&EPA
      United States
      Environmental Protection
      Agency
 Share your opinion
 EPA invites comments on its proposed
 cleanup plan for the Peters Cartridge
 Site.  Public input helps EPA
 determine the best course of action.
 EPA also encourages people to attend
 the upcoming public meeting on
 Wednesday, July 15, at the Warren
 County Administration Building at
 406 Justice Drive, Lebanon, Ohio,
 starting at 6:30 p.m.

 There are several ways to offer
 comments on the proposed plan:
  • Orally or in writing at the public
    meeting.
  • Fill out and mail the enclosed
    comment form.
  • Electronically via the Internet at:
    epa.gov/region5/publiccomment/
    peterscartridge-pubcomment.htm
  • Fax to Patricia Krause at
    312-697-2568

 Comments can be submitted to EPA
 from July 6 to Aug. 6, 2009.

 Contact EPA
 These EPA representatives are
 available to answer questions and
 provide more information. If you
 need special accommodations at the
 July 15 public meeting contact
 Patricia Krause by July 9.

 Patricia Krause
 EPA Community Involvement
 Coordinator
 Superfund Division
 312-886-9506
 krause.patricia@epa.gov

 Pamela Molitor
 EPA Remedial Project Manager
 Superfund Division
 312-886-3543
 molitor.pamela@epa.gov

 Region 5 toll-free: 800-621-8431,
 9:30 a.m.  - 5:30 p.m., weekdays
EPA   Proposes  Cleanup
Plan   for  Ammunition  Site
Peters Cartridge Factory Site
Kings Mills, Ohio
June 2009
Contaminated soil and sediment at the Peters Cartridge site in Kings Mills,
Ohio, will be excavated and contained through a plan proposed by U.S.
Environmental Protection Agency. At the Peters Cartridge site, EPA proposes
to excavate surface soil contaminated by past manufacturing activities at
the location.  The excavated soil will be removed, combined and covered
to prevent people from coming into contact with dangerous chemicals. To
prevent wildlife exposure to the pollution, EPA proposes these cleanup
actions:  soil and material deposited in the drainage swales and culverts, and
sediment (mud) in the drain outlets and shoreline areas would be excavated
and consolidated on-site with the soil excavated from other parts of the
property.

Chemicals are present in ground water (underground water supplies) as a
result of former site activities.  These chemicals have not flowed far from
where they were released into the environment and current concentrations
are below drinking water levels regulated by EPA.  Ohio EPA studies
demonstrated that contaminants from the site are not significantly impacting
the Little Miami River.  EPA's proposal to consolidate and cover the
contaminated soil will keep precipitation and surface water from filtering
through the soil and carrying contaminants into the ground water.

For both soil and ground water cleanup, the plan calls for "institutional
controls" to protect the public and future workers from exposure to
contaminants remaining underground or lying under paved areas or buildings.
Institutional controls could include zoning restrictions, use restrictions, soil
management plans, recorded restrictive covenants, public notices and posted
signs.

Once the cleanup actions outlined in the proposed plan are implemented,
EPA believes they will protect public health  and the environment.

Public comment
The purpose of this proposed plan fact sheet is to provide background
information about the Peters  Cartridge site, describe the various cleanup
options that were considered and identify EPA's suggested cleanup
alternative.1 The public is encouraged to comment on this proposal. EPA
will be accepting comments starting July 6, 2009.  EPA also encourages
the public to attend and participate in a public meeting at the Warren County
Administration Building, 406 Justice Drive, Lebanon, Ohio, on July 15, 2009.
The meeting will be held at 6:30 p.m.  See the adjacent box for ways to
participate in this process. EPA could alter its proposed plan or choose a new
one based on public comments so your input is important.

i Section 117(a) of the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA, known as the Superfund law) requires EPA to provide an opportunity for public input
with a meeting and comment period. It also requires a newspaper ad announcing the proposed
cleanup plan with a brief description.  This fact sheet summarizes the feasibility study and other
site-related reports. The full study and all other official site documents can be found at the
Salem Township Library in Morrow, Ohio and at the EPA Region 5 office in Chicago.

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The public is also encouraged to review the supporting
documents for the Peters Cartridge site such as the recently
completed "remedial investigation" and "feasibility study."
A remedial investigation is a study of the nature and extent
of contamination at a cleanup site, while the feasibility
study evaluates different cleanup options.

These documents are available at the Salem Township
Library at 535 W. Pike St. in Morrow and at the Warren
County Administration Building in Lebanon. You can also
review these materials online at: http://www.epa.gov/
region5/sites/peterscartridge.

About the Peters  Cartridge site
The Peters Cartridge site is located along the southern
bank of the Little Miami River in Kings Mills, Ohio.  The
area is shown in Figure  1 below.  The location occupies
about 71 acres, nearly all of which is located west of
Grandin Road.

Peters Cartridge Co. began production in 1887.  From
1887 to 1934, the facility produced ordnance and shot shell
ammunition. In 1934, the Remington Arms Co. purchased
Peters Cartridge and continued production at the facility
until 1944 when operations  were stopped. Next to the
site was the Little Miami Railroad, which was established
in this area in 1845. The railroad ran from Xenia to
Cincinnati and served as a major transportation route for
19th century industry in Southern Ohio.

The Peters Cartridge site can be divided into two primary
areas  (see Figure 2 on Page  7). Area A includes about 15
acres  along the southern bank of the Little Miami River
and is relatively flat.  The main buildings and the Little
Miami Scenic Trail are located in Area A.  The ground
surface in the eastern section of Area A is mostly covered
by asphalt or concrete. Area B occupies about 56 acres
of wooded, steeply sloping hills and ridges.  Several small
/  APeters Cartridge Site
         BE^s^      » x.  •» -w  T     ^^^—•
     Pfe^ fvXSM*^^
                       /
Figure 1 -Map shows location of former facility and Little
Miami River.
outbuildings, bunkers, concrete supports, foundations,
conveyance structures and other facilities historically
used by Peters Cartridge are located throughout Area B.
Ownership of Area B, which is currently vacant, was
transferred to Hamilton Township in 2007.  The township
plans to retain this area as open space.  Since 1944 the
Peters Cartridge site has been divided into several land
parcels owned and occupied by others.  Portions of Area A
are currently in use by commercial and industrial businesses
and contain a public bike trail and parking lot.

As a result of environmental site assessments, EPA
decided the location was eligible for cleanup under
the federal Superfund program. In 2004, EPA issued a
legal order to the former owner of Peters Cartridge Co.
requiring that certain response actions be taken including
the investigation of contamination and development of
alternatives to address risks posed by contamination found
on the property. The former owner is called a "potentially
responsible party" or PRP. E.I. du Pont de Nemours and
Co. acquired the Remington Arms Co. and through that
ownership DuPont is considered potentially liable for site
investigation and cleanup.

Summary  of site  risks
People and wildlife that come  in contact with contaminated
soil or sediment at the site may face health risks, mainly
from lead, mercury, copper, antimony, arsenic, benzo (a)
pyrene and naphthalene. There are many different health
effects associated with exposure to these chemicals.
Lead: Potential health effects  include memory or
concentration problems, nerve disorders, kidney damage,
and learning disabilities and behavior problems in
children.  Small children or unborn babies are the most
sensitive to lead exposure.
Arsenic: Potential health effects include gastrointestinal
disorders, anemia, skin  lesions, liver or kidney damage,
and increased risks of nonmelanoma skin cancer and also
bladder, liver and lung cancer.
Mercury: Potential health effects include harm to the
brain, heart, kidneys, lungs and immune system. At high
levels of exposure, mercury's harmful effects on animals
can include death, reduced reproduction, slower growth,
and abnormal behavior. Birds and mammals that eat fish
and predators that eat fish-eating animals are more exposed
to mercury than other animals in water ecosystems.
Antimony: Potential health effects include vomiting, liver
damage and skin irritation.
Benzo(a)pyrene: Potential health effects include
developmental and reproductive effects, cancer, red blood
cell damage and suppression of the immune system.
Naphthalene: Potential health effects include anemia,
visual impairment, respiratory damage, liver damage or
neurological damage.
Copper:  Potential health effects include nausea, vomiting,
diarrhea and headaches.

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EPA's proposed cleanup actions are designed to reduce the
risks associated with these soil and sediment contaminants
at the site.

Cleanup options considered
EPA considered four options for managing and cleaning
up contaminated soil, sediment and ground water.  Each
option was evaluated against nine criteria required by
law (see box on Page 4 for an explanation of the criteria).
EPA's proposed cleanup actions are designed to reduce
health risks. Cleanup goals  were established based on
federal and state regulations. EPA believes these cleanup
actions will protect human health and the environment.
Full details are provided in the remedial investigation and
feasibility study reports at the Salem Township Library
and Warren County Administration Building, and on EPA's
Web site.

Each cleanup alternative reduces human and wildlife
exposure to lead and other chemicals in soil and is
summarized below:

Alternative 1 - No Action:  In this option, no cleanup
or control measures would be implemented nor would
contaminant levels be monitored. EPA always  includes a
no action option for comparison purposes. Cost: $0.

Alternative 2 - Capping/Containment: In this option, a
soil layer (or "cap") consisting of 2 feet of clean fill would
be placed over 10 acres where contaminant levels exceed
cleanup goals. Clean soil would be brought to the site, and
the upper 6 inches would be topsoil to support vegetation
growth. Institutional controls would be used to limit
exposure to contaminated soil, including implementing
deed restrictions requiring the property only be used for
nonresidential purposes, requiring periodic inspection
and maintenance of the cap, and limiting future invasive
activities where contaminated soil has been capped.
Cost: $3.8 million.

Alternative 3 - Excavation and On-site Consolidation
(this is EPA's recommended alternative):
Under this option, surface soil, where contaminant
concentrations exceed the cleanup goals, would be
excavated and placed elsewhere on the site. An estimated
32,000 cubic yards of soil would be excavated. The
excavated areas would be backfilled with clean material
and seeded. The consolidation area would be about 3
acres in size and would be located on the flat section in
the southwest portion of the Hamilton Township property.
A 2-foot-thick low-permeable soil cover that allows very
little water to pass through, an impermeable synthetic
material cover that prevents water from passing through,
and a 6-inch-thick vegetation support layer would be
placed above the excavated material. An impermeable
liner would be placed below the excavated material and
ground water would be monitored to make sure drinking
water sources were protected.  The final grade of the
consolidation area would be approximately 1 foot or less
above the level of the existing surface.  Like Alternative
2, institutional controls would be required to restrict land
use to nonresidential purposes and limit site activities
where contaminated soil has been capped.  A fence would
be constructed around the consolidation area to restrict
access.  Cost: $5 million.

Alternative 4 - Excavation and Off-site Disposal: Under
this option, surface soil, where contaminant concentrations
exceed the cleanup goals, would be excavated and
transported off-site for disposal. The volume of soil to
be excavated would be about 32,000 cubic yards. As in
Alternative 3, the excavation areas would be backfilled
with clean material, leveled with the surface and
seeded.  Institutional controls would restrict land use to
nonresidential purposes. Cost: $6.3 million.

Alternatives 2, 3, and 4 all include excavation of shoreline
sediment areas at culvert discharge pipes along the Little
Miami River. This will limit pollution from entering the
river and protect aquatic wildlife. These three alternatives
also include the removal of bottles and debris in
stormwater culverts on the property. Alternatives 2, 3, and
4 will all also restrict site ground water from being used
for drinking.

Evaluation  of cleanup  alternatives
Each of the cleanup options was evaluated against the
nine criteria set by  Superfund law (see evaluation chart on
Page 4).  EPA is recommending Alternative 3 based on the
following justifications: (1) EPA believes this option will
achieve the best balance among the nine criteria, (2) this
alternative will significantly reduce the exposure of people
and wildlife to contamination, (3) it complies with all
federal and state regulations, and (4) it is a cost-effective
way to manage the  most highly contaminated material.

Alternative 1, the no action option, would not protect
human health and the environment and does not comply
with regulations. Alternative 2 would comply with
regulations and provides the same degree of long-term
protection from exposure as Alternative 3.  Implementing
and maintaining the cap, however, would be much more
difficult due to the steep slopes and rugged terrain at the
site. Alternative 4 would protect human health and the
environment and comply with regulations, but is more
expensive than Alternative 3 and would be more disruptive
to the local community due to  increased truck traffic.

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Next steps
EPA will review comments received during the public
comment period before making a decision on the cleanup
plan.  Based on new information in public comments,
EPA may change its proposed options or select another
alternative presented in this plan. EPA will respond to
comments in a "responsiveness summary." This will be
part of a document called a "record of decision" or ROD
that describes the final cleanup plan for the site.

EPA will announce the ROD in a local newspaper, and
a copy will be posted on EPA's Web site and placed
at the Salem Township Library and Warren County
Administration Building. EPA will negotiate with DuPont,
the potentially responsible party, to conduct the cleanup
under Agency oversight.  The cleanup will  then be
designed and constructed, a process that could take several
years.
Peters Cartridge Factory entrance
Explanation of evaluation  criteria
EPA uses nine criteria to evaluate and compare cleanup
options. See the table below comparing the options
against these criteria.

1. Overall protection of human health and the
environment addresses whether an option protects both
human health and the environment.  This standard can
be met by reducing or eliminating contaminants or by
reducing exposure to it.
2. Compliance with applicable or relevant and
appropriate requirements (ARARs) ensures that each
cleanup option complies with federal and state laws.
3. Long-term effectiveness and permanence evaluates
how well an option will work over the long-term,
including how safely remaining contaminants can  be
managed.
4. Reduction of toxicity, mobility or volume through
treatment addresses how well the option reduces the
toxicity, movement and amount of contaminants.
5. Short-term effectiveness compares how quickly an
option can help the situation and how much health risk
there will be while the option is under construction.
6. Implementability evaluates how difficult the option
will be to construct and whether materials and services
are available in the area.
7. Cost includes not only buildings, equipment, materials
and labor but also the cost of maintaining the option
for the life of the cleanup. A cleanup is considered
cost effective if its costs are proportionate to its overall
effectiveness.
8. State acceptance determines whether the state
environmental agency (in this case Ohio  EPA) accepts the
option. EPA evaluates this criterion after receiving public
comments.
9. Community acceptance evaluates if the nearby
residents  accept the option. EPA evaluates  this standard
after a public hearing and comment period.
              Chart comparing  cleanup  options with nine Superfund  criteria
EVALUATION CRITERIA
Overall Protection of Human Health and
the Environment
Compliance with ARARs
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility or
Volume Through Treatment
Short-Term Effectiveness
Implementability
Cost (millions)
State Acceptance
Community Acceptance
Alternative 1
D
D
D
D
D
•
$0
Alternative 2
•
•
B
D
B
•
$3. 8 million
Alternative 3*
•
•
•
D
B
•
$5 million
Alternative 4
•
•
•
D
B
•
$6.3 million
Will be evaluated after public comment period
Will be evaluated after public comment period
                 • - Meets Critera     B - Partially Meets Critera      D - Does Not Meet Critera
  *EPA's Suggested Alternative

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              Use This Space to Write Your Comments

EPA is interested in your comments on the proposed cleanup plan for the Peters Cartridge
site. You may use the space below to write your comments. Submit them at the July 15 public
meeting, or detach, fold, stamp and mail to EPA Community Involvement Coordinator
Patricia Krause Comments must be postmarked by Aug. 6, 2009. If you have any questions,
please contact Patricia directly at 312-886-9506, or toll free at 800-621-8431, 9:30 a.m. - 5:30
p.m., weekdays.  Comments may also be faxed to Patricia at 312-697-2568 or sent via the Web at
epa.gov/region5/publiccomment/peterscartridge-pubcomment.htm.
   Name
   Affiliation

   Address	
   City  	   State 	   ZIP

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                   Peters Cartridge Site - Comment Sheet
   Detach, fold, stamp and mail
Name _                                           „,
A jj  -                                           place
Address _                                           c.
                                                                               Stamp
                          State -                                           Here
Zip _
                                       Patricia Krause
                                       Community Involvement Coordinator
                                       Superfund Division (SI-7J)
                                       EPA Region 5
                                       77 W. Jackson Blvd.
                                       Chicago, IL 60604-3590

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   Site-Wide Locations
 Targeted for Remediation
Legend
L   w Aies A
•     | Area B
    2 Estimated Remediation Area
|   _| Proposed Consolidation Area
|      Parcel Boundaries
QTjTnil LMR Scenic Trail - Paved
      Little Mami Rwr
                   1 Featu'e
                       soo
                        I Pert
      125   250
Figure 2 - Map shows site boundaries for Area A, Area B, estimated cleanup areas, consolidation area, Little Miami River
and the LMR scenic trail. EPA's recommended cleanup alternative would excavate and contain polluted soil and sediment
at the Peters Cartridge site.

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&EPA
     United States
     Environmental Protection
     Agency

     Region 5
     Superfund Division (SI-7J)
     77 W. Jackson Blvd.
     Chicago, IL 60604-3590
  PETERS CARTRIDGE  SITE:  EPA Proposes Cleanup Plan
                             Reproduced on Recycled Paper
               EPA
            Proposes
         Cleanup Plan
 For  Former Ammo Plant
          Kings Mills, Ohio

        Public Comment Period
        July 6-August 6, 2009

            Public Meeting
       Wednesday, July 15, 2009

            (details inside)
A snapshot of the
Peters Cartridge cleanup
proposal ...

  • Excavation of soil and sediment
  contaminated with chemical
  concentrations above site-specific
  cleanup levels.
  • Consolidation of excavated soil on
  the site.
  • Construction of a soil cover with
  vegetation over consolidated earth.
  • Removal of debris from stormwater
  culvert.
  • Implementation of institutional
  controls.
  • Estimated total cost is $5 million.

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