u s EPA RECORDS CENTER REGIONUS EPA RECORDS CENTER REGION 55

1111111111111111111111111111111111111111 410972410972

THIRD FIVE YEAR REVIEW REPORTTHIRD FIVE YEAR REVIEW REPORT

ALBION-SHERIDAN TOWNSHIP LANDFILL SUPERFUND SITEALBION-SHERIDAN TOWNSHIP LANDFILL SUPERFUND SITE

AlbionAlbion Calhoun County , MichiganCalhoun County, Michigan

August 2012August 2012

PREPARED BY:PREPARED BY:

United States Environmental Protection AgencyUnited States Environmental Protection Agency RegionRegion 55

Chicago, IllinoisChicago, Illinois

Approved by:Approved by: Date:Date:

£ ^ c i i ^ 6 - 2 - 1

Richard C. Karl, DirectorRichard C. Karl, Director US EPA RegionUS EPA Region 55

Table of ContentsTable of Contents

List of AcronymsList of Acronyms I'V v Executive SummaryExecutive Summary vv Five Year Review Summary FornlFive Year Review Summary Form , vlvi

INTRODUCTION1.01.0 INTRODUCTION 11 2.02.0 SITE CHRONOLOGYSITE CHRONOLOGY 22

BACKGROUND3.03.0 BACKGROUND 22 3.13.1 Physical CharacteristicsPhysical Characteristics 22

Land and Resource Use3.23.2 Land and Resource Use 33 History of Contamination3.33.3 History of Contamination 33 Initial Response3.43.4 Initial Response 33 Basis for Taking Action3.53.5 Basis for Taking Action 33

REMEDIAL ACTIONS4.04.0 REMEDIAL ACTIONS 55 Remedy Selection4.14.1 Remedy Selection 55 Remedy Inlplenlentation4.24.2 Remedy Implementation 66 Institutional Controls4.34.3 Institutional Controls 77

4.44.4 System Operations/Operation and Maintenance (O&M) 99System Operations/Operation and Maintenance (O&M) 5.05.0 PROGRESS SINCE LAST FIVE YEAR REVIEWPROGRESS SINCE LAST FIVE YEAR REVIEW 1100 6.06.0 FIVE YEAR REVIEW PROCESS 1111FIVE YEAR REVIEW PROCESS

6.16.1 Administrative ComponentsAdministrative Components 1111 6.2 Community Notification and Involvement 11116.2 Community Notification and Involvement 6.36.3 Doculnent ReviewDocument Review 1212 6.46.4 Data Review Data Review 1212 6.56.5 SiteSite InspectionInspection 1313

7.07.0 TECHNICALTECHNICAL ASSESSMENTASSESSMENT 1313 7.1 QuestionQuestion 7.1 A:A: Is the remedy fianctlonlng as Intended by the decision documents?Is the remedy functioning as intended by the decision documents? 1313 7.27.2 Question B: Are the assumptions used at the time of remedy selection still valid?Are the assumptions used at the time of remedy selection still valid?Question B: .... 1414 7.37.3 Question C: Has any other Information come to light that could call Into question theQuestion C: Has any other infornlation come to light that could call into question the

protectlveness ofprotectiveness of the remedy?the remedy? 1515 8.08.0 ISSUES ISSUES 1515 9.09.0 RECOMMENDATIONSRECOMMENDATIONS AND FOLLOW-UP ACTIONSAND FOLLOW-UP ACTIONS 1515 10.010.0 PROTECTIVENESS STATEMENT(S)PROTECTIVENESS STATEMENT(S) 1616 11.011.0 NEXT REVIEWNEXT REVIEW 1616

11

AttachmentsAttachments Figure 11Figure Figure 22Figure Figure 33Figure Figure 44Figure Attachment 11Attachment AttachmentAttachment 22

TablesTables Table 11Table Table 22Table Table 33Table Table 44Table TableTable 55 TableTable 66

Site Location MapSite Location Map Site IC Area MapSite IC Area Map Site Arsenic Isoconcentration MapSite Arsenic Isoconcentratlon Map Site Groundwater Contour MapSite Groundwater Contour Map List of ReviewedList of DocumentsDocuments Reviewed Five Year Review AdvertisementFive Year Review Advertisement

Chronology of Site EventsChronology of Site Events Institutional Control AreasInstitutional Control Areas Annual System Operations/ O&M CostsAnnual System Operations/ O&M Costs Actions Taken Since Last Five Year ReviewActions Taken Since Last Five Year Review Identified Issues that Impact ProtectivenessIdentified Issues that Impact Protectlveness Recommendations and Follow-up ActionsRecommendations and Follow-up Actions

1IlHI

Acronymsms

AgenciesAgenciesARARsARARs

CDCDCFRCFR FSFSgpmgpmICICMCLMCL

MDEQMDEQ

MDNRMDNR

mg/kgmg/kg NCPNCPNPLNPL O&MO&Mppbppb

MDEQ and EPA MDEQ and EPA Applicable or Relevant and Applicable or Relevant and Appropriate Requirements Appropriate Requirements Consent Decree Consent Decree Code of Federal Regulations Code of Federal Regulations Feasibility Study Feasibility Study gallons per minute gallons per minute Institutional Control Institutional Control Maximum Contaminant Maximum Contaminant LevelLevel Michigan Department of Michigan Department of Environmental Quality Environmental Quality Michigan Department of Michigan Department of Natural Resources Natural Resources

milligrams per kilogram milligrams per kilogram National Contingency Plan National Contingency Plan

National Priorities List National Priorities List Operation and Maintenance Operation and Maintenance

parts per billion parts per billion

ppmppm PRPPRP RARA RDRD RlRl RIIFSRI/FS

RODROD SiteSite

UAOUAO

EPAEPA

UU/UEUU/UE

)Jg/LHg/L VESVES VOCsVOCs

parts per million parts per million Potentially Responsible Party Potentially Responsible Party Remedial Action Remedial Action Remedial Design Remedial Design Remedial Investigation Remedial Investigation Remedial Investigation! Remedial Investigation/ Feasibility Study Feasibility Study Record of DecisionRecord of Decision Albion-Sheridan Township Alblon-Sherldan Township Landfill Superfund Site Landfill Superfund Site Unilateral Administrative Unilateral Administrative OrderOrder United States Environmental United States Environmental Protection Agency Protection Agency Unrestricted Use/ Unlimited Unrestricted Use/ Unlimited Exposure Exposure micrograms per Liter micrograms per Liter Vapor Extraction System Vapor Extraction System Volatile Organic Compounds Volatile Organic Compounds

IV IV

Executive SummaryExecutive Summary

This Is the third year review report for the Alblon-Sherldan Landfill Superfund Site (Site)This is the third fivefive year review report for the Albion-Sheridan Landfill Superfund Site (Site) located In Albion, Calhoun County, Michigan. The first five year review was completed inlocated in Albion, Calhoun County, Michigan. The first five year review was completed in September 2002 and the second year review report was signed In August 2007. TheSeptember 2002 and the second fivefive year review report was signed in August 2007. The components of the Site remedy selected In the 1995 ROD and enforced under the terms of thecomponents of the Site remedy selected in the 1995 ROD and enforced under the terms of the 1999 Consent Decree have been implemented and remain in place with no known exposure1999 Consent Decree have been Implemented and remain In place with no known exposure pathways that result in unacceptable risks. The Site remains in long term operation andpathways that result in unacceptable risks. The Site remains in long term operation and maintenance (O&M).maintenance (O&M).

Arsenic is contaminant of concern In the groundwater at the Site. An arsenic trend analysis forArsenic is aa contaminant of concern in the groundwater at the Site. An arsenic trend analysis for groundwater is updated annually In the O&M progress reports. The trend over the last yearsgroundwater is updated annually in the O&M progress reports. The trend over the last fivefive years has found total arsenic levels decreasing to below the 10 ppb maximum contaminant levelhas found total arsenic levels decreasing to below the 10 ppb maximum contaminant level (MCL) at all but one Isolated monitoring well location within the Site landfill property boundary.(MCL) at all but one isolated monitoring well location within the Site landfill property boundary. The decreasing trend indicates that total arsenic In groundwater at or above the MCL Is notThe decreasing trend indicates that total arsenic in groundwater at or above the MCL is not migrating off-site. This Is significant change since the last year review when EPAmigrating off-site. This is aa significant change since the last fivefive year review when EPA detennlned that elevated arsenic contaminated groundwater was moving off site. One off-sitedetennined that elevated arsenic contaminated groundwater was moving off site. One off-site monitoring well locafion on the Norfolk Southern Railway rlght-of way remains above the 10monitoring well location on the Norfolk && Southern Railway right-of way remains above the 10 ppb MCL (61 ppb, 58 ppb, and 61 ppb over the last three years), but there are no known humanppb MCL (61 ppb, 58 ppb, and 61 ppb over the last three years), but there are no known human exposures related to the groundwater from this area.exposures related to the groundwater from this area.

The Site landfill cap remains In place and continues to provide an adequate barrier for wasteThe Site landfill cap remains in place and continues to provide an adequate barrier for waste containment. There is no evidence of cap breach and the existing use of the Site property iscontainment. There is no evidence of aa cap breach and the existing use of the Site property is consistent with the objectivesconsistent with the objectives ofof the landfill cap and land use restrictions.the landfill cap and land use restrictions. Declaration ofAA Declaration of Restrictive Covenant on tliree Site parcels owned by CDC Associates has been recorded at theRestrictive Covenant on three Site parcels owned by CDC Associates has been recorded at the Calhoun County Recorder's Office and site use remains In compliance. Additional InsfitutlonalCalhoun County Recorder's Office and site use remains in compliance. Additional institutional controls (IC) are needed on Site parcel(s) formerly owned by the state of Michigan and currentlycontrols (IC) are needed on Site parcel(s) formerly owned by the state of Michigan and currently owned by Calhoun County.owned by Calhoun County.

EPA has detennined that the Albion-Sheridan Landfill Site remedy is functioning as intendedEPA has detennlned that the Alblon-Sherldan Landfill Site remedy isfianctlonlngas Intended and is protective of human health and the environment In the short term. The Site landfill capand is protective of human health and the environment in the short term. The Site landfill cap remains In place and continues to provide an adequate barrier for waste containment. There is noremains in place and continues to provide an adequate barrier for waste containment. There is no evidence of cap breach and the existing use of the Site property Is consistent with theevidence of aa cap breach and the existing use of the Site property is consistent with the objectives of the landfill cap and land use restrictions. There is no evidence of Site arsenicobjectives of the landfill cap and land use restrictions. There is no evidence of Site arsenic contaminant migration above MCLs impacting drinking water. However, in order for thecontaminant migration above MCLs impacting drinking water. However, in order for the remedy to be protective In the long-temi, the following actions need to be taken to ensure long­remedy to be protective in the long-tenn, the following actions need to be taken to ensure long­terni protectlveness: Implement additional effective ICs to ensure Site property and groundwatertenn protectiveness: implement additional efTective ICs to ensure Site property and groundwater protectlveness; enforce maintain, and monitor the effective ICs; and Implement theprotectiveness; enforce compliance,compliance, maintain, and monitor the effective ICs; and implement the ongoing O&M program.ongoing O&M program.

v

Five Year Review Summary FormFive Year Review Summary Form

SITE IDENTIFICATIONSITE IDENTIFICATION

Site Name: Albion-Sheridan Township Landfill Superfund SiteSite Name : Albion-Sheridan Township Landfill Superfund Site

EPA ID : MID9

Region: 5

EPA ID : MID9 80504450

State: MI

80504450

State: MI City/County: Albion, Calhoun

SITE STATUS

NPL Status: Final

Multiple OUs? No

Has Yes

the site achieved construction completion?

Lead agency:Lead agency: EPAEPA Author name (Federal or State Project Manager): Jeff GoreAuthor name (Federal or State Project Manager): Jeff Gore Author affiliation: EPA, Region 55Author affiliation: EPA, Region Review period: 10/6/2011 to August 2012Review period: 10/6/2011 to August 2012 Date of site inspection: 10/26/2011Date of site inspection: 10/26/201 Type of review: StatutoryType of review: Statutory Review number: 33Review number: Triggering action date: 811512007Triggering action date: 8/15/2007 Due date (five years after triggering action date): 8115/2012Due date (five years after triggering action date): 8/15/2012

VIVI

I Issues/RecommendationsIssues/Recommendations

Issues and Recommendations Identified in the Five Year Review:

OU(s): Issue Category:Issue Category: Operation and Maintenance.Operation and Maintenance.

Issues and Recommendations Identified in the Five Year Review: |

OU(s): 11

Issue: Arsenic groundwater trend analysis for Site.Issue: Arsenic groundwater trend analysis for Site.

Recommendation: Conduct aa multi-year trend analysis for arsenic duringRecommendation: Conduct multi-year trend analysis for arsenic during the O&M program by monitoring arsenic levels in groundwater over thethe O&M program by monitoring arsenic levels In groundwater over the next years to see If the trend of reduced arsenic levels In mlgrafingnext fivefive years to see if the trend of reduced arsenic levels in migrating groundwater continues.groundwater continues.

Affect CurrentAffect Current Affect FutureAffect Future ImplementingImplementing OversightOversight Milestone DateMilestone Date ProtectlvenessProtectiveness ProtectivenessProtectiveness PartyParty PartyParty

NoNo YesYes PRPsPRPs EPA/ MDEQEPAI MDEQ August 2013August 2013 annually throughannually through August 2017August 2017

OU(s):OU(s): 11 Issue Category:Issue Category: Institutional Controls.Institutional Controls.

Issue: Additional ICs for Site property parcel(s).Issue: Additional ICs for Site property parcel(s).

Recommendation: EPA will work with the PRPs, Calhoun County, andRecommendation: EPA will work with the PRPs, Calhoun County, and the Michigan Department of Environmental Quality (MDEQ) to ensurethe Michigan Department of Environmental Quality (MDEQ) to ensure that ICs in the form of restrictive covenant(s) are Implemented on Sitethat ICs in the form ofrestrictive covenant(s) are implemented on Site property parcel(s) owned by Calhoun County. The ICs will assure thatproperty parcel(s) owned by Calhoun County. The ICs will assure that land and groundwater use on Site parcel(s) are adequately restricted andland and groundwater use on Site parcel(s) are adequately restricted and the Site remedy is not disturbed.the Site remedy is not disturbed.

Affect CurrentAffect Current Affect FutureAffect Future Implementing O\'ersightOversight Milestone DateMilestone DateImplementing Protectlveness Protectiveness Party PartyProtectiveness Protectiveness Party Party

NoNo YesYes PRPs/ Calhoun EPA/ MDEQ August 2013 County PRPs/ Calhoun EPAlMDEQ August 2013 County

Vllvu

I

ProtectiYeness Statement(s)Protectiveness Statement(s)

Protectiveness Determination:Operable Unit:Operable Unit: Protectiveness Determination: Short-term ProtectiveShort-term Protective

Protectiveness Statement:Protectiveness Statement: The Albion-Sheridan Landfill Site remedy is functioning as human health and the environment in the short term.human health and the environment In the short term. The Site landfill cap remains in place The Alblon-Sherldan Landfill Site remedy Is functioning as intended and is protectiveintended and is protective ofof

The Site landfill cap remains in place and continues to provide an adequate barrier for waste containment. There is no evidence ofand continues to provide an adequate barrier for waste containment. There is no evidence of aa cap breach and the existing use of the Site property Is consistent with the objectives of thecap breach and the existing use of the Site property is consistent with the objectives of the landfill cap and land useuse There is no evidenceevidence ofof SiteSite arsenic contaminantarsenic contaminantlandfill cap and land restrictions.restrictions. There Is no migration above MCLs impacting drinking water.migration above MCLs impacting drinking water. However, in order for the remedy to beHowever, in order for the remedy to be protective in the long-term, the following actions need toto be taken to ensure long-termprotective in the long-term, the following actions need be taken to ensure long-term protectlveness: Implement additional effective ICs to ensure Site property and groundwaterprotectiveness: implement additional effective ICs to ensure Site property and groundwater protectiveness; enforce maintain, and monitor the effective ICs; and Implementprotectiveness; enforce compliance,compliance, maintain, and monitor the effective ICs; and implement the ongoing O&M program.the ongoing O&M program.

Site" ide Protectiveness StatementSitewide Protectiveness Statement

Protecti"veness Determination:Protectiveness Determination: Short-term ProtectiveShort-term Protective

Protectiveness Statement:Protectiveness Statement: The Albion-Sheridan Landfill Site remedy is functioningThe Alblon-Sherldan Landfill asas intended and is protective of human health and the environment in the short term.human health and the enviromnent in the short term. The Site landfill cap remains In place

Site remedy is functioning Intended and is protective of The Site landfill cap remains in place

and continues to provide an adequate barrier for waste containment. There is no evidence ofand continues to provide an adequate barrier for waste containment. There is no evidence of aa cap breach and the existing use of the Site property is consistent with the objectives of thecap breach and the existing use of the Site property is consistent with the objectives of the

land use There is no evidence of Site arsenic contaminantlandfill cap andlandfill cap and land use restrictions.restrlcfions. There Is no evidence of Site arsenic contaminant migration above MCLs impacting drinking water.migration above MCLs impacting drinking water. However, In order for the remedy to beHowever, in order for the remedy to be protecfive In the long-term, the following actions need toto be taken to ensure long-termprotective in the long-term, the following actions need be taken to ensure long-term protectlveness: Implement additional effective ICs to ensure Site property and groundwaterprotectiveness: implement additional effective ICs to ensure Site property and groundwater protecfiveness; enforce compliance, maintain, and monitor the effecfive ICs; and Implementprotectiveness; enforce compliance, maintain, and monitor the effective ICs; and implement the ongoing O&M program.the ongoing O&M program.

V111vm

INTRODUCTION1.01.0 INTRODUCTION

The United States Environmental Protection Agency (EPA), in consultation with theThe United States Environmental Protection Agency (EPA), in consultation with the Michigan Department of Environmental Quality (MDEQ), has conducted year reviewMichigan Department of Environmental Quality (MDEQ), has conducted aa fivefive year review of the remedial actions Implemented at the Albion-Sheridan Landfill Superfund site inof the remedial actions implemented at the Albion-Sheridan Landfill Superfund site in Albion, Michigan. EPA conducted the review between September 2011 and August 2012.Albion, Michigan. EPA conducted the review between September 2011 and August 2012. This report documents the results of the year review. The purpose of year reviews IsThis report documents the results of the fivefive year review. The purpose of fivefive year reviews is to determine whether the remedy at site Is protective of human health and the environment.to determine whether the remedy at aa site is protective of human health and the environment. Five year review reports document the methods, and conclusions of the review, asFive year review reports document the methods, findings,findings, and conclusions of the review, as well as identifying Issues found during the review. If any, and making recommendations towell as identifying issues found during the review, if any, and making recommendations to address them.address them.

This review Is required by statute. EPA must Implement year reviews consistent withThis review is required by statute. EPA must implement fivefive year reviews consistent with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).the Comprehensive Environmental Response. Compensation, and Liability Act (CERCLA). as amended, and the National Oil and Hazardous Substances Pollution Contingency Planas amended, and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA §§ 121(c). as amended, states:(NCP). CERCLA 121(c). as amended, states:

If aa remedial action is selected that results in any hazardous substances, pollutants, orIf remedial action is selected that results in any hazardous substances, pollutants, or contaminants remaining at the site, the remedial action shall be reviewed no less oftencontaminants remaining at the site, the remedial action shall be reviewed no less often than each years after the initiation of such remedial action to assure that humanthan each fivefive years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action beinghealth and the environment are being protected by the remedial action being implemented.implemented.

The NCP (part 300.430(0(4)(11) of the Code of Federal Regulations (CFR)) states:The NCP (part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR» states:

]1' aa remedial action is selected that results in hazardous substances, pollutants, orIf remedial action is selected that results In hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use andcontaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often thanunrestricted exposure, the lead agency shall review such action no less often than every fivefive years after the initiation of the selected remedial action.every years after the initiation of the selected remedial action.

This is the third fivefive year review for the Albion-Sheridan Landfill Superfund Site. EPAThis is the third year review for the Albion-Sheridan Landfill Superfund Site. EPA completed the second fivefive year review report in August 2007.completed the second year review report In August 2007.

1

SITE CHRONOLOGY2.02.0 SITE CHRONOLOGY

Table 1. Chronology of Site EventsTable 1. Chronology of Site Events

DateDate EventEvent

Initial discovery of waste management problems at the Site by the EPAInitial discovery of waste management problems at the Site by the EPA19861986

Field Investigation TeamField Investigation Team EPA proposesproposes Albion-Sheridan Landfill Site for National Priorities ListEPA Alblon-Sherldan Landfill Site for National Priorities List

June 1988June 1988 (NPL)

October 1989 NPLNPL finalfinal listing for the Albion-Sheridan Landfill Site

(NPL)

October 1989 listing for the Alblon-Sherldan Landfill Site

19901990 Surface drum removal conductedSurface drum removal conducted

January 1992January 1992 Remedial Investigation/ Feasibility Study inlfiatedRemedial Investigation! Feasibility Study initiated

19951995 Remedial Investlgafion/ Feasibility Study completedRemedial Investigation! Feasibility Study completed

March 1995March 1995 Record of Decision (ROD) signedRecord of Decision (ROD) signed

December 1995December 1995 Remedial Design startedRemedial Design started

September 1997September 1997 Remedial Action startedRemedial Action started

July 1999July 1999 RD/RA Consent Decree enteredRD/RA Consent Decree entered

September 1999September 1999 Site remedy construction completionSite remedy construction completion

October 2000October 2000 Landfill erosion repair work completedLandfill erosion repair work completed

May 2001May 2001 Final inspection of landfill repair workFinal inspection of landfill repair work

June 2001June 2001 Addlfional gas probes and monitoring wells InstalledAdditional gas probes and monitoring wells installed

September 2002 First fivefive year review completedFirstSeptember 2002 year review completed

February 2005February 2005 Trend analysis for arsenic in groundwater begunTrend analysis for arsenic in groundwater begun

January 2006January 2006 Arsenic MCL is reduced to lOppbArsenic MeL is reduced to 10ppb

August 2007 Second fivefive year review completedAugust 2007 Second year review completed

3.0 BACKGROUND3.0 BACKGROUND

Physical Characteristics3.13.1 Physical Characteristics

The 50-acre Albion-Sheridan Landfill Superfund site (Site) includes an I8-acre closedThe 50-acre Albion-Sheridan Landfill Superftjnd site (Site) includes an 18-acre closed landfill located at 29975 East Erie Road, approximately one mile east of Albion, Michigan,landfill located at 29975 East Erie Road, approximately one mile east of Albion, Michigan, on the eastern edge of Calhoun County (See Figure 1). The city of Albion has populationon the eastern edge of Calhoun County (See Figure I). The city of Albion has aa population of approximately 10,000. The Site is enclosed by security fence, which also containsof approximately 10,000. The Site is enclosed by aa security fence, which also contains aa surface water runoff retenfion basin located on the western end and small wooded area insurface water runoff retention basin located on the western end and aa small wooded area in the north.the north.

2

Land and Resource Use3.23.2 Land and Resource Use

The Site is surrounded by aa combination of residential, agricultural, commercial,commercial, andThe Site is surrounded by combination of residential, agricultural, and industrial properties. Five residences are located approximately 1000 to 1500 feet southwestIndustrial properties. Five residences are located approximately 1000 to 1500 feet southwest of the landfill along East Erie Road. Several residences and commercial businesses areof the landfill along East Erie Road. Several residences and commercial businesses are located along Michigan Avenue about 500 feet north of the Site fence. Housinglocated along Michigan Avenue about 500 feet north of the Site fence. Housing developmentsdevelopments are located to the east and west of the Site, and undeveloped land formallyare located to the east and west of the Site, and undeveloped land formally used for agriculture is immediately west of the Site. An active railroad track borders Eastused for agriculture is immediately west of the Site. An active railroad track borders East Erie Road to the south of the landfill, and beyond the railroad tracks there is an extendedErie Road to the south of the landfill, and beyond the railroad tracks there is an extended wooded area that includes the North Branch of the Kalamazoo River. South of the river iswooded area that includes the North Branch of the Kalamazoo River. South of the river is agricultural land. The Site does not fall within the plain of the river.agricultural land. The Site does not fall within the floodflood plain of the river.

History of Contamination3.33.3 History of Contamination

The Albion-Sheridan Landfill Site had been used as aa sand and gravel pit and also for open,The Alblon-Sherldan Landfill Site had been used as sand and gravel pit and also for open, non-pem1itted dumping for an unspecified period of time prior to 1966. Gordon Stevicknon-permitted dumping for an unspecified period of time prior to 1966. Gordon Stevlck privately operated the landfill from 1966 to 1981. The landfill accepted municipal refuse andprivately operated the landfill from 1966 to 1981. The landfill accepted municipal refuse and industrial wastes from households and industries in the city of Albion and nearby townships.industrial wastes from households and industries in the city of Albion and nearby townships. In the early 1970s, the Michigan Department of Natural Resources (MDNR) approved theIn the early 1970s, the Michigan Department of Natural Resources (MDNR) approved the landfill to accept an estimated 6,000 cubic yards of metal plating sludges. Other materialslandfill to accept an estimated 6,000 cubic yards of metal plating sludges. Other materials such as paint wastes and thinners, oil and grease, casting sand and dustdust and sand and dirt containing ash were also disposed of at the Alblon-Sherldan Landfill. The landfill ceased such as paint wastes and thinners, oil and grease, casting sand and , and sand and dirt containing flyfly ash were also disposed of at the Albion-Sheridan Landfill. The landfill ceased operation in 1981.operation in 1981.

3.43.4 Initial ResponseInitial Response

In 1986, an EPA Field Investigation Team (FIT) contractor performed site screeningIn 1986, an EPA Field Investigation Team (FIT) contractor performed aa site screening inspection to obtain data for EPA to score the Site under the Hazardous Ranking Systeminspection to obtain data for EPA to score the Site under the Hazardous Ranking System (HRS). Based on the HRS score, EPA proposed that the Site be Included on the National(HRS). Based on the HRS score, EPA proposed that the Site be included on the National Priorities List (NPL) in 1988, and In 1989 Alblon-Sherldan Landfill site was officially placedPriorities List (NPL) in 1988, and in 1989 Albion-Sheridan Landfill site was officially placed on the NPL. During 1988 and 1989, an EPA technical team observed surface debris on theon the NPL. During 1988 and 1989, an EPA technical team observed surface debris on the landfill, including drums which appeared to contain grease and paint waste. Some of thelandfill, including drums which appeared to contain grease and paint waste. Some of the waste was classified as RCRA hazardous waste, which was characteristic for toxicity andwaste was classified as RCRA hazardous waste, which was characteristic for toxicity and ignitability. Certain waste samples contained volatile organic compounds (VOC) Includingignitability. Certain waste samples contained volatile organic compounds (YOC) including ethylbenzene, toluene, tetrachloroethylene, 1,1,1-trlchloroethane and xylene.ethylbenzene, toluene, tetrachloroethylene, 1,1, I-trichloroethane and xylene.

On March 19, 1990, EPA issued Unilateral Administrative Order (UAO) to potentiallyOn March 19, 1990, EPA issued aa Unilateral Administrative Order (UAO) to fivefive potentially responsible parties (PRPs) directing that removal action be taken at the Site. The UAOresponsible parties (PRPs) directing that aa removal action be taken at the Site. The UAO waswas amended on May 3, 1990, to delete one of the PRPs. Two of the PRPs performed time­amended on May 3,1990, to delete one of the PRPs. Two of the PRPs perfom1ed aa time­critical removal of an estimated 46 drums from the landfill surface later in 1990. Twenty­critical removal of an estimated 46 drums from the landfill surface later in 1990. Twenty­two drums were overpacked and sent to an off-site facility for incineration. The remainingtwo drums were overpacked and sent to an off-site facility for incineration. The remaining 24 drums were crushed and sent to Type Solid Waste Landfill in Michigan.24 drums were crushed and sent to aa Type 22 Solid Waste Landfill in Michigan.

3.53.5 Basis for Taking ActionBasis for Taking Action

EPA began remedial planning as the Site was proposed for the NPL on June 24, 1988. TheEPA began remedial planning as the Site was proposed for the NPL on June 24, 1988. The Site was listed on the NPL on October 4. 1989.Site was listed on the NPL on October 4, 1989.

3

AA remedial investigation (RI) was carried out from January 1992 to April 1994. The majorremedial invesfigation (RI) was carried out from January 1992 to April 1994. The major results of the RI and the conditions at the Site at that time found that soil and groundwatergroundwaterresults of the RJ and the conditions at the Site at that time found that soil and were exposure routes which included the following:were exposure routes which Included the following:

•• The thicknessThe thickness ofof the existing landfill cover was between 11 and 4 feet.the existing landfill cover was between and 4 feet. The minimumThe minimum cover thickness for closed landfill in the state of Michigan required at least feet.cover thickness for aa closed landfill in the state of Michigan required at least 22 feet.

Refuse material was found scattered on the ground surface throughout the area of the•• Refuse material was found scattered on the ground surface throughout the area of the landfill. The cover had undergone significant revegetation since landfilling hadlandfill. The cover had undergone significant revegetatlon since landfilllng had stopped, consisting mainly of grass with some patches of small trees. The thicknessstopped, conslsfing mainly of grass with some patches of small trees. The thickness of the fillfill material in the landfill ranged from 16 to 35 feet.of the material in the landfill ranged from 16 to 35 feet.

The geology of the Site was characterized by approximately 20 to 54 feet of glacial•• The geology of the Site was characterized by approximately 20 to 54 feet of glacial sediments overlying sedimentary bedrock. There were no obvious clay confiningsediments overlying sedimentary bedrock. There were no obvious clay confining layers beneath the Site, although discontinuous layers containing silt and/or clay didlayers beneath the Site, although discontinuous layers containing silt and/or clay did exist, creating an unconsolidated sediment aquifer. The uppermost bedrock beneathexist, creating an unconsolidated sediment aquifer. The uppermost bedrock beneath the Site was generally encountered at an approximate elevation of 935 to 925 meanthe Site was generally encountered at an approximate elevation of 935 to 925 mean sea level (MSL).sea level (MSL).

•• Groundwater beneath the Site was contained within the unconsolidated sedimentGroundwater beneath the Site was contained within the unconsolidated sediment aquifer, which was encountered at depths of 10 to 30 feet below ground surface, andaquifer, which was encountered at depths of 10 to 30 feet below ground surface, and the bedrock aquifer. The direction of groundwater in the unconsolidated unitthe bedrock aquifer. The direction of groundwater flowflow in the unconsolidated unit was west-southwest near the landfill and curved in more southerly direction near thewas west-southwest near the landfill and curved in aa more southerly direction near the North Branch of the Kalamazoo River.North Branch of the Kalamazoo River.

•• Several VOCs, SVOCs, and pesticldes/PCBs were present in landfill waste samples,Several VOCs, SVOCs, and pesticides/PCBs were present in landfill waste samples, although many of them were found in estimated concentrations below the detectionalthough many of them were found in estimated concentrations below the detection limit. 4-methyl phenol was the most concentrated contaminant at 15 mg/kg.limit. 4-methyl phenol was the most concentrated contaminant at 15 mg/kg. AA number of inorganic substances were present above background soil levels Includingnumber of inorganic substances were present above background soil levels including antimony, arsenic, chromium, copper, lead, mercury, and zinc. The highest levelsantimony, arsenic, chromium, copper, lead, mercury, and zinc. The highest levels Included lead at 208 mg/kg, arsenic at 13 mg/kg, and chromium at 13 mg/kg.included lead at 208 mg/kg, arsenic at 13 mg/kg, and chromium at 13 mg/kg.

Test pitting revealed one area of the landfill which contained large number of•• Test pitting revealed one area of the landfill which contained aa large number of drums. Sampling results showed some of the drums contained liquids, solids anddrums. Sampling results showed some of the drums contained liquids, solids and suspected paint sludges; contaminant concentrations included levels up to 730,000suspected paint sludges; contaminant concentrations included levels up to 730,000 ppm 1,2,4-trlmethyl benzene, 6500 ppm acetone, 2400 ppm aluminum, and ppmppm 1,2A-trimethyl benzene, 6500 ppm acetone, 2400 ppm aluminum, and 33 ppm arsenic.arsemc.

•• Groundwater samples taken at 13 monitoring wells surrounding the landfill revealedGroundwater samples taken at 13 monitoring wells surrounding the landfill revealed only one organic compound above the MCL, 1.2-dlbromo-3-chloropropane. Noonly one organic compound above the MCL, 1,2-dibromo-3-chloropropane. No SVOCs were detected above background concentrations. Arsenic, ammonia-SVOCs were detected above background concentrations. Arsenic, ammonia­nitrogen, cobalt, iron, manganese, and nitrate/nitrite were detected above background,nitrogen, cobalt, iron, manganese, and nitrate/nitrite were detected above background, and antimony and nitrate exceeded established MCLs at two well locations.and antimony and nitrate exceeded established MCLs at two well locations.

EPA and MDNR prepared ROD in March of 1995 which outlined the elements ofEPA and MDNR prepared aa ROD in March of 1995 which outlined the elements ofaa comprehensive remedy at the Site (see next section).comprehensive remedy at the Site (see next section).

4

4.04.0 REMEDIAL ACTIONSREMEDIAL ACTIONS

Remedy Selection4.14.1 Remedy Selection

The major components of the Alblon-Sherldan Landfill Site remedy Involved implementationThe major components of the Albion-Sheridan landfill Site remedy involved implementation of the following:of the following:

•• Removal, off-site treatment, and disposal of the drums which contained hazardous orRemoval, off-site treatment, and disposal of the drums which contained hazardous or liquid wastes, as well as other drums encountered during grading of the landfillliquid wastes, as well as other drums encountered during grading of the landfill surface;surface;

•• Construcfion of solid waste landfill cover which made use of Flexible MembraneConstruction of aa solid waste landfill cover which made use of aa Flexible Membrane liner (FMl) over the entire landfill mass;Liner (FML) over the entire landfill mass;

Design studies to determine if passive venting or active landfill gas collection•• Design studies to detem1ine if aa passive venting or active landfill gas collection system should be installed at the Site;system should be installed at the Site;

Monitoring of groundwater to ensure effectiveness of the remedial action in lowering•• Monitoring of groundwater to ensure effectiveness of the remedial action in lowering the arsenic concentration in groundwater through natural oxidation; andthe arsenic concentration in groundwater through natural oxidation; and

•• Institutional controls on landfill property to limit both land and groundwater use, andInstitutional controls on landfill property to limit both land and groundwater use, and controls on adjacent property to limit groundwater use until the clean-up standard iscontrols on adjacent property to limit groundwater use until the clean-up standard is attained.attained.

Remedial action objectives of the selected remedy are to reduce the risks associated withRemedial action objectives of the selected remedy are to reduce the risks associated with exposure to the contaminated materials on-Slte; to eliminate or reduce migration ofexposure to the contaminated materials on-Site; to eliminate or reduce migration of contaminants to the groundwater, and to reduce the risks associated with arseniccontaminants to the groundwater, and to reduce the risks associated with arsenic contamination in the groundwater. The landfill cap will reduce the direct contact andcontamination in the groundwater. The landfill cap will reduce the direct contact and groundwater leachate risks due to the soils contained under the cap. Groundwater monitoringgroundwater leachate risks due to the soils contained under the cap. Groundwater monitoring during the remedy will determine progress toward the goal of achieving MCLs for theduring the remedy will detem1ine progress toward the goal of achieving MCls for the groundwater contaminant plume created by dumping at the landfill.groundwater contaminant plume created by dumping at the landfill.

The ROD also allowed for aa contingent remedy, in situ oxidation of groundwater, forThe ROD also allowed for contingent remedy, in situ oxidation of groundwater, for groundwater treatment if residential wells became at risk of being contaminated, or if arsenicgroundwater treatment if residential wells became at risk of being contaminated, or if arsenic contamination in groundwater did not decline at specified rates years after landfill capcontamination in groundwater did not decline at specified rates fivefive years after landfill cap installation.Installafion.

The contingent remedy was based on meeting aa trend analysis evaluation to be performed onThe contingent remedy was based on meeting trend analysis evaluation to be performed on arsenic concentrations in the monitoring wells fivefive years from the completion of thearsenic concentrations in the monitoring wells years from the completion of the construction of the landfill cap. The statistical test was designed to determine if arsenic wasconstruction of the landfill cap. The statisfical test was designed to determine if arsenic was declining sufficiently to fall below the MCl (previously 50 ppb) within 15 years. Thisdeclining sufficiently to fall below the MCL (previously 50 ppb) within 15 years. This statistical test was completed in the Hull && Associates February 2005 Annual Report onstatistical test was completed in the Hull Associates February 2005 Annual Report on groundwater quality, and confirmed that the historic fivefive year arsenic data and future trendgroundwater quality, and confirmed that the historic year arsenic data and future trend supported the current remedy of natural oxidation of arsenic in groundwater. Since thesupported the current remedy of natural oxidation of arsenic In groundwater. Since the revised 10 ppb MCL for arsenic became finalfinal in 2006, the multi-year trend analysis forrevised 10 ppb MCL for arsenic became In 2006, the multi-year trend analysis for arsenic in groundwater was adjusted accordingly to confirm the effectiveness of the currentarsenic in groundwater was adjusted accordingly to confirm the effectiveness of the current remedy of natural oxidation of arsenic in groundwater. The most recent monitoring resultsremedy of natural oxidation of arsenic in groundwater. The most recent monitoring results

5

based on the March 2012 Site Annual Report contim1 that the trend ofarsenicarsenic levels inbased on the March 2012 Site Annual Report confirm that the trend of levels in groundwater continue to decline in order to meet the 10 ppb clean-up standard and arsenic isgroundwater continue to decline in order to meet the 10 ppb clean-up standard and arsenic is not migrating off-site above the MCL.not migrating off-site above the MCL.

Remedy Implementation4.24.2 Remedy Implementation

EPA issued Special Notice Letters on June 6, 1995, to the private party PRPs associated withEPA Issued Special Notice Letters on June 6, 1995, to the private party PRPs associated with the Site. Four PRPs were offered the opportunity to undertake the remedial design andthe Site. Four PRPs were offered the opportunity to undertake the remedial design and remedial action (RD/RA) during negotiations in the summer of 1995. Negotiations failed;remedial action (RD/RA) during negotlafions in the summer of 1995. Negotiations failed; therefore, EPA issued aa UAG to the four PRPs requiring them to conduct the RD/RA. Twotherefore, EPA Issued UAO to the four PRPs requiring them to conduct the RD/RA. Two of the PRPs, Cooper Industries and Coming, Inc. (hereinafter "RD/RA PRPs") complied withof the PRPs, Cooper Industries and Coming, Inc. (hereinafter "RD/RA PRPs") complied with the UAG.the UAO.

The RD/RA PRPs received approval from EPA for aa RD Work Plan in August 1996. TheyThe RD/RA PRPs received approval from EPA for RD Work Plan in August 1996. They completed the RD for the Site in August 1997 and EPA approved the RA Work Plan incompleted the RD for the Site in August 1997 and EPA approved the RA Work Plan In September 1997.September 1997.

From 1998 through September 1999, the PRPs conducted the construction activities for theFrom 1998 through September 1999, the PRPs conducted the construction activities for the RA at the Site, including excavating and disposing of located drums, installing andRA at the Site, including excavafing and disposing of located drums, installing and abandoning monitoring wells, and removing an on-site underground storage tank. The off­abandoning monitoring wells, and removing an on-site underground storage tank. The otT­site disposal of the drums was completed in December 1998. In 1999, the PRPs installedsite disposal of the drums was completed in December 1998. In 1999, the PRPs installed aa permanent Site perimeter fence and constructed the new landfill cover. Components of thepermanent Site perimeter fence and constructed the new landfill cover. Components of the muUl-layer landfill Included:multi-layer landfill included:

•• Fill Layer: The layer consists of six inches of graded cover placed over theFill Layer: The fillfill layer consists of six inches of graded cover fillfill placed over the landfill waste;landfill waste;

Gas Collection Layer: This layer consists of 12-inch thick sand layer on top of the•• Gas Collection Layer: This layer consists of aa 12-inch thick sand layer on top of the existing waste mass and fillfill layer for passive gas collection;existing waste mass and layer for passive gas collecfion;

Flexible Membrane Liner (FML): The FML consists of layer of linear low density•• Flexible Membrane Liner (FML): The FML consists of aa layer of linear low density polyethylene (LLDPE). Textured FML was placed along the south end of the landfillpolyethylene (LLDPE). Textured FML was placed along the south end of the landfill with the steepest slope, and smooth FML was placed over the remaining portion ofwith the steepest slope, and smooth FML was placed over the remaining portion of the landfill.the landfill. The FML were joined by fusion weld;The FML panelspanels were joined by aa fusion weld;

•• Drainage Layer: geocomposlte drainage net, which consists of layer of geonetDrainage Layer: AA geocomposite drainage net, which consists of aa layer of geonet between layers of geotexfile, was Installed on top of the FML;between layers of geotextile, was installed on top of the FML;

•• Cover Soil Layer: An 18-inch thick cover soil layer was installed over the entireCover Soil Layer: An 18-inch thick cover soil layer was installed over the entire landfill cap. There was no compaction requirement for the cover soil layer;landfill cap. There was no compaction requirement for the cover soil layer;

Topsoil Layer: minimum of six Inches of top soil was installed over the cover soil•• Topsoil Layer: AA minimum of six inches of top soil was installed over the cover soil layer and fertilized; andlayer and fertilized; and

Vegetative Cover: Native plant species seeding was used to establish vegetafive• Vegetative Cover: Native plant species seeding was used to establish aa vegetative cover to control erosion.cover to control erosion.

6

An RD/RA Consent Decree (CD) was finalizedfinalized and entered in U.S. District Court in JulyAn RD/RA Consent Decree (CD) was and entered in U.S. District Court in July 1999. The RD/RA CD brought in the Decker Corp. and the city of Albion to join with the1999. The RD/RA CD brought in the Decker Corp. and the city of Albion to join with the RD/RA PRPs. The CD required Decker Corp. and the city of Albion (hereinafter "O&MRD/RA PRPs. The CD required Decker Corp. and the city of Albion (hereinafter "O&M PRPs") to implement all operation and maintenance activities at the Site, while the RD/RAPRPs"') to Implement all operation and maintenance activities at the Site, while the RD/RA PRPs were responsible for the RD and RA construction work.PRPs were responsible for the RD and RA construction work.

RA construction activities officially concluded with the completion ofaa Site inspection onRA construcfion acfivltles officially concluded with the completion of Site inspection on September 7, 1999 and signing of the Preliminary Closeout Report for the Albion-SheridanSeptember 7, 1999 and signing of the Preliminary Closeout Report for the Albion-Sheridan Landfill site on September 28, 1999.Landfill site on September 28, 1999.

Institutional Controls4.34.3 Institutional Controls

ICs are non-engineered instruments, such as administrative and legal controls, that help toICs are non-engineered Instruments, such as administrative and legal controls, that help to minimize the potential for exposure to contamination and that protect the integrity of theminimize the potential for exposure to contamination and that protect the integrity of the remedy. ICs are required to assure the long-term protectiveness for any areas which do notremedy. ICs are required to assure the long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure (UU/UE). ICs are required by the 1995allow for unlimited use or unrestricted exposure (UUIUE). ICs are required by the 1995 ROD to restrict land and groundwater use and protect the Integrity of the Site remedialROD to restrict land and groundwater use and protect the integrity of the Site remedial action. An IC evaluafion study was completed in April 2007 to outline the required ICs foraction. An IC evaluation study was completed in April 2007 to outline the required ICs for the Site. Since that time, the trend of arsenic levels in groundwater has continued to decreasethe Site. Since that time, the trend of arsenic levels in groundwater has continued to decrease toward meeting the 10 ppb MCL clean-up standard as documented in the March 2012 Annualtoward meeting the 10 ppb MCL clean-up standard as documented in the March 2012 Annual Report. In addition. Site property parcels previously referenced as owned by the state ofReport. In addition, Site property parcels previously referenced as owned by the state of Michigan are now known to be owned by Calhoun County. Quit Claim Deed referencingMichigan are now known to be owned by Calhoun County. AA Quit Claim Deed referencing Calhoun County ownership was recorded on January 14, 2011.Calhoun County ownership was recorded on January 14, 2011.

The areas listed below in Table require ICs in order to protect the integrity of the remedy.The areas listed below in Table 22 require ICs in order to protect the integrity of the remedy.

Table 2. Institutional Controls Summary TableTable 2. Institutional Controls Summary Table

Media, EngineeredMedia, Engineered Controls Areas thatControls && Areas that ICIC IC Instrument ImplementedIC Instrument Implemented oror

Do Not Support UU/UE onDo Not Support UUIUE on ObjectiveObjective plannedplanned Current ConditionsCurrent Conditions

Site / Site area (~50Site boundaryboundaryI Site area (~50 Prohibits use of landfillProhibits use of landfill Declaration of RestricfiveDeclaration of Restrictive acres): On site soil mulfi­acres): On site soil multi­ cap land, groundwatercap land, groundwater Covenant recorded (liber-2136,Covenant recorded (liber-2136, media landfill cap andmedia landfill cap and underlying Site, andunderlying Site, and page-992) at Calhoun Countypage-992) at Calhoun County adjacent stormwater retenfionadjacent stormwater retention assures integrity ofassures integrity of recorder'sofficeon June 21 1999,recorder's office on June 21 1999, basin. Property owned bybasin. Property owned by landfill and other RAlandfill and other RA pursuant to Michigan Code R.pursuant to Michigan Code R. CDC Associates.CDC Associates. components.components. 299.610(e).299.610 (e).

Site boundary/ Site area (-50Site boundaryl Site area (~50 Prohibits use of landfillProhibits use of landfill Planned restriction in the form ofPlanned restriction in the form of acres): On site soil multi­acres): On site soil multi­ cap land, groundwatercap land, groundwater restrictive covenant(s) to berestrictive covenant(s) to be media landfill cap andmedia landfill cap and underiylng Site, andunderlying Site, and developed, with input from thedeveloped, with input from the adjacent stormwater retentionadjacent stormwater retention assures integrity ofassures integrity of state of Michigan,state of Michigan, basin. Property owned bybasin. Property owned by landfill and other RAlandfill and other RA Calhoun County.Calhoun County. components.components.

7

Table 2. Institutional Controls Summary TableTable 2. Institutional Controls Summary Table

Media, EngineeredMedia, Engineered Controls Areas thatControls && Areas that ICIC IC Instrument ImplementedIC Instrument Implemented oror

Do Not Support UU/UE onDo Not Support UUIUE on ObjectiveObjective plannedplanned Current ConditionsCurrent Conditions

Site boundary/ Site area (-50Site boundary/ Site area (~50 Prohibits use of land,Prohibits use of land, Declaration of RestrictiveDeclaration of Restrictive acres): Groundwateracres): Groundwater groundwatergroundwater Covenant recorded (llber-2136,Covenant recorded (liber-2136, underiylng on-site area.underlying on-site area. underlying Site, andunderlying Site, and page-992) at Calhoun Countypage-992) at Calhoun County Property owned by CDCProperty owned by CDC assures integrity ofassures integrity of recorder's office on June 21 1999,recorder's office on June 21 1999, Associates.Associates. landfill and other RAlandfill and other RA pursuant to Michigan Code R.pursuant to Michigan Code R.

components.components. 299.610(e).299.610 (e). Site boundary/ Site area (-50Site boundary/ Site area (~50 Prohibits use of land,Prohibits use of land, Planned restriction in the form ofPlanned restriction in the form of acres): Groundwateracres): Groundwater groundwatergroundwater restrictive covenant(s), with inputrestrictive covenant(s), with input underlying on-site area.underlying on-site area. underlying Site, andunderlying Site, and from the state of Michigan.from the state of Michigan. Property owned by CalhounProperty owned by Calhoun assures Integrity ofassures integrity of County.County. landfill and other RAlandfill and other RA

components.components.

Figures 11 and 2 attached to this document outline the Site location and associated ICs. TheFigures and 2 attached to this document outline the Site location and associated ICs. The maps also show the property owners for the various land parcels in the vicinity of the Site.maps also show the property owners for the various land parcels in the vicinity of the Site.

CURRENT AND PLANNED INSTITUTIONAL CONTROLSCURRENT AND PLANNED INSTITUTIONAL CONTROLS

AA Declaration of RestrictiveSite Institutional Controls Currently Implemented:Site Institutional Controls Currently Implemented: Declaration of Restrictive Covenant was recorded (liber-2136, page-992) at the Calhoun County Recorder's Office onCovenant was recorded (liber-2136, page-992) at the Calhoun County Recorder's Office on June 21, 1999, pursuant to Michigan Code R. 299.610 (e) on three parcels owned by CDCJune 21,1999, pursuant to Michigan Code R. 299.610 (e) on three parcels owned by CDC Associates covering portions of the Site landfill cap property and adjacent stormwaterAssociates covering portions of the Site landfill cap property and adjacent stormwater retention basin.retention basin. Restrictions on the parcels owned by CDC Associates include that thereRestrictions on the parcels owned by CDC Associates include that there shall be no use of the groundwater underiylng the Property; no residential, commercial orshall be no use of the groundwater underlying the Property; no residential, commercial or agricultural use of the landfill cap property; no tampering with, development on, or removalagricultural use of the landfill cap property; no tampering with, development on, or removal of, the contaminant or monitoring systems that remain on the Property; and no use of, orof: the contaminant or monitoring systems that remain on the Property; and no use of. or activity at, the Property that may Interfere with, damage, or otherwise impair theactivity at, the Property that may interfere with, damage, or otherwise impair the effectiveness of any response action (or component thereof) selected and/or undertaken byeffectiveness of any response action (or component thereot) selected and/or undertaken by EPA, or any party acting as representative for EPA (See Figure 2).EPA, or any party acting as representative for EPA (See Figure 2).

Institutional Controls Planned: Institutional Controls in the form of restrictive covenant(s)Institutional Controls Planned: Instltufional Controls in the form of restrictive covenant(s) are planned for the Site landfill parcels owned by Calhoun County. These additional ICs willare planned for the Site landfill parcels owned by Calhoun County. These additional ICs will assure that all property on the Site is properly restricted, that the use of groundwaterassure that all property on the Site is properly restricted, that the use of groundwater underlying the Site is properly restricted, and that the remedy is protected over the long-term.underiylng the Site is properly restricted, and that the remedy is protected over the long-term.

CURRENT COMPLIANCECURRENT COMPLIANCE

Based on the Site inspection conducted by EPA and MDEQ in October 2011, complianceBased on the Site Inspection conducted by EPA and MDEQ In October 2011, compliance with the existing implemented use restrictions was observed. The Ie currently implementedwith the exisfing implemented use restrictions was observed. The IC currently implemented at the Site on the three parcels owned by CDC Associates was reviewed by EPA Regionalat the Site on the three parcels owned by CDC Associates was reviewed by EPA Regional Counsel and the Michigan Attorney General's Office in 2012 and found to be in compliance.Counsel and the Michigan Attorney General's Office in 2012 and found to be in compliance.

8

The additional plamied ICs listed are needed so that the Site remedy can remain protective inThe additional planned ICs listed are needed so that the Site remedy can remain protective in the long-term. No Site uses inconsistent with the intended uses and restrictions as depicted inthe long-term. No Site uses inconsistent with the intended uses and restrictions as depicted in the implemented ICs were observed noting that plmmed ICs for Site parcels owned bythe Implemented ICs were observed noting that planned ICs for Site parcels owned by Calhoun County are needed. Furthermore, there was no evidence of impairments of theCalhoun County are needed. Furthermore, there was no evidence of impairments of the remedial action components at the Site.remedial action components at the Site.

4.44.4 System Operations/Operation and Maintenance (0«&M)System Operations/Operation and Maintenance (O&M)

EPA and MDEQ had concerns over erosion at the landfill, which had become evident soonEPA and MDEQ had concerns over erosion at the landfill, which had become evident soon after RD/RA PRPs completed construction in September 1999. During Site Inspections inafter RD/RA PRPs completed construction in September 1999. During Site inspections in January, February, and April 2000. EPA and MDEQ documented significant landfill slopeJanuary, February, and April 2000, EPA and MDEQ documented significant landfill slope and drainage basin erosion at aa number of locations. Vegetation had not been established atand drainage basin erosion at number of locations. Vegetation had not been established at numerous areas and the liner was exposed at certain spots on the slope. EPA sent aa commentnumerous areas and the liner was exposed at certain spots on the slope. EPA sent comment letter to the RD/RA PRP contractor in April 2000 outlining the deficiencies in the landfillletter to the RD/RA PRP contractor in April 2000 outlining the deficiencies in the landfill cover.cover.

issued letter in June 2000 stating that the PRP group was out of compliance with theEPEPAA issued aa letter in June 2000 stating that the PRP group was out of compliance with the terms of the RD/RA CD, due to their failure to adequately respond to the April 2000terms of the RD/RA CD, due to their failure to adequately respond to the April 2000 comment letter. In July 2000, the PRP group issued response letter to EPA, agreeing tocomment letter. In July 2000, the PRP group issued aa response letter to EPA, agreeing to provide work plan to address the Site erosion concerns. The work plan was approved inprovide aa work plan to address the Site erosion concerns. The work plan was approved in September 2000, with the landfill erosion repair work taking place in September and OctoberSeptember 2000, with the landfill erosion repair work taking place in September and October of that year. inspecfion of the landfill repair work took place during May 2001.of that year. AA finalfinal inspection of the landfill repair work took place during May 2001.

Monitoring of the groundwater and gas probes as approved in the Site Operation &&Monitoring of the groundwater and gas probes as approved in the Site Operation Maintenance (O&M) Plan began in October 1999. Two additional groundwater monitoringMaintenance (O&M) Plan began in October 1999. Two additional groundwater monitoring wells were added to the O&M program in 1 over concern of proper coverage ofwells were added to the O&M program in 200200 lover concern of proper coverage of groundwater on the western side of the landfill. Although some quarterly groundwatergroundwater flowflow on the western side of the landfill. Although some quarterly groundwater monitoring occurred initially, annual monitoring was approved in the O&M plan and occursmonitoring occurred initially, annual monitoring was approved in the O&M plan and occurs to date at the Site.to date at the Site.

Two additional perimeter fence line gas probes were constructed in June 2001, after elevatedTwo additional perimeter fence line gas probes were constructed in June 200 I, after elevated gas levels were recorded along the eastern fence line on two consecutive quarterly samplinggas levels were recorded along the eastern fence line on two consecutive quarterly sampling events ending in July 2000. Elevated landfill gas levels did not occur after the July 2000events ending in July 2000. Elevated landfill gas levels did not occur after the July 2000 sampling event. The O&M Plan stated that after eight consecutive samples indicating thesampling event. The O&M Plan stated that after eight consecutive samples indicating the absence of aa concern of elevated gases, the perimeter gas probe sampling program could end.absence of concern of elevated gases, the perimeter gas probe sampling program could end. As aa result of no landfill gas detections occurring at the seven gas probes during 20020011 andAs result of no landfill gas detections occurring at the seven gas probes during and 2002, the perimeter fence line monitoring was discontinued at the end of 2002.2002, the perimeter fence line monitoring was discontinued at the end of 2002.

AA fivefive year summary of the arsenic groundwater monitoring data and trend analysis wasyear summary of the arsenic groundwater monitoring data and trend analysis was completed by Hull Associates for the Albion Site O&M, and was Included in thecompleted by Hull && Associates for the Albion Site 0 & M, and was included in the February 2005 Annual Report on Groundwater Quality. The Informafion is located inFebruary 2005 Annual Report on Groundwater Quality. The information is located in Section 2.3, Appendix and Appendix D of the report. The arsenic data summary and trendSection 2.3, Appendix CC and Appendix 0 of the report. The arsenic data summary and trend analysis tables are contained in all subsequent O&M annual reports and confirm thatanalysis tables are contained in all subsequent O&M annual reports and confirn1 that aa ongoing decrease in arsenic levels in groundwater is taking place at the Site. The O&Mongoing decrease in arsenic levels in groundwater is taking place at the Site. The O&M report also began Including section on ICs in 2008.report also began including aa section on ICs in 2008.

9

Annual O&M oversight cost estimates for the Site are estimated to be approximatelyAnnual O&M oversight cost estimates for the Site are estimated to be approximately $30,000. Table lists O&M cost esfimates for 2009 thru 2011, which include sampling, lab$30,000. Table 33 lists O&M cost estimates for 2009 thru 2011, which include sampling, lab analysis, reporting, routine ongoing Site maintenance, and inspections:analysis, reporting, routine ongoing Site maintenance, and inspections:

Table 3. Annual System Operations! O&M CostsTable 3. Annual System Operations/ O&M Costs DatesDates Total Cost EstimateTotal Cost Estimate

From ToFrom To Jan. 1,2009Jan. 1,2009 Dec. 31,2009Dec. 31, 2009 Jan.Jan. 1,20101,2010 Dec. 31,2010Dec. 3L 2010 Jan.Jan. L1,20112011 Dec. 31,2011Dec. 31. 2011

5.05.0 PROGRESS SINCE LAST FIVE YEAR REVIEWPROGRESS SINCE LAST FIVE YEAR REVIEW

This is the third year review for the Site. EPA completed the first five year review inThis is the third fivefive year review for the Site. EPA completed the first five year review in September 2002 and the second in August 2007. The 2007 review found theSeptember 2002 and the second in August 2007. The 2007 five-yearfive-year review found the remedy to be protective in the short-term. There was no evidence of cap breach and theremedy to be protective in the short-term. There was no evidence of aa cap breach and the existing use of the Alblon-Sherldan Landfill Site property was consistent with the objectivesexisting use of the Albion-Sheridan Landfill Site property was consistent with the objectives of the landfill cap and land use restrictions. The groundwater remedy was also protective ofof the landfill cap and land use restrictions. The groundwater remedy was also protective of human health in the short-term because there was no evidence of groundwater use in the areahuman health in the short-term because there was no evidence of groundwater use in the area of the plume above the 10 ppb arsenic MCL, based on current and historic sampling of Siteof the plume above the 10 ppb arsenic MCL. based on current and historic sampling of Site monitoring and residential groundwater wells. Long term protectlveness would requiremonitoring and residential groundwater wells. Long term protectiveness would require compliance with land and groundwater use restrictions that prohibit Interference with thecompliance with land and groundwater use restrictions that prohibit interference with the solid waste cap; prohibit residential, commercial or any other use that would allow thesolid waste cap; prohibit residential. commercial or any other use that would allow the continued presence of human exposure, and restrict use of groundwater until groundwatercontinued presence of human exposure, and restrict use of groundwater until groundwater cleanup standards are achieved throughout the plume area.cleanup standards are achieved throughout the plume area.

The 2007 year review also made the following recommendations to issues noted at theThe 2007 fivefive year review also made the following recommendations to issues noted at the Site:Site:

## IssuesIssues

1I ArsenicArsenic groundwatergroundwater trend ICtrend && IC analysisanalysis

22 ArsenicArsenic plume southplume south of Siteof Site

33 Exisfing SiteExisting Site declaration ofdeclaration of restrictionsrestrictions

44 Labels onLabels on monitoringmonitoring wellswells

$30,000$30,000 $30,000$30,000 $30,000$30,000

Table 4: Actions Taken Since the Last Five Year ReviewTable 4: Actions Taken Since the Last Five Year Review

Recommendations/Recommendations/ Follow-up ActionsFollow-UD Actions

multi-yearNewNew multi-year analysis based on newanalysis based on new data ICsdata && ICs

ICs for propertyIes for 22 property ownersowners

Analyze and ifAnalyze and updateupdate if needed for landneeded for land owned by Michiganowned by Michigan && CDC Associates.CDC Associates. Be sure labels are onBe sure labels are on all monitoring wells.all monitoring wells.

PartyParty ResponsibleResDonsible Albion PRPsAlbion PRPs

Albion PRPsAlbion PRPs

Albion PRPsAlbion PRPs

Albion PRPsAlbion PRPs

MilestoneMilestone DateDate April 2008April 2008

April 2008April 2008

April 2008April 2008

SeptemberSeptember 20082008

Action TakenAction Taken and Outcomeand Outcome Ongoing annualOngoing annual analysis findsfindsanalysis decreasingdecreasing arsenic levelsarsenic levels ICs not neededICs not needed now as arsenicnow as arsenic plume decreasedplume decreased ICs still neededICs still needed on propertyon property owned byowned by Calhoun CountyCalhoun County Monitoring wellsMonitoring wells inspected duringinspected during annual sampling.annual sampling.

Date ofDate of ActionAction ongomgongoing

20122012 annualannual

ongomgongoing

20122012 annualannual

1010

Actions taken at the Site after the 2007 recommendations:Actions taken at the Site after the 2007 recommendations:

1) The arsenic trend analysis for groundwater is updated annually in the O&M progress1) The arsenic trend analysis for groundwater is updated annually in the O&M progress reports. The trend over the last fivefive years has found arsenic levels decreasing to below the 10reports. The trend over the last years has found arsenic levels decreasing to below the 10 ppb MCL at all but one isolated monitoring well location within the Site landfill propertyppb MCL at all but one Isolated monitoring well locafion within the Site landfill property boundary. One off-site monitoring well location on the Norfolk && Southern Railway right-ofright-ofboundary. One off-site monitoring well location on the Norfolk Southern Railway way remains above the 10 ppb MCL (61 ppb, 58 ppb, and 61 ppb over the last three years).way remains above the 10 ppb MCL (61 ppb, 58 ppb, and 61 ppb over the last three years).

2) With the decrease in arsenic levels in the groundwater at the Site, it has been discussed2) With the decrease in arsenic levels in the groundwater at the Site, it has been discussed and determined that Site ICs would not be appropriate at this time for the two off-siteand determined that Site ICs would not be appropriate at this fime for the two off-site property owners referenced in the 2007 year review. The groundwater will continue toproperty owners referenced in the 2007 fivefive year review. The groundwater will continue to be monitored during the next fivefive years to see if the trend of reduced arsenic levels remainsbe monitored during the next years to see if the trend of reduced arsenic levels remains at the Site.at the Site.

3) ICs are still required for the on-site property owners. The restrictive covenant IC3) ICs are still required for the on-site property owners. The restrictive covenant IC covering the Site parcels owned by CDC Associates was reviewed by the EPA Regionalcovering the Site parcels owned by CDC Associates was reviewed by the EPA Regional Counsel office and the Michigan Attorney General office in 2012 and found to be aa validCounsel office and the Michigan Attorney General office in 2012 and found to be valid document. The Site property parcels referred to as being owned by the state of Michigandocument. The Site property parcels referred to as being owned by the state of Michigan have been reviewed to detern1ine ownership by Calhoun County. These parcels still requirehave been reviewed to determine ownership by Calhoun County. These parcels still require restrictive covenant ICs.restrictive covenant ICs.

4) Monitoring wells are Inspected during the annual Site monitoring program to detennlne if4) Monitoring wells are inspected during the annual Site monitoring program to detennine if the lock and labels are in proper condition and repaired as needed.the lock and labels are in proper condition and repaired as needed.

FIVE YEAR REVIEW PROCESS6.06.0 FIVE YEAR REVIEW PROCESS

Administrative Components6.16.1 Administrative Components

The Alblon-Sherldan Landfill Site year review report was prepared by Jeff Gore, EPAThe Albion-Sheridan Landfill Site fivefive year review report was prepared by Jeff Gore, EPA Remedial Project Manager. Mary Schafer, State Project Manager with the MichiganRemedial Project Manager. Mary Schafer, State Project Manager with the Michigan Department of Environmental Quality (MDEQ) assisted In the review. The year reviewDepartment of Environmental Quality (MDEQ) assisted in the review. The fivefive year review consisted of Site Inspection and review of relevant documents. The nofice letter to MDEQconsisted of aa Site inspection and review of relevant documents. The notice letter to MDEQ regarding Initiafion of the year review was sent October 16, 2011.regarding initiation of the fivefive year review was sent October 16,2011.

Community Notification and Involvement6.26.2 Community Notification and Involvement

The completed third year review report will be available in the Site record repository,The completed third fivefive year review report will be available in the Site record repository, and the EPA website for public view. An advertisement notice regarding the yearand the EPA website for public view. An advertisement notice regarding the fivefive year review process was placed in the Albion Recorder newspaper for public review on May 24,review process was placed in the Albion Recorder newspaper for public review on May 24, 2012 and is included as an attachment to this report. No public comments regarding the2012 and is included as an attachment to this report. No public comments regarding the fivefive year review have been received.year review have been received.

Community relations ongoing at the Site include reporting on the comprehensive operationCommunity relations ongoing at the Site Include reporting on the comprehensive operation and maintenance sampling program currently being carried out to assure that human healthand maintenance sampling program currently being carried out to assure that human health and the environment are protected. Local residents who provide access for O&M samplingand the environment are protected. Local residents who provide access for O&M sampling are able to ask about the Site progress at that time.are able to ask about the Site progress at that time.

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6.36.3 Document ReviewDocument Review

In preparation for this fivefive year review report, the author reviewed Site documents includingIn preparation for this year review report, the author reviewed Site documents including the following:the following:

•• Second Five Year Review Report, August 2007;Second Five Year Review Report, August 2007;

•• First Five Year Review Report. September 2002;First Five Year Review Report, September 2002;

•• RD/RA Consent Decree, July 1999;RD/RA Consent Decree, July 1999;

Record of Decision, March 1995;•• Record of Decision, March 1995;

•• Albion-Sheridan Landfill Site and operations maintenance documents; andAlbion-Sheridan Landfill Site filefile and operations && maintenance documents; and

•• Albion-Sheridan Landfill Institutional Controls Study, April, 2007.Albion-Sheridan Landfill Institutional Controls Study, April, 2007.

6.46.4 Data ReviewData Review

The parties initiated the O&M monitoring program to provide Infomiation on potentialThe parties initiated the O&M monitoring program to provide infonnation on potential contaminant concentrations in groundwater and air and provide landfill maintenance, in ordercontaminant concentrations in groundwater and air and provide landfill maintenance, in order ensure that the remedy is protective of human health and environmental standards. Theensure that the remedy is protective of human health and environmental standards. The parties began monitoring groundwater and fence line gas probes, as approved in the Siteparties began monitoring groundwater and fence line gas probes, as approved in the Site O&M Plan in October 1999. Two additional fence line gas probes and two additionalO&M Plan in October 1999. Two additional fence line gas probes and two additional groundwater monitoring wells were constructed in June 2001. The O&M Plan stated thatgroundwater monitoring wells were constructed in June 2001. The O&M Plan stated that after eight consecutive samples indicating the absence of concern of elevated gases, theafter eight consecutive samples indicating the absence of aa concern of elevated gases, the perimeter gas probe sampling program could end. As result of no landfill gas detections atperimeter gas probe sampling program could end. As aa result of no landfill gas detections at the seven gas probes during 2001 and 2002, the perimeter fence line monitoring wasthe seven gas probes during 2001 and 2002, the perimeter fence line monitoring was disconfinued at the end of 2002.discontinued at the end of 2002.

The landfill cap requires regular maintenance involving inspecfion and repair of any soilThe landfill cap requires regular maintenance involving inspection and repair of any soil burrowing or erosion locations, and mowing of the landfill surface. The cap has not requiredburrowing or erosion locations, and mowing of the landfill surface. The cap has not required major maintenance since the repair of the Site landfill cap in 2000 to correct and controlmajor maintenance since the repair of the Site landfill cap in 2000 to correct and control erosion damage.erosion damage.

AA review of the groundwater data from the March 2012 Annual Report on Groundwaterreview of the groundwater data from the March 2012 Annual Report on Groundwater Quality for the Site indicate that most monitoring wells continue to show aa trend ofQuality for the Site indicate that most monitoring wells continue to show trend of decreasing total arsenic levels in groundwater. Monitoring results in 2011 found alldecreasing total arsenic levels in groundwater. Monitoring results in 2011 found all monitoring wells located within the Site fence line boundary with the exception of MW­monitoring wells located within the Site fence line boundary with the exception of MW­04SG to be below the 10 ppb MCL. Although total arsenic levels for MW-04SCi confinue to04SG to be below the 10 ppb MCL. Although total arsenic levels for MW-04SG continue to be above the MCL (26 ppb, 17 ppb, and 75 ppb over the last three years), it is located in anbe above the MeL (26 ppb, 17 ppb, and 75 ppb over the last three years), it is located in an Isolated unconsolidated saturated unit which is not part of continuous aquifer whichisolated unconsolidated saturated unit which is not part of aa continuous aquifer which Impacts groundwater migration. As result, the three monitoring wells along theimpacts groundwater migration. As aa result, the three monitoring wells along the downgradient southern fence line (MW09SB, MW06SB, and MW07SB) are Indicating thatdowngradient southern fence line (MW09SB, MW06SB, and MW07SB) are indicating that total arsenic at or above the 10 ppb MCL is not migrating off-site. This is significanttotal arsenic at or above the 10 ppb MCL is not migrating off-site. This is aa significant change since the last year review when elevated off-site arsenic groundwater migrationchange since the last fivefive year review when elevated off-site arsenic groundwater migration was determined to be occurring. Although one off-site monitoring well (MW15SB)was detennined to be occurring. Although one otT-site monitoring well (MW15SB)

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continues to have total arsenic levels above the MCL (61 ppb, 58 ppb, and 61 ppb over theconfinues to have total arsenic levels above the MCL (61 ppb, 58 ppb, and 61 ppb over the last three years), it is located on the Norfolk && Southern Railway right-of way whichlast three years), it is located on the Norfolk Southern Railway rlght-of way which provides aa separate off-site concern. There are no known exposures related to this Norfolk &&provides separate off-site concern. There are no known exposures related to this Norfolk Southern Railway groundwater monitoring well. It is recommended that these positiveSouthern Railway groundwater monitoring well. It is recommended that these positive trends regarding total arsenic levels in groundwater be monitored over the next fivefive years totrends regarding total arsenic levels in groundwater be monitored over the next years to see if they continue and are confirn1ed.see if they continue and are confirmed.

Michigan groundwater cleanup criteria were exceeded at certain groundwater monitoringMichigan groundwater cleanup criteria were exceeded at certain groundwater monitoring well locations for ammonia (10 ppm), aluminum (50 ppb), and manganese (50 ppb). Therewell locations for ammonia (10 ppm), aluminum (50 ppb), and manganese (50 ppb). There are no EPA primary MCLs for ammonia, total aluminum and total manganese. AA review ofare no EPA primary MCLs for ammonia, total aluminum and total manganese. review of the monitoring results for upgradient residential well RW06 and downgradient residentialthe monitoring results for upgradlent residential well RW06 and downgradient residential well RW04 indicates that sampling results have remained relatively stable over time. Nowell RW04 indicates that sampling results have remained relatively stable over time. No MeL exceedences were found during the 2011 monitoring event, and manganese levels atMCL exceedences were found during the 2011 monitoring event, and manganese levels at RW04 of 62 ppb and RW06 of 67 ppb were the only results slightly aboveabove the MichiganRW04 of 62 ppb and RW06 of 67 ppb were the only results slightly the Michigan standards.standards.

Site Inspection6.56.5 Site Inspection

The Site inspection for this fivefive year review was performed on October 26, 2011 by EPAThe Site inspection for this year review was performed on October 26, 2011 by EPA Remedial Project Manager Jeff Gore and MDEQ Project Manager Mary Schafer. BarbaraRemedial Project Manager Jeff Gore and MDEQ Project Manager Mary Schafer. Barbara Vertort-Tiffany of MDEQ was also present during the Site inspection. The fivefive year reviewVertort-Tlffany of MDEQ was also present during the Site inspection. The year review site inspection checklist was used as aa guideline for the Site inspection, and is available for recordrecord in the Sitein the Site file.file. Overall, the Site was found to be in good condition with only minor site inspection checklist was used as guideline for the Site inspecfion, and is available for

OveralL the Site was found to be in good condition with only minor Issues.issues.

The weather was cloudy upon arrival at the Site with the access lock on the gate along ErieThe weather was cloudy upon arrival at the Site with the access lock on the gate along Erie Road secured. Site access is available both along Erie Road at the south end and throughRoad secured. Site access is available both along Erie Road at the south end and through aa locked gate by at the north end of the property. The site visit included walk aroundlocked gate by aa fieldfield at the north end of the property. The site visit included aa walk around the surface of the landfill, along the Site fence line, and across Erie Road south of the Sitethe surface of the landfill, along the Site fence line, and across Erie Road south of the Site fence line which includes an active railroad track and open wooded area.fence line which includes an active railroad track and open wooded area.

The landfill surface had been recently mowed and was found to be in good condition with noThe landfill surface had been recently mowed and was found to be in good condition with no sign of significant brush debris or surface erosion. Recently Installed fence signs along thesign of significant brush debris or surface erosion. Recently installed fence signs along the perimeter of the Site were in place and there no sign of vandalism or significant animalperimeter of the Site were in place and there waswas no sign of vandalism or significant animal burrowing. The groundwater monitoring wells were found to be in good condition andburrowing. The groundwater monitoring wells were found to be in good condition and property locked. All the wells that are part of the Site monitoring program were propertyproperly locked. All the wells that are part of the Site monitoring program were properly labeled, but certain older monitoring wells and piezometers not in the Site sampling programlabeled, but certain older monitoring wells and piezometers not in the Site sampling program were not labeled. The location of the monitoring well nest MW07 looked as if it needed towere not labeled. The location of the monitoring well nest MW07 looked as if it needed to be adjusted on the O&M annual report to be properly represented in the document.be adjusted on the O&M annual report figuresfigures to be properly represented in the document.

7.07.0 TECHNICAL ASSESSMENTTECHNICAL ASSESSMENT

7.1 Question A: Is the remedy functioning as intended by the decision documents?7.1 Question A: Is the remedy functioning as intended by the decision documents? Answer: Yes.Answer: Yes.

RA Performance: The Site remedy selected in the 1995 ROD has been Implemented andRA Performance: The Site remedy selected in the 1995 ROD has been implemented and remains ftinctional, operational, and effective. With continued maintenance of the Site solidremains functional, operational, and effective. With continued maintenance of the Site solid

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waste cap with flexibleflexible membrane liner, the source area remedy should contain any soilwaste cap with membrane liner, the source area remedy should contain any soil contamination and ensure that no excess human health risks develop. Site groundwater overcontamination and ensure that no excess human health risks develop. Site groundwater over the last fivefive years has found the trend in arsenic levels decreasing and indicating that totalthe last years has found the trend in arsenic levels decreasing and Indlcafing that total arsenic at or above the 10 ppb MCL is not migrating otT-site. This trend of no off-sitearsenic at or above the 10 ppb MCL is not migrating off-site. This trend of no off-site migration above the arsenicarsenic MCL needs to be monitored and confirmed over the next fivefivemigration above the MCL needs to be monitored and confirmed over the next years.years.

Cost of System Operations/O&M: Current annual O&M costs at the Site are primarilyCost of System Operations/0«&M: Current annual O&M costs at the Site are primarily attributable to operation, maintenance, and management of the Site; and include sampling,attributable to operation, maintenance, and management of the Site; and include sampling, lab analysis, reporting, routine maintenance, and inspections. Site estimated annual O&Mlab analysis, reporting, routine maintenance, and inspections. Site estimated annual O&M costs for 2011 are approximately $30,000.costs for 2011 are approximately $30,000.

Opportunities for Optimization: The trend of decreasing arsenic levels in groundwaterOpportunities for Optimization: The trend of decreasing arsenic levels in groundwater found over the last fivefive years needs to be monitored over the next fivefive years to confirm thatfound over the last years needs to be monitored over the next years to confirm that total arsenic at or above the 10 ppb MCL is not mlgrafing off-site.total arsenic at or above the 10 ppb MCL is not migrating off-site.

Early Indicators of Potential Remedy Problems: There have been no indications of anyEarly Indicators of Potential Remedy Problems: There have been no indications of any potential Issues with the Alblon-Sherldan Landfill remedy over the last years.potential issues with the Albion-Sheridan Landfill remedy over the last fivefive years.

Implementation of Institutional Controls and Other Measures: The 1995 ROD includedImplementation of Institutional Controls and Other Measures: The 1995 ROD Included measures implementing the use of ICs on landfill property to limit both land and groundwatermeasures implementing the use of ICs on landfill property to limit both land and groundwater use, and to limit groundwater use on adjacent property until the arsenic clean-up standard isuse, and to limit groundwater use on adjacent property until the arsenic clean-up standard is attained. The Site property owned by CDC Associates had restrictive covenant recorded atattained. The Site property owned by CDC Associates had aa restrictive covenant recorded at Calhoun County Recorder's Office on June 21 1999. The restrictive covenants limit land andCalhoun County Recorder's Office on June 21 1999. The restrictive covenants limit land and groundwater use on the Site, and protect the remedy.groundwater use on the Site, and protect the remedy. Institutional Controls In the form ofInstitutional Controls in the form of restrictive covenant(s) are planned for the Site landfill parcels owned by Calhoun County,restrictive covenant(s) are planned for the Site landfill parcels owned by Calhoun County, Michigan. These additional ICs will ensure that all property on the Site is properly restricted,Michigan. These additional ICs will ensure that all property on the Site is properly restricted, that the use of groundwater underiylng the Site Is property restricted, and that the remedy isthat the use of groundwater underlying the Site is properly restricted, and that the remedy is protective over the long-term.protective over the long-tem1.

Current Use Compatibility with Land and Groundwater Use Restriction: Based on theCurrent Use Compatibility with Land and Groundwater Use Restriction: Based on the Site inspection conducted by EPA and MDEQ in October 2011, compliance with the existingSite inspection conducted by EPA and MDEQ in October 2011, compliance with the existing Implemented use restrictions was observed noting that planned ICs for Site parcels owned byimplemented use restrictions was observed noting that plmmed ICs for Site parcels owned by Calhoun County are needed. No Site uses inconsistent with the Intended uses and restrictionsCalhoun County are needed. No Site uses inconsistent with the intended uses and restrictions as depicted in the implemented ICs were observed. The additional planned ICs listed areas depicted in the implemented ICs were observed. The additional planned ICs listed are needed so that the Site remedy can remain protective in the long-term.needed so that the Site remedy can remain protective in the long-term.

Question B: Are the assumptions used at the time of remedy selection still valid?7.27.2 Question B: Are the assumptions used at the time of remedy selection still valid? Answer: No.Answer: No.

Standards outlined and reviewed in theChanges inChanges in Standards and To Be Considered:Standards and To Be Considered: Standards outlined and reviewed in the Albion-Sheridan Landfill Site 1995 ROD and the two previous year review reports areAlbion-Sheridan Landfill Site 1995 ROD and the two previous fivefive year review reports are still valid at the Site. Groundwater remedial action objectives are the attainment of EPAstill valid at the Site. Groundwater remedial action objectives are the attainment of EPA MCL drinking water standards. However, In 2006, EPA revised the arsenic MCL forMCL drinking water standards. However, in 2006, EPA revised the arsenic MCL for drinking water from 50 ppb to 10 ppb.drinking water from 50 ppb to 10 ppb.

1414

Changes in Exposure Pathways: Groundwater trends at the Site over the last years hasChanges in Exposure Pathways: Groundwater trends at the Site over the last fivefive years has found the levels decreasing and indicating that total arsenic at or above the 10 ppbfound the arsenicarsenic levels decreasing and indicating that total arsenic at or above the 10 ppb MCL is not migrating off-site. No other changes in the Site conditions that affect exposureMCL is not migrating off-site. No other changes in the Site conditions that affect exposure pathways were identified as part of the fivefive year review. There are no current or knownpathways were identified as part of the year review. There are no curtent or known planned changes in the Site land use.planned changes in the Site land use.

Changes in Risk Assessment Methodologies: Risk assessment methodologies used at theChanges in Risk Assessment Methodologies: Risk assessment methodologies used at the Albion-Sheridan Landfill Site have not changed, and do not call into question theAlbion-Sheridan Landfill Site have not changed, and do not call into question the protectlveness of the remedy.protectiveness of the remedy.

7.37.3 Question C: Has any other information come to light that could call into questionQuestion C: Has any other information come to light that could call into question the protectiveness of the remedy? Answer: No.the protectiveness of the remedy? Answer: No.

There has been no other known Infomiation that could call into question the protectiveness ofThere has been no other known infonnation that could call into question the protectiveness of the remedy.the remedy.

Technical Assessment SummaryTechnical Assessment Summary

According to the data reviewed and the Site inspection, the remedy is substantiallyAccording to the data reviewed and the Site inspection, the remedy is substantially functioning as intended by the 1995 ROD. Certain parcels at the Site which are owned byfunctioning as intended by the 1995 ROD. Certain parcels at the Site which are owned by Calhoun County are not yet subject to appropriate land or groundwater use restrictions. ICsCalhoun County are not yet subject to appropriate land or groundwater use restrictions. ICs in the form of restrictive covenant(s) are planned for these property parcels. No otherin the form of restrictive covenant(s) are planned for these property parcels. No other additional information has been identified that would call into question the protectiveness ofadditional information has been identified that would call into question the protectlveness of the remedy.the remedy.

ISSUES8.08.0 ISSUES

The following Issues in Table were identified during the year review process whichThe following issues in Table 55 were identified during the fivefive year review process which impact protectiveness of the remedy under CERCLA:impact protectiveness of the remedy under CERCLA:

Table 5. Issues that may Impact ProtectivenessTable 5. Issues that may Impact Protectiveness IssueIssue Currently AffectsCurrently Affects Affects FutureAffects Future

Protectiveness (Y/N)Protectiveness (YIN) Protectiveness (Y/N)Protectiveness (YIN) Arsenic groundwater trendArsenic groundwater trend NN YY

analysis for Site.analysis for Site. Additional ICs for SiteAdditional ICs for Site NN YY property parcel(s).property parcel(s). Y-yes; N=noY=yes; N=no

9.09.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONSRECOMMENDATIONS AND FOLLOW-UP ACTIONS

Recommendations and follow-up actions in Table for issues that impact protectiveness andRecommendations and follow-up actions in Table 66 for issues that impact protectiveness and were noted in Table 5:were noted in Table 5:

•• The multi-year trend analysis for arsenic In the O&M program will continue toThe multi-year trend analysis for arsenic in the O&M program will continue to monitor arsenic levels during the next years to see if the trend of reduced arsenicmonitor arsenic levels during the next fivefive years to see if the trend of reduced arsenic levels and migration in groundwater remains at the Site.levels and migration in groundwater remains at the Site.

lS15

EPA will be working with the PRPs, Calhoun County, and MDEQ to ensure that ICs• EPA will be working with the PRPs, Calhoun County, and MDEQ to ensure that ICs in the form of restrictive covenant(s) are implemented on Site property parcel(s)in the form of restrictive covenant(s) are implemented on Site property parcel(s) owned by Calhoun County. The ICs will assure that land and groundwater use onowned by Calhoun County. The ICs will assure that land and groundwater use on Site parcel(s) are adequately restricted and the Site remedy is protected.Site parcel(s) are adequately restricted and the Site remedy is protected.

Table 6. Recommendations and Follow-up Actions1 Table 6. Recommendations and Follow-up Actions | AffectsAffects

Party OversightRecommendations!Recommendations/ Party Oversight MilestoneMilestoneIssueIssue Protectiveness(Y/N)Protectiveness(YIN)

Follow-up ActionsFollow-up Actions ResponsibleResponsible AgencyAgency DateDate CurrentCurrent FutureFuture

1 ArsenicArsenic Mulfi-year analysisMulti-year analysis Albion-Albion- EPA/EPA! AugustAugust NN Yy

groundwatergroundwater confinues tocontinues to SheridanSheridan MDEQMDEQ 20132013 trendtrend monitor reducedmonitor reduced PRPsPRPs annuallyannually analysisanalysis arsenic levels overarsenic levels over throughthrough

the next yearsthe next fivefive years AugustAugust at the Site.at the Site. 20172017

1 AdditionalAdditional RestrictiveRestrictive PRPs,PRPs, EPA/EPA! AugustAugust NN Yy ICs for SiteICs for Site Covenant(s) forCovenant(s) for CalhounCalhoun MDEQMDEQ 20132013 propertyproperty property parcel(s)property parcel(s) CountyCounty parcel(s).parcel (s). owned by Calhounowned by Calhoun

CountyCounty Y=yes; N=noY=yes; N=no

PROTECTIVENESS STATEMENT(S)10.010.0 PROTECTIVENESS STATEMENT(S)

The Albion-Sheridan Landfill Site remedy is functioning as intended and is protective ofThe Albion-Sheridan Landfill Site remedy is functioning as intended and is protecfive of human health and the environment in the short term. The Site Landfill cap remains in placehuman health and the environment in the short term. The Site Landfill cap remains in place and continues to provide an adequate barrier for waste containment. There is no evidence ofand continues to provide an adequate barrier for waste containment. There is no evidence of

cap breach and the existing use of the Site property is consistent with the objectives of theaa cap breach and the existing use of the Site property is consistent with the objectives of the landfill cap and land use restrictions. There is no evidence of Site arsenic contaminantlandfill cap and land use restrictions. There is no evidence of Site arsenic contaminant migration above MCLs Impacting drinking water. However, in order for the remedy to bemigration above MCLs impacting drinking water. However, in order for the remedy to be protective in the long-tenn, the following actions need to be taken to ensure long-tennprotective in the long-tenn, the following actions need to be taken to ensure long-tenn protecfiveness: implementing additional instltufional controls to ensure Site property andprotectiveness: implementing additional institutional controls to ensure Site property and groundwater protectiveness; enforcement, maintenance, and monitoring ofgroundwater protectiveness; enforcement, compliance,compliance, maintenance, and monitoring of effective ICs; and ongoing implementation of the O&M program.effective ICs; and ongoing implementation of the O&M program.

NEXT REVIEW11.011.0 NEXT REVIEW

Since the Albion-Sheridan Landfill Site contains hazardous substances, pollutants, orSince the Albion-Sheridan Landfill Site contains hazardous substances, pollutants, or contaminants that will potentially remain above levels that allow for unlimited use andcontaminants that will potentially remain above levels that allow for unlimited use and unrestricted exposure, the Site will require ongoing year reviews. Therefore, anotherunrestricted exposure, the Site will require ongoing fivefive year reviews. Therefore, another report will be scheduled years after this report is completed. The completion date of thereport will be scheduled fivefive years after this report is completed. The completion date of the current year review is the signature date shown on the cover attached to the front of thiscurrent fivefive year review is the signature date shown on the cover attached to the front of this report.report.

1616

Attachment 11Attachment

List of Albion-Sheridan Landfill SiteList of Albion-Sheridan Landfill Site Documents Reviewed for Five Year Review ReportDocuments Reviewed for Five Year Review Report

•• Second Five Year Review Report, August 2007Second Five Year Review Report, August 2007

•• First Five Year Review Report, September 2002First Five Year Review Report, September 2002

RD/RA Consent Decree, July 1999•• RD/RA Consent Decree, July 1999

•• Record of Decision, March 1995Record of Decision, March 1995

•• Alblon-Sherldan Landfill Site file and operations and maintenance documentsAlbion-Sheridan Landfill Site tile and operations and maintenance documents

•• Alblon-Sherldan Landfill Institutional Controls Study, April, 2007Albion-Sheridan Landfill Institutional Controls Study, ApriL 2007

1717

Superfund Site Location U.S. Environmental Protection Agency

Albion-Sheridan Township LandfillAlbion-Sheridan Township Landfill MID980504450MID980504450Calhoun County, MlCalhoun County, MI

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State

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-+-- Conrail Railroad

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Produced by Sarah BackhouseProduced by Sarah Backhouse U.S. EPA Region on 5/31/07U.S. EPA Region 55 on 5131107 Image Date: 2006Image Date; 2006 ++

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~~r~~:~~=~~· OR WWITORINQ SYSTEM OR OTHEROlI_ITOlIlIIIGI'fSTIIOlilOntEll OtS'>DNSE ACTION,IIE*'ODE ACTIOII.).

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) BASE IMP CREATED FROM m ENOINEERINO L SCIEPJCE REPORT DATED J U L * ^ 9 9 * . THE OWNERSHIP DF THE CENTRAL PORTION OF THE LANDFILL IS UNCLEAR. CONFIICTINO SOU"CES OF tNFORHATION « R E OBTAINED; ONE SOURCE IMIIHO

I) auE .... ' CllU.tEO rllOllWlr ENOIHUIlIHll' ICrUCE 1l(I'OIlT IlIII.TtO JUly 11M, Tllt OI'MUSHI. OF Tllf: I:[HTMl I'OIltiON OFTMEI.AHOFILll'lINCL[AII,COHFLICTtNG~'OF h'(III:W,t1OlrlW(llf QlT"'lHfO; ONE IOlJRCflioWlWi

INSTITUTIOMAL CONTROLS flEVIEW

INSTITUTIONAL CONTROLS REVIEW

ENVIHONMNtAL RESOURCE RECOVERY, IMC. AS THE RROPEKTY O m t H , AND TW OTHER SOOflCf NAHtm I « STATE Of HICHIOAM AS THE pnOPERTY OWNER.

fJNIIKMlVfIAlllElOIJfIttll(coYlIlT,JIIC,AlTltf1'flOl'ElllY a.Nf1l ....JlOlHlO1l'lllSQUllCEIWilllIOTltf.ST...tfOi .ICIIlo.o.N AS ntt I'IlOI'tIlN 0IlNI1l.

I THE PROPERTY 0mERSn(p f t w PARCELS 3 6 Z - D M . O I ) A W 3M-O4S-0O IS CURRENTLY SEIKO EVALUATED IT THE CALHOUK COUHTY TREASURER'S OFFICE/LANO BANH AUTMMIIY. AT TXI3 T l W . CAL'<Ol« COUNTY IS BELIEVED TO BE Tut OIWER FOR THESE PARCEIS.

aI 1Itll"llOll'Ul'I'l»NEII'MI"0II''''ICfLS30I·0;)f·OONIO:sg·I)I,·oo I' CUIlIlVtTLY IUNO ('II\lUATfO n MCllHlUl c:oMn' nlAJUlllll'S O"f1C(fLAJC) ......1: IIP/nIOln", AT THI' Tll1l,CAl.MCUIICOUNTTI'IU1('1[OTOI[1'loIf.(lIINfJll'OIl TItESE'Afl(;ElI.

C-IO'

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_, ...... '1 - - ^ 1 PtOPERTY LINE-- - - -- POOT't' L'.N 7 00 us______ NoIlCIl.LTIIlI

P««EL LINES " --- \\1 1 I ... __ - ......IMtt UlIllltl' "LLAPntOHIIHTE L I H j r OP FILL·.m!i!>Il-':·::::::-_~-1 ,-\\\\\ UI I'!: .- — — .-FEWCE..... --1 I~~\\II 1 I' 1 1I0OI$1. QIlCUIllIiIIJIITlll IOItn-U. JIllLKwoesa-^ QRDUNOHATER yONITOniNQ WELL ..... -f I' 91 \)ljll A" __ -. lINCM. utlOl.lfTIALMTtllllllURESlDtNTIAL WTEH «ELL..... 1 I :\'-t-- --,J L I...". " 1 ^ 4 .

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""'AlIIfAJ....IlIOUUIIlIIIIITJTVTlOtW.ADtAS RiaulRIMG IN8TITUTI0IWL

I Ir -","-_./ I I I I CONTROLSffi^^^Eu/ 1 -l- - ­AIl(A Of A11llt1ll; llOCCllltOOJil'ol1Oll IIIQlIIOlJIIlIJIlftIlAlO¥IIO ../l

--<>...-- AflIlIIIt; COJC[lIfMtlOll CCIliIfOI.NARStNlC CONCENTMTION CONTOUaS/("\:/ l: 1:?lnu, i -." ~ - l ,,-_/ ----------- l.IIJlIHO (,.lIIlCOO¥TICIi CCllfTOUIIIIIINFtmED CCMCEHIMTION CONTOURS

/ /1' I 1 It/"). 1II111UTlllCTllltlllfCllJlll(OEIISTINGUII1I... USE RESTRICTIO*' RECORDED llIlClUfIIO*IlfU,.QTlIIICJlIIORESTPICTINO ....USE OF ORDUNOBATtR,/ I I I ~,=,,'I \ ---( OIV~IftIM[ACOW:...O"'MDEVELOPMENT (AREA CWEREO BY THE

LANoriLL CAP) FOR RESIOBITIAL./1/ 1 1 :) ^ ^ C0MHERCIA4. OR ACI1CUI.TJWL kAE,N. b. ~:c~:'o:. =I::=~. AND DISOUPtlON OF THE CONTAIIMEHINCI01Plll"lI1110fTM.CIllIflAI..-' OR WMITORtNa lYBTE* ON OTHERClIIlIOflTtlllll11mTOIlltO'OlOII I 1 : - r- I \-...1 HESfOWSE ACTION.Ill""" ""t1011.

SITEI 1 I 1 J 1_ - ...1 c:::::::J ::'P ftCt "llIICII.. lin 1 I 1 1 --j

1 EXISTINO LANDFILL CAP COVPPIS I FLEIIBLI I --""1 1 / I --i c=J ~I-:~~IO~I:::L(F ' COVER1 I I 1 --i n ^

" ~~.../__I__ - \ -.., >-------1------1---1--1---1--+----- I 1;+-............-- N 1\ 000

,..... MMITORINO MELL ID ....IcmTOTAL..... · ^ / L../\ 1"'-I~I"'IIIU'" AWSEKIC ­

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m * n <0.OOS-. ..­.,. q• n n to .003••

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,COO IMtSSB O.MOI I M I I M co.•

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lA'I'lII'''', ~mroi _..,<0,0OJ 1 -~··~'JIlIIOlJltlAL.·O,• • FOBMRIY RESIDENTIAL W - 0 7

....J ,'_ 0.010.01 CONTCW)ccwru INTERVALIIfTlI'I'IAI,

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".4.;100 .n FIGURE 3

AlBION·SHERIDNl FIGUflE 3

ALBION-SHEfllDAN DATEDe-no.M.'JULY I B M .,.... '"" OBWBSHIP T«( CENTWL. POBTTON TOWJSHIP LANDFILL

'I IMP ~'lO '1lClI_ (_'IIf:Ulle' KilO "-llllI') SASE~ ., CREATED FROM M ENOINEERINO 1 SCIENCE BEPORT THE OF TOR'fSH IP LANDFIllQMI'(I1 fWfCl.tttw.PalTIOlI

OF(11 THEfH[l.A'CW'fll..Jll,JClW.I I UNCLEAR. COHFIICTIW)CCWUClI.. IOlJIlCUOf 1mM4T101i'll(q:OIT.IIillD:OIllIlll.llClIIAII.

LAWRILL BOIMCI OP A.RSENICARSENIC ENVIRONMENTAL BTSOURCE RECOVEHV, INC. AS THE PBOPEBTY ISOCONCENTHATION HAP INFOMMTIOH RTRE OBTAINED; ONE SOURCE NMIIW lll¥'l~.l..lltlOUllClillfCO'i'lJl'f'.IC.ASn.:PllOf'UT'f ISOCONCt:NTRATlOH WJt OMNER, AW) THE OTHER SOURCE NAMING THE STATE OF~Il,""THt;OnuIClUllClMlfI"TMlITAll(l1 FOA THE SH.\llCMFOR THE SHALLOW

BEDROCK MICHIIMN AS THE PROPERTY CHNER..1QlIIWtAl"-PIOPUT'f0lllill.ll.

BEDROCK ) THE PROPERTY OPNERSHIP »0* PARCELS 3SI-D3S-00 AND:t1TM[~II"'OiIIIlfIl!llI"l'OiII'NIClU*."',OlI""

3GZ-OA5-D0 IS CURRENTLY lEINQ EVALUATED lY THE CALHOUN~ C·IO!"·lM~·OlI JI Q1111um.'f Ill.. lVo\UIIlUO" 1M: C-101 T'MAJUl'l11l'1 Ol"f1CI/LAllO IWllI NJ'IJIllIlln. At ntIS

TIME,TIll!(, CALHOUN COUNTY~Cl»ln IS BELIEVED TO BE TN OPNER0iIIMIJI COUNTYCOUlm TREASURER'S OFFICI/LANO SANK AUTHORITY. AT TXIS

IS .nllno to H THE "'"FOR THESE PARCELS,'-llf'llollllO(U,

~ N. ~.OO(\ NN

,.......... I 0 100 ; o oo 100 lOO 400

SCALE IN FEETSCAUlNrtET

N. 7.~O

N. 7.000

• — — — — — PROPERTY LINE------I'flOI'EAl'TlifilE

PARCEL LINES------'M(;llllNES

- A - OROliNDWATER MON"W06S8~ ~~~ITORIIlG.ll I * * 0 6 S B T SHALLOW B E D R X K

--950.0-I'OTlWTI0WUlIC ""f,t,CE CllfIfTOU\9 5 0 . 0 POTENTLOMETRLC SURFACE CONTOUR 3".

950.0------. =:O~lc.TJIJC_ _ - ~ " SURFACEINFERREDCONTOURPOTENTIOMETBIC

I a a U . U - — — — — — - SURFACE CONTOUR

C I P L O O D P L A I N

c==JfLOClll't.AIIIII ~ __ QROUNWATER FLO« DIRECTION~QIlOUIOIAT[R'LOI'OllllCTIOlrl is

I I I I I I :

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-------+-- +-_+-+_-\,-l_--l.=-:...::-:.:I.=-::..::-=...=-=-=Ie--=--=-l:::;-__--,iSLc- --\----\--~-_i__~_;_~--" ',00. T ; T ? i r ^ .I ~ .....,~_,.Mwo'sa ." ...

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tl.4.""OO." FIGURE 4FlGUFlE"POTENTIOMETRIC SURFACEPOTENTIOJ,lETRIC SURFACE

0, MAP FDR THEMAP FOR THEg SHALLOW BEDROCKSKAL.LCM' BEDROCk NOTE:

BASE MAP CREATED FROM WW ENGINEERING d SCIENCE REPORTNt: _ CMATUl , .. ,. [II(IIIoE(l1I1IG , ICIUICI II(POIlTDATED JULY 1994. THE OWNERSHIP OF THE CENTRAL PORTION OF THE LANDFILL IS UNCLEAR. CONFLICTING SOUBCES OF

trt.UO.M.'f , ... , ntlOIIIEUt!I'''' 'OIf.Clfff1W.l'OIIUOIl Of THI! lANDfiLL IS lNCUNI. COIIl'lICTIIIll IIOJIIC(S Of

ENVIBOHMENTAi RESOURCE RECOVERY, INC. AS THE PROPERTY C·101 INFORMATION WERE OBTAINED: ONE SOURCE NAMINGIJ(FOft!MTI(lfiIWI![ 01110111[0; OIlE ICUllCf IWIIIIG

!lWllIlOfItl(lrITlU. HSOUllCf. ~[CO'I'tlff. TNt ..... TM: "[~T'I'WNER, AMD THE OTHER SOURCE NAMING THE STATE OF MICHIGAN0IiMtl, AHll THEOTllEI! SCIOI!C[ tWUIIO TMf ST1ol[OfIlIQUlWrIAS THE PROPERTY OWNER.1o'lH[~E~TVOIItIE".

Attachment 11Attachment

List of Albion-Sheridan Landfill SiteList of Albion-Sheridan Landfill Site Documents Reviewed for Five Year Review ReportDocuments Reviewed for Five Year Review Report

•• Second Five Year Review Report, August 2007Second Five Year Review Report, August 2007

First Five Year Review Report, September 2002•• First Five Year Review Report, September 2002

•• RD/RA Consent Decree, July 1999RD/RA Consent Decree, July 1999

Record of Decision, March 1995•• Record of Decision, March 1995

•• Albion-Sheridan Landfill Site filefile and operations && maintenance documentsAlbion-Sheridan Landfill Site and operations maintenance documents

Albion-Sheridan Landfill Institutional Controls Study, April, 2007•• Albion-Sheridan Landfill histitutional Controls Study, April, 2007

.^^^^°'''%

EPA Begins ReviewEPA Begins Review of Albion-Sheridan Township Landfill Superfund Siteof A lb ion-Sher idan Townsh ip Landf i l l Super fund Site

Albion, MichiganAlbion, Michigan

The U.S. Environmental Protection Agency is conducting aa five-yearfive-year review of the Albion­The U.S. Environmental Protection Agency is conducting review of the Albion-Sheridan Township Landfill Superfund site about aa mile east of Albion. The Superfund lawSheridan Township Landfill Superfund site about mile east of Albion. The Superfund law requires regular checkups of sites that have been cleaned up - with waste managed on-site - torequires regular checkups of sites that have been cleaned up ~ with waste managed on-site ~ to make sure the cleanup continues to protect people and the environment. This is the third five­make sure the cleanup continues to protect people and the environment. This is the third five­year review of this site.year review of this site.

The cleanup includes aa multi-layer cap with venting over an 18-acre landfill, cap maintenance,The cleanup includes multi-layer cap with venting over an 18-acre landfill, cap maintenance, long-tern1 ground water treatment, monitoring and limits on use of the area.long-term ground water treatment, monitoring and limits on use of the area.

More infonnation is available at the Albion Public Library, 501 Superior St. The review shouldMore infomiation is available at the Albion Public Library, 501 Superior St. The review should be completed by the end of August.be completed by the end of August.

The review is an opportunity for you to tell the EPA about site condifions and anyThe five-yearfive-year review is an opportunity for you to tell the EPA about site conditions and any concerns you have. Contact:concerns you have. Contact:

Jeff GoreJeff Gore Cheryl AllenCheryl Allen Remedial Project ManagerRemedial Project Manager Community Involvement CoordinatorCommunity Involvement Coordinator 312-886-6552312-886-6552 312-353-6196312-353-6196 gore.jeffrey@epa.govgore.jeffrey@epa.gov allen.cheryl@epa.govallen.cheryl@epa.gov

You may also call the EPA toll-free at 800-621-8431, 9:30 a.m. to 5:30 p.m., weekdays.You may also call the EPA toll-free at 800-621-8431, 9:30 a.m. to 5:30 p.m., weekdays.

EPAEPA Superfund DivisionSuperfund Division 77 W. Jackson Blvd.77 W. Jackson Blvd. Chicago, IL 60604Chicago, IL 60604