Congressional District # 13
CHEMICAL RECOVERYEPA ID# OHD057001810
Last Updated: May, 2015
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 predominantly 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 standing on the property. One is a warehouse/office building, and the other is the Rodney Hunt Still building. The foundation from the former Brighten Still building is located in the northwest corner of the site. Sumps located inside 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 west side, bordering the River. This side of the site is covered with heavy vegetation.
Based on Sanborn Maps dating back to 1884, the CRS site has been in industrial use since the late 1800s. These maps indicate Citizens Gas & Electric Co. and its predecessors operated a "Gas Works" that included one or more gas holder tanks from approximately 1888 to 1910 on the property. 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 operation 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.
Within the last several years, new information has been collected that indicates the presence of a previously unknown Manufactured Gas Plant (MGP) at the site in the past. Extensive NAPL contamination has been found at the site as a result of the operation of this plant. The contamination consists of semi-volatile organic compounds (SVOCs) and polyaromatic hydrocarbons (PAHs) associated with coal tars and other residues.
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, the 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 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 present 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.
In 2010 and 2012, as part of the Additional Groundwater Studies (AGWS) required in the Consent Decree for Remedial Design and Remedial Action at the site, non-aqueous phase liquid (NAPL) was found in wells near the former locations of the gas holders. The NAPL is comprised primarily of MGP constituents, including mono-cyclic aromatic hydrocarbons (MAHs, which includes benzene, toluene, ethylbenzene and xylene [BTEX]) and polycyclic aromatic hydrocarbons (PAHs), with some chlorinated compounds co-eluted within the NAPL mixtures. All of these compounds are key constituents of concern in groundwater at the Site.
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 groundwater contamination at elevated levels, requiring further investigation and potential additional cleanup.
In May 2003, twenty-three PRPs agreed to fund a 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 site 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. 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. These 2003 samples were collected from soil, groundwater, surface water, and sediments, along with the potential seeps along the slope of the river bank. All samples were collected and analyzed for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), PCBs, and metals.
A final RI report was published in 2006. 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, 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, 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 (HHRA) 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 each chemical with the chemical- and medium-specific risk-based screening concentrations developed as part of EPA Region 9's preliminary remediation goals (PRGs). The results of the HHRA show that, under current conditions, the site poses an unacceptable risk for site trespassers due to surface soil contamination. Currently there are no residents 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 could 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 could 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 for the CRS site to evaluate potential adverse impacts to ecological receptors from hazardous contaminants in the soil, groundwater, surface water, and sediments. The analytical results indicated that the site is contaminated with various compounds (metals and VOCs in the surface soil and metals in the sediments) at levels below ecological screening standards. Arsenic, the only chemical of concern found in sediments, was also detected at concentrations below state standards for fish and other benthic receptors.
EPA and Ohio EPA evaluated seven cleanup alternatives, five containment alternatives and two excavation with off-site disposal alternatives (plus a no action alternative), for the CRS site. EPA, with concurrence from Ohio EPA, proposed a preferred cleanup alternative for the CRS site in 2007. On July 26, 2007, EPA held a public meeting at the Elyria City Council Chambers, presenting the findings of the 2003 Remedial Investigation and discussing the seven cleanup options to remediate the CRS site. EPA's preferred cleanup option was also presented, along with the rationale for proposing it.
EPA's preferred cleanup option was a combination of excavation/off-site disposal and a two-foot soil cover over the 2.5-acre site, with monitored natural attenuation (MNA) of groundwater contaminants until Safe Drinking Water Act cleanup standards are achieved. EPA received public comments from July 16, 2007 to September 14, 2007. All comments received during this period were responded to in the Record of Decision (ROD) responsiveness summary.
On October 30, 2007, EPA Region 5 signed a Record of Decision (ROD) for the CRS site, documenting the selected cleanup action. The remedial action objectives for the site are to: eliminate direct contact with the contaminated soil; prevent any further contamination of surface water and groundwater; and restore groundwater at the site 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) regarding of the site and river bank slope; (6) installation of fencing around the site; and (7) implementation of institutional controls for soil and groundwater.
EPA arrived at an agreement, recorded 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. During the design, extensive NAPL contamination was discovered at the site due to a former Manufactured Gas Plant (MGP). Based upon this new information, EPA has determined that monitored natural attenuation will no longer be an effective remedial action for sitewide groundwater. The 2007 ROD will be amended to reflect the new site conditions, and a new remedy will be chosen for sitewide groundwater.
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 EPA 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.
Property ReuseThe site is located in a setting of commercial and industrial parcels. The surrounding land uses are anticipated to remain the same into the future. New zoning restrictions in the area of the site would prohibit zoning of any land uses other than industrial/commercial. Currently, the CRS Site is being used for storage. Future reasonably anticipated land use options for the CRS Site include light industrial and commercial. This could occur only after the selected remedy for soil is completed and all direct contact threats are removed.
ContactsRemedial Project Manager, U.S. EPA
jennifer elkins (email@example.com)