UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5

77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590 uS EPA RECORDS CENTER REGION 5

495075

REPLY TO THE ATTENTION OF:

MEMORANDUM

SUBJECT: Enforcement Action Memorandum — Determination of Threat to Public Health and the Environment at the Park Avenue $2.75 Cleaners Site, Canton, Wayne County, Michigan 48188 (Site ID # C5BZ)

FROM: Brian M. Kelly, 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 determination of an imminent and substantial threat to public health and the environment posed by the release of dry cleaning solvents and breakdown products, including perchloroethylene (PCE), trichloroethene (TCE), cis-1,2-dichloroethene (DCE), and vinyl chloride (VC). Levels in the breathing zone and sub-slab in commercial spaces have been found above both action levels and trigger levels (see Table 1) set by the Michigan Department of Health and Human Services (MDHHS), at the Park Avenue $2.75 Cleaners Site (site).' The site is an active dry cleaner in the Cherry Hill Court Shopping Center, with an address of 260 South Lilley Road, Canton, Wayne County, Michigan 48188.

Perchloroethylene (PCE), trichloroethene (TCE), cis-1,2-dichloroethene (aka 1,2- Dichloroethylene) (DCE), and vinyl chloride (VC) are listed as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance at 40 C.F.R. §302.4.

'According a September 7, 2016 memorandum from MDHHS to EPA, at this site no further action is required if sub-slab sampling result is below action levels, indoor air must be collected if sub-slab sampling result is above action levels, and mitigation is required if indoor air sampling result is above action levels. Evacuation is required if indoor air sampling result is above trigger levels.

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

The proposed removal of hazardous substances would be taken pursuant to Section 106(a) of 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: Park Avenue $2.75 Cleaners Site Superfund Site ID C5BZ CERCLIS ID: MIN000506287 Site Location: 260 South Lilley Road, Canton, Wayne County, Michigan 48188 Lat/Long: 42.3071358, -83.457897 RCRA ID: N/A State ID: None NPL Status: Non NPL Category: CERCLA Time-Critical

A. Site Description

1. Removal site evaluation

On June 21, 2016, MDHHS requested emergency assistance from the Environmental Protection Agency (EPA) after indoor air sampling results from the pet groomer located adjacent to the dry cleaner at the site came back at 540 ug/m3 PCE. The MDHHS' PCE trigger level for indoor air requiring evacuation is 470 ug/m3 [Admin Record Item 8] the Removal the Removal Management Level (RML) is 530 ug/m3.

Between June 21 and continuing to the present, EPA has been overseeing Antea Group's assessment and sampling. Immediate actions involved the suspension of dry cleaning work, installation of exhaust units, optimization of air flow, and sampling of the indoor air and sub-slab soil gas probe/vapor monitoring points (vapor pins). The EPA Environmental Response Team is assisting with technical direction.

Indoor Air Samples

Indoor air samples collected on June 22, 2016 from each business showed solvent levels (PCE, TCE, DCE, and VC) below MDHHS' action and trigger levels [Admin Record Items 8 and 11]. These lower levels were likely due to the suspension of active dry cleaning after the initial indoor air samples at the site were analyzed.

Sub-Slab Soil Gas Samples

Subslab soil gas samples collected on July 15, 2016 from three vapor pins installed by Antea Group between the shopping center at the site and nearby residential homes showed solvent levels (PCE, TCE, DCE, and VC) below MDHHS' subslab soil gas action and trigger levels.

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Subslab soil gas samples collected between July 15 and 22, 2016 from three vapor pins installed by Antea Group in three businesses at the site showed solvent levels (PCE) as high as 2,100,000 ug/m3 —far above the MDHHS action level (5,800 ug/m3) requiring collection of indoor air.

MDHHS Action Levels and Trigger Table 1

Levels (Commercial Spaces) ug/m^3

EPA Removal Management

Levels Sub-slab

cis-1,2-dichloroethene (DCE) Action - 1,200 Trigger - 3,500 N/A

perchloroethylene (PCE) Action - 5,800 Trigger — 16,000 18,000

trichloroethene (TCE) Action - 290 Trigger - 880 290

Exceedances of MDHHS Action and Trigger Levels for Sub-Slab Soil Gas *also exceeds RML

cis-1,2- dichloroethene (DCE)

perchloroethylene (PCE)

trichloroethene (TCE)

Rite AID SVMP -19 17,000 2,100,000* 2,400* Dry Cleaner SVMP-3 22,000 11,000 1,900* Dry Cleaner SVMP-16 24,000* Dry Cleaner SVMP-17 29,000* 650* Dry Cleaner SVMP-18 1,600 1,100* Pet Groomer SVMP-13 430

2. Physical location

The dry cleaner is located in the Cherry Hill Court Shopping Center, between a Rite Aid and a pet groomer. To the west are residential homes, to the north are stoun water retention ponds and Cherry Hill Road, to the east are parking lots and South Lilly Road, and to the south are commercial businesses.

An Environmental Justice (EJ) analysis for the site was conducted. Screening of the surrounding area was done with 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 low potential for EJ concerns at this location.

3. Site Characteristics

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Soil and air samples collected between June and August 2016, along with previous investigative work indicate the release is limited to soils under the dry cleaner, north to the Rite Aid, and south to the pet groomer. It is likely the solvents migrated north and south in the buildings footprint, while being confined by natural clay to the east and west.

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

The release of TCE, PCE, and DCE above action and trigger levels set by MDHHS, has been documented in the samples listed on the table above.

The Rite Aid, dry cleaner, and pet groomer are operating businesses and used by the public. Perchloroethylene, vinyl chloride, trichloroethene, and cis-1,2-dichloroethene are listed as CERCLA hazardous substance at 40 C.F.R. § 302.4.

5. NPL status

The site is not on the NPL.

6. Maps, pictures and other graphic representations

Attachments 4 and 5 show the location and photos of the site.

B. Other Actions to Date

1. Previous actions

The shopping center was built in 1997 with the dry cleaner opening about a year later. In 2005, as part of a financial transaction, a Phase I Environmental Site Assessment was conducted by Land America Assessment Corporation. The Phase I concluded the dry cleaning operations of the Park Avenue $2.25 Cleaners (now Park Avenue $2.75 Cleaners) warranted a Phase II investigation.

In January 2006, a Phase II Assessment was conducted to address possible environmental concerns associated with the dry cleaner. The Phase II investigation established that a dry cleaning solvent containing PCE is used at this facility. PCE product and waste generated as a result of the dry cleaning process are stored onsite in 30-gallon drums on pallets until picked up by Safety Kleen. The report noted that there was minimal staining on the epoxy coated concrete floor; however, the epoxy coating was breached in several areas. Due to the ability of PCE to penetrate concrete in those areas, the potential for PCE contamination was considered a Recognized Environmental Condition (REC) - a terms used in Phase I Environmental Site Assessments to identify the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, ground water, or surface water of the property.

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Soil samples obtained under the building exceeded Michigan Part 201 criteria for drinking water protection and volatilization to indoor air. The Phase II recommended that a release be reported to the Michigan Department of Environmental Quality (MDEQ), the concrete floor be resealed with a coat of epoxy, and remedial action be perfonned.

In August 2006, Delta Environmental Consultants (now Antea Group), completed a Site Assessment, which concluded that the soil impacted with PCE and its breakdown products with concentrations above criteria was limited to the fill material immediately below the concrete floor under the dry cleaning machines.

In October 2006, the Park Avenue $2.75 cleaners reported to the MDEQ a release of ten gallons of PCE.

In 2009, a soil vapor extraction system (SVE) was installed, but due to the moisture content in the soil material, the air flow was restricted, and it was ultimately unsuccessful in remediating the solvent release. In 2010, a low-vacuum radon blower was installed to vent the vapors from below the floor.

Between 2011 and 2014, work plans were developed and reviewed with alternating approaches and assessment activities.

In 2015, the Park Avenue $2.75 Cleaners consultant, Antea Group, completed assessment activities that identified groundwater exceedances of MDEQ screening levels. Soil gas probe/vapor installed at this time (vapor pins) did not show exceedances of screening levels - likely due to vapor pin leaks.

In June 2016, after indoor air samples exceeded the MDHHS trigger level for evacuations, EPA assistance was requested. [Admin Record Items 7 and 12]

2. Current actions

The dry cleaner's consultant, Antea Group, is actively investigating the release. A draft assessment plan was approved by EPA [Admin Record Item 9].

State and Local Authorities' Roles

1. State and local actions to date

MDEQ has been working with the dry cleaner since 2006, with the finding of a potential imminent and substantial threat from vapor intrusion, MDEQ and MDHHS have requested EPA assistance.

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.

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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):

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

June 16, 2016 indoor air sampling showed 540 ug/m3 PCE (trigger level 470 ug/m3). Resampling of indoor air later in June 2016 no longer showed exceedances for indoor air at the site.

Twelve samples (3 DCE, 4 PCE, 5 TCE) collected in July 2016 from the sub-slab of the businesses exceed MDHHS action level for indoor air sampling and analysis. The businesses are open and used daily by the public, workers, and animals at the pet groomers. Given the high levels of TCE, PCE and DCE found in soil gas at the site, it is likely the solvents will migrate from sub-slab to the ambient air if action is not taken.

A summary of Agency for Toxic Substance and Disease Registry (ATSDR) ToxFAQs list significant human and animal risks when exposed to DCE, PCE, TCE and VC. Exposure may result in irregular heartbeat, kidney and liver damage, nausea, immune and nerve damage, and cancer [Admin Record Items 1-4].

Groundwater does not exist at the site.

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

No other federal or state response mechanism is available to respond in a timely manner given the exigencies of the situation.

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

I. Proposed action description

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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 endangemient to public health, or welfare, or the environment. Removal activities on site will include, but not limited to:

1) Investigating the extent of contamination in groundwater, subsurface soils, sub-slab, and ambient air related to dry cleaning operations;

2) Investigating and monitoring the vapor intrusion pathway;

3) Developing and submitting a work plan to mitigate contaminate pathways;

4) Implementing the work plan to mitigate the contaminate pathways;

5) Notifying adjacent parties of work to be perfotmed, milestones, and status of work; and

6) Ensuring 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

The removal action will be conducted in a manner not inconsistent with the NCP. The On-Scene Coordinator (OSC) will initiate planning for provisions of post-removal site control consistent with the provisions of 40 C.F.R. § 300.415(1).

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 endangetment 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.

2. Contribution to remedial performance

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

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

Not Applicable

4. 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 August 12, 2016, EPA sent a letter to Beth Vens of the MDEQ requesting Michigan ARARs.

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5. Project Schedule

The removal should be completed within 6 months of approval of the work plan.

Estimated Costs

Not available, Enforcement Action Memorandum

VI. 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.

VII. OUTSTANDING POLICY ISSUES

None.

VIII. ENFORCEMENT

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

IX. RECOMMENDATION

This decision document represents the selected removal action for the Park Avenue $2.75 Cleaners Site in Canton, Wayne 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 dry cleaner will perform the removal action under the oversight of the OSC.

'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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You may indicate yoijYproval by signi g below.

ougl Ballotti, Acting Director Da e Superfund Division

Approve:

Disapprove: Douglas Ballotti, Acting Director Superfund Division

Enforcement Addendum

Attachments: 1. Administrative Record Index 2. Region 5 EJ Analysis 3. Independent Government Cost Estimate 4. Site Location Map 5. Photographs 6. Detailed Cleanup Contractor Costs

Date

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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. DOT, w/o Enf. Addendum, ( Lindy_Nelson@ios.doi.gov) Heidi Grether, Director, MDEQ, w/o Enf. Addendum (GretherH@michigan.gov) Joe Walczak, MDEQ, w/o Enf. Addendum (walczakj@michigan.gov) Beth Vens, MDEQ, w/o Enf addendum (VENSB@michigan.gov)

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BCC PAGE HAS BEEN REDACTED

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ENFORCEMENT ADDENDUM

HAS BEEN REDACTED – FOUR PAGES

ENFORCEMENT CONFIDENTIAL

NOT SUBJECT TO DISCOVERY

FOIA EXEMPT

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ATTACHMENT 1

ADMINISTRATIVE RECORD FOR THE

PARK AVENUE $2.75 CLEANERS SITE CANTON, WAYNE COUNTY, MICHIGAN

ORIGINAL

SEPTEMBER, 2016

NO. SEMS ID DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES

1 928940 9/1/95 ATSDR Public ToxFAQs Fact Sheet - 1, 1 2 Dichloroethylene - CAS #75-35-4

ToxFAQs Fact Sheet - 2 Trichloroethylene - CAS #79-01-6

ToxFAQs Fact Sheet - Vinyl 2 Chloride - CAS #75-01-4

ToxFAQs Fact Sheet - 1, 1, 2 2, 2 Tetrachloroethane - CAS #79-34-5

2 922665 7/1/03 ATSDR Public

3 926968 7/1/06 ATSDR Public

4 928941 9/1/06 ATSDR Public

5 928943 9/21/15 Antea Group

6 928947 6/20/16 Brighton Analytical

7 928948 6/21/16

8 928945 7/21/16 Antea Group

9 928944 7/28/16 Koenigbauer, F., and Michalek, C., Antea Group

10 928946 7/29/16 Antea Group

File Project Summary to Date 5

Antea Group Results for Samples 4 Submitted on 6/17/2016

Kelly, B., U.S. Indoor Air Sample Results 1 EPA Map-June 2016

Kelly, B., U.S. Additional Assessment Work 17 EPA Plan

Kelly, B., U.S. Soil Vapor Analytical Results 1 EPA Map - July 2016

Quiggle, L., Mankowski, Michigan Dept. M., U.S. EPA of Health and Human Services

Email re: Requesting USEPA 2 Assistance for Rockov Cleaners

16

11 928942 8/5/16 Kelly, B., U.S. Distribution EPA List

12 929446 8/22/16 Owens, P., Kelly, B., U.S. MDEQ EPA

13 929445 9/7/16 Quiggle, L., Kelly, B., U.S. Michigan Dept. EPA of Health and Human Services

14 Kelly, B., U.S. Ballotti, D., EPA U.S. EPA

Pollution Report (POLREP) 4 1 - Initial

Letter re: Referral for 260 1 South Lilley Road

Memo re: Compiled MDEIHS 3 Recommendations for Park Avenue $2.75 Cleaners

Action Memorandum re: Request for a Time-Critical Removal Action at the Park Avenue $2.75 Cleaners Site (PENDING)

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ATTACHMENT 2

EJ ANALYSIS

PARK AVENUE $2.75 CLEANERS CANTON, WAYNE COUNTY, MICHIGAN

Sta

I.lhO EP

n4't

F1 tal Protection A.,Y

E1SCREEN Report (Version 2016)

0.5 mile Ring Centered at 42.307131,-83.457946, MICHIGAN, EPA Region 5

Approximate Population: 3,159

Input Area (sq. miles): 0.79

Selected Variables State

Percentile

EPA Region

Percentile

USA

Percentile

El Indexes

EJ Index for PM2.5 14 19 11

EJ Index for Ozone 15 18 12

EJ Index for NATA. Diesel PM 6 13 8

EJ Index for NATA` Air Toxics Cancer Risk 13 18 17

EJ Index for NATA* Respiratory Hazard Index e 16 13

EJ Index for Traffic Proximity and Volume 26 23 19

EJ Index for Lead Paint Indicator 69 69 48

El tndex for Superfund Proximity 37 37 28

EJ Index for RMP Proximity 1 3 1

El Index for Hazardous Waste Proximity 2 5 3

El Index for Water Discharger Proximity 30 38 28

inaex Tor me seiecteo Area Lomparea to All mopes olocKgroups in tne btate/Kegion/ub 109

75

EJ Indexes

State Percentile i,....,Regional Percentile USA Percentile

This report shows the values for environmental and demographic indicators and FJSCREEN indexes. It shows environmental and demographic raw data (e.g., the

estimated concentration of ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the

selected block grouper buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this

means that only 5 percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the

data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to this screening-level information, so it is

essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of

these issues before using reports.

August 12,2016 1/3

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ATTACHMENT 3

SITE LOCATION AND LAYOUT MAPS

19

SVMP-4 • SVMP-10

SVMP -16 Date 7/16/2016

1,600 4.100 1,100 15

cls-1,2-DCE PCE ICE

Vinyl Chloride

• SVMP-r, SVN..P- 1

SVMP-I 1 Date 7/16/2016

eis-1,2-DCE <24 PCE <41 ICE

Vinyl Chloride <15

g SVMP-12

SVMP-12 Date 7/15/2016

els-1.2-DCE <24 PCE <41 ICE <1.6

Vinyl CMorlide <15

SWAP 13

Vinyl Chloride <34

Date /15/2016 530

1200 430 <15

Dote 7/22/2018 <24

4,200 <2.6 <15

cle-1,2-DCE PCE

els-1,2-DGE PCE

ale-1,2-DCE PCE

<24 400 <1.6 <16

ICE TEE PLOT IMIE REVIEWED BY FKE NAME 07/27/16 MB 0e000v-2016 Vinyl Chloride

TEE Vinyl Chloride Vinyl Chloride anteagroup

Date 7/15/2016 PROJECT NO. PREPARED BY DRAWN BY 2/CG-173-2 FK DD

S 7V"P-21 Date /22/2016 ris-1,2-0CE 024

74 PCE TEE 6

15 Vinyl C e

• SVMP-8 (Outside of Building)

SVMP-21 UR—Y1-1,

Rite Aid

LEGEND

e SVE- I Soil Vapor Extraction Well

4-VP-I Vapor Monitoring Point

• SB-I Soil Boring Location (June 2005)

Expansion Joint in Concrete

0 Groundwater Monitoring Well

▪ Soil Vapor Monitoring Point

Sample ID Sample Date cis-1,2-Dichloroethene Tetrachloreethene Trichloroethene Vinyl Chloride

SVMP-20 7/15/2010 7/22/2016 I)

Date Date

SWAP-17

<85 ds-1,2-0CE SVMP-20 24 PCE

0i6-1,2425E 20,000 650

320 ICE

<1.6 111111 I) <53

PCE ICE

015 Vinyl Chloride

Vinyl Chloride

All concentrations in p /m3 unless otherwise specified

< Denotes not detected at or above laboratory reporting limit

I 20.000 I Result > SGvi-ss-nr criteria

SGyi-ss-or = HOED Soil Screening Values for Vapor Intrusion Shallow Gas (<1.5 meters) dated May 23, 2013

r°,<, )40 4t. fr 4E e)i 5,4-14,74 fr.pov•

woo" Existing DTE Transformer 23

re SVMP-0 5 T SVMP

Pet Groomers 010016 COMM AREA 0=00

SWAP 15 MP-

SVMP 1 ii0 . 0°. ,01,:tart e, I SVMP-3 66111001111

.

0,4 ii_46, _ mu,* waoem

--'.0 * , • sswei, wirhs uts

L'ir-2 SVMP-17

SVMP-13 SVMP-14•

41,611

SERAPE

SVMP-18 IOW =ME fLON

Dale els ,2-DCE

PCE ICE

Vinyl Chloride

• 06-3 SVMP-16

Rockov Cleaners

031 SVMP 19

7/22/2016 7,000

2,100,500 2,400 <650

• 95-19 • SVMP-7

SVMP 16 Date 7/22/2016 1 2413CE 064 PCE 24,000 TEE 34

SOIL VAPOR ANALYTICAL MAP DATA COLLECTED JULY 2016

ROCKOV CLEANERS 260 SOUTH LILLEY ROAD

CANTON, MICHIGAN

SVMP 17 Dale 7115/2010

cls- ,2-DCE <06 PCE 29,000 TEE 660

<53

Asphalt Parking Lot

Vinyl Chlxcde 10)

0 .45 I. 15

SCALE IN FEET

Vapor Pin Inside Rite Aid Waiting Room

SUMMA Canister inside Pet Groomers

ATTACHMENT 4

PHOTOGRAPHS

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