The Site is located at 6900 East Michigan Avenue in Comstock, Kalamazoo County, Michigan.  The Site’s geographic coordinates are 42°16’48.0” North latitude and 85°29’33.0” West longitude.  The Site is bordered to the north by an operational power plant, the Kalamazoo River, residential homes, and East Michigan Avenue; to the east by Morrow Lake; to the south by undeveloped land and some residential homes; and to the west by undeveloped land and some residential homes. The closest residential homes are located approximately 0.25 mile west of the Site and the closest body of water to the Site is Morrow Lake, approximately 110 feet directly east. 

The Site contains a single, estimated 10-story decommissioned power plant building located on a largely undeveloped, partially forested lot, with a network of dirt roads and work areas and several smaller shop buildings. Currently throughout the Site are numerous staged piles of debris, trailers, scrap metal, and heavy machinery and equipment.  Consumer’s Energy constructed this coal-burning power plant building in 1939. Consumer’s Energy closed this facility in the late 1980’s, and the property was later sold to private industry. Nordic Fuel Supply and their affiliates operated the plant until they closed in 1998. B&B Enterprises & Environmental, LLC (B&B) subsequently purchased the property from the State of Michigan in 1999.

Subsequent to that purchase, metal from inside the power plant building was salvaged for sale. In the process of salvaging metal from the facility, intact asbestos was disturbed which resulted in thousands of cubic yards of friable asbestos abandonned in the on site building.

1.1.2.1 Location

6900 East Michigan Avenue in Comstock, Kalamazoo County, Michigan

1.1.2.2 Description of Threat

Friable loose asbestos and approximately 100 55-gallon drums, and hundreds of smaller containers, of potentially hazardous wastes.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On May 17, 2012, the Michigan Occupational Safety and Health Admininstration (MIOSHA), supported by MDEQ, requested EPA's assistance in evaluating the site for any potential threats.

EPA performed a site assessment on July 3, 2012.  During the site assessment, EPA and its contractors conducted field sampling designed to identify, assess, and collect bulk samples of suspected ACM from inside and outside the power plant building.  Written and photographic documentation of site conditions were also recorded.

A Site Assessment Report was issued on July 27, 2012.  The following is documented in the Site Assessment Report:

Eight bulk samples and one surface soil sample were analyzed for asbestos in accordance with EPA Method 600/R-93/116, "Method for the Determination of Asbestos in Bulk Building materials," using polarized light microscopy.

Lab analysis indicated asbestos in all six bulk samples collected from inside the power plant building in the following in the following concentrations:

• Sample MPP-ASB-01: 15% chrysotile and 10% amosite asbestos
• Sample MPP-ASB-02: 10% chrysotile and 2% amosite asbestos
• Sample MPP-ASB-03: 15% chrysotile
• Sample MPP-ASB-04: 15% chrysotile and 3% amosite asbestos
• Sample MPP-ASB-05: 12% chrysotile and 2% amosite asbestos
• Sample MPP-ASB-06: 5% chrysotile and 2% amosite asbestos

Lab analysis indicated asbestos in all three samples collected outside the power plant building at the following concentrations:

• Sample MPP-ASB-07: 15% chrysotile asbestos
• Sample MPP-ASB-08: 20% chrysotile asbestos
• Sample MPP-S-01: less than 0.1% asbestos

Throughout the site, several areas contained drums and containers exposed to the weather and without secondary containment.

On Monday, October 15^th, 2012, the crew further improved the site from existing physical hazards and removed waste containers from inside the building and moved them to the staging pad.  This completed the staging of waste containers.  The containers will be sampled this week and testing will be done later for hazard categorization of the wastes.

On Tuesday, October 16^th, 2012, the crew continued to improve the safety of the site building work zone.  The second decontamination shower trailer was made operational.  The crew initiated asbestos removal from the building.  USCG and the contractors conducted particulate monitoring and sampling.  Monitoring and sampling will be conducted daily and adjusted as results deem appropriate.  Perimeter monitoring may be halted during times of inclement weather.

On Wednesday, October 17^th, 2012, the crew completed setup of the load out room and continued removing asbestos bags from the top floor of the building.  Eight cubic yard boxes were filled today.   USCG conducted perimeter air monitoring and provided health and safety oversight of removal activities.

On Thursday, October 18^th, 2012, the crew continued to remove and dispose of asbestos from the top floor into cubic yard boxes.  A total of 17 cubic yard boxes were filled and sealed for disposal.  U.S. EPA and START opened drums in Level-B and collected samples from drums which required the samples to be collected in Level B PPE.  All containers were screened and the remaining drums will be sampled for hazard categorization purposes by the crew.

On Friday, October 19^th, 2012, the crew filled and sealed 20 cubic yard boxes of asbestos with material from the top floor of the site building.  One enclosed roll-off containing 10 cubic yard boxes of asbestos  was picked up for disposal.  Perimeter air monitoring was not conducted due to heavy rains.  Fifty four soil samples from the exterior extent of contamination survey were shipped to an offsite laboratory for asbestos analysis.

On Saturday, October 20^th, 2012, the crew bagged and staged asbestos bags for removal from the building on Monday, October 22, 2012.  The crew completed sampling drums in Level-C for hazard categorization analysis.

No site work occurred on Sunday October 21, 2012.  Off hours site security continued.