Safety-Kleen Systems, Inc., corrective action

Corrective Measures Implementation Report

Safety-Kleen is currently in the final phase of the corrective action process at the site to address historical contamination. Previous corrective action activities at the site implemented by Safety Kleen consisted of an initial RCRA Facility Investigation (RFI), interim corrective measures (ICM), and corrective measures studies (CMS). These previous steps of the corrective action process were submitted in a series of workplans and associated reports of results and findings.

A phased RFI was conducted by Safety-Kleen from 1990 through 2008 to identify the source and nature of any releases, and to characterize their magnitude and extent. EGLE determined that the RFI phase of the corrective action was complete, and that the nature and extent of contamination at the facility had been delineated on January 25, 2016.

During the RFI phase, Safety-Kleen implemented ICMs at the Mason site to reduce or eliminate potential threats to human health or the environment by removing potential sources of contamination and eliminating potential pathways that could contaminate groundwater. These ICMs included excavation and removal of contaminated soils, soil vapor extraction to remove VOCs from soil and groundwater, groundwater collection and treatment to contain and treat contaminated groundwater, in-situ treatment of groundwater by chemical oxidation, and groundwater monitoring.

Safety-Kleen submitted a proposed Corrective Measures Implementation (CMI), Report on December 23, 2023. EGLE reviewed the CMI Report and provided comments on June 5, 2024. On June 24, 2024, Safety-Kleen submitted a revised CMI Report of actions taken to address the contamination. The CMI Report provides data to support a determination that corrective measures have been completed at each Waste Management Unit, and documents that the implemented measures have been effective in reducing contaminant concentrations associated with historical releases to soil and groundwater at the facility to concentrations below applicable criteria. In addition, Safety-Kleen is completing corrective measures through implementation of an offsite Restrictive Covenant for groundwater use on a portion of the City of Mason property and an onsite Restrictive Covenant to address the Volatilization to Indoor Air Pathway. The Restrictive Covenants are Corrective Actions that have been implemented as required for EGLE approval of this CMI Report. The offsite Restrictive Covenant on the City of Mason dump property was recorded by Ingham County on October 16, 2023, and the onsite Restrictive Covenant was recorded with Ingham County on July 31, 2024.

The Safety-Kleen CMI Report consists of:

• CMI Report
• Appendices A-G

The CMI Report is also available for review at the following location:

• Lansing: EGLE, MMD, Deborah A. Stabenow Building, 525 West Allegan Street, Lansing, Michigan 48933 (contact Vickie Terry at TerryV2@Michigan.gov or 517-284-6546); by appointment.

Corrective Action

Environmental clean-up activity performed to address contamination resulting from hazardous waste treatment, storage and disposal facilities (TSDF) is referred to as "corrective action" in the hazardous waste regulations. Hazardous waste TSDFs are required to submit corrective action plans to EGLE for review and approval. The corrective action plans provide details on how the site owner(s) and/or operator(s) will investigate and clean-up the contamination to meet standards protective of human health and the environment. Though the corrective action cleanup process varies from site to site, it typically includes an initial site assessment, site characterization, evaluation of remedial alternatives, and implementation of the selected remedy.

Environmental Justice and Limited English Proficiency

EGLE conducts Environmental Justice (EJ), and Limited English Proficiency (LEP), screenings for communities surrounding a hazardous waste facility as part of the corrective action process. The EJ screen helps to identify EJ communities in the vicinity of a TSDF, and to choose the type and scope of site-specific community engagement activities. For EJ communities, the MMD considers the need for CMI Report approval conditions to mitigate EJ concerns and ensure that authorized activities will be protective of human health and the environment. The LEP screen helps EGLE identity the need for oral or written translations in identified language(s) for vital documents and public events.

EGLE did not identify any EJ or LEP communities within the facility’s vicinity.

• EJ and LEP Screen