Behr Dayton Thermal Products VOC Plume Site

 
Site Contact:
Steven Renninger
On-Scene Coordinator

(renninger.steven@epa.gov)

Site Location:
1600 Webster Street
Dayton, OH 45404
response.epa.gov/behrdaytonthermalproductssite

The Behr Dayton Thermal Products VOC Plume Site (OU4) is located in Dayton, Ohio at the intersection of Daniel and Lamar Street. At the request of the Ohio EPA, U.S. EPA Region V has initiated a vapor intrusion investigation at the site.

In March 2006, elevated levels of TCE were documented in the groundwater off-site as high as 3,900 ppb. In October 2006, the Ohio EPA documented elevated levels of TCE in soil gas as high as 160,000 ppb. See Documents section for TCE and Vapor Intrusion Fact Sheets.

Vapor Intrusion is the migration of volatile organic compounds from contaminated shallow groundwater to soil gas to indoor air. ATSDR and the Ohio Department of Health (ODH) have established TCE screening and action levels for residential and commercial sub-slab and indoor air. The ATSDR residential indoor air screening level is 0.4 parts per billion (ppb) and the action level is 100 ppb. The ATSDR residential sub-slab screening level is 4 ppb.

In November 2006, the U.S. EPA collected sub-slab air samples from eight residences located south of the Behr Dayton Thermal Products facility along Milburn Avenue, Daniel Street and Leo Street. TCE residential sub-slab concentrations were detected as high as 62,000 ppb. The results of the EPA sub-slab testing indicated that eight samples exceed the ATSDR residential TCE sub-slab screening level of 4 parts per billion by volume (ppbv).

Based on ATSDR and ODH recommendations, the U.S. EPA followed sub-slab air sampling with indoor air sampling at eight locations in November 2006. TCE residential indoor air concentrations were detected at a range of 0.4-260 ppb. The results of the EPA indoor air sampling indicated that eight samples exceed the ATSDR residential TCE indoor air screening level of 0.4 ppbv and three samples exceed the ATSDR residential TCE indoor air immediate action level of 100 ppbv.

On December 19, 2006, an Administrative Order by Consent was signed between EPA and DaimlerChrysler (former owner of the Behr facility) to conduct a vapor intrusion investigation and mitigation. As of July, 2009, Chrysler completed the following removal activities:

-sampled a total of 118 residential/commercial properties for vapor intrusion
-installed a total of 56 vapor abatement mitigation systems for vapor intrusion
-installed a one square block residential SVE system along Daniel Street
-sampled, operated and maintained the residential SVE system

Additionally in 2008, EPA completed the following removal activities:

-sampled a total of 277 residential properties for vapor intrusion
-installed a total of 149 vapor abatement mitigation systems for vapor intrusion

On July 17, 2009, EPA issued a Unilateral Administrative Order (UAO) to Behr Dayton Thermal Products to complete the following removal activities:

-operate and maintain the residential SVE system along Daniel Street
-conduct annual performance monitoring at all vapor abatement mitigation systems that were installed by EPA or Chrysler to date for vapor intrusion
-upgrade any residential vapor abatement mitigation system, if necessary
-sample additional locations for vapor intrusion, if identified by EPA
-conduct vapor intrusion sampling at the completed Salvation Army facility.

On August 13, 2009, EPA began weekly meetings with Behr Dayton to discuss project updates. In addition, EPA began weekly meetings with representatives from Behr VOC Area Leaders (BVOCAL) to update the local community group on the project status.

During the week of August 17, 2009, U.S. EPA distributed over 700 fact sheets in the McCook Field Neighborhood announcing the September 1st EPA public meeting. The fact sheets explained the importance of the meeting and the need to have property owners and tenants (if applicable) sign new access agreements to give U.S. EPA and Behr Dayton personnel permission to enter the property for inspection and/or sampling activities. A copy of the U.S. EPA mailer is included in the Documents Section of the Site Website.

On August 24, 2009, Behr Dayton submitted a DRAFT Phase III work plan.

On August 27, 2009, a project command post was establisted at 919 North Keowee. In addition, Behr Dayton submitted a revised DRAFT Phase III work plan.

On September 1, 2009, U.S. EPA conducted a public meeting at Kiser Elementary School. Approximately 100 people attended the meeting. EPA RPM Stacey Coburn updated the status of the site remedial investigation and EPA OSC Steve Renninger updated the status of the on-going removal action with Behr Dayton.

On September 3, 2009, U.S. EPA issued a letter to Behr Dayton formally approving the final version of the Phase III work plan. A complete copy of the Phase III work plan can be found in the documents section of the Site Website.

The EPA-approved work plan requires Behr Dayton to conduct the following work:

1) If access is granted, inspect properties where a vapor abatement system was installed either by EPA or by Chrysler. Inspection activities include the following, but not limited to:
• System vacuum/pressure readings (header and sub-slab probe)
• Confirm operation of the blower fan
• Confirm padlock is attached to the on/off switch
• Visual inspection of system piping and components
• Inspection of floor and wall seals
• Confirm operation with residents
• Confirm a copy of the Operation and Maintenance manual is in the residence and updated as necessary

2) If access is granted, Behr Dayton will collect a sub-slab sample in properties that have been sampled once by EPA or Chrysler and initially determined not to require a vapor abatement system. If the sub-slab sample shows a TCE concentration greater than the screening level provided by the ODH, a vapor abatement system will be offered to be installed to the property owner. If a vapor abatement system is installed, proficiency indoor air samples will be collected 30 days, 180 days and 365 days following installation of the system. In addition, the property will be placed into the annual vapor abatement sytem inspection program. If the sub-slab sample shows a TCE concentration less than the ODH sub-slab screening level, the property is eligible to be re-sampled one more time in 2011. If the 2011 sub-slab sample shows a TCE concentration less than the ODH sub-slab screening level, the property will not be sampled again and will receive a NO FURTHER ACTION letter.

3) If access is granted, Behr Dayton will collect a sub-slab sample in properties that have never been sampled by EPA or Chrysler. If the sub-slab sample shows a TCE concentration greater than the screening level provided by the ODH, a vapor abatement system will be offered to be installed to the property owner. If a vapor abatement system is installed, proficiency indoor air samples will be collected 30 days, 180 days and 365 days following installation of the system. In addition, the property will be placed into the annual vapor abatement sytem inspection program. If the sub-slab sample shows a TCE concentration less than the ODH sub-slab screening level, the property is eligible to be re-sampled two more times in 2011 and 2013. If the 2011 and 2013 sub-slab samples both show a TCE concentration less than the ODH screening level, the property will not be sampled again and will receive a NO FURTHER ACTION letter.

4) If access is granted, Behr Dayton will collect indoor air samples from the newly constructed buildings within the Salvation Army complex.

5) Perform weekly inspections and periodic effluent air sampling of the neighborhood SVE system.

IMPORTANT NOTE:
EPA will be responsible for obtaining access agreements to allow Behr Dayton access to complete its work. Once an access agreement is signed by the property owner (and tenants), EPA will provide a copy of the access agreement to Behr Dayton for scheduling. It is important that everyone who wishes to participate in this investigation sign a NEW access agreement.

On September 8, 2009, EPA mailed out approximately 200 letters and access agreements to properties that have an installed vapor abatement system requesting access for inspection.

On September 15, 2009, EPA mailed out letters and access agreements to 242 properties that are eligible for 'retesting' and 'new testing'.

On October 15, 2009, EPA provided BVOCAL with a list of 285 properties that have yet to return a signed access agreement to allow vapor abatement system annual inspections, re-sampling or new sampling. BVOCAL will attempt to go door-to-door or make phone calls to attempt to obtain more signed access agreements.

March 4, 2010 UPDATE:

Since September, 2009, Behr Dayton has completed the following:

1) 104 properties that have an installed vapor abatement system (2007 or 2008 installation date) have been inspected. In 2007 and 2008, EPA and Chrysler installed vapor abatement systems in a total of 205 properties.

2) 17 properties have been 're-sampled'. EPA has obtained signed access agreements from 53 of the 118 properties eligible to be 're-sampled'.

3) 29 properties that have "never" been sampled have been sampled (baseline sampling) by Behr Dayton. EPA has obtained signed access agreements from 43 of the 129 properties eligible to be sampled.

4) Behr Dayton has installed a total of 15 new vapor abatement systems at the Behr Site. A project total of 220 vapor abatement mitigation systems have been installed to date at residential and commercial structures.

5) Behr Dayton has completed weekly inspections of the neighborhood SVE system and has collected effluent air samples which have not shown TCE levels exceeding the site action levels.

December 21, 2010 Update: A total of 241 vapor abatement mitigation systems have been installed to date (including EPA, Chrysler, and Behr).

September 6, 2012 Update:
During Jan/Feb 2012, the PRPs completed the following:
+ 88 SSDS inspections
+ Of the 88 inspections, 7 properties required its SSDSs to be upgraded. Upgraded SSDSs could be recaulking extraction well, fixing piping issues, replacing fan, etc.
+ 31 properties (not with a SSDS) were resampled as part of Bi-Annual Resampling
+ 1 new property was sampled
+ 1 new SSDS was installed
+ Proficiency sampling continued at properties with new SSDSs

During the Summer/Fall 2012 time period, the following is scheduled:
+ 94 properties with SSDSs will be inspected
+ SSDS upgrades will be conducted on an as-needed basis
+ 4 properties will be identified by the PRPs to have indoor air sampling conducted as part of the Performance Sampling phase of the work plan
+ 54 properties (not with a SSDS) will be resampled as part of Bi-Annual Resampling
+ Properties will have SSDSs installed on an as-needed basis
+ SSDS proficiency sampling will be conducted, as stated in the work plan.

The following web site summarizes site activities since 2012:

http://www.epa.gov/region05/cleanup/behr/


For additional information, visit the Pollution Report (POLREPS) section.