EPA Region 5 Records Ctr.

223995

BUTZEL LONG GUST KLEIN & VAN

JOHN P WILLIAM!

• O * C 4 T M NLCIM

J PATHICM MAMTIM

JOHN • WIAVC*

GCO*OI H IIMN. jm

MAftK T MCLftON

DANlCl P MALONI

t O W A H Q o OOV.O

JUSTIN O

J A M C t I 1

OAVlD • CALlONtMAft fc M LC1OTTI

MiCHAK. J LAVO'I

A T T O H N t Y S A N D C O O N S C L L O M 9

r i R S T N A T I O N A L BUILDING

D E T R O I T , MICHIGAN

TtL tCOPiCR ( 3(3)

T E L E X eio ??

BIRMINGHAM or r iCE

-^ SUITE 2OO

3?27O T E L E G R A P H ROAD

BIRMINGHAM, MICHIGAN 4eoio

(30) Z">O ift i f t

T E L E C O P I E R ( 3 > 3 ) ?•.« « ^ 3 9

OAMItL • TUHfL

»U»AH CANlMO N

A L A N * LtviNK

DAHLINC M DOM

«CViM r O

«OBf •? C

C*HIV A 0«»ITTDAviO M oCHMANN JOSHUA A SHIN

NICHOLAS J «f*

MAHM MANflOU*

»O«l*T A VOONIN

*J MiCMAf L MUOC T

OtCAJV H rtLOMAN

OAViQ m T l tLMAM

JQMN W DUNHAM1

lUOIHI L MAHTHAROLDc cAreJINK O JOHNtT

MART PtAT

AMC* C LlTTtLL

ANOLO M •MAPlONlf L COHN

Ootro it Of f icoMarch 1, 1989

Ms. Fran AllansU.S. Env i ronmental Protect ion AgencyRegion VSouth Dearborn StreetChicago, Illinois 60604

Re: Sea Ray Boats, Inc,Metarnora Land f i l l

r Mr>. All ans :

Enclosed please find a copy of the "Investigation Report, U.S.Chemical Company, Review of Waste Management Transactions" preparedby Dr. Lawrence N. Halfen, as well as seven three-ring binderscontaining attachments to the report, copies of the MDNR records,ind other materials upon which trie Investigation Report is based.

Bri e f l y , these seven binders consist of the following:

Investigation report, Waste Management Transactions,Appendices (these are the materials actually referencedin the Investigation Report);

• - Manifest Key by Identification Numbers, Rook One of Two;

Mahi.fest Key by Identification Numbers, Rook Two of Two(these, two volumes contain the key to be used indeciphering' the rest of the materials) ;

Ms. Fran AllansMarch 1, 1989'Page 2

Manifest Documents 1980, 1981, 1982;

Manifest Records 1981 to 1987; .

RCRA Part B Permit File, U.S. Chemical Company;

U.S. Chemical Company, MID 006 523 385. •

You may recall our telephone discussion of September 27, 1988wherein we discussed the status of the PRP investigation in thiscase and our concerns regarding EPA's impending document review atU.S. • Chemical Company in' Roseville, Michigan. "During . thatdiscussion, you requested that we send you copies of the variousdocuments we acquired during our own investigation for your review,and also to provide a basis for cross-checking U.S. Chemical'srecords. We hope that the enclosed will' satfisfy your request, andwill aid EPA in expediting its PRP investigation.

We believe these data qualify as confidential as part of EPA'songoing investigation. We-urge you to treat them as confidentialuntil completion*of your PRP search so that uncooperative partieswill not be able to become'aware of and base their actions upon thedata.

Wq_ reiterate the request, made in our February 23, 1988neet iTigX.with you -and in subsequent • correspondence and telephonediscussi'ons, that EPA send §104 notices to the additional PRPs asindicated in the Investigation Report. Further, EPA still has notinterviewed or taken sta'tements from Russell Parrish and RobertBarton; we urge that this be done as soon as possible due to Mr.Parrish's advanced, age and Mr. Barton-'s poor state of health. The.importance of obtaining this evidence was first emphasized in' ameeting on September 18, 1986, between Jack Shumate on behalf ofSea Ray, Michael Grice on behalf of Chrysler, and T. LeverettMelson and Bob Whippo of EPA. We'are concerned that the Agency hasnot moved, in the intervening 2 1/2 years, to obtain and preservesuch important testimony.

Finally', please be reminded that we would like to sample thedrums which' will be excavated this spring in order to correlatetheir contents with what is known about U.S. Chemical. Althoughthis issue was raised in our September 27, 1988 conversation, wenever resolved the manner in which this would be accomplished. Asspring will soon be upon us, your attention to this matter wouldbe most appreciated.

Ms. Fran AllansMarch 1, 1989Page 3

\ If you have any questions or comments regarding the above,please do not hesitate to call.

Very truly yours,

BUTZEL LONG GUST KLEIN & VAN ZILE

Darlene DomanikDD/abEnclosures

cc: T. Leverett NelsonSeth PhillipsJack D, Shumate, Esq.'Henry G. Kolb, Esq.John A. Cronkhite, ,Esq.David L. Maurer, Esq^.

*U.S. CHEMICAL COMPANY29163 Calahan Street

Roseville, Michigan 48066

' REVIEW OF

WASTE MANAGEMENT TRANSACTIONS

Lawrence N. Halfen, Ph. D.ENVIRONMENTAL CONSULTATIONS, INC

Grand Rapldi, Michigan

INVESTIGATION REPORT

U.S. CHEMICAL COMPANY29163 Calahan Street

Roseville, Michigan 48066

REVIEW OF

WASTE MANAGEMENT TRANSACTIONS'

Based Upon

MDNR RECORDS

and

OTHER SOURCES

r Prepa-ed By:

Lawrence N. Halfen, Ph.D.ENVIRONMENTAL CONSULTATIONS, INC.6688 Forest Valley Drive, S.E.Grand Rapids, Michigan 49508

TABLE OF CONTENTS

& . INVESTIGATION* REPORT

U.S. CHEMICAL.COMPANYt

,• -f

EXECUTIVE SUMMARY

INTRODUCTION . '

Purpose

PRP Evaluations

Weighting of Information

SUMMARY OF CONCLUSIONS

U.S. CHEMICAL COMPANY SITE INVOLVEMENT

Background

Ford Motor Company

Chevrolet Motor Division Flint Assembly Plant

GMC Fisher Body PI ant.. No. 1, Flint, Michigan

Inmont Corporation

Disposal Considerations

Drum Inventory Disposal'

Manifest Usage

Regulatory Administration by the MDNR

Fiscal Considerations

U.S. Chemical Company RCRA Application

Chem-Met Services, Incorporated

U.S. Chemical Cdmpany Clients

1981

1982

2

4.

4•»

5

7

13

13

14

15

16

17

17

18

18

19

21

23

2A

25

25

26

• '. 1983 ' ;"-V • 27

1984* . , . 2 8

Chemical and Container Correlations . 29

Additional Information Regarding \).S. Chemical Company 32

Additional Details Regarding Metamora Landfill . 33

SUMMARY - 3 5

EXECUTIVE SUMMARY

T h i s D e p o r t d e m o n s t r a t e s that a number of U.S. Chemical Companycl ients selected U.S. Chemical Company merely -as a disposaT'contractor.These client companies should be considered PRP candidates for the MetamoraLandfi l l because of their s igni f icant business volume with U.S. ChemicalCompany, w h i c h rout inely used the Metamora Landfi l l for d isposal ofaccumulated drums of was tes . Many of the U.S. Chemical Company clientsused th ts con t rac to r , to p rocess and/pr d ispose of major volumes ofindustri al- wastes over a period of several years. During this same period,U.S. Chemical Company was repeatedly compelled by MDNR 'inspectors to sendthousands of drums of these accumulated waste*/ f-om their faci l i ty tod isposa l .

In format ion f"om past' employees of the Metamora Landfil l indicatesthat the Metamora Landf i l l accepted semi-truck loads of drummed industrialwaste f^om U.S. Chemical Company as late as 1979. These wastes includedpa in ts , s o l v e n t s , resins and sol ids from their recovery operations. In1978, U.S. Chemical Company described its wastes '-to the MDNR as paintres idues, so lven ts and resins. The U.S. Chemical Company RCRA applicationdescr ibed its was tes as chlorinated so lvents , paint thinness and mixedf lammable so lven ts . The MDNR has stated that ,the Metamora Landfill hasbeen contaminated by thlorinated hydrocarbons, paint th.irine^s, resins andpaint ^es idues. These findings were purportedl-^confjj'-med by the test pitac t i v i t y conducted by the MDNR in 1985.' ' • •

Bus iness and manifest records indicate that the fol lowing firms we'remajor c l i e n t s ( i .e. a long on-going re lat ionship at high "waste volume) ofU.S. Chemical Company and probably hadv the i r was tes regularly transportedto Metamo-a Landf i l l fo- d isposa l . Containers bearing their names wereal so found at the s i te .

Inmont CorporationGene ral E lect - ic Corporat ionFord Motor CompanyRed Spot Paint CompanyDiamond Shamrock Chemical Corporat ion '

Cons ider ing f irms that were major U.S. Chemical Company cl ients duringt h i s t ime , the- f o l l o w i n g a d d i t i o n a l f i rms appear to have con t r i bu tedheavi ly to the waste streams handled by U.S. Chemical Company and may wellhave had ma te r i a l s hauled to the Metamora Landf i l l on a regular bas is :

Ace Auto Body & Auto Body Supply CompanyAutomot ive Finishes Inc.AK'Z'O Coat ings of America

• BASFC-Mar ProductsGage ProductsGeneral Motors Corporat ion

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T

GP P las t icsSiebert-OxidermoStandard Detroit Paint CompanySterling PlasticsWhite Color Card CompanyWolverine Coil Coating Company

Spec i f i c and current add resses for these f i rms are ava i lab le Inappendices. *Many of these firms are also listed 1n the PRP Chart whichsubmitted by the«present PRPs to the US EPA on February 23, 1988.

thewas

In addition to the above-mentioned firms which are major arrdconsistent business partners wfth U.S. Chemical Company, manifest and wastetransaction records '-included in this report implicate an additional 220firms with the waste disposal activities of U.S. Chemical Company. Theirconsistent association with U.S. Chemical Company, although at lower wastevolumes, makes these firms su-spect as possible contributors to the MetamoraLand f i l l problem.

The cos'ts associated with.the disposal of the thousands of waste drumswhich were handled by U.S. Chemical Company provided it with the'1 fiscalincentive to locate landfills for the disposal of this material whichprovided the lowest possible disposal cost. Using a landfil-1 such asMetamora Landfill rather than sending the waste to a processing .operationli k e Chem-Met Services, Inc'. (until it absolutelyclosure of Metamora Landfill) certainly resulted inThe magnitude of these savings may have approacheddollafs for1each year that U.S. Chemical Company was

had to following ,;.-tJdisposal cost _ "\a quarter of a .mi'l lionable to send wastes to

Metamora Landfill rather than/' use Chem-Met Services, Inc.

This^U.S. Chemical Company disposal activity, which probably includessi g n i f i c a n t amounts of pass-through disposal services, without any type ofwaste processing, implicates the generator firms in the problems associatedwith the Metamora Landfill. Because-mariy of the generators were actuallyusing U.S. Chemical Company only as a waste transporter, this justifies theinclusion-of U.S. Chemical Company clients as potential PRPs at this site.

The US EPA must compel U.S. Chemical Company to make all of their pastfinancial and waste management records available for review by the agencywithout delay. Such delays increase the possibility of document loss"and/or destruction.- Th'ese waste management records, which served as .thebasis for client billi.ngs by U.S. Chemical Company} also serve to tie thoseclients to the Meta-mora Landfill by providing direct confirmation of thewaste disposal Relationships presented in this report.

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INTRODUCTION

T h i s report is the result of direct i investigations' and documentcollections from the files of the Michigan Department of Natural Resourceswhich deal with the waste management activities of U.S. Chemical Company ofRoseville, Michigan. This report is an attempt, to -enhance -ourunderstanding of the business activity of this company, during a time when-the Metamora Landfill was in operation, during the time when the''site wasbeing closed b'y MDNR enforcement actions and following the. closure of thatl a n d f i - 1 1 . Based upon the information which is presently available t.6-xme, 'Ihave- no "eason to believe that any factual statement] presented-in this

t is false. ' • .

Purpose

The purpose ofResponsible Pa-t iescontributions'as an indust 1

presents theresultedLandfi 1 1f i n d i n g sconvi neeu.s..should be

this Deport is to identify additional Potentially(PRPs") at the Metamora L a n d f i l l because of waste

to the site as a "esult of the use of U.S. Chemical Companyial waste disposal contractor by these companies. This reportfiles, statements, deliberations and conclusions which have

from a detailed examination of 'the relationship between Metamoraand U.S. Chemical Company (and its client-generators). Theconclusions and opinions presented in this report are intended tothe US EPA that there is an adequate 'basis fpr the belief that

Company and its clients are involved at' Metamora Landfill andincorporated into the Superfund Section 104(e) arid' notice letter

process as soon as pos-sible. The companies which u'sed U.S. ChemicalCompany as a disposal corftractor are ma'jor . potenti al contributors tbMetamora Landf iM and should be evaluated as PRPs for-th.is si,te.'

This report attempts to quantify the volume of business activity whichU.S. Chemic-al Company has done with various' generators over the years. Inaddi tion ,' attention is focused upon the wastes which' are produced by thisf i rm as a r e s uit Of the. recovery process which i't employs in itsoperations .<"-Compari ng business volume to plant capacity, it is evidentthat this company also acted 'as a .waste hauler for some of 'itsgenerator-clients, merely transporting wastes from ^hese generators to thel a n d f i l l site .of eventual disposal. . » " "

Investigations of the current U.S. .Chemical Company operation have•been undertaken -in the past months which have resu-lted in the generation ofdata pertaining to personnel and the methods' of handl ing. materials at theU.S. Chemical Company facility. The fi-m has al so prepared a RCRA Part 8application package which was obtained from* the 'MDNR. This informationis incorporated . into this report where it is deemed appropriate.Information derived from MDNR Act 64/136 inspection files for U.S. Chemlca.lCompany is also included in this' report. Interviews' w.1th operators ;andemployees of the Metamora Landfill as well as other knowledgeablei n d i v i d u a l s have also be used in the preparation of this report. •

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. I •*

PRP Evaluations. • "

A number oV) considerations have been drought into the process pf-identifying U.S.j/hemical Company arid i t s v c l ien ts as a Wajor factor 1n thepresent condition of Metamora'Landfill and, other si'tes in this area of the

.State of Michigan. TheJJ.Si 'Chemical Company operation is located 1n thesame area-of the state ws the'Metamora Landfill ,w>fhey had the equipment,and manpower to bring together an accumulation ofTwiste materials at their,site in Rosevil le. They produced a waste'stream which 'had "tb be removed"from that locattion^unde'r steady pressure from/regulatory authorities.* -Theyalso accepted volumes of wastes whidh exceeded theif processing' capacity.They had the ability, to move this waste material from their site in th.eirown fteet of trucks without the necessity -of involving other'Businessconcerns. MDNR records for 'the Act 136 program do not contain reports ofthe nature and scope of waste removal activities for U.S. Chttmical Companyas was required under'the regulations associated with Michigan Act 136 (TheLiquid Industrial. Waste Hau'lers Ac-t, Act 136'of the Public Acts to 1969).However, some companies which generated these wastes reported theset ransact ions and these report's are still on file with the MDNR. Thesewaste . removal Deports provide a partial picture of the volume and frequencyof w a s t e t ranspor t and produc t ion by U.S. Chemica l Company. These •documents were used to- develop a profile of this'reclaimer-processor as an-operation with a substant ial and consistent drum intake -which required,resolution in a cost-ef fect ive fashion throughlthe active recruitment oflandfil l operators to supply disposal sites. \ '

' [ }W i t h th i s background, I believe that i t - is reasonable to, consider acompany for PRP status at ' . the Metamora Landfill if jt had a sustainedbusiness connection with U.S. Chemical Company in th« 1960s and 1970s andpa r t i cu la r l y i f there were large vo lumes of was tes Ir tvolved 1n theset r a n s a c t i o n s . Those compan ies which sent mater ia ls to U.S. ChemicalCompany which clear ly could not be processed by 'the U.S. Chemical Company-ecovery system should also be, considered for PRP status. Here, U.S."''Chemical Company is acting only as a transporter of the wastes which isouts ide the l imitat ions of its operational permit in |ny event. <• U.S.Chemical Company had a c lear need for a drum disposal site which was ifl thelocal area, able to handle semi-truck loads of drums and outside the levelof general public visibil i ty until the manifest submission requirementbrought drum management into the open. At this po.int, U.S. ChemicalCompany began usihg Chem-Met' Services,'Inc. for'drum el iminatlon'at A co^stf i gu re wh ich was dec idedly "higher .than the cost, of typl.caj landfi'lldisposal . • *

There were manyThe majority of therecords f i led byMichigan Actsubmitted asFor purposes

W e i g h t i n g of In fo rmat ion

sources of information used to prepare this report,early information was obtained from waste remo.vaA

generators in an effort to comply w1tn the requlrements^fVs136. This is supplemented by manifest documents which were -required under newly applied waste management regulations.of th is study, these documents were taken at face value and

are considered to be reasonably accurate, where they are available. It Isunfortunate that they records did- not extend further back Into the .time of

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Metamora' Landf i 1 1 operation but they do provide a profile of the businessvolume o'f U.S. Chemical Company .near the end of the Metamora Landfilloperational period, and thereafter^ -The submissions of Chem-Met Services,Inc. are also a'ssumed to be accurate, in terms of the beginning of abusiness relationship ̂ with U.S. 'Chemical Company at a sensitive period intime. " , , A

Documentation submitted by U/5T~"'iChemical Company as- part of its- RCRAcompliance program is also taken as relatively accurate since the veracityof these submissions, is subject to inspection . and verification untie" thepermitting process. Int a- similar fashion, the representation,* made on theearly MDNR -inspection reports are probably an acceptable transcription ofthe actions, di scussions "and circumstances which existed at that time atthe sites in question. The MDNR inspection staff- may not hav,e been able toobserve and evaluate every aspect of the U.S., Chemical Company operation,but I am "easonably certain that the figures for drum numbe-s mentionedrepetitively in MDNR Deports from that time period a^e quite close to.reality. • • .j • • . . • /

To the extent that there is chemical 'da.ta a v a i l a b l e in the documentsprovided by gene-ato-s and/or U.S.. Chemical Company, 'I have no "eason to.argue that these data are not Representative of the niaterials which we^eincorporated into the process! ng 'feed stocks of the -U.SC Chemical Companyoperation at that time.'. It should be n.oted, however, that there would be •no value in conducting analytical procedures upon Waste, materials whichwere clearly . unacceptable ^for processing and only accepted for directdisposal. Analytical .data for these pass-through wastes were not found andwene probably never generated- in the first place.

Information derive'd -from interviews must be evaluated "bore carefully.The -^presentations of Russell Pa.rrish impress me as being relatively"straight- forward and free of evasion. This, elde-ly. man has separatedhimself from the operations of the, Metamo-ra. Landfill by retirement,.' Kis-tfnput, while largely consistent with' the statements of others, -^uf fers.Jrom 'the erosion of mempry ove". the passage of time in sensitive areas. such: asidentifying people involved -in the U'.S. Chemical Company transactions, ".rtisson, Eugene Parrish, has provided information in interviews which is notconsistent with statements made.by other l a n d f i l l employees and others whohave knowledge of the site operations. Consequently, careful considerationneeds to be given-to the quality of interview information. - • - . - .

.It is j nteresting to .note the tone of communications originating fromU.S. Chemical Company which consistently represent its operation, in the afavorable way. Correspondence in the MDNR enforcement files available tome at the-' Np'rthvil le of.fice indicates that there have been environmentalviolations 'and compliance problems at the. U.S. Chemical Company 'facil ity inRoseville.

Waste removal recordsand attached to this reportinterviews, submissions andappended in, this fashion.

and -MDNR manifest records have been, tabulatedof appendices. Records ofas a series

other relevant documents have also been

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S '' SUMMARY Of;" CONCLUSIONS'

In my p -o fess iona l judgment, was tes wh ich • were produced and/o-.sccepted by U.S. Chemical Company we-e 'deposited in the Metamo-a Landf i l ldu- ing the pe-iod of the l a te 1960s and ea-ly 1970s. These wastes .weref.rece ived f-om a la-ge numbe- of subs tan t ia l industrial 'co.ncerns wh ich havema in ta ined long-s tanding bus iness -e l a t i onsh ips wi th U.S. Chemical^Company.The -eco-ds and documents w h i c h fo-m the b a s i s f o r ' t h i s report c lean ly• i nd i ca te the f o l l o w i n g : • •

1. U .S . Ch.emical Company generated m a s s i v e quant i t ies of paint and .s o ] v e n t - " e , l a t e d w a s t e s . w h i c h had to1 be sent fo r d i s p o s a l in 'at i m e l y :nanne- at othe- s i t e s not fa- from. R o s e v i l l e , Michigan,.

2. Cons' ide-able. amounts of tms ma'te-ial w'e-e a v a i l a b l e for d i sposa lin the l a t e 1960s and f lu- ing the 1970s when Metamo ra L a n d f i l l wasopen . .

? . C o s t s f o - secu-e w a s t e d i s p o s a l we-e c o n s i d e - a b l e p-esent ing th is( i -m w j t h " a d e f i n i t e Economic i n c e n t i v e to 'use inexpens i ve ,

, j v a i l a o l e s i t e s fo - d isc-a-d- ing w a s t e m a t e r i a l s such as Metamo-a. a n d f i l l , B e - l i n S Fa- -o and G S H Indus t - i a l F i l l Company.

•- . The c n e m i s t - y uf toe w a s t e s p-oduced hy U . S . Chemica l Company is •c o n s i s t e n t w i t n t h e i n i t i a l B i n d i n g s f o - w a s t e s f o u n d a t t h eMetamo-a L a n d f i 1 1 . - . '

•. . 'he nj:;ies of . suve-a l J . c j . C h e m i c a l Company c l i e n t s inatch> the namesjn c o n t a i n e - s e x c a v a t e d a t the Metamo-a L a n d f i l l ir>-'!'986.

• . :5ast e-np1. oyees ot Metjmo-j ^ a n d f i l l state that tne l a n d f i l l was.ice ept i ng d-jms jf waste -jp u n t i * the t):ne that the s i t e was closed:. / t;ie MONK i n 1979, ' • . < • ' • •

'. !'' I j» ."> , J.S. C h e m i c a l Company sta;t.ed to use- Chem-Met '^e-v.'ic., 'o- (J'-sposa!' s'e-vices which continued fo- seve-al yea-s andi n v o l v e d thousands' of d-.ums of paint and sol vent--e1ated wastes .

•- . 'J . S . C h e m i c a l Company has at least 240 cifstome-s inc.ljding some oftne la-gest indust-ies in M i c h i g a n and Ohio. _ .

"* . j.S. Ch e m i c a l Company has co n s i s t e n t l y op*?-ate-.l w i t h a m i n i m u ml e v e l of sens.itivity as fa- as -epo-'t;ng cind environmentalc o m p l i a n c e ba'sed upon'agency Mies.

\'j. T h i s -epo-t - d i s p l a y s seve-al p o i n t s whe-e the-e a-e s i g n i f i c a n ti n c o n s i s t e n c i e s between the -ep-es'entat i ons of Lugene Pa--ish andothe-s -ega-ding the Metamo-a Landf. i l l . \

'1. A d d i t i o n a l PR p c a n d i d a t e s fo- t h i s s i t e have r>pen i d e n t i f i e d who

\

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r

need to be brought into this matter. This is doubly justifiedbecause a considerable fraction of the wastes ,.which U.S. ChemicalCompany accepted from their clients could neve" h'ave been .processedah-the Roseville site. A close examination of the U.S. ChemicalCompany records as well as sworn depositions of key figures in thismatter are needed. This includes owners, employees and.generatorrepresentatives.

12. The industrial operations identified by this records review 'includethe following: ;.

A b i t i b i CorporationAce Body & Automotive Supply CompanyAction Oldsmobile Company

^ Advanced Custom Paints Company ; :Advanced Friction Metals CompanyAdvanced Medical i Research Center,AFCO IndustriesAKZO Coatings of America * •A & L F i n i s h i n g CompanyAlbar IndustriesS. M. Al Idn Company. ,A l l e n Ford\ CompanyA l l e n Park • Col 1 "i sion CompanyA l l i e d F i l m Laboratories • •Alma Plastics Company 'American Can;CompanyAmerican JetW-ay Corporation ..

• ' A P Parts Company 'Argo Paint CompanyArmada Products CompanyArmstrong Buick-Opel CompanyAtech Chemical Co-atings CompanyAuger Auto Body &. C o l l i s i o n ShopAuto Body Color, IncorporatedAuto C raft, Inco.rpprat.edAutometric Collision CompanyAutomotive Finishes, IncorporatedAutomotive Molding CompanyAzzow Brothers Collision CompanyB a l l Metal Container £roupBarnum & Tenney Body ShopBASF •Bendix Corporation

t ' Bernard Engraving CompanyB i l 1 Cook Buick Company '. • ^Bob Dusseau, Incorporated

• Borden Chemica.l Cpmpany•' Boroughs Corporation , •Bors't Lincoln-Mercury Company

IncorporatedBruce C o l l i s i o n CompanyBundy Tubing CompanyBushing, IncorporatedCabaron Auto Body ShopC a d i l l a c Enameling Works, IncorporatedCad Met, IncorporatedCast Fo^e CompanyC h a r l i e Brown's C o l l i s i o n ShopClark Bothers Metal Fabricators, IncorporatedC-Mar Products, Incorporated . .,C l e v i t e Industries, IncorporatedConstruction Testing i Inspection CompanyContainer Specialties, IncorporatedContinental Fiber Drum, IncorporatedContinuous F i n i s h i n g , "IncorporatedContzmev Specialties, -Dayton Di v i s i o nCoon -Brothe-s AMC CompanyCourier IncorporatedCousins Waste Control CorporationCrown Conk i Seal CompanyDan Scenga Chevrolet-Oldsmobile Company'Dawes Paint CompanyDealers Auto C o l l i s i o n CompanyDe-Sta-Co D i v i s i o n of Dover CorporationDetroit-Edison CompanyDick Scott Buick CompanyDiversified Glass Products., IncorporatedDossenfiel Glass Products,% IncorporatedEagle Trailer, IncorporatedFa ton CorporationElectroplating Service CompanyEnamalum CorporationEppinge r Manufacturing Company^ pEuneka Body ShopE-uropean C o l l i s i o n Company •Everfresh Juice CompanyP. Ess Sheet Metal Fabricators CompanyExotic Rubbe^ 4 Plasttcs CompanyEx-Cello CorporationExtrusion Painting CompanyFisher B u i c k , IncorporatedFlorkey's Conveye' Service, IncorporatedFord Motor CompanyFramecrest, IncorporatedFrank .A. Wilson CompanyFrankel Metal CompanyFrank's C o l l i s i o n Company -Fruehauf Co-rporationGage Products

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Gagl iano Auto Craft CompanyGene Hamilton Chevrolet CompanyGeneral Cable CorporationGeneral Elect r icGeneral Motor's Corporation

'George P. Johnson,CompanyGMF Robotics CompanyGoodfe l low Finishing', IncorporatedQorno Ford Company • '.GP P las t i cs Company

Industries, IncorporatedRobot ics, ' Incorporated

Greenf ie ld Custom Auto Serv iceGr i l les , Incorporated »Grow Gnoup, IncorporatedGTE Valeni te CorporationJ. B. Har- is C o l l i s i o n , IncorporatedHen"y Ford HospitalHe r i tage C o l l i s i o n Company AHibar Industr ies, IncorporatedHilton Paint ing S Sa les CompanyHoover Un iversa l CompanyHosle r Pon t iac CompanyHowmet Turbine Components Corpora t ionHuron Tool & Manufactur ing CompanyInmont Corpora t ionInternal Grinding and Ab ras i ves CompanyInt.e rnational W a s t e Management Corporat ionJack Dykstra Ford CompanyJe'-'-y's Horseless Car- iage CompanyJ i m ' s Col 1i s i on ShopJim Mui r CompanyJim Robb ins .CompanyK a i s e r A l um inum & Chemica l Co'rpo rat ionKay Screen Point ing CompanyK e l f o r d C o l l i s i o n , Incorporated<i"schne- K o l j i s i o n S e r v i c e .K r ug Lincoln-Mercury Company<ux Manu fac tu - i ng CompanyLampus Ford Company •Lea- S ieg ler Corpora t ion .Len Indust - fes, IncorporatedL ivon ia Chrysler-Plymouth, IncorporatedMac-0-Lac Paint C'ompanyManufacturers Enamel ing Corpora t ionMar ine Po l lu t ion Confol Corporat ionMa"k Wayne Motors Company

.Master C o l l i s i o n CompanyMayco P l a s t i c s , Incorporated

-10-

Mel Farr Ford CompanyMercury Paint CompanyMetal Craft CompanyMet-L-Aid, IncorporatedMichlin Chemical CorporationMicro Gear X Machining Company-Micro Paint CompanyMiller's Custom Bumping & Paint ShopMirrex, IncorporatedModern Hard Chrome Service Compan.yModern Materials CorporationMonroe Auto Equipment CompanyMorgan's Collision CompanyMorrow Collision CompanyMotor City Collision CompanyMurray Sandblast & Paint CompanyNorthern Auto Parts CompanyNTN Bower CompanyNumatics, IncorporatedOlsonite CorporationOwens-Illinois, IncorporatedPage Toyota, IncorporatedPainter Supply CompanyPaint Work, IncorporatedPar Kut International CorporationP h i l l i o d Cabinet CompanyPhoto Crafts/ IncorporatedPlating Specialties, IncorporatedPoweMine, IncorporatedPrecision Coating, IncorporatedPrecision Systems, Incorporated.Prefinished Metals CompanyProgressive Tool CompanyProto Crafts, IncorporatedPYC Davis Graphics CompanyRademacher Chevrolet CompanyRed Spot Paint CompanyRegency Oldsmobile Body ShopRitter Custom Collision CompanyRoger Rinke Cadillac CompanyRoyal Lincoln-Mercury Body ShopSalco CorporationSa-an Protective Coating CompanySawicki 4 Sons, IncorporatedScherer-Thompson, Incorporated 'Schober Pointing CompanySeaway Motors CompanySelastomer CompanyShaheen Oldsmobile Body ShopShelby Graphics Company

-11-

Siebert-Oxidenmo, IncorporatedSinclair & Valent ine, IncorporatedSki Noise Control CompanySomerset Pontiac CompanySOS Mechanical , IncorporatedSperry V ickers Corporat ionSp i r atex CompanyStandard Detroit Paint CompanyStar tc-Hickey W e s t , IncorporatedSt. C la i ' r Metal Products CompanySteal ing P las t i cs Company y

Sto ry O ldsmob i l e Body Shop *S tow-Dav i s Furniture CompanyStr ieker Paint P-oducts CompanySt roh .Container CompanySuburban Oldsmobi le CompanySupe r ior Buick CompanySupe r io r Coach CompanyTay lo r Auto Paint , CompanyTernes Supply CompanyToledo CommutatO" 'CompanyToledo Paint & Chemical CompanyTom Holze r CompanyTom ft Je^y Co l l i s i on CompanyT^y Col 1 i si.on Se-v iceT"oy Motors, IncorporatedUnion Carb ide Corpora t ionUni roya l , IncorporatedUnited Pa in t and Chemica l CompanyUnited Steel &. Wi^ CompanyUniversal Engineer ing CompanyUn i ted 'S ta tes Gypsum CompanyU.S. Chemical CompanyVacumet F in ish ing , IncorporatedV a l e c r e s t Corpora t ionValeron Corporat ionVenture Industr iesVylente l Buick CompanyWalbro CorporationW a l c o n Corporat ionW a l l e d Lake Co l l i s ion CompanyW a r d ' s C o l l i s i o n , IncorporatedWestborn C o l l i s i o n CompanyWhi te Color Card CompanyW o l f Detroi t Envelope CompanyW o l v e r i n e Aluminum CompanyWo lve r i ne Coi l Coat ing CompanyW o l v e r i n e Nut CompanyWood Motors Corporat ionWyandot te Paint Company *•

•V

-12-

At present, it is impossible to determine what involvement, If any,these firms may have had in the Metamora Landfill problem. However, In myjudgment, many of these companies will have some'type of records in theirfiles which defi'ne their business associations with U'.S. Chemical CompanyWhich should be obtained through the use of a. Superfund. Section 104(e)letter. Some of the detail obtained will certainly pertain to the timeperiod wh'en the Metamora Landfill" was in operation. In addition,--U.S.Chemical Company should be required to immediately produce their entireexisting business and operational Accords for this period. The US EPAshould obtain testimony from the owners, executives and employees p'f. U..S.Chemical Company with emphasis upon fiscal and waste management activitiesusing the full authority of CERCLA to*assure compliance. Delays will'favorthe loss of valuable documents and/or testimony thus, allowing many PRPcandidates to avoid liability for th'e Metamora Landfill. It is remarkablethat the file for this CERCLA site' does not contain a complete responsefrom U.S. Chemical Company to the June 20, 1985 information request andnotification letter sent by the U.S EPA. . ... .

U.S. CHEMICAL COMPANY .SlfE INVOLVEMENT

Background

An interview conducted with Mr. Russel l Parrlsh, the owner of thesit.e, d isc losed that U.S. Chemical Company used the Metamora Landfill as adisposal si.te for a period of at least two years during the early .1970s(See Appendix 1). U.S. Chemical Company was described as bringing.drums ofwaste materfaT" to the landfi l l in van- semi-trailers and unloading thesedrums in.to spec i f i c areas of the la/idfill wh ich 'were subsequently coveredw i t h s o i l . Mr. Eugene Par r i sn , who succeeded his father as the s i teoper^to" in 1974, s t a t e d in his in te rv iews that he did n o t . a l l o w thefurtrer d isposa l of drums at the s i te once he had responsibility for s i te 'opera t ions (See Appendix 2). This statement conf l ic ts with the statementsof otne- landf i11 employees (See Appendix 3). During this same period inthe e a ~ ] y 1970s, U.S, ChemicaJ Company held thousands of drums in a verylarge inventory of drummed processing wastes and non-usable materials whichwere eventua l ly eliminated.

W79,During the period of- 1969 through^ £979, the regulations,, associatedwith Michigan Act 136 (Th'e Liquid Industrial Waste Haulers Act) requiredthat the^e be Deporting of waste removal transactions, by all concerns thatheld.a license under the act. -These reports, called Waste Removal Records,were to be filed with the MDNR on a month'iy basis. U.S. Chemical Companyneld this license but there are no Waste Removal Records on file for thisfi'Tn. Waste Removal Record documents were required under this program.Thei" license number was 102 but there was nothing found in the reportingf i l e held by Lar-y Elmleaf of the MDNR under this number. MDNR enforcementof this license, "requirement was not at a very high level at the beginningof this program so that those records which do exist are largely voluntarysubmissions which were frequently made by the generators of the waste.

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Ford Motor Company\

These MDNR f i les, 'suppl ied by generators, contained ent-ies whichindicated that U.S. Chemical Company was very active in hauling industrialliquid wastes during this period in time. These records are not completeand most of the records were missing for the e'arly years of the program,however, the"e were suff ic ient records from the period of 1977 to 1980 toi nd i ca te that Ford p l a n t s were major c l ien ts ' tha t used U.S. Chemica lCompany -egula^ly. For example, U.S. -Chemical 'Company did a considerableamount of business with the Ford Motor Company operations in Mount Clemens,Michigan. The '•eco^ds of this assoc iat ion are tabulated in Appendix 4.These "ecords were submitted by For?d'and indicate that the business volumefor th is plant was at the fo l low ing leve ls for the yea-s in question:

1977 1,148,000 ga l lons ( so l ven t ) .224 bulk shipments

1978 957,200 ga l lons (so lvent )187 bulk shipments

.1979 531,700. gal lons ( so l ven t )110 bulk shipments •

1980 (January) I» 49,100 ga l lons ( so l ven t ) •* '

11 bulk shipments

The 1979 numbers a n e low in par t b e c a u s e there wene seven sh ipments^ecorded fo" which a volume- of waste was not provided. The.1980 numbersstop in Janua-y because the old reporting system was scrapped when the newmani fes t ^equiCements were inst i tuted to manage hazardous waste along with-liquid industr ial was tes . It should be noted that the Ford Motor Companyplant on 'Mound Road in Ut ica, Michigan, a lso sent approximately 13,000ga l lons of so lvent to U.S. Chemical Company in Decembe-, 1979, The Fordv i n y l p l a n t in Mt . C l e m e n s a l s o sent a p p r o x i m a t e ] y 49,000 ga l lons o fs o l v e n t to U.S, Chemical Company, largejy in 1979, as Deported in anotherFord "ecord neld by the MDNR.

U.S. C h e m i c a l . C o m p a n y has submitted a RCRA Part B permit appl icat ionwhich is on f i le w i th the MDNR. In'this document, the f-iin Indicates that1

the non -vo la t i l e so l ids range for their processing feed stock is frorn 5 to30%. This document a lso conta ins a page which deta i ls the nature of thewas te which was generated at the Ford Motor Company paint plant in MountClemens. These documents are attached as Appendix 5. This Waste ProductSurvey Form, c lear ly indicates' that approximately 20% of the wastes broughtinto the recove r y opera t ion from this source we re so l ids. I f theassumption is made that 55 gal lon drums were used to store and ship thesesoli-ds fo l lowing processing, the numbers of drums of solid, ignitlblewastes which would have been vproduced f"om processing this source for theyears in quest ion would be:

-14-

r

1977

1978

1979

1980

4175 drums

3480 drums

1933 drums

179 drums

The residues f"om the Utica plant, assuming the same solids content, wouldhave -esulted'in an additional 47 drums. -The vinyl, plant would add anadditional 178 drums to the accumulation. If these materials were to bemoved with a van trailer sized according to the regulations of the times,approximately 125 f u l l loads of drums would have had to be shipped out ofthe U.S. Chemical Company processing facility in this three year period toeliminate this accumulation of processing wastes f"om this one company./ Atotal of almost 10,000 drums of processing wastes would have been producedf-om servicing only the Ford Motor Company ove- tbese three years. Theprocessing of the Ford material did not appea^to bunch up at any point inthe yea:" suggesting that there had to be approximately three and one halffuck loads of Ford-related drums removed from the site every month as a"esult of this account. This would correspond to a generation frequency ofapp-oximately 280 drums pen month.

Chevrolet Motor-Division Fl int'Assembly Plant

Anothe" generator which was active during- this period of time was theChevrolet Motor Division Flint Assembly Plant of General MotorsCorporation. The waste stream reco-ds which were found in the documentswhich we-e supplied by this source described the wastes as "paint" whichwas sent to U.S. Chemical Company for -eclamation. The transactions wereas follows:

1977 157,600 gallons (paint)30 bulk shi pments

1978 330,000 gallons (paint)55 bulk shipments

1979 .250,000 gallons (paint)42 bulk shipments

The General Motors operation also shipped a 4400 gallon load1977. The tabulation of these shipments is found in Appendix 6.

of oil in

If the assumption i.s made that approximately 15% of this-material issolids (a figure which is in the middle of the. range of solids found intypical wastes according to the RCRA Part B application submission) thefollowing accumulations of S5 gallon drums of solid processing wastes wouldhave been produced from processing only this waste stream:

-15- •*-

1977 430 drums

1978

1979

900̂ drum's

682 drums

This is a total of about 2,000 drums or approximately 56 drums per monthwhich represents almost an additional truck load of drums of solid wastewhich would have to be sent for disposal each month.

*

GMC Fisher Body Plant No. 1, Flint, Michigan/

• A n o t h e r source of w a s t e products for the U.S. Chemical Companyoperat ion was the General Motors Corporation Fisher Body Plant Number 1 inFlint, Michigan. The materftl received from this installation, was termed"solvents". The business volume which occurred in these transactions wasas f o l l o w s :

1977 33,610 gal lons (so lvent ) .10 bulk shipments

1978 20,400 gallons (so lvent )6 bulk shipments

1979 35,200 gal lons (so lvent )9 bulk shipments

»1980 4180 gallons (solvent)

1 bulk shipment

A g a i n , applying the 15% sol'idsfollowing waste volume estimates:

conversion factor, resulted in the

1977

1978

•1979

1980

92 drums

56 drums

96 drums

12 drums

This is a total of 256 drums which originated from processing this wastestream. This would add an additional 7 drums -per month to the volume ofwastes which had to be removed from the U.S. Chemical Company plant InRoseville. The tabulation of the business activity associated with' thiswaste stream is found in Appendix 7.

» r>These limited records derived from servicing waste streams from these

-16-

th"ee accounts indicate that approximately 12,200 drums of solid wasteswere produced at this- site over the three ye'ars in question. Approximately340 drums would have--to be removed as a "esult of this activity, eachmonth. These calculations do not include the other clients which werese-viced by this company but for which no records were provided to the MDNRby either the generator or U.S. Chemical Company. Better records becameavailable thereafter when waste volume reporting was finally enforced 1n1980' with tfie implementation of hazardous waste regulations and manifest

"ements.

Inmont,Corporation .

The MDNR "eco'-ds also indicate that U.S. Chemical" Comp-any received ashipment of used lacqueV thi'inne-. f^om Inmont Corporation in November,, 1979,which was transported in a bulk load of 4180 gallons by Americhem. Usingthe same solids content assumption of 15% employed above", this load, wouldhave cheated an additional 11 drums of waste for disposal.. This tabulationis found in Appendix 3.

Disposal Considerations

In an interview at the home of Mr. Russell Parrish in Florida, he-stated that a representative of U.S. Chemical Company originallyestablished a business arrangement with Metamora Landfill prior to 1974 inwhich drums of waste were to be trucked to this si.te (See Appendix 1).This U.S. Chem'ical Company representative, thought by Mr.. Parrish to be tjieowner of U.S. Chemical Company, indicated t-hat the wastes brought to the'Metamora site were the residuals of the ^covery process for paint andsolvent from industrial sources such •rt''%:oTd Motor Company and GeneralMoto^ Corporation. These wastes were represented to be safe for disposalU,this site but subsequently -esulted' in two fi^es which -equired officialattention to control. Following the closure, o.f the Metamora site in 1979,any U.S. Chemical Company disposal plans which .involved Metamora Landfillrequi^d an acceptable alternative di-sposal site i f. the wastes continued tobe produced and/or accepted. _It was during this period of time that therewas the appeanance of shipments of drums of waste' materials from U.S.Chemical Company to Chem-Met Services, Inc.-, in Wyandotte, Michigan. Thisi n i t i a t i o n of activity was sported in Chem-Met Services, Inc. processing-epo-ts't,o the MDNR. This disposal facility was in a position to acceptthe. type of wastes which we-e generated by U.S.-Chemical Company f-om theirso l v e n t recovery operations a l b e i t at what _had to be a considerableincrease in price over the cost of disposal at' a simple landfill such asthe Metamora L a n d f i l l . -The volumes involved were considerable as indicatedoy the data found in Appendix 9. Furthermore, the numbers involved are inline with the volumes of drummed wastes which U.S. Chemical Company had tonave a v a i l a b l e for disposal at the time. Four months1 of business activitynear the end of 1979 involved .a total of 26§8" drums of waste which were.directly "elated to the ^cove^y of usab.le product from paint, thinner and.

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solvent. The representations of Mr. Parrlsh and the records of Chem-MetServices Inc. are consistent with my belief t.hat U.S. Chemical Company hada continuing need for a drum disposal site for' pass-through-wastes andprocessing residues. The business history of O.S. Chemical Company'shouldbe examined by the US EPA to' determine if there was a significant priceincrease for U.S. Chemical Company services during this time period whichrefl.ec.ts- the increased costs resulting* from using Chem-Met Services',' Inc.rather than the Metamora Landfill.

rum Inventory.Disposal . . ' • t.

.The creation of this Inventory of waste as a result of reclamationoperations (as well as continui-ng pressure from the MDNR site inspectionsto be considered later) 'required this firm to. continually consider methods.of disposing of this material off site. As previously noted for 1979,Chem-Met Servioes, Inc. was one vendor used .for this purpose. The MDNRrecords for '1979 also -include waste removal • records for U.S. Chemical,.Company which we^e submitted by Great Lakes Environmental Services, Inc'.These -ecords indicate that U.S. Chemical Company "shipped still bpttpms andpaint sludges via this licensed transporter to Chem-Met Services, Inc. in afashion similar to previous Chem-Met Services, Inc. "ecords. .However, U.S.Chemical Company also shipped wastes" to -Tricil, Ltd., -for disposal .byincineration. In . these records, a total of 39,.000 gallons of waste wassent to T r i c i l , Ltd., over a three month period with an additional 12,1300g a l l o n s .going to Chem-Met Services, Inc. Assuming that there- was arecovery factor of 85% from processing this waste, this disposal volumecorresponds to the processing of. 340,000 gallons of recoverable material.

It is .interesting to note that the Tric'il, Ltd.," facility was equippeddt that time with -an in'ci-nerator which had a burner capable of handlingpumpable l i q u i d s only. High solids wastes, normal ly.would not have, beensent in tanke" loads in the first place and protxably would not have beenacceptable at the Tri'ciJ , Ltd. operation. The tabulation of this activityis found in Appendix 10. Here the records may Indicate that U.:S. ChemicalCompany was s t i l l f n t h e business of handling pass-through wastes forclients. Otherwise, the^e is no reason why an appropriate liquid materialshould be sent for incineration when it cou'Td have been recovered 1nRosevi M e - w i t h i n the. limits of the pperational permit held by th;1s ffnm. .

"f •. • '

Mani fest Usage ' .* . - « ' •

The i n i t i a t i o n of the manifesf^system in 1380 resulted in existing-ecords and documentation of waste hauling/processing "activity fileddirectly by U.S. Chemical Company.. These Deports'indicate that the wastesproduced by .this firm were being managed' by Chem-Met Services, Inc., whichrepresents a continuation of the practice from the end of-1979. During thelast quarter :of 4980, U.S. Chemical Company sent a total .of 162,360 gallonsof waste to Chem-Met Services, Inc. which corresponds to 2952 drums of

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r

M '•'was te . This waste wRs.sent in 37 shipments over a three month period priorto the end of the year. .The wastes were described as "solids"'or else theywe^e a s s i g n e d wastew numbers of F003 or F005. The tabulat ion o'fHhlsa c t i v i t y is found i'n Appendix 11, Over this three month perigd, theaverage number of drums snipped'was about 980 which is consistent with thenumbe-s shipped during* thte last months of 1979 as previously indicated*byrecords f-om Chem-Met Services, Inc. ' During this same perigd, V i c ' s WasteOil Service was used to transport wastewater to Chem-~Met Services, Inc.from U.-S. Chemical Company. A total of six loads sized at 1500 gal.lo'nswere involved in the last quarter of 1980.. The origin of this wastewateris not l isted but may have resulted from water atcumulation in the U.S.Chemical Company drum storage containment which would explain why. i't wasnot discharged to the sewer. This relationship with V i c ' s .Waste OilService was maintained for a number of years with reference to ' th is .type of;shipment in many reports submitted to the MDNR. . • •

Regulatory Administrat ion by the MDNR•

The MDNR "ecords of s i te inspect ions which are maintained at theNo r thv i11e Dis t r ic t O f f i ce provide the. fo l lowing information regarding theU.S. Chemical operat ions: . ', ' '

1. As of 12/23/69, Leonard Corac i in formed the Water Resources. Commission that his firm re-refined and re-processed paint thinners

and solvents for resale and reuse. • •*•

2. This firm used Liquid1 Disposal Incorporated for wastes which" could" n o t be processed at 'that time. This al.so suggests that the firm

may have accepted- wastes which could not be processed by their.equipment.

3. S i n c e that, time, this company has been ^involved with th'e fol lowingdisposal fac i l i t ies in an effort, to elimiriate wastes ; byinc inerat ion or f ixa t ion: '' .

Liqu-id Disposal Incorporated „ . "' . . . 0The-mal Conve-sion CompanyBerlin S Far^o * .Hartley .& Hartley ' - . .Robert Ross & SonsTricil , Ltd. . •Michigan Recovery Systems, Inc.Systems Technology Corporation . •Chemi'cal. Recovery Systems, Inc. -Chem-Met Services, Inc. . it • ' •Petro-Chem Processing, Inc.

4. On-8/24/76, - Mr. Coraci indicated an interest in landfllling process,wastes as part of a conversation with Mr. Tom Leep of the MDNRduring a s i t e inspection in Rosevi l le .

-19-

I

5. M-. Greenway advised the MDNR in an Apri) 3, 1978 letter that thewaste generated by U.S. Chemical Company consisted of paintpigments, calcium ca'rbmate ( s i c ) , carbon b lack, -aluminum sj l icate,ch\o~ ides , resins and ni trocel 1-u.lose* In addition, ' so l ven tresidues included ketones, a lcohols , 'hydrocarbons and aceta-tes.•••

6. It .was the understanding of the MDNR in 197-8 that mater ia ls coiningto U..S. Chemical Company were sent so. the fl-m could dorec lamat ion at .their fac i l i ty in R o s e v i l i e and send the "ecove red'product back to the point of origin. No wa.s'tes-we-e co l lec ted fordisposal a t another site. ' • • ' . - ' . * . ' . .

7. The storage of drums at the Rqsev i l le s i te in the spring of 1974resul ted -in ,an .enforcement order aga ins t . the fi-m because therewe-re more than 6500 drums on s i t e . T h i s was to r esu l t in theremoval of 465 drums pe" month over a period of 16 months. Many ofth'ese drums we re in poor condi t ion. • •

3 . v l n the sp r ing of 1977, compl iance inspect ions revealed the presenceof .approx imate ly 7000 drums on the s i t e in inadequate -storage.This ' •esul ted in a direct ive from the MDNR that these mater ia ls beremoved f^om the s i te under a schedule which was to be submitted.byU.S. Chemical Company. " ' - • . • .

9. -M-. Jim MilJ-er inspected the fac i l i ty for the MDNR on 11/29/77. -.Atthat t ime, there were an ^estimated 8000 d.njms on the site. 'Oncea g a i n , U.S. Chemical Company was directed to el iminate the drumsfr.om the s i te and maintain.a level of no-mo-e than 2000 d rums.

10. Another inspect ion was made by Jim Mil ler on 12/13/77. ' At thist ime he was informed that the faci l i ty processed approximately320,000 gallons^of industrial 'wastes per month. Of this waste,220,000 gallons was received in' bulk shipments. An. additional100,000 gal lons was- received in drums. This represents'about 1800

„ drums pen month. Of this volume, approximately. 200,DOO. gal Ions was'. - ;shipped back' to the w a s t e . source. The d i f ference which ts 120,000. 'gal lons pe" month would Acquire app roximate ly 2200' drums if all of

th is residue wejre contained i n - th i s fash ion . '

.* 11. The c a p a c i t y of the f a c i l i t y ' t o - ecove r -so lven ts f rom w a s t e'• m a t e r i a l s - w a s , a p p r o x i m a t e l y 7000. gal 1 orvs per day accord ing to

.statements found in U.S. EPA reporting documents. At a rate of320,000 gal lons p.er month; the firm would require arTadditional 16days each mortth to complete the monthly intake o f . w a s t e mater ialsassuming that th'ey worked seven days per week without breakdowns.

12. An inspection on 8/10/78 by Tom Leep of the MDNR revealed*thatthere were approximately 3700 drums on the site. Between 'Decanber,1977 and August, 1978,., approximately 4300 drums were eliminatedfrom the inventory on this si te while the company conducted its

-2d-

" e g u l a " b u s i n e s s a c t i v i t i e s . T h i s - e p - e s e n t s t h e d i s p o s a l o f -approx imate ly 540 druins pe" month, above and beyond the number ofd"ums nonna 1 ly; generated to s a t i s f y the "equ'i "ements o'f cu" rentbusiness ' . •

13.V, . . — ~^

.The U.S. Chemical Company Waste Analys i S' PI an -which was p-part of the RCRA Pa^t B a p p l i c a t i o n submission l i s t s themajor constituents in thef i - in: ' • *

v a r i o u s w a s t e sfeams

epa^ed asf o l l o w i n g

'lanagod' hy. ' the

:001 T " i c n l o"oethyl eneMethy lene 'Chl.o"ide1 , 1 , l -T ' - i ch l o-oetn-ane

- 003

Methyl ene C h l o ' i d oT-i ctil o^oe thy lene.1 , 1 , 1-T" i ch l o-~oet lUni>

•Metnyl I s o L v j C y l v.'toni.1

n-Buty l A l c o h o lMethano l

'001

Metnyl E tny 1 , -Isobut*nol

'a imnan le MMOO '.oi v e n t s4

) ' ' . ' i ' s i n f o r m a t i o n i n d i c a t e s t h a t ' J . j . . i n e m i c . a l Company had ai tent p r o b l e m w i t h \^"- jm i nven to r y w h i c h was r e ( j j ] d - ] y the sub jec t o f.11 t e n t i on. 'he / o l ' j ues of- w a s t e brought i n t o tni? f a c i l i t y d'ea^lyi t e s t n a t -'any of the d^ns w h i c h ha-] to be e l i m i n a t e d were f u l l o f

i ng w a s t e s o~ w a s t e s w n i c n were never sub jec t t o p r o c e s s i n g by U . S . .i ' . C o m p a n y . T h » > c a p a c i t y t o p r o c e s s a l l t h e w a s t e s - w h i c h w e - eo s i m p l y was not a v a - i l a o ' i e jn - s i t e . Howeve ' , b r ing ing in w a s t e s '< t j re c o u l j n o t b e p r o c e s s e d ( b j t w e ' e ac .cept -ed f o r d i s p o s a l a t

s i t e . , was ' in c o n t r a d i c t i o n to tne cond1. l ions w h i c h t h e _ M D N R app l i ed, '1e o p e r a t i o n , joc^ments w h i c h suppo"'. the s ta temen ts made in th islave been c o l l e c t e d in Appena i< 12.

i sca-1 Cons i d e ^ a t i ons

'ne e l i i i nna t ion ot the d,"umst ^ a n s p o - t a t ion w h i c h was a v a i l a b l e in•jumpany fucks and d n i v e - S . D i s p o s d l *

f-om th isthe fo rm of

in the n r i d d l e n d

s i t e w o u l d ' -equinean e x i s t i n g f leet of

l a te - 1970s at the

-21-

r a c i h t i e s outl ined above (assuming that they we re in ope-ation) would 'have-eqj i "eo payments of about $20 to $30 pe- drum. If the figure of $25 isused fon c a l c u l a t i o n purposes, the e l im ina t ion of 1000 d"ums per monthwould "equine funding at the $25,000 level wi th an annual cost of $300,000.The .$25 rpe," d r um c o s t is c o n f i r m e d by U. S. ' Chemi ca l Company in t he i r -c l o s u r e pliin e s t i m a t e s wh i ch we^e submit ted as part of their RCRA Part Ba p p l i c a t i o n . I f an . a l t e r n a t i v e s i t e cou ld be developed which might takethese d rums -at d c o s t - of $5 pe r d rum, the .yearly cost sav ings would be5 2 4 0 , 0 0 0 pe r y e a - .o r app -^ox ima t e l y $20 ,000 per month." For every vansemi-f,j j l e " load of d"ums wh ich cou ld be e l im ina ted in this way, the firm• v o u l d be a b l e t o s a v e d p p ^ o x i i q a t e"l.y ' a p p r o x i m a t e l y $1600 w h i l e s t i l l^ " D v i d i n g the d i sposa l s i t e ope^ato" wi th a $400 payment. The d isposa l 's i t e ope"dto r a c c e p t i n g approx imate ly two loads of drums per week could!oo< fo-"wa"d to income of at l eas t $3200 pe r month whi le the inventory ofJ . S . Chemica l Company would be -educed by -at least 640 drums-which wouldnot h a v e to be h 'and led-by the mo"e expens i ve a l ternat ives. Over a threeyea" l ime pi.v"iod, tne l a n d f i l l ope"ato r would have been paid in excess of$60,000 w h i l e d- ispos 'a l c o s t s fo r U.S. Chemical Company would" be cut by

S / ? U , 0 0 0 wnen. compd"ed • wi th t h e ' e x c l u s i v e use of Chem-Met Se rv i ces ,

- 1 i m i n a t i o n • of d"ums at minimal cost ' during", this time period made. ' d n j f 1 1 ! i ng t h i ? s e w a s t e s the method of cho ice . There were many landfi l l

: a n d i d d t e s fo " t h e s e <l"ums in o p e - a t i o n . a t t ha t t ime under minimum~'-"Jj 1 jt i on. Fo r e x a m p l e , Append ix 13 d i s p l a y s addi t ional fac i l i t ies in theiniinej: ice a"ea of the Metdmora L a n d f i l l wh ich wene a v a i l a b l e at one time o"jno t / i e " to. accep t was tes fo r d i s p o s a l . ' Af least fou" of these areas have:>econe e n v i r o n m e n t a l problems whtch have ~-esul ted.- in the inclusion of theses i t e s ' i the l i s t i n g o f M ich igan S i t e s o f Env i -onmenta l •Con tamina t ion in•9.-vS. 'no c n e m i c a l con taminan ts "epo"ted at these s i t es a"e s imi la r to the'y ;^?^ j * w a s t e s w h i c h w o u l d h a v e been ' jeherated^ a t t h e U . S . Chemica l

:ne Me:w 11 n i n;pnt."jcd t the

'i ".apee" C o u n t y , the . Tho"nv f 1 1 e L a n d f i l l and the Sp"ingb"Qok Farm'; ' j"'.' two d'idi 11 on.jl d i s p o s a l s i t e s w i t h i n a ve"y sho"t d i s t a n c e of

' i ^ a n n f H l w n i c o we"e a lso a v a i l a b l e . These s i t e s were we l l" a n g e ' o f the U . S . C h e m i c a l C&mpany fucks (as w e l l as other

' w h i c h d l s D fave led as fa'" ds Swa'" t^ Creek to deal w i t h w a s t e sin ,<5 rd""o o p e " 3 t i o n whix:h is an' ad_di t ionj l 45 m i l es beyond

R e v i e w of MDNR "eco"ds has not p-oduced any documents wh ich ind ica tee x a c t l y w'he"e t'he t h o u s a n d s of d"ums of process i ng - w a s t e s arv'd o the"n a t e - i d l s we"e sent t h a t we",e commonly in inventp"y at the U .S . Chemica.lCompany 's i te au"inij the 1960s and 1970s. Howeve", a f te r the man'ifest.^sys ten went into p lac 'e , t h i s fi"1!! st.i"ted to send those containers by the4 \thousanos to Cnem-Met S e r v i c e s , Inc. Based upon statements by Russelis^-^

-22-

Pa- ' - ish, Nancy Par ish and Robe r t 8a r ton (and p^ior to the constraints ofm a n i f e s t -epo^t ing) , U.S. Chemica l Company 'made regular -use of landfiltd i s p o s a l at the Metamor-a L a n d f i l l for ful l drums of processing wastes 'ando t h e ~ w a s t e s w h i c h we"e p r o b a b l y a c c e p t e d - only f o r t r anspo r t withoutprocessing in Rosev i ' l le . Th is s i t e was used along with several, others toreceive drums of waste which were eliminated from'the, U.S. Chemical Company-i n v e n t o r y a t m i n i m a l c o s t . W r . R u s s e l l Pa r r i sh has ind ica ted in h i sin te rv i ew that a. r ep -esen ta t i ve of U.S. Chemica l Company ac t ive ly -soughthim out to e s t a b l i s h e x a c t l y t h i s - type of business relat ionship for thed i s p o s a l of indust - ia l w a s t e s f--om Gene-al Motors and Ford Motor Company(See Append ix 1). .* . t

— . , . ^ .

'J.S. >hemi.c.al Company RCRA App l i ca t i on ,

T h e - R C R A Pa-t B a p p l i c a t i o n wh ich was submitted by th is f i~m,on August1, 1983, i n d i c a t e d that the ;ope-at-ion processed the fo l low ing wastes on anannual b a s i s ( See Appendix 1 Q ) : ''

F001

F002

F003

FOOb

FQ04

0001

400,000 poundsApproximately 50,000 gallons

400,000 poundsApproximately 50,,000 gallons

9,000,000 poundsApproximately 1,184,000 gallons

9,000,000 poundsA p p r o x i m a t e l y 1 ,184,000 gal 1ons

Not L i s t e d

Not L i s t e d

T h i . s a r i t h m e t i c i s i n t e r e s t i n g s i n c e t h i s d i s c l o s u r e i nd i ca tes that U.S.C n e m i c a l Company was h a n d l i n g app rox ima te l y 206,000 ga.llons o f w a s t e per.nontn in 1983. Y e t , dur ing ttie inspec t ion by M r. Jim Mil ler on December13, 1 9 7 7 , the s i t e rep0r- ted A business volume of wastes at a level of3 2 0 , 0 0 0 g a l l o n s p.e~ mon th . The R C R A Pa r t B a p p l i c a t i o n i n f o r m a t i o n" e p r e s e n t s a w a s t e p r o c e s s i n g v o 1 u m e ~ r e d u c t i o n w h i c h w o u l d p l a c e t h ef a c i l i t y w i t h i n the des ign capac i . ty .o f thei r re c ]a m a t ion equipment to dealw i t n the. m a t e r i a l s which wene being brought into the plant. A volume of206,000 g a l l o n s cou ld be processed in approximate ly 30 days of continuous.ope ra t i on . T h i s p rocess ing volume Deduct ion happened during the timeper iod when i t , w a s increasingly d i f f i cu l t to sh ip drums of waste withoutm a n i f e s t s - and othe r R C R A / A c t 64 documentation. The question remains as towhat was the f a t e of the add i t i ona l 120,000 ga l l ons per month in 1977? Thef a c i l i t y did not have ' the capabi l i ty to p rocess all of this material sincethey r e p 0 r ted a c a p a c i t y l i m i t of 7000 g a l l o n s per 'day in their 1980Hazardous W a s t e Permit App l i ca t ion . Some w a s t e s must have been accepted

-23-

with the clear understanding that there would be no capacity or capabilitya v a i l a b l e - at this site to process them. This wpuld have been a d i s t i n c tvariance from the conditions under which the MDNR expected them to operatein 1977.

Chem-Met Services, Incorporated

U.S. Chemical Company continued to use Chem-Met Services, inc. fo.r thed i s p o s a l of F series waste d u r i n g 1981. A t o t a l of 121 sniprments ofbarrels-were made to this I S O - s i t e i n v o l v i n g approximately 523,000 gallonsof material in approximately 9500 drums. The monthly rdte Of j-um disposalappears to be set at an average of 80"0 drums. This was subtended jjy sevenbulk shipments of wastes to Chemical Recovery Systems, Inc. which totaled42,000 gall o n s . ^ A d d i t i o n a l wastes wene shipped to Systems Tej:hnolqgyCorporation in nine shipments totaling approximately 29,000 g a l l o n s near'the end of the vea-*:" The tabulation of those data a°e found in Appendix

ii- ' ' 'Records submitted by Chem-Met Services, Inc. to the MDNR for 1982

in d i c a t e that U.S. Chemical Company shipped 375,000 gallons of waste in 101s h i p m e n t s to the f a c i l i t y in a p p r o x i m a t e l y &800 drums w i t h a monthlyaverage of 570 drums. A t a b u l a t i o n of these records is found in AppendixIjS. ..A s i m i l j r , . but incomplete, set of records was provided-, to the MDNRfrom U.S. C h e m i c a l Company. Those records, which cove0 only Januarytnrouyh May, i n d i c a t e that they sent approximately 185,000 gallons of wasteto Cht?::i-Met Services, Inc. This corresponds to approximately '3363 "drumsfor j monthly -at^ of 670 drums. W h i l e the "ecords .suppl ied by the MDNR'-oni J.S. Chemical. Company are incomplete, the i n d i c a t i o n s are that therew i l l 3e <i data gap of approximately 1300 drums by the end of 1982 between-'„ n e s-.> two souncos of dat a , based upon p r e l i m i n a r y compdrisons. The U.S.

jl Company data t a b u l a t i o n is found in Append i x •• 1_7» - , *• * •

.i ' ' ]

'J.S. C h e m i c a l Company shipped 298,000 ga l l o n s of m a t e r i a l to Chew-Metces, Inc. in 1983.•• These shipments involved 84 t r i p s - and included.jr,--s -it a monthly average of 450 d"um^. This was1 t'he same jjme

Company was applying for- a 1?CRA Part B Pens-itnumber of drums on £ne plant ^fB" fo 4300tab u l a t i o n of this yea" ,oL act ivi ty' is found-

i o .1 : n wn i c n U.S. C h em i c a 1*nich wo-jlo l i m i t t h e total.j.'lits .See Appendix 14). Thei n Appendix 13.

. r i f t y one s h i p m e n t s w e r e reco rded f"oi irU.S. Chent i^a i Company, t oC h e m - M e t S e r v i c e s , Inc.. in 1984 w h i c h i n v o l v e d approx ima te l y . 200.,000"ga l l ons of w a s t e . This represents aboi^t 3600 drums''tor-a monthly ^ate ofd rum sh ipmentAppendi x 19.

of 300 con ta ine rs The tabulat ions" ' for 1934 ape a t tached fn ..

D u r i n g 1985, U.S. Chemica l shipped approx-imately :.3<27,000 gal lon^ .of1''was te to Chem-Met S e r v i c e s , Inc. in 82 t-r ips-"wtoi-chf invqlved about-6000d rums. The monthly ave r ago fo r sh ipments , -aV th is level^s almost 50.0,

-24-

The t a b u l a t i o n s covering 1985 a~e attached as Appendix 20. It wasduring t h i s year that Mi". Greenway ' i ndicated to the regulatory agenciesthat U.S. Chemical Company was instituting a new policy to reduce the' levelof drum-related business done by the fi"m.

Busi n e s s activity in 1986 began much the same 'as in 1985, however, inthe late" stages of the year and thereafter a shift was noted in the MDNRrecords. The association with Chem-Met Services, Inc. phased out as bulkshipments to Petro-Chem Processing, Inc. we'-e -initiated. During 1987, thisnew "elationship predominated with only an occasional diversion to MichiganRecovery Systems. The tabulations of these "ecords are found in AppendixII-

•»

U.S. Chemical Cl i e n t s

1931

;l.S. Chemical Company engaged i'n hauling of industrial wastes f-om therators f a c i l i t y to its plant to reclaim the solvents from the'waste.

'-/hen tnese shipment took place, manifest copies were submitted to the MDNR.Review of the manifests which were submitted in 1981 reveals that there^e"e d number of major customers for this se°vice as listed below:

49,900 gal Ions,900 drums

106,400 ga l l ons.1930 drums

552,001) yd l i o n s.Bulk Loads

4

57,500 gal Ions1230 drums

94,100 g a l l o n sMostly Bulk Loads

48,200 gallons'330 dr

Coatings ;fAmerica

BASF

jd-JO P'O'JiJ'JtS

•

. jL>ne~al Motors

•?-j'j Spot1 •

no', ve ' i ne Co i 1C o a t i n g C o . 19,100 gal Ions

350 d

An a d d i t i o n a l 46 ousinesses were listed "in these records as having shippedwaste m a t e r i a l s to the U.S. Chemical Company. These manifest records taken

-25-

in total represent approximately 1,184,000 gal lons of waste. Thisvolume would result in production of approximately 3500 drums of solid^swhich would have to be sent for disposal based' upon a 15% non-recoverabfef rac t ion . Th is f igure would be current generation which would exist owerva/id above any drums which were being maintained in inventory on s^te. Thetabu la t ion of the data from these MDNR records is found in Appendix 22. ;.

T-here we re a l so ou ts ide hau le rs t tvat brought ma te r i a l s to LhS. ;>C h e m i c a l " Company for p r o c e s s i n g on a regular t as i s . These! haulers-del ivered approximately l^^OO -gal lons of waste iV a seven indfith .periodfrom June to December in™81. This amount of waste weu.ld also increasethe number of drums of s o l i d s . w h i c h would have to b.e" sent for di sposal-'b*y320 drums over the seven month period. The''tabul atitfn of this businessdata is found in Appendix 23. • .. • •

3Ct l ' (

I

V o.

-*.. "1982

r •'

Add i t i ona l w a s t e t ransact ion records were .obtained f^om the MDNR'Vjhichcovered aspects of 1931 and £982. ? These record1? were not complete fore i ther year but do g i v e an ex'cejlenit indication' o f ' t h e \evel of busTfv&/swh ich U.S. Chemica l Company did wMth var ious concerns. Some'o'f ' these wastev o l u m e s w e n e of c o n s i d e r a b l e s i z e and ar'e."consistent w i th the "yee^T/"eco rds " e f e r e n c e d in o t he r are.a^^of th is report.—These tables "af'einc luded as Appendix 24.. These/^ecords conf i rm' the business" volume.s;' of;:nany of the larger c l ient^ ,of U.S. Chemica l Company mentioned previously.

r:ie1 ' * ,\ u ' '• \ •• •

1982 m a n i f e s t -ec0r'ds fo r major c l i en ts 'of U.S. Chemical Compaq^i n c l u d e the f o l l ow iw j i ndus t r ia l . o p e a t i o n s :

AKZO Coatings Of*

i) \ crU f\ O I

ro"d Motto-1 Co.

- ^ 147 ,.090 gallons26/4 dru;ns

,, .ff., l-23,'2.00 gallons.'' 2240 drums

Bui k loads

Moto'

Red I;

Wol ve^i ne Co i1Codt.i ng Inc . _,,#

d-urns

.- . ,98,. 3.20 gal' loffs1800 drums

40,100 gal Ions730 dr •V-./ ...-* ^-,

-25-

In a d d i t i o n to these major c l i e n t s , U.S. Chemical Company also ha"d acollection of smaller accounts which include approximately 66 additional.businesses. Summarizing the manifest documents for- 1982, U.S. Chemi.calCompany hauled in and processed 1,279,414 gallons of waste which would have

.•'^suited in approximately 3500 dnums of residue generated at an averageMonthly ra.te of 290 drums. The tabulations of this business activity arefqund i n Appendix 2 5 . . • ' • ' . -

iy. H a u l e r s .,other than U.S. Chemical Company also brought materials to' thi/s. • faci 1'i ty for processing. In these cases, manifests we°e sent to theMDNft1.^fleeting the function of U.S. Chemical as solely a TSD facility.Opening in this mode in -1982, U.S. Chemical Company acceptedapproximately 215,000 gallons of waste derived f~om" existing accounts aswell as 26 additional gene"ato"s. This volume represents an additional3900 d-u:jis of waste which had to ̂ be managed on the site. These tabulationsane inc 1 uded-.' as Appendix 26.

1983

J . 5. C h em i c a 1o;n "d number of

i nc luded :

r

•f r-

Company accepted w a s t e s t ranspor ted to- their fac i l i ty^er^ a c t i v e c l i e n t s in 1983. These major c l i e n t s

*'\. N

Ace Body S Auto3ooy Supply Co. 3700 gal Ions

67 drums

A K Z O C o a t i n g s o fAmer ica 102,000 gal Ions

• 1.850

?-od'ucts

l' .E- lec t - ic

General

GP P l a s t i c s

• 127,800 g a l l o n s2300 •£ "urns

1900" yal Ions35 drums

***»249,400 gaT'TortsBulk Le^ds ..

14,300 gal Ions260

•V

24'7 ,ODO gali-dnsMost ly ' Bui

2^00* gal• 38 drums

-27-

V•I

Red Spot ^

Standard DetroitPaint Co.

Stealing Plastics

White Color Card Co.

Wolverine CoilCoating Co.

69,000 gallons1250 drums

15',400 gallons280 drums

605 gallons11 drums

1600 gallons-29 drums

44,000 gallons800 drums

U.S. Chemical Company also served approximately 42 other clients that weresmalle" contributors* to the business volume processed .at their facility.These small cl vents, when combined with the larger operations listed above,contributed a total, of 1,103,300 gallons of waste. "Processing this wastewould have produced a volume of solid waste which would f i l l approximately3000 drums. Data tabulations which pertain to 1933 a-e found in Appendix2 7 . . . .

D u r i n g 1983, wastes brought into U.S. Chemical- Company by otherhaulers included approximately 116,000 gallons in 140 shipments. Thisa d d i t i o n a l volume would result in the .generation of an additional 300 drumsof s o l i d wastes for disposal. The tabulation of records fo- this wasteac t i v i t y i's found in Appendix 28.

\

J

1984

Mucn the same pattern was maintained in 1984 during which time the' c 1 i ents of U.S. Chemical Company continued as follows:

AKZO Coatings o'fAmerica

Automotive Finishes Inc.

BASF

Ford Motor Co.

ft

116,500 gal Ions2100 d~

27,000 ga l lons491 drums •

5 1,500 'ga l Ions940 drums-

292,800 gal lonsBulk Loads

-28-

General Electr ic

General Motors

Red Spot

Si ebe"t-Oxide-mo

W o l v e " i ne Coi lC o a t i n g Co.

28,000 gal Ions

408,100 gallonsBulk Loads

85,240 gallons1540 drums.

56..900' gallons1030 drums

21,800 gallons400 drum$

When the volume of wastes provided by smaller clients is added to the majo'*operations outlined above, U.,S. Chemical Company processed 1,440,596gallons of wastes which would have produced a solid waste volu/ne sufficientto f i l l 3900 dnums. The tabulations of these data are found in Appendix29.

Outside haulers also brought materials to U.S. Chemical Company forprocessing. The volume which appeared from this source was l'24,920 gallonswnicn would have added an additional 340 drums to the yearly total. The-lata tables "elated .to this activity are found in Appendix 30.

i

Chemica l and Conta ine" Cor re la t ions

On M a r c h 3, 1985, the MDNR publ ished ,1 Safety Plan for operat ions atthe Met a mo "a Landfi l l wh ich was d iscovered in the f i les of the LapeerBounty H e a l t h Department- In th is document, t'he MDNR identi f ied thosec h e m i c a l s wh tch had. been documented on the s i te . These chemicals arel i s t e d be low w i th those chem'icals 'which a-e cenfal to painting, solventd e g - e a s i n g and - p l a s t i c s / v i n y l f ab r i ca t i on underlined.

Pu^geab le Halo'ca^bons - , '" .. v

Chlo-ofo"rn • ' _ •1,1-Dicnloroethanel,2-Dichloroethane ' " . " ,Methyl Chlorofomi • . .Methylene Ch1o"ide ' »Tecrachloroethene ' ' . " • • .TrTchl oroethy1eneT r i c h l o r o e t h e n e ,1,2,4-Trichlofobenzene ' '

-2.9-

Purgeable Aromatic Hydrocarbons

BenzeneTthylbenzeneToluene

Chlorinated 'Hydrocarbons • ,

1,2-Dichlorobenzene1,4-DichlorobenzeneHexachlorobenzeneHexach'l orocyclopentadi eneOctachlorocyclopentene

Phthalate Esters & Polar'Pesticides»

Bis (2-ethy lhexy l ) Phtha la teDi-n-Butyl PhthalateDi-n-Octyl Phthalate

Metals & Inorganics

I roaCopperLead .Z incNTcTelC a d m i u mM a g n e s i u mChrpmi urnC a l c i u mSodi umP o t a s s i u mAmmo n i aN i t r i t e s • *Ni t ^ a t e sCyan ideArsen i c

When th is l is t is compared w i th the waste stream information provided byU . S . C h e m i c a l Company in i t s ^ e p o ^ t s ' to the regu la tory* agenc ies aspresented ear l ier in this report, many of the same compounds are listed inboth p l a c e s . There is not a complete match since wastes from other sourcesmay h a v e been added to the U . S . Chem ica l Company cont r ibu t fons . . Theacetate este-s and other organic solvents which were mentioned by Mr.Greenway in his RCRA Part B appl icat ion submissions were not found on thisl ist because the MDNR did not spec i fy that a determination be made for

•these compounds. It does not mean that this material was not present 1nthe samp-le.

The U.S. EPA 'contract laboratory analytical results f"om samplescollected during the test pit activities of December, 1986, have beenformulated into a Technical Memorandum by the MDNR which is included inth is report as Appendix 31. These data revea l that the fo l l ow ingindustrial chemicals were found in the drums which were 'excavated in. theMDNR Phased Feasibility Study in December, 1986:

Organic Compounds

Butyl Benzyl 'PhthalateC h i o r o b e n z e n e ,1,2-DichloroethaneEthyl benzeneIsophoroneMethyl Ethyl Ketone4-Methyl-2-PentanoneNaphthalenePolychlor inated BiphenylStyreneTolueneTetrachloroethene1,1,2-TrichlorbethaneTrichloroetheneXylene

Inorganic 'Materials

.AluminumAntimonyBariumCadmi urnCalciumChromium tCopperIronLea? ' •NickelSil iconSodiumTitanium

The most commonly detected chemicals , which are underlined above, aregeneral ly assoc ia ted with painting arid coating ac t iv i t ies which is thebusrness of the major users of the U.S-. Chemical Company operation. Thesemater ials are exactly what would be expected to be found in wastes fromso lven t recovery operat ions f-^om. this firm. In addit ion,1 the physicala p p e a r a n c e s of the m a t e r i a l s - e x c a v a t e d at the -1 andf i 11 ' l oca t i on were'•eco'-ded and are a lso^ presented in Technical Memorandum No. 3. Thephys ica l s ta te of the wastes are a l s o - c o n s i s t e n t with residual materialsf -om s o l v e n t r e c o v e r y . o p e r a t i o n s on pa in ts and so lven ts from coat ingoperat ions. It s h o u l d . a l s o be noted that the, 'presence of' chlorinatedresidues in the 1/ist of organic material's may be tied to the chlorinatedsolvent ac t iv i ty a lso found at. the U.S.. Chemical Company si te In Rosevil le.

During the test pit operations at .the Met amor a Landfil l; containers*w»re found which held waste materials which' also had legible labels' onthem. These names were, recorded a/id listed in a letter from Mr*. SethP h i l l i p s to Mr. J o h n - T a n a k a of the U .S . EPA on January 12, 1987 (See '

'Appendix '32) . The names which were supplied are .presented below with thcrsenames which are tied in- some way to il.S. Chemical Company being

Chevrolet , Van Slyke - . M IMorton ChemicalNordco^ Drumkimont Corp.Ma tinckrodt

,-31-

r

' GE/ Sili cones • ' ' . . tRfnshed Mason Products, Detroit, MI . - •A and Hass, PhiladelphiaFord SterlingPurity (logo) - .Red SpotDiamond Shamrock Chemical Corp., Defoit, MI

From this admittedly limited site excavation activity, -it was possible"toidentify the names of at least five clients of the Rosevill-e reclaimer,U.S. Chemical Company. Further, these -Were companies which had anestablished business relationship with U.S. Chemical Company which may haveresulted ' in the production -of drummed' waste which had to be managed bydisposal away from the Roseville plant .due to MDNR pressure.

*

' The US EPA has"contacted U.S. Chemical Company regarding their role inthe Metamora Landfill problem. This correspondence resulted in nomeaningful response from U,S. Chemical Company. It is also interesting to-note that the regulatory file did not have a response from U.S. ChemicalCompany to the information request of June 20, 1985. Consequently, 'the USEPA has not had the.benefit of the business records and waste stream datawhich is contained in this information. • The US EPA also does.not have alisting of the clients' of this, firm from which additional PRP candidatesmay be identi fied. •

Additional Information Regarding' U.S. Chemical Company '

The. organizational structure of U.S. Chemical Compa-ny was 'apparentlybased upon the original leadership of Anthony,and Leonard Coraci. Earlydocuments l i s t these i n d i v i d u a l s with Mr. Leonard. Coraci designated aspresident of the corporation. No title has been p-ovided for Mr. AnthonyCoraci. The early envi-onmental interactions which this fi-TU had with theMDNR were largely conducted by Mr. Leonard Coraci,. . 1

. sIn the ea~ly 1970s, the f i rm added an attorney to its s ta f f by th£

name of M-. W i l l i a m Greenwa^y who has since ~isen to the position of v ice 'p r e s i d e n t o f the -company, as w e l l as c o u n s e l . S ince Mr . G r e e n w a y ' sadd i t ion to the organizat ion, Mr. Leonard Corac i has assumed"-a less v is ib le"ole. A lmos t all correspondence from the company in_. the environmental areao r i g i n a t e s w i th M r . Greenway.

The o f f i c e manager for this organizat ion is a woman by the name ofC l a i r e L. Ha l l . The general foreman for the operation is Joseph HoustonkSr. M r . Houston is an olde.r man, p robably in his late f i f t i es . Mr.Houston has worked for th is - ' company for many years and .is probabl'y in aposi t ion to. know about was te shipment act iv i ty from periods back into the1970s. .

The unit operators for this organization are as follows:

Fred AT lorRaymond HoustonNesley Houston

The materials handlers include:

David BrysonLucius RyanGeorge LoweAngelo RemsenRobert Harris

. A l v i n EmersonJoseph Houston, Jr.

The truck drivers are:

MorrisAustin

Houston-Everette, Jr.

Tfie majority of these individuals have worked for--the company' for at leasta few yea^s. wit;h' this s ta f f , the.company maintains, a continual, presenceat the Rosev i1 le facility 24.hours each day. . *, .

' "

Addit ional Deta i ls Regarding Metamora Land'fill <"•'i

As part of the site Investigation and early management.of the 'MetamoraLandfill matter, the-flDNR prepared a* detailed -chronology of .the eventsassociated with this site &$d included it in their enforcement documents*This chronology is included in this report as Appendix 33. " . ,:•

• ' * • i •* ' . " : . - ' ' .:'' '

On May 10, 1982, Conservation Off icer Gregory.Eagle interviewed.NancyP'arnsh at he^ home at 1811 Dryden Road in Metamora, Michigan See. Appendix_ 3 ) . During .this interview (a record of which is incorporated into the MDNRpubl ic record for this s i te) the farmer wife of Eugene Parrish st'ated thatshe was responsib le for the bookkeeping for the landfill operation up until

.August, 1979, when the couple divorced. She furhter stated that severalshipments of paint were brought into the 'landfill' by a Detroit area firm.These t ransact ions were not recorded on the ledgers of the landfill... Ms.Parrish is quoted in the record.as saying that-they wa'nted to conceal, this.d isposa l operation from the IRS. Further, inspection of the logs of. the'landf i l l and other1 records whi 'ch>are avai lable from the landf.il,!'operation'smake no mention of the delivery qf drums of paint or that U.S. ChemicalCompany ever di'd business, there (See Appendix 2).' ** '

There have-been two serious fire situatJons at the Metamor a Landfill.Ms. Parrish,-stated that .the 1972 fire occurred shortly after, a large -IcjjBdof paint was brougnt In from a Detroit firm. 'This fire was" characterisedby exploding drums .and fire hot spots which could not tbe -controlled bywater app l ica t ion . The f i re was eventual ly pu t . o t f t by burying 1t.-According to Nancy Parrish, the second fire in 1980 was the'- res'ult of

' '

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acceptance of extremely hotignited other materials.

foundry' s.and fnom the Imlay City Foundry which

On May 17', 1982, "Gregory Eagle interviewed Robert -Barton who wasdescribed by Nancy, Parn'sh as her husband's right-hand man. 'He was the

, foreman of, the 'landfill. Mr. Barton was not very cooperative during'theinterv iew but did identify U.S. Chemical Company in Detroit as the sourceof the largest 'drum shipments accepted at Metamora ' Landfil 1. He alsos ta ted that they accepted drums fr;om virtually every manufacturer in.theLapee- .area. -He was also able to ident'-ify where the drums were placed in

*tn-e landf i l l . A popy of* the 'enforcement document which contains thisinformation is found in Appendix 3.

' r • , ' ' * "

.On January 21; 1988,.an interview was conducted by Laftrejice* Hal fen andW i l l i a m Bnown at . the home of 'Rober t •S&rt.on, now l iv ing north of -Lapeer {See.Appendix 3J. Mr. Barton indicated tnat he remembered the arrival of u\S.C n e m i c a l Company . t r u c k s at the Undfi.n from t>ime to t ime a f te r hfsemployment in 1974 and thereafter. ' v His peri-od of employment was f"om 1974until the si te was closed by the MDNR in- 1979/ This recollection by "Mr.Barton is a l inkage of the U.S. Chemical Company drum -problem with theMetamora ,Landfil 1 drum deposi ts . • • '. » ".

' xW-,

• r »«'

•-< ^X -i

The ^cords and documents1ndicate the fo l low i ng r

SUMMARY

which fo'Tn the b a s i s for this Deport c lean ly

1. U . S . Chemical Company wa's and is an operat ion which -generates acons ide r ab le quant i ty of paint and so lven t - r e la ted wastes which have to bemanaged f o r ' d i s p o s a l at ot°her ' l oca t ions . . •

2. Cons iderab le amounts of th i s mate^ral we rea-s a resi jit of, U.S. Chemical Company operat ions_ inthrough the 1970s when Metamora Landf i l l was in

subject to eViminationthe late 1960s and all

operat ion.

3. C o s t s assoc ia ted wi,t/i was te 'd i sposa l wene considerable* -presentingthe management of this finn w i th a def in i te economic incentive to find aneconomica l and cons is ten t way of disca-ding waste materials.

4. The chemica l natu re of the wastes produce'd i s. consistent with thei n i t i a l f i n d i n g ' s nel.ated to the c h e m i s t r y o f m a t e r i a l s found, a t thel a n d f i l l as a^e the 'names on some o f the c o n t a i n e r s wh ich have beenexcava ted .

5. Pas t employees andaccep t i ng dr

uins Of wdste upMDNR in 1974.

l a n d f i 1 1 use-sunti l"*the tjrne

indicate that . the landf i l l wasthat the s i te was closed by the

6. At the t ime that the landf i l l c losed , ' 'U .S . Chemical Company startedd i sposa l connec t ion w i th Chem-Met S e r v i c e s , Inc. which lasted for s.everal

s and i n v o l v e d thousands of drums of paint and solvent-re lated was tes .

. 7. _ Customer .of U .S . Chemica l Company include' almost 100 companiesi nc l ud i ng some of the la rges t manufactur ing o rgan iza t ions in Michigan andOhio. '

8. U . S . Chemical Company has cons is tent ly d isp layed a posture ofmin imum rep0 r t ing and environmental compliance even if there was no optiona v a i 1 a b l e to them. • . *• •

9.. T h e r e are severa l points in this review whe^e it ,is apparent thatthere are s i gn i f i can t cons is tency problems between, the-representations ofEugene P a r r i s h and others "egar,ji ng • hi s administration -of the MetamoraL a n d f i l l . • ' - • ' *

10. Th is ' invest igat ion suggests that there—sne many'addit ional PRPcandidates foe this s i te which have not been Bought into the matter. Someof these. PRP candidates may be mucft more. Iflvalved in this landfill than anyf i rm p resen t l y i d e n t i f i e d as respons ib l e for problems at th is s i te.Clear ly , a c lose examination o f ' t h e U.S. Chemical Company records as wellas sworn depositions of keyposs ib le .

figures0 in 'the are needed as soon as

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