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Morrow Power Plant

All POL/SITREP's for this site Morrow Power Plant
Comstock Township, MI - EPA Region V
POLREP #4
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Morrow Power Plant - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V

Subject: POLREP #4
Morrow Power Plant
C5H3
Comstock Township, MI
Latitude: 42.2883837 Longitude: -85.4962873


To: Mark Johnson, ATSDR
Valincia Darby, Department of Interior
Bruce VanOtteren, MDEQ
Joe Walczak, MDEQ
Dan Wyant, MDEQ
Bill Schuette, Michigan Department of Attorney General
Rodney Stokes, Michigan DNR
Todd Goeks, NOAA
Marguerite Matera, NOAA
Wayne Babcock, U.S. Department of Interior
Lindy Nelson, U.S. DOI
Sam Borries, U.S. EPA
Yolanda Bouchee-Cureton, U.S. EPA
Mindy Clements, U.S. EPA
Jason El-Zein, U.S. EPA
Sherry Fielding, U.S. EPA
John Glover, U.S. EPA
Jennifer Manville, U.S. EPA
Thomas Marks, U.S. EPA
Carol Ropski, U.S. EPA
Annette Trowbridge, U.S. Fish & Wildlife
Michelle Watters, ATSDR
Nola Hicks, EPA
Linda Dykema, MDCH
Rob Alvarez, USCG AST
Jennifer Magro, MDEQ
Scott Thelan, MiOSHA
Anthony Casaletta, MiOSHA
Mike McNulty, ITC
Cheryl McIntyre, EPA
Michael Ortega, LEWIS REED & ALLEN P.C.

From: Jeffrey Kimble, OSC
Date: 11/5/2012
Reporting Period: 10/29 - 11/3/2012

1. Introduction
  1.1 Background
   
Site Number: C5H3    Contract Number:  
D.O. Number:      Action Memo Date: 9/19/2012
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 10/3/2012    Start Date: 10/4/2012
Demob Date:      Completion Date:  
CERCLIS ID: MIN000510761    RCRIS ID:
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:

1.1.1 Incident Category

Time-critical removal


1.1.2 Site Description

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

See Initial Polrep for information on site assessment history. 

Asbestos and other hazardous waste was found at the site in an abandonned nature.

2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

As a result of the referral and site investigation, the EPA OSC determined that a Time-critical removal action at this site was warranted.  EPA will conduct a cleanup to remove a large portion of the friable asbestos from the site building and will also remove and dispose of drums and smaller containers found to have waste in them.

Once the easily accessed asbestos has been removed, the building will be further stabilized and the remaining asbestos documented so that the information can be handed over to MDEQ and MiOSHA for further actions at the site.
 
The EPA action is to deal with the immediate threats only.

2.1.2 Response Actions to Date

On Monday, October 29th, 2012, the crew completed the 8th floor and began setup and removal of ACM from the 6th and 7th floors.  Approximately, 5 cubic yards of friable ACM were placed in an on-site 20yd roll-off.  Two cubic yards of non friable asbestos was collected from around the property.  One 20yd roll-off of ACM was transported to the landfill for proper disposal.  The USCG and contractors conducted air monitoring and sampling.

On Tuesday, October 30th, 2012, the crew continued cleanup of the 6th and 7th floors.  The oustide crew collected and disposed approximately 10 cubic yards of non friable ACM.  USCG did not conduct perimeter air monitoring due to rain.   

On Wednesday, October 31th, 2012, the crew continued clean up of the 6th and 7th floors.  The outside crew began cutting and bagging drums and containers for non hazardous disposall.  USCG did not conduct perimeter air monitoring due to rain.

On Thursday, November 1st, 2012, the crew completed gross cleanup on the 6th and 7th floor and began to wash the floors and building surfaces with clean water.  The crew began moving equipment and setup to the 4th and 5th floors.   Empty drums and containers were cut, bagged, and staged for disposal. A 20yd roll-off of non friable asbestos was picked up for disposal.  The USCG and contractors conducted air monitoring and sampling.

On Friday, November 2nd, 2012, the crew completed washing the 6th floor, and completed the setup of the 4th and 5th floor.  Approximately 5 cubic yards of ACM were removed and placed in a roll-off for disposal.  The outside crew completed collecting and disposing of non friable ACM from areas identified during previous EPA and State of Michigan investigations.  On Monday, November 5th, additional ERRS will mobilize to the Site to begin bulking waste streams for disposal. This will allow the asbestos crew to remain focused on that task. Empty totes and overpack drums were delivered to the Site for bulking liquid wastes.  The USCG and contractors conducted air monitoring and sampling.

On Saturday, November 3rd, 2012, the crew continued ACM removal on the 4th and 5th floors.  RCRA empty drums were crushed and staged for disposal.  The USCG and contractors conducted air monitoring and sampling.

No site work occurred on Sunday November 4th, 2012.  Off hours site security continued.

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

Ongoing.

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Disposal
Facility
 Friable Asbestos  solid  10 yards  001  Westside RDF
14094 M-60 West
Three Rivers, MI
 Friable Asbestos  solid  20 yards  002   Westside RDF
14094 M-60 West
Three Rivers, MI
 Friable Asbestos  solid  10 yards  003   Westside RDF
14094 M-60 West
Three Rivers, MI
 Friable Asbestos  solid  20 yards  004   Westside RDF
14094 M-60 West
Three Rivers, MI
 Friable Asbestos  solid  20 yards  005   Westside RDF
14094 M-60 West
Three Rivers, MI
 Friable Asbestos  solid   10 yards  006   Westside RDF
14094 M-60 West
Three Rivers, MI
 Friable Asbestos  solid   20 yards  007  Westside RDF
14094 M-60 West
Three Rivers, MI
 Non Friable Asbestos  solid   20 yards  008  Westside RDF
14094 M-60 West
Three Rivers, MI


  2.2 Planning Section
    2.2.1 Anticipated Activities

Collection of friable asbestos
Continue off site disposal of asbestos
Bulk waste streams for disposal
Collect bulk samples for waste stream lab analysis

2.2.1.1 Planned Response Activities

Remove friable asbestos from the on site building. 
Remove hazardous wastes from site.
Secure building to prevent access to remaining asbestos.

2.2.1.2 Next Steps

Continue cleanup.

2.2.2 Issues

The cold weather may impact the ability to finish the job site this year.  If winter weather halts work due to inability to "work wet", the site will have to be finished in the spring of 2013.  However, the OSC is pushing to try and finish the site before the end of the year if at all possible.

  2.3 Logistics Section
    ERRS:  3 trailers, 2 decon shower trailers, 3 generators, 5 trucks, 1 water truck, 1 storage pod.

EPA:  Haz cat trailer.

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    2.5.1 Safety Officer

OSC Jeff Kimble
ERRS Brooks Cooper

2.5.2 Liaison Officer

OSC

2.5.3 Information Officer

OSC

3. Participating Entities
  3.1 Unified Command

None, this is an EPA cleanup.


3.2 Cooperating Agencies

Michigan Department of Environmental Quality

Michigan Occupational Safety and Health Administration

4. Personnel On Site
  U.S EPA - 1
U.S. Coast Guard Strike Team - 4
ERRS - 12
START - 1

5. Definition of Terms
  ACM - asbestos containing materials
EPA - Environmental Protection Agency
ERRS - Emergency and Rapid Response Services
START - Superfund Technical Response and Assessment Team
Hazcatting - Hazard categorization, a testing method used to determine the general chemical class of an unknown compound

6. Additional sources of information
  6.1 Internet location of additional information/report

6.2 Reporting Schedule

Periodic, as determined by the OSC. At this point, Polreps will be issued weekly.

7. Situational Reference Materials
  No information available at this time.


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