UNITED STATES ENVIRONiViENTAL PROTECTION AGENCY REGION 5

77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590

US EPA RECORDS CENTER REGION 5

IIIIIIImhIIIIiIiiIIiIIIIIII ii ii 494974

MEMORANDUM REPLY TO THE ATTENTION OF

SUBJECT: Enforcement Action Memorandum — Detennination of Threat to Public Health and the Environment at the Trex Properties Grand Rapids Site, Grand Rapids, Kent County, Michigan 49503 (Site ID # C5BY)

FROM: Jeff Lippert, On-Scene Coordinator Emergency Response Branch 1 Emergency Response Section 2

THRU: Jason H. El-Zein, Chief Emergency Response Branch 1

TO: Douglas Ballotti, Acting Director Superfund Division

I. PURPOSE

The purpose of this Action Memorandum is to document the deteilnination of an imminent and substantial threat to public health and the environment posed by trichloroethylene (TCE) in the environment and near human populations and to select the response action. The threat is located at the Trex Properties Grand Rapids Site (Site), 312 Ellsworth Avenue SW, Grand Rapids, Kent County, Michigan 49503. The Site is a former solvent recycling facility currently owned and operated as a photography studio.

On June 7, 2016, the Michigan Department of Health and Human Services (MDHHS) requested assistance with high levels of TCE in the sub-slab soil vapor of the Site [Administrative Record Item #13]. On June 8, the EPA and the Michigan Department of Environmental Quality (MDEQ) collected a total of 12 indoor air samples at the Site and surrounding commercial businesses. Laboratory analysis of the samples concluded that three samples were above the State of Michigan's Commercial Indoor Air Action Level for TCE of 1.6 parts per billion by volume (ppbv). All three exceedances were in the building at the Site. The results were 35 ppbv, 130 ppbv, and 220 ppbv [Administrative Record Item #16].

Commercial businesses and a bus depot are adjacent to the Site. US 131 is located to the east of the bus depot. The Grand River is about 1,750 feet to the west of the Site.

Trichloroethylene (TCE), a hazardous substance as defined by CERCLA Section 101(14), has been detected in the groundwater, soil, soil vapor and indoor air at the Site. A completed vapor intrusion pathway has been identified.

Recycled/Recyclable 6 Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post-Consumer)

The uncontrolled conditions of the hazardous substances present at the Site require that this action be classified as both emergency and time-critical removal actions. The On-Scene Coordinator (OSC) initiated the response based on a hazardous substance release. The OSC anticipates that the cleanup will take 360 days to complete.

The proposed removal of hazardous substances would be taken pursuant to Section 106(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1), and Section 300.415 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R. § 300.415.

II. SITE CONDITIONS AND BACKGROUND

Name: Trex Properties Grand Rapids Superfund Site ID: C5BY CERCLIS ID: MIN000506292 Site Location: 312 Ellsworth Avenue SW, Grand Rapids, Kent County, Michigan 49503 Lat/Long: 42.957385/-85.6750867 RCRA ID: MID 020 906 764 State ID: None Potentially Responsible Parties (PRPs): Trex Properties, LLC; Detrex Corporation NPL Status: Non NPL Category: CERCLA Emergency and Time-Critical

A. Site Description

1. Removal Site Evaluation

On March 23, 2016, Trex Properties, LLC (Trex Properties) submitted data to MDEQ that showed extremely high levels of TCE in the sub-slab soil vapor. The levels were as high as 1,533,000 ppbv. For comparison, the MDHHS health based screening level for a commercial building is 54 ppbv. The level of TCE found in the sub-slab soil vapor was over 28,000 times higher than the MDHHS health based screening level.

On April, 1, 2016, MDEQ contacted Trex Properties and requested immediate action at the Site due to the extremely high sub-slab soil vapor concentrations of TCE. This call was followed by a letter to Trex Properties from MDEQ on April 4, 2016 [Administrative Record Item #11].

On June 7, 2016, MDEQ sent the sub-slab soil gas data to MDHHS. Upon review of the data by the MDHHS that same day, the MDHHS immediately requested EPA assistance with the Site. The Site is described in the referral as having immediate public health concerns due to "extremely high trichloroethylene levels".

On June 8, 2016, the EPA in collaboration with the MDEQ collected 12 indoor air samples at the Site and surrounding commercial businesses. Laboratory analysis of the samples concluded that three samples were above the MDHHS's Commercial Indoor Air Action Level for TCE of 1.6

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ppbv. All three exceedances were in the building at the Site. The results were 35 ppbv, 130 ppbv, and 220 ppbv. These levels are between 21 and 137 times higher than the MDHHS's Commercial Indoor Air Action Level for TCE.

2. Physical Location

The Site is located in a mixed light industrial and commercial area. It borders Ellsworth Avenue SW to the west, with commercial and light industrial properties to the west all the way to the Grand River. These other properties are included with the Site and require sub slab soil gas sampling and indoor air sampling. The Site is bordered to the north by Bartlett Street NW and the Rapid bus terminal beyond, by the Rapid bus terminal to the east with US 131 beyond, and by a parking lot and Wealthy Street to the south.

An Environmental Justice (EJ) analysis for the Site was conducted. Screening of the surrounding area used Region 5's EJ Screen Tool [which applies the interim version of the national EJ Strategic Enforcement Assessment Tool (EJSEAT)]. Region 5 has reviewed environmental and demographic data for the area surrounding the Site and has determined there is a high potential for EJ concerns at this location.

3. Site Characteristics

The Detrex Corporation (Detrex) operated the Site from approximately 1967 and ceased operations in 1996. During the operating period of the Site, Detrex specialized in the sale of halogenated hydrocarbon solvents and cleaning equipment and the collection of solvent wastes generated in degreasing and other commercial/industrial operations.

Throughout the time that Detrex operated the Site, hazardous wastes managed were U.S. EPA Hazardous Waste Codes F001 and F002. These wastes contain primarily 1,1,1-trichloroethane, TCE, tetrachloroethylene, methylene chloride, and trichlorotrifluoroethane No other waste streams were managed at the Site.

In 1989, Detrex developed a closure [Administrative Record Item #6] plan for a number of hazardous waste units at the Site. The MDEQ approved the closure plan in a letter dated September 5, 1990. Closure activities were performed between December 3, 1990 and March 8, 1991 and waste was shipped for disposal.

From 1991 through 1996, Detrex operated the Site as a transfer station for 55-gallon drums of spent solvent waste. Detrex ceased operations at the Site in 1996.

Hazardous substance disposals and releases occurred while Detrex operated at the Site.

As documented in the March 2016 Enviro Analytics Group Report; Detrex transferred all of its environmental liabilities to Trex Properties, LLC [Administrative Record Item #10]. The Michigan Department of Environmental Quality (MDEQ) and Trex Properties entered into an agreement for Corrective Action in 2015 in order to characterize contamination at the Site.

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The March 2016 Enviro Analytics Group Report documents that on December 4, 2014 a meeting was held between Trex Properties and the MDEQ to discuss the status of the Site. Data had been collected at the Site on several occasions. An agreement was reached in the meeting that additional investigation activities would be necessary [Administrative Record Item #101. Trex Properties performed these agreed upon activities in July and August 2015.

Trex Properties submitted a report summarizing the 2015 activities on March 23, 2016 [Administrative Record Item #10]. The report documented levels of TCE in the sub-slab vapor as high as 8,240,000 [tg/m3 [1,533,000 ppbv]. For comparison, the MDHHS health based screening level for a commercial building is 54 ppbv. The level of TCE found in the sub-slab soil vapor was over 28,000 times higher than the MDHHS health based screening level.

The same report also documented levels of TCE in the soil as high as 155,000 parts per million (ppm) approximately 15 feet outside the south wall of the building. This level exceeds the MDEQ's Residential Soil Volatilization to Indoor Air Inhalation Criteria of 1000 ppb by 155,000 times.

This same report documented levels of TCE in the groundwater as high as 88,600 lg/L, approximately one foot away from the east wall of the building. This level of TCE exceeds the MDEQ's Residential Groundwater Volatilization to Indoor Air Inhalation Criteria of 2,200 [tg/L by over 40 times. Similarly, the level of TCE documented in the groundwater exceeds EPA's Removal Management Level (RML) of 22iLtg/L by more than 4,000 times.

On April, 4, 2016, the MDEQ wrote a letter to Trex Properties and requested immediate action at the Site due to the extremely high sub-slab soil vapor concentrations of TCE [Administrative Record Item #11].

On June 7, 2016, the MDEQ sent the sub-slab soil gas data to the MDHHS. Upon review of the data by the MDHHS that same day, the MDHHS immediately requested EPA assistance [Administrative Record Item #13] with the Site. The Site is described in the referral as having immediate public health concerns due to "extremely high trichloroethylene levels".

4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant

A release of hazardous substances, pollutants, or contaminants is present due to documented vapor intrusion at the Site. A completed exposure pathway exists for vapor intrusion, as TCE has been documented in the groundwater (TCE as high as 88,600 µ,g/L), in the soil gas (TCE as high as 1,533,000 ppbv), in the soil (TCE as high as 155,000 ppm) and in the indoor air (TCE as high as 220 ppbv) at the Site.

The MDHHS has also concluded that there is a vapor intrusion completed exposure pathway at the Site.

5. NPL status

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The Site is not on the NPL.

6. Maps, pictures and other graphic representations

Attachment 3 contains maps including the Site location, the Site layout and sampling location.

B. Other Actions to Date

1. Previous actions

There have been no previous removal actions at the Site.

2. Current actions

Trex has begun emergency actions at the site with EPA oversight. Trex's emergency actions to mitigate high levels of TCE in the indoor air at the site have included the following:

• Installation of a sub-slab depressurization system • Installation of carbon filtration • Sealing of cracks in the basement floor • Installation of exhaust fans in the basement • Reconfiguration of the ventilation system

C. State and Local Authorities' Roles

1. State and local actions to date

The MDHHS has requested EPA assistance in cleanup of the Site [Administrative Record hem #13].

2. Potential for continued State/local response

Given the exigency of the situation, neither the state nor local governments have the resources to conduct a removal action at the Site.

III. THREATS TO PUBLIC HEALTH OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

The conditions remaining at the Site present a substantial threat to the public health or welfare, and the environment, and meet the criteria for a time-critical removal action, pursuant to the NCP at 40 C.F.R. § 300.415(b)(1), based on the following factors in 40 CFR § 300.415(b)(2):

1. Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants

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Analytical results indicate that hazardous substances (TCE), as defined by CERCLA § 101(14) are present and represents an actual or potential exposure threat to nearby human populations. Concentrations of the hazardous substance exceed relevant screening or regulatory levels.

Trex Properties submitted a report summarizing the 2015 activities on March 23, 2016 [Administrative Record Item #10]. The report documented levels of TCE in the sub-slab vapor as high as 8,240,000 pz/m3 [1,533,000 ppbv]. For comparison, the MDHHS health based screening level and EPA's RML for a commercial building's soil vapor is 54 ppbv. The level of TCE found in the sub-slab soil vapor was over 28,000 times higher than these health based screening levels.

The same report also documented levels of TCE in the soil as high as 155,000 parts per million (ppm) approximately 15 feet outside the south wall of the building. This level exceeds the MDEQ's Residential Soil Volatilization to Indoor Air Inhalation Criteria of 1000 ppb by 155,000 times.

This same report documented levels of TCE in the groundwater as high as 88,600 jag/L, approximately one foot away from the east wall of the building. This level of TCE exceeds the MDEQ's Residential Groundwater Volatilization to Indoor Air Inhalation Criteria of 2,200 [ig/L by over 40 times. Similarly, the level of TCE documented in the groundwater exceeds EPA's Removal Management Level (RML) of 22 lig/L by more than 4,000 times.

On June 8, 2016, the EPA in collaboration with the MDEQ collected 12 indoor air samples at the Site and surrounding commercial businesses. Laboratory analysis of the samples concluded that three samples were above the MDHHS's Commercial Indoor Air Action Level for TCE of 1.6 ppbv. All three exceedances were in the building at the Site. The results were 35 ppbv, 130 ppbv, and 220 ppbv. These levels are between 21 and 137 times higher than the MDHHS's Commercial Indoor Air Action Level for TCE.

The EPA, the MDEQ and Trex Properties have conducted vapor intrusion pathway sampling and have documented the TCE exceedances at the Site.

The Trex Properties Grand Rapids Vapor Intrusion Conceptual Site Model (CSM) illustrating a completed exposure pathway for TCE, is presented below.

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Indoor Air

MEIN NI MINT IP

Vadose Zone Soil Gas

}Soil and Groundwater Contamination

Groundwater — Maximum TCE = 88,600 ug/L

Potential Exposure Pathway

Soil Gas — Maximum TCE 1,533,000 ppbv

Soil — Maximum TCE .-155,000 mg/kg

Indoor Air — Maximum TCE = 220 ppbv

Commercial/Industrial Worker Resident Living over Plume Working over Plume Basement or Crawl Space Without Basement

There is actual vapor intrusion exposure occurring and there is a potential for additional vapor intrusion to occur at this Site.

TCE is a hazardous substance within the meaning of Section 101(14) of CERCLA because it is listed at 40 C.F.R. § 302.4. Historical groundwater, soil and sub-slab sampling, along with the MDEQ and the EPA indoor air sampling results indicate that TCE vapors are entering the Trex Properties Site building at levels that the MDHHS considers harmful to human health'. TCE is a man-made chemical that is widely used as a cleaner to remove grease from metal parts. TCE is a nonflammable, colorless liquid with a sweet odor.

TCE in the groundwater, soil, soil vapor and indoor air has been documented. TCE in the indoor air can be inhaled by people working inside the Site building and also potentially in neighboring buildings.

Rain water runoff and infiltration into soil and groundwater could cause additional migration of VOCs off Site, into the nearby Grand River. Groundwater flow is estimated to flow west towards the Grand River, which is only 1,750 feet from the Site.

See health action levels listed above provided by the MDHHS.

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According to the Agency for Toxic Substance and Disease Registry toxicological effects of TCE are as follows:

Breathing small amounts of TCE may cause headaches, lung irritation, dizziness, poor coordination, and difficulty concentrating. Breathing large amounts of TCE may cause impaired heart function, unconsciousness, and death. Breathing it for long periods may cause nerve, kidney, and liver damage. Drinking large amounts of TCE may cause nausea, liver damage, unconsciousness, impaired heart function, or death. Drinking small amounts of TCE for long periods may cause liver and kidney damage, impaired immune system function, and impaired fetal development in pregnant women, although the extent of some of these effects is not yet clear. Skin contact with TCE for short periods may cause skin rashes. Some studies of people exposed over long periods to high levels of TCE in drinking water or in workplace air have found evidence of increased cancer. In its 9th Report on Carcinogens, the National Toxicology Program (NTP) determined that trichloroethylene is "reasonably anticipated to be a human carcinogen." The International Agency for Research on Cancer (IARC) has determined that trichloroethylene is "probably carcinogenic to humans" [Administrative Record Item #9].

2. Actual or potential contamination of drinking water supplies or sensitive ecosystems

Analytical results document TCE in the groundwater at the Site. According to the Grand Rapids City Water Department Manager, hookup to City water is optional in Grand Rapids. Because the plume of TCE in the groundwater is not delineated, it is possible that businesses or residences could be using the groundwater. Therefore, potential for contamination of drinking water exists.

3. High levels of hazardous substances, pollutants, or contaminants in soils largely at or near the surface that may migrate

TCE was detected in subsurface soils above screening or regulatory levels and in groundwater, indicating that migration from soil to groundwater is occurring. The analytical results indicated that the vapor intrusion pathway is complete and there is need for additional assessment at nearby businesses. Shallow groundwater flows to the west towards the Grand River. TCE was also documented in soil gas above screening levels. Volatilization of hazardous substances in the soil and groundwater may be a threat to nearby workers based on concentrations in soil gas samples as described above. The "Multiple Lines of Evidence Approach" outlined in the Region 5 Vapor Intrusion Guidebook (EPA, 2010) indicates that in this case, groundwater is known to be contaminated with TCE in a plume that is not fully delineated, therefore collection of soil gas samples to determine if vapor intrusion is a potential problem above the plume is recommended.

Vapor intrusion may cause potential exposure to hazardous substances by migrating to nearby human populations. Commercial and industrial properties are located in and along the direction of anticipated groundwater flow.

4. Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released

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Grand Rapids experiences 32 inches of precipitation per year. The hazardous substances located on Site are likely leachable, as indicated by their presence in surface soil, subsurface soil and groundwater. Rain, melting snow, and flood waters all have the potential to cause additional releases and off Site migration of hazardous substances.

5. The availability of other appropriate Federal or state response mechanisms to respond to the release

Local and State agencies do not have the resources to respond to this Site. In an email dated June 7, 2016, the MDHHS requested assistance from the EPA Removal Branch in addressing contamination at the Site.

IV. ENDANGERMENT DETERMINATION

Given the conditions at the Site, the nature of the known and suspected hazardous substances on Site, and the potential exposure pathways described in Sections II and III above, actual or threatened releases of hazardous substances from the Site, if not addressed by implementing the response actions selected in this Action Memorandum, may present an imminent and substantial endangerment to public health, or welfare, or the environment.

V. PROPOSED ACTIONS

A. Proposed Actions

1. Proposed action description

The response actions described in this memorandum directly address actual or potential releases of hazardous substances on the Site, which may pose an imminent and substantial endangerment to public health, or welfare, or the environment. Trex has already begun removal efforts to mitigate TCE vapors at the Site. Those efforts have included 1) Installation of a sub-slab depressurization system; 2) Installation of carbon filtration; 3) Sealing of basement cracks; 4) Installation of exhaust fans; and 5) Reconfiguration of the ventilation system.

Removal activities going forward will include:

1. Develop and implement a Site Specific Health and Safety Plan

2. Develop and implement a Site Specific Work Plan

3. Investigate and characterize the extent of TCE and other associated contamination in the soil both on and off-site

4. Investigate and characterize the extent of TCE and other associated contamination in the groundwater both on and off-site

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5. Investigate storm sewers and outfalls for TCE and other associated contamination

6. Perform removal of the TCE source soils and contaminated groundwater

7. Perform sub-slab soil vapor sampling at other off-site potentially impacted buildings

8. Install vapor mitigation systems at on and off-site impacted properties with elevated sub-slab and/or indoor air levels of TCE and other associated contamination

9. Perform indoor air sampling at buildings with sub-slab levels of TCE and other associated contamination

10. Perform an investigation of groundwater usage in the area potentially affected by the TCE contamination to determine if contaminated groundwater is being used for drinking

11. Ensure that all hazardous substances, pollutants or contaminants sent off-site are treated, stored, and/or disposed of in accordance with the EPA Off-Site Rule, 40 C.F.R. § 300.440.

EPA's removal action is being conducted in a manner not inconsistent with the NCP. The OSC initiated planning provisions for post-removal Site control consistent with the provisions of Section 300.415(1) of the NCP. Removal of hazardous material is expected to eliminate the need for post-removal Site control.

The response actions described in this memorandum directly address actual or threatened releases of hazardous substances, pollutants or contaminants at the facility which may pose an imminent and substantial endangerment to public health and safety, and to the environment. These response actions do not impose a burden on the affected property disproportionate to the extent to which that property contributes to the conditions being addressed.

1. Contribution to remedial performance

The proposed removal action at the Site will not impede future actions based on available information.

2. Engineering Evaluation/Cost Analysis (EE/CA)

Not Applicable

3. Applicable or relevant and appropriate requirements (ARARs)

All applicable, relevant and appropriate requirements (ARARs) of federal and State law will be complied with, to the extent practicable, considering the exigencies of the circumstances. On

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July 6, 2016, EPA sent a letter to Joe Victory of the MDEQ to request Michigan ARARs [Administrative Record Item #19]. The MDEQ responded on July 8, 2016 with all the parts of Public Act 451 [Administrative Record Item #20]. MDEQ is currently working on a response that encompasses direct citations of state laws and rules. MDHHS provided the acceptable TCE vapor levels of 1.6 ppbv.

Federal

49 U.S.C. § 5101 et seq. regulates the transportation of hazardous waste and hazardous substances by aircraft, railcars, vessels, and motor vehicles. It is applicable if hazardous materials are transported to or from a site. No other chemical-specific, performance, or location-specific requirements were found.

State

EPA is currently awaiting MDEQ's ARARs. EPA will continue to use the MDHHS's indoor air number of 1.6 ppbv.

4. Project Schedule

The removal should be completed within 360 days of approval of the work plan.

Estimated Costs

Not available, Enforcement Action Memorandum

A. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Given the conditions at the Site, the nature of the known and suspected hazardous substances on Site, and the potential exposure pathways described in Sections II and III above, actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the response actions selected in this memorandum, may present an imminent and substantial endangerment to public health, or welfare, or the environment.

B. OUTSTANDING POLICY ISSUES

Not Applicable.

C. ENFORCEMENT

For administrative purposes, information concerning the enforcement strategy for this Site is contained in the Enforcement Confidential Addendum'.

'Neither the lack of a total cost estimate nor deviation of actual total costs from this estimate will affect the United States' right to cost recovery.

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D. RECOMMENDATION

This decision document represents the selected removal action for the Trex Properties Grand Rapids Site in Grand Rapids, Kent County, Michigan developed in accordance with CERCLA, as amended, and is not inconsistent with the NCP. This decision is based on the administrative record for the Site (Attachment 1). Conditions at the Site meet the NCP criteria at 40 C.F.R. § 300.415(b) for a removal action, and I recommend your approval of the removal action proposed in this Action Memorandum. Region 5 expects that the PRP will perform the removal action under the oversight of the OSC.

You may indicate your proval by signi g below.

Approve:

Dougl Bal otti, Acting Director Super und Division

Disapprove: Douglas Ballotti, Acting Director Superfund Division

Enforcement Addendum

Attachments: 1. Administrative Record Index 2. Region 5 EJ Analysis 3. Maps

cc: P. Easter, EPA HQ (Easter.patrick@Epa.gov) B. Schlieger, EPA HQ (Schlieger.brian@Epa.gov) Josh Woodyard, EPA HQ (Woodyard.joshua@Epa.gov) L. Nelson, U.S. DOI, w/o Enf. Addendum, ( Lindy_Nelson@ios.doi.gov) Keith Creagh, Director, MDEQ, w/o Enf. Addendum (creaghk@michigan.gov) Bill Schuette, Michigan AG, w/o Enf. Addendum (SchuetteB@michigan.gov) J. Walczak, MDEQ, w/o Enf. Addendum (walczakj@michigan.gov)

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Date

BCC PAGE HAS BEEN REDACTED

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ENFORCEMENT ADDENDUM

HAS BEEN REDACTED – THREE PAGES

ENFORCEMENT CONFIDENTIAL

NOT SUBJECT TO DISCOVERY

FOIA EXEMPT

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ATTACIDIENT II

U.S. ENVIRONMENTAL PROTECTION AGENCY REMOVAL ACTION

ADMINISTRATIVE RECORD FOR THE

TREX PROPERTIES GRAND RAPIDS SITE GRAND RAPIDS, KENT COUNTY, MICHIGAN

ORIGINAL JULY, 2016

NO, SENIS ID DATE

1 927952 12(1716

429035 6147

429019 5f1Si8S

4 429036 725188

5 429024 31.31I89

6 429071 7/190

7 429016 1V94

MDEQ

MDEQ

U.S. EPA

Daily, D.; MDEQ

Public

TTILEDESC'RIPTION PACES

1986 Remaril Action 11 Documentation

Letter re: Items Disctrased during Hazard= Waste Compliance Invection

Potential Hazard= Waste Site 11 Pre:railway Azisessorent

Letter re: C-onfinnation of 1 Meeting of July 19,1988

Final Site Invwtigation Report for 40 Gold Shield Solvents

Plan of Closure for Hazardous 120 Waste Storage Units

Prelitukury Asse=enfilisual 73 Site Inspection Report

Site Investigation and Site- 350 Specific Analysis Report -Deirers Corporation

ToxFAQs Fact Sheet - 2 Trichloroethylene - CAS 479-01-6

927953 1:9104 Craig, D., Demers. Corporation,

9 922665 5/1)15 ATSDR

AUTHOR RECIPIENT

Detrex Copraration File

Delaaker, D.. Burin, S., Gold MDEQ Shield Solvents,

Inc.

Johason N., File IvIDEQ

Hoffmarr, Gun C., Darer NIDEQ Chemical

Indasuies, Inc.

Conestoga Rovers & Associates

Conestoga Rovers & Associates

PRC Environmental Management Inc.

10 927948 3.1)16 Enriro Anal-yam Trex Properties, RCRA Facility Investigation 347 Group II.0 Rout for the Foerra Detest

Golashield Facility

17

NO. SEMS ID DATE AUTHOR RECIPIENT PAGES TITLEDESCRIPTIO.N

11 c27;.77 44i1 McCabe, J., MDEQ

Craig, D., Eirdro Analyncs Grog.

Letter re: Request to Implement Presumptive .Mitieation for Vapor Iritrusion

12 927954 6616 Victory. L. MDEQ PowerPoint Presentation - Former 7 Ire-it Facility, Grand Rapids. MI

13 927951 6:716 Groessch, K_, 3,1ichigan Deparmient of

Mankawski, M., U.S.. EPA

Emall re: Request for 'U.S. EPA Assistance at 312 Ellsworth Ave., Grand PApids

4

Health and Izrinvrrt Serdces

14 92'7950 61446 Quisele, Michigan

London. A.„ Kent C ounty Health

LeTtE.'.7 Tmn-i7o.nt Publ.: 'Health 31 Hazard a: n Ellsworth

Department of DepartmArt Grand Rapids Health and Fry-0v, Serdces

15 494955 615;16 Lippert J., 1J3 • Distribution Lis: Pollurion Repor: .:POLF'..EP) I - 9 EPA Lliti31

ld 917055 6115/16 Hornell, Tetra File Indoor Air Soripling Data Tech

17 508775 61616 El-Zeui. I., U.S.. Bolin. P., Fausone General Nodce Letter 7:07 I-TeX EPA Bohn LLP Properties LLC"

18 927947 6301.6 Lippert, I. US Distribution Us: Polltinon Repotr, (POLP.EP) 2 - EPA PPS' Removal Acton. Continues

19 927949 71616 Lippert; US. EPA

lactory, 3., 1),IDEQ Letter re: Request for AFAR for the Treat Properties Site

1

20 928895 7,4116 Victory, L. MDEQ Lippert; T., U.S. Prali I re: AP.AF,s for the flex 14 Properties Site trAPARs table attached)

EPA

21 Lippert:J.; U.S. EPA

Ballotti, D., U.S. EPA

Action Memorandum. re. Request for a Time-Critica3 Romr

Action at the Tres; Properties Grand Rapids Site (PENDDIG)

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ATTACHMENT 2

ENVIRONMENTAL JUSTICE ANALYSIS

AUGUST 2016

EJSCREEN Report for 1 mile Ring Centered at 42_857379;85.673333, MICHIGAN, EPA Region 5

Approximate Population: 14080

Tres

Selected Variables Raw

Data

State

Avg.

%de in

State _

EPA Region

Avg.

%lie in EPA

Region

USA

Avg.

%ire in

USA

Environmental Indicators

ParticuIate Matter (PM IS is tig/mt'? 10..4 0.75 75 10.8 34 078 83

Ozone (RA) 43.1 44.7 18 44.4 38 48.1 30

NATA Diesel PM legrml. 1.73 0.727 91 0.712 90-95th 0.824 80-90th

NATA Cancer Risk tilifefiree risk per million). 60 43 83 42 80-90th 49 70-1301h

NATA Respiratory Hazard Index' 2.5 1.5 83 1.5 80-85th 2,3 00-70th

NATA Neurological Hazard Index 0.391 0.058 88 0.087 80-90th 0.053 80-90th

Traffic Proximity and Volume (daily traffic courtudisno: to road! 380 79 zie CD - ' 110 94

Lead Paint Indicator Pm-1.960 Housing) 0.72 0.39 80 0.4 80 0.3 87

NPL Proximity te counsikrrt di=rtee) 0.32 0.095 94 0.038 Z5 0.0945 ;5

RMP Proximity (facility oountflun dironre) 0.55 0.21 90 0.33 83 0.31 85

TSDF Proximity (Natty courttAnt di=noe) 0.013 0.063 33 0.051 27 0.054 35

Water Discharger Proximity (facility cri=nce) 0.13 0.19 ' _ 0.23 95 0_25 91

Demographic Indicators

Demographic Index 58% 29% 87 28% 33 35% 81

Minority Population 49% 23% 84 24% 83 38% Oil

Low Income Population 67% 35% 90 32% 92 34% 91

Linguistically Isolated Population a% 2% 91 2% ea 5% 74

Population With Less Than High School Education 22% 11% 89 12% St 14% 77

Population Under S years of age 7% 0% 83 13% 53 7% ea

Population over 64 years of age 6% 14% 13 13% 113 13% 19

• The Naerthat-Seate Atr Twits Assesswers EPA's ongoirg, earrprehvrive tvaluaftwi of r toxics in the United States EPA devxlopred the tiATA ta prioritize or torics.emi=ion sources, and lomiorr. of interest for further ttudt. I: is important to remember that NATA prorrr;des broa4 estimates OF ke Ith risks ther geographic areas &the courrtr,t. not deEnieVe titkt o esiFt.s trtetv'th.rals or lo=tions. MOM ireormatian on the NATA a,olscian be Found at• httpeliwww.epa.gorwtmfatorfnatamarru'indec borrl

For additional information, see: www.epa.govienvironmentaljustice

EISCREEN is a screenirg tool or pre-Pete:10,d use or4 It ca, help identif,r areas th2t IV12Y 1.1arrarte additional conoderafor, analysis, or outreach. It does not prthide a oasrls for decisiowirrraleing, but it !may help itentify potential areas of Er concern iJoers' :Kau ld lieep hr rnknd that r„creeringtoole are SiibieCt to sulz-tandal unceralnry in their dentoerwolik and enyironm;ental data. parPOZIarly when tooWng at -small pograpbtc areas Irrpo,tant atoeats aid tirxertat bees appty so this Ix:reenter-level leforrnasior, sots is rrrarrtia to Lindero/anti the herimbors en appropriate ; ..rrterpretabarp and ipprti ins of these irtoi=tors. Please see EJSCREEN slocurrertmton for else-boon of these isaae tteibre wirs reports Its stereening toot ettaes nos prosee ciata on every environmental irt,pact and ternogratthic factor that may be rele,rant to a parbo..tar tocation. EISCREEN outp.ds should be supp4m.nted with addltional information and local knowledge before taklng thy ;than to address potential El concerns.

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19

DATE; 12t2:2315 Topographic Map

Trex Properties, LLC FIG. 500

312 SW Ellsworth Av., Grand Rapids, MI

BY: KKT

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Legend

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ATTACHMENT 3

SITE LOCATION, LAYOUT, AND SAMPLE LOCATION MAPS

20

FORMER DRUM STORAGE AREA N0.2 (PAW 4)

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FORMER DRUM STORAGE AREA NO3 (SOW 8)

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Trex Properties Grand Rapids 312 Ellsworth Aliti

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Figure 5 Indoor-Air Sampling Locations

at the Source Property

Pripared For. EPA I thsp.aso %he Tech, Int.

Legend

ni 1st floor Air Santo Location

• 2nd SoorAir Sample Locaton

Basement At Sam* Imam

II Grab Air Sample Location

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22