&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. ------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- &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. ------- |