Hazardous Waste Cleanup: Tecumseh Products Company Facility - Tecumseh, Michigan

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Cleanup Status
Site Description
Additional Site Information
Contaminants at this Facility
Institutional/Engineer Controls
Land Reuse
Site Responsibility

TPC was brought under RCRA regulation when they applied for and were granted Interim Status for container and tank storage areas for solvent wastes in June 1982. Later that year the tank and drum storage area underwent closure. Thereafter TPC was a hazardous waste generator until 2008, when manufacturing stopped.

A Phase II investigation was done by an interested buyer in January 2009. contamination was discovered onsite in soil and shallow groundwater. Exceedances of VOCs contamination was discovered onsite in soil and shallow groundwater. In March 2009, TPC sampled the groundwater at surrounding properties. It was determined that contaminated groundwater was moving offsite. TPC notified the Michigan Department of Environmental Quality and residents within the and facilitated connection to municipal water where needed in April 2009. The site was referred by MDEQ to EPA in May 2009. EPA Region 5 immediately began working with EPA Headquarters to add TPC to the Government Performance and Results Act 2020 Baseline. EPA entered into an Administrative Order of Consent with TPC March 2010. TPC sold the facility in 2010, but remains the legally responsible party for cleanup. The property was sold again most-recently in 2016.

Cleanup Status

Soil Gas Interim Remedies – A soil vapor extraction system was installed in the northern portion of the site in spring/summer 2012. This system prevents

soil vapors from entering the newest portion of the building (scheduled to remain on-site),
removes contamination in the soil, and
controls the off-site migration of soil vapor.

In 2013 a second SVE system was installed at the south property line after additional contamination was identified. These systems will be expanded as part of the Final Remedy to prevent ongoing contamination of the groundwater into the future. Soil gas at residential properties close to the Tecumseh Products groundwater plumes was evaluated by sampling indoor air at individual homes. In other cases, soil gas was addressed by installing mitigation systems, similar to radon systems. EPA requested the installation of those systems in certain areas because the conditions are expected to change and fluctuate during future cleanup actions by TPC. To date, indoor air contamination at unacceptable levels was found in only one home, which was addressed by TPC. The Michigan Department of Community Health and Michigan Department of Environmental Quality have been assisting EPA with evaluation of the results and coordination with residents..

Groundwater Interim Remedies – A permeable reactive barrier was installed by TPC in May 2011 along the southern half of the eastern property boundary. The purpose was to reduce the concentrations of contaminants in shallow groundwater and eliminate the potential for soil gas vapor intrusion into buildings above the plume. Shallow wells close to the PRB suggest a beneficial effect, but additional groundwater treatment is needed, as proposed in the March 2017 CMP.
Investigation status – An investigation report was submitted by TPC in September 2012. The report was not approved at that time, and TPC has collected additional information as agreed under the AOC to address concerns identified by EPA. Upon completion of the ongoing work, EPA believes there is sufficient information to select a final remedy. Supplemental information will continue to be collected throughout the remediation process.
Next steps – In March 2017, TPC submitted a comprehensive Revised CMP. EPA reviewed the proposal and prepared a Statement of Basis that summarizes the selected remedy. The Statement of Basis will be presented for public comment in late-2018, and a public meeting may be held to present the proposal and answer questions, if requested. After the comment period, EPA will issue a Final Decision and TPC will install the remedy in late early 2019. The systems will be operated for a number of years, based loosely on the schedule outlined in the CMP, and monitoring will be performed to ensure the effectiveness of the remedy long into the future. Redevelopment activities will occur concurrently with cleanup activities, using the Restrictive Covenant as a basis for ensure the protection of future visitors and occupants.

Site Description

The 53-acre, former Tecumseh Products Company plant signed an Order with EPA Region 5 in March 2010 to conduct RCRA Corrective Action activities. The property was acquired by TPC in 1934 to produce automotive parts, refrigeration systems, small tools and toys, and later for reconditioning compressors and condensing units for refrigeration and air conditioning units, with operations including parts degreasing, unit assembly, paint preparation, unit painting, unit reconditioning, shipping and receiving. As required by the program, Tecumseh Products Company is conducting a facility investigation to determine if any areas of the site have released hazardous ingredients to the environment, evaluating EPA's forms, and performing interim measures to prevent or lessen unacceptable threats to human health and the environment.

Additional Site Information

A quarterly monitoring program was enacted April, 2010, and soil gas sampling has been conducted above the groundwater plume. Groundwater pollutants extend beyond the facility boundary in plumes extending to the northeast and east. The southern-most plume discharges to wetland adjacent to the River Raisin, approximately ½-3/4 miles east of the facility. Sub-slab soil gas samples collected underneath the facility showed elevated levels of TCE throughout the footprint of the building prior to demolition. Off-site soil gas and indoor air sampling has generally been favorable, but several residential mitigation systems were installed as a preventative measure in areas close to the plumes.

In September 2012, TPC submitted an investigation report. EPA requested additional information. The additional information was collected between 2013 and 2016, and was used to determine the areas requiring cleanup and further monitoring. In January 2016, TPC submitted a CMP and EPA asked for further clarifications. The collection and evaluation of data from source areas, throughout the site, and at off-site locations is ongoing. This data was used to amend the proposal for soil and groundwater cleanup in March 2017.

Contaminants at this Facility

Major contaminants of concern are

Trichloroethene (1,1,1-TCE)
Trichloroethane (1,1,1-TCA)
Cis-1,2-dichloroethene (1,2-DCE)
Vinyl chloride, and
Tetrachloroethene (PCE) in groundwater, and to a lesser extent, on-site soil.

Institutional and Engineering Controls at this Facility

Institutional Controls on the property include

a nonresidential land use restriction,
vapor mitigation control requirements on existing and new construction,
prevention of damage to monitoring wells and corrective measures on property,
prohibition on groundwater use or well installation (except for cleanup), and
special handing (due care) requirements for contaminated soil.

Engineering controls at the property include operating SVE systems and will include additional vapor mitigation controls and/or engineered barriers.

Governmental Institutional Controls include the City of Tecumseh Ordinance #4-11, Groundwater Use Ordinance (Lenawee County, Liber 2532, Page 0965, recorded September 21, 2016) for the off-site area of impacted groundwater.

Land Reuse Information at this Facility

The property was purchased in 2016 by 100 E. Patterson, LLC, and is scheduled for mixed commercial redevelopment.

Site Responsiblity at this Facility

Corrective Action activities at this facility have been conducted under the U.S. Environmental Protection Agency with support from the Michigan Department for Environmental Quality.