REMEDIAL INVESTIGATION REPORT/CONCEPTUAL SITE MODEL

Former Station A Manufactured Gas Plant

DTE Gas Company
Detroit, Michigan
Prepared for:
DTE Gas Company
One Energy Plaza Drive, Suite 655 GO
Detroit, Michigan 48226

Prepared by:
Stantec Consulting Services Inc.
27280 Haggerty Road, Suite C-11
Farmington Hills, MI 48331

January 20, 2015

TABLE OF CONTENTS
1.0

INTRODUCTION ................................................................................................................ 1

2.0

SITE HISTORY AND POTENTIAL CONTAMINANT SOURCE AREAS .................................... 3

2.1 Site History .................................................................................................................... 3
2.2 Potential Contaminant Source Areas ...................................................................... 4
2.3 1984 Response Actions .............................................................................................. 6
2.4 1985 Response Actions .............................................................................................. 6
2.5 2011 Response Actions .............................................................................................. 7
2.6 2012 Response Actions .............................................................................................. 7

3.0

2014 REMEDIAL INVESTIGATION WORK SCOPE .............................................................. 9

3.1 Soil Boring Installation ................................................................................................. 9
3.2 Monitoring Well Installation ..................................................................................... 10
3.3 River Gauges ............................................................................................................. 11
3.4 Groundwater Gauging and Sampling .................................................................. 12
3.5 Flux Chamber Sampling .......................................................................................... 12

4.0

SITE DESCRIPTION ........................................................................................................... 14

4.1 Site Setting ................................................................................................................. 14
4.2 Geology/Hydrogeology .......................................................................................... 14

5.0

SUMMARY OF PREVIOUS RESPONSE ACTIONS ............................................................. 16

6.0

COMPLETED INTERIM RESPONSE ACTIONS.................................................................... 18

7.0

SOIL CHARACTERIZATION.............................................................................................. 19
7.1 Oily Substances and Tar-Like Materials ................................................................. 19
7.2 Constituents of Potential Concern in Soil .............................................................. 19
7.3 Part 201 Soil Cleanup Criteria ................................................................................. 19
7.4 Evaluation of Copcs in Soil ...................................................................................... 20
7.4.1 1984 Soil Data .......................................................................................................... 20
7.4.2 2011 Soil Data .......................................................................................................... 21
7.4.3 2012 Soil Data .......................................................................................................... 21
7.4.4 2014 Soil Data .......................................................................................................... 21

8.0

GROUNDWATER CHARACTERIZATION .......................................................................... 22

8.1 Non-Aqueous Phase Liquids ................................................................................... 22
8.2 COPCs in Groundwater ........................................................................................... 22
8.3 Part 201 Groundwater Cleanup Criteria ............................................................... 22

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TABLE OF CONTENTS (Cont.)

8.4
9.0

Evaluation of COPCs in Groundwater ................................................................... 23

SOIL GAS CHARACTERIZATION ..................................................................................... 24

9.1 COPCs in Soil Gas ..................................................................................................... 24
9.2 Part 201 Soil Gas Screening Criteria ....................................................................... 24
9.3 Evaluation of COPCs in Soil Gas ............................................................................. 24

10.0 AMBIENT AIR CHARACTERIZATION................................................................................ 26

11.0 ENVIRONMENTAL RECEPTORS AND PATHWAYS ........................................................... 27
11.1 Drinking Water Pathway ........................................................................................ 27
11.2 Volatilization of COPCs in Soil and Groundwater to Indoor Air ........................ 28
11.3 Volatilization of COPCs in Soil to Ambient Air ..................................................... 28
11.3.1 Parcel 1 .................................................................................................................... 28
11.3.2 Parcel 2 .................................................................................................................... 29
11.3.3 Parcel 2A ................................................................................................................. 29
11.4 Direct Contact with COPCs in Soil ........................................................................ 29
11.4.1 Parcel 1 .................................................................................................................... 29
11.4.2 Parcel 2 .................................................................................................................... 29
11.4.3 Parcel 2A ................................................................................................................. 30
11.5 Groundwater/Surface Water Interface Pathway .............................................. 30
12.0 CONCLUSIONS ............................................................................................................... 31
13.0 DATA GAPS .................................................................................................................... 33
14.0 ADDITIONAL FUTURE RESPONSE ACTIONS .................................................................... 34

iii

TABLE OF CONTENTS (Cont.)

LIST OF FIGURES
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.

Site Location Map

Site Parcel Map
Site Map
Site and Surrounding Properties Map
Residual Contaminant Source Materials and Soil Exceeding Part 201 Criteria 1984
- 2012 Soil Samples Map
Residual Contaminant Source Materials and Soil Exceeding Part 201 Criteria 2014
Soil Samples Map
Groundwater Analytical Results May 29, 2014 - June 2, 2014
Groundwater Contour Map May 29, 2014
Geologic Cross Section Location Map
Geologic Cross Sections - A-A through C-C
Soil Gas Analytical Results September 24, 2012

LIST OF TABLES
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.

1984 Soil Analytical Results Detectable VOCs and Base/Neutrals

1984 Soil Analytical Results Metals
2011 Soil Analytical Results
2012 Soil Analytical Results VOCs, PAHs, Phenols, Available Cyanide and pH
2012 Soil Analytical Results - Metals
2012 Soil Gas Analytical Results
2014 Soil Analytical Results VOCs, PAHs, Available Cyanide, Ammonia and pH
2014 Soil Analytical Results Metals
2014 Soil Analytical Results Phenols
2014 Groundwater Analytical Results VOCs, PAHs, Metals, Cyanide and
Ammonia
2014 Groundwater Analytical Results Phenols
Groundwater Elevation Data

LIST OF APPENDICES
A.
B.
C.
D.
E.
F.

Parcel 1 Aerial Photographs

Boring Logs
Map of PVC Membrane
Laboratory Analytical Reports 2014 Soil Data
Laboratory Analytical Reports 2014 Groundwater Data
Ambient Air Assessment Report

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1.0

INTRODUCTION

Stantec Consulting Corporation (Stantec), on behalf of DTE Gas Company (DTE Gas), a
subsidiary of DTE Energy, has prepared this Remedial Investigation Report/Conceptual
Site Model (Report) for the former Station A manufactured gas plant (MGP) located at
3085 West Jefferson in Detroit, Michigan (the Site). Refer to the Site Location Map
(Figure 1) for detailed information on the location of the Site. The Site is no longer
owned by DTE Gas and currently consists of portions of the City of Detroits Riverside
Park along with land owned by the Norfolk Southern Corporation (NSC).
The Site consists of approximately 10 acres of land and is located adjacent to the
Ambassador Bridge with the Detroit River bordering the Site to the southeast. Riverside
Park consists of three parcels. Parcels 1 and 2 are shown on Figure 2 and were part of
the former Station A manufactured gas plant. Parcel 3 was not historically owned or
used by DTE Gas and is not included in this Report. Based on available information, the
approximate locations of the former MGP components have been overlaid onto the
existing Site Map (Figure 3). Refer to the Site Map (Figure 3) and Site and Surrounding
Properties Map (Figure 4) for Site and surrounding area features including the
approximate locations of the former MGP structures. Soil borings and monitoring wells
have been installed on the Site. Soil and groundwater samples have been collected to
investigate potential subsurface impacts related to historical MGP activities at the Site.
Concentrations of volatile organic compounds (VOCs), polynuclear aromatic
hydrocarbons (PAHs) and inorganics have been detected in soil and groundwater
samples above Part 201 of Public Act 451 of 1994, as amended (Part 201) cleanup
criteria.
The October, 30, 2013 Response Activity Plan (ResAP) prepared by Stantec and
approved by the Michigan Department of Environmental Quality (MDEQ) on
December 5, 2013 was implemented in January through June 2014. An additional work
plan was developed through email correspondence between the Michigan
Department of Environmental Quality (MDEQ), DTE Gas and Stantec to collect ambient
air samples using flux chambers on Parcel 1. The work scope and flux chamber
sampling locations were approved in a November 15, 2013 email from the MDEQ to the
DTE Gas and Stantec. The flux chamber sampling work plan was implemented in
September 2014. The activities completed during implementation of the ResAP and
flux chamber sampling are discussed in Section 3.0.
This Report has been prepared to include the information present in a Conceptual Site
Model (CSM). This Report was prepared to identify the current conditions using historical
and current data for the Site and surrounding area. This information presented in the
Report generally follows the Standard Guide for Developing Conceptual Site Models for
Contaminated Sites (ASTM E1689-95 (Reapproved 2008)). The objectives of the Report
were the following:
1

To integrate technical information from various sources;

To evaluate potential risks to human health and the environment; and,
To identify data needs and data collection activities.

The Report includes:

A description of background and operational history of the Site;

A summary of the Sites environmental setting;
A chronology of Site characterization activities and interim response actions;
A summary of completed interim response actions;
A description of the nature and extent of impacts in soil and groundwater;
An evaluation of migration pathways; and,
An evaluation of environmental receptors.

2.0

SITE HISTORY AND POTENTIAL CONTAMINANT SOURCE AREAS

2.1

Site History

A summary of the history of the Site was derived from historical maps provided by DTE
Gas, historical photographs and previous environmental reports. The significant
historical operations and features of the Site and adjacent properties are summarized in
this section.
The former Station A MGP was constructed by the Detroit Gas and Light Company in
1867 and was operated by the Detroit Gas and Light Company, Detroit City Gas
Company and Michigan Consolidated Gas Company (MichCon) until 1954 at which
time natural gas pipelines became established. Please note that MichCon changed its
legal name to DTE Gas Company (DTE Gas), a subsidiary of DTE Energy, in 2013.
The MGP primarily generated coal gas and water gas to supply the city of Detroit prior
to the availability of natural gas. The coal gas manufacturing process consisted of
heating bituminous coal in retorts. The water gas manufacturing process generally was
similar to the coal gas process but also injected steam to produce gas. Coke
generated during the gas production was either returned to the ovens for further
processing or sold locally. Impurities in the gas were removed before delivery to the
customer. The byproducts typically associated with MGP processes included tar, pitch,
hydrogen cyanide, hydrogen sulfide, and various liquids. Many of these impurities were
useful products that could be sold.
Based on readily available historical drawings and maps, the following non-DTE Gas
operations were also previously present on Parcels 1, 2 or 2A:

Tar Distillation Operation;

Railroad;
Pintsch Gas Plant;
Toluene recovery operation;
Detroit International Bridge Company; and,
Boat slip.

Parcel 2A of the former MGP site was sold to Wabash Railroad Company (predecessor
of NSC) in 1969 and has continued to be used for railroad related usage. Parcels 1 and
2 of the former MGP site were sold to the City of Detroit in 1979 and were developed
into an extension to the Riverside Park. Parcel 1 currently consists of a baseball diamond
infield, two small bleacher sections and a fenced backstop. The remainder of Parcel 1
consists predominantly of grassy areas. There are no play structures, picnic areas or
other recreational features on Parcel 1. Parcel 2 consists of an asphalt parking lot,
3

grassy areas and picnic pavilion adjacent to the Detroit River. The City of Detroit is the
owner of Parcels 1 and 2. Railroad tracks and property owned by NSC (Parcel 2A)
separates Parcels 1 and 2. According to the City of Detroit Recreation Department,
Riverside Park is currently closed and will remain closed until environmental remediation
is completed.

2.2

Potential Contaminant Source Areas

The primary potential contaminant source areas on the Site are former MGP operations,
tar distillation operations, toluene recovery operations, and pintsch gas plant
operations.
MGP Operations
The MGP structures indicated on historical and Sanborn maps included the following as
shown on Figure 3:

Two (2) relief gas holders;

Condenser and scrubber;
Purifiers;
Water Gas Tar, Oil Water, and Oil Tar Separators;
Retorts;
Tar Tanks and Gas/Oil Storage Tanks;
Ammonia well and tank;
Oil and Tar Wells; and,
Other Various Buildings.

During the generation of manufactured gas, byproducts from two primary processes
often resulted in impacts to the environment: gas production and gas clean-up. During
gas production, the coal gas and water gas processes generated residual
hydrocarbons. According to Management of Manufactured Gas Plant Sites (Hayes
and others; 1996, Amherst Scientific Publishers, Amherst, Massachusetts), the
hydrocarbon residuals associated with the coal gas process consisted primarily of coke
and hydrocarbons (tars, oils and lampblack). The gas cleanup phase generally
consisted of scrubbing the gases to remove naphthalene, ammonia, cyanide and light
oils.
Tar Distillation Operations
Historical documentation indicated that tar distillation operations occurred on the Site
from the early 1900s to the 1920s. The tar distillation company was a distiller of coal tar
products and a manufacturer of roofing and paving materials including:

Pitch (for paving, roofing and waterproofing);

Felt (for building, roofing and slater);
4

Asphalt; and,
Tarvia (a surfacing and binding material for roads and drives).

As indicated on Figure 3, tar distillation operations occurred at the western portion of

Parcel 2. Former structures associated with tar distillation operations included tar tanks,
storage tanks, condensers, stills and boiler and coolers. Potential residual contaminants
associated with a tar distillation operation include various hydrocarbons (including tars).
Toluene Recovery Operations
Historical documentation shows that a toluol recovery plant was built and operated to
generate toluene from the coal and water gas from approximately 1917 to 1919. The
toluene was a critical war material used for the primary purpose of manufacturing
trinitrotoluene (TNT). As indicated on Figure 3, toluene recovery operated within Parcel
1. Former structures associated with the toluene recovery operations included toluol
tanks, toluol pipe trench, toluol loading pipe trench, and a toluol machinery building.
Toluene would be the primary potential residual contaminant associated with a toluol
recovery plant.
Pintsch Gas Plant Operations
Historical documentation indicated that a Pintsch Gas Plant operated at the Site from
the 1890s to the 1930s. Pintsch plants were typically operated by railroad companies
and these plants produced compressed illuminating gas for use in passenger rail cars.
As indicated on Figure 3, former structures associated with a Pintsch Gas Plant included
a gas plant, tar holders, gas holders and storage tanks. These former structures are
noted on Parcels 1 and 2A (Figure 3). Types of wastes that would result from a Pintsch
gas operation could include hydrocarbons released during production, ash from coal
and coke incineration and wastes derived as a result of tar management and gas
purification.
Other Potential Sources
During the 2014 investigation activities, contractors working for the Detroit International
Bridge Company (DIBC) were observed to be installing large diameter utilities along the
eastern portion of the Site without City of Detroit permission. Barren soil and soil piles
were observed on Parcel 1 along the entire eastern boundary. This information and
concern over the potential for exacerbation of potential subsurface impacts were
communicated to the City of Detroit and the MDEQ. This potential exacerbation is a
potential contaminant source area. Aerial photographs of the site disruption are
included as Appendix A.
Also, historical documentation indicated that various activities may have occurred on
the Site that may have exacerbated or contributed potential contaminants. Some of
these activities include: Placement of fill materials to expand shoreline, railroad

operations, Steamship S.S. Montrose salvage activities, storm sewer installation by

Wayne County Road Commission, and various other historical adjacent operations.

2.3

1984 Response Actions

In 1984 a site investigation of Parcels 1 and 2 was conducted by EDI Engineering &
Science (EDI) on behalf of DTE Gas. The work scope and results of this investigation are
presented in Site Investigation Former Coal Gas Manufacturing Plant Station A (EDI;
October 1984).
Twenty-nine soil borings were advanced and four surface soil samples were collected
on Parcels 1 and 2 in 1984. The soil borings are identified on Figure 3 as S-1 through S-16,
S-19 through S-28 and S-30 through S-32. The four surface soil sample locations are
designated on Figure 3 as SS-1, SS-2, SS-3 and SS-9. Soil samples were collected from
selected soil borings for laboratory analysis of volatile organic compounds (VOCs),
base/neutrals, total cyanide (wet weight), total phenols (wet weight) and metals. The
VOCs, base/neutrals and metals analytical results of the 1984 soil samples are
presented in Tables 1 and 2. These tables contain the MDEQ Part 201 nonresidential soil
cleanup criteria for comparison purposes.
Six monitoring wells (W-1 through W-6 on Figure 3) were installed on Parcels 1 and 2 to
determine groundwater flow direction and collect groundwater samples for laboratory
analysis. Because the sampling methodologies are not known, the 1984 groundwater
data are not presented in this Report. In 2012, these monitoring wells were not
observed on Parcels 1 and 2.
Six subsurface air wells were installed and these air wells are identified as A-1 through A6 on Figure 3. According to EDI October 1984, these air wells were installed to depths
ranging from five to ten feet below the surface (bs). In 2012, these air wells were not
observed on Parcels 1 and 2.
Drilling logs for the 1984 soil borings, monitoring wells and air wells are presented in
Appendix B. The depths of the soil borings advanced in 1984 ranged from three feet to
30 feet below the surface. The information presented on these drilling logs indicate that
contaminant source materials from former MGP operations and/or other former
operations on Parcels 1 and 2 were encountered in the subsurface. The 1984 boring
locations where potential contaminant source materials are indicated are presented
on Figure 5. Figure 5 also presents the 1984 soil samples that exceeded the Part 201
screening criteria.

2.4

1985 Response Actions

The results of the 1984 site assessment indicated that shallow soils (generally upper
twelve inches) within a portion of Parcel 2 were stained blue as a result of ferric
6

ferrocyanide being present within these soils. The results of the investigation of the bluestained soils are presented in Additional Investigation, Investigation of Blue Staining of
Surface Grasses, Riverside Park, Station A (EDI; March 1985). To prevent potential direct
contact exposures, a blue PVC membrane overlain by approximately one to two and a
half feet of clean granular material, topsoil and grass was emplaced over parts of the
grassy areas within Parcel 2. A map showing the extent of the PVC membrane/barrier is
presented in Appendix C. In 2012 and 2014, the presence of the blue PVC membrane
was confirmed. The components of the 1985 response actions are presented in
Remedial Action Plan (EDI; October 1985).

2.5

2011 Response Actions

In October 2011, a subsurface investigation was conducted by TEI Environmental

Solutions (TEI) on behalf of the City of Detroit Recreation Department. The results of this
subsurface investigation are presented in Phase II Subsurface Investigation Riverside
Park (TEI; January 17, 2012). Six soil borings were advanced on Parcels 1 and 2. These
six borings are referred to as SP-1 through SP-6 on Figure 3. Three of the soil borings (SP1, SP-2 and SP-3) were advanced on Parcel 1 and the three remaining soil borings (SP-4,
SP-5 and SP-6) were advanced on Parcel 2. During the advancement of these six soil
borings, soil samples were collected for laboratory analysis of VOCs, semi-volatile
organic compounds and metals. The October 2011 soil analytical results are presented
in Table 3. The boring locations where contaminant source materials are indicated are
presented on Figure 5. Figure 5 also presents the 2011 soil samples that exceeded the
Part 201 screening criteria.
Temporary monitoring wells were installed in borings SP-2, SP-3 and SP-6 and
groundwater samples were collected for laboratory analysis from these temporary
monitoring wells. Temporary monitoring wells were not installed in borings SP-1, SP-4 and
SP-5 because groundwater was not encountered during the advancement of theses
borings. The construction details of the temporary monitoring wells are not known. The
MDEQ generally requires that monitoring wells be allowed to stabilize for at least 72
hours before groundwater samples are collected. Because the construction details of
the temporary monitoring wells are unknown and the groundwater samples were
collected on the same day the boring was advanced, the October 2011 groundwater
data are not presented in this Report.
Drilling logs for the 2011 soil borings are presented in Appendix B. The depths of the
October 2011 soil borings ranged from 15 feet to 20 feet below the surface.

2.6

2012 Response Actions

In September and November 2012, a subsurface investigation consisting of soil and soil
gas sampling on Parcels 1 and 2 was completed by Stantec, on behalf of DTE Gas. The
7

results of this investigation are presented in Response Activity Plan (Stantec; October 30,
2013) This investigation consisted of the advancement of 54 shallow soil borings (33 on
Parcel 1 and 21 on Parcel 2) and the installation of 15 soil vapor points in 15 of the soil
borings. On Figure 3, these borings are designated as:

SB-1 through SB-5;

SB-10, SB-11 and SB-11A;
SB-14 through SB-39;
SB-41 and SB-43 through SB-46;
VP-1 through VP-10; and,
VP-12 through VP-16.

The depths of the borings ranged from one foot to 6.5 feet bs.
During the advancement of the soil borings, soil samples were collected for laboratory
analysis of selected VOCs, polynuclear aromatic hydrocarbons (PAHs), metals, phenols,
available cyanide and pH. The soil analytical results are presented in Tables 4 and 5.
Soil gas samples were collected from the soil vapor points for laboratory analysis of
selected VOCs, naphthalene, 2-methylnaphthalene and mercury. The soil gas data are
presented in Table 6.
The soil and soil gas data for Parcels 1 and 2 were presented to the MDEQ and the City
of Detroit during meetings conducted in early 2013. The results of the soil and soil gas
data from Parcel 1 were presented in Response Activity Plan Parcel 1 (Stantec;
February 20, 2013).
Drilling logs for the 2012 soil borings are presented in Appendix B. The information
presented on these drilling logs indicate that contaminant source materials from former
MGP operations and/or other operations formerly present on Parcels 1 and 2 were
encountered in the subsurface. The 2012 boring locations where contaminant source
materials are indicated are presented on Figure 5. Figure 5 also presents the 2012 soil
samples that exceeded the Part 201 screening criteria.

3.0

2014 REMEDIAL INVESTIGATION WORK SCOPE

A proposed work scope for a subsurface investigation consisting of soil sampling,

monitoring well installation and groundwater sampling on Parcels 1, 2 and 2A was
outlined in the ResAP prepared and submitted by Stantec on October 30, 2013 and
approved by the MDEQ in December 2013. In January through July 2014, the work
outlined in the ResAP was completed by Stantec, on behalf of DTE Gas. Additionally, in
order to evaluate the Ambient Air Volatile Source Inhalation pathway, a work plan was
developed through email correspondence between the MDEQ, DTE Gas and Stantec
to collect flux chamber samples on Parcel 1. The work scope and flux chamber
sampling locations were approved in a November 15, 2013 email from the MDEQ to DTE
Gas and Stantec. Stantec, on behalf of DTE Gas, completed the flux chamber
sampling on September 18, 2014. The timing of the flux chamber sampling was delayed
because the sampling criteria (as outlined in the MDEQs Guidance Document for the
Vapor Intrusion Pathway dated May 2013) could not be met due to weather
conditions and delayed the sampling. A summary of the work completed in 2014 is
provided below.

3.1

Soil Boring Installation

The ResAP proposed the advancement of fifty-eight soil borings with fifteen of the soil
borings being converted to monitoring wells. Prior to beginning the soil boring
installation activities, a MISS DIG utility locate meeting was conducted to determine the
accessibility of each proposed boring location. During this meeting, numerous utility
manholes were observed along the east side of Parcel 1. The origin of the utility
manholes and the associated underground utilities were not known to the City of
Detroit or the attendees at the MISS DIG utility locate meeting. Based on available
information, it appears that the unknown utilities were installed by the DIBC.
Additionally, a storm sewer and electric line were identified on maps obtained from the
Michigan Department of Transportation (MDOT) as being connected to the pump
house southwest of Parcel 2. Based on the presence of these utilities, proposed borings
A1 and E1 and proposed monitoring wells AA1, EE1, Q1 and P1 were not installed due
to utility concerns. Soil borings SB-105-14, SB-106-14 and SB-107-14 were advanced to
replace proposed borings Q1, EE1 and P1, respectively. Additionally, SB-96-14 through
SB-101-14 were advanced to investigate oily substances and/or tar-like materials
observed in soil borings installed during the 2014 investigation.
Based on these changes to the ResAP, the 2014 investigation consisted of the
advancement of 61 soil borings (33 on Parcel 1, 26 on Parcel 2 and 2 on Parcel 2A). On
Figure 3, these borings are designated as SB-47-14 through SB-107-14. A prefix of P1, P2
or P2A was added to each boring name to identify the Parcel where the boring was
installed. The borings that were installed on each parcel are:
9

Parcel 1
P1SB-47-14 through P1SB-68-14;
P1SB-94-14 through P1SB-98-14; and,
P1SB-102-14 through P1SB-107-14.
Parcel 2
P2SB-69-14 through P2SB-86-14;
P2SB-89-14 through P2SB-93-14; and,
P2SB-99-14 through P2SB-101-14.
Parcel 2A
P2ASB-87-14 and P2ASB-88-14.
The depths of the borings ranged from 4 feet (auger refusal) to 36 feet bs.
During the advancement of the soil borings, soil samples were collected from select
boring locations as outlined in the October 2013 ResAP. The soil samples were
submitted for laboratory analysis of selected VOCs, PAHs, metals, phenols, available
cyanide, ammonia and pH. The soil analytical results are presented in Tables 7 through
9. Figure 6 presents the 2014 soil samples that exceeded the Part 201 screening criteria.
Laboratory analytical reports from the 2014 soil sampling are included as Appendix D.
The following Quality Assurance/Quality Control (QA/QC) samples were collected
during the soil boring installation:

Duplicate soil samples (4) results shown on Tables 7 through 9;

Matrix Spike/Matrix Spike Duplicate samples (4);
Equipment Blanks (2);
Field Blanks (4); and,
Trip Blanks (5).

Drilling logs for the 2014 soil borings are presented in Appendix B. The information
presented on these drilling logs indicate that contaminant source materials from historic
operations formerly present on Parcels 1, 2 and 2A were encountered in the subsurface.
A highly plastic clay unit was observed at depths ranging from 26 to 36 feet bs. Visual
impacts were not noted within this clay unit. The 2014 boring locations where
contaminant source materials are indicated are presented on Figure 6.

3.2

Monitoring Well Installation

The Work Plan proposed the installation of fifteen monitoring wells. Groundwater was
not encountered at all of the soil borings at the Site. Therefore, monitoring wells were
10

only installed at locations where a groundwater unit was observed. Based on these
observations, eleven monitoring wells were installed at the Site. The monitoring well
locations are shown on Figure 3. The wells that were installed on each parcel are:
Parcel 1
P1SB-65-14/MW-1;
P1SB-64-14/MW-2;
P1SB-59-14/MW-3;
P1SB-68-14/MW-4; and,
P1SB-105-11/MW-11
Parcel 2
P2SB-89-14/MW-5;
P2SB-81-14/MW-6;
P2SB-93-14/MW-7;
P2SB-92-14/MW-8;
P2SB-91-14/MW-9; and,
P2SB-90-14-/MW-10
Monitoring wells were not installed at the P1SB-94-14, P1SB-106-14 and P1SB-107-14
locations as groundwater was not observed at these locations. A monitoring well was
not installed at the proposed AA1 location (see Figure 3) due to utilities. A replacement
well was not proposed for this location due to the proximity of P1SB-65-14/MW-1.
Drilling/Well Construction logs for these monitoring wells are presented in Appendix B.
Following installation of the monitoring wells, the wells were developed by
pumping/surging until the pumped water was relatively free of particulate matter or the
well went dry at least three times. The top-of-casing elevation was then surveyed. From
top-of-casing elevations and depth to groundwater measurements, groundwater
elevations were determined.

3.3

River Gauges

It was stated in the Email Response to Notice of Approval of Response Activity Plan
Letter (DTE Gas email to the MDEQ dated December 5, 2013) that DTE will plan to
utilize stilling wells to monitor the river levels as suggested and will consider instrumenting
the stilling wells with data loggers when routine monitoring is implemented. Stilling well
installation was not completed during the soil boring/monitoring well installation phase
of the investigation as ice was still prevalent on the Detroit River and significant
anchoring to the seawall would need to be completed. Therefore, in order to establish
the elevation of the Detroit River during the groundwater sampling event, two river
gauges (RG-1 and RG-2 shown on Figure 3) were established at the top of the seawall
in Parcel 2. The river gauge elevations were surveyed relative to site elevation
11

benchmarks. If necessary, a methodology for installing the stilling wells can be discussed
with the MDEQ and provided to the City of Detroit for review and approval prior to
installing stilling wells.

3.4

Groundwater Gauging and Sampling

Depth to groundwater gauging data and groundwater samples were collected from
site monitoring wells on May 29 through June 2, 2014. A second groundwater gauging
event was completed on July 7, 2014. During the May 29, 2014 groundwater gauging
event, non-aqueous phase liquid (NAPL) was identified at the bottom of monitoring
wells MW-1, MW-3 and MW-5. Therefore, groundwater samples were not collected from
these monitoring wells.
Groundwater samples were submitted for laboratory analysis of selected VOCs, PAHs,
metals, phenols, available cyanide, ammonia and pH. The groundwater analytical
results are presented on Tables 10 and 11 and Figure 7. Groundwater elevation data
are presented in Table 12 and a groundwater contour map is included as Figure 8.
Laboratory analytical reports from the 2014 groundwater sampling are included as
Appendix E.
The following QA/QC samples were collected during the groundwater sampling event:

Duplicate groundwater samples (1) results shown on Tables 10 and 11;

Matrix Spike/Matrix Spike Duplicate samples (1); and,
Field Blanks (1).

An equipment blank was not collected as detailed in the ResAP as dedicated

downhole sample tubing was utilized for each individual monitoring well.

3.5

Flux Chamber Sampling

To further evaluate the potential ambient air risks from subsurface MGP residual
materials at and around the VP-3 area, the isolation flux chamber method (dynamicchamber method) was used to directly measure contaminant concentration at the soilair interface. A sampling plan to collect ambient air samples using flux chambers was
prepared and submitted to the MDEQ as part of a November 13, 2013 electronic
message from Stantec. In their November 15, 2013 electronic message to Stantec, the
MDEQ approved of the flux chamber sampling plan. The flux chamber samples were
collected on September 18, 2014. As noted above, the flux chamber sampling would
have occurred sooner, however, sampling criteria (as outlined in the MDEQs
Guidance Document for the Vapor Intrusion Pathway dated May 2013) could not be
met due to weather conditions and delayed the sampling.

12

On September 18, 2014, flux chamber samples were collected within a 100 foot radius
of VP-3 at the nine locations at and around VP-3 (Figure 3). On this figure, the flux
chamber sample locations are identified as P1FC-01-14 through P1FC-09-14. Flux
chamber samples were collected three times on September 18, 2014 at each sample
location. The work scope, sampling procedures and results of the sampling activities are
presented in Appendix F.

13

4.0

SITE DESCRIPTION

4.1

Site Setting

The Site is located in Section 24 of Township 2 South, Range 11 East (T2S R11E) of Wayne
County at 3085 West Jefferson Avenue in the City of Detroit, Michigan (Figure 1). The
Site is located adjacent to the Detroit River and Ambassador Bridge and consists of
approximately 10 acres of land. DTE Gas currently does not own any portions of the
Site.
The Site currently consists of portions of the City of Detroits Riverside Park (i.e., Parcel 1,
and 2) along with land owned by the NSC (Parcel 2A) (Figure 2). The Site is bounded by
Jefferson Avenue to the north, the Ambassador Bridge to the east, and the Detroit River
to the south. Railroad tracks are situated between Parcel 2A and Parcel 1 and are
reportedly used by various railroad companies. A vacant lot is situated west of
Riverside Park Parcel 1. Vehicles were observed parked in this lot during a portion of the
remedial investigation. A boat slip/launch is situated west of Riverside Park Parcel 2.
The surrounding properties are primarily commercial/industrial with the nearest
residential property located approximately 1,300 feet to the west of the Site (Figure 4).
On-Site groundwater is not being used as a drinking water source. The City of Detroit
receives its water supply from the Great Lakes System. According to the Detroit Water
and Sewerage Department (DWSD) website, the system uses fresh water from three
intakes. Two intakes are located in the Detroit River approximately 8 miles north and 14
miles south of the Site.

4.2

Geology/Hydrogeology

According to historical drilling logs for borings advanced within Township 2 South,
Range 11 East, the geology of the Site area consists of Pleistocene age glacial drift
underlain by Devonian age Dundee Limestone. The glacial drift ranges in thickness
from 73 feet to 114 feet and consists predominately of clay.
The discussion of the geology and hydrogeology of Parcels 1, 2 and 2A is based on the
evaluation of boring logs and soil descriptions presented in Appendix B.
The geology of Parcels 1, 2 and 2A consists of fill materials overlying native clay. The
thickness of the fill materials overlying the native clay ranges from approximately 8 feet
to 24 feet bg.
The fill materials above the native clay generally consist of the following:

14

Silty sand, clay and silt with concrete;

Wood debris, slag, coal, brick and concrete; and,
Dry, stiff clay (most likely a clay cap in some areas).

Residual contaminant source materials were encountered in some of the borings. As

indicated by the information in the boring logs, clay is generally present above residual
contaminant source materials. It appears likely that when the former MGP structures
and other structures were dismantled, a clay cap was placed over the contaminant
source materials.
Beneath the fill material is a brown clay unit that is present at depths ranging from 8 to
32 feet bs. Below the brown clay unit is a gray high plasticity clay unit that was
observed at depths ranging from 26 to 36 feet bs. Soil impacts were not observed within
this deeper clay unit.
The soil types and fill materials described above are presented on geologic cross
sections presented on Figures 9 and 10.
Groundwater beneath the Site was encountered intermittently within the fill materials.
Based on groundwater elevation data collected from site monitoring wells on May 29,
2014, the depth to groundwater is approximately 7 to 10 feet below the surface. The
ResAP proposed monitoring wells at the P1SB-94-14, P1SB-106-14, P1SB-107-14 and P2SB79-14 locations. However, groundwater was not encountered during the installation of
these borings. Therefore, monitoring wells were not installed. Based on the above
information, a continuous groundwater unit was not observed across the Site. It
appears that the groundwater encountered during the investigation does not
constitute a potable aquifer.
The May 29, 2014 groundwater contour map prepared from elevation data recorded in
site monitoring wells (Figure 8) indicates that groundwater flows south towards the
Detroit River.

15

5.0

SUMMARY OF PREVIOUS RESPONSE ACTIONS

The locations of the soil borings and monitoring wells advanced/installed as part of the
remedial investigations conducted on the Site are presented on Figure 3.
A
chronological summary of the correspondence with the MDEQ are presented as
follows:

Site Investigation Former Coal Gas Manufacturing Plant Station A (EDI Engineering &
Science (EDI); October 1984);
Additional Investigation, Investigation of Blue Staining of Surface Grasses Riverside
Park, Station A (EDI; March 1985);
Remedial Action Plan (EDI; October 1985);
Phase II Subsurface Investigation (TEI Environmental Solutions (TEI): January 2012);
Meeting with MichCon, City of Detroit, MDEQ and Stantec: (April 2012);
Response Activity Plan (Stantec; July 2012);
Response Activity Plan Comments (MDEQ; August 31, 2012);
Response to MDEQ Comments (Stantec; September 7, 2012);
Response Activity Plan Parcel 1 (Stantec; February 20, 2013);
Riverside Park Closure Notification Letter (City of Detroit; March 27, 2013);
Insufficient Information Letter (MDEQ; July 19, 2013);
Meeting between MDEQ and DTE Gas (October 16, 2013);
Email Correspondence to DTE Gas with Response Activity Plan Comments (MDEQ;
October 16, 2013);
Response Activity Plan Comments Email Response (Stantec; October 30, 2013);
Response Activity Plan (Stantec; October 30, 2013);
Response Activity Plan Air Sampling Comments (MDEQ; November 5, 2013);
Revised Air Sampling Plan (Stantec; November 8, 2013);
Email Approving Revised Air Sampling Plan (MDEQ; November 15, 2013);
Notice of Approval of Response Activity Plan Letter (MDEQ; December 4, 2013);
Email Response to Notice of Approval of Response Activity Plan Letter (DTE Gas;
December 5, 2013);
Notice of Exceedance of Groundwater/Surface Water Interface Criterion Based on
Acute Toxicity Letter (Stantec; June 25, 2014); and,
Meeting between MDEQ, City of Detroit and DTE Gas (November 12, 2014).

A summary of the remedial investigations and interim response actions discussed in the
correspondence above is presented in the following table.

16

Consultant
EDI
Engineering
& Science
(EDI)

1984

EDI

1985

TEI
Environment
al Solutions
(TEI)

Stantec
Consulting
Services, Inc.
(Stantec)

Stantec

Activity

Date of Activity

2011

2012

2014

Twenty-nine soil borings (S-1 through S-16, S-19 through

S-28 and S-30 through S-32), four surface sample
locations (SS-1, SS-2, SS-3 and SS-9), six monitoring wells
(W-1 through W-6) and six subsurface air wells (A-1
through A-6) were installed. Forty-four soil samples
were submitted for analysis for VOCs, base/neutrals,
total cyanide, total phenols and metals.
A blue PVC membrane overlain by approximately one
to two and a half feet of clean granular material,
topsoil and grass was placed over blue stained soil to
prevent potential direct contact exposures.
Six soil borings (SP-1 through SP-6) and three
temporary monitoring wells (SP-2, SP-3 and SP-6) were
installed. Nine soil samples were submitted for analysis
for VOCs, SVOCs, and metals.
Thirty-nine shallow soil borings (SB-1 through SB-5, SB-10,
SB-11, SB-11A, SB-14 through SB-39, SB-41, SB-43
through SB-46) and fifteen vapor points (VP-1 through
VP-10 and VP-12 through VP-16) were installed.
Seventy-six soil samples were submitted for analysis for
VOCs, PAHs, metals, phenols, available cyanide and
pH. Fifteen soil gas samples were collected from the
vapor points and submitted for analysis for VOCs,
naphthalene, 2-methylnaphthalene and mercury.
Sixty-one soil borings (SB-47-14 through SB-107-14) and
eleven monitoring wells (MW-1 through MW-11) were
installed on the property. Thirty-two soil samples and
eight groundwater samples were submitted for
analysis for VOCs, PAHs, phenols, metals, available
cyanide, ammonia and pH. Flux chamber sampling
was conducted at nine locations (P1FC-01-14 through
P1FC-09-14). Twenty-seven flux chamber samples
(three samples from each flux chamber location)
were submitted for laboratory analysis for BTEX, TMBs,
Naphthalene and 2-methylnaphthalene.

17

6.0

COMPLETED INTERIM RESPONSE ACTIONS

As discussed in the Remedial Action Plan (EDI; October 1985), shallow soils (generally
upper twelve inches) within Parcel 2 were stained blue as a result of former
manufactured gas purification processes which caused ferric ferrocyanide impacts. To
prevent direct contact exposures, a blue PVC membrane overlain by approximately
two to four feet of clean granular material, topsoil and grass was emplaced over parts
of the grassy areas within Parcel 2. Appendix C includes a map of the PVC membrane.

18

7.0

SOIL CHARACTERIZATION

The evaluation of constituents of potential concern (COPCs) in soil consisted of the

following:

7.1

Review of boring logs for the presence/absence of oily substances and tar-like
materials; and,
Comparison of soil data generated from vadose zone soil samples to the MDEQs
Part 201 nonresidential soil cleanup criteria.

Oily Substances and Tar-Like Materials

The presence of oily substances and/or tar-like materials was recorded in the boring
logs during the 1984, 2011, 2012 and 2014 investigations. Refer to Figures 5 and 6 for
locations of the borings indicated these residual contaminant source materials. The
data on Figures 5 and 6 indicate that residual contaminant source materials were
encountered within the former footprints of the MGP and the tar distillation operation.
Refer to Appendix B for copies of borings logs.

7.2

Constituents of Potential Concern in Soil

Soil analytical results for the individual COPCs outlined below and the Part 201
nonresidential cleanup criteria based on the December 30, 2013 MDEQ criteria tables
for these COPCs are presented in the following tables:

7.3

Table 1 1984 Soil Analytical Results Detectable VOCs and Base/Neutrals

Table 2 1984 Soil Analytical Results Metals
Table 3 2011 Soil Analytical Results
Table 4 2012 Soil Analytical Results VOCs, PAHs, Phenols, Available Cyanide and
pH
Table 5 - 2012 Soil Analytical Results Metals
Table 7 - 2014 Soil Analytical Results VOCs, PAHs, Available Cyanide, Ammonia
and pH
Table 8 2014 Soil Analytical Results Metals
Table 9 2014 Soil Analytical Results Phenols

Part 201 Soil Cleanup Criteria

The concentrations of the COPCs in soil samples collected at the Site were compared
to the MDEQs December 30, 2013 Part 201 nonresidential soil cleanup criteria.
Nonresidential cleanup criteria were used to compare to Site data because the
property is used for recreational (i.e., Riverside Park) and industrial (i.e., NSC property)
19

purposes. In Section 11.0, potential current unacceptable exposures to the COPCs for
human health and the environment are discussed based on current and potential
future uses of the Site.
In Section 7.4, the concentrations of the COPCs in soil samples are compared to the
following Part 201 nonresidential soil cleanup criteria:

Drinking water protection (DWP);

Groundwater/surface water interface protection (GSIP);
Soil volatilization to indoor air inhalation criteria (SVIIC);
Volatile soil inhalation criteria (VSIC; ambient air);
Particulate soil inhalation criteria (PSIC; ambient air); and
Direct contact.

The MDEQs Remediation and Redevelopment Division Operational Memorandum No.

2, Attachment 5 (October 22, 2004) states that the exposure assumptions inherent in the
Part 201 soil cleanup criteria are based on dry soils. Based on a review of boring logs,
soil samples SP-2 (14-15 ft), SP-3 (17-18 ft) and SP-4 (14-15 ft) were collected below
observed saturated conditions at these boring locations. Therefore, it is more
appropriate to use groundwater samples (Section 8.0) collected near these areas to
evaluate potential unacceptable exposures to COPCs. In Section 11.0, potential
current and unacceptable exposures to the COPCs to human health are evaluated.

7.4

Evaluation of COPCs in Soil

An evaluation of COPCs in soil based on the dates of sample collection is presented

below:

7.4.1 1984 Soil Data

Tables 1 and 2 present soil data collected during the 1984 investigation conducted by
EDI. Nonresidential DWP, GSIP, SVIIC, VSIC, PSIC and direct contact criteria were
exceeded in unsaturated zone soil samples collected during the 1984 investigation.
Refer to the Soil Exceeding Part 201 Criteria Map (Figure 5) for the locations of
unsaturated zone soil samples exceeding nonresidential criteria.
The potential for COPCs in soil to leach to groundwater in such a manner that
unacceptable drinking water and GSI exposures are indicated will be assessed by
evaluating the concentrations of COPCs in groundwater (Section 8.0).

20

7.4.2 2011 Soil Data

Table 3 presents soil data collected in October 2011. Analytical results collected from
below an observed saturated zone are noted on the table. Nonresidential DWP, GSIP,
SVIIC, VSIC, PSIC and direct contact criteria were exceeded in unsaturated zone soil
samples collected during the 2011 investigation. Refer to the Soil Exceeding Part 201
Criteria Map (Figure 5) for the locations of unsaturated zone soil samples exceeding
residential criteria.
The potential for COPCs in soil to leach to groundwater in such a manner that
unacceptable drinking water and GSI exposures are indicated will be assessed by
evaluating the concentrations of COPCs in groundwater (Section 8.0).

7.4.3 2012 Soil Data

Tables 4 and 5 present shallow soil data collected in September 2012. Nonresidential
DWP, GSIP and direct contact criteria were exceeded. SVIIC, VSIC and PSIC criteria
were not exceeded in the shallow soil samples. Refer to the Soil Exceeding Part 201
Criteria Map (Figure 5) for the locations of unsaturated zone soil samples exceeding
residential criteria.
The potential for COPCs in soil to leach to groundwater in such a manner that
unacceptable drinking water and GSI exposures are indicated will be assessed by
evaluating the concentrations of COPCs in groundwater (Section 8.0).

7.4.4 2014 Soil Data

Tables 7 through 9 present data for soil samples collected in January through May 2014.
Nonresidential DWP, GSIP, SVIIC, VSIC and direct contact criteria were exceeded. PSIC
criteria were not exceeded in the soil samples. Refer to the Soil Exceeding Part 201
Criteria Map (Figure 6) for the locations of unsaturated zone soil samples exceeding
residential criteria.
The potential for COPCs in soil to leach to groundwater in such a manner that
unacceptable drinking water and GSI exposures are indicated will be assessed by
evaluating the concentrations of COPCs in groundwater (Section 8.0).
In Section 11.0, potential current and unacceptable exposures to the COPCs to human
health and the environment are discussed based on current and potential future uses
of the Site.

21

8.0

GROUNDWATER CHARACTERIZATION

The evaluation of COPCs in groundwater consisted of the following:

8.1

Review of gauging data for the presence/absence of NAPLs; and,

Comparison of groundwater data generated from samples collected from site
monitoring wells to the MDEQs Part 201 nonresidential groundwater cleanup
criteria.

Non-Aqueous Phase Liquids

Approximately 2-3 inches of Dense Non-aqueous phase liquids (DNAPLs) were observed
at the bottom of the monitoring wells MW-1, MW-3 and MW-5 during the groundwater
gauging/sampling event on May 29, 2014. Refer to Figure 3 for locations of MW-1, MW3 and MW-5. The presence of DNAPL at each location was verified with a disposable
bailer.
NAPLs were observed within the soil during previous site investigations and the 2014
remedial investigation. The locations and depths of the observed NAPLs are shown on
Figures 5 and 6.

8.2

COPCs in Groundwater

Groundwater analytical results for the individual COPCs outlined below and Part 201
nonresidential cleanup criteria for these COPCs are presented in the following tables:

8.3

Table 10 Groundwater Analytical Results VOCs, PAHs, Metals, Cyanide and

Ammonia
Table 11 Groundwater Analytical Results Phenols

Part 201 Groundwater Cleanup Criteria

The evaluation of COPCs in groundwater consisted of the comparing groundwater

data to the following Part 201 groundwater cleanup criteria:

Non-residential drinking water criteria;

GSI criteria;
Final acute value (FAV); and,
Nonresidential volatilization to indoor air inhalation criteria (GVIIC).

In Section 11.0, potential current and unacceptable exposures to the COPCs to human
health are evaluated.
22

8.4

Evaluation of COPCs in Groundwater

A groundwater sampling event was conducted from May 20 through June 2, 2014.
Refer to Tables 10 and 11 for a summary of the analytical results from this event. Refer
to the Groundwater Analytical Map May 29 June 2, 2014 (Figure 7) for the
groundwater analytical data.
The May-June 2014 data indicate that the horizontal extent of COPCs in groundwater
has not been defined. The following compounds and the MDEQ cleanup criteria that
were exceeded are:

Benzene (DW, GSI, Final Acute Value (FAV));

Toluene (GSI);
Ethylbenzene (DW, GSI, FAV);
Xylenes (DW, GSI, FAV);
1,2,4-trimethylbenzene (DW, GSI);
1,3,5-trimethylbenzene (DW, GSI);
Acenaphthene (GSI);
Flourene (GSI);
Naphthalene (DW, GSI, FAV);
Phenanthrene (GSI, FAV);
2-Methylnaphthalene (GSI);
2-4-dimethylphenol (GSI);
Cresols (GSI);
Arsenic (DW, GSI, FAV);
Lead (DW, GSI);
Available Cyanide (GSI, FAV); and,
Unionized Ammonia (GSI)

The May June 2014 data indicate that the groundwater concentrations did not
exceed the nonresidential volatilization to indoor air inhalation criteria.
In Section 11.0, potential current and unacceptable exposures to the COPCs to human
health and the environment are discussed based on current and potential future uses
of the Site.

23

9.0

SOIL GAS CHARACTERIZATION

9.1

COPCs in Soil Gas

Soil gas analytical results for the individual COPCs outlined below and Part 201
nonresidential cleanup criteria for these COPCs are presented in Table 6 Soil Gas
Analytical Results.
BTEX
Naphthalene
2-methylnaphthalene
TMBs
Mercury

9.2

Part 201 Soil Gas Screening Criteria

The evaluation of COPCs in soil gas consisted of comparing soil gas data to the
Nonresidential Vapor Intrusion Deep Soil Gas Screening Level published by the MDEQ in
May 2013.
In Section 11.0, potential current and unacceptable exposures to the COPCs to human
health are evaluated.

9.3

Evaluation of COPCs in Soil Gas

Refer to the Response Activity Plan Parcel 1 Riverside Park (Stantec; February 20, 2013)
for the soil gas sampling methodology. The soil gas analytical results are presented in
Table 6. The MDEQs Part 201 nonresidential vapor intrusion deep soil gas screening
levels (SGVI-nr) are presented in Table 6 for comparison purposes. SGVI-nr values are used
to evaluate vapor intrusions of COPCs into indoor air.
The data in Table 6 indicate that mercury was not detected in the soil gas samples.
The data in Table 6 and on Figure 11 indicate that SGVI-nr screening values were not
exceeded in 14 of the 15 soil gas samples collected. As indicated in Table 6, the screen
intervals of the Parcel 1 soil gas probes ranged from 3 feet to 5.5 feet bs. The screen
intervals of the Parcel 2 gas probes ranged from 1.5 feet to 4.0 feet bs. Based on the
review of boring logs presented in the Appendix B, with the exception of one boring
(VP-3), residual MGP source materials were not encountered in the upper 5 feet of the
subsurface. Residual MGP source materials were encountered in the soil gas probe VP3 boring at 3.5 feet to 6 feet bs. The screen of VP-3 was installed within MGP residue
from 5 feet to 5.5 feet bs. Therefore, since the VP-3 screen was installed within MGP
24

residue (source of soil gas impacts), the soil gas sample collected from VP-3 is
considered representative of residual MGP source materials (i.e. represents worst case
soil gas emissions).
The data in Table 6 indicate that the concentration of benzene in VP-3 (Parcel 1)
exceeded the SGVI-nr screening values. No exceedances of the SGVI-nr screening values
were observed on Parcel 2.
In Section 11.0, potential current and unacceptable exposures to the COPCs to human
health and the environment are discussed based on current and potential future uses
of the Site.

25

10.0 AMBIENT AIR CHARACTERIZATION

On September 18, 2014, flux chamber samples were collected at nine locations at and
around VP-3 (Figure 3). The flux chamber sample locations are identified as P1FC -01-14
through P1FC-09-14 on Figure 3. Flux chamber samples were collected at three
different times on September 18, 2014 at each sample location. The flux chamber
samples were transported to a laboratory for analysis of the following compounds by
method TO-15:

BTEX;
TMBs; and,
2-Methylnaphthalene and naphthalene.

The flux chamber analytical results are presented in Appendix F. As indicated by the
information in Appendix F, the flux chamber analytical results indicate that there are no
unacceptable exposures to the ambient air pathway.

26

11.0 ENVIRONMENTAL RECEPTORS AND PATHWAYS

Exposure to a receptor can only occur if there is a complete exposure pathway, and a
complete exposure pathway consists of the following elements as listed below (Risk
Assessment Guide for Superfund, Volume II: Environmental Evaluation Manual; USEPA,
1989).

A source of chemical;
A mechanism by which the chemical is released;
A retention or transport medium through which a chemical travels from the point of
release to the receptor location; and,
A route of exposure (ingestion, inhalation, or dermal contact) by which the
chemical enters the receptors body and causes potential adverse health effect.

If any of these elements do not exist or are not present, the exposure pathway is
considered incomplete and exposure is unlikely.
The exposure pathways that appear to be relevant to the on-Site and off-Site
environmental receptors are:

Drinking water exposure pathway (on-Site and off-Site)

Groundwater/surface water interface pathway
Volatilization to indoor air exposure pathway
Volatilization to ambient air exposure pathway
Direct contact with soil

Based on soil, groundwater and/or soil gas analytical results and background research
on the Site and surrounding area, the evaluation of the above environmental receptors
and relevant exposure pathways is presented in subsequent sections of this report.

11.1

Drinking Water Pathway

Groundwater underneath the Site is not used as a drinking water source. The drinking
water for the City of Detroit is supplied by the Detroit Water and Sewerage Department
(DWSD) that obtains fresh water from the Great Lakes System. According to the DWSD
website, the system uses fresh water from three intakes. Two intakes are located in the
Detroit River: one to the north near the mouth of Lake St. Clair (approximately 8 miles
from the Site) and one to the south near Lake Erie (approximately 14 miles from the
Site). The third intake is located in Lake Huron (approximately 61 miles from the Site). As
stated in Section 4.2, groundwater is only intermittently present underneath the parcels.
Based on the above, the drinking water pathway is not relevant and the drinking water
criteria are not applicable.
27

11.2

Volatilization of COPCs in Soil and Groundwater to Indoor Air

There are no buildings situated on Parcels 1, 2 and 2A. Therefore, unacceptable indoor
air exposures are not indicated. Because of the lack of buildings and since buildings
are not planned to be constructed on the parcels, the indoor air pathway is not
relevant and the Part 201 soil and groundwater indoor air criteria are not applicable.

11.3

Volatilization of COPCs in Soil to Ambient Air

11.3.1 Parcel 1
This pathway is relevant; however, for reasons discussed below there are no
unacceptable exposures. The data in Table 6 indicate that the concentration of
benzene in VP-3 exceeded the SGVI-nr screening values. However, as described in
Response Activity Plan Parcel 1 Riverside Park (Stantec; February 20, 2013), the
concentrations of COPCs in the VP-3 soil gas do not result in unacceptable ambient air
exposures to recreational users. To further evaluate potential ambient air risks, the
following activities were conducted:

Ambient air concentrations of COPCs detected in the VP-3 soil gas sample were
estimated by modeling the vapor flux rates of COPCs from soil gas;
The risk associated with the modeled concentrations of COPCs in ambient air was
then calculated and the risks were determined to be acceptable (i.e, no
unacceptable risk) per Part 201; and,
As indicated by the information in Appendix F, the flux chamber analytical results
indicate that there are no unacceptable ambient air exposures.

During the 2014 remedial investigation, a soil sample collected from the P1SB-10514/MW-1 (8-13) location indicated benzene, naphthalene and phenanthrene
concentrations exceeding VSIC. Based on the presence of clay from the ground
surface to 13.5 feet bs, there are no unacceptable ambient air exposures.

28

11.3.2 Parcel 2
This pathway is relevant; however, for reasons discussed below there are no
unacceptable exposures. The data in Table 6 indicate that the concentrations of
COPCs in the soil gas samples did not exceed the SGVI-nr screening values. Based on this
information, there are no unacceptable ambient air exposures on Parcel 2.

11.3.3 Parcel 2A
This pathway is relevant; however, for reasons discussed below there are no
unacceptable exposures. Parcel 2A consists of railroad property and is maintained by
NSC. Access to Parcel 2A is reasonably restricted by fencing separating Parcel 2A from
public activities on Parcel 1 and Parcel 2. Based on this information and the ambient air
assessment completed around VP-3, there are no unacceptable ambient air exposures
on Parcel 2A.

11.4

Direct Contact with COPCs in Soil

11.4.1 Parcel 1
Potential unacceptable exposures to the direct contact pathway were evaluated by
comparing the concentrations of COPCs in soil to nonresidential direct contact criteria.
The soil samples that contained COPCs in excess of nonresidential direct contact
criteria are presented on Figures 5 and 6. As indicated on these figures and the soil
analytical tables, none of the soil samples that exceeded the direct contact criteria on
Parcel 1 were collected at the surface. The soil samples exceeding direct contact
criteria were identified at depths ranging from 7.5 to 15 feet bs. Based on the depth of
the soil exceeding the direct contact criteria, there are no current unacceptable
exposures on Parcel 1 to the direct contact pathway. However, as previously noted the
DIBC appears to have completed subsurface activities along the northeastern
boundary of Parcel 1 since the 2012 site investigation. It may be necessary for the DIBC
or the City of Detroit to further evaluate the area disturbed by the DIBC to ensure
exacerbation of subsurface contamination hasnt occurred. Future potential direct
contact exposures will be prevented by conducting additional interim response actions
and/or restricting subsurface activities.

11.4.2 Parcel 2
Potential unacceptable exposures to the direct contact pathway were evaluated by
comparing the concentrations of COPCs in soil to nonresidential direct contact criteria.
The soil samples that contained COPCs in excess of nonresidential direct contact
criteria are presented on Figures 5 and 6. The soil samples exceeding direct contact
criteria on Parcel 2 were identified at depths ranging from 0.5 to 9 feet bs. The shallow
29

soil sample exceeding direct contact on Parcel 2 (P2SB-70-14 0.5-2 bs) is located
beneath the asphalt parking lot. The soil sample (P2SB-92-14 7-9 bs) exceeding direct
contact criteria within the grassy area of Parcel 2 is at a depth of 7 to 9 feet bs.
Additionally, as shown in Appendix C, a PVC membrane was emplaced within the
grassy areas of Parcel 2 to prevent direct contact exposure. Based on access to Parcel
2 being restricted by a locked gate, the presence of asphalt and the PVC membrane,
there are no current unacceptable exposures on Parcel 2 to the direct contact
pathway. Future potential direct contact exposures will be prevented by conducting
additional interim response actions and/or restricting subsurface activities.

11.4.3 Parcel 2A
Potential unacceptable exposures to the direct contact pathway were evaluated by
comparing the concentrations of COPCs in soil to nonresidential direct contact criteria.
The soil samples that contained COPCs in excess of nonresidential direct contact
criteria are presented on Figures 5 and 6. Soil samples collected on Parcel 2A did not
exceed the direct contact criteria. Based on access to Parcel 2A being reasonably
restricted there are no current unacceptable exposures on Parcel 2A to the direct
contact pathway. Future potential direct contact exposures will be prevented by
conducting additional interim response actions and/or restricting subsurface activities.

11.5

Groundwater/Surface Water Interface Pathway

Concentrations of COPCs in groundwater samples collected from monitoring wells

located near the river exceed generic GSI and FAV criteria. The exceedances are
shown on Table 10. Based on these data and the proximity of the monitoring wells to
the Detroit River, the evaluation of potential unacceptable impacts to the river is
warranted.

30

12.0 CONCLUSIONS
The following conclusions were derived based on the information presented in this
Report:

The former MGP, tar distillation, Pintsch gas plant and toluene production
structures have been identified in historical maps and photographs as the
primary potential contaminant source areas.

Oily substances and/or tar-like materials were observed at boring locations

advanced in proximity to the former MGP, tar distillation, toluene production
structures and Pintsch gas plant structures.

Current unacceptable exposures to the drinking water pathway are not

occurring because Site groundwater is not used as a drinking water source.
Future potential unacceptable drinking water exposure can be prevented by
restricting groundwater uses.

There are no buildings situated on Parcels 1, 2 and 2A. Therefore, there are no
unacceptable indoor air exposures occurring.

Concentrations of COPCs in groundwater samples collected from monitoring

wells located near the river exceed generic GSI criteria and FAV screening levels.
A Notice of Exceedance of Groundwater/Surface Water Interface Criterion
Based on Acute Toxicity letter was submitted to the MDEQ on June 25, 2014.
Additionally, a Notice of Intent to Evaluate Final Acute Value Exceedances letter
was submitted to the MDEQ on July 21, 2014. As discussed in Section 14.0 of this
Report, future response actions include a Request for Mixing Zone Determination
and Feasibility Analysis. These response actions will satisfy the requirements
outlined in the July 21, 2014 letter to commence activities to evaluate the FAV
exceedances.

Based on visual observations, the native clay unit observed from 26 to 36 feet bs
at the Site delineates the vertical extent of the impacts.

Ambient Air Exposure

o

Ambient air concentrations of COPCs detected in the VP-3 soil gas sample
were estimated by modeling the vapor flux rates of COPCs from soil gas. This
location was chosen because the benzene soil gas concentrations at VP-3
(79,000 ppbv) was the only exceedance of the SGVI-nr screening values.
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Based on the modeled concentrations of COPCs at VP-3 in ambient air, there

are no unacceptable risks associated with the VP-3 area (refer to the
Response Activity Plan Parcel 1 Riverside Park (Stantec; February 20, 2013).

As indicated by the information in Appendix F, the flux chamber analytical

results indicate that there are no unacceptable ambient air exposures at any
of the parcels (Parcel 1, 2, or 2A).

In addition, either pavement or a PVC membrane covers Parcel 2 to further

limit any potential risks. Also, access to Parcel 2A is reasonably restricted and
soil samples collected from Parcel 2A did not exceed the VSIC criteria.

Direct Contact Exposure

o

There are no current unacceptable exposures to the direct contact pathway

on Parcel 1. This is concluded because the only soil samples that exceeded
direct contact criteria were identified at depths ranging from 7.5 to 15 feet
below the surface on Parcel 1. Future potential direct contact exposures will
be prevented by conducting additional interim response actions and/or
restricting subsurface activities.

There are no current unacceptable exposures to the direct contact pathway

on Parcel 2. This is concluded because the only soil samples that exceeded
direct contact criteria were identified at depths ranging from 0.5 to 9 feet
below the surface on Parcel 2. Access to these locations is restricted either
by pavement or a PVC membrane installed under the grassy areas on Parcel
2. Future potential direct contact exposures will be prevented by conducting
additional interim response actions and/or restricting subsurface activities.

There are no current unacceptable exposures to the direct contact pathway

on Parcel 2A. This is concluded because the soil samples collected on Parcel
2A did not exceed the direct contact criteria. Oily and tar-like substances
were observed on Parcel 2A at depths of 8 to 12 feet bs. Based on access to
Parcel 2A being reasonably restricted and the depth to the observed
impacts, there are no current unacceptable exposures on Parcel 2A to the
direct contact pathway. Future potential direct contact exposures will be
prevented by conducting additional interim response actions and/or
restricting subsurface activities.

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13.0 DATA GAPS

The following potential data gaps have been identified based on the information
presented in this Report.

The lack of groundwater use and subsurface activities restrictions (i.e., Restrictive
Covenant) for the Site is a data gap. Such restrictions will likely be required to
procure a No Further Action status.

The lack of mixing zone-based GSI criteria is a data gap. A request to develop
mixing zone-based GSI criteria will be submitted to the MDEQ.

The lack of location and depth information for the utilities located along the east
side of Parcel 1 is a data gap. The origin of these utilities is unknown. The utility
location and construction information should be obtained by the City of Detroit for
the utilities that have been installed on their property (if possible).

The lack of soil and groundwater analytical data from the east side of Parcel 1 is a
data gap. Soil borings/monitoring wells can be installed in this area after utility
information is obtained by the City of Detroit.

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14.0 ADDITIONAL FUTURE RESPONSE ACTIONS

The objectives of the future response actions are to:

Further define the extent of residual MGP subsurface source materials within and
around potential contaminant source areas.
o Additional site investigation activities will be completed to further define the
extent of any remaining MGP impacts.
Complete additional evaluation of potential unacceptable impacts to the Detroit
River.
o A Request for a Mixing Zone Determination will be completed and submitted
to the MDEQ. The Mixing Zone Determination will request site-specific
groundwater/surface water interface criteria for the interface with the Detroit
River. Prior to the preparation of the Request for Mixing Zone Determination,
an evaluation will be completed to determine if additional data are required
to complete the Request. Additional data collection may include, but is not
limited to, monitoring well installation and groundwater sampling events.
Complete a Feasibility Analysis to determine the appropriate remedial action plan.
o Following receipt of the additional investigation data and the Request for
Mixing Zone Determination, a Feasibility Analysis will be completed. The
Feasibility Analysis will include options for remediation or elimination of
exposure pathways and the data required to complete this evaluation.

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