Congressional District # 13
CHEMICAL RECOVERYEPA ID# OHD057001810
Last Updated: March, 2012
The Chemical Recovery Systems, Inc. (CRS) site is approximately 2.5 acres in size. The CRS site is located at 142 Locust Street in a predominately industrial/commercial area near the central business district of Elyria, Lorain County, Ohio. The CRS site is located on a peninsula formed by the East Branch of the Black River ("River"). The CRS site is bordered to the west by the River, to the north by Englehard Chemical Company, and to the south by BASF. Presently, the site is owned by the Obitts family trust. Two buildings located in the southeast corner of the site remain on the property. One is a warehouse/office building, and the second is a Rodney Hunt Still building. The foundation from the former Brighten Still building is located in the northwest corner of the site. Sumps located inside of the two still buildings were allegedly used to dispose of waste. One of the sumps located in the shell of the Rodney Hunt building is easily identified. The site is fenced on all sides except for the side bordering the River, which is covered with heavy vegetation.
Russell Obitts began operation at the CRS site in 1960. From 1960 through 1974, Obitts Chemical Company operated as a solvent reclamation facility, receiving used organic solvents from various industries. Operations involved distilling away the impurities in the "dirty" solvents, and selling the "cleaned" reclaimed solvents. The solvents were transported to and from the CRS site in 55-gallon drums or by tanker trucks. The collected spent solvents were transferred to aboveground storage tanks (ASTs) on the site. Nine ASTs with a capacity of 53,000 gallons were known to have been situated on the site. The types of solvents known to be reclaimed at the facility during its operation included but were not limited to: acetone, hexane, isopropyl alcohol, tetrachloroethene (PCE), toluene, methylene chloride, methyl-ethyl-ketone, ethylbenzene, trichloroethene (TCE), dichloroethane, xylene, and paint solvents.
In 1974, Chemical Recovery Systems, Inc. purchased the business from the Obitts. Chemical Recovery Systems ran the solvent reclamation operations on the site until 1981. The solvents continued to be stored in 55-gallon drums and tanker trucks waiting to be cleaned on site. The number of 55-gallon drums used for "dirty" solvent storage numbered from 4,000 to 9,000. Operational problems included improper construction of the ASTs and deteriorating and leaking conditions of many of the drums. Frequent spills and releases were documented.
This site is being addressed by potentially responsible party actions, under a Federal enforcement agreement. Potentially responsible parties (PRPs) are parties whom EPA has determined may be legally responsible for site contamination.
Threats and Contaminants
In August 1978 and April 1980, Ohio Environmental Protection Agency (Ohio EPA), Northeast District Office, documented releases of chemicals from the CRS site to the East Branch of the Black River (River). Concerns about these releases into the River and the potentially dangerous conditions on-site frequently documented by the local fire marshal led EPA to bring suit against Chemical Recovery Systems in 1980, requiring the facility owners to correct the problems identified at the site.
On October 7, 1980, EPA filed a complaint alleging violations of Section 7003 of the Resource Conservation and Recovery Act and Section 301(a) of the Clean Act Water Act. The two principal concerns cited in the complaint were the threat of fire and explosion posed by the presence of approximately 4,000 drums of chemicals waste on the CRS site and the presence of defective distillation units. The second complaint alleged that a leachate stream containing polychlorinated biphenyls (PCBs) was running down the bank of the CRS property and discharging into the River.
In 1982, EPA conducted a hydrogeologic and extent of contamination study at the CRS site. Volatile organic compounds (VOCs) and heavy metals were detected in the soil, groundwater, surface water, and sediments. Specific contaminants at elevated concentrations in soil and groundwater included toluene, ethylbenzene, vinyl chloride, benzene, TCE, PCBs, methylene chloride, cadmium, beryllium, copper, arsenic and polycyclic aromatic hydrocarbons (PAHs). In 1996, Ohio EPA confirmed the presence of VOCs and heavy metals in the soil and groundwater.
Chemical Recovery Systems ceased operations in 1981 because of legal actions taken by the State and Federal Environmental Protection Agencies. A Consent Decree (a legally binding document, signed by a judge and entered into the public record formalizing an agreement between EPA and the PRPs) requiring partial cleanup of the CRS site was signed in 1983. The ASTs and drums were removed from the site in the fall of 1981. In 1983, the site was fenced, sump pumps at the still buildings were filled, and visibly contaminated soils were excavated and backfilled with clean soil. Both the 1982 EPA study and the 1997 Ohio EPA Site Team Prioritization Report showed residual soil and ground water contamination at elevated levels, requiring further investigation and potential additional clean up.
During May 2003, twenty-three potentially responsible parties (PRPs) agreed to fund the Remedial Investigation/Feasibility Study (RI/FS) required by an Administrative Order on Consent (a legal agreement between the PRPs and EPA). The RI is a study to determine the nature and extent of the contamination. The FS is an evaluation of site cleanup alternatives. EPA approved the workplan and field sampling plan to conduct the RI/FS in 2003. The RI/FS Report was approved in 2006.
Field sampling began in July 2003 (Phase I) and ended in November 2003 (Phase II). Phase III samples were collected to eliminate data gaps identified during the review of the analytical data from the first two phases. Phase III samples were collected from the potential seeps along the slope of the river bank.
The 2003 samples were collected from soil, ground water, surface water, and sediments. All samples were collected and analyzed for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), PCBs, and metals. Laboratory results indicated that soil and groundwater have been impacted by historic site activities. VOCs (hydrocarbons and chlorinated), and SVOCs, PCBs, cadmium, iron and lead were above action levels in the soil. VOCs (hydrocarbons and chlorinated), SVOCs, and arsenic were also detected above groundwater action levels. Arsenic was the only chemical detected above the screening level for surface water. For sediments and surface water samples collected, arsenic was detected above action levels in all samples, including the upgradient/background samples. Benzo(a)pyrene was also detected in all sediment samples above action levels.
A Human Health Risk Assessment was conducted to evaluate the potential risks as a result of exposure to residual contamination in the soil, groundwater, surface water, and sediments. Chemicals of concern (COC) evaluated in the risk assessment were identified by comparing the maximum concentration of a chemical with the chemical- and medium-specific risk based screening concentrations using Region 9's preliminary remediation goals.
Under current conditions, the site poses an unacceptable risk for site trespassers due to surface soil contamination. Currently there are no individuals within a one mile radius, or municipalities within a four mile radius, of the site using the (impacted) shallow groundwater or the River surface water as a drinking water supply. Future commercial/industrial users of the site would be exposed to unacceptable surface soil contamination, soil vapor contamination (if a building is placed on the impacted area) and drinking water contamination (if site groundwater was used as a drinking water source). Future residential users of the site would be exposed to unacceptable surface soil contamination, soil vapor contamination (if a building is placed on the impacted area) and drinking water contamination (if site groundwater was used as a drinking water source).
A screening level ecological risk assessment was conducted to evaluate the potential adverse impacts to the ecological receptors due to the presence of hazardous contaminants in the soil, groundwater, surface water, and sediments. The analytical results indicate that the site is contaminated with various compounds (metals and VOCs in the surface soil and metals in the sediments). Arsenic, the only chemical of concern found in sediments, was detected at concentrations below state standards for fish and other benthic receptors.
EPA and and Ohio EPA evaluated an array of seven cleanup alternatives, five containment alternatives and two excavation with off-site disposal alternatives, plus a no action alternative. EPA, in consultation with and with concurrence from Ohio EPA, proposed a preferred alternative. On July 26, 2007, EPA held a public meeting at the Elyria City Council Chambers, presented the findings of the 2003 Remedial Investigation, and discussed the seven cleanup options to remediate the CRS site. The proposed preferred cleanup option was also presented along with the rationale for selecting the proposed cleanup option.
EPA's preferred cleanup option was a combination of excavation/offsite disposal and a two-feet soil cover over the 2.5 acre site with monitored natural attenuation of groundwater until Safe Drinking Water Act Standards are achieved. The public comment period began on July 16, 2007, and ended on September 14, 2007. During this period written comments were received regarding the proposed preferred remedy. All comments received regarding the proposed selected remedy were responded to in the Record of Decision (ROD).
On October 30, 2007, Region 5 signed the Record of Decision for the CRS site, documenting the selected cleanup action. The remedial action objectives for this site are to: eliminate direct contact with the contaminated soil; prevent any further contamination to surface water and groundwater; and restore groundwater to Safe Drinking Water Act Standards. The remedy selected for the site includes: (1) demolition of the two on-site structures; (2) excavation and off-site disposal of approximately 0.5 acre of highly contaminated soil located in the northwest corner of the site to a depth of four feet and backfilling with clean material; (3) application of two feet of clean soil over the 2.5 acre site; (4) monitored natural attenuation of groundwater until it is restored to Safe Drinking Water Act standards; (5) regrading the site and river bank slope; (6) installation of fencing around site; and (7) implementation of institutional controls for soil and groundwater.
EPA arrived at an agreement (in a Consent Decree) with a group of PRPs for cleaning up the site in July 2010, and the design of the remedy is underway.
In 2003, EPA conducted community interviews with local officials and the general public. The purpose of the interviews was to find out what concerns, if any, there were regarding the site. In addition, two availability sessions were held during March 2003. The purpose of the sessions was to discuss the Superfund process with concerned citizens, to share what we already knew about the site from previous investigations, and to answer any other site related questions or concerns.
Congressional InterestThe CRS site is located in the 13th Congressional District, in Elyria, Lorain County, Ohio.
ContactsRemedial Project Manager, U.S. EPA
jennifer cheever (email@example.com)