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Egyptian Lacquer Manufacturing Company Cleanup

The TN Department of Environment and Conservation received a request to extend the public comment period for interested parties to submit comments about the Corrective Action Plan (CAP) for the accidental release of organic solvents from the Egyptian Lacquer Manufacturing Company (ELMCO) in Franklin, TN. Given the interest in the environmental investigation and clean-up of this site, the Department is granting this extension request. The Department will now receive comments about the ELMCO CAP until close of business (4:30 PM) September 19, 2008. This will ensure adequate time is provided for receipt and review of all comments received by the Department.

Egyptian Lacquer Manufacturing Company (ELMCO) is a paint and lacquer manufacturing facility that is located at 113 Fort Granger Drive, Franklin, Williamson County, Tennessee. In January, 2007, sampling along Liberty Creek, near the facility, was conducted by the City of Franklin and TDEC in response to complaints from citizens of strong odors from the creek. Analytical results from the samples confirmed the presence of toluene and acetone in both water and air samples. The Department initiated emergency response actions to contain the chemicals using its emergency response contractors. Upon further investigation by TDEC, the acetone and toluene were found to be entering Liberty Creek and the Harpeth River through seeps along the banks of the creek and river.

At TDEC’s request, ELMCO conducted an immediate investigation of their above ground solvent storage tank farm and the associated underground pipelines that carried various solvents to the manufacturing facility. On February 28, 2007, the investigation revealed that the toluene and acetone pipelines had been compromised and leaked solvents into the subsurface. ELMCO agreed to assume responsibility for continuing the response efforts at the seeps along Liberty Creek and the Harpeth River, and to initiate further efforts to delineate the extent of contamination in soil and groundwater resulting from the solvent release. The following is a brief summary of the activities that ELMCO has undertaken to address the contamination caused by the facility:

  • Placement of booms and pads along the seeps in Liberty Creek and the Harpeth River to collect any free product.
  • Installation of an interceptor trench, measuring 140‘ by 15‘, along Liberty Creek to intercept the free product before it reaches the creek.
  • Air monitoring to insure that vapors do not pose a risk.
  • Installation of monitoring wells to delineate contamination and monitor contaminant concentrations.
  • Monthly sampling of seeps along Liberty Creek and the Harpeth River.
  • Delineation and bioremediation of contaminated soils on site.
  • Permanently decommissioned pipeline that transported solvents to the facility.
  • Permanent removal of all above ground storage tanks to be completed by April, 2008.

In accordance with the requirements of a Voluntary Consent Order, entered into between TDEC and Egyptian Lacquer on June 1, 2007, a Corrective Action Plan (CAP) was submitted to TDEC on August 28, 2007. TDEC found the CAP to be deficient, and an amended CAP will be submitted by ELMCO to TDEC by April 4, 2008.

TDEC has established links on its website in an effort to facilitate public access to specific documents submitted by ELMCO. These documents will include analytical results from soil, air, and water sampling events, as well as any workplans that require TDEC approval. As documents come into the Department, they will be posted in a timely manner for public review.

Public Notice

  • The Egyptian Manufacturing Company - Public Meeting Concerning Revised Corrective Action Plan August 7, 2008. (Comment period extended to September 19, 2008)
  • Reports

  • WPC's September 2008 Summary of Water Sampling Results
  • WPC's September 2008 Water Sampling Report
  • ELMCO Seep Sampling Report September, 2008 (replaces August 2008 sampling)
  • TDEC TRIP Report - August 12, 2008
  • ELMCO July 2008 Seep Sampling Report
  • ELMCO June 2008 Seep Sampling Report
  • WPC's June 2008 Summary of Water Sampling Results
  • WPC's June 2008 Water Sampling Report
  • ELMCO's June, 2008 Groundwater Monitoring Results
  • Initial Report of Confirmation Soil Sampling Investigations Under Former Tank Farm and in Biox Treatment Area at ELMCO Facility
  • ELMCO Seep Sampling Results May 2008
  • Seep Monitoring Results - April 2008 Event
  • ELMCO Investigation Report - March 25, 2008
  • WPC's Summary of Water Sampling Results from Liberty Creek
  • Water Sampling Results from Liberty Creek - March 18, 2008
  • ELMCO Seep Sampling Report - February, 2008
  • ELMCO Seep Sampling Report - January 28, 2008
  • WPC's Summary of 2007 Water Sampling Results from the Harpeth River and Liberty Creek
  • ELMCO Seep Sampling Report - December 10, 2007
  • ELMCO Seep Sampling Report - November 9, 2007
  • Plans

  • Revised Comprehensive Corrective Action Plan Addressing The Solvent Release From ELMCO, June 23, 2008
  • ELMCO Investigative Workplan - December 20, 2007
  • ELMCO Air Monitoring Plan - December 14, 2007