Congressional District # 01
AMERICAN CHEMICAL SERVICE, INC.EPA ID# IND016360265
Last Updated: March, 2015
Site DescriptionThe American Chemical Service, Inc. (ACS) site is located at 420 S Colfax, Griffith, Indiana. The ACS site consists of the 15-acre ACS operating facility area and about 5 acres of surrounding wetlands located north of a set of abondoned railroad tracks. The site also consists of the 13-acre "Off-site Containment Area" and the "Kapica Pazmey Area."
ACS began operations in 1955 as a solvent recovery firm (later receiving interim status under the newly-passed (in 1976) Resource Conservation and Recovery Act (RCRA) statute) and as a chemical manufacturer. Upon losing its interim status under RCRA in 1990, ACS ceased its solvent reclamation activities and began to operate solely as a chemical manufacturer. The Kapica Pazmey Area property was the site of a separate chemical drum reconditioning operation.
From 1955 until at least 1975, ACS disposed of a variety of hazardous wastes that were produced during company operations into an area on the southern portion of its property ( the "Offsite Containment Area"). ACS also disposed of numerous drums containing waste chemicals and the remainder of solvent recovery distillations in different areas of the northern portion of the property. In addition, ACS accepted quantities of waste chemicals from outside sources for disposal in an incinerator it had built on the property. Incinerator ash was disposed of on the ACS site.
In 1972, the Indiana State Board of Health (ISBH) responded to residents' complaints and inspected the ACS facility. From 1972 to 1973, ISBH attempted to achieve improvements in ACS waste handling, spill prevention, and site maintenance standard operating procedures. In 1974 and 1975, ISBH also responded to reports that ACS was discharging chemicals into the sanitary sewer and dumping chemicals on its property.
The United States Environmental Protection Agency (EPA) placed the ACS site on the National Priorities List (NPL) in 1989, and completed a remedial investigation and feasibility study (RI/FS) at the ACS site in 1992. EPA determined that the ACS site may contain the remnants of an estimated 35,000 buried chemical drums (which may or may not still contain their contents) and pigment and resin sludges containing contaminants such as polychlorinated biphenyls (PCBs) and volatile organic compounds (VOCs). The VOCs are a source of the groundwater contaminant plume beneath the site.
Approximately 10,000 people live within three miles of the site, with the closest residence located less than one-quarter mile away. About 50 homes are located in the immediate vicinity of the site, which is also surrounded by railroad tracks, drainage ditches, and marshy areas. More than 2,000 private wells are in use within the site area.
Site ResponsibilityThis site is being addressed through federal, state, and potentially responsible party (PRP) actions.
Threats and ContaminantsThere are two groundwater aquifers of concern beneath the ACS site and its surroundings. EPA refers to them as the "upper aquifer" and the "lower aquifer." The upper aquifer is closest to the ground surface and is separated from the lower aquifer by a layer of clay which acts as a water barrier between the two aquifers. Generally, the upper aquifer beneath the ACS site is heavily contaminated with VOCs such as benzene, toluene, xylene, and vinyl chloride, and with semi-volatile organic compounds (SVOCs) such as creosote. A groundwater contaminant plume extends a few hundred feet off site to the southeast. Here, the contaminants include benzene and chloroethane, but they are found at much lower levels than under the on-site area.
The lower aquifer has only been impacted beneath the ACS site in the northern area. Benzene and chloroethane are the compounds of concern in the lower aquifer. Because the clay layer is a good barrier between the two aquifers, EPA is investigating whether the lower aquifer may have been impacted by the drilling of groundwater monitor wells during the remedial investigation.
It is important to note that, although a couple of homes to the south along Reder Road are situated over the groundwater contaminant plume, they do not have their drinking water wells installed in the upper aquifer. In that area, low levels of contaminants are found in the upper aquifer, but the homes have their wells installed in the lower aquifer which is not impacted at that location. Recently, one of the homes was placed on the city water supply. EPA monitors the water quality in these wells annually as a precaution.
The soil beneath the site is heavily contaminated with many types of compounds, including polychlorinated biphenyls (PCBs), heavy metals, volatile organic compounds (VOCs), semi-VOCs, and pesticides. These materials are the remnants of the ACS solvent recycling business. Surface water run-off from the ACS site and naturally-occurring upper aquifer discharges also caused low levels of PCBs to be carried into the wetlands north of the site.
Human health threats are posed by the contaminants in the soil and groundwater beneath the site. Exposure could come from the ingestion of, or dermal contact with, contaminated water or soil. In addition, the inhalation of airborne contaminants could pose a risk if someone were to dig into the contaminated soils.
Ecological receptors could be harmed by exposure to PCBs in the wetland area.
EPA completed the remedial investigation and feasibilty study (RI/FS) at the ACS site on September 30, 1992, and issued a Record of Decision (ROD) that contained the selected cleanup actions for the site. The cleanup action, termed a remedial action, was to include the following work:
- groundwater cleanup through a pump and treat program;
- wetlands sediment cleanup and monitoring;
- excavation of intact chemical drums for off-site incineration;
- excavation and off-site disposal of miscellaneous contaminated debris;
- excavation of contaminant source areas and on-site treatment using low-temperature thermal desorption;
- evaluation of soil cleanup through a soil vapor extraction pilot study; and
- long term groundwater monitoring and limited private well monitoring.
EPA estimated the total cost of the above cleanup work (in 1992) would be $47 million.
EPA began a two-pronged approach to having the "polluters pay" for the cleanup of the ACS site after the ROD was issued. There were over 1,800 parties identified as having sent some waste to ACS for recycling, incineration, or disposal during its period of operation. Dealing with that many parties during a cleanup action would have been unwieldy; thus, EPA began to settle with the smaller parties by allowing them to "cash out" of the cleanup process by paying their estimated fair share of the cleanup costs into a special fund for use in cleaning up the site. In 1994-1995 EPA settled with over 900 smaller parties and established a $24.5 million cleanup fund from the settlement payments. Many smaller parties no longer existed or could not be found.
Also in 1994, EPA completed cleanup discussions with the remaining companies that had been identified as sending larger amounts of wastes to ACS by issuing an order to the companies to begin to put together the blueprints for the remedial action and to undertake the cleanup. The companies complied with the order and began planning the remedial action.
Part of the planning work included the testing of the low-temperature thermal desorption (LTTD) treatment method on samples of site waste to be sure it was a compatible cleanup method. Testing was also conducted to determine the safest way to handle highly contaminated material and debris that would be excavated from the ground and treated in a LTTD system. While the testing work was underway, the companies petitioned EPA to allow them to construct a subsurface barrier wall ("slurry wall") around the entire ACS property to prevent movement of contaminated water off site. The companies also constructed a water treatment plant on site to treat water that was pumped from within the slurry wall and also from certain areas outside of the wall. The interior water pumping functioned to keep the contaminants within the containment system, and the exterior pumping helped to begin to clean up the groundwater contaminant plume. The slurry wall and water treatment plants were installed in 1996-1997 and have been operated since then to help contain site wastes in place.
Meanwhile, the companies presented the waste treatment testing results to EPA. The results showed that because there was a large amount of debris associated with the buried chemical contaminants, the LTTD treatment method selected in the ROD would not work well at the ACS site. Testing results indicated that the companies would need to thermally treat the soil and debris using an incineration method instead. Also, the companies determined that it would be extremely hazardous to excavate the highly contaminated wastes from the ground as the levels of VOCs would make the excavated wastes highly flammable. In order to safely and effectively clean up the soil and debris at the ACS site, the companies would have to spend over $250 million to excavate and incinerate the wastes, a considerable cost increase over the ROD estimate.
EPA reviewed the waste treatment study results in 1998 and determined that LTTD would not be a viable cleanup alternative for ACS site wastes. EPA did not consider on-site incineration to be a good alternative to LTTD either. Because it would not have been safe or cost effective to excavate the highly contaminated wastes from the ground, EPA issued a proposed plan in April 1999 to amend the 1992 ROD and select a safer cleanup alternative for the site. After a reasonable opportunity for public comment on the proposed remedy change, EPA issued a ROD amendment in July 1999 that included the following work to both clean up and contain site wastes in place using safe, effective, and cost-effective cleanup methods:
- installation of a slurry wall around the site (completed in 1997);
- installation of a groundwater extraction and treatment system to maintain an inward groundwater flow within the barrier wall and to clean up contaminated groundwater outside of the barrier wall;
- excavation of known intact chemical drums for off-site incineration; and
- implementation of soil vapor extraction in certain areas of the site to remove very high levels of VOCs from the ground.
Some aspects of the 1992 ROD remedy were unchanged, including the groundwater cleanup method (now slated for outside of the slurry wall) and the wetlands cleanup action. The new cleanup was estimated to cost a total of $70 million when factoring in money already spent to study the site and to perform the waste treatment testing, plus future operating costs of the soil vapor extraction equipment and water treatment plant.
The companies completed a final design report in late 1999 to conform with the selected cleanup remedies in the ROD amendment and/or 1992 ROD. EPA then reached an agreement with the companies in January 2001 (termed a "Consent Decree") under which the companies would complete all the necessary cleanup work at the site. Some of the funds collected earlier would be used by the companies to complete the work and the rest would be provided by the companies.
A significant amount of cleanup work has been completed since the January 2001 agreement. During the period of 1999-2002, the companies first added more technology to the water treatment plant to both allow for an increased amount of water to be treated and for the treatment of more highly polluted water that was expected to be removed from within the slurry wall confines. Next, a soil vapor extraction system was installed in the off site containment area and brought up to operating speed. The wetlands were cleaned up by excavating a few thousand cubic yards of sediment that were contaminated with PCBs above a 1 part per million cleanup level. Lastly, over 400 intact chemical drums were excavated and shipped off site for incineration.
During the period of 2002-2004, the companies installed a final soil cover over the off site containment area and installed a soil vapor extraction system in the on site area. The on site soil vapor extraction system was tested and adjusted for efficiency and was brought on line during the summer of 2004.
Also in the fall of 2004, EPA completed the placement of a final cover over the on site area and began to inject a chemical oxidant compound under a small area along the southern area of the site (near the Colfax Avenue and Reder Road intersection) that had small amounts of hydrocarbon contamination at the water table (a part of the off site groundwater cleanup program). Then, because all cleanup components had been installed, EPA claimed a "construction completion" milestone in September 2004 for the ACS site.
In April 2005 a second round of chemical oxidant injections was performed in and around Colfax Avenue (near Reder Road), and in July 2005 the third round of injections occurred. Still later, in early 2006, a fourth and final round of chemical oxidant was injected into the ground. EPA then began a period of monitoring groundwater quality in this area that will continue until contaminant levels no longer exceed cleanup standards.
The site is now in the operation and maintenance ("O&M") phase. The soil vapor extraction systems will be operated for about 5 years and the water treatment system will be operated for 30 years or more. Initially, the soil vapor extraction systems were removing over 1,000 pounds per day of volatile organic chemical contaminants from the ground. In August 2011, the soil vapor extraction sytems were transitioned from active soil vapor extraction to passive soil vapor extraction when the remedial goal of 100 pounds per day was reached. It is estimated that over 900,000 pounds of volatile organic chemical contaminants have been safely removed from the ground at the ACS site and safely destroyed.
The soil covers are inspected periodically and repaired as necessary.
The third five-year review report for the site was completed in March 2011. The report concluded that the site cleanup and remedy are operating as designed and they are protective of human health and the environment in the short-term. Additionally, the remedial action will achieve long-term protectiveness when the site cleanup goals are met, and Institutional Controls (ICs) are in place and effective. The next five-year review is scheduled for 2016.
Five residential wells at the south side of the site are sampled annually. To date, no site-related contaminants have been detected in these wells.
Success StoryAfter EPA learned that the 1992 cleanup remedy could be much more expensive than anticipated and was perhaps unsafe to implement, EPA worked with ACS, Inc. and the other responsible companies to craft a safe, new and effective remedy in 1999. This new remedy also allowed for ACS, Inc. to remain as a viable, working concern. The new remedy has been constructed and is being safely and effectively operated and maintained. ACS, Inc. also appears to be operating successfully, employing a number of local residents. Moreover, there have been no lost-time incidents reported during the construction and operation of the cleanup remedy since it began.
EPA maintains an "open door"policy at the ACS site to the extent that it does not impact the operating ACS, Inc. chemical-blending business. EPA has provided tours of the operating water treatment plant to local youth groups and interested cleanup professionals from overseas. EPA also provides area firefighters and ACS staff with an annual tour of the cleanup facilities to familiarize them with the working components, in case they need to respond to an emergency situation at the site or the ACS factory.
A few local residents remain involved as well. When these citizens raised an issue concerning noise levels at the water treatment plant, EPA investigated the matter and adjusted certain equipment to reduce noise levels. EPA then invited them to tour the facility and see the adjustments made. The residents accepted the offer and afterwards expressed appreciation for the efforts EPA demonstrated to address their concerns.
Property ReuseThe amended cleanup remedy was designed to allow ACS, Inc. to continue to operate as a chemicals concern. ACS continues to operate at its facility as EPA continues the cleanup actions around it.
ContactsRemedial Project Manager, U.S. EPA
Giang-Van Nguyen (email@example.com)
Community Involvement Coordinator, U.S. EPA
AliasesAMERICAN CHEM SERV INC
AMERICAN CHEMICAL SERVICE, INC
AMERICAN CHEM SERV