifest
No.
Date
Shipped
Total
Trucks
Construction and Demolition Debris
Orchard Hill, Watervliet, Ml
Ml Train
Construction and Demolition Debris
Orchard Hill, Watervliet, Ml
File: Table2.xls
Page 10 of 10
12/16/2008
-------
APPENDIX H - SOIL EXCAVATION AREAS DURING FOUNDRY COVER REMOVAL
56
-------
I
J?
I
!
I
NOT TO SCALE -f
LEGEND
i O'.K.*/S.<'-yPU:
:; nsjtp O'Brign & G&re Engineers, inc.
Figure 5a Sample Location Map (OBG, 2008)
-------
i r
i i i
F^w6ekHAppfwimate-timrts-o#-T6E™lmpacted-9oH-Exctrvatron
Grass arQa
Figure 5b Approximate Limits of TCE Impacted Soil Excavation (W&C, 2009)
-------
2 jgEgggSgSSSaT
RNIIIIMV MMnBUNCE
|£fY g - Mm ^ MS
3®fHflt® 33t§¥iaU«¥ll
\
KJr
_V
Figure 5c ICE Excavation Sample Locations (OB
ROBERT BOSCH LLC
3737 RED ARROW HIGHWAY
ST. JOSEPH, MICHIGAN 49085
CONFIRMATION SAMPLE
LOCATION MAP
MAINTENANCE BUILDING
FILE NO, 6407.42677
APRIL 2009
HEN IS GERE
200? © OsBrier) & Gere Engineers, Inc.
-------
APPENDIX I - SURFACE WATER SAMPLING LOCATIONS 2020
57
-------
er Sampfe
Legend
A Surface Water Sample Location
-f-v Existing Monitoring Well
SW-3
SW-4
POCW-3A, B, C
SW-2
POCW-2A, B
SW-1
BENDIX SUPERFUND SITE
ST. JOSEPH, Ml
Woodard
&Curran
SURFACE WATER LOCATIONS
(AERIAL PHOTO - SEPTEMBER 2020)
DOC: Figure 6-1 SW Loc.mxd
SCALE: As Shown
JOB NO.: 205410.23
DATE: April 2023
SOURCE: UAV
DRAWN BY: NJK/KCS
-------
APPENDIX J - PORE WATER SAMPLING LOCATIONS (2000-2004)
58
-------
POCW-6
BB-04A
P0CW-4B i POCW-4C
A"
^POCW-4A
PViWPVPPRIVM
, P0CW-3B • P0CW-3C
, Tgocwp
IP0CW-2BV ^
P0CW;2mHB
RTW-9R
Figure 7a - Pore Water Sampling Locati
Legend
Monitoring Wells
Pore Water Sample Criteria Exceedances
0
No Exceedances
•
DWC
0
DWC and GSIC
o
GSIC and FAV
o
GSIC, GVIIC and FAV
•
GSIC, GVIIC and GCC
CVOC Isoconcentrations
- CVOC Isoconcentrations
Marin k:
»¦— jxt-- TECHNICAL SKILL.
Ol I II II 1 CREATIVE SPiWT.
r GROUP
Notes:
GSIC = Site-Specific Mixing Zone Based Groundwater Surface Water Interface Criteria (TCE,
cis&trans-1,2-DCE, 1,1-DCE and Vinyl Chloride)
GVIIC = Groundwater Volatilization to Indoor Air Inhalation Criteria (TCE, 1,1-DCE and Vinyl Chloride)
FAV = Part 57 Final Acute Value (TCE and cis-1,2-DCE)
¦ GCC = Groundwater Contact Criteria (Vinyl Chloride)
DATE
2/10/16
MDEQ POREWATER SAMPLE
CRITERIA EXCEEDANCES
Bendix Site
St. Joseph, Berrien County, Michigan
DRAWN BY 0ESIGNED8Y PROJECT NO.
-------
s
I
4 54-10
S5- 10
l
-------
JF Tflll"lll
¦Hb
ft ft
N
i
55—10
ND
S4-10
ND
S3-16
ND
DISTANCE
FROM
SHORE
(TYP.)
Figure 7c - Pore Water
Sampling Locations
uRjiPhCFC <5!V f\LE
40 6CJ so
5°!
IEGEMQ ' '
$$5 SA EPA GEOPRuBt SPRUNG LOCATIONS
60 VOCs CONCENTRATIONS
o WOODARD & CUPRAN SAMPLING LOCATION* SEPTEMBER, i',399
A GPT-6 CRT EXPLORATION (MONITOR WELL)
f POCW 15
AIL GROUNDWATER CONCENTRATIONS ARC PRESEHiYP A3 ug/f
GROUNDWATER SAMPLE DEPTH 0 5' BELOW SEDIMENT SURFACE
SAMPLES COLLECTED SEPTEMBER, 1999
{ IN FEET )
I Inch « 80 1
BOSCH BRAKING SYSTEMS
ST» JOSEPH, MICHIGAN
;k.0Y: ROD
I CONCEPTUAL MODEL
^rjfTRI 71 f u ix> VOCs
1 SCALE
j__
1 =
I JOB NO.:
DATE: NOVEMBER, 1999 I SHEET:
95194.14 J
Icon, .mod
^ vvarAFor : :t
-------
~\
V.
Q
NORTHWEST
SOUTHEAST 2
640 +
620 +
CPT SOUNDING AND
GROUNDWATER SAMPLE
LOCATION
SLOTTED-AUGER
GROUNDWATER
SAMPLING LOCATIONS
¦100-
GEOPROBE GROUNDWATER
SAMPLE LOCATION
MONITORING WELL SCREEN
GROUNDWATER LEVEL
INTERPRETED CONCENTRATIONS OF TOTAL
VOC's IN GROUNDWATER (ppb)
GROUNDWATER
FLOW PATH
20
Figure 7d - Pore Water
Sampling Locations
I PES BY KDK I PR BY KAP I CK BY KDK
200
200
scale
400
feet
scale
CONCEPTU
.INTERPRETIVE
REMEDIAL INVESTIGATION REPORT
BOSCH BRAKING SYSTEMS
ST. JOSEPH. MICHIGAN
SCALE. NOTEP
DATE DEC 1999
JOB NO 9319414
|3194512B
JV WO0DARD &CURRAN
Engineering Science Operations ^
-------
APPENDIX K - GROUNDWATER SAMPLING LOCATIONS & STATISTICS
59
-------
P0CW-5A,B
BB-04A
POCW-6
BB-03A,B
P0CW-4A,B.C
BB-02A,B,C
STW-1
BB-01A
STW-2A,B
P0CW-2A.B
POCW-1 A,B
STW-3
P0CW-3A,B,C
BDW-1
MWW-3
OW-25
OW-29
MWW-101C
MWW-101B
MWW-101A
MWW-2R
OW-19
MWW-1 RA
MWW-1 RB
OW-20
MWE-3
OW-24
OW-8
EW-3
MWW-100A
MWW-100 B
MWW-102A
MWW-102 B
MWW-102C
EW-2
MWE-1
BDW-2R
OW-22
TOW-26
OW-26
OW-27
OW-15
OW-17
OW-13
Legend
OW-7
MWE-2
OW-5
SVP-5
SVE-1 thru SVE-4
SVP-1 thru SVP-6
Piezometer
PW-2
OW-16
OW-3
Extraction Well
Well in Current Monitoring Network
Soil Vapor Monitoring Point
MW-3
BENDIX SUPERFUND SITE
ST. JOSEPH, MICHIGAN
CURRENT & HISTORIC
MONITORING WELL LOCATIONS
Soil Vapor Extraction Well
OW-1
OW-2
Soil Vapor Extraction System Monitoring Point
Abandoned
(AERIAL PHOTO - 2004)
Woodard
&Curran
BGW-1
SCALE: As Shown
DOC: MonitoringWellLocations
1,200
5 Feet
Notes:
1) The locations of the onsite wells not in use, new monitoring wells,
and piezometer as shown are approximate.
DATE: April 2023
JOB NO.: 205410.23
DRAWN BY: NJK
SOURCE: 2004 ORTHO
-------
Number of
Number of Non-
Number of
Detected
Percent of
Detects where
Detected
Samples 10 to
Percent of
Detections
Number of
Number of
Number of
Reporting Limit
Samples
10,000 Times
Percent Non
Detections
Exceeding 10
Maximum
sspaAnalyte
MCL
Location
Wells
Samples
Non-Detects
Exceeds MCL
Exceeding MCL
MCL
Detects
Exceeding MCL
Times MCL
Detected Value
Units
1,1-Dichloroethane
East
12
209
137
0
0
0
65.6%
0.0%
0.0%
8.5
ug/L
1,1-Dichloroethane
MWE
3
59
18
0
0
0
30.5%
0.0%
0.0%
71
ug/L
1,1-Dichloroethane
POCW
20
267
140
0
0
0
52.4%
0.0%
0.0%
58
ug/L
1,1-Dichloroethane
Surface
4
60
60
0
0
0
100.0%
0.0%
0.0%
ND
ug/L
1,1-Dichloroethane
West
20
352
194
0
0
0
55.1%
0.0%
0.0%
51
ug/L
1,1-Dichloroethane
West & POCW
40
619
334
0
0
0
54.0%
0.0%
0.0%
58
ug/L
1,1-Dichloroethene
7
East
12
209
194
13
0
0
92.8%
0.0%
0.0%
3.7
ug/L
1,1-Dichloroethene
7
MWE
3
59
45
26
7
0
76.3%
11.9%
0.0%
34
ug/L
1,1-Dichloroethene
7
POCW
20
267
180
7
3
0
67.4%
1.1%
0.0%
36
ug/L
1,1-Dichloroethene
7
Surface
4
60
60
0
0
0
100.0%
0.0%
0.0%
ND
ug/L
1,1-Dichloroethene
7
West
20
352
183
47
71
0
52.0%
20.2%
0.0%
39
ug/L
1,1-Dichloroethene
7
West & POCW
40
619
363
54
74
0
58.6%
12.0%
0.0%
39
ug/L
1,1,1-Trichloroethane
200
East
12
209
209
0
0
0
100.0%
0.0%
0.0%
ND
ug/L
1,1,1-Trichloroethane
200
MWE
3
59
59
0
0
0
100.0%
0.0%
0.0%
ND
ug/L
1,1,1-Trichloroethane
200
POCW
20
267
252
0
0
0
94.4%
0.0%
0.0%
0.67
ug/L
1,1,1-Trichloroethane
200
Surface
4
60
60
0
0
0
100.0%
0.0%
0.0%
ND
ug/L
1,1,1-Trichloroethane
200
West
20
352
351
0
0
0
99.7%
0.0%
0.0%
0.95
ug/L
1,1,1-Trichloroethane
200
West & POCW
40
619
603
0
0
0
97.4%
0.0%
0.0%
0.95
ug/L
Alkalinity
East
12
202
0
0
0
0
0.0%
0.0%
0.0%
540000
mg/L
Alkalinity
MWE
3
56
0
0
0
0
0.0%
0.0%
0.0%
480000
mg/L
Alkalinity
POCW
20
266
0
0
0
0
0.0%
0.0%
0.0%
440000
mg/L
Alkalinity
Surface
4
0
0
0
0
0
NA
NA
NA
NA
Alkalinity
West
20
348
0
0
0
0
0.0%
0.0%
0.0%
500000
mg/L
Alkalinity
West & POCW
40
614
0
0
0
0
0.0%
0.0%
0.0%
500000
mg/L
Calcium
East
12
202
2
0
0
0
1.0%
0.0%
0.0%
435000
mg/L
Calcium
MWE
3
56
4
0
0
0
7.1%
0.0%
0.0%
495000
mg/L
Calcium
POCW
20
266
1
0
0
0
0.4%
0.0%
0.0%
910000
mg/L
Calcium
Surface
4
0
0
0
0
0
NA
NA
NA
NA
Calcium
West
20
348
6
0
0
0
1.7%
0.0%
0.0%
455000
mg/L
Calcium
West & POCW
40
614
7
0
0
0
1.1%
0.0%
0.0%
910000
mg/L
Chloride
East
12
202
1
0
0
0
0.5%
0.0%
0.0%
115000
mg/L
Chloride
MWE
3
56
0
0
0
0
0.0%
0.0%
0.0%
320000
mg/L
Chloride
POCW
20
266
0
0
0
0
0.0%
0.0%
0.0%
340000
mg/L
Chloride
Surface
4
0
0
0
0
0
NA
NA
NA
NA
Chloride
West
20
348
0
0
0
0
0.0%
0.0%
0.0%
375000
mg/L
Chloride
West & POCW
40
614
0
0
0
0
0.0%
0.0%
0.0%
375000
mg/L
cis-l;2-Dichloroethene
70 East
12
214
99
0
54
40
46.3%
25.2%
18.7%
3600
ug/L
cis-l;2-Dichloroethene
70 MWE
3
60
0
0
43
42
0.0%
71.7%
70.0%
31000
ug/L
cis-l;2-Dichloroethene
70 POCW
20
269
92
0
92
46
34.2%
34.2%
17.1%
11000
ug/L
cis-l;2-Dichloroethene
70 Surface
4
60
8
0
0
0
13.3%
0.0%
0.0%
13
ug/L
cis-l;2-Dichloroethene
70 West
20
355
49
0
184
114
13.8%
51.8%
32.1%
7400
ug/L
cis-l;2-Dichloroethene
70 West & POCW
40
624
141
0
276
160
22.6%
44.2%
25.6%
11000
ug/L
Dissolved Organic Carbon
East
12
209
1
0
0
0
0.5%
0.0%
0.0%
18000
mg/L
Dissolved Organic Carbon
MWE
3
59
0
0
0
0
0.0%
0.0%
0.0%
200000
mg/L
Dissolved Organic Carbon
POCW
20
267
14
0
0
0
5.2%
0.0%
0.0%
36000
mg/L
Dissolved Organic Carbon
Surface
4
0
0
0
0
0
NA
NA
NA
NA
Dissolved Organic Carbon
West
20
352
13
0
0
0
3.7%
0.0%
0.0%
77000
mg/L
Dissolved Organic Carbon
West & POCW
40
619
27
0
0
0
4.4%
0.0%
0.0%
77000
mg/L
Ethane
East
12
55
20
0
0
0
36.4%
0.0%
0.0%
14.5
ug/L
-------
Number of Non-
Detects where
Number of
Number of
Number of
Reporting
sspaAnalyte
MCL Location
Wells
Samples
Non-Detects
Exceeds 1
Ethane
MWE
3
0
0
0
Ethane
POCW
20
82
44
0
Ethane
Surface
4
0
0
0
Ethane
West
20
23
17
0
Ethane
West & POCW
40
105
61
0
Ethene
East
12
55
42
0
Ethene
MWE
3
0
0
0
Ethene
POCW
20
82
41
0
Ethene
Surface
4
0
0
0
Ethene
West
20
23
6
0
Ethene
West & POCW
40
105
47
0
Ferrous Iron
East
12
202
68
0
Ferrous Iron
MWE
3
56
24
0
Ferrous Iron
POCW
20
266
167
0
Ferrous Iron
Surface
4
0
0
0
Ferrous Iron
West
20
348
230
0
Ferrous Iron
West & POCW
40
614
397
0
Hardness
East
12
195
12
0
Hardness
MWE
3
55
8
0
Hardness
POCW
20
264
14
0
Hardness
Surface
4
0
0
0
Hardness
West
20
347
13
0
Hardness
West & POCW
40
611
27
0
Magnesium
East
12
195
15
0
Magnesium
MWE
3
55
10
0
Magnesium
POCW
20
264
15
0
Magnesium
Surface
4
0
0
0
Magnesium
West
20
347
19
0
Magnesium
West & POCW
40
611
34
0
Methane
East
12
59
1
0
Methane
MWE
3
0
0
0
Methane
POCW
20
82
17
0
Methane
Surface
4
0
0
0
Methane
West
20
24
3
0
Methane
West & POCW
40
106
20
0
Sulfate
East
12
202
68
0
Sulfate
MWE
3
56
15
0
Sulfate
POCW
20
266
19
0
Sulfate
Surface
4
0
0
0
Sulfate
West
20
348
60
0
Sulfate
West & POCW
40
614
79
0
Sulfide
East
12
202
189
0
Sulfide
MWE
3
55
51
0
Sulfide
POCW
20
266
244
0
Sulfide
Surface
4
0
0
0
Sulfide
West
20
348
327
0
Sulfide
West & POCW
40
614
571
0
Sulfite
East
12
199
1
0
Sulfite
MWE
3
54
0
0
Number of
Number of
Detected
Percent of
Detected
Samples 10 to
Percent of
Detections
Samples
10,000 Times
Percent Non
Detections
Exceeding 10
Maximum
Exceeding MCL
MCL
Detects
Exceeding MCL
Times MCL
Detected Value
Units
0
0
NA
NA
NA
NA
0
0
53.7%
0.0%
0.0%
112
ug/L
0
0
NA
NA
NA
NA
0
0
73.9%
0.0%
0.0%
78.2
ug/L
0
0
58.1%
0.0%
0.0%
112
ug/L
0
0
76.4%
0.0%
0.0%
12.5
ug/L
0
0
NA
NA
NA
NA
0
0
50.0%
0.0%
0.0%
1610
ug/L
0
0
NA
NA
NA
NA
0
0
26.1%
0.0%
0.0%
743
ug/L
0
0
44.8%
0.0%
0.0%
1610
ug/L
0
0
33.7%
0.0%
0.0%
10000
mg/L
0
0
42.9%
0.0%
0.0%
6800
mg/L
0
0
62.8%
0.0%
0.0%
3000
mg/L
0
0
NA
NA
NA
NA
0
0
66.1%
0.0%
0.0%
12000
mg/L
0
0
64.7%
0.0%
0.0%
12000
mg/L
0
0
6.2%
0.0%
0.0%
560000
mg/L
0
0
14.5%
0.0%
0.0%
525000
mg/L
0
0
5.3%
0.0%
0.0%
600000
mg/L
0
0
NA
NA
NA
NA
0
0
3.7%
0.0%
0.0%
595000
mg/L
0
0
4.4%
0.0%
0.0%
600000
mg/L
0
0
7.7%
0.0%
0.0%
340000
mg/L
0
0
18.2%
0.0%
0.0%
450000
mg/L
0
0
5.7%
0.0%
0.0%
540000
mg/L
0
0
NA
NA
NA
NA
0
0
5.5%
0.0%
0.0%
300000
mg/L
0
0
5.6%
0.0%
0.0%
540000
mg/L
0
0
1.7%
0.0%
0.0%
23400
ug/L
0
0
NA
NA
NA
NA
0
0
20.7%
0.0%
0.0%
10000
ug/L
0
0
NA
NA
NA
NA
0
0
12.5%
0.0%
0.0%
9600
ug/L
0
0
18.9%
0.0%
0.0%
10000
ug/L
0
0
33.7%
0.0%
0.0%
365000
mg/L
0
0
26.8%
0.0%
0.0%
144000
mg/L
0
0
7.1%
0.0%
0.0%
355000
mg/L
0
0
NA
NA
NA
NA
0
0
17.2%
0.0%
0.0%
340000
mg/L
0
0
12.9%
0.0%
0.0%
355000
mg/L
0
0
93.6%
0.0%
0.0%
0
mg/L
0
0
92.7%
0.0%
0.0%
0
mg/L
0
0
91.7%
0.0%
0.0%
0
mg/L
0
0
NA
NA
NA
NA
0
0
94.0%
0.0%
0.0%
100
mg/L
0
0
93.0%
0.0%
0.0%
100
mg/L
0
0
0.5%
0.0%
0.0%
8400
mg/L
0
0
0.0%
0.0%
0.0%
3600
mg/L
-------
Number of Non-
Detects where
Number of
Number of
Number of
Reporting Limit
sspaAnalyte
MCL
Location
Wells
Samples
Non-Detects
Exceeds MCL
Sulfite
POCW
20
266
0
0
Sulfite
Surface
4
0
0
0
Sulfite
West
20
341
0
0
Sulfite
West & POCW
40
607
0
0
trans-l;2-Dichloroethene
100
East
12
209
126
0
trans-l;2-Dichloroethene
100
MWE
3
59
0
0
trans-l;2-Dichloroethene
100
POCW
20
267
148
0
trans-l;2-Dichloroethene
100
Surface
4
60
53
0
trans-l;2-Dichloroethene
100
West
20
352
81
0
trans-l;2-Dichloroethene
100
West & POCW
40
619
229
0
Trichloroethene
5
East
12
209
144
5
Trichloroethene
5
MWE
3
60
35
17
Trichloroethene
5
POCW
20
267
151
9
Trichloroethene
5
Surface
4
60
48
0
Trichloroethene
5
West
20
358
163
80
Trichloroethene
5
West & POCW
40
625
314
89
Vinyl chloride
2
East
12
209
61
1
Vinyl chloride
2
MWE
3
59
0
0
Vinyl chloride
2
POCW
20
281
95
0
Vinyl chloride
2
Surface
4
60
7
0
Vinyl chloride
2
West
20
385
64
1
Vinyl chloride
2
West & POCW
40
666
159
1
NA: Not Applicable. Constituent was not analzyed.
ND: Non-Detect. Constituent was below reporting limits.
Number of
Number of
Detected
Percent of
Detected
Samples 10 to
Percent of
Detections
Samples
10,000 Times
Percent Non
Detections
Exceeding 10
Maximum
Exceeding MCL
MCL
Detects
Exceeding MCL
Times MCL
Detected Value
Units
0
0
0.0%
0.0%
0.0%
4800
mg/L
0
0
NA
NA
NA
NA
0
0
0.0%
0.0%
0.0%
7600
mg/L
0
0
0.0%
0.0%
0.0%
7600
mg/L
0
0
60.3%
0.0%
0.0%
13
ug/L
19
0
0.0%
32.2%
0.0%
250
ug/L
1
0
55.4%
0.4%
0.0%
110
ug/L
0
0
88.3%
0.0%
0.0%
0.32
ug/L
50
0
23.0%
14.2%
0.0%
410
ug/L
51
0
37.0%
8.2%
0.0%
410
ug/L
27
0
68.9%
12.9%
0.0%
15
ug/L
26
33
58.3%
43.3%
55.0%
300
ug/L
74
8
56.6%
27.7%
3.0%
97
ug/L
0
0
80.0%
0.0%
0.0%
0.7
ug/L
162
133
45.5%
45.3%
37.2%
4100
ug/L
236
141
50.2%
37.8%
22.6%
4100
ug/L
68
33
29.2%
32.5%
15.8%
520
ug/L
51
37
0.0%
86.4%
62.7%
4500
ug/L
167
137
33.8%
59.4%
48.8%
10000
ug/L
5
0
11.7%
8.3%
0.0%
3.1
ug/L
291
208
16.6%
75.6%
54.0%
12000
ug/L
458
345
23.9%
68.8%
51.8%
12000
ug/L
-------
APPENDIX L-TREND PLOTS FOR SELECTED MONITORING LOCATIONS
60
-------
Chart 1. Contaminant Concentration Trends in BDE-1 (2018-2022)
BDE-1
^ 30.0
"^25.0
D 20.0
o 15.0
to 10.0
E 5.0
S o.o
c
o
u
u
O
u
m
oo
(N ln
00
CsJ
LO 00
Date
-------
Chart 2. Contaminant Concentration Trends in POCE-6 (2018-2022).
500.0
_i
"as 400.0
ZJ
on 300.0
c
.2 200.0
2 100.0
5 o.o
u
c
o
u
u
O
POCE-6
1,1,1-tri ch I oro ethane —1,1-Dichlo.roethane 1,1-Dichloroethene
cis-l,2-Dichloroethene trans-1,2-Dichloroethene Trichloroethene
Vinyl chloride
-------
Chart 3. Contaminant Concentration Trends in STE-1 (2018-2022).
STE-1
"Sb
ZJ
in
c
o
¦M
O)
u
c
o
o
u
O
u
15.0
10.0
5.0
0.0
1,1,1-trichlorGethane
1,1-Dichloroethene
trans-1,2-Dichloroethene
Vinyl chloride
1,1-Dichloroethane
cis-l,2-Dichloroethene
Trichloroethene
-------
Chart 4. Contaminant Concentration Trends in STE-2 (2018-2022).
STE-2
2,500.0
"SB 2,000.0
fjn 1/500.0
o 1,000.0
F 500.0
-------
Chart 5. Contaminant Concentration Trends in STE-3 (2018-2022).
STE-3
^ 4,000.0
3 3,000.0
in
.2 2,000,0
ro
£ 1,000.0
-------
Chart 6. Contaminant Concentration Trends in MWE-3
before and after 2008 Cover Removal.
BOSCH 2022 ANNUAL GROUNDWATER REPORT
VOLATILE ORGANIC COMPOUNOS
PARENT COMPOUND: TRICHLOROETHYLENE
Western Plume - MWE-3
-------
Chart 7. Contaminant Concentration Trends in STE-3
before and after 2008 Cover Removal.
BOSCH 2022 ANNUAL GROUNDWATER REPORT
VOLATILE ORGANIC COMPOUNDS
PARENT COMPOUND: TRJCHLOROETHYLENE
Eastern Plume - STE-3
-------
Chart 8. Contaminant Concentration Trends in MWW-101A (2018-2022).
MWW-101A
8,000.0
= 6,000.0
GO
o 4,000.0
ro
s_
c
a;
u
c
o
u
u
O
2,000,0
0.0
Date
1,1,1-trichloroethane
cis-l,2-Dichloroethene
Vinyl chloride
1,1-Dichloroethane
trans- 1,2-Dichloroethene
1,1-Dichloroethene
Trichloroethene
-------
Chart 9. Contaminant Concentration Trends in MWW-102A (2018-2022).
MWW-102A
8,000.0
_i
"iP 6,000,0
o 4,000.0
ra
c
OJ
u
c
o
(J
u
O
2,000.0
0.0
1,1,1-trichloroethane
cis-l,2-Dichloroethene
Vinyl chloride
Date
1,1-Dichloroethane
trans- 1,2-Dichloroethene
1,1-Dichloroethene
Trichloroethene
-------
Chart 10. Contaminant Concentration Trends in MWE-3 (2018-2022).
MWE-3
"S5
40,000.0
30,000,0
.2
+-»
2 20,000,0
O)
u
c
o
u
u
O
u
10,000.0
0.0
00 CO 00 00 cr>
-------
Chart 11. Contaminant Concentration Trends in POCW-1A (2018-2022).
40.0
POCW-1A
1,1,1-trichloroethane
1,1-Dichloroethene
trans- 1,2-Dichloroethene
Vinyl chloride
Date
1,1-Oichloroethane
cis-l^-Dichloroethene
Trichloroethene
-------
Chart 12. Contaminant Concentration Trends in POCW-2A (2018-2022).
POCW-2A
"35
zs
00
c
o
OS
U
c
o
u
O
u
12,000.0
10,000.0
8,000.0
6,000.0
4,000.0
2,000.0
0,0
CO
00
00
CO
-------
Chart 13. Contaminant Concentration Trends in POCW-4A (2018-2022).
POCW-4A
200.0
1,1,1-trichloroethane
cis-l,2-Dichloroethe ne
Vinyl chloride
Date
1,1-Dichloroethane
trans-l,2-Dichloroethene
1,1-Dichloroethene
Trichloroethene
-------
Chart 14. Contaminant Concentration Trends in POCW-4B (2018-2022).
POCW-4B
"Sb
Z5
on
c
.2
ra
-------
Chart 15. Contaminant Concentration Trends in STW-1 (2018-2022)
STW-1
60.0
"SB 50.0
Z3
w 40.0
¦2 30.0
¦i—1
cu
£ 20,0
§ 10,0
o
o
u
O
(j
0,0
o
OJ
OJ
o
rsi
tH
LO
o
fNl
00
O
C\l
O
CnI
O O O iH
N N (N (N
o o o o
f\l (N (N (N
C-J LO
00
-------
Chart 16. Contaminant Concentration Trends in STW-2A (2018-2022)
STW-2A
in
8,000.0
6,000,0
'B 4,000.0
ra
£ 2,000.0
u
O
(J
u
O
u
0.0
CO 00 00 00 CT1
-------
APPENDIX M - TOTAL VOCS REMOVED BY MRS AUGUST 2009 TO DECEMBER 2022
61
-------
Annual Mass Removed
250
200
150
100
50
u
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Total
121
237
212
178
147
137
133
152
119
113
86
84
84
91
¦ EW-1
3.0
0.7
0.3
09
1.2
0.3
0.7
0.5
99
1.4
4.1
17.8
12.9
185
~ EW-2
13
32
29
14
0.9
1.1
OA
46
15.3
82
13.5
0.2
0.2
3.57
¦ EW-3
105
233
183
175
145
136
132
147
94
29 2
686
66.5
709
688
Annual Extraction Well Removal
Annual Volume Treated
4
3
2
1
n
—I
l l l
0
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Total
1.20
2.18
5.04
669
5.65
4.33
5.19
5.26
5.30
3.75
4.42
4.00
4.07
5,41
¦ EW-1
0.24
0.07
0.04
0.13
0.15
0.04
008
005
0.55
006
020
0.79
0.40
1.36
~ EW-2
020
006
0.57
006
0.05
008
004
056
089
2.71
039
0.02
003
0.23
¦ EW-3
0.76
2.05
4.43
650
5.45
4.22
5.06
465
3.86
098
3.83
3.20
364
3.83
Annual Extraction Well Removal
-------
APPENDIX N - SOIL VAPOR SAMPLING LOCATIONS
62
-------
P0CW-5A,B
[ POCW-6 ]
BB-01A
P0CW-4A,B,C
P0CW-3A,B,C
P0CW-2A,B
P0CW-1A,B
Lake Bluff Terrace
Legend
© Soil Vapor Locations
-0- Monitoring Well
2011 NOAA Aerial Imagery from the 7
Department of Commerce (DOC), National
Oceanic and Atmospheric Administration
BENDIX SUPERFUND SITE
ST. JOSEPH, Ml
Soil Vapor Survey Locations
FIGURE 9a - Soil Vapor
Sampling Locations
WOODARD
&.CURRAN
DOC: F1 SG Samples.mxd
JOB NO.: 205410.18
DATE: NOVEMBER 2018
DRAWN BY: SET
SOURCE: 2011 NOAA Imagery
-------
Eagle Technologic
•bake Bluff-Terrace'
^eodgate Dr
>t Joseph, Office
Lake Pines Apartments
Lake-Pme-Path- •
8l'CPAS" «
Bendix Parcels
SW>Sr4i
Figure 9b: Bendix Corp./Aliied Automotive
Soil Vapor Sampling Locations
j » -m
Data Sources
Google Earth
-------
APPENDIX O - SITE INSPECTION FORM
63
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Site Inspection Checklist
1. sin: INFORMATION
Site name:
Bendix Corp./Allied Automotive
Date of inspection:
9/12/2023
Location and Region:
3737 Red Arrow Hwy., St. Joseph, MI
EPA ID:
MID005107222
Agency, office, or company leading the FYR:
US EPA, Region 5, Joseph Kelly
Weather/temperature:
65 degrees F, cloudy/drizzle
Remedy Includes: (Check all that apply)
~ Landfill cover/containment
IEI Monitored natural attenuation
~ Access controls
~ Groundwater containment
IEI Institutional controls
El Groundwater pump and treatment
~ Surface water collection and treatment
~ Vertical barrier walls
El Other: SVE
Attachments:
~ Inspection team roster attached
IEI Site map attached
1
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Site Inspection Checklist
II. INTKRVIKWS (Check all that apply)
T , v f Environmental
1 O&M Site Manager ° " °Ung ° Health & Safety 9/12/2023
Bosch' Director,
Interviewed: IEI at site ~ at office ~ by phone Phone Number: Click here to enter text.
Problems, suggestions: ~ Report attached
General discussion indicated PRP believes remedies are operating as intended.
Jedd Steinglass „ . „,
„ „ . Senior PM and
& Connor Obrion , ,
2 O&M Staff j j £> Lead Field 9/12/2023
z. wouyx jian from Woodard & , . .
„ Technician,
Curran,
Interviewed: El at site ~ at office ~ by phone Phone Number: Click here to enter text.
Problems, suggestions: ~ Report attached
General discussion indicated PRP's consultant believes remedies are operating as intended.
Discussion touched on system performance and outstanding report reviews.
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: Michigan EGLE
Contact: Samantha Belisle, Project Manager, 9/12/2023, P: 517-290-0686
Problems, suggestions: IEI Report attached
* see 2023-08-16 Bendix 2024 FYR EGLE issues letter
Agency: Berrien County Health Dept.
Contact: Nick Margaritis, Environmental Health Manager, 9/27/2023, P: 269-927-5653
Problems, suggestions: IEI Report attached
Contacted Mr. Maragritis to make sure no permits were issued for well installations in vicinity of
the groundwater plumes.
Agency: Lincoln Charter Township
Contact: Marc Florian, Trustee, 8/18/2023, P: 269-429-1589
Problems, suggestions: ~ Report attached
Notified Mr. Florian of site inspection planned for 9/12. Mr. Florian did not identify any issues but
requested to attend the inspection. EPA expressed it is not authorized to allow third-party access to
PRP properties or to allow participation in deliberative matters such as inspections.
Agency: Click or tap here to enter text.
Contact: Name , Title , Click or tap to enter a date., P: Phone Number
2
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Site Inspection Checklist
Problems, suggestions:
Click or tap here to enter text.
4. Other Interviews (optional): ~ Report attached
Adjacent Industrial/Commercial Property (Walsworth Publishing) reported no issues with
adjacent Bosch site. Board members of Churchill Farms development reported no issues
and appreciated W&C's presentation/update the night of 9/11/23.
III. OVSITi: DOCl MKNTS & RKCORDS VKRII
•IKI) (Check all llial appl\)
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: Click or tap here to enter text.
2.
Site-Specific Health and Safety Plan
El Readily available
IEI Contingency Plan/Emergency Response Plan
El Readily available
Remarks: Click or tap here to enter text.
3.
O&M and OSHA Training Records
El Readily available
El Up to date
~ N/A
Remarks: Contractor H&S plan requirements
4.
Permits and Service Agreements
~ Air discharge permit ~ Readily available
~ Up to date
~ N/A
El Effluent discharge ~ Readily available
El Up to date
~ N/A
~ Waste disposal, POTW ~ Readily available
~ Up to date
~ N/A
~ Other permits: Click or tap here to enter text.
Remarks: Michigan DMR permit submitted in April, under review.
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
~ Readily available
El Up to date ~ N/A
Remarks: Quarterly/Annual Reporting
8. Leachate Extraction Records
~ Readily available
~ Up to date ^ N/A
Remarks: Click or tap here to enter text.
9. Discharge Compliance Records
~ Air ~ Readily available
~ Up to date El N/A
El Water (effluent) ~ Readily available
El Up to date ~ N/A
Remarks: Michigan DMR permit submitted in April, under
eliminating need for permit
review; CatOx destroys vapors
10. Daily Access/Security Logs
~ Readily available
~ Up to date ^ N/A
Remarks: Site is fenced. Fence is in good condition. Guard office located northeast of main plant
building is staffed 24 hours per dav Guard reports no incidents of trespassing/vandalism
IV. O&M COSTS
1. O&M Organization
~ State in-house ~ Contractor for State
~ PRP in-house IEI Contractor for PRP
~ Federal Facility in-house ~ Contractor for Federal Facility
Remarks: Annual costs of $140,000 to $185,000, depending on scheduled maintenance or
upgrades. Replaced flow meters, Catalytic Oxidizer and pump for EW-3 over the last year.
2. O&M Cost Records
4
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Site Inspection Checklist
~Readily available ~ Up to date ^ Funding mechanism/agreement in place
Original O&M cost estimate NA/PRP lead ~ Breakdown attached
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
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons:
Last year, MRS pump replaced for EW-3 and CatOx system replaced. Periodic cleaning of system
from scaling.
V. AC "(TINS AM) INSTH I TIONAL CONTROLS
Applicable
~ N/A
1. Fencing Damaged ~ Location shown on site map
Remarks: Perimeter fencing in good condition (see photos)
Gates secured ~ N/A
2. Other Access Restrictions ~ Location shown on site map
Remarks: Access controlled by guard; no reports of trespassing.
Gates secured
3. Institutional Controls (ICs)
A. Implementation and Enforcement
Site conditions imply ICs not properly implemented
Site conditions imply ICs not being fully enforced
Type of monitoring (e.g., self-reporting, drive by)
E Yes ~ No ~ N/A
E Yes ~ No ~ N/A
RC being developed but not
finalized yet. ICIAP will describe
monitoring procedures and
frequency. CAP removed at
foundry.
5
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Site Inspection Checklist
Frequency Click or tap here to enter text.
Responsible party/agency
Click or ta
p here to ent
er text.
Contact: Name , Title , Click or tap to enter a date., P: P
hone Number
Reporting is up-to-date
~ Yes
~ No
El N/A
Reports are verified by the lead agency
~ Yes
~ No
El N/A
Specific requirements in deed or decision documents have been
met
~ Yes
~ No
El N/A
Violations have been reported
El Yes
~ No
~ N/A
Other problems or suggestions:
ICs have not been completed but are in progress; past removal of foundry building constituted a
removal of existing cover that is being evaluated as a violation; there is currently no inspection or
reporting process because the LTS plan and ICIAP plan have also not been finalized. These items were
required by the Consent Decree and initiated during the last FYR.
B. Adequacy D ICs are adequate ~ ICs are inadequate El N/A
Remarks: ICs are in the process of being completed but were not completed following the
schedule in the Consent Decree; past removal of foundry building constituted a removal of
existing cover that is being evaluated.
4. General
A. Vandalism/Trespassing ~ Location shown on site map El No vandalism evident
Remarks: Access controlled by guard
B. Land use changes on site ~ N/A
Remarks: Past removal of Foundry building before last FYR. Access to former lagoons should be
controlled due to presence of waste, per suggestions to draft Restrictive Covenant.
C. Land use changes off site IEI N/A
Remarks: CI id ' " to enter text.
vi. gknkual sin: conditions
1. Roads IEI 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: Surface cover at former foundry to prevent infiltration was disturbed over the eastern plume;
lagoons south of building were capped with compacted clay at MDEQ (EGLE)'s instruction; all caps
should be maintained under Restrictive Covenant to prevent contact with or disturbance of wastes,
though not considered landfill caps, below. Roads are access roads for industry, and not for remedies.
6
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Site Inspection Checklist
Ml. LANDI ILL( OVKUS
1. Landfill Surface ~ Applicable IEIN/A
A. Settlement (Low Spots) ~ Location Shown on Site Map ~ Settlement Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter text.
Remarks: A landfill for foundry sand and asbestos exists adjacent to Hickory Creek but is not the
subject of current SEMD actions. Capped lagoons are not considered landfills.
B. Cracks ~ Location Shown on Site Map ~ Cracking Not Evident
Lengths: Click or tap here „,¦ , , . ... Depths: Click or tap here to enter
° Widths: Click or tap here to enter text,
to enter text. text.
Remarks: A landfill for foundry sand and asbestos exists adjacent to Hickory Creek but is not the
subject of current SEMD actions.
C. Erosion ~ Location Shown on Site Map ~ Erosion Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter text.
Remarks: A landfill for foundry sand and asbestos exists adjacent to Hickory Creek but is not the
subject of current SEMD actions.
D. Holes ~ Location Shown on Site Map ~ Holes Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter text.
Remarks: A landfill for foundry sand and asbestos exists adjacent to Hickory Creek but is not the
subject of current SEMD actions.
E. Vegetative Cover ~ Grass ~ Cover Properly Established
~ Tress/Shrubs (indicate size and locations on a diagram ~ No Signs of Stress
Remarks: A landfill for foundry sand and asbestos exists adjacent to Hickory Creek but is not the
subject of current SEMD actions.
F. Alternative Cover (armored rock, concrete, etc.) IEI N/A
Remarks: Click or tap here to enter text.
G. Bulges ~ Location Shown on Site Map ~ Bulges Not Evident
Areal Extent: Click or tap here to enter text. Height: Click or tap here to enter text.
Remarks: A landfill for foundry sand and asbestos exists adjacent to Hickory Creek but is not the
subject of current SEMD actions.
H. Wet Areas/Water Damage ~ Wet Areas/Water Damage Not Evident
~ Wet Areas d Location Shown on Site Map
tex
~ Ponding d Location Shown on Site Map
& tex'
Areal Extent: Click or tap here to enter
text.
Areal Extent: Click or tap here to enter
7
-------
Site Inspection Checklist
~ Seeps ~ Location Shown on Site Map Areal Extent: Click or taP here t0 eilter
, |—| , pi c;. a i Areal Extent: Click or tap here to enter
~ Soft Subgrade L-l Location Shown on Site Map h
Remarks: A landfill for foundry sand and asbestos exists adjacent to Hickory Creek but is not the
subject of current SEMD actions.
I. Slope Instability ~ Location Shown on Site Map ~ Slope Instability Not Evident
~ Slides Areal Extent: Click or tap here to enter
Remarks: A landfill for foundry sand and asbestos exists adjacent to Hickory Creek but is not the
subject of current SEMD actions.
2. Benches ~ Applicable ISI 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.)
A. Flows Bypass Bench ~ Location Shown on Site Map ~ N/A or Okay
Remarks: Click or tap here to enter text.
B. Bench Breached ~ Location Shown on Site Map ~ N/A or Okay
Remarks: Click or tap here to enter text.
C. Bench Overtopped ~ Location Shown on Site Map ~ N/A or Okay
Remarks: Click or tap here to enter text.
3. Letdown Channels ~ Applicable ISI 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 ~ 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 ~ Degradation Not Evident
,. , . . „ , . , , , Areal Extent: Click or tap here to enter
Material Type: Click or tap here to enter text. , ,
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 or tap here to enter text.
Remarks: Click or tap here to enter text.
8
-------
Site Inspection Checklist
D. Undercutting
~ Location Shown on Site Map ~ Undercutting Not Evident
Areal Extent: Click or tap lit
;re to enter text. Depth: Click or tap here to enter text.
Remarks: Click or tap here t
o enter text.
E.
Obstructions
Type: Click or tap here to ei
~ Location Shown on Site Map ~ Undercutting Not Evident
iter text.
Areal Extent: Click or tap lit
;re to enter text. Size: Click or tap here to enter text.
Remarks: Click or tap here t
o enter text.
F.
Excessive Vegetative Growth ~ Location Shown on Site Map ~ Excessive Growth Not Evident
Areal Extent: Click or tap lit
, , ~ Vegetation in channels does not obstruct
;re to enter text. &
flow
Remarks: Click or tap here t
o enter text.
4. Cover Penetrations
~ Applicable ISI N/A
A.
Gas Vents
~ Active ~ Passive
~ Properly secured/locked
~ Functioning ~ Routinely sampled
~ Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
~ N/A
Remarks: Click or tap here t
o enter text.
B.
Gas Monitoring Probes
~ Properly secured/locked
~ Functioning ~ Routinely sampled
~ Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
~ N/A
Remarks: Click or tap here t
o enter text.
C.
Monitoring Wells
~ Properly secured/locked
~ Functioning ~ Routinely sampled
~ Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
~ N/A
Remarks: Click or tap here t
o enter text.
D.
Leachate Extraction Wells
~ Properly secured/locked
~ Functioning ~ Routinely sampled
~ Good condition
~ Evidence of leakage at penetration
-------
Site Inspection Checklist
~ Needs Maintenance
Remarks: Click or tap here to
~ N/A
enter text.
E. Settlement Monuments
Remarks: Click or tap here to
~ Located ~ Routinely Surveyed ~ N/A
enter text.
5.
Gas Collection and Treatment
~ Applicable
E N/A
A. Gas Treatment Facilities
~ Flaring
~ Good condition
Remarks: Click or tap here to
~ Thermal Destruction
~ Needs Maintenance
enter text.
~ Collection for Reuse
B. Gas Collection Wells, Manifolds, and Piping
~ 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
E N/A
A. Outlet Pipes Inspected
Remarks: Click or tap here to
~ Functioning
enter text.
~ N/A
B. Outlet Rock Inspected
Remarks: Click or tap here to
~ Functioning
enter text.
~ N/A
7.
Detention/Sediment Ponds
~ Applicable
E N/A
A. Siltation
Areal Extent: Click or tap her
Remarks: Click or tap here to
~ Siltation Not Evident
e to enter text. Depth: Clic
enter text.
~ N/A
< or tap here to enter text.
B. Erosion
Areal Extent: Click or tap her
Remarks: Click or tap here to
~ Erosion Not Evident
e to enter text. Depth: Clic
enter text.
< or tap here to enter text.
C. Outlet Works
Remarks: Click or tap here to
~ Functioning
enter text.
~ N/A
D. Dam
~ Functioning
~ N/A
10
-------
Site Inspection Checklist
Remarks: Click or tap here to enter text.
8. Retaining Walls
~ Applicable
E 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 ~ Deformation Not Evident
Remarks: Click or tap here to enter text.
9. Perimeter Ditches/Off-Site Discharge
~ Applicable
E N/A
A. Siltation ~ Location Shown on Site Map ~ Siltation 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. 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 or 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 or tap here to enter text.
Remarks: Click or tap here to enter text.
D. Discharge Structure
Remarks '
~ Functioning
~ N/A
Mil. YKUTICAL BAKKIKK WALLS
~ Applicable
E N/A
1. Settlement ~ Location Shown on Site Map ~ 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.
2. Performance Monitoring Type of Monitoring: Click or tap here to enter text.
~ Performance Not Monitored
Frequency: Click or tap here to enter text.
~ Evidence of Breaching
Head Differential: Click or tap here to enter text.
11
-------
Site Inspection Checklist
Remarks: Click or tap
to enter text
ix. (;uoiM)\\ \ i i:u/si ui \( i: watku uimidiks
Applicable
~ N/A
1. Groundwater Extraction Wells, Pumps, and Pipelines
Applicable
~ N/A
A. Pumps, Wellhead Plumbing, and Electrical ~ N/A
El Good Condition El All Required Wells Properly Operating ~ Needs Maintenance
Remarks: Click or tap here to enter text.
B. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
IEI Good Condition El Needs Maintenance
Remarks: Contractor reports stormwater entry in Manhole 4, which is pumped out as part of
preventative maintenance, but occasionally triggers an alarm and system shutdown following heavier rain
events; considering replacement of special gaskets.
C. Spare Parts and Equipment
IEI Readily Available ~ Good Condition
Remarks: Limited/small spare parts stored on-site.
~ Needs to be Provided
~ Requires Upgrade
2. Surface Water Collection Structures, Pumps, and Pipelines
~ Applicable
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
~ Readily Available ~ Good Condition
Remarks: Click or tap here to enter text.
~ Needs to be Provided
~ Requires Upgrade
3. Treatment System
Applicable
~ N/A
A. Treatment Train (Check components that apply)
~ Metals removal ~ Oil/Water Separation ~ Bioremediation
El Air Stripping ~ Carbon Absorbers
~ Filters Click or tap here to enter text.
El Additive (e.g. chelation agent, flocculent) Sulfuric acid is injected into the system for cleaning and
12
-------
Site Inspection Checklist
Mg02 neutralizes scaled water.
El Others Catalytic Oxidizer
El Good Condition ~ Needs Maintenance
IEI Sampling ports properly marked and functional
IEI Sampling/maintenance log displayed and up to date
El Equipment properly identified
El Quantity of groundwater treated annually 5.25-5.4 million gallons
~ Quantity of surface water treated annually Click or tap here to enter text.
Remarks: Recent system upgrades including CatOx, EW-3 pump, and flow meters.
B. Electrical Enclosures and Panels (properly rated and functional)
~ N/A
El Good Condition ~ Needs Maintenance
Remarks: See attached photos
C. Tanks, Vaults, Storage Vessels
~ N/A
~ Proper Secondary Containment
El Good Condition ~ Needs Maintenance
Remarks: T-109 is a repurposed inground concrete-walled, open-top tank for off-spec MRS water
(condition unknown); knock-out tank for SVE in trailer in good condition.
D. Discharge Structure and Appurtenances
~ N/A
El Good Condition ~ Needs Maintenance
Remarks: EGLE permitted
E. Treatment Building(s)
~ N/A
El Good condition (esp. roof and doorways)
~ Needs repair
El Chemicals and equipment properly stored
Remarks See attached photos
F. Monitoring Wells (Pump and Treatment Remedy) ~ N/A
El Properly secured/locked
El Functioning
El Routinely sampled
El All required wells located
El Good condition
~ Needs Maintenance
Remarks Click or tap here to enter text.
4. Monitoring Data
A. Monitoring Data:
13
-------
Site Inspection Checklist
~ Is Routinely Submitted on Time El Is of Acceptable Quality
B. Monitoring Data Suggests:
~ Groundwater plume is effectively contained ~ Contaminant concentrations are declining
5. Monitored Natural Attenuation
A. Monitoring Wells (natural attenuation remedy) ~ N/A
El Properly secured/locked El Functioning El Routinely sampled
~ All required wells located ~ Needs Maintenance IEI Good condition
Remarks: OW-19 is out of network, but has a cracked manhole cover. Contractor reports a dent was
noted on the protective casing for POCE-5 during Q3, but the well remains protected and was able to be
gauged and sampled. Will continue to monitor. Success of MNA is being evaluated.
X. OTHER KIM 1.1)1 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. OVKUAU. OBSERVATIONS
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.).
Soil vapor extraction system appears to be reducing contaminant conditions in the area of installation.
Volume of COCs appears to be reducing. Contractor had previously suggested re-sampling to see if
objectives had been met (reportedly, to reduce COCs in soil to concentrations below EGLE levels for direct
contact). It is not clear that the area of the SVE is the only area that would benefit from operation of an
SVE system. The MRS system was reportedly installed to reduce the amount of groundwater discharging
through NAPL zone to reduce contaminant loading and enhance MNA; not clear this is working because
levels of COCs at monitoring locations adjacent to surface water bodies are still high, and degradation is
not complete at the point of surface water discharge. It is not clear that the system was designed to address
the principal threat wastes.
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.
O&M on remedial systems appears to be adequate; systems are serviced with frequency and monitored
with telemetry, among other things. Periodic maintenance keeps down-time at a minimum. Deficiencies
with regard to the protectiveness of the remedy include the current institutional controls being used to
ensure that off-site exposures are prevented. Restrictive Covenants and groundwater use
restrictions/ordinances may not be in a form that would meet current acceptance criteria.
3. Early Indicators of Potential Remedy Problems
14
-------
Site Inspection Checklist
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.
The MRS continues to treat a substantially lower volume of VOCs than anticipated, and is pumping at a
lower rate than proposed in the design stage. Increased costs were observed during periods where the
CatOx system was replaced, and/or other system components were upgraded.
4. Early Indicators of Potential Remedy Problems
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
The 2019 FYR identifies a number of concerns that suggest the potential need to optimize the monitoring
plan and/or the remedy. Most of those concerns remain valid.
15
-------
APPENDIX P - SITE PHOTOGRAPHS & PRP PRESENTATION
64
-------
Soil Vapor Extraction wells SVE-2 and SVE-3, facing south,
along western side of loading dock
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
Former Lagoon Area & Southern Perimeter Fence, facing southwest.
Former Lagoon Area & Eastern Perimeter Fence, facing southeast.
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
MWE-2, facing northeast, with former foundry
area (demolished in 2008) in background
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
¦HH
4 SVE lines to trailer, manifolded into exhaust line combined
with MRS air stripper line
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
Condensate tank for the SVE system
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
Control Panel for SVE system
WtHK:
11
Tank T-109, holding tank for off-spec water from MRS, prior to
recirculation for treatment
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
Extraction well discharge lines, flow meters, and influent sampling
ports for MRS.
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
MRS flow meters and air stripper trays
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
Control Panel for MRS system
MRS well EW-1 and electrical connections,
facing south-southwest
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
MRS wells EW-2 and EW-3, facing northwest
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
Maiden Land landfill area, adjacent to Hickory Creek, facing south
View of POCE-3, facing east
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
Damaged manhole cover at OW-19 (Eagle Tech denied access).
Woodard & Curran team sampling at MWW-101
Bendix Corp. FYR Inspection Photos,
MID005107222, 09/12/2023
-------
BOSCH
Woodard
&Curran
Bendix
Superfund Site
St. Joseph, Ml
Five Year Review Site Visit
September 12, 2023
St. Joseph, Ml
lSBV
mm-..
' m m
I ,r
-------
I
Bendix FYR Site Visit Agenda
Welcome & Safety Moment: 10:00 am to 10:05 am
Desktop Review: 10:05 am to 12:00 pm
¦ Remediation Systems Summary
¦ Preview of Site Walk
¦ Monitoring Locations Review
¦ Questions, List of Actions
Break: 12:00 pm to 12:30 pm
Site Walk: 12:30 pm to 2:00 pm
Review of Actions & Adjourn: As needed
Woodard &Curran
-------
Desktop Remediation System
Woodard
&Curran
-------
Remediation System Summary - Overview
~ Mass Reduction System (MRS) = Extracts groundwater from three wells in the
north lot (western groundwater plume source), transfers water to an air
stripper to remove chlorinated VOCs. Treated water is discharged to surface
water, contaminated vapor is thermally destroyed onsite via a catalytic
oxidizer (CatOx).
Soil Vapor Extraction (SVE) System = Extracts vapor phase VOCs from the
continuing soil source of the eastern groundwater plume, which is
contaminated soil in the area of a former lagoon.
Extracted contaminated vapor is also thermally
destroyed onsite via the CatOx.
Woodard&Curran
-------
Remediation System Summary - Annual Costs
$190,000
$180,000
$170,000
$160,000
$150,000
$140,000
$130,000
$120,000
$110,000
$100,000
$185,000
2019 2020 2021 2022
Woodard&Curran
-------
I
Remediation System Summary - Recent Investments
CatOx replacement completed
in June 2022
¦ Aged equipment was beyond
useful life and compromised
housing raised a safety concern
¦ Included in-kind replacement
though catalyst capacity was
more modest due to decreasing
influent concentrations. Can be
increased if needed in the future.
¦ Also includes greater ability to
optimize groundwater extraction
and treatment
Woodard &Curran
-------
Remediation System Summary
4-YEAR DOWNTIME %
(JAN 2019 - DEC 2022)
Woodard&Curran
Down
-------
Remediation System Summary - Downtime Evaluation
80
70
60
50
40
30
20
10
0
Woodard&Curran
Total Downtime (Days) by Alarm Condition
¦ ¦¦
I I
I.
-I
POWER OUTAGE
WEATHER
AIR STRIPPER FOAMING
HEAT EXCHANGER WATER HEATER
¦ 2019 ¦ 2020 ¦ 2021 2022
SVE SYSTEM
CATOX
OTHER
-------
Remedial Operation Status - Downtime Evaluation
~ Preventive maintenance reduces downtime by over
40% (2022 versus 2021)
~ Focus on air stripper
¦ Clean in Place (CIP) runs 90 minutes per day.
¦ Proactive visits for cleaning and system checks every two
weeks
Woodard&Curran
-------
Remediation System Summary - Extraction Wells
EW-1
7,000
6,000
5,000
4,000
3,000
2,000
1,000
I
i
T?
r 1
TCE
I cis-1,2-DCE
trans-1,2-DCE
IVC
•DOR Goal
Woodard&Curran
-------
Remediation System Summary - Extraction Wells
EW-2
TCE ^¦cis-1,2-DCE trans-1,2-DCE ^«VC DORGoal
Woodard&Curran
-------
I
Remediation System Summary - Extraction Wells
EW-3
25,000
DEC-11
MAR-14
JUL-16
OCT-18
FEB-21
JUN-23
TCE
I cis-1.2-DCE
trans-1,2-DCE
IVC
•DOR Goal
Woodard&Curran
-------
I
Remediation System Summary-Well trends
MWW-100A
MWW-101B
60,000
50,000
40,000
(X)
U
> 30,000
~03
¦4—'
o
^ 20,000
10,000
1
DOR Goal
MRS Startup
0
Oct-08 Sep-11 Aug-14 Jul 1/ Jun-20 Jun-23
25,000
20,000
3 15,000
U")
U
o
2 10,000
ro '
4—'
o
5,000
0
—
DOR Goal
Apr-15 Nov-16 Jul-18 Feb-20 Oct-21 Jun-23
Woodard&Curran
MWW-102B
14,000
12,000
10,000
8,000
6,000
4,000
2,000
0
Apr-15 Nov-16 Jul-18 Feb-20 Oct-21 Jun-23
MWW-102A
18,000
16,000
14,000
12,000
DOR Goal
,pA
c
« 10,000
u
o
>
8,000
6,000
4,000
2,000
0
DOR Goal
fT O
Q
\ A j/
U 0\ jh*
-15 No\
/-16
Jul
-18 Feb
-20 Oct
21 Jun
-------
Remediation System Summary - MRS Cleanup Goals
Sample Location
Baseline VOC
Concentration
(M9/L)
Baseline Year
Most-Recent VOC
Concentration
(M9/L)
Overall Concentration
Reduction from Baseline
Four-Sample Average
Reduction vs. Baseline
Reduction Goal
Achieved DOR Goal?
EW-1
2,336
2017
2,056
12%
35%
<2,000 |jg/L
No
EW-2
11,107
2009
2,950
73%
79%
75%
Yes
EW-3
20,461
2009
1,355
93%
90%
75%
Yes
MWW-1
2,244
2009
125
94%
94%
60%
Yes
MWW-1RA
8,881
2009
86
99%
99%
60%
Yes
MWW-100A
48,340
2009
1,821
96%
96%
60%
Yes
MWW-101A
15,635
2015
2,043
87%
78%
60%
Yes
MWW-101B
22,930
2015
1,870
92%
91%
60%
Yes
MWW-101C
2,364
2015
253
89%
86%
60%
Yes
MWW-102A"
13,388
2015
3,306
75%
61%
60%
No
MWW-102B
13,010
2015
1,556
88%
87%
60%
Yes
MWW-102C
990
2015
45
95%
94%
NA
NA
Notes:
¦ Total VOC concentrations include a sum of detections of vinyl chloride, cis-1,2-dichloroethene, trans-1,2-dichloroethene, and trichloroethene.
¦ MWW-101 and MWW-102 triplet wells were installed after MRS startup in late 2014. Baseline readings were established from the first round of samples (April 2015).
¦ EW-1 initially exceeded the 2,000 |jg/L threshold in June 2017, at which time the baseline was set at 2,336 |jg/L, with a Reduction Goal of <2,000 |jg/L.
¦ One half of the detection limit of VOCs that were not detected is used in the total VOC concentration calculation.
¦ * - Denotes the average concentration between the sample result and its quality control (QC) duplicate.
¦ ** - MWW-102A has met the first of two consecutive reduction periods to qualify for DOR achievement status.
¦ DOR = Demonstration of Reduction
¦ NA = denotes that baseline total VOC concentrations at this location did not meet the minimum required concentration of 2,000 |jg/L to be included on the DOR list but is included on this table for informational purposes only. If the average
concentration increases to above this value for four consecutive sampling events, then the location will be subject to compliance with the established reduction goals.
Woodard&Curran
-------
Desktop Preview of Site Walk
Woodard
&Curran
-------
Restricted area: 3737 Red Arrow Highway, St. Joseph,
Berrien County, Michigan, 49085 comprising approximately 3
37 acres
Restrictions include:
1. Residential use or other uses that allow for
routine exposures to children
2. Extraction of groundwater within the restricted
area for consumption or irrigation
3. Elimination of the existing asphalt pavement,
concrete, and building slab soil cover in the immediate
area of the loading dock
4. Removal or alteration of groundwater monitoring wells
5. Exposure of building occupants to conditions
that exceed occupational health or other applicable
standards for air contaminants
Proposed Marker
Locations
A
Legend
Proposed Sign Markers
I ' Approximate Site Boundary
0 45 90
Woodard
* Curran
project #: 20S410
Map Created: May 2023
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources:
-------
Lagoon
I Surfaces -
Hydrogeologic
Study
OOW-M
©OW-13
©OW-IO
©OW-II
APPENDIX C
OBSERVATION WELL, MONITOR WELL 8
SOL BORING LOCATION MAP
BENDiX HYDRAULICS DIVISION
NW 1/4, SW1/4, SECTION O
ST JOSEPH TOWNSHIP, BERRIEN COUNTY, MICHIGAN
SCALE l" = 200' OATE; 6/6-7/84
0W I-0W-I4 KECK CONSULTING SERVICES
WELLS INSTALLED 9/1 -9/8/8!
MW-l-MW-3 BENDIX WELLS, INSTALLED 10/75
A - 6" WATER SUPPLY WELL,PLEASURE INDUSTRIES
BASE MAP >978 MICHIGAN DNR AERIAL PHOTOGRAPHY
o SB -1- SOIL BORINGS BY KHK
N
• TR - TP<5T RHff JNvJ
. KrcK^vv
-------
Lagoon Surfaces - 1955, 1967, and 1975 Aerial Photos
*»•
Woodard &Curran
-------
Access Roads,
¦ Surface Cover
LE66NO
intend GfmindwMv OiMteian
(nlefpieava Tola) VOC
Conumlnjuonn
t f
Ptotti
hppomm ioc**» p»
GwufKfcwaw OM*
Not to Scale
m>D0*CtvM« pun
-------
Extraction Wells,
y Treatment Building
MWW-101A
MWW-101B
MWW-101C
598.49
598.46
598.46
BDW-1
597.97
MWE-3
600.66
MWE-1
600.94
BDW-2R
599.67
Inferred Western Plume
Source Area!
East^ri Plume
Source Are^T
Woodard &Curran
-------
Damaged Monitoring Locations - Beach Bluff Wells
Woodard&Curran
-------
I
Damaged Monitoring
Locations - Beach Bluff Wells
Restoration completed in September
2020, workplan for replacements
submitted immediate y following
No activity since response to comments
on replacement well workplan was
provided to EPA on October 8, 2020
Considerations include
¦ Data continuity
¦ Resiliency of monitoring points
¦ Impact of activities to residents
Woodard &Curran
Legend
A Surface Water Sample Location
-0" Proposed Well Point Location
0 Existing Monitoring Well Location
-fy- Former Well Point Location
-Im'/i1'
DOC: BBWELLG319.MXD
JOB NO 205410.20
SOURCE: UAV
BENDIX SUPERFUND SITE ^
ST. JOSEPH, Ml ^
Clf*I IDC
FIGURE 3 fitcuRRAN
PROPOSED LOCATIONS FOR
REPLACEMENT WELL POINTS
(AERIAL PHOTO ¦ SEPTEMBER 2020)
-------
Monitoring
Locations Review
Woodard
&Curran
-------
Locations Not Identified by EPA Field Team - Table 3-3
Boring Namt
Bite
WM Riser
Construction KcttrM
Will
Diameter
pitches)
Measuring Point Elevation
(ft above mean sea level!
NAVD88
Boring
Dtp#! (fwt)
Will Depth
{fwtbfs)
Screen
Length
Screened
Irtterwl
(1**1 bgi)
Screened Intswal
Elivafcns
Northing
UTWZone 16
NAD S3
Easting
UTM Zone 16
NAD 83
Alternat# Namt, Notes
Wells In Current Groundwater Monitoring, Extraction Well and Pieiometer Network
RPW-1
Stainless Steel
2
630.18
67
62
2
6CH-P
5?n ie ti r>i? tr
4u5 ;Sn jilt
04J-_1b 5r C
OW-23
BDVV 2R
!ih« JU4
PV€
4
633-19
77
75
8
7(i i 1
•* 11ti" h j"i
4bS j 4b-1
•V Kfs ^4
OW-18
MWW "AA
•ii"u JLJf-
r v<-
2
1' ! hS
80
80
S
t'i In 11
'i'H he 11 j-,
4h^r11 $h^
4 ! M18 1 !rt
MWW-'KB
F U
2
h'i=i
44
44
5
3 t t' 4 t
S ^il K\ c"i1,1 'ft
4fi55614 4t?
5^0203 545
MWW-2R
1i 'i? 2lll4
p. r
4
j2J fi
87
85
5
Pit "'i
w 'n tn • 44 ! ^
4n'>k ,11- U,
ib4
l",W.'-2, OW-29
MV.W-1
J '1
Stank >s y •! 1
2
Hj' I 1
101
87
2
Kr Lf,
h ti' h3 fo h"
4rT^q1"r
A T-'nlfHO
0fA' 31
IWA'-'i ilA
t| |t ft
P'f
2
h1 *
80
76
5
Tilt T-
1 *>k t'i
40S^b14
"27w in
MrtW "COS
17 2i JS
PVC
2
Ui5 73
42
42
5
J7 tJ 42
SXT'UjZJ 79
4r b 4 144J°
^4 Li14
MAW 11A
PVC
2
ijlllN
82
73.9
5
hrl 11 ',1 -1
>b1 14 tn' 'ft- 14
4f£i:'r k '1 f
M'ft'W- 116
11,21 ::oi
PVC
2
u2M.£ti
89.3
69,1
5
f,> I
Sht: 11 fnH Yi
4uW^ 22
:h12Jj«4
M*VW UC
M 21 14
Pi -
2
4 V
51.3
58.7
5
S. 1. aL'"
V! Ui3 ti 1 HT J i
4t > 1rl
vj ^ 1
M»7W u 2 A
1- „
2
m 1 ;i
84
78.9
5
'J 4 t '|J
W v bH 1-
4n5x^' W
-
MAW- r.-s
F
2
•jJJ i'
71,2
89
5
f 1 h c't
F 1 \(t &¦»* "f"
4L5"t5~ J i'
- .. ¦-
20
*1 23 2214
P>i_
2
I'M,1
81
59.2
5
> 2 L 5^
brri:iot7*^
4brr^ it-141
"4 1 . - ^44
PHI sV 1A
PVC
4
-,'li SI
87
86,7
5
(*,1 Tt "h ~
^ ^t^47r,
4uV*^ -1
CP-8
POCsV la
PVC
4
t,,«4ij
78
76.5
5
'1 5 U L i
Me ti 11' «t
4r5:r.72 1
SO^Gj"*
fOCnV -'A
^ t." 1 4*!
PVC
4
Uu
79
77.9
5
'7 J
In l " lb
4r^ P 1^1
CP4
PCOV-23
> ;c
PVC
4
025 1
69
68,3
5
• ¦
ci7t [J 566 a
4r^"a1J ,jr
rvi 1^^
Pl\*tV-W
1 W
PVC
4
^ M 111
66
«
5
;iri.
>Tt
4i S b4 H?1
CP-?
PUL'uV 3ti
4 H 1U- *
PVC
4
bJ4,Ul
di' 0
79.5
5
fn S t" "¦ 1
') tu ^ iof ®)4 H
4CS£ 1 5^
f0
POI i)V jC
4 71W4
PVC
4
72.7
S
b! , L "V 1
bt'L 2'J !o !A 2^
4rlcrir
irl.PV*
PC'CtfMA
4P ir »3
PVC
4
G2J 25
80
78,5
5
'i 5L~e5
' 1 -l^rh 1 ir
CP.
pei \ 17:
CP-9
st\v;b
, y
PVC
4
633.97
71
70
5
65 to 70
56P 3, iat^.3 I?
¦'
~n vm 07
JfW-i
U 1' H
PVC
4
635,16
78.5
77,5
S
\ 51- -•! h
hi- to >6
4rh ^44 - h
1 34
CP-10
BDe 1
1 H 1^2
PVC
2
628.80
89,5
37.96
2
3f, ^ h / ih
'h_ t.4 h ' ^1 i S4
41)55'V Pi
^Dr3»79:
ow-10
BGE-1
^ u 1ujj
Stainless Steel
2
635.09
43.5
43.5
2
41 5 tc 4J =i
5y^ 5L ii 1 brf 59
4 i:f
0^lr71 715
0W4
MVVE-1
11! 1^22
Stainless Steel
2
631159
89.5
54
10
44 tu5n
5uf ^!.
PVC
4
1 "1
46
45
10
35 to 45
cmF 73
4ast !ic{ bb
^ 14^'• 1M4
MWfc-ji
PVC
4
b ^
85
60
5
55 to 60
')?<* 1 tr ' 'V1 1!
4fS5rir j 1
543521 ujri
POCE 1
b-t(i
PVC
4
1 4
11
10
S
5(010
5o7 !L lu Sijt. f3
4i-5c2bfi ISfi
-ir-2'i^h
POCE-2
ii 11 * > ti t
Stainless Steel
2
jwi ^.7
24
14
10'
4 Is 14
508.2. lu 57t.27
4hri > Sn '
11*] 1 If1
ES-2*V-2
POCE-3
1 S ir»TM
pvr
4
16
15
5
10 to 15
c^2: ii.p.
4f '1 >44 } it
^ mj4'jr
PC€M
1 ! 12
Sinless St"d
2
iu,' it'
32
13
10
3 to 13
5f° h, in1 n"i
4h5"»"i(f ^2
¦~*dKJbhl
ts-iMw :t
POCE D
i J "ud'i
rvc
4
18
15
s
12»17
Sfw V fu 571- ^
u~r2^
VW-37
Woodard&Cyrran
-------
Locations Not Identified by EPA Field Team
~ OW-6 and OW-7: Abandoned
ow-7 rm
OW-5
SVP-5
PW-2
OW-3
PW-1
OW-13
MWE-2
SVE-1 thru SVE-4
SVP-1 thru SVP-6
i
BDE-1
Woodard &Curran
-------
Locations Not Identified by EPA Field Team
OW-19: Not on Bosch property, no access
Table 3-3
Well Construction Summary • Current Monitoring Network
Bendix Superfund Site, St. Joseph, Ml
Boring Name
Date
Well Riser
Construction Material
Well
Diameter
(inches)
Measuring Point Elevation
(ft above mean sea level)
NAVD88
Boring
Depth (feet)
Well Depth
(feet bgs)
Screen
Length
(feet)
Screened
Interval
(feet bgs)
Screened Interval
Elevations
Northing
UTM Zone 16
NAD 83
Easting
UTM Zone 16
NAD 83
POCE-6
3/27/1999
PVC
4
594.26
11
10
5
5 to 10
589.26 to 584.26
4655587.312
540945.076
POCE-7
3/27/1999
PVC
4
595.07
16
15
10
5 to 15
590.07 to 580.07
4655621.754
540964.008
STE-1
3/27/1999
PVC
4
629.36
56
55
10
45 to 55
584.36 to 574.36
4655659.362
540818.738
STE-2
7/1/1997
Stainless Steel
2
627.95
55
55
10
45 to 55
582.95 to 572.95
4655548.538
540820.306
STE-3
9/13/1991
Stainless Steel
2
632.53
51
50
10
40 to 50
592,53 to 582.53
4655430.275
540787.366
BB-01A
10/7/2004
Galvanized steel, PVC
1
589.56
35
32
5
27-32
562.56 to 557.56
4655959.696
539767.049
BB-02A
10/7/2004
PVC
1
591.63
40
37
5
32-37
559.63 to 554.63
4655965.548
539770.501
BB-02B
10/8/2004
PVC
1
591.41
46
32
5
27 to 32
564.41 to 559.41
4655965.548
539770.501
BB-02C
10/8/2004
PVC
1
591.56
40
23
5
18 to 23
573.56 to 568.56
4655965.548
539770.501
BB-03A
10/6/2004
PVC
1
594.15
40
40
5
35 to 40
559.15 to 554.15
4655976.565
539776.339
BB-03B
10/7/2004
PVC
1
594.09
40
24
5
19 to 24
575.09 to 570.09
4655976.565
539776.339
BB-04A
10/6/2004
PVC
1
596.41
39
39
5
34 to 39
562.41 to 557.41
4655988.369
539786.694
OW-1
9/1/1981
PVC
2
632.03
89
58.92
2
56.92 to 58.92
575.13 to 573.13
4655107.953
540229.347
OW-2
9/2/1981
PVC
2
630.87
104
58.92
2
56.92 to 58.92
573.95 to 571.92
4655116.119
540409.379
OW-3
9/2/1981
PVC
2
NA
74
48.02
2
46.02 to 48.02
NA
4655270.65
540577.202
OW-3 (B)
1/6/1982
Galvanized Steel
2
629.99
50
48.28
2
46.28 to 48.28
583.71 to 581.71
NA
NA
OW-4
9/3/1981
PVC
2
630.63
64
43.54
2
41.54 to 43.54
589.09 to 587.09
4655182.428
540571.815
OW-5
9/4/1981
PVC
2
628.71
64
48.49
2
46.49 to 48.49
582.22 to 580.22
4655331.388
540582.593
OW-6
9/8/1981
PVC
2
629.57
74
47.61
2
45.61 to 47.61
583.96 to 581.96
4655267.466
540506.384
OW-7
1/7/1982
Galvanized Steel
2
630.62
74.5
49.1
2
47.1 to 49.1
583.52 to 581.52
4655388.343
540467.405
OW-8
1/7/1982
Galvanized Steel
2
631.80
84
68.76
2
66.76 to 68.76
565.04 to 563.04
4655618.531
540407.963
OW-9
1/8/1982
Galvanized Steel
2
630.59
69.5
38.53
2
36.53 to 38.53
594.06 to 592.06
4655566.967
540576.326
OW-10
1/8/1982
PVC
2
628.80
69.5
37.96
2
35.96 to 37.96
592.84 to 590.84
4655217.131
540639.793
OW-11
1/12/1982
Galvanized Steel
2
628.95
69.5
38.5
2
36.5 to 38.5
592.45 to 590.45
NA
NA
OW-12
1/13/1982
Galvanized Steel
2
630.82
69.5
44.68
2
42.68 to 44.68
588.14 to 586.14
NA
NA
OW-13
1/13/1982
Galvanized Steel
2
630.02
64.5
49.3
2
47.3 to 49.3
582.72 to 580.72
4655430.543
540627.108
OW-14
1/14/1982
Galvanized Steel
2
630.14
64.5
49.24
2
47.24 to 49.24
582.9 to 580.9
NA
NA
OW-15
1/26/1984
Galvanized Steel
2
613.80
49
28.98
2
26.98 to 28.98
586.82 to 584.82
4655430.275
540787.366
OW-16
6/14/1984
Galvanized Steel
2
631.93
84
59
2
57-59
574.93 to 572.93
4655283.335
540252.83
OW-17
6/15/1984
Galvanized Steel
2
633.60
79
71
2
69-71
564.60 to 562.60
4655499.538
540226.678
OW-18
6/19/1984
Galvanized Steel
2
630.38
83
73
2
71-73
559.38 to 557.38
4655659.463
540219.364
OW-19
6/20/1984
Galvanized Steel
2
632.79
64
55
2
53 to 55
579.79 to 577.79
4655660.781
540296.52
Woodard &Curran
, MWW-101C
MWW-101B
/ MWW-101A
OW-8
WW-100A
WW-100B
-------
Locations
~ OW-28:
Houses built
on top (west
of BDW-2R)
Holiday House Rd
WOOCARD&CURRAN
Engineering • Science • Operations
scote
Not Identified by EPA Field Team
LEGEND
595
— INTERPRETED GROUNDWATER CONTOURS
FORMER LAGOON SITES
1 j
EXISTING BUILDINGS
OW-25^
MONITORING WELL
*
WETLAND
PZ-1S^
PIEZOMETER
B—11a
SOIL BORING
ce Lake Bluff Terrace
A, OW-194.
OW-18
WoodgaleDr MR. « w,wl
Woodgate Dr
¦ Of-'Ml H
TANK FA
-0 n
aid eh In
OW-1
a |aBatf"ab tf3fn|
l\LmLl/inL MULJiivniiwn nu v>»
BOSCH BRAKING SYSTEMS
ST. JOSEPH. MICHIGAN
-------
Locations
~ OW-30:
May exist
in woods
between
Austin
Trail and
Lake Bluff
Terrace
Not Identified by EPA Field Team
/
/
/
&
'
/W-3
M x ll
/ 0W-3^r>
Qi .fS J h
,i f> a Q/o a a
\t c9cnC3£5C3aacPi=i
Woodard &Curran
-------
Locations Not Identified by EPA Field Team
~ OW-32:
Likely
destroyed
during
construction
of Churchill
Farms
Woodard»Curran
-------
Locations Not Identified by EPA Field Team
~ OW-34:
Likely
destroyed
during
construction
of Churchill
Farms
Woodard»Curran
-------
Locations
~ BGW-1:
Same as
MW-36D,
currently in
the
monitoring
orogram,
ocated east
of H&J
Florist
Eastern Plume
Source Area£
MWE-2
603.23
BGW-1
605.67
Identified by EPA Field Team
LEGEND
^^00 94^
inferred Western Plume
Source Areaw
OW-18
¦fr
f FORMER t
TANK FARM
POSCII P
B '0
B-» B-1 I
FIGURE 2-1
EXISTING MONITORING WELL NETWORK
0 a D ,£jj []|
OW-1
OW—2
a
FORMER SOUTH LAGOON
REMEDIAL INVESTIGATION REPORT
BOSCH BRAKING SYSTEMS
ST. JOSEPH, MICHIGAN
JOB NO.: 93194.05
IALL0F2-1
SCALE: NOTED
DATE; JANUARY 1997
WW-365
uw-
Woodard &Curran
-------
Locations Not Accessible by EPA Field Team
~ STE-3 (aka ES-4)
~ POCE-1
~ POCE-2 (aka ES-2)
~ POCE-3
~ POCE-4 (aka ES-3)
~ OW-15
Woodard&Curran
-------
Questions, List of Actions Prior
to Site Walk
Woodand
&Curran
-------
APPENDIX Q- FYR NOTIFICATION
65
-------
U>' \ • 1,1, IVIRONMENTAL Pi TION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
IRE HON OIF:
SR-6J
VIA EMAIL
August 11, 2023
Mr. John Young, Director, Environmental, Health and Safety
Robert Bosch LLC, Contaminated Sites Management (RBNA/HSE 7)
38000 Hills Tech Drive
Farmington Hills, Michigan 48331
Re: Notification of the Five-Year Review Start for the Bendix Corp./Allied Automotive Site
3737 Red Arrow Highway, St. Joseph, Michigan
MID005107222
Dear Mr. Young:
This letter is to notify you that the United States Environmental Protection Agency (EPA) has
begun the process of the Five-Year Review (FYR) for the Bendix Corp./Allied Automotive (aka
Bosch) Superfund Site in St. Joseph, Michigan. A Statutory FYR for the Site will be conducted
as required by Section 121 of the Comprehensive Environmental Response Compensation and
Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA). The law requires that remedial actions that result in any hazardous substances,
pollutants, or contaminants remaining at the site shall be subject to a FYR to determine if the
remedy remains protective of human health and the environment.
The FYR for Bendix Corp./Allied Automotive Site is due on August 20, 2024, and we are
providing you this notification to confirm that EPA and the Michigan Department of
Environment, Great Lakes, and Energy (EGLE) are beginning the necessary coordination
activities. A site inspection is being scheduled for Fall 2023, in accordance with recent
correspondences with Bosch regarding this event.
The review schedule for the other components is as follows:
Data and Document review Start-August 11, 2023
Public notification Start - August 2023
Site Inspection - September 12, 2023
• Draft Five-Year Review Report-by June 15, 2024
Five-Year Review Report Review and Approval-by August 20, 2024
Recycled/Recyclable * Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post Consumer)
-------
The results of the FYR will be placed in the public repositories.
If you have any questions or concerns regarding this FYR for the Bendix Corp./Allied
Automotive Site, please contact me by phone at (312) 353-2111 or via email at
kelly.ioseph@epa.eov.
Sincerely,
Joseph C. Kelly
Remedial Project Manager
US EPA, Superfund and Emergency Management Division
cc:
D.J. Leidy, Robert Bosch LLC (by email)
Jedd Steinglass and Dave Dinsmore, Woodard & Curran (by email)
Dick Stauffer and Marc D. Florian, Lincoln Charter Township (by email)
Samantha Belisle and Nathan Zielinski, EGLE (by email)
Cheryl Allen, EPA (by email)
Jamie Getz and Richard Clarizio, ORC (by email)
Ellen Ryan-Scarpello (by email)
R5 SF Records (by email)
2
-------
APPENDIX R - REVISED PLUME MAPS
66
-------
i uc uoncentranons
TCE Concentration
Interpretative Contour Map
Bendix Superfund Site
St. Joseph, Ml
2020-2022
POCW-5A: <0.5
PQCWSB: <0.5
=OCW-lA: <0.6 I
I POCW-S6: 1.4 J I
I FCOV-SC: 26
PQCW-2A: <12
PGCW-2B: ¦ D.S
P0CW-4A: <0.5 1
P-ODAMB: 31
POCW-4C: 0.5
EPA Plume predictions
STW-2A: <26
¦ 3TW-2E: o.ee
POCW-1A 28
POCW-1B:
waw-i: ^ ¦ 2
SWWW-101B 1JD0
fiW¥W-1§1C: 2B0
r MMS-mfi, : *K> ]
HWW-100B: <0,5
MVfVf-1 RA:
flWW-1 RE: *-0,5
MWW-3 * 5.0 I
mw;-2P *'2D f
W&C Plume depiction
M»VA'-1 55 L j ii "]*-
MWA'-1C2A: <25
MWW-102B 1,200 I
MWW-1Q2C: 46 I
EW-2: a00
EW-1:150 ft
W/JE-3 ¦-' 20
• ND to < 5 ug/L
>= 5 to < 100 ug/L
>= 100 to < 1,000 ug/L
>= 1,000 to < 12,800 ug/L
# >= 12,800 ug/L
I j Lagoons
North Parking Lot
[_ Bendix Foundry
L ^ Bendix Manufacturing Plant
rTT:
PqCE-7 0.30 J
I PQCE-S: 2.4
STE-2. 12 f
)CL i: '-0.S
| PQCE-4: D.5
PQCE-3: <0.5 I
¦ POCE-2: *0.5
STE-3 <12
BDCE-l: ' 0.5
I BDE-1: <0.5
•BT^rl <0.Sr—
J
Figure 10 a - Combined Plume Interpretations of EPA/W&C (TCE)
ft 2Q22 Monitoring Well Network
¦€- Extraction WeU
~ Piezometer
f * \ * Noveitsb&r 2022: TCE Interpretive Concentration Contours
Contours Based On Highest Concentration of Well Cluster
Highest Concentrations of Sample/Duplicate Usee
}\ Estimated Concentrations
MD = Not Detected
UNITS' ppb OR pg/L
1 inch = 450 feet
wc<
N
A
•uin
Combined
Interpretations of
W&C 2022
Annual Report and
SSPA 2023 CSM
Th -:J =\rty ~-l5 Psdamor: rhts nap # for reference and grapttcal aiJy and F»Jd not be -TdHrf upon bp tMni pvties for »ny legal d&astons.
Artt rdia .¦-« ,rie ma:- :c Jz»a ;cwa -cd -awn Ja I d& r H e .lew' -is*. kuu.** LSHl World Imagery
-------
kOCE-S: <0.5
POCW-5A: • 0.5
PQCW-5B: -4.5
POC4V-EA: 1.4
POCW-SB: 760
POCW-SC: 3,o
POCW-2A: SOC
FOCW-2B: -0.5
POCW-44: 35
POCW-4B: 43® I
P0CW-4C: -itS
POCW-1A: 1
POCW-1B: -f.i,
3TW^
r MWW-1024 1,tdC
I MW»V-102B: 2201
IP
W&C Plume depiction
3TW-2A: £,80
STW-2S: <0.€
. • • • • <
¦!,ec«:
¦K3: /
MWW-1: 29 / I
% nl. "
EPA Plume predictions
MWW-10QA: 120
I MWW-IQOB: "'D£
VWW-1 RA
j r^V. =-3: 2:5,000
cis-i ,i-uvc uonceniranons
• ND to < 70 ug/L
>= 70 to < 100 ug/L
>= 100 to < 1,000 ug/L
• >=1,000 to < 10,000 ug/L
• >= 10,000 ug/L
Lagoons
' North Parking Lot
Bendix Foundry
| Bendix Manufacturing Plant
EVV-3: 57C
EW-2: 930
EW-1:4.80 A
[mwe-2: 3
FOCE-S
31G
2 DC
E--
*
rOCE-3: ¦ 0
5TE--3: 3.5C J
J1
POCE-2: <0.5
SESP3
¦ '7"iT
i K«
. uun- i • trm
II 1,1,1. -JF VAHnl) \
'ZM StUrMQ "*% f " ~' "1 | \ *
Figure 10 b - Combined Plume Interpretations of EPA/W&C (cis-l,2-DCE)
Cis-1,2-DCE Concentration
Interpretative Contour Map
Bendix Superfund Site
St. Joseph, Ml
2020-2022
~
k_l
C
Sr
CD
(U
+
•'—J
2022 Monitoring Well Network
Extraction We I
PiftzooMter
November 2022: Cis-1,2-DCE Inlerpretive Concentration Contours
Contours B.ssed On Highest Concentration of Well Cluster
Hichest Concentrations of Sample/Duplicate Usee
J: Estimated Concentrations
ND = Not Detected
J NITS ppb OR pg/L
1 inch = 450 feet
Combined
Interpretations of
W&C 2022
Annual Report and
SSPA 2023 CSM
i :! "-IS (fcdalrft*: rbte map «for and grac.tycsl pijrpcfSK only and #oJd no« be relted upon by ttMid parties 'or my legal dtastora.
A ft nib wa » j ftg nag er .1:' j :crn.-i gad hgnrin rigfl t>t r thg .:W rtt Egg* SgumM Li Pi jjfajij jmgBBE
-------
STW-2:
HOCL-tj o.i; j
VC Concentration
Interpretative Contour Map
Bendix Superfund Site
St. Joseph, Ml
2020-2022
POCW-SA: *1.0
POCW-53 e.4
; =OCtV-SA:
POCW-SB: 81
PODW-SC: S.i
POCW-2A: 5.1
POCW-2B: <
*C*T
7
POCW-4A: 110
POCW-4B: 1
POCW-4C = 2 to < 100 ug/L
>= 100 to <1,000 ug/L
>= 1,000 to < 10,000 ug/L
>= 10,000 ug/L
Lagoons
North Parking Lot
Bendix Foundry
Bendix Manufacturing Plant
EV.
:
EW
POCE-7: 3.5
EW-1: 420 d
MWE-2: 2 .!
Figure 10 c- Combined Plume Interpretations of EPA/W&C (Vinyl Chlori
BGVv-1 - .0
POCE-4: 3.4S J
POCE-2: C.0B J
S IX* >¦
I STE-2: i&D f
*
'\
I F'OCE-2 -4. 0
STE-3 1D0
2022 Monitoring Well Network
Extraction Well
Piftzomatw
j,* November 2022 Vinyl Chloride Interpretive Concentration Contours
Contours Based Or* Highest Concentration of Well Cluster
Highest Coicentrations of Sample/Duplicate Usee
J: Estimated Concentrations
ND = Not Detected
JN|TS ppb OR (ig/L
1 inch = 450 feet
Combined
Interpretations of
W&C 2022
Annual Report and
SSPA 2023 CSM
Th-d C-Js rhts f-ap « rcr •nrtrence ami gafAIal pjcpasK only and strald not be upon by tNnl pwtjes i^r wy legal cIkjsiona.
¦ >\ •>: i i- •• ¦ ••• i ¦ i ¦ : il ¦ r- ¦¦ : :- l': :¦ Paidui«> i.-'l H l i-. '¦
-------
APPENDIX S - POTENTIAL SOURCE AREAS REQUIRING FURTHER INVESTIGATION
67
-------
FIGURE 1
Figure 11a Potential Spurces (ESj, 1993)
-------
4>~
—
4»
4*
^ IS*
*.
4...
'¦
*
¦*
5
-------
FIGURE 3
-------
-------
-------
-------
-------
APPENDIX T - EGLE FYR RECOMMENDATIONS
68
-------
State of Michigan
DEPARTMENT OF
ENVIRONMENT, GREAT LAKES, AND ENERGY
Lansing
GRETCHEN WHITMER
GOVERNOR
PHILLIP D. ROOS
DIRECTOR
August 16, 2023
VIA EMAIL
Joseph Kelly
United States Environmental Protection Agency
Region 5
77 West Jackson Boulevard (SR-6J)
Chicago, Illinois 60604-3507
Dear Joseph Kelly:
SUBJECT: Issues Recommended for Inclusion in the Upcoming Five-Year Review
Report (FYR) for the Bendix Corporations/Allied Automotive, Superfund
Site, Saint Joseph, Michigan
Michigan Department of Environment, Great Lakes, and Energy (EGLE) staff would
like to provide the United States Environmental Protection Agency (USEPA) the
following list of issues and concerns we request be included in the upcoming Bendix
Corporation/Allied Automotive Superfund Site, Fifth FYR Report.
All the issues listed in the 2019 FYR Report are still outstanding. Little progress has
been made in terms of completing the recommendations and follow-up actions listed
in 2019. A comprehensive list of the concerns that EGLE has that need to be
addressed and/or evaluated follows:
• A remedy must be implemented that will achieve Record of Decision (ROD)
objectives in an expeditious timeframe to prevent the constant discharge of
contaminants to Lake Michigan.
• The effectiveness of the groundwater extraction and treatment system needs to
be evaluated.
o Critically evaluate the size and operating capacity, as well as zone of
influence of the current Mass Reduction System and plan contingency
action(s) if necessary,
o A comprehensive mass flux analysis needs to be completed to further
evaluate the system effectiveness.
• Given the ongoing discharge of chlorinated solvents to Lake Michigan, the
effectiveness of the Monitored Natural Attenuation remedy needs to be
evaluated.
• A requirement in the ROD specified, "Maintenance of existing cover system to
minimize infiltration to precipitation to volatile organic compounds (VOCs) in
CONSTITUTION HALL • 525 WEST ALLEGAN STREET •P.O. BOX 30473 • LANSING, MICHIGAN 48909-7973
Michigan.gov/EGLE • 800-662-9278
-------
Joseph Kelly
2
August 16, 2023
vadose zone soils and restrict access to/direct contact with those soils." The
foundry building at the site was demolished in 2009. Although some soil was
excavated, confirmation samples were not collected in this area and the
concrete slab was never replaced. The removal of this building may have
activated a source area by allowing increased infiltration to this area. An
approved work plan should be implemented to further investigate and remove
any remaining source in this area, or to install an impermeable surface barrier.
• The extent of impacts in groundwater have not been comprehensively
characterized and there are several locations where the plume boundaries
have not been defined. A review of the monitoring well network must be
completed, and additional monitoring wells are required to define the extent of
groundwater contamination. Areas of specific concern are:
o The area surrounding MWE-3
o The area to the west of the plant
o Along the southern and northern edge of the plume
o The former lagoon area
• A USEPA and EGLE approved vapor intrusion (VI) investigation must be
completed for the plant site to ensure workers are protected.
• A USEPA and EGLE approved VI investigation must be completed to evaluate
off-site commercial and industrial structures where contaminated groundwater
is present beneath the structure at concentrations exceeding applicable
volatilization to indoor air criteria. Additionally, an evaluation of structures within
the 100-foot inclusion zone of the groundwater plume boundary should also be
completed.
• There is a need for additional pore water and sediment sampling along the
Churchill Farms shoreline to address concerns with human health and the
environment. It is understood that collecting these samples is a difficult process
due to the variable lake conditions. To ensure the sampling is completed safely
and correctly, it is recommended that a contractor with extensive aquatic
experience be utilized.
• Ensure Institutional Controls will remain in place for the long-term, which
includes the development of an approved Institutional Control Implementation
and Assurance Plan. Additionally, the institutional controls already in place
should be reviewed and updated based on input from the USEPA and EGLE,
as many do not have sufficient restrictions to ensure long-term protectiveness
of human health.
• EGLE installed three monitoring well nests with four or five screens in each in
the Churchill Farms Subdivision (DEQ-1-55, 1-63, 1-76 and 1-86; DEQ-2-55,
2-72, 2-80, 2-88; DEQ-3-55, 3-65, 3-77, and 3-85) and these wells should be
incorporated into the routine monitoring plan.
-------
Joseph Kelly
3
August 16, 2023
• The analysis of 1,4-dioxane and per- and polyfluorinated alkyl substances
(PFAS) should be added to the groundwater sampling plan. The June 30, 2020,
Historical Site Use memorandum completed by Woodward & Curran indicated
1,4-dioxane may be present in groundwater at the site; however, no sitewide
groundwater event with analysis for 1,4-dioxane has been completed to date.
And while the Historical Site Use memorandum did not document historical
uses of PFAS at the plant, EGLE does not find the supporting evidence for this
conclusion to be sufficient, as the conclusion was primarily based on former
employee recollection. Due to the variable manufacturing history of the site
dating back to 1939 and several changes in ownership, sampling should be
completed to determine if it has been previously utilized at the site.
• An annual update should be prepared and distributed to the Churchill Farms
subdivision residents. It would be preferred that the agencies provide input on
the update if it is something that is prepared by the Potentially Responsible
Party (PRP). These updates should be based on information from a Final
Annual Report (not a draft) that has been reviewed by the agencies and
approved.
• An approved work plan to replace the wells that were destroyed by storms in
October 2019 at Beach Bluff should be implemented.
If you have additional questions regarding this matter, please contact Samantha Belisle,
Project Manager, Remediation and Redevelopment Division, at 517-290-0686;
BelisleS1@Michigan.gov; or EGLE, P.O. Box 30426, Lansing, Michigan 48909-7926.
We look forward to working together on the upcoming FYR.
Sincerely,
S j--*' y • v,
Samantha Belisle
Project Manager
517-290-0686
cc: Robert Franks, EGLE
Nate Zielinski, EGLE
------- |