vvEPA
www.epa.gov/R5Super
Cleanup and Industrial Revitalization in the Tri-State Region
THE SOUTH POINT PLANT SUPERFUND SITE AND LAWRENCE COUNTY, OHIO
ntroduction
The tri-state region, where Kentucky, Ohio, and West Virginia
come together on the Ohio River, has long been known as one
of the nation's commercial and industrial manufacturing hubs.
Fueled by rich iron, coal, and clay resources and sustained by
direct transportation links and proximity to major markets, the
region's five counties have hosted some of the country's largest
steel, cement, and chemical manufacturing companies.
In the early 1980s, however, the region faced challenging times.
Rising energy costs, an extended economic recession, and the
export of manufacturing operations overseas led to the closure of
many local facilities. In Lawrence County, Ohio, unemployment
approached 20 percent.
Communities' efforts to reverse these trends met several
challenges. Industrial manufacturing had left behind aging
infrastructure and environmental contamination. Combined with
the region's mountainous terrain and extensive floodplains, there
were few sites available that might attract business interest.
The situation in Lawrence County was particularly acute: a 600+-
acre area along the Ohio River next to the Village of South Point
that had hosted munitions, fertilizer, and chemical manufacturing
facilities for four decades was largely idle. Industrial operations
had contaminated soils and ground water. The U.S. Environmental
Protection Agency (EPA) placed the area - the South Point
Plant Superfund site - on its National Priorities List (NPL) of
contaminated sites in September 1984.
Over the next two decades, local governments worked diligently
with each other and with their state and federal partners as part
of a regional economic revitalization effort. One of the signature
accomplishments of this project has been the cleanup and reuse
of the South Point Plant site as The Point, an industrial park with
eight tenants that employs almost 200 people. Future plans for
the facility include additional tenants, expanded facilities, and the
construction of an intermodal facility that will serve as a vital
storage and road, rail, and river transportation resource for the
region.
This case study explores the partnerships and key factors that
have led to the successful cleanup and reuse of the South Point
Lawrence County and the Village of South Point are located in the tri-state
region, where Ohio, Kentucky, and West Virginia come together along the
Ohio River.
Plant Superfund site. In particular, the case study reviews the
lessons learned by local governments, business owners, and state
and federal regulators at The Point. These parties developed
creative solutions to address obstacles and used innovative tools
to create new opportunities that have resulted in local regional
economic revitalization while preserving the protection of human
health and the environment. EPA Region 5, for example, issued
the first Ready for Reuse (RfR) Determination for industrial uses
in the Midwest for the South Point Plant site.
In the following pages, the case study discusses the evolution of
remediation and redevelopment efforts at the South Point Plant
site between its NPL listing in 1984 and ongoing reuse activities
at the site in 2009. This case study is intended to provide relevant
information and lessons learned from the South Point Plant site
to parties with a general interest in Superfund site reuse, as well
as Midwest communities with a particular interest in commercial
and industrial reuse opportunities for local environmentally
impaired properties.
View of the entrance to The Point industrial park in South Point, Ohio, 2008.
I U.S. Environmental Protection Agency
I Superfund Redevelopment Initiative
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South Point Plant Superfund Site, South Point, Ohio
SITE HISTORY, CONTAMINATION, AND REMEDIATION
From 1943 until the late 1990s, manufacturing facilities at the site produced ammonium
nitrate explosives, fertilizers, industrial chemicals, coal pitch pellets, ethanol, and liquid
carbon dioxide. As this photo illustrates, the site was covered by operations buildings,
warehouses, storage tanks, and other structures to support the site's varied manufacturing
activities.
Site operations, waste materials, and four major releases resulted in the contamination
of soil and ground water with volatile and semi-volatile organic compounds, ammonia,
nitrates, and metals like arsenic and cadmium. EPAlisted the site on the National Priorities
List, the Agency's list of top-priority Superfund sites, in September 1984.
Following a risk assessment and remedial investigations, EPA selected a remedy in the site's 1997 Record of Decision. EPA
determined that contaminants were either manufactured or disposed of at five site locations; the majority of the site property was
never contaminated.
Components of the site's remedy include:
the excavation and on-site consolidation and off-site disposal of contaminated site soils;
the placement of a dual barrier cap over the site's Eastern Disposal Area, a 13-acre area located on the site's eastern edge;
surface controls for the site's Northern Fly Ash Ponds;
ground water pumping, containment, monitoring, and discharge into the Ohio River; and
institutional controls that restrict the use of site ground water and stipulate that the site can be used only for commercial/
industrial purposes.
Throughout all site activities, EPA staff met regularly with community stakeholders to share site information and updates and to
incorporate community feedback into the Superfund process. The selected remedy enabled the site to be reused for commercial/
industrial land uses, which EPA had determined to be the site's reasonably anticipated future land use. Cleanup activities at the
site began in May 2001 and the construction of the site's remedy was completed in December 2001.
In May 2006, EPA completed the first Five-Year Review (FYR) for the site. The FYR concluded that the site remedy continues
to be protective of human health and the environment.
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Project History
1983- 1998
Recognizing Opportunities, Building Relationships
In 1983, there were a lot of cooks in the kitchen, and no
coordinated strategy at hand to address the economic hardships
facing the tri-state region. Multiple local organizations,
including two chambers of commerce, were each working to
bring businesses and jobs to Lawrence County. "Our industries
were shutting down left and right and we knew that it was going
to take a lot to bring our economy back," recalled Ralph Kline,
Assistant Executive Director of the Ironton-Lawrence County
Community Action Organization. "We realized that we could
accomplish a lot more if we worked together."
The result was the formation of the Lawrence Economic
Development Corporation (LEDC), a non-profit community
improvement corporation. The LEDC was designated as the
economic development agent for Lawrence County. The
LEDC's original goals - job creation and retention - remain
unchanged today.
While the LEDC developed a toolkit of economic development
tools during the 1980s, it was clear that two key ingredients
would be needed to foster long-term economic development
and revitalization. First, the LEDC needed an inventory of
sites and buildings located in close proximity to transportation
networks and infrastructure. Second, regional coordination
would be needed to attract state and federal resources and link
together vital resources in the tri-state area. For example, the
Port of Huntington, the largest inland port in the United States
by tonnage, is located in Lawrence County.
In this context, one site stood alone. "As the LEDC continued
its work, the idea of developing a premier, world-class industrial
park made more and more sense," said South Point Mayor Bill
Gaskin. "And the property that would become The Point really
stood out. Everyone saw this area as a tremendous potential
opportunity."
Owned at the time by Ashland Oil (later Ashland, Inc.), the
property was centrally located on the Ohio River and offered
more than 500 acres for industrial development. Ashland had
sold an 80-acre portion of the property to an ethanol production
company in 1981 and also operated energy production
facilities, but was unsure of its long-term plans in the tri-state
region. During the late 1980s and 1990s, the LEDC cultivated
a close working relationship with the company, providing
market research and technical assistance to support its efforts
to explore its options at the property.
The LEDC also worked closely with site staff from EPARegion
5 and Ohio EPA during these years, clarifying the property's
status as a Superfund site. "Our priority was making sure that
the agencies understood the value of the site, and that the
community would be able to use this remarkable property for
industrial land uses in the future," stated Dr. Bill Dingus, the
LEDC's Executive Director.
The Lawrence Economic Development Corporation
The Lawrence Economic Development Corporation (LEDC) is a non-profit community organization. The LEDC was formed
in 1983 through the merger of several local economic development organizations and designated as the economic development
agent for Lawrence County. The goals of the agency are job creation and retention. The ownership and development of The
Point is one of LEDC's primary responsibilities.
The LEDC offers several services to area businesses, including:
financing assistance
technical assistance
IĞ resource information
community profiles
industrial development
industrial development bonds
a site and building inventory
The LEDC also administers a city and county-wide revolving
loan fund, as well as a Regional 166 revolving loan fund. The
LEDC is directed by a Board of Trustees, composed of local
elected officials and business leaders.
The LEDC's offices at The Point.
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All told, the LEDC worked patiently with businesses and
state and federal agencies for more than a decade, building
relationships and putting economic development tools and
resources in place. In 1998, all of the organization's patient
preparations began to pay off.
He also noted that, thanks to discussions with EPA and Ohio
EPA, the LEDC and the community's concerns regarding the
site's Superfund status had been addressed. "We knew that
there were portions of the site that would need to be cleaned up,
as well as the site's ground water, and that the vast majority of
the area was not contaminated. The site was also already very
familiar to us - members of our families had worked there for
years. And we knew that the site's PRPs [potentially responsible
parties] would be responsible for the site's cleanup."
Remedial investigations were conducted at the site from 1989
to 1992, with the feasibility study and Record of Decision
(ROD) for the site's remedy completed in 1997. The site's
ROD concluded that "it is reasonably anticipated that future
use at the site will remain industrial."
Timeline of Events
1943: Buckeye Munitions builds South Point Plant for production of ammonium nitrate explosives
1946: Allied Chemical (later Allied Signal and Honeywell International, Inc.) purchases site property
1946-1978: Allied Chemical produces fertilizers and various chemicals at the site
1979: Ashland Oil purchases the site property and operates coal-water fuel pilot plant and pitch prilling test plant
1981-1995: South Point Ethanol (SPE) operates ethanol production facilities on 80-acre portion of the site
1983: Local organizations create the Lawrence Economic Development Corporation (LEDC)
Sept. 1984: EPA lists the site on the NPL
1985-1997: Cardox leases a portion of the site property for liquid carbon dioxide production
Sept. 1997: EPA issues the Record of Decision for the site
1999: Biomass, Inc. acquires the SPE site property and plans to operate a wood/sawdust burning power plant
1999: The area is designated as an Ohio Enterprise Zone and a non-contiguous developable site within the federal
Huntington-Ironton Empowerment Zone
May 2001: Site cleanup begins
2001: The LEDC acquires 504 acres of site property for redevelopment as The Point industrial park
2001-2004: Infrastructure installation and building rehabilitation and construction for The Point
Dec. 2001: Construction of the site's remedy completed
Dec. 2001: First business locates at The Point
July 2002: EPA provides Superfund Redevelopment Initiative and Region 5 reuse planning services for the site
Oct. 2004: EPA issues RfR Determination for The Point
2005: Four businesses are located at The Point
May 2006: EPA completes first Five-Year Review for the site
Sept. 2007: Ohio University Southern opens education and training center at The Point
2009: Eight businesses are located at the point; LEDC plans for intermodal facility at The Point are moving forward
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1998-2004
Laying the Foundation for the Future
When Ashland, Inc. decided to move out of the tri-state region
in 1998, the LEDC opened negotiations with the company to
acquire the property. The LEDC would eventually acquire the
property in 2001, following completion of the site's cleanup,
for $3.86 million. In 1998, however, the LEDC did not have
many resources at its disposal. The three-year transition
period enabled the organization to formalize relationships into
partnerships and leverage the resources needed to make The
Point a reality.
Between 1999 and 2003, the LEDC:
developed a two-phase, community-based master plan for
the industrial reuse of the site property;
coordinated with the Village of South Point, Lawrence
County, and neighboring localities;
identified state agency resources to enable the adaptive
reuse of existing buildings and the construction of shell
buildings at the site;
initiated marketing and outreach efforts to attract
businesses to The Point;
built relationships with regional, state, and federal
organizations and elected officials and pursued state and
federal resources; and
coordinated with U.S. EPA Region 5, Ohio EPA, and site
PRP Honeywell International during the site's cleanup.
The LEDC's activities led to three major outcomes. First, in
1999, The Point was designated as an Ohio Enterprise Zone
and a non-contiguous developable site within the Huntington-
Ironton Empowerment Zone (EZ), state and federal designations
that provided the LEDC with $2.2 million in acquisition funds
and a range of incentives to attract businesses to locate at The
Point. "The EZ designation provided The Point with critical
dollars in the early its development stages for acquisition and
development costs," stated Cathy Burns, Executive Director of
the Empowerment Zone. "EZ funds were the primary funding
source during The Point's first three years of development to
secure title by the LEDC and pay for all environmental expenses
and the master plan. These three steps were critical and had to
be accomplished before other funds could be applied for."
Second, the Village of South Point annexed the site property to
enable the extension of updated water and sewer infrastructure
to The Point. "The site has always been a good place to build
for industry, dating back to the Second World War," noted South
Point Mayor Bill Gaskin. "The Village has always supported
industry at the site, and we plan on continuing to provide
that support into the future. Annexing the site and extending
Community Profile (Part II) - Partners and Grants
The Point was designated as part of the federal Huntington-
Ironton Empowerment Zone in 1999, and is also located in
an Ohio-designated Enterprise Zone. The Empowerment
Zone/Enterprise Community (EZ/EC) program was created
in 1993 to empower economically distressed communities
to create economic development opportunities and jobs in
rural and urban areas. The Huntington-Ironton EZ was one
of 20 communities selected in the program's second round.
I The EZ has provided The Point with $4.8 million in funding
and enabled The Point to leverage an additional $8.5 million
in public and private dollars.
Building on these designations, The Point has received
assistance from diverse organizations and grant resources.
State
Ohio Department of Development (ODOD),
Governor's Office of Appalachia- multiple grants
Ohio General Assembly - CAP-786 Rural Areas
Community Improvements grant
Ohio Valley Regional Development Commission
Federal
Appalachian Regional Commission (ARC) - Area
Development program
U.S. Department of Agriculture (USD A) - Rural
Community Development Initiative program
U.S. Department of Housing and Urban Development
(HUD) - Community Development Block Grant
program and Congressional Grants, EDI-Special
Projects
U.S. Economic Development Administration (EDA)
- Public Works and Economic Development program
Nonprofit
Foundation for the
Tri-State Community
-21st Century
Endowment Fund
fronton-Lawrence
County Community
Action Organization
(ILCAO) - multiple
grants
Southern Ohio
Agricultural
and Community
Development
Foundation (SOACDF)
- multiple grants
EMPOWERMENT
ZONE
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infrastructure several years ago was a key part of that ongoing
effort."
Third, following completion of the site's cleanup in 2001, the
LEDC received reuse planning assistance from EPA Region
5 and EPA's Superfund Redevelopment Initiative in 2002.
Efforts to address future land use considerations at the South
Point Plant site fit well with emerging nationwide interest in
the revitalization of contaminated areas, including Superfund
sites. "The LEDC and the Village of South Point requested our
assistance to address potential stigma or public safety concerns
that prospective businesses might have regarding the site,"
recalled EPA Region 5 Reuse Coordinator Tom Bloom. "They
were highly organized and highly motivated, and we have
worked with them to develop several tools that have supported
the site's reuse while also ensuring that the community's health
is protected."
The Point: Master Plan Overview
In 1999, the LEDC developed a community-based, two-phase Master Plan for the reuse of the South Point Plant Superfund site
as The Point, a premier, world-class industrial park. The Master Plan was a key component of the tri-state region's successful
Huntington-Ironton Empowerment Zone application.
The first phase of the Master Plan has focused on the development of a 185-acre land area located along Commerce Drive, which
extends northwest across the site from The Point's eastern, main entrance, located adjacent to U.S. Route 52. Phase 1 activities
have included road paving, the extension of infrastructure along Commerce Drive, and the adaptive reuse and construction of
three buildings for commercial and industrial users. Development of this land area is ongoing.
The second phase of The Point's Master Plan focuses on the development of intermodal facilities - docks, cranes, forklifts,
storage and loading areas, and other infrastructure - which will connect interstate highways and the Norfolk-Southern rail line
with river barges and container ships on the Ohio River. Other potential components of The Point's second phase of development
include an ethanol production facility or other large-scale manufacturing facility.
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Ready for Reuse (RfR) Determinations:
An Overview
An RfR determination is an environmental status report that
documents a technical determination by EPA, in consultation
with states, tribes, and local governments, that all or a portion
of a site can support specified types of uses and remain
protective of human health and the environment. An RfR
Determination provides potential users of a site with clear
information about the environmental status of a property and
the actions needed to maintain the integrity of the remedy.
Atthe SouthPointPlant Superfund site, the RfR Determination
issued by EPA Region 5 in October 2004 was the second
industrial RfR Determination issued in the country, following
the Tex Tin Superfund site in Texas City, Texas, and the first
issued in the Midwest.
Since 2003, six EPA Regional offices have issued a total of
seventeen RfR Determinations for sites in their Regions, with
as many as seven additional documents currently underway.
Local officials, developers, and EPA staff in Regional offices
say that RfR Determinations have played an important role
in the reuse of sites and serve many beneficial purposes.
Local officials and developers report that they have used RfR
Determinations to improve local economic conditions by
encouraging reuse.
Other sites for which RfR Determinations have been written
include:
Arlington Blending and Packaging (Arlington, TN)
Augustus Hook (Frankfort, IN)
Conroe Creosoting Company (Conroe, TX)
H.O.D. Landfill (Antioch, IL)
Ingram Richardson (Frankfort, IN)
MGM Brakes (Cloverdale, CA)
Midvale Slag (Midvale, UT)
RSR Corporation (Dallas, TX)
Sharon Steel (Midvale, UT)
Southern Maryland Wood Treating (Hollywood, MD)
In 2003, EPA's assistance enabled the development of a toolkit
of communications materials to address stigma and public
safety concerns for the South Point Plant site, as well as an
analysis of reuse opportunities and remedy considerations. The
site's remedy, for example, included institutional controls - a
property deed restriction - instituted by the site's PRPs that
restricted the use of ground water at the site and stipulated that
the site property could only be used for industrial purposes.
In 2004, EPA also developed a Ready for Reuse (RfR)
Determination for the site; the report stated that EPA had
determined that the LEDC's site property was ready for
industrial reuse (see sidebar). "The RfR Determination has
been one of our most powerful tools," said Jeremy Clay, The
Point's Director. "We share it with businesses up front and it
moves them past any site contamination or stigma concerns they
might have. We have financing tools and property incentives
and other resources to help businesses locate here, but the RfR
[Determination] is what makes those discussions possible."
As a result, by the end of 2004, two businesses had located at the
industrial park, citing The Point's location, business incentives,
and building availability, as well as the completed cleanup and
RfR Determination for the South Point Plant Superfund site,
as key factors in their decisions. As Marty Meyer, President of
M&M Service, the first business to locate at The Point, stated
in a 2002 interview, "I can see a large future for this park. The
Point offers opportunities that are difficult to match in this
region. We certainly anticipate being here for the long term."
The Point was openforbusiness. Its expansion and development
could now move forward.
Ready for l\eitsi>
,
'' I'oini
The RfR Determination certificate for the South Point Plant site, on
display at the LEDC's offices.
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2005 - 2009+
Realizing the Possibilities ...
Since the LEDC attracted the first two companies to The Point
in 2004, the roster of companies has expanded to include eight
diverse small businesses, as well as a satellite campus for Ohio
University, which opened a training center at The Point in 2007.
All of the businesses have located within the 185-acre area laid
out in the first phase of The Point's Master Plan.
Many other companies have visited The Point over the past five
years; The Point's Director Jeremy Clay estimates that there are
typically 2-4 companies in leasing or acquisition discussions
with the LEDC at any given time. The business marketing and
outreach process at The Point is now no different from similar
efforts at commercial and industrial parks across the country.
During his interactions with the LEDC, Ohio EPA Project
Manager Kevin O'Hara has noticed several reasons why the
organization may have been so successful in attracting interest
Businesses Located at The Point, 2009
1) American Electrical Power - electric utility
one building, 24 employees
2) Applied Industrial Technologies - industrial products
distributor
1 building, 9 employees
3) Calgon Carbon Corporation - activated carbon and
air/water treatment system manufacturer
1 building, 3 employees
4) Engines, Inc. - parts fabrication and machine shop
services
3 buildings, 90 employees
5) M&M Mailing - direct mail marketing company
1 building, 6 employees
6) M&M Service - service
station equipment
specialist
1 building, 13
employees
7) Mercier's - railroad
right-of-way maintenance)
company
one building, 50
employees
8) Superior Marine Ways
- shipbuilding and
tugboat services
riverfront facility, 9
employees
Businesses at The Point: Applied Industrial Technologies, Engines Inc.,
M&M Mailing, and Mercier's.
in The Point. "Having a dedicated agency like the LEDC
managing The Point is a major plus in the first place," he
stated. "The location of their offices right there at the property
is also a major strength. Their location conveys that the site is
safe and open for business, and that the community welcomes
businesses' interest in the property."
LEDC Executive Director Bill Dingus notes that The Point
explicitly emphasizes the property's Superfund history as part
of its marketing activities and discussions with prospective
businesses. "Since the site was cleaned up [in 2001], we have
marketed The Point's status as part of a Superfund site as a
major plus," he said. "Up front, we let companies know that
the site has been evaluated by U.S. EPA and Ohio EPA, that a
responsible party [Honeywell International] has addressed the
site's contamination and is responsible for the site's remedy,
and that all [the companies] need to be concerned with is
ensuring the appropriate operation of their own facilities. There
is more certainty here regarding site conditions than at most
any greenfield or brownfield in the area, in my opinion."
The Point has also benefited from a unique combination
of geographic and economic factors. "We have been very
fortunate," reflected Ralph Kline from the Ironton-Lawrence
County Community Action Organization. "When this all got
started, I'm not sure that any of us knew just how special and
unique that piece of land was."
In addition to The Point's large, contiguous acreage, proximity
to major markets, out-of-floodplain location, deep water
port frontage on the Ohio River, and access to transportation
networks, the industrial park is also benefiting from ongoing
infrastructure and economic development initiatives in the tri-
state region. These initiatives - including the expansion of the
Heartland Corridor rail network, the expansion of the Port of
Huntington, and the development of intermodal facilities like
the Pritchard Intermodal Park - provide vital support for the
LEDC's future plans for The Point.
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Reuse in Action: M&M Mailing
In 2006, Ken McGuire decided to relocate his business, M&M
Mailing, from West Virginia to SouthPoint, Ohio. "The availability
and pricing of land here at The Point was compelling, and having
utilities available was great," Mr. McGuire said. "Moving to The
Point has significantly reduced the company's operating costs.
Perhaps as important, everyone took an interest and wanted to
work with me. For example, the LEDC helped me get connected
with state and federal programs. There is such a willingness to
work together at The Point."
M&M Mailing opened for business in March 2007; the company
operates out of a 16,000-square-foot facility located along the
eastern edge of The Point. The company is a direct mailing
organization, processing circulars, publications, and billings for
clients nationwide. Other company operations include ink jetting
and bar coding for mail processing.
Since the company relocated to The Point, Mr. McGuire estimates that its revenues have increased approximately seven percent.
"There has been an increase in sales, and a decrease in operational expenses," he stated. "I'm optimistic for the future."
M&M Mailing's future plans include investments in new mailing technologies and expanded services for one of its major
clients, the U.S. Postal Service. The company is also considering leasing or acquiring an adjacent piece of land at The Point,
which would expand its facilities by 5,500 square feet. "We always have plans to grow," said Mr. McGuire. "And we can grow
well at The Point."
According to the LEDC's Executive Director Bill Dingus, The
Point is the finest intermodal transportation site on the Ohio
River between Cincinnati and Pittsburgh. "This property has
always had a remarkable location, dating from when explosives
were manufactured here during the Second World War," he
stated. "And now, if you look at the future of transportation
in this country, that means just-in-time container shipping
deliveries and a return to using our nation's waterways as a
primary transportation network. We are positioned to play a
central part in supporting intermodal transportation on the Ohio
River in the years to come."
... Adapting to Challenges
The successful development of The Point over the past several
years has not sidestepped challenges. While the site property's
status as part of a Superfund site was addressed directly by
EPA's RfR Determination, the LEDC has had to address three
other long-standing issues.
The first challenge has been the development of The Point
around the 80-acre portion of the Superfund site that is owned
by another entity, Biomass, Inc. The company acquired the site
acreage in 1999 to refurbish former power plant facilities for
use as a coal or biomass burning power plant. Due to financing
and permitting issues, the company's plans have not yet been
implemented. The LEDC has addressed the Biomass property
The Heartland Corridor
The Heartland Corridor
is a railroad line that
runs between the Port
of Hampton Roads in
Norfolk, Virginia, through
western Virginia and
southern West Virginia,
to Columbus, Ohio. This
railroad line, owned by
Norfolk Southern, is a
primary route for moving
freight from the East Coast
to the Midwest.
The Norfolk Southern
Corporation is modifying
28 railroad tunnels along the corridorto enable double-stacked
container trains to travel along its entire length. The company
estimates that these modifications will improve transit time
between Norfolk and Chicago and Norfolk and Detroit by
one full day, respectively. The company anticipates that the
project will be completed by 2011.
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by ensuring that infrastructure can be extended to the property
and by continuing to contact the company. "We're not sure
what else we can do in this situation," said Bill Dingus. "We
remain hopeful that we'll be able to work with the company in
the future."
Two other unexpected findings - archaeological resources and
an endangered species - have also required the LEDC's attention
in recent years. An initial property assessment identified 16
archaeological areas requiring further evaluation; The Point
has completed these evaluations and is now coordinating with
the Ohio Historic Preservation Office to excavate and preserve
cultural artifacts. Road construction in 2003 uncovered habitat
for the eastern spadefoot toad at The Point; the LEDC has
developed a management plan for the species that will dedicate
several acres for its habitat.
"We have tried our best to both follow our Master Plan, and
also to respond flexibly when we need to," said The Point's
Director Jeremy Clay. "And with the [archaeological resources
and endangered species], they've had a beneficial effect as well
as being challenging. They've helped prioritize phase 1 areas
for development, while we work to get the other areas ready
as well."
Careful planning. Creative outreach and marketing.
Coordination with local, state, and federal partners. Flexibility.
The end result: the successful redevelopment of The Point
industrial park at the South Point Plant Superfund site.
South Point Training Center
Ohio University Southern, one of five regional campuses of Ohio University, is located in nearby Ironton, Ohio. In 2003, the
University was seeking to locate a satellite campus in the tri-state region. According to Jim Crawford, Director of the University's
Center for Development at the time, "The Point was located where we needed to be, and building our facility there meant that we
could provide training services for the employees of companies located at The Point as well."
The Point's industrial history and contamination were a primary concern for the University. Following meetings with the LEDC
and correspondence with EPA and Ohio EPA, during which the parties reviewed EPA's Preliminary Closeout Report and RfR
Determination for the South Point Plant site, the University determined that the agencies' documentation of the site's contamination,
remediation, and current availability for industrial reuse were sufficient to move forward with the project. According to Ohio EPA
Project Manager Kevin O'Hara, "we were able to field [the University's] questions and walk them through how the site's remedy
had addressed potential health risks at the site. We were able to communicate that, following the site's cleanup, Ohio EPA has not
had any concerns about the protectiveness of the site's remedy."
Following allocation of funding resources for the project, the Ohio University Southern South Point Training Center was
built in 2006-2007, in a partnership between the University, the LEDC, the Lawrence County Chamber of Commerce, and the
Huntington-Ironton Empowerment Zone. The Center's 2,000 square feet include training and conference space, five offices, and
a courtyard. The Center is also connected to the LEDC's offices. The Center opened in September 2007.
In its first year of operation, according to Executive Director Cathy Burns, the Center had training contracts with approximately
20 business clients; the Center also hosted approximately 20 not-for-profit events. "Our plans for the future focus on continuing
to provide off-site training and increasing on-site training," Ms. Burns said. "We also have some space for business incubation.
Overall, we would like to maximize the use of this facility in coming years."
BUSINESS TRAINING
RESOURCE CENTER
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Lessons Learned
Site Specifics
Participants involved at the South Point Plant site agree that a
combination of significant factors have contributed to the site's
cleanup and successful redevelopment.
The site is one of the land areas best suited for industrial
development in the tri-state region.
Local and regional governments worked together
consistently over a long period of time to put in place the
requisite resources, partnerships, and expertise.
EPA and Ohio EPA provided timely reuse planning
assistance for the site as efforts to redevelop the site
property were moving forward.
Localized soil contamination meant that the site's cleanup
could proceed rapidly, with the majority of the site's
acreage never having been affected.
The site's PRPs remain responsible for maintaining the
site's remedy.
EPA had selected a remedy for the site that would be
consistent with the property's reasonably anticipated
future land use.
The Bigger Picture
While these conditions created an ideal climate for the
successful reuse of the South Point Plant site, there are also
a range of broader lessons learned that can help guide similar
projects at contaminated sites throughout the Midwest and
across the country.
Think long-term.
It can take many years to remediate contamination that has
accumulated over decades of site activities. However, this
lengthy process also provides a time window for site stakeholders
to build partnerships and identify resources, coordinate with
EPA and state agencies, and develop a strategy for returning a
site to use while protecting future users. The LEDC was formed
in the early 1980s and worked for more than a decade to put in
place the pieces needed to develop The Point.
Identify the key characteristics of the site and its
surroundings to inform future land use opportunities.
The South Point Plant site was uniquely suited for industrial
redevelopment, in a region with significant industrial resources
and infrastructure. Other Superfund sites may be suited to other
types of land uses. Many sites can also support multiple land
uses, providing an opportunity for communities to address
multiple priorities. For example, many sites are well-suited to
community land uses like community centers and civic areas, as
well as recreational and ecological land uses, that can provide
community-wide amenities.
EPA and Reuse: Lessons Learne
Since the inception of the Superfund program, EPA has been
building on its expertise in conducting site characterization
and remediation to ensure that contamination is not a barrier
to the reuse of property. Today, consideration of future use is
an integral part of EPA's cleanup programs.
"At older sites, EPA did not focus on taking reuse
considerations into account early in the cleanup process,"
reflected Region 5 Homeland Security Advisor Matthew
Mankowski, a former EPA project manager at the site.
"Today, that has changed. Superfund cleanups can be very
creative and flexible in allowing for future site uses, but that
information needs to be plugged in early to be as effective as
possible."
At the South Point Plant site, future land use considerations
were able to inform EPA Region 5's selection of the site's
I remedy, which enabled the site's reuse for industrial purposes.
Site PRP Honeywell International worked with the LEDC
during the site's remedial design, enabling the use of on-site
soils for the site's landfill cap. In return, the PRP regraded
those areas for the LEDC in accordance with The Point's
Master Plan. EPA Region 5 's RfR Determination for the site
provided the community with a tool to address site stigma
concerns.
Thanks to lessons learned at sites like the South Point
Plant site across the country, EPA has developed additional
tools to ensure an integrated approach to the cleanup and
redevelopment of contaminated sites. For example, for sites
like the South Point Plant site, EPA developed its partial
deletions guidance. Partial deletions allow EPA to remove
the cleaned and uncontaminated portions of a Superfund site
from the NPL, expediting the reuse of those properties.
fu
iecond, EPA works with site stakeholders to consider how
iture land use considerations can inform the implementation
and long-term stewardship of site remedies as well as cleanup
planning. At some sites, for example, reuse considerations
can inform the future location of ground water monitoring
wells and other operation and maintenance equipment that
might inadvertently hinder redevelopment efforts. At other
sites, detailed site reuse plans have provided additional
benefits that save time and reduce redevelopment costs. For
example, future infrastructure corridors or building footers
can be installed in coordination with site cleanup activities.
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Engage local governments.
As the organizations responsible for their communities' general
welfare, local governments are particularly well-positioned to
host redevelopmentprojects,bringtogetherdiverse stakeholders
to discuss site reuse opportunities, and use planning tools and
incentives to foster positive site outcomes.
Collaborate and consider local and regional partnerships.
Community-based reuse planning processes can be most
effective when they engage diverse stakeholders, including site
owners and prospective purchasers, are based on detailed site and
community information, and lead to implementable strategies
and next steps. In the tri-state region, local governments in
three states realized that, by working together rather than by
competing against each other, they could develop a regional
economic revitalization plan that harnessed the region's natural
resources and extensive industrial infrastructure.
M&M Service was the first business to locate at The Point. It renovated
two buildings for office and warehouse uses in 2002.
Work with a site's natural features and adaptively reuse
buildings, roads, and other infrastructure.
The South Point Plant site's location out of the floodplain and
proximity to the Ohio River were key factors in the development
of The Point. The LEDC was also able to reduce infrastructure
costs and attract initial business interest by upgrading existing
site infrastructure, including roads and water and sewer lines,
and restoring on-site buildings for immediate reuse. At other
Superfund sites, natural features can be an important part of
recreational and ecological reuse plans, while site buildings
and equipment also often serve as important reminders of a
community's history and heritage.
Access site-related information and recognize opportunities
provided by the Superfund program.
Superfund sites are among the most comprehensively
documented and evaluated areas of land in the United States.
The LEDC markets The Point's status as part of a Superfund
site as an opportunity for companies looking for industrial
space in the tri-state region. At most sites, a completed
remedial investigation/feasibility study, draft proposed plan, or
RfR Determination will provide prospective purchasers with
extensive site information.
Contact and work with site owners, PRPs, and trustees.
The LEDC worked with previous site owner Ashland, Inc.
to acquire the land needed for The Point and continues to
coordinate with Honeywell International, one of the site's
PRPs. According to Manager Chuck Geadelmann, "Honeywell
International maintains a good working relationship with the
LEDC and supports the safe and appropriate reuse of the site
for industrial purposes." At other sites, these parties may be
able to take the lead on a site's cleanup and redevelopment.
Build on past experience.
Parties at the South Point Plant site were charting new territory
in addressing stigma and other site issues. Today, thanks to the
bona fide prospective purchase (BFPP) provisions of the 2001
Brownfields Revitalization Act, environmental insurance, and
EPA tools like RfR Determinations, established resources are
available. Prospective purchasers can contact EPA site teams
to learn more, or see the Resources section on page 13 for
additional information.
Southeast District Office
Logan. Ohio 43138
February ^p 2008
.
ll has come to my attention that your organization recently considered The Point
Industrial Park in Lawrence County, Ohio for the location of a new distribution facility.
Unfortunately, I have also heard that the site was removed from consideration due to
reservations regarding the South Point Plant Superfund site on which the industrial park
was developed. The purpose of this correspondence is to share information with
fl^^Bltfl^decision-makers regarding the extensive actions taken by Ohio EPA and
U.S. EPA to ensure the site is protective of the environment and safe for workers in an
industrial setting.
The Point Industrial Park was once the site of the Buckeye Ordinance industrial facility
which was built in 1943 to produce ammonium nitrate. The plant later produced
ammonia, urea, nitrogen fertilizer, and other nitrogen compounds until 1978. As a result
of those operations, there was nitrate and other limited contamination released to the
soils and groundwater from a few discrete areas of the 600+ acre facility. Due to
proximity to the Village of South Point and potential threat to the village public water
supply, U.S- EPA and Ohio EPA oversaw extensive investigation of the site in the early
to mid 1990's. The investigation identified a few areas of the plant which required
cleanup actions to ensure safe conditions for industrial property use and to prevent
exposure to contaminated groundwater. In 2001, cleanup actions were conducted at
those discrete areas where actions were needed. The Point Industrial Park, as a result
of Ohio EPA and U.S. EPA actions, is a safe area for development and in many ways is
considerably better than other alternatives since there has been extensive investigation
to ensure that potential contamination has been identified and cleaned up.
EPA Region 5 and Ohio EPA continue to work with site
stakeholders to ensure the protectiveness of the site's remedy
and support revitalization outcomes. In February 2008, Ohio
EPA provided this reuse support letter to a prospective business
concerned about The Point's status as part of a Superfund site.
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Conclusions
The timeline of events at the South Point Plant Superfund
site illustrates how the integration of cleanup and reuse
considerations at contaminated areas can result in two
successful outcomes: the protection of human health and the
environment and community revitalization. Over the next few
years at the site, new businesses will continue to locate at The
Point, new jobs and tax revenues will continue to benefit the
Village of South Point and surrounding Lawrence County,
and the industrial park will continue to play a vital role in the
reestablishment of one of the country's preeminent industrial
regions.
In the tri-state region, local governments came together
to share resources, collaborate regionally, and coordinate
closely with the site's owners, potentially responsible parties,
community representatives, and state and federal agencies. In
turn, their initiative has led to new economic opportunities at
the South Point Plant site, and a bright future for surrounding
communities.
SOUTH POINT
View of the Ohio River, looking north from The Point.
Sources and Resources
Sources
Images and maps for this case study were obtained from
EPA Region 5, the Huntington-Ironton Empowerment Zone,
Lawrence County, the LEDC, Ohio University Southern,
The Point industrial park, the Village of South Point, and a
December 2008 site visit.
Resources
EPA site progress profile:
cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0504434
EPA Superfund Redevelopment Initiative:
www.epa.gov/superfund/programs/recycle/index.htm
2001 Brownfields Revitalization Act and BFPP information:
www.epa.gov/brownfields/html-doc/2869sum.htm
Environmental insurance information:
www.epa.gov/brownfields/insurebf.htm
Huntington-Ironton Empowerment Zone:
www.empowerwv-oh.org
Ironton-Lawrence County Community Action Organization:
www.ilcao.org
Lawrence County (includes The Point and the LEDC):
www.lawrencecountyoliio.org
Ohio University Southern:
www.southern.olTiou.edu
Village of South Point:
www.villageofsouthpoint.com
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&EPA
United States
Environmental Protection
Agency
EPA Region 5
77 West Jackson Boulevard
Chicago, IL
May 2009
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