United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R05-91/177
September 1991
&EPA
Superfund
Record of Decision
Anderson Development
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" 80272-101
REPORT DOCUMENTATION 11. REPORT NO. .
PAGE EPA/ROD/ROS-91/177
-
.. 1'1118Ub1118
. ~rERFUND RECORD OF DECISION
Anderson Development, MI
First Remedial Action (Amendment) - Final
7. AuIIor(a)
1 ~
:s. R8c:1pIenI'a ~on No.
s. Report 0.18
09/30/91
6.
8. P8rf0rmlng Organlz81lon ~ No.
.. I'IIrIIInI*Ig a..,........, ...... ... Add-.
10. PtojectlT88IIIWoril UnIt No.
11. ConIr8ct(C) or Gr8ftt(G) No.
(C)
(0)
1~ ---- 0rpnIuII0n ...... ... Addr8u
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
1:s. Type of Report . Pettod Covered
Agency
800/000
14.
15. ~No'"
11. AII8hct (I.IJmt: 200 _Ide)
The Anderson Development site is an active chemical manufacturing facility in Adrian,
Lenawee County, Michigan. The site occupies approximately 12.S 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
nffices, as well as a O.S-acre former process wastewater pretreatment lagoon
1taining lagoon sludge and an underlying clay layer. From 1970 to 1979, the
.~lderson 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
(See Attached Page)
17. ~ An8/y8I8 L D88cr1ptore
Record of Decision - Anderson Development, MI
First Remedial Action (Amendment) - Final
Contaminated Media: soil, sludge
Key Contaminants: VOCs (toluene, MBOCA and its degradation products), metals
... 1dInft8n/Op8n-End8d T-
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c. C06A TI FI8IcIIGrcqt
iIIIIII1y 9t8I8m8nt
18. Sec\8'lty CIa.. (Thia Report)
None
20. Security CIa.. (Thla Page)
Nonp
21. No. 01 Pagea
44
n Price
8aa~18
&HI IMlrucliona on 1141"",..
2r.l (4.")
(Formelty NTlS-3S)
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EPA/ROD/R05-91/177
Anderson Development, MI
F' .~t Remedial Action (Amendment) - Final
Abstract (Continued)
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
tid phase activated carbon beds; thermally regenerating or disposing of spent carbon
L 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
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/
RECORD OF DECISION AMENDMENT
ANDERSON DEVELOPMENT COMPANY SITE
ADRIAN, .MICBIGAN
LENAWEE.COUNTY
PURPOSE
This decision document amends the September 1990 Record of Decision
(ROD) for the Anderson Development Company Site, in Adrian,
Michigan. This. decision document presents the selected remedial
action for the Anderson Development Company Site in Adrian,
Michigan, and was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent practicable,
the Nation Contingency Plan (NCPj.
..
BASIS
The decision to amend the Record of Decision is based on the
Administrative Record for the Anderson Development Company Site.
The attached index identifies the items which comprise the
Administrative Record upon which the selection of the remedial
action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the remedial action selected
in this Record of Decision Amendment, may present an imminent and
substantial endangerment to public health, welfare, or the
environment. .
DESCRIPTION OF THE AMENDMENT
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;
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-2-
.
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.
.
DECLARATION
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. The remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element. Because the contaminants will be
removed in the process and disposed of off-site, a five year review
is not necessary.
The state of Michigan concurs on the selected remedy.
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STATE OF MICHIGAN
NATURAL RESOURCES COMMISSION
L,,"'~Y DEVUYST
. "SEL.E
~E J. FL.UHARTV
(.. A~N E. GUYER
DAVID HOL.L.I
o STEWART MYERS
RA YMOND POUPORE
~
..,,~
JOHN ENGLER. Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON BUIL.DING
P O. BOX 30028
L.ANSING. MI 48909
September 27, 1991
OO~@~O\IJ~[ID
. OCT 0.1 1991
OFFICE Of SUPERFUND
ASSOCIATE DIVISfON DIRECTOR
ROI.AND HARMES. Director
Mr. Va1das Adamkus, Regio~a1 Administrator
u.S. Environmental Protection Agency
Region 5, 5RA-14
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Adamkus:
The Michigan Department of Natural Resources (MDNR), on behalf of the State of
. Michigan, has reviewed the proposed Record of Decision (ROD) Amendment for the
Anderson Development Company (ADC) Superfund site, (lenawee County), which we
received on September 4, 1991. The remedy in the proposed ROD Amendment
consists of low temperature thermal treatment (lT3) of contaminated soils in
and around the pretreatment lagoon at ADC. The full-scale implementation of
this remedy is contingent upon the successful testing of this technology at
the site. Should this technology not prove successful during testing, the
site would be remediated by in-situ (in-place) vitrification, which was the
remedy selected in the original ROD which was signed on September 28, 1990.
The selected remedial action for this site is expected to provide a permanent
remedy for the site which is protective of the public health, safety, welfare,
environment, and natural resources. The remedy is expected to meet the
criteria for a Type B cleanup under the rules implementing the Michigan
Environmental Response Act (1982 P.A. 307, as amended). The backup remedy of
in-situ vitrification, if implemented, can also meet the Type B cleanup
criteria. We concur with the selection of lT3 as the final remedy for this
site, with in-situ vitrification as the backup remedy. This concurrence is
contingent upon the successful evaluation of lT3 through the proof of process
testing and the design process.
I look forward to our continued cooperation in the evaluation and full-scale
implementation of the final remedy for this site.
Sincerely,
c::L d--J<
. Delbert Rector
Deputy Director
517-373-7917
Ac:.....t,..J4
cc:
Mr. Jonas Dikinis, EPA
Ms. Mary Tyson, EPA
~Michae1 Valentino, EPA
Mr. Alan Howard, MDNR
Mr. William Bradford, MDNR
Mr. Scott Cornelius/Mr. Brady Boyce. MDNR
,3'",
;::. ::-:
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AMENDMENT TO RECORD.OP DECISIO~
SOKKARY OP REMEDIAL ALTERNATIVB SELECTION
AlmERaON DBVBLOPMENT COMPANY SITE
ADRIAH, MICBIGAII
*******
TABU OP CONTENTS
I. INTRODUCTION 1
II. SITE CHARACTERISTICS 2
III. 8ITE HI8TORY 4
IV. RBIIBDIAL IHVB8TIGATION RE8ULT8 ,
V. REASONS POR IS8UING '1'JIB ROD AKEJtDXEH'l' ,
VI. DESCRIPTIOlf OP '1'JIB IfB1r ALTERNATIVB ,
VII. StJJCKARY OP '1'JIB COMPARATIVB A!lALY8I8 OP
ALTERNATIVES 11
VIII. 8TATUTORY DETERXIHATIOlf8 15
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I. INTRODUCTION
The Anderson Development Company (ADC) site is located in an
industrialized area in the southeast side of the city of Adrian, in
Madison Township, Lenawee County, Michigan. (See Fiqure 3 -1). The
ADC facility is located at 1415 E. Michigan street. The ADC
facility occupies roughly 12.5 acres of a 40 acre industrial park,
and includes several buildings which are used for manufacturing and
storage, offices and laboratory space. within this 12.5 acre area
is a former process wastewater pretreatment lagoon which contains
anywhere from two feet to five feet of standing water, depending on
the time of year and amounts of precipitation. The approximate
area of this lagoon is one-half acre.
The Record of Decision (ROD) for the site which was signed on
september 28, 1990 addressed contaminated site matrices in and
around_the former pretreatment lagoon area. This document amends
the ROD and provides for implementation of concurrent treatability
studies for the purposes of determining the applicability of low
temperature thermal desorption and ISV to 'Site contaminants and
matrices. Low temperature desorption is selected as the remedial
alternative; yet it is contingent upon the successful completion of
the above mentioned treatability study. In the event that low
temperature desorption is determined to be unacceptable, the Site
will be remediated by implementing ISV technology at the Site.
The lead agency for the remedial action at this site is the united
States Environmental Protection Agency (U.S. EPA). The State of
Michigan Department of Natural Resources (MDNR) is the support
agency. This ROD a~endment will become part of the Administrative,
Record File. '
The remedy selected in the ROD was a final remedial action. It
consisted of in situ vitrification (ISV) of surface soils, lagoon
sludge and clay which contain 4,4 '-Methylene bis(2-chloroaniline),
i.e., MBOCA or Curene 442, above the Site specific, health-based
action level of approximately 1.6 mg/kg of MBOCA, on a dry weight
basis. The selected remedy was a source control remedial action
which would have resulted in removing all MBOCA above the clean-up
level. Because the findings of the Remedial Investigation did not
indicate groundwater contamination, and because of the immobility
of MBOCA in soils and immiscibility of MBOCA in water, only short-
term post remedial action groundwater monitoring was required.
Additionally, there was no need to perform a five year review
because contaminants above health-based standards would not remain
on-site.
The present amendment to the ROD also requires treatment of all
contaminated site media above the 1. 6 mg/kg MBOCA (dry weight
basis) clean-up goal, without a need for groundwater restoration
measures. Based on sampling conducted at the Site, approximately
3000 to 4000 tons of soil, sludge and clay will need to be
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~Sl"---
References:
USGS 7.5 Minute Series. Adrian Quadrangle
Adrian. Michigan. 1979.
~
1
Scale In Feet
I
2,000
o
2.000
FIGURE 3-1
SITE LOCATION MAP
3.2 "\...I~ :. 't'
. , -\ -'-I I .
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~
remediated via application of low temperature thermal desorption of
contaminated matrices, followed by placement of treated soils,
sludge and clay into the excavated former lagoon, covering of the
lagoon with clean native soils and grading to allow for proper
surficial drainage.
The selection of low temperature thermal desorption iS,contingent
upon the successful demonstration of a full-scale treatability
study to be performed in October 1991. If U. S. EPA determines that
low temperature desorption can safely and effectively remove MBOCA
from the contaminated matrices, achieve all Michigan Environmental
Response Act (Act 307) soil clean-up criteria and meet all other
clean-up and performance standards, and not generate products of
incomplete combustion at levels which would pose human health or
environmental risks, then site remediation will be pursued by
employing this technology. In the event that low temperature
desorption fails to meet the clean-up and performance ,standards
specified in the Scope of Work (SOW) attached to the Consent Decree
for conduct of remedial design and remedial action (RD/RA) , then
the Site is to be remediated via ISV. An engineering-scale ISV
treatability study will be performed concurrently with the low
temperature desorption treatability study. The results of the ISV
engineering-scale test are expected to be available in late 1991 or
early 1992.
II. SITE CHARACTERISTICS
Based on the information gathered from borings and wells completed
during the Remedial Investigation (RI) field activities, the
hydrogeology immediately surrounding the ADC plant was described in
the RI. In the pretreatment lagoon area, there is an upper brown
till unit, 30 to 40 feet thick, with small but variable amounts of
sil t, sand and gravel. This un! t does not contain perched
aquifers, but contains small "pockets" of groundwater where the
permeability is believed to be qreater than that of the remainder
of this "confininq layer." Below this confininq layer is a
saturated and confined aquifer composed primarily of poorly sorted
. grey 'and black sand, silt and gravel. The thickness of this unit
was not determined. The aquifer and confininq layer are
hydraulically connected, althouqh the low permeability of the clay
layer would significantly retard the vertical travel of
contaminants at the Site.
Based on water level measurements, well loqs, construction details
and survey data collected during the RI, it is estimated that in
the sandy, confined aquifer, qroundwater flows approximately'to the
northwest. However, in the clay-rich confining layer, the flow
pattern could not be predicted because of the heteroqeneity of the
unit. The clay-rich confininq layer is not used for any water
supply purposes. The residential wells closest to the ADC Site are
those located in the Sunnyside Subdivision, and are believed to be
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1.
confined and deeper aquifer. Also, the residences in the Sunnyside
Subdivision are provided with a central water supply. The only
known operating domestic water supply well in the Sunnyside
Subdivision is at the Sunnyside Cafe, located on East Maumee
Street, and hydraulically upgradient to. the Site.
The "area of contamination" for which a response action is
necessary is limited to the former pretreatment lagoon area, and
the remedial action selected in this Record of Decision represents
a complete Site clean-up. During negotiations for conduct of the
Remedial Investigation and Feasibility Study, the "Site" was
limited to the extent of the ADC property, and was not intended to
include areas of contamination away from the facility (e.g., the
Adrian Wastewater Treatment Plant). Contaminated media (above the
health-based clean-up action level) include lagoon sludge, some of
the naturally occurring clay w~ich underlies the lagoon, and a
small volume of surface soils located adjacent and to the north of
the lagoon. For a map of the area and map of the lagoon area,
refer to ~iqur.. 2 and 3-2, respectively. .
Situated in an industrialized setting, the ADC facility is within
1000 feet of Aldrich oil, AGET Manufacturing, Marco Plastics,
Adrian Packaging, Inter-American Zinc and Hydro-Tech Chemicals.
The former pretreatment lagoon is located approximately 400 feet
south of the ADC main office building and is within 200 feet of the
property boundary of Hydro-Tech Chemicals.
Approximately 330 homes are located within a one kilometer (5/8
mile) radius of the ADC plant, including two residential
subdivisions: Drexel Park and Sunnyside. Boundaries for the Site
include Church Street to the north, Gulf Street to the west,. Wabash
Street to the east, and railroad tracks to the south and east. The
closest residences to the Site are approximately 1/4 mile away.
Adrian is located in glacially-derived topography, a moraine
comprised of unconsolidated and heterogeneous clay, silt, sand and
gravel. The underlying bedrock formation is the Coldwater Shale,
located approximately 100 to 250 feet below the land surface. Most
surface soil around the ADC Site is hard clay till, brown to grey
in color , with variable amounts of sand and gravel. Surface runoff
from the Site is conveyed by City storm sewers to the East Side
Drain, which is an ephemeral tributary to the South Branch of the
River Raisin. Adrian (population 21,276) water supplies are drawn
from Lake Adrian, a reservoir located on Wolf Creek which merges
with the River Raisin at approximately two miles upstream of the
mouth of the East Side Drain. No wetlands or floodplains have been
identified near the Site. The ADC facility is within 6000 feet of
the River Raisin at its closest point. The lagoon is fenced, and
access is provided via a gate and unpaved road to the west of the
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L£GEND:
----
RAIlROAD
UNIMPROVED ROADWAY
~ EXISTING BUILDING TO BE
~ LlSED FOR SLUDGE STORAGE
rI SLUDGE AHDCLAY AREA
L......:...J REQUIRING RENEDIA TION
II&mW:I L T' PROCESS EQUIPMENT AREA
~ (SEE F~URE 2.2 fOR EOUIPMENT LAYOUT)
-OI_T[ SCAlE
~--
~ 0
SITE PLAN
ADC SITE
ADRIAN, MICHIGAN
~ r[ET
IUI8UIW.
- .~ r~ SUIIW'r. AHQ(1t$ON COMP""'.
-, --=-. COUOUO BY PMOT~
~s BY .. WIIIPS. INC.. DAft or
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DIRECTION or rlOW
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(1 roOT CONrOUR INTERVAl)
(rErT ABovE IASL)
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SPOT El.£\'AnON (USGS)
EDGE or INooOED ARL<
........
~
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FIGURE
4
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J.
Under CERCLA i 117 and section 300.435(c) (2) (ii) of the National
Contingency Plan, the lead agency is required to propose an
amendment to the Record of Decision (ROD) if the differences in the
remedial action alter the basic features of the ROD and allow the
public the opportunity to comment on the proposed changes. A
public meeting for the original ROD was held on July 12, 1990 with
approximately 50 residents in attendance. The amendment to the ROD
was made available to the public on August 28, 1991. 'The public
meeting was held on September 12, 1991, at City Council Chambers in
Adrian, Michigan.
III. SIT. HISTORY
Anderson Development Company (ADC) is a corporation principally
involved in the manufacture and sale of specialty organic
chemicals. It is located on the southeast side of the City of
Adrian in Lenawee County, Michigan. The Site covers approximately
12.5 acres, including a pretreatment lagoon, within a 40 acre
industrial park. ADC is surrounded by light industrial and
residential areas.
ADC is a specialty organic chemical manufacturing facility. ADC
began production of MBOCA, i.e., 4,4 '-Methylene bis(2-
chloroaniline), in 1970 under the trade name CUrene 442. MBOCA is
used as a hardening agent in the manufacture of polyurethane
plastics. Throughout the 1970' s, ADC produced as much as 1.3
million pounds of MBOCA annually. During this period, ADC
accounted for 25% to 40% of the MBOCA production in the United
States. MBOCA has a number of synonyms, depending on its producer:
Curalon M (Uniroyal): Cyanaset (American Cyanamid): MOCA (DuPont),
etc. MBOCA is biodegradable and belongs to a class of compounds
known as aromatic amines. Its molecular formula is CH2(C6H3ClNH2)2.
MBOCA is a known animal carcinogen and the National Institute for
Occupational Safety and Health (NIOSH) recommends that it be
regulated as a human carcinogen. Two known biological degradation
products (metabolites) are N-acetyl -MBOCA, (AC) and N,N'-diacetyl
-MBOCA, (DAC). Based on studies of similar degradation products of
benzidine and other aromatic amines, these degradation products are
considered even more toxic than MBOCA. MBOCA is generally
considered to be a crystalline solid which does not readily
dissolve in water. It has a high affinity for organic and
inorganic particulate matter. MBOCA has a very low vapor pressure
of 10-5 mm Hg @ 24 degrees Celcius. Pure MBOCA has a melting point
of approximately 110 degrees Celcius (about 230 degrees
Fahrenheit) .
The process waste discharges of the MBOCA production process caused
MBOCA contamination of the nearby East Side Drain, the Adrian
Wastewater Treatment Plant (WWTP) and River Raisin. Originally,
ACe discharged its process wastewater and cooling water, untreated,
into the East Side Drain. This occurred through 1973 when the MDNR
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~
late 1973, ADC separated the process wastewater from its cooling
water, thus allowing for pretreatment of the wastewater to the
satisfaction of the MDNR prior to discharge to the municipal water
treatment system. MBOCA discharges to the WWTP continued,
resulting in decreased efficiency of the WWTP. At the WWTP, MBOCA
settled out with other solids and fOI~ed a sludge material which
was applied to the land leading to MBOCA contamination at the WWTP
drying beds. Eventually, MDNR advised the City of Adtian not to
accept ADC discharges contaminated with MBOCA. MBOCA was found in
surface sediments on and around the ADC plant in 1979, and MBOCA
production was stopped. MBOCA discharges to the environment
occurred via surface water and airborne routes. The airborne
mechanism of contamination may have resulted from sublimation of
MBOCA during the manufacturing process or generation of MBOCA
particles as fugitive emissions which were subsequently discharged
to the- environment through the plant's ventilation system. No
MBOCA was detected in the subsurface soil at a depth of greater
than 1. 5 feet and no groundwater contamination was 'detected.
Treated process wastewater and storm water run-off discharges from
the ADC plant resulted in the contamination of the East Side Drain
bottom sediments.
The Michigan Department of Natural Resources (MDNR), Michigan State
Toxic Substance Control Commission (TSCC), ADC and local
, governmental agencies, through comprehensi ve cleaning and
monitoring efforts, cleaned the contaminated areas (those above an
MBOCA level of 1 ppm) in 1980 and 1981. Clean-up actions included
in-plant decontamination, residential carpet shampooing/vacuuming,
street sweeping, removal of some surface soils from roads and'
parking lots, and paving/tilling/covering of unpaved areas near the
plant. Contaminated soils were placed in the Wayne County
Municipal Landfill. This response action was funded by the State,
who later recovered their costs from ADC.
The Site was placed on the National Priorities List (NPL) in 1983.
In June 1984, a Remedial Action Master Plan (RAMP) was developed by
U.S. EPA using available data. It was recommended in the RAMP that
further investigations were necessary and some kind of remedial
action needed to be implemented. On April 30, 1986, Anderson
Development Company entered into an Administrative Order by Consent
("AOC" or "the Order") with U.s. EPA for the conduct of a Remedial
Investigation and Feasibility Study (RI/FS). C. C. Johnson and
Malhotra, P.C. was contracted by ADC to conduct all work related to
the RI/FS.
On May 23, 1986, the U. S. EPA Region V Regional Administrator
signed a CERCLA 106 Administrative Order by Consent stipulating the
undertaking of a Remedial Investigation and Feasibility study
(RI/FS) for the purposes of determining the nature and extent of
the threat to the public health or welfare or the environment due
to the release or threatened release of hazardous substances or
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.t
action alternatives to prevent or mitigate the migration or release
of hazardous substances or contaminants from the site.
The signed Order underwent a 30 day public comment period shortly
thereafter. No comments were received .during public comment and
the Order became effective on July 2, 1986.
On July 2, 1990, the u.s. EPA published, and placed in the
repository for public viewing, a Proposed Plan for remedial action.
A formal public hearing was held on July 12, 1990 to answer
questions in regard to the Proposed Plan and to accept verbal
public comment on the Proposed Plan. u.s. EPA accepted written
comment on the Proposed Plan through August 8, 1990.
:IV. ItIDD!ID:IAL :I1IVB8T:IGAT:IOIf RB8ULU
The Remedial Investigation was completed in four phases. The first
three phases only addressed environmental contamination of MBOCA,
AC and DAC. Phase I field sampling began in October 1987 and was
completed in November 1987. The results of this sampling phase
were presented in two technical memoranda submitted in April 1988.
Additional sampling for Phase II of the RI was conducted in
September 1988, with results presented in a November 1988 technical
memorandum. Further waste characterizat!on of the pretreatment
lagoon was conducted in November 1988. Phase III results were
presented in the Revised RI Report submitted by ACC in January
1989.. The final phase (Phase IV) was. conducted in April 1989 for
the purpose of characterizing lagoon sludge, lagoon clay and lagoon
area groundwater for most u. S EPA Target Compound List (TCL)
compounds, as well as assessing the vertical extent of MBOCA, AC
and DAC contamination in the clay beneath the lagoon. Phase IV
sampling results were presented in the Revised RI Report submitted
in July 1989 and resubmitted with further revisions in September
1989 (Final RI Report).
Samples. of soil, sediment, surface water and groundwater were
collected as part of the RI. Surface soil, near-surface soil and
sediment are the primary environmental media which have indicated
detectable MBOCA, AC or DAC contamination. RI data indicate
current on-site MBOCA levels up to 2,800 mg/kg (pretreatment
lagoon sludge) and off-site MBOCA levels up to 350 ug/kg (surface
soils within 2000 feet of ADC Site). Various volatile and semi-
volatile organic compounds including toluene and 4-methylphenol
were found in the lagoon sludge. Both the number and
concentrations of detectable organics were lower in the lagoon
clay.
Results of the RI indicated that groundwater and surface water on-
site as well as off-site are not contaminated with MBOCA, AC, or
DAC. Low levels of several volatile and semi-volatile organic
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1.
that the groundwater and surface water are not contaminated at
levels of concern and do not need remediation.
While various organic compounds were detected in this limited water
bearing layer of clay, some of these, such as acetone and methylene
chloride, have been attributable, at least in part, to laboratory
contamination. Furthermore, levels of both detectable volatile and
semi-volatile organics were found to be much lower in the confined
aquifer than in the confining layer groundwater. When the sandy
aquifer was reached during drilling, artesian conditions were found
as. water levels rose to the piezometric surface of the aquifer.
These conditions would tend to mitigate downward contaminant
migration into the underlying aquifer.
An assessment of the health risks associated with MBOCA
contamination on-site and off-site was carried out and presented in
the Endangerment Assessment (EA). Various exposure scenarios,
through which different populations could potentially be exposed to
MBOCA, were evaluated. Risks associated with oral ingestion and
d.ermal exposure to MBOCA contaminated soil/sediment were considered
for each of the scenarios.
MBOCA action/clean-up levels for 1 X 10E-04 to 1 X 10E-07 risk
levels were determined for different exposure scenarios and
compared with the maximum observed MBOCA levels. Consistent with
the NCP, a 1 X 10E-06 "point of departure" was considered for
clean-up purposes. This comparison indicated that except for the
ADC lagoon area, no surface or subsurfaces soil/sediment
remediation is warranted. .
An "action level" or clean-up level of 1684 ug/kg (rounded down to
1.6 ppm) of MBOCA for soils (10E-06 risk level) was calculated
based on the. residential exposure scenario considered in the
Endangerment Assessment.
The exposure routes and calculated target levels were determined in
accordance with u.s. EPA guidance documents, SUDer fund Public
Health Evaluation Manual (SPHEM) and SUDerfund EXDosure Assessment
Manual (SEAM). A 10E-06 carcinogenic risk level of approximately
1.3 ppm was calculated based on the standardized exposure
assumptions as defined in Rule 299.5711 of Act 307. Within this
rule is an algorithm which establishes an acceptable risk for
exposure via direct contact with contaminated soils. Although the
Act 307 clean-up goal is slightly more stringent than that which
was determined according to u.s. EPA guidance, because the state
does not see any practical or significant difference between these
two values, the higher value was acceptable to MDHR. This action
level of 1.6 ppm necessitates remedial action for some surface
soils, lagoon sludge and clay beneath the sludge in the ADC
pretreatment lagoon area. The total volume of clay to be treated
can only be approximated at this time because of the fact that
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~
deep as five (5) feet. Further sampling and analyses will be
conducted during design for the purposes of delineating the extent
of vertical contamination, thus allowing for more accurate cost
analyses.
Feasibility study (FS) activities began in December 1988. A draft
FS was submitted by ADC on October 3, 1989. The draft FS included
remedial action objectives to address contamination of'the lagoon
sludge, clay beneath the lagoon and some surface soils around the
lagoon. The Final FS was submitted to U.s. EPA and MDNR on March
2, 1990. The FS and Proposed Plan were made available for public
comment on July 2, 1990.
From the data gathered during the RI, the following conclusions
were drawn in the FS:
*
MBOCA concentrations in the environment surrounding the
ADC plant have decreased significantly since 1980. This
reduction is attributable to the cessation of MBOCA
production, the initial remedial action undertaken at the
.plant and surrounding area, and to a lesser extent, to
the biodegradation of MBOCA in the environment..
*
No MBOCA, AC or DAC was detected in off-site groundwater,
and only one surface water sample contained MBOCA at a
detectable concentration (1 ug/l).
*
Concentrations of MBOCA, AC and DAC in the surface and
subsurface soils and sediment around the ADC plant area
varied from non-detectable levels to a maximum of 350
ug/kg. MBOCA concentrations in soils around the former
lagoon area were found to be as high as 98,000 ug/kg.
*
Sludge in the former pretreatment lagoon contained MBOCA
levels as high as 2,800,000 ug/kg, manganese levels as
high as 101,000,000 ug/kg (10% by weight), toluene as
high as 140,000 ug/kg and numerous other organic
constituents in concentrations as high as 200,000 ug/kg.
*
Subsurface clay beneath the lagoon contained MBOCA at
concentrations up to 660,000 ug/kg, AC concentrations up
to 3900 ug/kg, and DAC concentrations up to 35,000 ug/kg.
Various inorganics and volatile and semi-volatile
organics were also detected in the clay layer, but at
levels lower than those found in the lagoon sludge.
*
The confining layer does not contain detectable levels of
MBOCA, but AC was found once at 21 ug/l. One Target
Compound List (TCL) organic (M-Chloroaniline) was
detected at 1000 ug/l, as well as several tentatively
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layer does not represent an adequate, continuous aquifer
and is considered unusable by both u.s. EPA and MDNR.
V.
RBASONS I'OR ISSUING '!'JIB ROD AMENDMENT
Following issuance of the ROD in September 1990, Anderso~ presented
U.S. EPA with the results of a bench-scale low temperature thermal
desorption test. The results of this test were reviewed by U.s.
EPA Region V, MDNR, and U.S. EPA's Risk Reduction and Engineering
Laboratory (RREL) in Cincinnati, Ohio. In December 1990, a letter
was sent to Anderson which identified certain technical
deficiencies in this bench-scale test. U.S EPA did indicate that
the technology did offer some promise with respect to Site
remediation.
Based on a preliminary review of the low temperature thermal
desorption process and the types of contaminants present at the ADC
Site, Region V and MDNR, in conjunction with RREL's Superfund
Innovative Technology Evaluation (SITE) Program and Supertund
TecbnologyAssessment and Research Team (START) Program, determined
that further evaluation, including additional testing at full-
scale, would be needed to completely evaluate the process. It is
anticipated that low temperature thermal desorption will be
effective in achieving the site-specific clean-up standards for the
. ADC site. The technology is expected, with a high degree of
confidence, to meet all air pollutant discharge limitations, as
well. Based on preliminary cost estimates prepared by Weston
Services, Inc. low temperature thermal desorption is expected to
have a capital cost approximately one-half that of ISV. In
addi tion, the community perception of low temperature thermal
desorption is favorable, as noted in the attached Responsiveness
Summary.
VI. DESCRIPTION 01' '!'JIB NEW ALTERNATIVB
This ROD amendment selects low temperature thermal desorption as
the preferred response action at the Anderson Site. Low
temperature thermal desorption is a process by which contaminated
soils are excavated, placed in feed hoppers and either directly or
indirectly heated in a thermal processing chamber in order to drive
off volatile and semi-volatile organic compounds. Several methods
of heating contaminated si te media can be employed and vary
according to a given vendor's specific design.
One process may entail heating air via a gas fired burner and
passing it over the contaminated matrix as it is agitated on a
conveyor belt which transports the matrix through the thermal
processing unit. Such a system may involve cocurrent or
countercurrent flow of hot air and contaminated soils. The
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volatilization and mass transfer of contaminants from the soil
matrix to the vapor phase) can be regulated by adjusting the air
flow rate over the matrix, the temperature of the hot air stream
and the rate of belt movement (i.e., the residence time). Another
design may entail indirect heating of the soil matrix within a
jacketed (i.e., thermally insulated) trough and by carrying it via
a series of rotating hollow screws within the thermal ,processor.
Hot oil passing through these screws serves as the heat transfer
medium. Process variables which determine the efficiency of the
operation, such as residence time and matrix temperature, can be
adjusted by means of varying the rotational speed of the hollow
screws and by varying the temperature of the heat transfer fluid
within the screws.
After the contaminants are driven from the soil matrix, these off-
gases -are treated in an air pOllution control train which is
designed to effectively treat the organics which are vaporized as
well as the particulate contribution from the process itself.
Methods of off-gas treatment may include the use of cyclonic
separators in a series and parallel alignment (multiple cyclones)
or a fabric filter system (i.e., baghouse) for removal of
particulates. organic vapors can be removed in a medium to high
energy venturi scrubber or condenser in series or "piggyback"
alignment with vapor phase activated carbon columns. Aqueous
streams from the scrubber or condenser are treated in liquid phase
carbon units.
Spent carbon and fines from the particulate removal equipment will
be sent off-site for thermal regeneration or disposed of at a'
licensed off-site landfill, respectively. After all contaminated
matrices have been treated to meet the clean-up and performance
standards in the SOW, the treated soils will be placed back into
the' excavated lagoon and covered with clean native soils.
Groundwater monitoring will take place on a semi-annual basis for
a period of two years thereafter.
During the full-scale test demonstration, all internal and external
process streams will be analyzed for a wide range of parameters.
In addition, stack emissions will be monitored by employing U.S.
EPA Method 5 (for particulates) and Method 25 (for volatile
organics) during all phases of the test demonstration to ensure
compliance with Federal and state regulations.
MBOCA vaporizes at approximately 250 of, and should therefore be
driven off of the contaminated matrices within the treatment
chamber. Of paramount importance in the effectiveness of this
technology is the ability to provide for sufficient surface area of
the contaminated individual soil "clumps" such that all the MBOCA
can be volatilized. The biggest concern here is with the clay
which underlies the lagoon. Because of the stiffness of the clay,
there is a materials handling concern which must be adequately'
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will have to be shredded to a size which will be conducive to
proper heat transfer across the individual clump, as well as
allowing for effective mass transfer of the solid MBOCA bound
within the soil matrix across the soil matrix, to the surface of
the individual clump and ultimately into the off-gas stream as a
vapor.
After the MBOCA is driven off, it may be found at several locations
wi thin the process. The cyclones and baghouse should be maintained
at temperatures greater than 300 .F, and therefore, MBOCA should
pass through these devices in the vapor phase. However, with the
reduction in off-gas temperature to be realized in either the
scrubber or condenser, this is where the greatest recondensation of
MBOCA should occur. The aqueous streams generated in these devices
will be treated in liquid phase activated carbon beds, followed by
off-site regeneration of the carbon. MBOCA and other organics
remaining in the off-gas will be treated in vapor phase carbon beds
prior to off-gas release to atmosphere via the discharge stack.
Most organj,c compounds are amenable to adsorption on activated
. carbon. Because the off-gas will be introduced to the the carbon
columns at approximately 90 .F, and because of the relatively high
molecular weight of MBOCA and its affinity for organics in soils
(as evidenced by the large retardation effect calculated during the
RI), MBOCA remaining in the off-gas should be readily removed in
the vapor phase carbon.
The system, therefore, should provide an effective
removing and treating MBOCA and should result in
restoration of the Site to levels which do not
unacceptable threat to human health or the environment.
means 0 f
complete
pose any
VII. SUMMARY OF TBB COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
The Nine Evaluation Criteria
This ROD Amendment examines two alternatives, ISV and low
temperature thermal desorption. These two alternatives are
evaluated in this ROD Amendment according to technical feasibility,
environmental protection, public health protection and
institutional 'issues.
The two alternatives were evaluated according to the following nine
criteria which are used by the U.S. EPA to provide the rationale
for the selection of the final remedial action at a site:
THRESHOLD CRITERIA
1) OVerall Protection of Human Health and the Bnvironment
addresses whether or not a remedy provides adequate protection and
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11
reduced or controlled through treatment, engineering controls, or
institutional controls.
2) complianoe with state and Federal .equlation. (Ana'.)
addresses whether or not a remedy will meet all the applicable or
relevant and appropriate requirements of other Federal and state
environmental statutes and/or provides grounds for invoking a
waiver. . .
PRIMARY BALANCING CRITERIA
3)' .eduotion of Toxioity, MObility, or Voluae is the anticipated
performance of the treatment technologies a remedy may employ.
4) Short-Tera Bffectivenes. addresses the period of time needed
to achieve protection, and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
5) Long-Tera Bffeotivene.. and Permanence refers to the ability
of a remedy to maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
') Iapl..entability is the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement a particular option.
7) Co.t includes estimated capital and operation and maintenance
costs, and net present worth costs.
MODIFYING CRITBRIA
8) state Aooeptance indicates whether, based on its review of the
RI/FS and the Proposed Plan, the state concurs in, opposes, or has
no comment on the preferred alternative at the present time.
9) COIIIJIUDity Acceptanoe will be assessed in the Record of
Decision following a review of the public comments received on the
RI/FS report and the Proposed Plan.
B.
ComDarative ADalvse. of Alternatives
The two alternatives were evaluated using the nine criteria. The
regulatory basis for these criteria comes from the National
Contingency Plan and Section 121 of CERCLA (Cleanup Standards).
Section 121(b) (1) states that, "Remedial actions in which treatment
which permanently and significantly reduces the volume, toxicity or
mobility of the hazardous substances, pollutants, and contaminants
is a principal element, are to be preferred over remedial actions
not involving such treatment. The off-site transport and disposal
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treatment should be the least favored alternative remedial action
where practicable treatment technologies are available." Section
121 of CERCLA also requires that the selected remedy be protective
of human health and the environment, cost effective, and use
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
The two alternatives are compared to the nine criteria in the
following section:
1)
OVerall Protection of Human Health and the Bnvironaent
By treating all Site media which contain MBOCA in concentrations
above the clean-up standard down to the 1.6 ppm clean-up standard,
and to all Type 307 clean-up criteria, the selected alternative, or
the contingency alternative will
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control equipment would mitigate any potential risks to nearby
populations. Ambient air monitoring stations set up around the
perimeter of the work zone would serve as a warning system to
suspend operations in the event of airborne releases of
contaminants. Because the prevelent contaminant, MBOCA, is of low
volatility, the probability of inhalation by workers is decreased.
5)
Lonq-Ter.a Brrectivene.. and Permanence
Each alternative would achieve long-term protectiveness of human
health and the environment because no MBOCA which would present
unacceptable human health risks would remain on-Site. Low
temperature thermal desorption would be effective in permanently
removing site volatile and semi-volatile organic compounds, and ISV
would offer extremely high destruction and removal efficiencies for
volatile and semi-volatile organics.
6)
zapl..entability
There should be no difficulties in implementing the selected
alternative. The low temperature thermal desorption equipment is
a fabricated unit, which has been used by Anderson's remediation
firm at other Superfund Sites. The contractor therefore has
familiarity with the equipment and is prepared to address operation
and maintainance problems which may' arise in the field. The
contingency alternative has not been commercially applied at full-
scale, although Geosafe is expected to implement ISV at one or more
sites before it would be implemented at the ADC site. Some
difficulties may exist in obtaining an adequate connection to a
power source and ADC may incur additional one-time costs to provide
for this hook-up. Al ternati vely, a portable, diesel-powered source
of electricity can be brought to the Site, although this may be
more costly than arranging for a proper hook-up.
7)
coat
The construction costs associated with ISV in the Feasibility Study
were estimated to be $2.3 million. Weston Services, Inc. has
provided Anderson with preliminary cost estimates for thermal
desorption in the amount of approximately $1.1 million.
8)
state Acceptance
The State of Michigan concurs with the selected remedy and the
contingency remedy.
9)
community Acceptance
The communi ty has favorably responded to the selected remedy,
al though there still exists some opposition to the contingency
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VIII. STATUTORY DBTBRMINATIONS
1.
Protection of Human Health and the Bnvironment
The selected remedy is protective of human health and the
environment by treating all contaminated lagoon area media found to
be above the clean-up level via either low temperature thermal
desorption or in ~ vitrification. '
Any short term risks associated with the excavation and handling of
contaminated materials (e. g., dust g.eneration) will be minimized by
the use of good construction practices such as dust suppression
measures and covering of contaminated and treated stockpiles.
Ambient air monitoring, as well as off-gas treatment system
emissions monitoring, will be conducted to assess possible exposure
during the low temperature thermal desorption full-scale on-site
treatability study and the remedial action.
2.
Attainaent of ARAR'.
The selected remedy will attain all Federal and State applicable or
relevant and appropriate requirements and all clean-up and
performance standards identified in the sow.
Federal ADR's
The maj or Federal and state of Michigan ARAR I sand TBC' s are
presented here. A more complete listing and presentation in matrix
format can be found in the Feasibility study Report, and a more
detailed discussion is presented in the September 1990 ROD.
General groundwater monitoring and corrective action requirements
for waste management units are included in 40 CFR Part 264 Subpart
F, promulgated under the Resource Conservation and Recovery Act of
1976 (RCRA). Although RCRA is not applicable to this Site because
no disposal of hazardous waste took place due to the fact that the
MBOCA is not considered a RCRA listed waste, these requirements are
relevant and appropriate for the Site. This subpart requires a
system of wells to detect hazardous constituents in groundwater
downgradient of the waste unit. The detection of waste unit
constituents downgradient could trigger the need for corrective
action. Corrective action is required for all releases of
hazardous constituents from any solid waste management unit
pursuant to 40 CFR Part 264 Subpart F. There have, however, been
no detected releases of contaminants in the groundwater. Each
alternative includes a groundwater monitoring program which would
meet the subsequent criteria of 40 CFR Part 264 Subpart F
monitoring requirements.
40 CFR Part 263 lists transporter regulations which are relevant
and appropriate to these alternatives. If spent activated carbon,.
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low temperature thermal desorption process must be discarded off-
Site, it will be done in compliance with 40 CFR Part 262 and 263
ARAR's.
The Clean Air Act sets maximum contaminant concentrations for
airborne releases. Each alternative provides for stack sampling
and air monitoring to evaluate air releases and assure compliance
with this ARAR. .
The Hazardous and Solid Waste Amendments (HSWA) to RCRA include
provisions restricting land disposal of RCRA hazardous wastes. The
purpose of the HSWA is to minimize the potential of future risk to
human health and the environment by requiring treatment of
hazardous wastes prior to land disposal. The land disposal
restrictions (LDR ' s) under HSWA are not aDDl icable for those
alternatives involving land disposal of contaminated soil, sludge
and clay or residual baghouse fines because the wastes are not RCRA
listed wastes or RCRA characteristic wastes.
It was determined that the MBOCA found at the Site is not a RCRA
"listed U waste because it does not meet the requirements of 40 CFR
Part 261.33 (i.e., it is not a discarded commercial product, off-
specification specie, container residue or spill residue). LDR
provisions are not considered relevant and appropriate. The Agency
is undertaking a rulemaking that will specifically apply to soil
and debris. Since that rulemaking is not yet complete, u.s. EPA
does not consider LDR's to be relevant and appropriate at this Site
to soil and debris that does not contain RCRA restricted wastes.
It may be noted, however, that the selected remedy meets MBOCA
treatment standards under the LDR' s. A treatment standard for
MBOCA is included in the Third Thirds treatment standards, at
Federal Reaister Vol. 55, No. 106. The revised concentration-based
standard is 35 mg/kg. Low temperature thermal desorption and ISV
would achieve clean-up goals more than one order of magnitude .more
stringent than the RCRA treatment standard for MBOCA.
The Clean Ai~ Act establishes National Ambient Air Quality
Standards (NAAQS) for primary air pollutants and is an ARAR for air
emissions from the Site during excavation, processing of
contaminated Site media within the thermal desorption treatment
chamber, and during processing of soils via ISV.
The Department of Transportation (DOT) Hazardous Materials
Transportation Act, 40 U.S.C. 1801 regulates off-site
transportation of hazardous waste and is relevant and appropriate
for the off-site transport of MBOCA-1aden materials.
The Occupational Safety and Health Administration (OSHA)
establishes rules and regulations at 29 CFR 1926 for remedial
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Pederal "To Be Considered" Requirements ("TBC's")
Low temperature thermal desorption may involve sending materials
excavated from the site to an off-site landfill. The u.s. EPA off-
site policy is a TBC and will be followed to ensure that wastes are
sent to a CERCLA off-site compliant RCRA permitted landfill.
The U.S. EPA Office of Groundwater has published Groundwater
Classification Guidelines (GWCG's) which enable classification of
all groundwater as Class I, II, or III, based on its use, value,
and vulnerability. The confined sand and gravel aquifer beneath
- the Site would be classified as a Class II aquifer (curre"nt or
potential source of drinking water). A Class II aquifer should be
protected from contamination which might render the aquifer
unusable or unacceptable as a source of drinking water. Therefore,
contamination or degradation of the groundwater is unacceptable and
should not be allowed to occur. The GWCG's are TBC for this Site.
The U.S.EPA Environmental criteria and Assessment Office has
prepared th~ Integrated Risk Information System (IRIS) to provide
heal th based and regulatory information on specific chemicals.
IRIS provides chemical specific information which is utilized by
U. S. EPA in risk calculations and development of health based
clean-up goals and is TBC. The risk tables presented in the FS
utilize IRIS values where appropriate. As presented in the
selected and contingency alternatives, the elimination of the
direct contact threat by complete excavation of the contaminated
area would comply with the health based clean-up goals developed
utilizing the IRIS database. The groundwater monitoring component"
of the alternatives comply with the TBC health based clean-up goals
developed utilizing the IRIS database.
The u.S. EPA Office of Emergency and Remedial Response, Office of
Solid Waste and Emergency Response has Prepared the SUDerfund
Public Health Evaluation Manual to provide methods and guidance in
preparing health-based risk assessments. The Tables presented in
the FS utilize the SPHEM where appropriate. As presented in the
selected and contingency alternatives, the elimination of the
direct contact threat by complete excavation of the contaminated
soils, sludqe and clay would comply with the TBC health based
clean-up goals developed utilizing the SPHEM. The groundwater
monitoring component of these alternatives comply with the health
based clean-up goals developed utilizing the SPHEM. "
state of Xichiaan ABAR's
The substantive provisions of Parts 6 and 7 of the rules
promulgated under Act 307 of the State of Michigan are considered
an ARAR for the remedial action to be undertaken at the Site.
These rules provide, inter glia, that remedial actions be
protective of human health, safety and welfare, and the environment
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this standard is achieved by a degree of clean-up which conforms to
one or more of three clean-up types (Rule 299.5705 (2) ~ ~.).
Type A criteria are based on reduction of hazardous substance
levels to background or below detectable levels (Rule 299.5707).
Type B criteria are based on reduction of hazardous substance
levels to an acce~table risk level (e.g., an excess lifetime cancer
risk of 1 X 10. for carcinogens) using standardize,d exposure
assumptions (Rule 299.5709). Type C criteria involve a site-
specific assessment of risk and remedy evaluation to select
remedies which do not pose an unacceptable risk (e.g., an excess
lifetime cancer risk of 1 X 10-6 for carcinogens). Remedy
evaluation under Type C criteria must include evaluation of
alternatives which meet Type B criteria. This evaluation must be
made against a variety of factors listed in Rule 299.5717.
Under Rule 299.5711, !2 of Act 307, an alternate concentration can
be selected for soils based upon the Toxici ty Characteristic
Leaching Procedure (TCLP), as set forth in 40 Code of Federal
Reaulations Part 261. Since concentrations of arsenic and barium
exceed Type B concentrations in the clay and sludge at the Anderson
Site, TCLP on pretreated sludge and clay will establish the
alternate clean-up standards for these metals and other inorganics
which presently exceed Type B criteria. Low temperature thermal
desorption will not remove inorqanics from soil matrices.
Because of the impermeability of the confining layer, the mobility
of metals is not expected to be significant.
Each of the two alternatives discussed in this ROD amendment would
meet the requirements of a Type B clean-up under the Act 307 Rules.
Act 348 of 1965 and Administrative Rules defines requirements for
air emissions during remedial actions and is an ARAR. Each
alternative complies with this ARAR by providing an air monitoring
program and a stack emissions monitoring program, as well.
Michigan Hazardous Waste Management Act, Public Act 64 of 1979, as
amended, sets regulations for generators and transporters of
hazardous waste and owners and operators of hazardous waste
treatment, storage and disposal facilities. The selected remedy
would comply with this alternative.
Rule 613 is the RCRA equivalent to 40 CFR Part 264 as previously
described under Federal ARAR's.
Michigan Soil Erosion and Sediment Control Act, Public Act 347 of
1972 sets regulations prescribing the requirements for soil erosion
and sedimentation control measures and procedures, and is an ARAR
for each alternative.
Michigan occupational Health and Safety Laws, Michigan Act 154 of
1974 regulates working conditions for the health and safety of
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state of Xichiaan TBC'.
SARA section l2l(e) states that no permit shall be required for the
portion of any remedial action conducted entirely on-site. It is
the intent of the U.S. EPA to meet the substantive requirements of
any permit related ARAR's or TBC's.
Based upon the above analysis, the selected and contingency
alternatives would meet Federal and State ARAR's and TBC's.
3. . Co.t-Bffecti vene..
The selected remedy provides cost-effectiveness in that it offers
protectiveness to human health and the environment, attains ARAR's,
and when compared against the alternatives in the Feasibility Study
which meet the threshold criteria, low temperature thermal
desorption can be implemented at a lower capital cost than ISV, on-
site thermal incineration and off-site thermal incineration. In
the event that the "back-up" or contingency alternative is
selected, the cost of ISV has been shown to be less than or equal
to the costs associated with partial excavation of the lagoon
followed by off-site incineration of the principal threat and
placement of the remaining contaminated materials into an on-site
RCRA landfill. The selected remedy is also less expensive than the
on-site incineration of all contaminated materials above the clean-
up level. Therefore, when compared to the alternatives presented
in the FS which meet Type B clean-up requirements, the selected
remedy is cost-effective.
4.
utilization of Permanent Solutions and Alternative Treatment
Technologie. or aesource aecovery Technologies to the Xaximum
Extent Practicable
The selected remedy provides the best balance with respect to the
nine evaluation criteria as set forth in the National Contingency
Plan. Treatment technologies are utilized to the maximum extent
practicable by either thermally treating the contaminated Site
media in order to drive off (i.e., volatilize) the contaminants of
concern followed by treatment of off-qases and aqueous streams and
off-site removal of contaminants ~ by vitrifying the entire mass
of contaminated materials, thereby leaving a glass-like,
impermeable monolithic structure which serves to encapsulate all
inorganic contaminants and any organic contaminants which may not
have been destroyed and removed during the vitrification process.
The selected alternative will achieve the health based clean-up
standard of 1. 6 ppm of MBOCA. This alternative is further balanced
with respect to the nine criteria because a permanent solution
which utilizes an innovative treatment technology (either low
temperature thermal desorption or ISV) is being selected. The
groundwater monitoring component of the selected remedial action
will assure that concentrations of contaminants do not increase
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5.
preterence tor Treatment aa a principal Bl..ent
The selected remedy eliminates the principal threat at the Site,
direct contact with and/or ingestion of contaminated sludge, soil
and clay by the use of treatment, via low temperature thermal
desorption or in~ vitrification, of the contaminated media, and
is in accord with the SARA preference for remedies usin9 treatment
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RESPONS:IVENESS SUMMARY
ANDBRSON DBVELOPKBN'1' COMPANY S:ITB
This Responsiveness Summary has been prepared to meet the
requirements of Sections 113(k) (2) (B) (iv) and 117(b) of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986 (CERCLA), which requires the United
States Environmental Protection Agency (U.S. EPA) to respond "...
to each of the significant comments, criticisms, and new data
submitted in written or oral presentations" on a Proposed Plan for
remedial action. This Responsiveness Summary addresses concerns
expressed by the public in the written and oral comments received
by U.S. EPA regarding the proposed revised remedy for the Anderson
Development Company ("ADC" or "Anderson") Site.
Public Comment Period
The United States Environmental Protection Agency (USEPA) recently
held a public comment period from August 28 through September 26,
1991, for interested parties to comment on the revised clean-up
plan for remediating contamination problems at the Anderson
Development Company site (ADC Site) in Adrian, Michigan. The
required public hearing on September 12, 1991, focused on the
results of a bench-scale treatability study for low temperature
thermal desorption as a means of remediating contaminated Site
soil, lagoon sludge and clay, and review of thermal desorption
processes. The public comment period was held in accordance with
Section 117 of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA) as amended.
The purpose of this Responsiveness Summary is to document USEPA's
responses to comments received during the public comment period.
These comments were considered prior to selection of the final
remedy for the Anderson Development Company Superfund Site, which
is detailed in amendment to the Record of Decision (ROD).
Community Involvement
U.S. EPA is responsible for conducting the community relations
program for this Site. A community relations program was
established for the site in 1986. It established a process for a
two-way flow of project information between local officials,
concerned citizens, the media, and U.S. EPA. Two information
repositories were established in the Adrian, Michigan local area:
at the Adrian City Hall, and at the Adrian Public Library. Several
different press releases and fact sheets were issued to inform the
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2
Community relations activities are summarized in the September 1990
ROD and the Community Relations Plan. All press releases, fact
sheets, and other documents prepared for this site are available
for review in the site administrative record, if additional
information is desired.
In July 1990, a public meeting was held in Adrian to d~scuss u.s.
EPA's proposed remedial alternative, in ~ vitrification (ISV)
for remediation of the ADC site. At that time, there was. much
public opposition to ISV. Major concerns raised by the community
centered around financial impacts to Anderson Development Company,
uncertainties regarding the effectiveness of ISV, and co~cerns
regarding the safety of ISV.
From the comments received during the recent public comment period
for the ROD amendment, there is strong community support for u.S.
EPA's proposed amendment to the 1990 ROD. The community is in
favor of low temperature thermal desorption. Some members of the
community continue to express opposition to in ~ vitrification
as the contingency remedial alternative.
Public Meetina
The required public hearing on the revised proposed clean-up plan
for the ADC Site was held from 7:00 p.m. to 8:15 p.m. on September
12 1991, in the City Council Chambers, Adrian City Hall in Adrian,
Michigan. Approximately 35 persons attended, including several.
local, county or federal officials or their representatives,
representatives of Anderson, and members of the local radio
stations. Representatives of USEPA and MDNR presented information
concerning low temperature th~rmal desorption treatment technology
and studies planned to be conducted at the Anderson Site, and
responded to questions from individuals attending the meeting. An
oral public comment period was held. A transcript of that public
meeting, including the oral public comment period, was prepared by
a court reporter in attendance. Copies of the transcript are
available at the Site information repositories.
Public Comments
Written Comments Received and ReSDonses
The following written public comments relate to the following
issues: 1. Community acceptance of low temperature thermal
desorption: 2. community support of u.S. EPA's decision to amend
the Record of Decision: 3. continued community opposition to ISV:
and 4. Economic attractiveness of low temperature thermal
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3
GORDON C. PHILBROCK: "... We strongly support this plan and urge
EPA to proceed as soon as possible. We are confident that this is
a safe and efficient method, at a reasonable cost, to treat the
soils at the site. However, we are still strongly apposed to the
use of In-situ Vitrification, even as a "back-up method". There
are too many unknown and hazards involved in this method."
DAVID R. SILER: "It remains my opinion that the EPA should abandon
the ISV approach to the Anderson Development Company Superfund site
remediation. The LTTD Approach recommended by Anderson is by far
the most logical and sure solution to the site problem. Please
revise the EPA position to permit the LTTD soil treatment."
EMORY M. SCHMIDT: "I am writing this letter to support the EPA
proposal to amend the record of decision for the Anderson
Development Company Superfund site.
... I understand that "low temperature. thermal desorption" is
proven safe and effective, and believe this technique is consistent
. with the best interests of the community and the environment, and
is economically reasonable."
ReSDonse: o.s. BPA acknowledges the commentors' support. The
safety and efficacy of low temperature thermal desorption will be
carefully evaluated during a fUll-scale on-Site test demonstration.
Sa.ed on data reviewed to date, o.s. BPA and KDHR are confident
that this technology will be effective in treating contaminated
Site .oils, sludge and clay. ADderson and it. contractor, Weston
services, Inc., presented cost estimate. which indicate this
technology can be implemented at a lower cost than ISV. Low
temperature thermal desorption technology is .arketed by several
vendors nationally. This technology has been utili.ed at other
superfund sites which were contaminated with various volatile and
semi-volatile organic compounds. Contaminated media at the
ADderson site contain a variety of volatile and semi-volatile
organic compounds in addition to .,.'-Xethylene bis(2-
chloroaniline)', i.e., BOCA. Bowever, after review of the process,
its'. air pollution control equipment and results of bench-scale
studies, the Aqencies believe the techDoloqy will meet all clean-up
and performance standards.
Regardinq the commentor's statement that there are UDkDOVDS and
hazards with ~espect to ISV, o.s. BPA believes that ISV still
offers potential for Superfund site remediation. ISV has been
tested approximately. ninety (90) times on a wide variety of waste
types at various scales. At least seven large scale tests have
been performed. Also, in the event low temperature thermal
desorption is determined by o.s. BPA, in consultation with MDHR, to
be unacceptable for clean-up at the ADC Site, it is anticipated
that ISV will be performed on a commercial scale for Superfund site
remediation before remedial operations at the ADderson site are
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According to the criteria u.ed by U.S. BPA to identify r..edial
tecbDologie. for Superfund .ite., ISV i. not an "experi.ental"
technoloqy. The experi.ental .tage of the proce.. ha. been
completed and ISV i. now con.idered an "iDDovative" tecbDology
available for u.e at superfund .ite..
congre.. ha. directed U.S. BPA to .eet certain .tatutory .andate.
for r..edy .election at superfund .ite.. The.e .andate. include
the preference. for treataent a. a principal element of the remedy,
and the utili.ation of permanent .olution. and alternative
treataent tecbDologie. to the .axi.us estent practicable. ISV i.
an alternative treataent, tecbDoloqy which provide. for a permanent
.olution. While ISV i. an emerging tecbDoloqy, it ha. undergone
esten.ive review by U.S. BPA, and data ha. been .ubmitted which
demon.trate. it. potential to .ucce.sfully treat contaminants
pre.ent at ADder.on. Bowever, an engineering-.cale treatability
study will be completed on actual contaminated .edia fro. the
, ADder.on site concurrent with the on-site thermal desorption te.t
demon.tration. The engineering-scale te.t will determine the
effectivene.. of IS V in treating XBOCA and other site contaminant.,
a. well a. determining the parameter. that provide for day~to-day
operation which .eet. the stringent performance and .afety
.tandard. of U.s. BPA and the state of Kichigan.
Regarding the u.e of iDDovative technologie., the preamble to the
IICP .tate., "... u.s. BPA .upport. .uch diversificatioD and expects
that it will generally be appropriate to inve.tigate r..edial
alternative. that u.e innovative tecbDologie. when .uch technology
offer. the potential for comparable or .uperior treatment
performance or impl..entability, fever or le..er adverse impacts
than other available approache., or lover cost. for .imilar levels
of performance than demon.trated technologie.."
WILLIAM J. ROSS: "... Approximately one and one-half years ago I
had the opportunity to participate in the public hearing held in
- Lenawee Country, regarding the cleanup process being recommended by
the EPA for Anderson Development Company. My comments were not
made from a technical point of view, but dealt with economic
feasibility and one of concern about the quality of life for
students and residents of Lenawee County.
Prior to the testimony and hearings, I drafted a letter dated
July 19, 1990 to the EPA outlining my concern about what was being
suggested by the EPA. Following the hearing I was dismayed at the
position that the EPA had taken regarding this cleanup issue for
the Anderson development Company. Needless to say, I was
pleasantly surprised when the EPA, after considerable input,
research and testing, reversed their decision and followed the
course being recommended by Anderson Development Company and
supported by myself and other residents of the Lenawee area. It
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5
reversed its decision, that the process now being recommended by
EPA is satisfactory to all parties concerned. It will, in fact,
provide the necessary and required cleanup and can be done at a
cost that can be handled by Anderson Development without materially
reducing its ability to continue as a viable economic entity in the
Lenawee County area. For this we are extremely grateful.
. .. The closing sentence of my July 19 letter said, "I
sincerely request that the Environmental Protection Agency
reconsider its proposed solution and work with Anderson offici.als
to find a mutually acceptable solution." It appears to me that the
EPA and Anderson have done just that and this problem is being
resolved to everyone's satisfaction."
ResDonse: u.s. BPA and KDHR have worked diliqently with ADderson
Development Company over the past year while evaluatinq both
ch..ioal ozidation and low temperature thermal desorption
teohnoloqies and their advantaqes and disadvantaqes with re.pect to
r..ediation of the ADC site. While the Aqencie. determined that
oh..ioal ozidation would not be a technically fea.ible aeans of
addressinq site contamination, we are oonfident. that 10w
t..perature thermal desorption will be successful durinq the on-
site test demonstration. If this technoloqy meet. all clean-up and
performance standards to the satisfaction of the Aqencies, it will
be impl..ented for full-scale site remediation.
DAVID B. MUNSON: "... We [Lenawee County Chamber of Commerce]
would like to thank EPA and the Michigan Department of Natural
Resources for listening to us and for sincerely considering the
public comments that you received. It speaks well for both
agencies that the community's voice was heard and that it had and
impact on your decision."
ReSDonse: u.s. BPA ackDoweledqes the co~~ent. The community's
concerns raised last year were carefully considered by u.s. BPA and
MDHR. .. are confident that, throuqh workinq closely with
ADderson, we have arrived at a solution which would effectively
addres. site contamination and be protective of human health and
the environment, would .eet all federal and state requirements,
result in 1... financial impacts to ADderson than would
impl...ntation of ISV, and which would be acceptable to the
community of Adrian.
An anonYmous written comment addressed the spill of the chemical
ortho-chloroaniline, toluene and zinc at the Anderson facility.
ResDonse:
The thermal desorption process is expected to effectively remove
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6
The questions raised by the author relating to other contaminants
and processes at the Anderson facility will be reviewed by U.S. EPA
as it evaluates these questions and will take appropriate follow-up
action, if warranted.
Oral Comments Received and ReSDonses
The following oral public comments relate to the following issues:
1. community acceptance of low temperature thermal desorption; 2.
Community support of u.S. EPA's decision to amend the Record of
Decision; 3. continued community opposition to ISV; and 4. Concerns
relating to damage to natural gas pipelines as a result of
implementing ISV at the ADC Site.
AL SMITH: "... The City did have some concerns about the previous
method that was being considered and the effect that it might have
on some of our utility lines. However, we have no problems with
the recommended system at this time, and we would support its use
in this project.
I also have a letter from Senator Jim BarrYman that he asked
me to read and put into the record tonight, 'I am writing to
express my support for the planned clean-up project on property
owned by Anderson Development Company...'."
RICHARD CANNON: "... I still oppose ISV, based on the merits that
it's not proven, in my opinion."
"... the Region 5 EPA should be [commended] in their ability
to work with business..."
STEVE FREEBORN: . "... I, also, still oppose the back-up position
[ISV] because it still seems to me it's an untested, unproven
method, but I do support LTTD and, as a citizen in this County,
very much look forward to the remediation of this site. I would
like to thank the EPA for listening to the public."
JACK GEORGAL:
"... I support the thermal desorption treatment..."
R.SDons.: o. S. BPA acoow1.dg.s the support of the communi ty.
R.garding the statem.nts that ISV ia unproven, r.f.r to the above
response. Discussion with Anderson D.velopment Company laat year
indicated that it would be f.asible to "tap into" high-powered
tranamission lines in c10ae proximity to the site. If this waa not
possible, another option would be to bring portable transformers to
the site during full-acal. application of ISV, although this would
result in increased costs to Anderson.
LARRY PARKINSON: "... I'm still concerned, as other people here,
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7
from what I've read of its recent failure, I think it was fortunate
it was not a catastrophe. Two, no one from the EPA, on the ISV
position, has addressed, to anyone's satisfaction, the danger of
the natural gas pipe lines in that area should you decide to revert
to your back-up position.
And I totally Oppose your back-up position. I don't think it
is a good method for this remediation because of the danger to the
natural gas pipe lines."
aeSDOn.e: Temperature. of 100 degree. C (212 degrees P) have ~een
.easured a. far a. five to seven. feet fro. the full-.cale I8V
treatment zone. The I8V .elt, as a rule of thumb, should thus not
~e located clo.er than 15 feet to underground utility lines and
.tructure. which could ~e damaged ~y temperatures ~ve 100 degrees
C. Bxamination of 8ite diagrams provided in the Remedial
Investigation Report does not indicate any ~ve ground .tructures
within 15 feet of the I8V treatment zone. Location of underground
utili tie. are not noted, ~ut there are not indications of
.tructure. which would likely have underground utilities running to ..
th- within 15 feet of the I8V treatment zone. The clo.est
pipeline on the 8ite, ~ased on .aps provided U.8. BPA ~y the local
ga. company, i. on the north .ide of the pre-treatment lagoon, .ore
than 150 feet away fro. the proposed processing area. Therefore,
underground natural ga. pipelines are of sufficient distance from
the 8ite that dangers to these lines (e.g., such as rupture) are
non-existent. The effects of high thermal gradients within close
proximity to the melt would have ~een negated well ~efore distances
of 150 feet from the melt. 80il temperatures near the gas
pipelines would remain at ~ient temperature, and s~sidence
effects would also not ~e seen at such distances, especially
considering the relatively small areal size of the melt.
Bxact locations of underground utilities (e.g., gas pipelines,
sewer. and water lines) will need to ~e determined during the
design phase.
Ho surrounding homes or ~usinesses are located within the likely
distance which might ~e affected ~y soil settling that will result
from I8V treatment. This matter vill need to be further examined
during the design phase.
U.8. BPA is aware of the failure of the Geosafe equipment at 1ts
test facility in Hanford, Washington earlier this year, which
resulted in compromise of the off-gas collection hood. While the
test involved non-hazardou8 material., the Agency i. aware of the
ramifications if a similar incident had taken place during clean-up
operations at a 8uperfund 8ite.
Geosafe i. carefully evaluating the situation, and following
conclusion of its' intensive investigation, the company will
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8
incident which re.ulted in an expul.ion of .olten qlas. froa the
.elt sone include .ov..ent of qa.e. and vapor. upward throuqh the
.elt ,one a. a function of .elt shape and properties of the aelt,
affect on aelt dynamic. of buried 4rua. within the aelt sone, .elt
dynaaic. as a function of .oil aoi.ture content and inten.ity of
the electrical field, etc. Geo.afe will look closely at these and
other factor. in it. att..pt to identify the condition., which lead
to tbe contact of aol ten qla.. onto the collection hood, and
.ub.equent iqnition of the bood.
A. a reault of the accident, Geo.afe ba. indefinitely .u.pended all
co_ercial full-.cale ISV operation.. A8 the coapany further
inve.tiqate. the rea.on. for the relea.e of tbe .olten qla.. fro.
the .elt sone, de.iqn of a new off-qa. bood ia underway. The hood
whicb baa been constructed of fiberqlas. (for ease of aoveaent
durinq full-scale operation.) will be con.tructed of a .aterial
which would be .ore re.i.tant to eztr..e t..perature.. Geosafe
e.ti.ate. that coapletion of the hood desiqn will occur .oaetiae in
late 1"2. until such tiae as the cau.al relationsbip between the
.elt condition. and qla.. ezpulsion are fully known, Geosafe will
. not be co_ercially via1>le. Geosafe will continue to perform
treatability te.tinq a. it is currently doinq for the ADC site.
Tbe re.ul t. of the enqineerinq-acale ISV test for the ADC Site
should be available in early 1"2.
u.s. BPA will continue to evaluate the potential for sit.
r..ediation via ISV on a site-by-site basi.. Factors such as
schedulinq of r..edial desiqn and reaedial action tasks,
contaainants of concern and site-specific hydroqeloqical
conditions, coaparitive costs of alternative clean-up options, and
evaluation of clean-up alternatives with respect to the evaluation
criteria specified in the Hational continqency Plan will be
con.idered by the Aqency. Soae superfund Site., by virtue of the
type. of contaainants found, aay not have any other suitable
treatment process other than ISV. POor such sites, it aay be
practicable to postpone r..ediation activities until such tia. as
Geosafe i. co_ercially active.
At the ADderson Developaent Coapany Site, however, u.S. EPA has
identified a proce.s which has a hiqh deqree of probability in
teras of .eetinq clean-up and perforaance standards. Therefore,
the Aqency will proceed forward with the low teaperature theraal
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1
FICHE/FRAME PAGES DATE
2
90/09/27
16
90/10/29
21
90/12/04
4
90/12/07
4
91/04/19
14
91/07/15
12
91/07/19
3
91/07/19
TITLE
Letter re: Review of
Record of Decision (ROD)
end In Situ Vltrificetlon
et Anderson Development
CDq)8ny
Review Comment. to
"Work Pie" to Conduct
e Bench Scele
Treetebillty Study for
Anderson Development
CDq)8ny Legoon"
(with cover letter)
Letter re: Review of
Low Temperature Thermel
Aeration Treatability
Study Report(attachment
tables and attachment of
letter from Brady Boyce
to Michael Valentino)
ADMINISTRATIVE RECORD INDEX.
UPDATE f3
ANDERSON DEVELOPMENT COMPANY SITE
ADRIAN, MICHIGAN
AUTHOR
Delbert Rector, MONR
Michael A. Valentino,
USEPA
Micheel A. Velentino,
USEPA
Letter re: J.P. Rupert,
Summerization of Anderson Development
understanding of the CDq)8ny
features of the ultimatum
offered to Anderson
Letter re: Approve I
of February 14, 1991
Proposel end Activities
Schedule
Technicel comments
on the dreft Remedial
Action Plan for LTTA
and comments regerding
the Heelth and Sef.ty
Plan
Repense to the EPA
Comments on Low
Tempereture Thermel
Aeration Bench-Scele
Treatability Study
Report
Letter re: Anderson
Michael A. Valentino,
USEPA
Brady W. Boyce, MONR
Canonie Environmental
James Huerta, Anderson
RECIPIENT
V. Adamkus, USEPA
J. Huerta, ADC
P.Rupert & J.
Huerta, ACC
DOCUMENT TYPE
DOCNUMBER
Correspondence
Correspondence
Correspondence
M. Velentino, USEPA Correspondence
J.P.Rupert&J.
Huerta, ADC
Correspondence
M. Valentino, USEPA Correspondence
M. Valentino, USEPA Correspondence
B. Boyce, MONR
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Page No. Z
081ZT/91
0 ADMINISTRATIVE RECORD INDEX
UPDA TE 13
ANDERSON DEVELOPMENT COMPANY SITE
0 ADRIAN, MICHIGAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUHBER
Deyelopment Superfund Deyelopment Co.
L.goon Water Disposal
59 91/07/19 USEPA end MONR Reyiew Michael A. Velentlno, J. Huerte, ADC Correspondence
Comments to Mey 1991 USEPA
Dreft Project Work
Plena for Lev
Temper.ture Tharmel
Aer.tlon (LTTA)
(lttechment)
2 91/08/07 Letter re: Aryid A. S.ther, Ms. Ot.k8 Correspondence
1~lementetlon Micheel Best end
of ISV testing Friedrich, Counsel for
Anderson De.yelopment Co.
t 91/08/08 Letter re: Proposal Tim Forden, Weston J. Huerta, ADC Correspondence
for the remedietion of Services, Inc:.
the Adrlen, Mlchl;en
sfte
Z 91/08/11 Letter re: Michael A. Velentlno, J. Huerta, ADC Correspondence
Reylew Comments on USEPA
NPre-Remedietion
Legoon Sludge end
Clay S~ling Plan"
and "Pre- Remedi et i on
Groundwater end Soil
S8q)llng Plen"
Z 89/11/00 'act Sheet Entitled: USEPA Faet Sheet
Innoyetlve Technololl\'
In-Situ Vitrification
6 90/09/00 'ect Sheet Entitled: USEPA Feet Sheet
"Questions and Answer,
about EPA's Final
Cleen-up Plen"
8 91/05/00 'ect Sheet Entitled: USEPA Fect Sheet
"Engineering Bulletin:
Thermal Desorption
Treatment"
4 90/08/09 Memo re: Technlcel Merk Meckes, USEPA M. Valentino, USEPA Memorendtin
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:>~q~ No. 4
38/27/91
ADMINISTRATIVE RECORD INDEX
UPDATE 13
ANDERSON DEVELOPMENT COMPANY SITE
ADRIAN, MICHIGAN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
7 88/08/00 Report Entitled: Roger K. Nielson and ReportsiStudies
low Temperature Thermal Michael G. Cosmos,
Treltment (lT3) of Weston Services, Inc.
Volatile Organic
Compounds from Soil:
A Technology Demonstrated
42 89/02/00 Report Entitled: K.H. Oms, M.A.H. Reimus Reports/Studies
Support for the In and C.L. Tinmermen,
Situ Vitrification BIUelle
Treltabillty Study at
the Idaho National
Engineering Llborltory:
FY 1988 SUllllllry
41 90/05/00 . Report Entitled: R.K. Flrnsworth, K.H. Reports/Studies
Inltill Tests on Oms Ind C.E. Bigelow,
In Situ Vitrification BIUelle .
using Electrode Feeding
Techniques
35 90/07/27 Report Entitled: James Huerta, Anderson M. Vllentino, USEPA Reports/Studies
Anderson Development Development Company
Company RI/FS Chemical
Oxidation Testing
(cover letter Ittached)
31 90/08/00 Report Entitled: U.S. Army Corps of Reports/Studi es
Position Paper on Engineers
low Temperature
Volatilization Systems
(L TVS)
54 90/09/00 Report Entitled: Canonle Environmental USEPA Reports/Studies
Treltability Study
Report Ind Remedial
Contracting Services
Proposal
29 91/01/00 Report Entitled: U.S. Army Corps of Reports/Stud i es
Cost Comparisons for Engineers
low Temperature
Volltilization Systems
(lTVS) at Four
Superfund Sites
17 91/04/08 Part III report for James Huerta, M. Valentino, USEPA Reports/Stud i es
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Page No.
08/27/91
5
fiCHE/FRAME PAGES DATE
11
91/07111
TITLE
January 24, 1991
(with FAX cover
sheet)
LT3 Process Description
ADMINISTRATIVE RECORD INDEX
UPDATE 13
ANDERSON DEVELOPMENT COMPANY SITE
ADRIAN, MICHIGAN
AUTHOR
DOCUMENT TYPE
DOCNUMBER
RECIPIENT
Co.
Weston Services Inc.
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