Congressional District # 06
ALLIED CHEMICAL & IRONTON COKEEPA ID# OHD043730217
Last Updated: December, 2012
Site DescriptionThe Allied Chemical & Ironton Coke site is located in the city of Ironton, Lawrence County, Ohio. It encompasses approximately 95 acres, including the former Coke Plant and five former lagoons (Coke Plant/Lagoon Area [CPLA]), the former Tar Plant, portions of the adjacent Ice Creek, and the Goldcamp Disposal Area (GDA). The GDA is a former sand and gravel pit used for disposal of tar plant waste and foundry sand. The Ohio River lies approximately 500 feet west of the former Tar Plant and GDA. Both the former Tar Plant property and the GDA lie on a relatively flat alluvial terrace above the 100-year flood level of the Ohio River. Portions of the CPLA lie within the 100-year flood plain. Much of the site area is covered by a fill that overlies the native soils.
The site is located in the southeastern section of Ironton and is surrounded by other industries, businesses, private residences, and waterways. The residential areas are northwest and along the southern edge of the site. In addition to private homes, there is one elementary school, baseball diamonds along the northern boundary of the site, and seven other schools within 2 miles of the Site. A cemetery lies northeast of the site.
Directly adjacent to the site, bordering the east and south, is Ice Creek, a tributary of the Ohio River. South of Ice Creek is the Village of Coal Grove. A resident's junk yard also lies along 450 feet of the site's southern boundary.
The lagoon area section of the CPLA was originally constructed in the 1970s to serve as a place for Allied to discharge and treat liquid wastes (previously the liquid wastes were discharged directly onto swampy lands that discharged directly into Ice Creek). This area was converted into a wetlands system, taking advantage of its natural flooding conditions and predisposition to wetlands-type vegetation.
The Coke Plant began operations in 1917. In 1977, the site and its operating facilities were sold and operated as the Ironton Coke Corporation. In 1980, the site owners filed for bankruptcy; consequently, the Coke Plant was shut down in 1982. Following closure of the plant, the property and facilities were purchased by Iron City Fuels, Inc. In March 1984, Allied purchased the Coke Plant property, with the exception of the surface facilities which were retained by Iron City Fuels. Iron City Fuels continued to salvage material from these surface facilities until March 1985, at which time ownership of these facilities were transferred to Allied (later to become known as AlliedSignal). Today, the property is owned by Honeywell, as a result of a 1999 merger between AlliedSignal and Honeywell.
Site ResponsibilityThis site is being addressed through federal and potentially responsible party (PRP) actions.
Threats and Contaminants
Products from the coking operation included crude tar, coke, light oil, and ammonia. Wastes generated from the coke plant were discharged into lagoons and into Ice Creek. The wastes included coke and coal fines, tar decanter sludges, boiler ash, and ammonia liquor. Specific constituents present in these waste streams included ammonia, benzene, cyanide, metals, naphthalene, phenolics, and polynuclear aromatic hydrocarbons (PAHs).
The tar plant was designed to manufacture products from the crude tar produced at the coke plant. Specific products included phthalic anhydride, creosotes, pitches, naphthalene, and anthracene. Most of the generated waste and residues from the tar plant were disposed in the GDA. Therefore, site groundwater, soil, and sediment contained PAHs (comprised of benzo(a)anthracene, benzo(a)pyrene, chrysene, and dibenzo(a,h)anthracene), naphthalene, benzene, phenolics, and inorganic compounds including arsenic and cyanide.
The natural groundwater flow at the site is generally towards the Ohio River and Ice Creek, with a component toward the City of Coal Grove well field. However, that municipal supply had not yet been affected by the site [by the time the Ohio Environmental Protection Agency (OEPA) and the United States Environmental Protection Agency (USEPA) were addressing the site].
An administrative order on consent (AOC) was signed between AlliedSignal (now known as Honeywell), USEPA and OEPA in April 1984 for performance of a remedial investigation and feasibility study (RI/FS) at the site.
Following completion of the RI in 1986, USEPA, OEPA, and Allied jointly agreed to divide the site into two operable units. This was done in order to expedite the completion of the FS for the GDA, designated as Operable Unit (OU)1.
Tar Plant operations were shut down in December 2000, with subsequent decontamination and demolition activities completed in 2003. The Tar Plant was designated as OU3 in March, 2003.
Goldwater Disposal Area (OU1)
The GDA FS was completed in August 1988, followed by the issuance of the GDA Record of Decision (ROD) on September 29, 1988, and a Unilateral Administrative Order (UAO) on March 9, 1989, for the performance of the GDA Remedial Design and Remedial Action (RD/RA). During the FS, the discovery of non-aqueous phase substances (NAPS) near the bedrock below the GDA, required (as per the ROD) that a supplemental NAPS RI/FS be performed to determine if the original ROD remedy would still be effective. The results of this supplemental investigation showed the original remedy to be protective, with requirements added for the expansion of the planned groundwater treatment system. An Explanation of Significant Difference (ESD) was issued by USEPA shortly thereafter to document this change to the GDA remedy.
The September 1988 ROD for the GDA included installation of a slurry wall 2,000 feet in length and to a depth of 90 feet; a cap over the GDA; and a groundwater pump and treatment both inside the slurry wall and outside the slurry wall. A UAO was issued to AlliedSignal/Honeywell by USEPA in March 1989, for the design and construction of the GDA remedy. Construction was completed in September 1995. As of July 2011, over 92,000,000 gallons of groundwater has been pumped from inside the slurry wall. This water is treated through a series of biological reactors. Over 1,014,000,000 gallons of groundwater has been treated from outside the slurry wall. The water is treated through a series of carbon adsorption vessels. Treated groundwater is in compliance with discharge requirements.
Coke Plant Lagoon Area (CPLA or OU2)
In December 1990 a ROD was signed (amended in July 1995) for the CPLA which included demolition of the coke plant, offsite disposal of low level contaminated soil, bioremediation within the lagoon area with subsequent wetland development, incineration of one lagoon and groundwater pump and treatment. A second UAO was issued in July 1991 for design and construction. Demolition of the coke plant is completed and over 100,000 cubic yards of soil or coal was excavated for disposal or recycling (coal). The groundwater pump and treatment system began pumping at 200 gallons per minute (gpm) in April 1997.
A second ROD Amendment was signed in July 1997 which changed the remedy from bioremediation by landfarming to offsite disposal of 40,000 cubic yards of material. This change was due to lower than expected contamination levels in the soil. By early 1998, off-site disposal was completed.
A third ROD Amendment was signed in September 1998 and included two changes to the cleanup in the lagoon area. The first change replaced the incineration of 122,000 cubic yards of lagoon material with recycling, treatment, and/or disposal of soft tar in an approved off-site hazardous waste facility and use of the remaining material in the lagoon as offsite alternative fuel. The second change involved the treatment of 457,000 cubic yards of material by in-situ bioremediation. The in-situ bioremediation was changed to hot-spot excavation and treatment consistent with the previous change and subsequent wetland development in the lagoon area. Approximately 6,800 cubic yards required excavation to meet the cleanup standard. Work began in October 1998 and construction was completed in December 2001.
USEPA required an ecological assessment of the lagoon area to gather sufficient information to characterize the condition of the existing benthic invertebrate and vegetative communities, and to evaluate potential impacts to the species with respect to the measured carcinogenic PAH levels in the lagoon materials. The field and laboratory testing was conducted between September and November 1997, with the results presented in the Reconnaissance Ecological Risk Assessment Report, dated January 1998 and revised in July 1998 and March 1999. The principal conclusions indicated that the residual levels would not significantly impact the successful establishment of the planned wetland ecosystem with regard to both aquatic and vegetative communities. Honeywell continues annual monitoring of the lagoons for vegetative and aquatic fauna biodiversity as well as water chemistry parameters. As of 2011 recovery of the wetlands habitat is occurring through natural processes. It is hoped that the ecosystem will be restored and success will be achieved when it contains sufficient biotic and abiodic resources to continue its development without any further assistance. However, there do appear to be several exotic/invasive/noxious species that need to be controlled in order for the wetlands to develop into quality habitat.
Tar Plant (OU3)
The tar plant was closed and operations ceased in December 2000. Closure of the plant was covered under the State of Ohio Cessation of Regulated Operations regulations. Honeywell began the decommissioning activities in May 2001 pursuant to a site management plan approved by OEPA and USEPA. While contaminated groundwater is already addressed by the current site groundwater pump and treatment system, contaminated soil beneath the former tar plant structures remained to be characterized and addressed. EPA issued an AOC to Honeywell on August 22, 2003 for performance of an RI/FS at the Tar Plant.
In December 2003 Honeywell completed all significant decontamination and demolition work at the Tar Plant. In addition, Honeywell submitted its first deliverable for the RI/FS; the technical letter report which provided a synopsis of all data previously collected as part of OU1 and OU2 that was relevant to the Tar Plant.
In June 2005, Honeywell submitted a draft Tar Plant RI report. However, this report documented areas at the Tar Plant that required further investigation. Therefore, an amendment to the work plan was submitted by Honeywell in February 2006 and after review and approval by USEPA and OEPA, Honeywell conducted additional field work. This field work (dubbed Phase Ia) was initiated in February 2006 and was completed in June 2006. Honeywell submitted a draft RI report on the Phase Ia work, which was revised per comments from USEPA and OEPA. The final RI reports covering both Phase I and Ia were approved by USEPA in March 2007.
The Phase I and Ia RI reports evaluated the extent of contaminant in Tar Plant soils, Ohio River sediments and surface water, air and in soil vapor. As part of the RI, human health and ecological risk assessments were performed. The risk assessments evaluated the potential or existing risks of adverse effects from exposure to the contamination found in soils, sediments, surface water and air. Honeywell looked at risks to humans working on, trespassing on or recreating on the site and to plants and animals that might be exposed to site-related contamination.
Along with the RI report, Honeywell produced a draft feasibility study (FS) in April, 2007. USEPA and OEPA asked Honeywell to update the FS with a feasibility study addendum (FSA), which was submitted to USEPA and OEPA on June 15, 2007.
Based on the results of the RI, the risk assessments, the FS and the FSA, USEPA along with OEPA released a Proposed Plan on July 16, 2007, with a list of potential cleanup options and identified USEPA’s preferred remedy for the Tar Plant. On September 20, 2007, USEPA finalized a ROD for the cleanup and containment at the former tar plant area. The approximately $10 million plan selected by the USEPA includes capping of contaminated soil, land-use restrictions to ensure the cap remains intact, and a project to dredge and then cap contaminated river sediment. USEPA evaluated several options and believes that this approach is the best way to protect public health and the environment in terms of effectiveness, implementation and cost. A consent decree was signed between Honeywell and USEPA in July 2010 for the implementation of the selected remedy at the site. In the summer of 2011, Honeywell completed a pre-design investigation at the river bank and the sediments parcel to fill in some additional data gaps prior to the completion of the preliminary Remedial Design Report. In November 2011 Honeywell submitted a Preliminary Remedial Design Report (30% Design) to the USEPA for review and comment. Based on USEPA review and comments on the Preliminary Remedial Design Report, a 95 % Remedial Design Document was submitted to the EPA in the summer of 2012. Based on USEPA review and comments (submitted in December 2012) on the 95% Remedial Design Document, Honeywell plans to submit the 100% Remedial Design Document by mid-June 2013. Honeywell is planning to start the construction of the River Parcel of the Tar Plant in early 2014 and plans to complete it by FY 2014. Honeywell is planning to start the construction of the Main Parcel remedy by early 2015 and plans to complete it by FY 2015.
Honeywell's Site Restoration Plan calls for placing as much of the Site into beneficial re-use as feasible. Two parcels (approximately 1.1 acres in total) outside the GDA slurry wall and cap perimeter and the uplands parcel of the CPLA (approximately 37 acres in total) have been deemed appropriate for industrial re-use and do not require any further action. These 37 acres were conveyed to Ironton in the fall of 2002 as part of a Brownfields redevelopment effort. More recently, Ironton conveyed part of this land to the State of Ohio Department of Transportation (ODOT). ODOT has since constructed a county garage from which it will conduct its highway maintenance activities, including, but not limited to, snow and ice removal, salt storage, equipment maintenance and storage, pavement maintenance, and other roadway operations. ODOT has also constructed office space for its county manager and clerical staff.
The development of the lagoons into functional wetlands is progressing. Annual vegetation and aquatic faunal biodiversity monitoring indicates increasing numbers and diversity of species, which indicates that the wetland habitats are developing. With a stong program to control several exotic/invasive/noxious species that are present, the wetlands should develop into quality habitat.
Property ReuseHoneywell's Site Restoration Plan calls for placing as much of the Site into beneficial re-use as feasible. Two parcels (approximately 1.1 acres in total) outside the GDA's slurry wall and cap perimeter and the uplands parcel of the CPLA (approximately 37 acres in total) have been deemed appropriate for industrial re-use and do not require any further action. These 37 acres were conveyed to Ironton in the fall of 2002 as part of a Brownfields redevelopment effort. More recently, Ironton conveyed part of this land to the State of Ohio Department of Transportation (ODOT). ODOT has since constructed a county garage from which it will conduct its highway maintenance activities, including, but not limited to, snow and ice removal, salt storage, equipment maintenance and storage, pavement maintenance, and other roadway operations. ODOT has also constructed office space for its county manager and clerical staff.
ContactsRemedial Project Manager, U.S. EPA
syed quadri (email@example.com)
Community Involvement Coordinator, U.S. EPA
AliasesALLIED CHEM & IRONTON COKE
IRONTON COKE CORP