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Record of Decision System (RODS)

ANDERSON DEVELOPMENT CO.

Abstract

Site Name:  ANDERSON DEVELOPMENT CO.
Address:  1415 EAST MICHIGAN STREET 
City & State:  ADRIAN  MI  49221
County:  LENAWEE
 
EPA ID:  MID002931228
EPA Region:  05
 
NPL Status:  Deleted from the Final NPL
 
ROD Type:  Record of Decision
ROD ID:  EPA/ROD/R05-90/137
ROD Date:  09/28/1990
Operable Unit(s):  01
 
Media:  SOIL LAGOON SLUDGE
 
Contaminant:  ORGANICS, MBOCA, DEGRADATION PRODUCTS
 
Abstract:  THE 12.5-ACRE ANDERSON DEVELOPMENT SITE IS AN ACTIVE CHEMICAL MANUFACTURING FACILITY IN ADRIAN, MADISON TOWNSHIP, LENAWEE COUNTY, MICHIGAN. THE SITE IS IN A 40-ACRE INDUSTRIAL PARK, AND IS COMPRISED OF SEVERAL AREAS OF CONTAMINATION THAT EXCEED HEALTH-BASED LEVELS, INCLUDING A 0.5-ACRE FORMER PROCESS WASTEWATER PRETREATMENT LAGOON CONTAINING LAGOON SLUDGE, CLAY UNDERLYING THE LAGOON, AND A SMALL QUANTITY OF SOIL NEAR THE LAGOON. FROM 1970 TO 1979, THE PLANT PRODUCED 4,4-METHYLENE BIS(2-CHLOROANILINE) (MBOCA), A HARDENING AGENT FOR THE PRODUCTION OF POLYURETHANE PLASTICS. PROCESS WASTEWATER WAS DISCHARGED DIRECTLY TO SURFACE WATER UNTIL 1973, WHEN IT WAS DISCHARGED TO A PUBLICLY OWNED TREATMENT WORKS (POTW). IN 1979, THE STATE ORDERED THE POTW NOT TO ACCEPT THE WASTE STREAM BECAUSE OF THE DECREASED EFFICIENCY OF THE POTW RESULTING FROM MBOCA. IN 1980 AND 1981, THE SITE OWNER AND THE STATE PERFORMED A CLEANUP ACTION OF ALL CONTAMINATED SITE AREAS WITH LEVELS OF MBOCA ABOVE 1 PPM. THIS INCLUDED DECONTAMINATING THE PLANT, SWEEPING STREETS, SHAMPOOING/VACUUMING RESIDENTIAL CARPET, AND REMOVING SOME SURFACE SOIL. THIS RECORD OF DECISION (ROD) ADDRESSES THE REMEDIATION OF PRETREATMENT LAGOON AREA. THE PRIMARY CONTAMINANTS OF CONCERN AFFECTING SOIL AND LAGOON SLUDGE ARE ORGANICS, NAMELY MBOCA AND ITS DEGRADATION PRODUCTS.

THE SELECTED REMEDIAL ACTION FOR THIS SITE INCLUDES REMOVING AND TREATING STANDING WATER IN THE LAGOON; EXCAVATING CONTAMINATED SOIL, CLAY, AND LAGOON SLUDGE FROM A 100-FOOT BY 75-FOOT AREA AND PLACING THE MATERIAL IN AN UNEXCAVATED PORTION OF THE LAGOON; TREATING THE CONTAMINATED MATERIAL BY IN-SITU VITRIFICATION; COLLECTING PYROLIZED GASES, AND TREATING THE GASES USING A SCRUBBER SYSTEM, AIR FILTERS, AND CARBON ADSORPTION BEDS; FILLING THE LAGOON CONTAINING THE VITRIFIED MATERIAL WITH CLEAN FILL; AND CONDUCTING GROUND WATER MONITORING AND SOIL SAMPLING. THE ESTIMATED PRESENT WORTH COST FOR THIS REMEDIAL ACTION IS $2,364,050, WHICH INCLUDES A TOTAL O&M COST OF $38,530 OVER 30 YEARS.

PERFORMANCE STANDARDS OR GOALS: A CLEANUP ACTION LEVEL OF MBOCA 1,684 UG/KG WAS CALCULATED BASED UPON EPA GUIDANCE DOCUMENTATION. THE CLEANUP LEVEL CORRESPONDS WITH THE EXCESS LIFETIME CANCER RISK LEVEL OF (10-6).
 
Remedy:  THE SELECTED REMEDIAL ACTION FOR THE ANDERSON DEVELOPMENT COMPANY SITE ADDRESS THE PRINCIPAL THREAT THROUGH REMEDIATION OF CONTAMINATED PRETREATMENT LAGOON SLUDGE, SURFACE SOILS AROUND THE LAGOON FOUND TO HAVE LEVELS OF CONTAMINATION ABOVE HEALTH BASED LEVELS, AND SOME OF THE NATURALLY OCCURRING CLAY WHICH UNDERLIES THE LAGOON FOUND TO HAVE CONCENTRATIONS OF CONTAMINANTS ABOVE THE CLEAN-UP ACTION LEVEL.

THE MAJOR COMPONENTS OF THE SELECTED REMEDIAL ACTION INCLUDE;

* REMOVAL AND PROPER TREATMENT OF THE STANDING WATER REMAINING IN THE LAGOON;
* EXCAVATION OF CONTAMINATED SOILS WITH CONTAMINANT CONCENTRATIONS ABOVE THE CLEAN-UP ACTION LEVEL, AND CONSOLIDATION OF THESE SOILS INTO THE LAGOON;
* EXCAVATION, FROM A 100 FT BY 75 FT AREA, OF LAGOON SLUDGE AND UNDERLYING CLAY, TO A DEPTH SUFFICIENT TO MET THE CLEAN-UP ACTION LEVEL, AND STAGING ONTO THE REMAINING PORTION OF THE LAGOON;
* IN SITU VITRIFICATION (IVS) OF THE RESULTANT STAGED MASS OF SOIL, SLUDGE AND CLAY TO A DEPTH SUFFICIENT TO MET THE CLEAN-UP ACTION LEVEL;
* AIR MONITORING AND CONFORMATIONAL SOILS SAMPLING DURING THE REMEDIAL ACTION; AND
* GROUNDWATER MONITORING, ADDITIONAL CONFORMATIONAL SOILS SAMPLING AND VERIFICATION BORINGS FOLLOWING THE REMEDIAL ACTION FOR A PERIOD OF 5 YEARS TO ASSESS AND CONFIRM THE EFFICACY OF ISV.
 
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