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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:  Amendment
ROD ID:  EPA/AMD/R05-91/177
ROD Date:  09/30/1991
Operable Unit(s):  01
 
Media:  SOIL SLUDGE
 
Contaminant:  VOCS, TOLUENE, MBOCA, METALS
 
Abstract:  THE ANDERSON DEVELOPMENT SITE IS AN ACTIVE CHEMICAL MANUFACTURING FACILITY IN ADRIAN, LENAWEE COUNTY, MICHIGAN. THE SITE OCCUPIES APPROXIMATELY 12.5 ACRES WITHIN A 40-ACRE INDUSTRIAL PARK, WHICH IS SURROUNDED BY RESIDENTIAL AREAS. SITE FEATURES INCLUDE SEVERAL ONSITE BUILDINGS USED FOR MANUFACTURING, STORAGE, LABORATORIES, AND OFFICES, AS WELL AS A 0.5-ACRE FORMER PROCESS WASTEWATER PRETREATMENT LAGOON CONTAINING LAGOON SLUDGE AND AN UNDERLYING CLAY LAYER. FROM 1970 TO 1979, THE ANDERSON DEVELOPMENT CORPORATION (ADC) PRODUCED SPECIALTY CHEMICALS ONSITE INCLUDING 4,4-METHYLENE BIS (2-CHLORORANILINE) (MBOCA), A HARDENING AGENT FOR THE PRODUCTION OF POLYURETHANE PLASTICS. UNTREATED PROCESS WASTEWATER WAS DISCHARGED DIRECTLY TO SURFACE WATER UNTIL 1973, WHEN THE STATE DISCOVERED ANILINE IN A SIDE DRAIN FROM THE FACILITY. LATER IN 1973, ADC BEGAN SEPARATING PROCESS WASTEWATER FROM ITS COOLING WATER, WITH SUBSEQUENT DISCHARGE OF WASTEWATER TO A PUBLICLY OWNED TREATMENT WORKS (POTW). AT THE POTW, MBOCA WAS SETTLED OUT WITH OTHER SOLIDS AND APPLIED TO THE LAND, WHICH HAS LED TO CONTAMINATION AT THE POTW DRYING BEDS. IN 1979, THE STATE ORDERED THE POTW NOT TO ACCEPT THE WASTE STREAM BECAUSE OF THE DECREASED EFFICIENCY OF THE POTW RESULTING FROM MBOCA CONTAMINATION. IN 1979, AFTER MBOCA WAS FOUND IN ONSITE SEDIMENT, PRODUCTION OF THE CHEMICAL CEASED. IN 1980 AND 1981, THE SITE OWNER AND THE STATE CLEANED UP ALL CONTAMINATED SITE AREAS, EXCEPT FOR THE ONSITE LAGOON AND THE ADJACENT SOIL, WITH MBOCA LEVELS GREATER THAN 1 MG/KG BY DECONTAMINATING THE PLANT, SWEEPING STREETS, SHAMPOOING/VACUUMING RESIDENTIAL CARPET, AND REMOVING SOME CONTAMINATED SURFACE SOIL OFFSITE. A 1990 ROD ADDRESSED SITE CONTAMINATION OF SURFACE SOIL, LAGOON SLUDGE, AND UNDERLYING LAGOON CLAY. THIS ROD AMENDS THE 1990 ROD, WHICH PROVIDED FOR TREATMENT OF THE CONTAMINATED MEDIA USING IN-SITU VITRIFICATION, AND DOCUMENTS THE SELECTION OF LOW TEMPERATURE THERMAL DESORPTION (LTTD) AS THE PREFERRED TREATMENT TECHNOLOGY, BASED ON COST AND OTHER CONCERNS. THE PRIMARY CONTAMINANTS OF CONCERN AFFECTING THE SOIL AND LAGOON SLUDGE ARE VOCS INCLUDING TOLUENE AND MBOCA AND ITS DEGRADATION PRODUCTS; AND METALS.

THE SELECTED AMENDED REMEDIAL ACTION FOR THIS SITE INCLUDES EXCAVATING AND STAGING 3,000 TO 4,000 TONS OF CONTAMINATED SOIL, CLAY, AND LAGOON SLUDGE WITH MBOCA CONCENTRATIONS ABOVE THE 1.6 MG/KG CLEAN-UP ACTION LEVEL IN AN LTTD DEVICE; PERFORMING TREATABILITY STUDIES TO EVALUATE EFFECTIVENESS OF THE LTTD TECHNOLOGY, THEN, IF EFFECTIVE, TREATING THE CONTAMINATED SOIL, CLAY, AND SLUDGE ONSITE USING LTTD; PLACING THE TREATED SOIL, SLUDGE, AND CLAY INTO THE EXCAVATED LAGOON, COVERING THE LAGOON WITH CLEAN SOIL, AND REGRADING THE AREA; OR IF THE RESULTS OF THE TREATABILITY STUDY INDICATE THAT LTTD IS UNACCEPTABLE, USING IN-SITU VITRIFICATION AS THE ALTERNATE REMEDIATION TECHNOLOGY; COLLECTING OFF-GASES AND TREATING THE GASES USING AN AIR POLLUTION CONTROL TRAIN, WHICH INCLUDES A SCRUBBER SYSTEM, AIR FILTERS, AND CARBON ADSORPTION BEDS; TREATING AQUEOUS STREAMS FROM THE AIR POLLUTION CONTROL TRAIN USING LIQUID PHASE ACTIVATED CARBON BEDS; THERMALLY REGENERATING OR DISPOSING OF SPENT CARBON AND FINES FROM THE PARTICULATE REMOVAL EQUIPMENT OFFSITE; AND MONITORING GROUND WATER AND AIR. THE ESTIMATED COST OF THE LTTD TREATMENT OPTIONS FOR THIS AMENDED REMEDIAL ACTION IS $1,100,000.

PERFORMANCE STANDARDS OR GOALS; THE "ACTION" OR CLEAN-UP LEVEL FOR MBOCA, THE PRIMARY CONTAMINANT OF CONCERN, IS 1,684 UG/KG, CALCULATED BASED ON EPA GUIDANCE DOCUMENTATION, AND CORRESPONDS TO THE EXCESS LIFETIME CANCER RISK LEVEL OF (10-6). OTHER VOLATILE, SEMI-VOLATILE AND INORGANIC CONTAMINANT CLEANUP STANDARDS ARE CONSISTENT WITH STATE STANDARDS.
 
Remedy:  THE SELECTED REMEDIAL ACTION FOR THE ANDERSON DEVELOPMENT COMPANY SITE ADDRESSES 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;
* EXCAVATION OF CONTAMINATED SOILS, SLUDGE AND CLAY WITH MBOCA CONCENTRATIONS ABOVE THE CLEAN-UP ACTION LEVEL;
* STAGING OF CONTAMINATED SOILS, SLUDGE AND CLAY AND PROCESSING OF THESE MATRICES IN A LOW TEMPERATURE THERMAL DESORPTION DEVICE;
* AIR MONITORING DURING THE REMEDIAL ACTION; AND
* GROUNDWATER MONITORING FOLLOWING THE REMEDIAL ACTION FOR A PERIOD OF 2 YEARS TO ASSESS AND CONFIRM THE EFFICACY OF LOW TEMPERATURE THERMAL DESORPTION.
 
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