City of Wyandotte...Cleanup Summary Report . Former Detroit Tubular Rivet Facility . 1213 Grove Street ... 44265 Plymouth Oaks Blvd. Plymouth, MI 48170 T 734-455-8600 F 734-455-8608

City of Wyandotte

Cleanup Summary Report Former Detroit Tubular Rivet Facility

1213 Grove Street Wyandotte, Michigan

September 2019

Teamwork - Trust - Leadership Since 1927

44265 Plymouth Oaks Blvd. Plymouth, MI 48170

T 734-455-8600 F 734-455-8608

www.ttlassoc.com

September 20, 2019 Project No. 9158.08

Mr. Greg Mayhew, P.E. City Engineer City of Wyandotte 3200 Biddle Avenue, Suite 200 Wyandotte, Michigan 48192

Cleanup Summary Report Former Detroit Tubular Rivet Facility

1213 Grove Street Wyandotte, Michigan

Dear Mr. Mayhew:

The Cleanup Summary Report (CSR) prepared for the City of Wyandotte and the Downriver Community Conference Brownfield Consortium (DCCBC) by TTL Associates, Inc. (TTL) for the above-referenced site (Site) is enclosed. The remedial actions were completed in accordance with the terms of the U.S. EPA Brownfield Cleanup Revolving Loan Fund Sub-Grant Agreement between the City of Wyandotte and the DCCBC, as well as U.S. EPA and Michigan Department of Environment, Great Lakes, and Energy (EGLE) requirements and guidelines.

This CSR documents the removal of asbestos-containing building materials (ACMs) and hazardous/regulated materials from the interior of the site building in accordance with the approved Cleanup Work Plan. These remediation activities were conducted as part of the City of Wyandotte’s efforts to prepare the site for sale and renovation for light industrial reuse.

TTL appreciates the opportunity to continue to provide the City of Wyandotte and DCCBC with our engineering, consulting, and testing services. Should you have any questions or require additional information, please contact us at (734) 455-8600.

Sincerely,

TTL Associates, Inc.

Steven J. Gach, P.E. Robin J. Clark Senior Engineer Senior Scientist

cc: Paula Boase, DCCBC Brad Stimple, U.S. EPA

Enclosure V:\Plymouth\DCCBC\1213 Grove Wyandotte\2017\915808 Remediation Activities\Report\DCCBC Wyand Grove Cleanup Summary Report.doc

CLEANUP SUMMARY REPORT FORMER DETROIT TUBULAR RIVET FACILITY

1213 GROVE STREET WYANDOTTE, MICHIGAN

FOR

CITY OF WYANDOTTE 3200 BIDDLE AVENUE, SUITE 200

WYANDOTTE, MI 48192

SEPTEMBER 20, 2019 TTL PROJECT NO. 9158.08

TTL ASSOCIATES, INC. 44265 PLYMOUTH OAKS BOULEVARD

PLYMOUTH, MICHIGAN 48170 (734) 455-8600

FAX: (734) 455-8608

CSR 1213 Grove Street, Wyandotte, MI September 2019 TTL Project No. 9158.08 Page i

TABLE OF CONTENTS

Page No. 1.0 Introduction ...........................................................................................................................1

1.1 Site Description ................................................................................................................1 1.2 Site Background ...............................................................................................................1

1.3 Site Environmental Conditions ........................................................................................2 1.4 Objectives of the Remedial Actions ................................................................................2 2.0 Preliminary Activities ...........................................................................................................4 2.1 Analysis of Brownfield Cleanup Alternatives .................................................................4 2.2 Cleanup Work Plan ..........................................................................................................4 2.3 Community Relations Plan and Public Comment Process ..............................................5 2.4 Approval of Cleanup Work Plan......................................................................................5 2.5 Equivalency Memorandum ..............................................................................................5 2.6 Memorandum of Decision ...............................................................................................6 2.7 Response Activities Contractor Selection Process ..........................................................6 3.0 Interior Building Environmental Response Activities.......................................................7 3.1 Asbestos Abatement Activities ........................................................................................7 3.1.1 Asbestos Abatement Procedures ...........................................................................7 3.1.2 Summary of Asbestos-Containing Materials Removed ........................................8 3.1.3 Air Quality Monitoring Results .............................................................................8 3.1.4 Remaining Asbestos-Containing Materials ...........................................................9

3.2 Cleaning and Removal of Aboveground Storage Tanks..................................................9 3.3 Decontamination of Structural Steel and Ceiling in the Former Electroplating Portion of

the Building ...................................................................................................................10 3.4 Emptying, Power Washing, and Backfilling of Water-Filled Pits and Trenches ..........10 3.5 Cleaning and Removal of Remaining Wastewater Treatment Facility Equipment .......10 3.6 Removal/Disposal of Debris ..........................................................................................11 3.7 Power Washing/Cleaning Small Areas of Oily Sludge and Oil-Stained Concrete ........11 3.8 Waste Disposal Documentation .....................................................................................11

4.0 Summary and Conclusions ................................................................................................13 TABLE Table 1.0 ACM Removed from the Site FIGURES Figure 1.0 Site Location Map Figure 2.0 Site Diagram Figure 3.0 Building Interior Diagram

CSR 1213 Grove Street, Wyandotte, MI September 2019 TTL Project No. 9158.08 Page ii

APPENDICES Appendix A EGLE Notifications Appendix B TSP Certifications Appendix C TTL Certifications Appendix D Disposal Documentation Appendix E Air Quality Monitoring Results and Final Clearance Documentation

CSR 1213 Grove Street, Wyandotte, MI September 2019 TTL Project No. 9158.08 Page 1

1.0 INTRODUCTION This Cleanup Summary Report (CSR) documents the interior building remedial actions conducted at the former Detroit Tubular Rivet (DTR) facility located at 1213 Grove Street, Wyandotte, Michigan (Site) during March and April 2019. The remediation was funded through a U.S. EPA Brownfield Cleanup Revolving Loan Fund (RLF) grant awarded to the Downriver Community Conference Brownfield Consortium (DCCBC), who awarded a sub-grant to the City of Wyandotte (the City). 1.1 Site Description The Site is approximately 3.6 acres in area and consists of two parcels located at 1213 Grove Street, Wyandotte, Wayne County, Michigan (located in the southwest corner of Section 28, Township 3 South, Range 11 East). The Site is located on the south side of Grove Street and the east side of 13th Street. The Site currently contains a vacant, approximately 53,000 square foot, one-story, light industrial building, which includes offices, storage and manufacturing areas. Surface-level parking, two truck loading docks, and landscaped areas occupy the remainder of the Site. The Site is located in a fully developed area with a mixture of commercial and residential properties. The Site is surrounded by residential properties to the northwest, commercial properties to the north, City of Wyandotte Department of Public Works property to the east and south, a vacant commercial property to the southwest, and vacant land and a school to the west. Figure 1.0 is a Site location map. Figure 2.0 depicts the Site and the surrounding properties. 1.2 Site Background From at least 1937 to 1940, the southwestern portion of the Site was occupied by a residence; the remainder of the Site was unimproved. The Site was vacant of structures from the late 1940s until the development of the current light industrial/manufacturing building in 1963, with several subsequent building additions. DTR occupied the Site from 1963 until filing for bankruptcy in December 2010 and ceasing Site operations in August 2011. DTR manufactured bolts, nuts, rivets and other small parts, and provided electroplating services at the Site. The Site building has been vacant since August 2011. The City acquired the property through tax reversion following DTR’s bankruptcy. In January 2012, the Michigan Department of Environment, Great Lakes, and Energy (EGLE) identified that the Site was abandoned, with signs of trespassing, and requested assistance from the U.S. EPA to address the environmental hazards identified at the Site. U.S. EPA inspected the Site, found 300 drums, totes and small containers within the Site building and conducted waste sampling and characterization activities. Hazardous substances, including cyanide, acids and methylene chloride, were identified in the containers. U.S. EPA concluded that the Site posed an “imminent and substantial threat to human health and the environment” and initiated Time-Critical Removal Actions. The U.S. EPA removal actions, conducted in May/June 2012, included the segregation, sampling and off-site disposal of the drums and containers of waste, vacuuming and cleaning the plating trenches located in the southwest portion of the building, and the dismantling and off-site disposal of the overhead ventilation system, which had been caked with caustic residue.


U.S. EPA’s cleanup activities focused on the removal of imminent hazards posed by the drums/containers of abandoned materials in the building, and did not include a comprehensive cleanup of the Site. Therefore, residual impacts remained within and around the building, including: the secondary containment area around two 1,750-gallon oil aboveground storage tanks (ASTs) in the southeastern portion of the building; the southwestern portion of the building where plating operations had impacted the floor, pits, trenches, painted structural steel and ceiling; an abandoned wastewater treatment plant (WWTP) in the south-central portion of the facility; and oily sludge and oil-stained concrete in areas where equipment was formerly located. Figure 3.0 depicts the Site building interior prior to the RLF Grant-funded interior building remedial activities. 1.3 Site Environmental Conditions Several environmental investigations were conducted at the Site following the 2012 removal actions to identify potential environmental concerns in anticipation of sale and redevelopment of the Site. These assessments/surveys included Phase I and Phase II Environmental Site Assessments (ESAs), a National Emissions Standards for Hazardous Air Pollutants (NESHAP) Asbestos Survey, a Limited Lead-Based Paint (LBP) Survey, and a Limited Hazardous Materials (HAZMAT) Survey. Based on the January 2013 Phase II ESA field observations and analytical results, it appeared that there are minor impacts beneath the Site building that may be attributed to the former DTR operations; however, no evidence of impacts in excess of the applicable Michigan Public Act 451 of 1994, Part 201 (Part 201) criteria was identified beneath the building. Elevated metals concentrations in soil outside the southeastern portion of the building may be attributed to material or waste handling in this area by DTR; however, did not exceed the applicable Part 201 non-residential criteria. In August 2017, TTL completed an Asbestos, Limited LBP, and HAZMAT Survey of the Site. The Asbestos Survey identified asbestos-containing black mastic associated with various floor tiles and sheet flooring, although the associated floor tiles and sheet flooring were not identified as asbestos-containing. In addition, the following materials were assumed to be asbestos-containing: roofing materials, laboratory sink insulation, and two fire-rated doors. The Limited LBP Inspection identified non-intact LBP on two doors and floor striping. The HAZMAT Survey identified fluorescent light bulbs, mercury light bulbs, lighting ballasts, air conditioners, emergency lights, miscellaneous cleaners and paints, two 1,750-gallon oil ASTs (possible residues), and the abandoned WWTP (possible residues). 1.4 Objectives of the Remedial Actions The City’s overall objective is to return the Site, which has been vacant since 2011 and off of the City’s tax rolls since 2010, to productive light industrial use. The City’s remedial objective for this project was to prepare the Site building for sale by removing hazardous materials and mitigating existing hazardous conditions, to encourage investment and redevelopment by a private developer for light industrial use.


The following specific objectives were included in the RLF-funded interior building environmental response activities:

• Abatement/removal of approximately 2,725 square feet of asbestos-containing mastics associated with floor tiles and sheet flooring, and associated (non-ACM) resilient floor tile, located primarily in the northwestern, office area of the Site building.

• Cleaning and removal of the two abandoned 1,750-gallon oil ASTs that appeared to have been emptied, but not cleaned, and power washing the oily secondary containment that surrounds the ASTs.

• Ceiling tile removal (non-ACM), fluorescent lighting fixture and lamp removal, and power washing the structural steel and ceiling in the southwestern portion of the building where the plating operations were located.

• Emptying, power washing and backfilling the water-filled pits and trenches in the

southwestern, former plating area portion of the building.

• Cleaning and removal of the WWTP equipment at the Site.

• Removal/disposal of debris in the southeastern portion of the building, including empty drums, trash and miscellaneous items.

• Power washing/cleaning small areas of oily sludge and oil-stained concrete where equipment was formerly located.


2.0 PRELIMINARY ACTIVITIES In accordance with the requirements of the RLF Sub-Grant Agreement between the DCCBC and the City, and to meet U.S.EPA RLF grant requirements prior to conducting on-site remedial activities, the following documents were prepared and submitted to the U.S. EPA:

• Analysis of Brownfield Cleanup Alternatives • Cleanup Work Plan • Community Relations Plan • Equivalency Memorandum • Memorandum of Decision

Each of the documents played a role in establishing the plan to be used in remediating the Site to meet the stated objectives. Information regarding the documents is summarized below. 2.1 Analysis of Brownfield Cleanup Alternatives TTL prepared an Analysis of Brownfield Cleanup Alternatives (ABCA) for the remedial action activities on behalf of the City. The ABCA provided a summary of the environmental history and conditions of the Site, stated the remedial objectives, identified and evaluated potential remedial alternatives, and identified the recommended remediation alternative. Three alternatives were identified and evaluated:

• Alternative 1 – No Action • Alternative 2 – Building Interior Hazardous Materials Removal and Decontamination • Alternative 3 - Building Interior Hazardous Materials Removal and Decontamination and

Exterior Soil Remediation Based on the analysis within the ABCA, Alternative 2 was selected. Alternative 1 (no action) did not achieve the remedial objectives. Alternative 3 (building interior hazardous materials removal and decontamination, plus soil remediation outside the southeastern portion of the Site building) would meet the project objectives by mitigating human health and environmental risks posed by the ACMs and other hazardous materials within the building (the same as Alternative 2) and would also remediate impacted soils exceeding the Part 201 residential direct contact criteria. However, this alternative was estimated to cost $50,000 more than Alternative 2 and provided marginal additional benefit because the identified impacted soils do not exceed the Part 201 non-residential direct contact criteria applicable for the proposed use. 2.2 Cleanup Work Plan The Cleanup Work Plan (CWP) was developed following the completion of the ABCA and the selection of the remedial action alternative. The CWP included a summary of the environmental conditions at the Site and the remediation objectives, a detailed scope of work for the cleanup, and the estimated budget and schedule for the completion of the remediation.


2.3 Community Relations Plan and Public Comment Process A community involvement process was implemented to enable public input and comment in the decision-making process. The community involvement process included the development of a Community Relations Plan (CRP), public noticing of the availability of the Draft ABCA in November 2018, and a public hearing to discuss the Draft ABCA and the project. A public repository was established at the City of Wyandotte Engineering Department, located at 3200 Biddle Avenue in Wyandotte, Michigan, as a means of making the Draft ABCA, the Draft CWP, and other project documents, readily available for public review. Previous environmental documents for the Site were also available from the City. The public notice was prepared and published in a local newspaper (The News-Herald) on November 7, 2018. The public notice identified the location and availability of the project documents in the public repository, sought public comment on the project, and advertised the date, time and location of the public hearing. The public hearing was conducted at 7 pm on November 19, 2018, at the City of Wyandotte Engineering Department. The intent of the public hearing was to seek relevant public comment on the proposed environmental response activities (asbestos abatement, removal of hazardous/regulated materials and other hazards, and decontamination of building surfaces) for the project site. The 30-day public comment period concluded on December 7, 2018. No public comments were received. 2.4 Approval of Cleanup Work Plan Following the completion of the public comment period, the Draft ABCA and Draft CWP were finalized. The asbestos abatement activities are regulated by the EGLE, Air Quality Division (AQD), Asbestos Program. TTL provided a copy of the final CWP to the EGLE, AQD, Asbestos Program for review and comment prior to conducting the activities. The CWP included Asbestos Abatement Specifications for the project and noted that the Notice of Intent to Demolish/Renovate would be submitted once a licensed asbestos abatement contractor had been contracted and the abatement work had been scheduled. The EGLE AQD acknowledged receipt of the CWP, but provided no comments (EGLE approval was not required). Although the building interior environmental response activities were not regulated under Part 201, a copy of the CWP was also provided to EGLE, Remediation and Redevelopment Division (RRD). EGLE RRD indicated that the proposed remediation activities were not regulated under Part 201, and did not require EGLE RRD involvement or approval. Appendix A includes documentation of EGLE correspondence regarding the CWP. 2.5 Equivalency Memorandum The Equivalency Memorandum documented that the remedial activities would be conducted in general accordance with the requirements of the pertinent federal and state authorities.


2.6 Memorandum of Decision The DCCBC approved the selected remedial action for the Site in a February 2019 Memorandum of Decision (MOD) which was submitted to the U.S. EPA. The MOD also documented the DCCBC’s finding that the proposed response activities were selected and developed consistent with Michigan environmental regulations, and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA), and were consistent with the National Contingency Plan (NCP). These decisions were based upon the ABCA, the CWP, and other site documents. 2.7 Response Activities Contractor Selection Process The response activities contractor was selected through a solicitation and competitive bidding process advertised by the City on the BidNet internet site, as well as the City’s website. A bid-walk was conducted by the City with the interested contractors on December 11, 2018. The lowest price qualified bidder, TSP Services, Inc. (TSP) of Redford, Michigan, was selected as the response activities contractor for this project.


3.0 INTERIOR BUILDING ENVIRONMENTAL RESPONSE ACTIVITIES Interior building environmental response activities were completed in accordance with the CWP by TSP during March and April 2019. TTL oversaw the remedial activities on behalf of the City, conducted asbestos abatement oversight and air monitoring, and prepared documentation regarding the remedial activities. 3.1 Asbestos Abatement Activities Asbestos abatement activities were conducted by TSP in general accordance with the December 2018 CWP and the associated October 2018 Asbestos Abatement Specifications. All ACM identified for removal (approximately 2,725 square feet of ACM mastic associated with floor tile and sheet flooring) was abated. TSP is licensed by Michigan Department of Licensing and Regulatory Affairs (LARA) as an Asbestos Abatement Contractor. The asbestos abatement activities were conducted in accordance with U.S. EPA NESHAP and State of Michigan regulations and requirements. Prior to conducting the abatement activities, TSP submitted a Notification of Intent to Renovate/Demolish Form to the EGLE AQD and LARA, as required (Appendix A). TSP’s certifications are provided in Appendix B. Mr. Robert Serlin of TTL performed air quality monitoring and project oversight during the abatement activities and is certified by LARA as an Asbestos Contractor Supervisor. A copy of Mr. Serlin’s certification is included in Appendix C. The asbestos abatement activities were conducted from March 26, 2019 through March 29, 2019. 3.1.1 Asbestos Abatement Procedures The ACM mastic and the associated non-ACM floor tile, sheet flooring, and overlying carpet were removed in fully enclosed containments. The containments were constructed using polyethylene sheeting barrier enclosures around each work area. The work areas were posted and demarcated per Occupational Safety and Health Administration (OSHA) regulations. Negative pressure was maintained in the containments throughout the duration of abatement activities in each work area, as outlined in the Asbestos Abatement Specification and according to OSHA Asbestos in Construction regulations. TSP used hand-held tools to remove floor tile and carpet. Liquid mastic remover was used to dissolve the remaining ACM mastic on the underlying concrete floor into a residue and an absorbent was used to remove the residue. A small area of mastic was scraped by hand to complete the removal of the ACM. Asbestos abatement workers wore disposable protective suits, negative pressure air purifying respirators equipped with high efficiency particulate air (HEPA) filters, as well as hard hats, gloves, and steel toed shoes/boots when appropriate. The abatement contractor cleaned the work areas of dust, dirt, and debris before leaving the site. The ACM waste was double-bagged and loaded into a


dumpster double-lined with 6-mil poly sheeting for storage until removed from the site. TTL’s daily site activity logs are included in Appendix D. 3.1.2 Summary of Asbestos-Containing Materials Removed All of the ACM targeted for abatement was removed during the response activities, including approximately 2,725 square feet of identified ACM mastics, along with associated (non-ACM) resilient floor tiles and sheet flooring and overlying carpet, located primarily in the northwestern, office area of the Site building. The following ACM, identified during the August 2017 NESHAP Asbestos Survey, was removed during the abatement activities.

Table 1.0 ACM Removed from the Site

HSA Material Description Material Location Quantity

915806-04

Black mastic associated with 9” x 9” olive gray floor tile with

white specks (most under carpeting)

Workroom, Mailroom, Office 1, Office 2, Office 3, Office 4,

Mechanical area, Reception area, Office Hallways

1,570 sf

915806-05

Black mastic under 9” x 9” black floor tile with white

streaks and brown mastic (most under carpeting)

Restroom, Reception area 60 sf

915806-15 Black mastic under red sheet flooring with brown mastic Foyer 30 sf

915806-17 Black mastic under beige sheet flooring with yellow mastic Transition Hallway 60 sf

915806-21 Black mastic associated with 9” x 9” white floor tile with gray

specks Shipping Office 160 sf

915806-24 Black mastic associated with 12” x 12” dark gray floor tile with white and gray streaks

Laboratory 300 sf

915806-28 Black mastic associated with 12” x 12” gray floor tile

Women’s Locker Room, Men’s Locker Room 545 sf

sf: square feet The disposal of the ACM waste is discussed in Section 3.8.


3.1.3 Air Quality Monitoring Results TTL conducted air quality monitoring in and around the asbestos abatement work areas to demonstrate the effectiveness of the abatement contractor’s work practices and engineering controls throughout the period that asbestos abatement activities occurred. The air monitoring included background samples, environmental samples and clearance samples. The air sampling was conducted from March 25 through March 29, and on April 15, 2019. The air samples were analyzed by TTL in accordance with the National Institute for Occupational Safety and Health (NIOSH) 7400 Method for analysis by Phase Contrast Microscopy (PCM). Air quality monitoring sample results adjacent to the work areas during asbestos abatement activities were within acceptable U.S. EPA and Occupational Safety and Health Administration (OSHA) levels. The air monitoring results were less than the OSHA Permissible Exposure Limit (PEL) of 0.1 fibers per cubic centimeter of air (f/cc) by PCM. At the completion of asbestos abatement activities for each work area, TTL conducted a visual inspection to ensure all ACM, dust, and debris were removed. Upon completion of the successful visual inspection on April 15, 2019, TTL collected final air clearance samples. Final air clearance samples were analyzed on-site by TTL in accordance with the NIOSH 7400 Method. The final air clearance sample results were below the U.S. EPA final air clearance guideline of 0.01 f/cc. A summary of the air quality monitoring results is included in Appendix D; the final air clearance certificate is also provided in Appendix D. 3.1.4 Remaining Asbestos-Containing Materials All of the ACM targeted for abatement was removed from the site building. Additional building materials assumed to be ACM were identified during the August 2017 NESHAP Asbestos Survey, but were not included in the scope of work for this project. These materials include roofing materials throughout the building, one laboratory sink (assumed insulation), and two fire-rated doors. These materials should be properly handled and managed during future building renovation activities. 3.2 Cleaning and Removal of Aboveground Storage Tanks The two 1,750-gallon oil ASTs located within the southeastern portion of the Site building had been reported as emptied, but not cleaned, and were assumed to contain minor amounts of residual oil. However, when TSP accessed the AST interiors, each AST contained approximately 325 gallons of heavy, viscous sludge that had to be removed. The ASTs and associated piping were drained of residual oil and sludge and cleaned using high-pressure water and biodegradable detergent. The residual oil and sludge and the rinsate were collected using a vacuum tanker, characterized, and transported off-site for treatment/disposal at a licensed facility. Once cleaned, the ASTs and piping were dismantled, removed and recycled. Following the removal of the ASTs and piping, the oily secondary containment that surrounded the ASTs was cleaned using a high-pressure water and biodegradable detergent. The rinsate was


collected by a vacuum tanker truck and transported off-site for treatment/disposal. The transportation and disposal of the former AST contents/rinsate and containment rinsate is discussed in Section 3.8. 3.3 Decontamination of Structural Steel and Ceiling in the Former Electroplating Portion of Building The southwestern portion of the building formerly included electroplating operations. The painted structural steel and ceiling in this area had been affected by the caustic plating operations, with steel corrosion and considerable paint flaking. To permit decontamination of this area, certain ceiling materials (non-ACM) and fluorescent light fixtures were removed. The light fixtures and lamps were removed, packaged for shipping and transported off-site for recycling/disposal. After the removal of the fluorescent light fixtures and lamps, the structural steel, ceiling, and walls of this area were power washed from the ceiling down to the floor, to remove potential contaminants associated with the former plating operations, using high-pressure water and biodegradable detergent. The rinsate was collected using a vacuum tanker and transported for off-site disposal at a licensed treatment facility, as discussed in Section 3.8. 3.4 Emptying, Power Washing, and Backfilling of Water-Filled Pits and Trenches Pits and trenches in the southwestern portion of the Site building were formerly used to contain the overflow of solvents, plating chemicals, and water from the plating operations. The pits, trenches, and surrounding floors were severely pitted and corroded, likely due to the caustics used in the plating operations. The pits and trenches were emptied and cleaned using a high-pressure water and biodegradable detergent. The rinsate was collected with a vacuum tanker and transported to a licensed treatment/disposal facility, as discussed in Section 3.8. After the pits and trenches were cleaned, they were backfilled with approximately 20.67 tons of 21AA gravel, compacted in approximately one-foot lifts, and paved over with concrete to match the level of the surrounding floor. 3.5 Cleaning and Removal of Remaining Wastewater Treatment Facility Equipment The abandoned WWTP at the Site pretreated industrial wastewater from the plating operations prior to discharge to the municipal sanitary sewer. The remaining WWTP equipment was assumed to contain residual contaminants associated with the former plating operations wastewater. This equipment was cleaned, along with small areas of oily sludge and oil-stained concrete where the equipment was formerly located, using high-pressure water and biodegradable detergent. The rinsate was collected using a vacuum tanker and transported to an off-site disposal facility. Once cleaned, the equipment and piping were dismantled and prepared for disposal, as applicable, then transported to the disposal facility, as discussed in Section 3.8.


3.6 Removal/Disposal of Debris

Debris, empty drums, trash and miscellaneous items discarded in the southeastern portion of the building were characterized, placed in roll-off containers, and transported to the disposal facility, as discussed in Section 3.8.

3.7 Power Washing/Cleaning Small Areas of Oily Sludge and Oil-Stained Concrete

Small areas of oily sludge and oil-stained concrete were present within the building in areas where equipment was formerly located. These areas were cleaned using high-pressure water and biodegradable detergent. Prior to power washing, debris was cleared from the floor and the areas to be power-washed were preliminarily cleaned with a mechanical sweeper. Power washing activities included overnight presoaking of the concrete floor with Ripper 1 water solution cleaner/degreaser. Power washing was then conducted with high pressure hot water spray followed by vacuum removal. The power washing rinsate was collected by a vacuum tanker truck, characterized and transported off-site for treatment/disposal at a licensed facility, as discussed in Section 3.8.

3.8 Waste Disposal Documentation

This section summarizes the transportation and disposal of the various waste streams generated during the interior building environmental response activities.

After completion of the asbestos abatement activities, TSP transported one approximately 15 cubic yard (153 bags) load of ACM waste, including ACM mastics, associated (non-ACM) resilient floor tiles and sheet flooring, and overlying carpet, to Republic Service’s (Republic’s) Sauk Trail Hills Development landfill, a licensed ACM disposal facility, in Canton, Michigan, on April 18, 2019. TSP has a blanket approval with Republic for disposal of asbestos waste; a copy of the service agreement with Republic for this project is provided in Appendix E. A copy of the Non-Hazardous Special Waste & Asbestos Manifest and a copy of the weight ticket are also provided in Appendix E.

During the process of cleaning out the two ASTs and power washing the ASTs’ secondary containment area; decontaminating the structural steel, ceiling and walls of the former electroplating operations area; emptying and power washing the pits and trenches in the former electroplating area; power washing the remaining former WWTP equipment; and power washing the small areas of oily sludge and oil-stained concrete present in areas where equipment was formerly located, approximately 7,922 gallons of oily water and/or sludge were generated, which were transported by Birks Works via vac-truck to Usher Oil Company of Detroit, Michigan (Usher Oil) for treatment and disposal. These wastes were transported to Usher Oil between March 25, 2019 and April 25, 2019 (five loads total). Copies of the Material Profile Forms submitted for approval by TSP to Usher Oil, signed by the City, for these waste streams, and the email from Usher Oil to TSP approving the disposal of the waste streams, are provided in Appendix E. Copies of the Uniform Hazardous Waste Manifests for the five loads (containing non-hazardous waste) received by Usher Oil are attached in Appendix E.


After the two ASTs were cleaned, they were transported by TSP to H & H Metals Co, Inkster, Michigan (H & H) for recycling on March 27, 2019. Copies of the weigh tickets for the ASTs are provided in Appendix E.

Two loads of trash/debris, including the cut-up decontaminated former WWTP equipment and materials staged in the southeastern portion of the building, were transported by H & H to Republic’s Sauk Trail Hills Development landfill in Canton, Michigan for disposal on April 16 and 30, 2019. Copies of the weight tickets for these materials are provided in Appendix E.

Fluorescent lighting equipment removed from the former electroplating area was transported to TSP’s warehouse for temporary storage, and subsequently picked up by and disposed at Cleanlites Recycling in Mason, Michigan on September 10, 2019. A copy of the bill of lading is provided in Appendix E.


4.0 SUMMARY AND CONCLUSIONS TSP, the City’s response activity contractor, conducted the building interior environmental response activities at the Site in March and April 2019, in accordance with the CWP and U.S. EPA and State of Michigan regulations and requirements. TTL oversaw the remedial activities on behalf of the City. Response activities completed included:

• The removal of approximately 2,725 square feet of asbestos-containing mastics associated with non-ACM floor tiles and sheet flooring.

• Emptying, cleaning and removal of the two 1,750-gallon oil ASTs and power washing their associated secondary containment.

• Decontamination of the structural steel and ceiling in the former electroplating area of the Site building.

• Emptying, power washing, backfilling, and sealing with concrete, the water-filled pits and trenches in the former plating area of the Site building.

• Cleaning and removal of the WWTP equipment from the Site. • Removal and disposal of the debris within the southeastern portion of the Site building. • Power washing/cleaning areas of Site building’s concrete floor where oily sludge and oil

staining was located. Since DTR’s 2010 bankruptcy and abandonment of hazardous materials at the Site, the 2012 Time Critical Removal Actions of the U.S. EPA at the Site, and the eventual acquisition of the Site by the City through tax reversion, the City has secured the Site and had it for sale for redevelopment for light industrial use; however, the residual contamination from DTR’s site operations and the condition of the building interior was an impediment for redevelopment. The building interior environmental response activities have removed hazardous materials, mitigated hazardous conditions, and decontaminated interior surfaces of the building. The response activities will facilitate the redevelopment of the Site for light industrial reuse, and will encourage potential developers to invest in the property. Therefore, the completed response activities have achieved the remediation objectives.

FIGURES

APPENDIX A

EGLE NOTIFICATIONS

NOTIFICATION OF INTENT TO RENOVATE/DEMOLISHMICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

(MDEQ) AIR QUALITY DIVISION

NESHAP, 40 CFR Part 61, Subpart M

MICHIGAN DEPARTMENT OF LICENSING AND

REGULATORY AFFAIRS (LARA), ASBESTOS PROGRAM,

P.A. 135 OF 1986, AS AMENDED, Section 220 (1-4) or (8)

1. NOTIFICATION:

Date of Notification:

Date of Original:

Document #:

Original Document #:

Notification Type:

DEQ (NESHAP) [260 ln. ft./160 sq. ft. or more is threshold]

Planned Renovation - 10 working days notice

Emergency Renovation

Scheduled Demolition - 10 working days notice

Intentional Burn - 10 working days notice

Ordered Demolition

LARA (MIOSHA) [Will not accept annual notifications]

Demo, Reno, Encap. (>10 ln. ft./15 sq. ft.) 10 calendar days notice

Emergency Renovation/Encapsulation

Original Revised Canceled¨¨þ

þ

¨

¨

¨

¨

þ

¨

02/04/2019 0000230239

Mark appropriate boxes: (both DEQ and LARA may apply):

Phone:

Internal Project #:

Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:

4. DEMOLITION CONTRACTOR:

Phone: Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:

Internal Project #:5. FACILITY OWNER:

City of Wyandotte

Mike Kowalewski

3200 Biddle Avenue

Wyandotte, MI 48192

734-324-4554

MIOSHALicensing Authority:

License No: Type IIType of Contractor:

$132.61x 0.01 =$13,261.00

Time & materialCalculate LARA Asbestos Project Fee:(1% Project Fee)

Total Project Cost:

Check here if the work hours are not the same across the days of the week or vary from day to

day and attach a document with Detailed Work Hours. ¨

Encapsulation:

Demolition:

Asb. Removal:

Work HoursDays of the Week

* Includes setup, build enclosure, asbestos removal, demobilizing, etc.

+Include only those dates you are conducting asbestos removal/demo.

Encapsulation:

Demolition:

Renovation:

END DATESTART DATE

Check here if this is a multi-phased project, attach a schedule showing the start/end

date of each phase.

¨2. PROJECT SCHEDULE:

¨

C36800

Work Schedule: Please indicate the anticipated days of the week and work hours

for the purpose of scheduling a compliance inspection.

M, Tu, W, Th, F 7a-5p

Asb. Removal: 02/18/2019 03/01/2019

Nearest Crossroad:

County:

City/State/Zip:

Location Address:

Facility Name:

Size: (sq. ft.)

Age:

No. of Floors:

Floor No.:

Present Use:

Prior Use:

If Apt. # of units:

6. FACILITY DESCRIPTION:

Detroit Tubular Rivet

1213 Grove Street

Wayne

1

56

Vacant

Light industrial

53000

Wyandotte, MI 48192

Specific Location(s) in Facility: Throughout building.

City/State/Zip:

Location Address:

Name:

8. WASTE TRANSPORTER(S):

Name:

Location Address:

City/State/Zip:

7. DISPOSAL SITE:

Name:

Location Address:

City/State/Zip: Canton, MI 48188

1

25000 Capitol

TSP Environmental

Redford, MI 48239

Sauk Trail Hills Landfill

5011 S Lilley

*

+

+

3. ABATEMENT CONTRACTOR:

Name:

Mailing Address:

City/State/Zip:

E-mail:

Contact: Phone:

Internal Project #:

[email protected]

TSP Services, Inc.

25000 Capitol

Robert Sherby

I18108

Redford, MI 48239

734-838-0426

9. ORDERED DEMOLITIONS: (See NESHAP regulations for definition of “Ordered

Demolition.”) A copy of the official Order must accompany this notification.

Gov’t Agency Ordering Demo:

Name/Title of Person Signing Order:

Date of Order: Date Ordered to Begin:

10. ASBESTOS INFORMATION

Is asbestos present? (i.e. Assumed or identified in asbestos inspection report) Will asbestos be removed prior to demolition? Yes NoNoYes

Estimate the amount of asbestos: Include RACM (Regulated Asbestos Containing Material) to be removed, encapsulated, etc. Also include the amount and type (floor tile, roofing, etc.) of

non-friable Category I and/or Category II ACM that will not be removed prior to demolition. (NOTE: In a demolition, cementatious ACM cannot remain in a structure, as it is likely to become

regulated in the demolition/handling process. It must be removed prior to demolition. Also, all asbestos must be removed prior to an intentional burn.)

RACM/ACM

to be removed

RACM to be

Encapsulated

Non-friable ACM not removed prior to demo.

Category I Category II Units of Measure

*Volume (cubic ft./meters) should be used only if unable to measure by linear/square measure (example: asbestos has fallen off of surface).

Ln. M.Ln. Ft.

þ ¨ ¨ ¨

Sq. M.Sq. Ft.

Cu. M.*Cu. Ft.*

2725

¨ ¨

þ ¨

¨ ¨

NOTIFICATION OF INTENT TO RENOVATE/DEMOLISH (continued)

11. PROJECT DESCRIPTION: Complete A) for Renovation (asbestos removal/encapsulation) or B) for Demolition:

A) RENOVATION: Mark all surfaces/types of RACM to be removed: Encapsulation (for LARA): Mark surfaces/types to be encapsulated:

Piping Fittings Boiler(s) Tanks(s)

Ceiling Tile(s)Tunnel(s)Duct(s)Beam(s)

Other (describe):Mag Block


Beam(s) Duct(s) Tunnel(s) Ceiling Tile(s)

Other (describe):

Method of removal: Describe how the asbestos will be removed:

B) DEMOLITION: Indicate if complete or partial demolition:

Method of Demolition: Describe the method of demolition of facility, bridge, etc.:

Complete Partial (describe part of facility to be demolished):

¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨ þ

¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨

¨ ¨

¨ ¨Excavator or other heavy equipment Disassembly by hand Explosives Other (describe):¨ ¨

Glove Bag Neg. Pressure Cont. Cut into sections and remove Hand Scraping

Dry Removal (please provide attachment with a description and explanation Other (describe):

¨ ¨ ¨ þ

¨ ¨

Flooring and mastic.

or

12. ENGINEERING CONTROLS: Describe work practices and engineering controls used to prevent visible emissions before, during, and after removal, and until proper disposal:

Water spray to control dust Place in leak tight containers Adequately wet material Other (describe):¨ ¨ þ ¨

13. UNEXPECTED ASBESTOS: Describe the steps you intend to follow in the event that unexpected RACM is found or previously non-friable asbestos becomes friable

(crumbled, pulverized, reduced to powder, etc.) and therefore regulated:

Stop Work Wet material Contact DEQ and abatement contractor Revise notification Other (describe):þ þ ¨ þ ¨

A) Indicate how you determined whether or not asbestos is in the facility. If analytical sampling was used, describe method of analysis. (The determination of the presence

or absence of asbestos must be made prior to submitting a renovation/demolition notification):

þ ¨

B) Name, address, and phone number of company performing asbestos survey: TTL Associates, 734-455-8600, 44265 Plymouth Oaks Blvd., Plymouth, MI,

48170

C) Name, accreditation number of inspector, and date of inspection: Kristen Malysz, A9268, 06/30/2017

14. PROCEDURE(S) USED TO DETECT THE PRESENCE OF ASBESTOS:

All suspect materials sampled and analyzed using Polarized Light Microscopy (PLM) Other (describe):

15. EMERGENCY RENOVATIONS: Date/time of emergency:Describe the sudden, unexpected event:

Explain how the event caused unsafe conditions, and/or would cause equipment damage and/or an unreasonable financial burden:

16. I certify that an individual trained in the provisions of 40 CFR Part 61, Subpart M, will be on-site during the renovation and during demolition involving RACM above the

threshold and/or during an ordered demolition. Evidence that this person has completed the required training will be available for inspection at the renovation or demolition

site.

Signature of Owner or Abatement/Demolition Contractor

Robin Swan 02/04/2019

Date

17. Signature Requirements for Projects with Negative Pressure Enclosures: (required by LARA)

Per Section 221(1)(2) of P.A. 135 of 1986, as amended, clearance air monitoring is required for any asbestos abatement project involving 10 linear feet/15 square

feet or more of friable material which is performed within a negative pressure enclosure. I (the building owner or lessee) have been advised by the contractor of my

responsibility under Act 135 to have clearance air monitoring performed on this project.

Signature of Building Owner or Lessee Signature of Asbestos Abatement Contractor Representative

NOTE: It is not mandatory that a signed copy be sent to LARA unless requested.

For affected projects, this section of the notification form must be completed, signed, and made part of your records before the project begins.

Date Date

18. I certify that the above information is correct:

Printed Name of Owner/Operator

02/04/201902/04/2019Robin Swan (Robert Sherby) Robin Swan (Robert Sherby)

Signature of Owner/Operator Date Date







1. NOTIFICATION:


Date of Original:

Document #:


Notification Type:






Ordered Demolition




Original Revised Canceled¨þ¨

þ

¨

¨

¨

¨

þ

¨

02/19/2019 0000302321


Phone:

Internal Project #:

Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:


Phone: Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:


City of Wyandotte

Mike Kowalewski

3200 Biddle Avenue

Wyandotte, MI 48192

734-324-4554

02/04/2019 0000230239



$132.61x 0.01 =$13,261.00


Total Project Cost:



Encapsulation:

Demolition:

Asb. Removal:




Encapsulation:

Demolition:

Renovation:

END DATESTART DATE


date of each phase.


¨

C36800



M, Tu, W, Th, F 7a-5p (No work 2/18 - 2/24)

Asb. Removal: 02/18/2019 03/08/2019

Nearest Crossroad:

County:

City/State/Zip:

Location Address:

Facility Name:

Size: (sq. ft.)

Age:

No. of Floors:

Floor No.:

Present Use:

Prior Use:

If Apt. # of units:



1213 Grove Street

Wayne

1

56

Vacant

Light industrial

53000

Wyandotte, MI 48192


City/State/Zip:

Location Address:

Name:


Name:

Location Address:

City/State/Zip:

7. DISPOSAL SITE:

Name:

Location Address:


1

25000 Capitol

TSP Environmental

Redford, MI 48239


5011 S Lilley

*

+

+


Name:

Mailing Address:

City/State/Zip:

E-mail:

Contact: Phone:

Internal Project #:

[email protected]

TSP Services, Inc.

25000 Capitol

Robert Sherby

I18108

Redford, MI 48239

734-838-0426











RACM/ACM

to be removed

RACM to be

Encapsulated




Ln. M.Ln. Ft.

þ ¨ ¨ ¨

Sq. M.Sq. Ft.

Cu. M.*Cu. Ft.*

2725

¨ ¨

þ ¨

¨ ¨









Other (describe):





¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨ þ

¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨

¨ ¨




¨ ¨ ¨ þ

¨ ¨


or








þ ¨


48170








site.



Date








Date Date











1. NOTIFICATION:


Date of Original:

Document #:


Notification Type:






Ordered Demolition





þ

¨

¨

¨

¨

þ

¨

03/04/2019 0000305899


Phone:

Internal Project #:

Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:


Phone: Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:


City of Wyandotte

Mike Kowalewski

3200 Biddle Avenue

Wyandotte, MI 48192

734-324-4554

02/04/2019 0000230239



$132.61x 0.01 =$13,261.00


Total Project Cost:



Encapsulation:

Demolition:

Asb. Removal:




Encapsulation:

Demolition:

Renovation:

END DATESTART DATE


date of each phase.


¨

C36800




Asb. Removal: 02/18/2019 03/15/2019

Nearest Crossroad:

County:

City/State/Zip:

Location Address:

Facility Name:

Size: (sq. ft.)

Age:

No. of Floors:

Floor No.:

Present Use:

Prior Use:

If Apt. # of units:



1213 Grove Street

Wayne

1

56

Vacant

Light industrial

53000

Wyandotte, MI 48192


City/State/Zip:

Location Address:

Name:


Name:

Location Address:

City/State/Zip:

7. DISPOSAL SITE:

Name:

Location Address:


1

25000 Capitol

TSP Environmental

Redford, MI 48239


5011 S Lilley

*

+

+


Name:

Mailing Address:

City/State/Zip:

E-mail:

Contact: Phone:

Internal Project #:

[email protected]

TSP Services, Inc.

25000 Capitol

Robert Sherby

I18108

Redford, MI 48239

734-838-0426











RACM/ACM

to be removed

RACM to be

Encapsulated




Ln. M.Ln. Ft.

þ ¨ ¨ ¨

Sq. M.Sq. Ft.

Cu. M.*Cu. Ft.*

2725

¨ ¨

þ ¨

¨ ¨









Other (describe):





¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨ þ

¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨

¨ ¨




¨ ¨ ¨ þ

¨ ¨


or








þ ¨


48170








site.



Date








Date Date











1. NOTIFICATION:


Date of Original:

Document #:


Notification Type:






Ordered Demolition





þ

¨

¨

¨

¨

þ

¨

03/11/2019 0000308017


Phone:

Internal Project #:

Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:


Phone: Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:


City of Wyandotte

Mike Kowalewski

3200 Biddle Avenue

Wyandotte, MI 48192

734-324-4554

02/04/2019 0000230239



$132.61x 0.01 =$13,261.00


Total Project Cost:



Encapsulation:

Demolition:

Asb. Removal:




Encapsulation:

Demolition:

Renovation:

END DATESTART DATE


date of each phase.


¨

C36800




Asb. Removal: 02/18/2019 03/29/2019

Nearest Crossroad:

County:

City/State/Zip:

Location Address:

Facility Name:

Size: (sq. ft.)

Age:

No. of Floors:

Floor No.:

Present Use:

Prior Use:

If Apt. # of units:



1213 Grove Street

Wayne

1

56

Vacant

Light industrial

53000

Wyandotte, MI 48192


City/State/Zip:

Location Address:

Name:


Name:

Location Address:

City/State/Zip:

7. DISPOSAL SITE:

Name:

Location Address:


1

25000 Capitol

TSP Environmental

Redford, MI 48239


5011 S Lilley

*

+

+


Name:

Mailing Address:

City/State/Zip:

E-mail:

Contact: Phone:

Internal Project #:

[email protected]

TSP Services, Inc.

25000 Capitol

Robert Sherby

I18108

Redford, MI 48239

734-838-0426











RACM/ACM

to be removed

RACM to be

Encapsulated




Ln. M.Ln. Ft.

þ ¨ ¨ ¨

Sq. M.Sq. Ft.

Cu. M.*Cu. Ft.*

2725

¨ ¨

þ ¨

¨ ¨









Other (describe):





¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨ þ

¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨

¨ ¨




¨ ¨ ¨ þ

¨ ¨


or








þ ¨


48170








site.



Date








Date Date











1. NOTIFICATION:


Date of Original:

Document #:


Notification Type:






Ordered Demolition





þ

¨

¨

¨

¨

þ

¨

04/01/2019 0000313241


Phone:

Internal Project #:

Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:


Phone: Contact:

E-mail:

City/State/Zip:

Mailing Address:

Name:


City of Wyandotte

Mike Kowalewski

3200 Biddle Avenue

Wyandotte, MI 48192

734-324-4554

02/04/2019 0000230239



$132.61x 0.01 =$13,261.00


Total Project Cost:



Encapsulation:

Demolition:

Asb. Removal:




Encapsulation:

Demolition:

Renovation:

END DATESTART DATE


date of each phase.


¨

C36800




Asb. Removal: 02/18/2019 04/01/2019

Nearest Crossroad:

County:

City/State/Zip:

Location Address:

Facility Name:

Size: (sq. ft.)

Age:

No. of Floors:

Floor No.:

Present Use:

Prior Use:

If Apt. # of units:



1213 Grove Street

Wayne

1

56

Vacant

Light industrial

53000

Wyandotte, MI 48192


City/State/Zip:

Location Address:

Name:


Name:

Location Address:

City/State/Zip:

7. DISPOSAL SITE:

Name:

Location Address:


1

25000 Capitol

TSP Environmental

Redford, MI 48239


5011 S Lilley

*

+

+


Name:

Mailing Address:

City/State/Zip:

E-mail:

Contact: Phone:

Internal Project #:

[email protected]

TSP Services, Inc.

25000 Capitol

Robert Sherby

I18108

Redford, MI 48239

734-838-0426











RACM/ACM

to be removed

RACM to be

Encapsulated




Ln. M.Ln. Ft.

þ ¨ ¨ ¨

Sq. M.Sq. Ft.

Cu. M.*Cu. Ft.*

2725

¨ ¨

þ ¨

¨ ¨









Other (describe):





¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨ þ

¨ ¨ ¨ ¨¨ ¨ ¨ ¨¨

¨ ¨




¨ ¨ ¨ þ

¨ ¨


or








þ ¨


48170








site.



Date








Date Date





1

Steve Gach

From: Schlaufman, Jeanne (DEQ) <[email protected]>

Sent: Saturday, September 29, 2018 9:03 PM

To: Steve Gach

Subject: Re: Quick Question

Hi Steve,

If there is no soil or groundwater contamination, then the property isn't regulated under Part 201. And, if the

property were regulated under Part 201, the statute is self-regulating, there is no requirement to involve the

DEQ, RRD.

Have a good weekend, Jeanne

From: Steve Gach <[email protected]>

Sent: Friday, September 28, 2018 4:23:59 PM

To: Schlaufman, Jeanne (DEQ)

Subject: Quick Question Hi Jeanne-

We are working a building interior cleanup project for the Downriver Community Conference Brownfield Association

(DCCBC) in the City of Wyandotte, which will be funded by a Revolving Loan Fund (RLF) Subgrant. Our previous internal

building cleanup RLF projects only had asbestos abatement, so we submitted the cleanup Work Plan to the Air Quality

Division (AQD). In addition to asbestos abatement, this project includes the removal of fluorescent lights, a small

wastewater treatment plant, and a couple of empty oil ASTs, pumping out and filling some concrete building trenches

and pits, and power washing some surfaces. Everything is within the building. There is no soil or groundwater

remediation to be performed, so Part 201 is not applicable. Our plan is to send the Work Plan to AQD. EPA suggested

that I check with RRD to confirm that you would not be interested in reviewing it.

Is this a project that RRD would be interested in reviewing, or should we just send it to AQD for review?

Thank you.

-Steve

Steven J. Gach, P.E. Senior Environmental Engineer TTL Associates, Inc. 44265 Plymouth Oaks Boulevard | Plymouth, MI 48170 | ttlassoc.com Direct: (734) 582-4980 | | Fax: (734) 582-4981

1

Steve Gach

From: Kajiya-Mills, Karen (DEQ) <[email protected]>

Sent: Monday, November 26, 2018 3:36 PM

To: Steve Gach

Subject: RE: Quick Question

Got it. Karen


Sent: Monday, November 26, 2018 3:24 PM

To: Kajiya-Mills, Karen (DEQ) <[email protected]>

Cc: Schlaufman, Jeanne (DEQ) <[email protected]>; Rob Clark <[email protected]>

Subject: RE: Quick Question

Hello Karen- Please find attached a work plan for a project we are working on for the Downriver Community Conference Brownfield Consortium (DCCBC) and the City of Wyandotte, at the former Detroit Tubular Rivet site, located at 1213 Grove Street. The DCCBC plans to loan funds from a US EPA Revolving Loan Fund Grant to the City of Wyandotte for the removal of asbestos-containing building materials (ACMs) from the site, as well as conducting other building interior cleanup activities. As a condition of the loan, US EPA requires that the work plan be submitted to the State of Michigan to help ensure that the planned work is not inconsistent with State requirements. As required, a Notice of Intent to Renovate/Demolish (NOIR/D) will be submitted by the abatement contractor (once selected by the City of Wyandotte) to the MDLARA, and to the MDEQ, AQD, NESHAP Asbestos Program, Detroit Field Office. Once the NOIR/D is submitted by the selected contractor, we will make sure a copy is forwarded to you. If you have any questions regarding the attached work plan or the planned asbestos abatement activities, please contact me. As you requested, I am also copying Ms. Jeanne Schlaufman on this, who I had contacted previously about the project (see below). Thank you very much for your time and consideration. -Steve (Following is the previous correspondence.)

From: Schlaufman, Jeanne (DEQ) [mailto:[email protected]]

Sent: Saturday, September 29, 2018 9:03 PM

To: Steve Gach Subject: Re: Quick Question

2

Hi Steve,

If there is no soil or groundwater contamination, then the property isn't regulated under Part 201. And, if the

property were regulated under Part 201, the statute is self-regulating, there is no requirement to involve the

DEQ, RRD.

Have a good weekend, Jeanne


Sent: Friday, September 28, 2018 4:23:59 PM

To: Schlaufman, Jeanne (DEQ)

Subject: Quick Question Hi Jeanne-

We are working a building interior cleanup project for the Downriver Community Conference Brownfield Association

(DCCBC) in the City of Wyandotte, which will be funded by a Revolving Loan Fund (RLF) Subgrant. Our previous internal

building cleanup RLF projects only had asbestos abatement, so we submitted the cleanup Work Plan to the Air Quality

Division (AQD). In addition to asbestos abatement, this project includes the removal of fluorescent lights, a small

wastewater treatment plant, and a couple of empty oil ASTs, pumping out and filling some concrete building trenches

and pits, and power washing some surfaces. Everything is within the building. There is no soil or groundwater

remediation to be performed, so Part 201 is not applicable. Our plan is to send the Work Plan to AQD. EPA suggested

that I check with RRD to confirm that you would not be interested in reviewing it.

Is this a project that RRD would be interested in reviewing, or should we just send it to AQD for review?

Thank you.

-Steve

Steven J. Gach, P.E. Senior Environmental Engineer TTL Associates, Inc. 44265 Plymouth Oaks Boulevard | Plymouth, MI 48170 | ttlassoc.com Direct: (734) 582-4980 | | Fax: (734) 582-4981

APPENDIX B

TSP CERTIFICATIONS

APPENDIX C

TTL CERTIFICATIONS

APPENDIX D

AIR QUALITY MONITORING RESULTS AND FINAL CLEARANCE DOCUMENTATION

SITE ACTIVITY LOGDate:

3/25/2019

Page 1 of 1

Project Name: 1213 Grove St, Wyandotte Project No.:

Site Activity: Asbestos Oversight and Air Monitoring 915808

Site Conditions: Visitors (Name and Organization):

Name: Signature/Date:

Rob Serlin 3/25/2019

V:\Plymouth\DCC Brownfield Consortium\1213 Grove Wyandotte\2017\915808 Remediation Activities\Remediation Report\Report cookbook\Appendix D01 - Site Activity Log -3.25.2019.docx REVISION 3 APRIL 18, 2016

Time Notes 0930 I arrived on site. Pump out activities were completed and TSP had begun the setup of the

containment for mastic removal activities. I checked the floor area where yellow carpet glue was on floor mastic. The cumulative total area of removal was approximately 560 square feet. The mastic remover will not be able to dissolve the yellow carpet glue and a different method will have to be utilized for removal in those areas.

1100 I left the site after taking photos and talking to the TSP crew. 1300 I arrived back on site to perform background air monitoring and observe site activities. 1315 I began background air monitoring while the TSP crew was completing set-up of the mastic

removal area. 1525 The TSP crew completed carpet and floor tile removal activities for the day and I began

collecting the air cassettes.

Sample Summary Sheet: NIOSH 7400Project & Contract No.: TTL Rep: Analyst Signature:

Facility: Client Rep: Location of Analysis:

Area: Date sampled: Date analysis completed:

ID Start Stop Start Stop Average Fibers Fields F/cc 8 Hour TWA

915808-3 1315 1528 133 11.17 11.17 11.17 1485.61 3 100 <0.002

915808-4 1335 1530 115 2.11 2.11 2.11 242.65 1 100 <0.011

* SAMPLE TYPE: BA - Background; P - Personal; PX - Personal Excursion; CL - Clearance; EN - Environmental; FB - Field Blank; MB - Media Blank

ID Fibers Fields F/mm2

915808-2 1 100 < 7FB

Rob Serlin

TTL office

March 27, 2019

Type*

Type*

March 25, 2019

Lance Lipka

Rob Serlin915808

1213 Grove St, Wyandotte

Containment area

1235

High Volume Rotometer ID

FB

Field and Media Blanks

1915808-1

Sample

Analytical ResultsSample Volume

Z045BA

100

Analytical Results

8 Hr. TWA is calculated based on a 480 minute sampling period regardless of the total sampling time. TWA calculations are not possible for samples that are determined to be occluded/void and Clients should refer to the f/cc data for exposure. Exposure calculations assume zero exposure for time not sampled. TTL is not responsible for final results calculated using air volumes that have been provided by non-

TTL personnel. Limit of Detection (LOD) = 7fibers/mm2; Optimum fiber load = 100 fibers/mm2 to 1300 fibers/mm2; Loading density between LOD and LOQ may have a positive bias; Loading density >1300 fibers/mm2 or >50% sample area occluded may have negative

bias; VOID = Samples occluded or could not be analyzed according to NIOSH 7400 method.

37920

1447

697

Low Volume Rotometer ID

Cassette Lot No

Cassette Make

< 7

Cassette Type Zefon

Microscope ID

Sample

Description

BA

Flow RateTotal Minutes

BA

Time

10' from entrance air lock to the containment

Inside the containment next to the airlock

V:\Plymouth\DCC Brownfield Consortium\1213 Grove Wyandotte\2017\915808 Remediation Activities\Remediation Report\Report cookbook\Appendix D02 - Sample Summary Sheet 03.25.19Revision 2: Updated: September 11, 2014


3/26/2019

Page 1 of 1







Time Notes 0700 I arrived on site. The air monitoring equipment was calibrated and environmental air monitoring

Samples were started. The crew would be removing carpet and floor tile. 1100 The carpet and floor tile were removed in one area and floor leveler with yellow carpet glue on

top of mastic was revealed. Mechanical means would be required to chip and fracture the cement like floor leveler.

1300 The TSP crew double lined the closed asbestos dumpster with 6 mil poly sheeting. 1325 I collected the samples and left the site. The TSP crew was setting up the next area for removal.





7-915808 718 1528 490 2.11 1.9 2.005 982.45 7 100 0.003

8-915808 733 1525 472 2.11 2 2.055 969.96 3 100 <0.003



6-915808 1 100 < 7FB

Rob Serlin

Containment area

March 27, 2019

Type*

Type*

March 26, 2019

Lance Lipka

Rob Serlin915808


Containment area

1235


FB


15-915808

Sample


Z045BA

100

Analytical Results




37920

1447

697


Cassette Lot No

Cassette Make

< 7

Cassette Type Zefon

Microscope ID

Sample

Description

EN


EN

Time





3/27/2019

Page 1 of 1








samples were started. Liquid mastic remover was used to dissolve the mastic and the residue was soaked up with an absorbent.

1130 The abatement crew went on lunch break. The floor leveler removal was being conducted by utilizing spud bars and hand tools.

1245 I collected the samples and left the site to evaluate the samples. The TSP crew was removing the mastic and floor leveler.





11-915808 720 1243 323 1.79 1.79 1.79 578.17 2 100 <0.005

12-915808 720 1244 324 1.69 1.58 1.635 529.74 6 100 <0.005



10-915808 2 100 < 7


EN

Time



Microscope ID

Sample

Description

EN

100

Analytical Results




37920

1447

697


Cassette Lot No

Cassette Make

< 7

Cassette Type Zefon


Z045BA

FB


19-915808

Sample

FB

Rob Serlin

Containment area

March 27, 2019

Type*

Type*

March 27, 2019

Lance Lipka

Rob Serlin915808


Containment area

1235




3/28/2019

Page 1 of 1








samples were started. The abatement crew were getting the supplies and equipment ready. 0800 The environmental air samples were started. The mastic removal activities were being

conducted. The abatement crew was also setting up other areas for abatement. 1230 I collected the samples and left the site to evaluate the samples.





915808-15 800 1220 260 1.5 1.5 1.5 390 2 100 <0.007

915808-16 802 1221 259 1.5 1.4 1.45 375.55 8 100 0.009



915808-14 1 100 < 7FB

Rob Serlin

Containment area

March 30, 2019

Type*

Type*

March 28, 2019

Lance Lipka

Rob Serlin915808


Containment area

1235


FB


1915808-13

Sample


Z045BA

100

Analytical Results




37920

1447

697


Cassette Lot No

Cassette Make

< 7

Cassette Type Zefon

Microscope ID

Sample

Description

EN


EN

Time





3/29/2019

Page 1 of 1








samples were started. The abatement crew were getting the supplies and equipment ready for abatement in lab area.

0800 The environmental air samples were started. The floor tile removal activities were being conducted.

1250 I collected the samples and equipment. 1315 I left the site to evaluate the samples.





915808-19 811 1250 279 1.5 1.4 1.45 404.55 3 100 <0.007

915808-20 810 1250 280 1.5 1.5 1.5 420 4 100 <0.006



915808-18 1 100 < 7


EN

Time

Inside lab room next to air lock

At the drinking fountain outside lab room

Microscope ID

Sample

Description

EN

100

Analytical Results




37920

1447

697


Cassette Lot No

Cassette Make

< 7

Cassette Type Zefon


Z045BA

FB


1915808-17

Sample

FB

Rob Serlin

Containment area

March 30, 2019

Type*

Type*

March 29, 2019

Lance Lipka

Rob Serlin915808


Containment area

1235




4/15/2019

Page 1 of 1







Time Notes 1030 I arrived on site and performed a visual inspection of the areas. 1100 The air monitoring equipment was calibrated. The clearance air monitoring samples were

started. 1545 I collected the samples and equipment. I left the site to evaluate the samples.





915808-23 1127 1330 123 10.49 10.01 10.25 1260.75 2 100 <0.002

915808-24 1128 1330 122 10.49 10.49 10.49 1279.78 1.5 100 <0.002

915808-25 1350 1515 85 14.34 14.34 14.34 1218.9 2 100 <0.002

915808-26 1345 1511 86 14.34 13.86 14.1 1212.6 1 100 <0.002

915808-27 1348 1513 85 14.34 14.34 14.34 1218.9 1.5 100 <0.002

915808-28 1354 1520 86 14.34 14.34 14.34 1233.24 1 100 <0.002



915808-22 1 100 < 7FB

Rob Serlin

Containment areas

April 16, 2019

Type*

Type*

April 15, 2019

Lance Lipka

Rob Serlin915808


Containment area

1235


Shipping office near middleCL

FB

CL


0915808-21

Sample

CL


Z008BA

100

Analytical Results




Women's restroom near middle

44211

1443

1446

Men's restroom near middle


Cassette Lot No

Cassette Make

< 7

Cassette Type Zefon

Microscope ID

Sample

Lab near middle

Description

CL


CL

CL

Time

Administration near middle of reception area

Administration in hallway


Page ____ of ___

Be sure to obtain copies of all worker records during the project and while on site.

A46666

A7679

A41524

8/21/2019

7/30/2019

2/28/2020Mike Corrion

City of Wyandotte

2102200154

Kevin Garrison

Lance Lipka

Medical Exam Expiration Date

Fit Test Expiration Date

12/23/2018

11/8/2019

2/26/2020 10/5/2019 8/21/2018

12/19/2018 8/21/2018

1/30/2020 8/21/2018

TTL Associates, Inc.CONTRACTOR/WORKER INFORMATION SHEET

Worker Name State Accreditation Number

Accreditation Expiration Date

Training Certificate Expiration Date

915808

1213 Grove St., Wyandotte, MI

TSP

Rob Serlin

V:\Plymouth\DCC Brownfield Consortium\1213 Grove Wyandotte\2017\915808 Remediation Activities\Remediation Report\Report cookbook\Appendix D13 - Contractor Info Sheet

Updated September 2014

Facility

Work Area

Inspection No. Inspection No.Inspection Attendees Company Inspection Attendees Company

Pass Fail Pass Fail

Notes Notes

Pass Fail Pass Fail

Clearance Standard: U.S.EPA Clearance Guideline of 0.01 f/cc PCM

U.S.EPA Clearance Guideline of 70 S/mm2 TEM

Other:

TTL Technician (Print) Signature Date

Updated September 2014

V:\Plymouth\DCC Brownfield Consortium\1213 Grove Wyandotte\2017\915808 Remediation Activities\Remediation Report\Report cookbook\[Appendix D14 - Clearance Certificate 915808 04.16.19.xlsx]Clearance Certificate


X

915808-27 <0.002

915808-26 <0.002

915808-24 <0.002

<0.002915808-25

915808-23 <0.002

X

915808-28<0.002

Rob Serlin

Lance Lipka TSP

1

Clearance Certificate

Visual Inspection

Final Air Clearance

Sample ResultSample No. Sample No. Sample Result

TTL

1213 Grove St., Wyandotte, MI

Containment

91580804.16.19Date

Project No.

APPENDIX E

DISPOSAL DOCUMENTATION

Disposal Date Trucking Co. Container# Manifest # Scale Ticket # YDS

4/18/2019 REPUBLIC 42P 5118498 1287586 15

Asbestos Out

lrevoir

Highlight

lrevoir

Highlight

Date Trucking Co. Manifest # Gallons3/25/2019 BIRKS WORKS 7992857 2288 Wastewater & oil3/25/2019 BIRKS WORKS 7992858 1049 8260 lbs oily sludge4/17/2019 BIRKS WORKS 7992872 1941 Sludge / Rinsate4/23/2019 BIRKS WORKS 7992874 2058 Water from pits4/24/2019 BIRKS WORKS 7992876 586 WWTP rinsate

Non Haz Liquid Out

Date Trucking Co. Truck # Weight (LBS)3/27/2019 TSP 16 15403/27/2019 TSP 16 1540

Scrap Metal Out

Page 1

Removal Date

Disposal Date Trucking Co. Truck # Weight Tons

4/15/2019 4/16/2019 H&H HH32 4.744/30/2019 4/30/2019 H&H HH20 3.1

Debris Out

Documents

City of Wyandotte...Cleanup Summary Report . Former Detroit Tubular Rivet Facility . 1213 Grove Street ... 44265 Plymouth Oaks Blvd. Plymouth, MI 48170 T 734-455-8600 F 734-455-8608