u s EPA RECORDS CENTER REGION 5 

I • 

FINAL CLOSE OU T REPORT 418691 

Waste Management of Michigan - Holland Lagoons Site 

Ottawa County, Michigan 

I. INTRODUCTION 

This Final Close Out Report documents that all response actions have been completed for 

the Waste Management of Michigan - Holland Lagoons Site, Ottawa County, Michigan, in 

accordance with Close Out Procedures for National Priorities List Sites (OSWER Directive 

9320.2-22). 

II. SUMMARY OF SITE CONDITIONS 

Background 

The Waste Management of Michigan - Holland Lagoons Site ("Site") is located at 2700 

N. 168'*^ Avenue, between Riley and James Streets, near Holland, Michigan. The Holland 

Lagoons Site is an 80-acre property located about 0.5 miles from the eastern shore of Lake 

Michigan in Ottawa County. The Site consists of a former lagoon area and office/maintenance 

garage building. The area consists of mixed residential, recreational, and agricultural use and is 

adjacent to the Southwest Ottawa County Landfill (SWOCLF) Superfund Site. 

The Holland Lagoons Site was operated by Jacobusse's Refuse Service Company as a 

municipal garbage dump, liquid waste dewatering facility, and headquarters for its hauling 

company from the mid 1940's until 1977. The company was purchased by Refuse Services, Inc., 

in 1972 and the name was changed to Holland Lagoons. Refuse Services, Inc., merged into 

Michigan Waste Systems, Inc., in 1973 and Michigan Waste Systems, Inc., subsequently 

changed its name to Waste Management of Michigan, Inc. (WMMI). 

From about 1957 to 1964, Jacobusse hauled municipal trash to an area in the middle of 

the Site and burned it, burying only the burned remains in the ground. After 1964, Jacobusse 

hauled municipal trash to other area landfills instead. 

Liquid industrial waste was placed into waste disposal ponds (lagoons) from 1967 to 

1978. Liquid wastes deposited into the lagoons during that time include cider vinegar tank 

settlings, liquid/sludges from an organic pigment plant, metal hydroxides, wet milk and food 

processing bacterial digester sludges, and wastes from an area specialty chemicals company. 

The lagoons were abandoned in 1978 and the sludges were excavated, mixed with lime to 

stabilize them, and hauled to the SWOCLF for disposal. WMMI later excavated discolored soils 

from the haul road as it was suspected that these soils contained sludges that spilled from the 

trucks that hauled the wastes to the SWOCLF. 

The Ottawa County Health Department allowed the disposal of 43 dmms of technical 

grade chloral hydrate at the Site in 1968. The Michigan Department of Natural Resources 

(MDNR) located and successfully removed the still intact drums in August 1980 for off-site 
disposal. In addition, a nearby residential well at the Thomas household was found to be 

contaminated with up to 67 parts per billion of trichloroethylene. This household is now hooked 

up to a municipal water supply. 

Pursuant to Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), the United States Environmental Protection Agency inspected the Holland Lagoons 

Site in 1982. Subsequent to the submittal of the Site Inspection Report, the EPA proposed the 

Holland Lagoons Site to the National Priorities List (NPL) on October 15, 1984 (49 Federal 

Register (FR) 40320), and added it to the final list on June 10, 1986 (51 FR 21099). 

From 1993 through 1997, the EPA and Michigan Department of Environmental Quality 

(MDEQ) held discussions to allow NPL sites with a state-lead enforcement designation to follow 

the Remedial Action Plan process in Part 201 of the Michigan Natural Resources and 

Environmental Protection Act (NREPA), Mich. Comp. L. 324.20101 et seq., rather than the 

National Oil and Hazardous Substances Pollution Contingency Plan (NCP) Record of Decision 

(ROD) process. The EPA and MDEQ signed a Memorandum of Agreement (MOA) 

memorializing this approach in 1997. During this negotiation period, the Holland Lagoons Site 

was designated as a state-lead enforcement site. 

Interim Response Activities 

In 1980, Park Township began to hook up residences located within the vicinity of the 

Holland Lagoons Site, including the Thomas residence, to the expanded municipal water supply 

line. The Ottawa County and Park Township continued to hook up residences down-gradient of 

the Holland Lagoons and SWOCLF Sites into the expanded municipal water supply system. All 

hook ups and abandonments were completed in 2009. 

In addition to actions taken earlier, WMMI removed four underground storage tanks from 

within the truck maintenance area in 1985. Concurrent with the Remedial Investigation (RI), 

WMMI performed an Interim Response Action (IRA) at the Site by excavating discolored soils 

plausibly contaminated with heavy metals on the haul road and from other on-site areas and to 

remove general surface debris from the Site. WMMI also excavated the former municipal trash 

landfill area and disposed of the material off-site. The RI began in 1994. The interim response 

was completed by the end of 2000. All subsequent soil samples showed levels of metals at or 

below generic residential criteria or background values for the State of Michigan. Michigan Part 

201 Cleanup Criteria is within the EPA's acceptable risk range. 

Area A - Site Entrance: Soil boring samples were collected and analyzed for inorganic 

and organic parameters. The white powder found on the ground surface north of the Site 

building appeared to be lime based on the elevated calcium level; however, the calcium levels 

were below background concentrations. No organic contaminants were detected above 

background or Part 201 Residential Cleanup Criteria. A trench approximately 80 feet by 10 feet 

was discovered during the Phase I Investigation in an area south of the building. A soil boring 

was collected and analysis detected lead and zinc at concentrations above background. The 

impacted soil was excavated, approximately 40 cubic yards, during the IRA. Verification 

samples showed that the soil that remained was below the background concentrations for the 

analytes tested. 
In 2001, two soil samples were collected from the same location as the previous 

collection and consisted mostly of the white powder material. Analysis detected no inorganic 

contaminants at concentrations that exceeded Part 201 Residential Cleanup Criteria. 

Area B - Former Dewatering Lagoon Area: Analysis of the soil boring samples collected 

from the former dewatering lagoon area did not detect any organic or inorganic contaminants 

above background or Part 201 Residential Cleanup Criteria. The results of the soil borings and 

analysis from the Phase I and Phase II Investigations demonstrated that the lagoons were 

properly abandoned. 

Area C - Former Landfill Area: Analysis of the soil boring samples collected from the 

former landfill area did not detect any organic or inorganic contaminants above background or 

Part 201 Residential Cleanup Criteria. The ash, metal cans, and glass bottles in the former 

landfill area were excavated during the ERA for disposal off-site. Approximately 1,855 cubic 

yards of material were removed from the area. Results of the analysis of verification samples 

showed there were two small areas with levels of inorganic parameters exceeding the 

background concentration. An additional 40 cubic yards of soil were removed during the interim 

response and disposed of off-site. No contaminants were detected above background or Part 201 

Residential Cleanup Criteria in verification samples. 

A bermed drum area was located in the south end of the former landfill. The berm was 

70 by 30 feet and contained six old, rusted drums. These drums were removed during the ERA 

along with 224 cubic feet of bluish-green stained soil found at the bottom of the bermed area. 

No contaminants were detected above background or Part 201 Residential Cleanup Criteria in 

verification samples. 

Area D - Haul Road: The results of the soil boring sampling from the haul road indicated 

that the bluish-green soil found at the ground surface along parts of the road was contaminated 

with heavy metals. Analysis of the soil sample detected chromium, copper, lead, nickel, 

selenium, zinc, and cyanide above their background values. Impacted soil, which was identified 

in the previous phased investigations, was removed during the IRA. An area 400 feet by 70 feet 

by 1.5 feet deep was excavated, removing approximately 1,433 cubic yards of soil. Verification 

samples indicated the soil that remained was not impacted above background concentrations for 

heavy metals. An additional 30 cubic yards of soil were removed from the adjacent Ottawa 

County property. 

During the Phase V Investigation, an additional 540 cubic yards of soil were excavated 

from the haul road area and disposed of off-site. The verification samples collected 

demonstrated that the remaining soil met the Part 201 Residential Cleanup Criteria. 

Area E - Former Daim Burial Area: Analysis of the soil boring samples collected from 

the former dmm burial area did not detect any organic or inorganic contaminants above 

background or Part 201 Residential Cleanup Criteria. 

Area F - Eastern Half of Site: The investigation of this area of concern involved 

collecting two soil samples from four boring locations. An additional four borings were 

collected from along the eastern edge of the area for background analysis. The results of the 

Phase I background borings and the Phase II borings indicated no contaminants were detected 
above the Part 201 Residential Cleanup Criteria. No environmental hazard was found in the 

eastern half of the Site. 

Underground Storage Tanks (USTs): A review of the 1985 UST report did not indicate 

that the four USTs had been removed. 

During the Phase I Investigation, a soil boring sample was collected from the area of the 

former UST #1 at the northeast comer of the building. A second soil boring sample was 

collected from the UST #4 location. The results of these soil boring samples did not detect any 

petroleum hydrocarbon or organic contaminants above Part 201 Residential Cleanup Criteria. 

During Phase II, an additional investigation was conducted to determine if USTs #3 and 

#4 located near the southwest comer of the building had been removed. The investigation 

involved searching the area with an electro-magnetic (EM) detector to determine if there were 

any buried large metal objects in the area. The results of the EM investigation detected no buried 

metal objects. Therefore, it was concluded that all four of the USTs had been removed and that 

no environmental impacts were associated with the former USTs. 

Remedial Investigation/Feasibility Study Results (RI/FS) 

In 1994, the MDNR and WMMI entered into an Administrative Order by Consent for 

Response Activities for WMMI to undertake a RI/FS at the Site. WMMI performed a RI and 

baseline risk assessment, including an ecological assessment at the Site from 1994-1996 and 

additional sampling was conducted between 1998 and 2007. The MDEQ approved the Holland 

Lagoons Site Final Feasibility Study and Remedial Action Plan Closure Report on October 13, 

2008. 

Groundwater: Groundwater was sampled as part of the Phase I, II, III, IV and V 

Investigations. The results of the groundwater samples collected up-gradient of the Site were 

used to develop inorganic parameters background and anthropogenic background concentrations 

for the area. Background concentrations are concentrations of chemicals common to 

groundwater that have not been impacted by anthropogenic effects. Anthropogenic background 

levels are determined by analyzing groundwater that has been impacted by an up-gradient source 

such as the SWOCLF Site. Anthropogenic background concentrations were determined from 

several wells located down-gradient of the SWOCLF Site but up-gradient of any known disposal 

areas on the Holland Lagoons Site. 

Benzene was the only organic contaminant detected in the on-site monitoring wells above 

the Maximum Contaminant Levels (MCL) established under the Safe Drinking Water Act 

(SDWA) and Part 201 Residential Cleanup Criteria. Benzene detections exceeded the MCL of 5 

micrograms per liter (|ag/l) and Part 201 Residential Cleanup Criteria of 5 |ig/l. All of these 

detections were found in wells located southwest of the Site at concentrations ranging from 14 

fjg/l to 28 |ig/l and no on-site source was detected. Benzene is a contaminant being monitored at 

the SWOCLF Site. At the SWOCLF Site, benzene had been detected at levels as high as 149 

|ag/l in purge wells and 305 fig/1 in monitoring wells; therefore, the MDEQ concluded that the 

source of the benzene is the SWOCLF Site. 
Inorganic contaminants found in wells on-site include: aluminum, arsenic, antimony, 

beryllium, cadmium, lead, manganese, zinc, and vanadium. Aluminum, antimony, lead, 

manganese, and zinc were found in background or anthropogenic background wells. Arsenic did 

not exceed the MCL or Part 201 Residential Cleanup Criteria. Subsequent sampling results 

indicated that aluminum, antimony, beryllium, cadmium, lead, manganese, zinc, and vanadium 

did not exceed MCLs, Part 201 Residential Cleanup Criteria, background, and/or anthropogenic 

background. 

In March 2005, the MDEQ and Ottawa County entered into a Stipulation for the 

SWOCLF Site, under which Ottawa County is required to perform the following remedial 

actions at the SWOCLF Site: constmct a new landfill cap; install and operate a new extraction 

well system around the landfill; prevent the discharge to Lake Michigan of groundwater 

containing hazardous substances exceeding Groundwater to Surface Water Interface Criteria; 

implement reliable land and resource use restrictions (institutional controls) to restrict 

constmction and use of wells within the groundwater plume; properly abandon all existing 

residential wells once residents have been hooked into the municipal water supply; and operate 

the then current down-gradient extraction system until it was demonstrated that requirements 

have been achieved. The responsibility for the remaining wells on the Holland Lagoons Site has 

been transferred to Ottawa County to use in monitoring the SWOCLF plume. The Stipulation 

also requires that an area-wide land and resource use restriction be implemented, which includes 

the Holland Lagoons Site. 

Currently, Ottawa County has constructed the new landfill cap and completed the hook 

up of residents to the municipal water supply. In 2009, Ottawa County implemented an areawide groundwater use restriction which prohibits human consumption of groundwater, limits 

well installation/use, and outlines procedures for well abandonments. All hook ups and 

abandonments were completed in 2009. Ottawa County continues to operate the down-gradient 

extraction system. In 2009, Ottawa County installed and began operation of a new extraction 

well system along the west and south boundary of the SWOCLF Site. 

Former Facility Office and Maintenance Garage Building: In 2007, WMMI conducted 

soil and groundwater sampling below the former facility office and maintenance garage building 

as noted as a recommendation in the 2006 Five-Year Review Report. The soil and groundwater 

sampling results did not reveal any chemicals of concerns above the MCLs or Part 201 criterion. 

ROD Findings 

WMMI produced a Feasibility Study and Remedial Action Plan Closure Report for the 

Site in January 1998 which MDEQ did not approve. A Declaration of Restrictive Covenant was 

filed with Ottawa County on August 18, 1997. A Final Feasibility Study and Remedial Action 

Plan Closure Report, which called for No Further Action to be implemented at the Site was 

approved by MDEQ on October 13, 2008. On May 19, 2011, the MDEQ approved WMMI's 

request to rescind the 1997 restrictive covenant because Ottawa County has implemented an 

area-wide groundwater restriction as part of the SWOCLF cleanup program. The Notice of 

Recision of Land and/or Resources Use Restrictions was filed and recorded by the Ottawa 

County Register of Deeds on June 2, 2011. The Ottawa County Contaminated Groundwater Use 

Ordinance (March 2009) meets the requirements of a "reliable use restriction" under state 

cleanup mles (Part 201). 
The EPA signed the ROD on August 17, 2011. The EPA has determined that no further 

remedial action is necessary for the Holland Lagoons Site. Previous responses at the Site 

eliminated the need for a further remedial action. Contaminated soil from on-site disposal pits 

was excavated and disposed of off-site. The excavated areas were filled with clean soil meeting 

residential cleanup levels. The Site operations did not contaminate the groundwater. The 

groundwater on-site is contaminated by an up-gradient plume migrating from the SWOCLF Site, 

which impacts the groundwater down-gradient of the SWOCLF Site, including the Holland 

Lagoons Site. Ottawa County is conducting a cleanup of the SWOCLF and has implemented an 

area-wide groundwater use restriction to prevent groundwater use. 

Final Inspection Activities 

The EPA remedial project manager (RPM) and Michigan project manager conducted a 

pre-final inspection on May 31, 2001 and EPA developed a punch list of minor tasks to be 

completed by WMMI. WMMI completed the punch list on July 31, 2001. 

i n . MONITORING RESULTS 

The No Further Action Final Feasibility Study and Remedial Action Plan Closure Report 

and ROD do not require any monitoring. As discussed previously, actions taken by the WMMI, 

including underground storage tank, municipal waste removal and soil excavation have 

addressed soil contamination. This is evidenced by the fact that all subsequent soil samples 

taken on Site showed levels of metal at or below residential criteria or background values for the 

State of Michigan. The groundwater underneath the Site is monitored as part of the SWOCLF 

groundwater monitoring program and contamination in the groundwater plumes is not related to 

contamination and sources at Holland Lagoons Site. 

IV. ATTAINMENT OF GROUNDWATER RESTORATION CLEANUP LEVELS. 

As stated above, the groundwater underneath the Site is monitored as part of the 

SWOCLF groundwater monitoring program and contamination in the groundwater plumes is not 

related to contamination and sources, at Holland Lagoons Site. 

V. SUMMARY OF OPERATION AND MAINTENANCE 

There will be no active remediation at the Site; therefore, no operation and maintenance 

(O&M) is necessary. Ottawa County will monitor the area-wide groundwater use ordinance. 

VI. DEMONSTRATION OF QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) 

The MDEQ, in consultation with the EPA, conducted oversight of the potentially 

responsible party RI and preliminary response activities at the Site. All field activities were 

reviewed and approved by the MDEQ to ensure consistency with the RI work plan and federal 

and state requirements. Details of the analytical procedures used to ensure the quality of the 

work are contained in the approved Quality Assurance Project Plan (QAPP) for the RI studies. 

The Quality Assurance/Quality Control (QA/QC) program has been sufficient to allow the 
MDEQ and EPA to determine that all analytical results were accurate to the degree needed to 

assure satisfactory completion of the RI and interim response actions. 

VII. FIVE-YEAR REVIEW 

The EPA conducted a Five-Year Review (FYR) at the Site, which it completed on 

September 26, 2006, pursuant to CERCLA Section 121(c) and as provided in the current 

guidance on Five-Year Reviews: OSWER Directive 9355.7-03B-P, Comprehensive Five-Year 

Review Guidance, June 2001. EPA has determined that no further remedial action is necessary 

for the Holland Lagoons Site. Previous responses at the Site eliminated the need for a further 

remedial action. Contaminated soil from on-site disposal pits was excavated and disposed of offsite. No further five-year reviews are required because the remedy allows for unlimited use and 

unrestricted exposure use. 

The first FYR identified five issues that needed to be addressed and all of the issues have 

now been addressed as described below: 

1. WMMI was not in compliance with the Administrative Order of Consent (AOC) 

requiring the completion of a Part 201 approved Remedial Action Plan (RAP). WMMI 

had not completed a MDEQ approved RAP which meets all the requirements of Part 201, 

Environmental Remediation, of the Natural Resources and Environmental Protection Act, 

1994 PA 451, as amended (Part 201). 

The MDEQ approved the Final Feasibility Study and Remedial Action Plan 

Closure Report on October 13, 2008, which was submitted by WMMI. 

2. WMMI must provide information to prove the six on-site source areas, due to the 

completion of past remediation activities, are no longer contributing contaminants to the 

groundwater plume migrating under the Site and that all of the contaminants found in the 

groundwater plume originate from the adjacent and up-gradient SWOCLF National 

Priorities List Site. 

The Final Feasibility Study and Remedial Action Plan Closure Report included 

data to confirm that the past remediation activities were completed at the six onsite areas and that no on-site sources were contributing to the groundwater plume 

migrating from the SWOCLF Site. 

3. Assure effective interim institutional controls (ICs) are in place pending the final RAP. 

The No Further Action ROD does not require any ICs. The 1997 restrictive 

covenant is not necessary and has been rescinded. The Declaration of Restrictive 

Covenant was filed with Ottawa County on August 18, 1997, prior to the 

determination that the plume was emanating from the SWOCLF Site. The Notice 

of Recision of Land and/or Resources Use Restrictions was filed and recorded by 

the Ottawa County Register of Deeds on June 2, 2011. However, Ottawa County 

is conducting a cleanup of the SWOCLF and has implemented an area-wide 

groundwater use restriction to prevent groundwater use. 
4. For the remedy to be protective in the long-term, effective ICs may be implemented and 

maintained as part of the final RAP. 

The No Further Action ROD does not require any ICs. The remedy is protective 

and allows for unlimited use and unrestricted exposure use. 

5. A contamination source area may exist beneath the former office building. 

In 2007, WMMI conducted soil and groundwater sampling below the former 

facility office and maintenance garage building. The soil and groundwater 

sampling results did not reveal any chemicals of concerns above the MCLs or 

Part 201 criterion. 

VIII. SITE COMPLETION CRITERIA 

The Site meets all the site completion requirements as specified in Close Out Procedures 

for National Priorities List Sites (OSWER Directive 9320.2-22). All of the known 

contamination originating from the Site was removed during the interim response actions, all 

area residences have access to the municipal water supply, the Site is subject to an area-wide 

groundwater use restriction, and all private wells within the restricted area have been identified 

and properly abandoned. The remedy is protective and allows for unlimited use and unrestricted 

exposure use. Therefore, the Site no longer poses any threats to human health and the 

environment. The No Further Action ROD does not require any monitoring or O&M. The 

groundwater is monitored as part of the SWOCLF groundwater monitoring program. A 

bibliography of all reports relevant to the completion of this Site under the Superfund program is 

found in Section IX. 

IX. BIBLIOGRAPHY 

Ottawa County Environmental Health Code, January 28, 1983 

MDNR 1979 Groundwater Report 

MDNR 1981 Soil Boring Report 

MDNR Sampling Report 1984 

MDNR Sampling Report 1985 

MDNR Sampling Report 1988 

Report on the Tank Removal Operations at the Former Jacobusse Site, October 1985 

Electromagnetic Survey Investigation, October 1993 

Phase I Remedial Investigation Report, December 1995 

Phase III Groundwater Sampling Report, May 6, 1996 

Remedial Investigation Report and Base Line Risk Assessment Report, January 1997 

8 
Declaration of Restrictive Covenant, August 1997 

Phase IV Ground Water Sampling Results, May 7, 1998 

Phase V Ground Water and Soil Analytical Data, January 27, 2000 

Preliminary Close-Out Report, September 26, 2001 

Final Feasibility Study and Remedial Action Plan Closure Report Feasibility Study, Febmary 

2008 

MDEQ Final Feasibility Study and Remedial Action Plan Closure Report Approval Letter, 

October 13, 2008 

Contaminated Groundwater Use Ordinance 09-1 of Ottawa County, March 1, 2009 

Notice of Recision of Land and/or Resources Use Restrictions was filed and recorded by the 

Ottawa County Register of Deeds, June 2, 2011. 

Record of Decision, August 17, 2011 

I2.jiji ^ )/j^ Ih2f'f l 

Richard C. Karl, Director Date 

Superfund Division