Congressional District # 05
FOREST WASTE PRODUCTSEPA ID# MID980410740
Last Updated: July, 2012
The Forest WasteProducts (Forest Waste) site is located in Forest Township, Genesee County, Michigan. The original site area encompassed 112 acres. The site was later expanded to include an additional 80-acre parcel in September 2005. Waste disposal areas located on-site include an 11-acre landfill and nine former lagoons that span a total of one acre. The site is surrounded by low-density residential development, farmland, wetlands, wood lots, a gravel quarry, and a small lake.
The site owners received a license from the state of Michigan in 1972 to dispose of general refuse and industrial and liquid waste. Wastes were accepted between 1973 and 1978. Wastes containing polychlorinated biphenyls (PCBs) and polybrominated biphenyls (PBBs) are documented to have been disposed of in the landfill. Soils in the former lagoon area were contaminated with metals, PCBs, and volatile organic compounds (VOCs). The state did not renew the license in 1978 due to operational and other various violations.
Area residences use private wells for drinking water. The subsurface groundwater sampling conducted through 1994 defined groundwater contamination as limited to the original site area east of the landfill and in the vicinity of the lagoons. In December 1995, groundwater contamination by VOCs was detected north of the landfill and outside the original site area. Later sampling has showed that the groundwater contamination from north of the landfill extends beyond the additional 80-acre parcel that was added to the site.
U.S. EPA fenced the site in 1984, conducted sampling to locate the soil and groundwater contamination from 1983 - 1992, and evaluated methods to cleanup the site from 1986 - 1993. Private parties who may be responsible for the contamination performed the other work under U.S. EPA and state agency oversight. Prior to 1994, the private parties removed wastes from the lagoons and landfill and initiated groundwater sampling. In accordance with a 1994 agreement, the private parties are responsible for all of the remaining cleanup work, including covering the landfill with a soil cap, treatment of the contamination north of the landfill, sampling groundwater, and other monitoring. Private parties must also reimburse federal oversight costs.
Threats and Contaminants
Wastes containing PCBs and PBBs are documented to have been disposed of in the landfill. Soils in the former lagoon area were contaminated with metals, PCBs, and VOCs. The groundwater was primarily contaminated with VOCs.
A health threat existed due to the potential for contact with contaminants and wastes by trespassers, including children. This health threat was eliminated by construction of a fence in 1984, complete removal of the lagoon contamination in 1989, and construction of a cap over the landfill in 1997. A health threat would exist if the landfill or site ground water were developed in the future. This health threat is being controlled by restrictions on usage of the site.
Vinyl chloride was the VOC of most concern, until the summer of 2011 when 1,4-dioxane was detected at more than 100 ug/l. There is concern about exposure to nearby residential well users from groundwater contamination. Although such exposure is unlikely, this concern is being addressed by groundwater monitoring. A health threat or interference with the groundwater treatment and monitoring could result from new groundwater pumping near the site. This health threat is being addressed through groundwater treatment, monitoring, and restrictions on installation of new pumping wells under Genesee County Health Regulations.
U.S. EPA installed a fence around the site in August 1984. Between 1985 and 1988, U.S. EPA sampled wastes, groundwater, and soil, and evaluated cleanup methods. Private parties completely removed contamination from the lagoons in 1988. About 9,000 tons of solidified waste and soil and almost 57,000 gallons of liquid wastes were disposed of off-site. In 1990, U.S. EPA dug 500 barrels of waste from the landfill. In 1992, private parties disposed of these barrels off-site. In 1993, the private parties removed about 3,000 barrels of waste and almost 2,000 cubic yards of contaminated soil from the landfill and disposed of them off-site.
A group of private parties entered into an agreement with U.S. EPA in 1994 to complete the remaining cleanup work. Between 1990 and 1992, U.S. EPA annually sampled groundwater east of the landfill to assure that contamination was not moving off-site. The annual sampling was later taken over by private parties beginning in 1993. This sampling continues today. To date, no significant groundwater contamination has moved off-site from east of the landfill. Private parties constructed a cap over the landfill in 1997.
VOC contamination was first detected north of the landfill in December 1995. Between 1996 and 2007, the private parties conducted a series of sampling events to locate the extent of contamination from north of the landfill. In 1997, the private parties purchased an 80-acre property north of the landfill. It was found that most of the contamination from north of the landfill underlies this 80-acre parcel. In 2000, vinyl chloride was detected in groundwater near the boundary of the 80-acre parcel, and in 2002 it was confirmed that this contamination extends beyond the 80-acre parcel. Annual sampling of nearby residential wells was initiated in 2001 and the groundwater monitoring network was extended to the boundaries of the vinyl chloride plume.
The private parties evaluated and tested groundwater treatment technologies to treat groundwater contamination north of the landfill from 2001 - 2004. In September 2005, U.S. EPA decided that the cleanup of the contamination north of the landfill should include expanding the site to include the additional 80-acre parcel, applying the cleanup standards to the boundaries of the expanded site and using natural dilution and biodegradation to help achieve the cleanup standards, treatment of deep and shallow groundwater contamination near and beyond the expanded site boundaries by injecting oxidants, treatment of shallow groundwater near the landfill by injecting oxygen or by digging a trench through the shallow groundwater and injecting air to remove the contamination, shut-down criteria for the groundwater treatment, and restricting installation of new monitoring wells near the site using Genesee County Health Regulations. From 2005 - 2006, U.S. EPA worked with the private parties, and Genesee County to better define the groundwater pumping restriction areas, and construction requirements for new wells in these areas.
From 2007 - 2010, the private parties tested and performed oxidant injections near the boundaries of the vinyl chloride plume in accordance with approved plans. In November 2007 U.S. EPA decided that groundwater treatment near the landfill is not required because VOC concentrations decreased near the landfill, and are at very low concentrations a short distance farther from the landfill. To date (December 2011) the oxidant injections near the contaminant boundaries have not resulted in successful treatment, and the vinyl chloride contamination has expanded in the shallow aquifer. Oxidant injection by recirculation was tested during the summer of 2011 with inconsistent results. The detection of 1,4-dioxane in the sentinel wells beyond the vinyl chloride plume probably cannot be controlled by oxidant injections, and, therefore, work on oxidant injections has been discontinued. Instead an groundwater investigation is proceeding to define the extent of the 1,4-dioxane groundwater contamination.
U.S. EPA completed five-year reviews in 1997, 2002 and 2007. The 2007 five-year review identified concern about methane contamination from the landfill, and with entry of the oxidant into the lake. These concerns were addressed by adding dissolved methane to the groundwater monitoring, monitoring for oxidant at the ends of the injection lines closest to the lake and eliminating injection points nearest to the lake where oxidant was detected.
Success StoryThe private parties have been very cooperative with U.S. EPA and the state of Michigan in conducting the investigations and cleanup actions. Genesee County was very cooperative in working with U.S. EPA to establish well-usage restrictions in the pumping restriction areas.
Community InvolvementIn March 2001, U.S. EPA prepared and distributed a fact sheet to update interested parties on progress and conditions at the site after VOCs were detected near the expanded site boundaires. In June 2005, U.S. EPA prepared and distributed a fact sheet to provide an update on site conditions and present cleanup methods being considered. U.S. EPA conducted a public comment period from July 10, 2005 to August 9, 2005, and a public meeting on July 20, 2005. Nearly 200 people attended. U.S. EPA distributed another fact sheet and conducted a public meeting in August 2007 to update residents on the pumping restriction area, the final design of the chemical injection systems, and other data.
All of the site property is under the control of Forest Township. The site is fenced (except for the additional 80-acres where no disposal occurred) and there is a separate fence around the landfill. Deed notices on the site property prohibit the following:
- Interference with the cleanup
- Use of groundwater (other than for monitoring)
- Access to the landfill area
- Excavation, regrading or removal of soil from the landfill area exept as necessary for monitoring and maintenance of the site cap; all construction except as approved by U.S. EPA and the state agency; removal of soil outside of the landfill area except for sampling; and all activities that could result in a health risk.
Forest Township controls usage of the site outside of the landfilled area through a permit system. To date, permits have been issued for model airplane flying, archery, and paintball. In September 2005, U.S. EPA confirmed that it is safe to use the site areas outside of the landfill area for limited recreational activities, such as those permitted by Forest Township.
The primary water supply for nearby residences is groundwater. Installation of new wells near the site is being restricted using Genesee County Health Regulations.
ContactsRemedial Project Manager, U.S. EPA
allison nowotarski (firstname.lastname@example.org)
Community Involvement Coordinator, U.S. EPA
AliasesFOREST WASTE DISPOSAL LDFL