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Midwest Metallurgical Laboratory

All POL/SITREP's for this site Midwest Metallurgical Laboratory
Marshall, MI - EPA Region V
POLREP #3
Removal Action Continues
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Midwest Metallurgical Laboratory - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V

Subject: POLREP #3
Removal Action Continues
Midwest Metallurgical Laboratory
BVTY
Marshall, MI
Latitude: 42.2944370 Longitude: -85.0037194


To: Carol Ropski, U.S. EPA

From: Jeffrey Lippert, On-Scene Coordinator
Tricia Edwards, On-Scene Coordinator
Date: 5/28/2010
Reporting Period: 5/24/10 - 5/28/10

1. Introduction
  1.1 Background
   
Site Number: B5TY    Contract Number:  
D.O. Number:      Action Memo Date: 4/6/2010
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 5/11/2010    Start Date: 5/11/2010
Demob Date:      Completion Date:  
CERCLIS ID: MIN000510419    RCRIS ID:
ERNS No.:    State Notification: MDNRE
FPN#:    Reimbursable Account #:

1.1.1 Incident Category
The site is categorized as a Time Critical Removal Action.

1.1.2 Site Description

The Site consists of a 25-acre industrial parcel bordered by 15 Mile Road and agricultural and residential properties to the west, vacant land to the north and east, and agricultural to the south.  The Site is the former location of Midwest Metallurgical Laboratory, a foundry for the Detroit Stoker Company. The Site includes one main building, an office area and two smaller out buildings.


1.1.2.1 Location

The Site is located at 15290 15 Mile Road in Marshall, Calhoun County, Michigan 49068 in a mixed residential/industrial/agricultural area.  Coordinates for the Site are 42.294437 degrees north and -85.0037194 degrees west.


1.1.2.2 Description of Threat
Several drums, totes, transformers, and other containers contained hazardous waste or potentially hazardous chemicals, including strong acids, ignitable liquids, waste oil, and waste liquids with hazardous concentrations of selenium. Many of the drums were in poor condition and were corroded or bulging. As described above, four liquid samples from Site drums, totes, and containers were identified as characteristically hazardous wastes. The buildings have been broken into and vandalized, and scrap metal from the property has been illegally salvaged by trespassers. Weathering and activity of trespassers could cause containers on-site to breach and the contents of the containers could thereby be released into the environment.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
The analytical results from four liquid samples containing acids indicated that the material is characterized as hazardous waste by corrosivity as defined in 40 CFR § 261.22. Corrosive wastes are considered characteristic hazardous wastes if they have a pH less than 2 or greater than 12.5 standard units (su). Analytical results showed that a sample collected from an unlabeled 250-gallon poly tote had a pH of 0.0 su.  Two other containers, an unlabeled 16-gallon poly drum and a “sulfuric acid”-labeled 1-gallon glass laboratory bottle also had a pH of 0.0 su.  Analytical results for another liquid sample collected from a 250-gallon poly tote labeled “Resin Binder” indicated it had a pH of 14.00 su.

In addition, TCLP results from a 250-gallon tote and 16-gallon poly drum showed concentrations of selenium that exceeded the Maximum Concentration of Contaminants for the Toxicity Characteristic as defined in 40 CFR § 261.24.

Soil samples collected from outside the building showed levels of arsenic above the State of Michigan’s Part 201 Generic Cleanup Criteria for Residential and Commercial I Direct Contact Exposure.  In an area where numerous large bags of “bag house dust” were dumped, the levels of arsenic in the soil were as high as 13 ppm.  This level is in exceedance of the State’s Direct Contact Level of 7.6 ppm.  The soil contamination is in close proximity to a deer bedding area.




2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

The Midwest Metallurgical Laboratory (MML) was founded in 1942. The casting/foundry building was constructed in 1960. The Site is a former ductile iron casting facility that provided complete foundry services, including Ni-Hard and Grey Iron castings from 1 to 900 pounds. In March 2002, the announcement was made that the MML facility was to be phased down and closed later that year as part of a plan to outsource production to lower cost producers. At the time of its closing, the MML facility employed approximately 65 workers.  Since the closing of the MML facility, Charleston Auctions has held several public auctions in an attempt to sell Site equipment and property.

 

U.S. EPA conducted an assessment at the Site on October 5 and 6, 2009.  Most buildings at the Site were found to contain uncontrolled hazardous wastes (containers labeled flammable, corrosive, and oxidizer).  Numerous drums, totes, and small containers of various sizes were found opened and unlabeled both inside the buildings and around the grounds.  U.S. EPA quantified more than 2,500 gallons of uncontrolled and unidentified liquid wastes on the property.  Five waste liquid samples were collected yielding pH results that are characteristically hazardous or TCLP levels that are characteristically toxic.

 

U.S. EPA documented unrestricted Site access in many areas and visual evidence of trespassing throughout the buildings and grounds.  Numerous locks have been cut and fencing has been taken down by trespassers, vandals, and thieves in efforts to gain access to the buildings and property.


2.1.2 Response Actions to Date

On Monday, 5/24/10 the following response actions were undertaken at the site by the ERRS contractors:

  • ERRS continued cutting up small plastic containers and totes in preparation for disposal utilizing Level C PPE. 
  • ERRS combined similar liquids from small containers into 5 gallon pails in preparation for final disposal utilizing Level C PPE.
  • EPA/START provided breathing zone air monitoring support during work actvities using a MulitRae PID to montior for volatile organic compounds (VOCs), carbon monoxide, hydrogen sulfide, lower explosive limit, and percent oxygen and for particulates using a personal data RAM (PDR) unit. 

On Tuesday, 5/25/10 the following response actions were undertaken at the site by the ERRS contractors:

  • Local news paper personnel from the Battle Creek Enquirer out of Battle Creek, MI were onsite today to document site activities and interview OSC Jeff Lippert and OSC Tricia Edwards about the site activities. 
  • ERRS continued cutting up small plastic containers and totes in preparation for disposal utilizing Level C PPE. 
  • ERRS combined similar liquids from small containers into 5 gallon pails in preparation for final disposal utilizing Level C PPE.
  • ERRS collected a 2 point composite floor dust/debris sample from the floor sweepings from Building 1 for hexavalent chromium. 
  • ERRS collected one waste solid sample from the baghouse area of the foundary sand/dust debris for TCLP RCRA 8 Metals. 
  • EPA/START provided breathing zone air monitoring support during work activities using a MulitRae PID to monitor for volatile organic compounds (VOCs), carbon monoxide, hydrogen sulfide, lower explosive limit, and percent oxygen and for particulates using a personal data RAM (PDR) unit. 

On Wednesday, 5/26/10 the following response actions were undertaken at the site by the ERRS contractors:

  • ERRS opened up the 4 silos on the site to evaluate the contents in each silo.  One silo was completely empty, two of the silo’s contained virgin foundry sand, and one silo contained a grey powder material  similar to Portland or granular bentonite. 
  • ERRS moved the pile of white virgin foundry sand in Building 1 to access the spent black foundary sand present behind the virgin foundary sand pile utilizing Level C PPE.  The spent foundry sand was placed in a visqueen lined 10 cubic yard roll-off box for later disposal. 
  • ERRS moved pallets of refractory products in preparation for final disposal activities. 
  • ERRS used a drum vacuum and removed approximately 360 gallons of oily gray to black liquid from the secondary containment structure located on the southeast side of Building 1.  Recovered liquids were placed in 55 gallons drums and labeled for proper disposal. 
  • EPA/START provided breathing zone air monitoring support during work activities using a MulitRae PID to monitor for VOCs, carbon monoxide, hydrogen sulfide, lower explosive limit, and percent oxygen and for particulates using a PDR unit.
  • EPA Section Chief, Beverly Kush was onsite to conduct a site inspection evaluation on behalf of the EPA. 

 On Thursday, 5/27/10 the following response actions were undertaken at the site by the ERRS contractors:

  • ERRS had an excavator delivered to the site today for use in excavation activities in the foundry sand bag area located on the hillside along the east side of the site.  ERRS cleared brush and small trees with the excavator in preparation for excavation activities. 
  • A 30 cubic yard roll-off contained crushed drums and small cut up poly plastic pieces was transported offsite to C and C Landfill located in Marshall, MI.  A new empty 30 cubic yard roll-off was also delivered to the site for continued disposal activities. 
  • ERRS boxed up all the previously collected light bulb rods in Building 1 in preparation for disposal utilizing Level C PPE. 
  • ERRS removed the orange to brown colored foundry sand/dust from the two bins located in the southeast side of Building 1 and placed the material in a lined 10 cubic yard roll-off box for disposal.  ERRS utilized Level C PPE during this task. 
  • EPA/START provided breathing zone air monitoring support during work activities using a MulitRae PID to monitor for VOCs, carbon monoxide, hydrogen sulfide, lower explosive limit, and percent oxygen and for particulates using a PDR unit.
  • The local news station (News 3) out of Kalamazoo, MI was onsite today to interview OSC Jeff Lippert about the site history and site activities. 

 On Friday, 5/28/10 the following response actions were undertaken at the site by the ERRS contractors:  

  • ERRS started foundry sand bag excavation activities on the east side of the property along the hillside at the site.   ERRS started this task in Level C PPE, and downgraded to Level D PPE after sufficient air monitoring data was collected to make the determination. 
  • ERRS loaded out 5 dump truck loads of foundry sand bag material and soil (approximately 75 tons) and the material was then transported to C and C Landfill in Marshall, MI for disposal. 
  • ERRS had two 10 cubic yard roll-offs that were full of foundry sand were transported to C and C Landfill in Marshall, MI for disposal.  Additionally, two empty 10 cubic yard roll-offs were also delivered to the site to continue disposal activities of the foundry sand material.  
  • EPA/START provided breathing zone air monitoring support during work activities using a MulitRae PID to monitor for VOCs, carbon monoxide, hydrogen sulfide, lower explosive limit, and percent oxygen and for particulates using a PDR unit utilizing Level B and Level C PPE.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

MML filed for Chapter 11 bankruptcy in the U.S. Bankruptcy Court for the Northern District of Indiana on July 12, 2006, Case No. 16857-02.  The case was converted to Chapter 7 on June 2, 2008.

Taxes for the 2004-2009 remain unpaid, and there are tax liens on the real property for tax years 2004-2008 totaling over $164,000.  IN addition on 2/2/2005, creditor Detroit Stoker Company recorded a judgment lien on the property in the amount of $354,000.  the Trustee put the property up for sale but offers were insufficient to satisfy the pending liens.

2.1.4 Progress Metrics
 

Waste Stream Medium Quantity Manifest # Treatment Disposal
 Bagged Foundry Sand and Soil  Solids/Soil  68.26 tons  MML-5 to MML-9  Landfill  C & C Landfill, Marshall, MI
           
           

 

 

 

 

 

 

 



  2.2 Planning Section
   
2.2.1 Anticipated Activities
Anticipated activities for the week of June 1, 2010 include:
  • Continued disposal of cut up small poly containers and crushed drums. 
2.2.1.1 Planned Response Activities
N/A

2.2.1.2 Next Steps
  • Disposal of the foundry sand from inside the building;
  • Disposal of foundry sand and;
  • Disposal of crushed drums and poly containers containers.
2.2.2 Issues
None.

  2.3 Logistics Section
    N/A

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    2.5.1 Safety Officer
John Behrens

2.6 Liaison Officer
None.

2.7 Information Officer


2.7.1 Public Information Officer
Mick Hans

2.7.2 Community Involvement Coordinator
None.

3. Participating Entities
  3.1 Unified Command
N/A

3.2 Cooperating Agencies
Township of Marshall Michigan
Michigan Department of Natural Resources and Environment
Calhoun County

4. Personnel On Site
  Jeff Lippert, U.S. EPA
Tricia Edwards, U.S. EPA
Keith Lesniak, U.S. EPA
John Behrens, Environmental Restoration, LLC
Rich Fellores, Environmental Restoration, LLC
Kellie Lippnet, Environmental Restoration, LLC
Jamie Robinson, Environmental Restoration, LLC
James Kalberer, Environmental Restoration, LLC
Keith Kidder, Weston Solutions

5. Definition of Terms
  U.S. EPA - United States Environmental Protection Agency
START - Superfund Technical Assessment and Response Team
ERRS - Emergency and Rapid Response Service
NCP - National Contingency Plan
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
RCRA - Resource Conservation and Recovery Act


6. Additional sources of information
  6.1 Internet location of additional information/report
None.

6.2 Reporting Schedule
PolReps will be issued weekly.

7. Situational Reference Materials
  NCP
CERCLA
RCRA