*>EPA
United States
Environmental Protection
Agency
Public Participation
EPA will open a 30-day public comment
period from June 24th to July 24th' 2013
for the community to state their opinions
about the clean up strategy for
contaminated sediment adjacent to the
C&D facility and source areas within the
facility. If enough interest is shown, EPA
will also schedule a public meeting to
present the clean up alternatives,
proposed cleanup plan, answer questions
and accept oral comments.
After consideration of public comments,
EPA will select a final cleanup plan and
discuss the selection in a document
called "final decision and response to
comments". Public comments will be
summarized and responses provided as
part of the decision.
If you have any comments or would like
to request additional information on the
C&D facility, please contact:
Bhooma Sundar
EPA Project Manager
312-886-1660
sundar.bhooma@epa.gov
Rafael Gonzalez
Public Affairs Specialist
312-886-0269
gonzalez.rafaelp@epa.gov
Region 5 toll-free: 800-621-8431,
8:30 am - 4:30 pm, weekdays
Documents Available
The Statement of Basis and other official
documents about this site can be viewed
at the Attica Public Library,
305 S. Perry St, Attica, IN 47918 or
through the internet at URL:
http://www.epa.gov/region5/cleanup/rcra
/cdtechnologies/index.html
Environmental Cleanup at
C&D Technologies	
EPA RCRA Corrective Action
Attica, IN	June2013
U.S. Environmental Protection Agency Region 5 has a Resource
Conservation and Recovery Act (RCRA) Consent Order with C&D
Technologies (C&D or the Facility) to investigate and cleanup releases of
hazardous waste at its Plant located in Attica, IN. EPA is proposing a plan
to clean up to address contaminated soil and its potential effects on
surface water, ground water and soil gas at the Facility and an
adjacent area bordering the Wabash River in Attica, Indiana.
This fact sheet is a summary of an official EPA document called a
Statement of Basis. The document describes a range of proposed
cleanup alternatives and EPA's preferred options for the C&D
facility. EPA will select the final cleanup plan for the soil and
sediment after considering comments from the public. The final plan
could differ from this proposed plan, depending on information or
comments EPA receives during the public comment period.
About the C&D Technologies Site
C&D owns and operates a battery manufacturing plant at 200 West
Main Street in the City of Attica, Fountain County, Indiana. The
Facility contains an active battery manufacturing area, a former
landfill, and riverbank property along the Wabash River. The
Facility is located on approximately 12.5 acres in the north-
northwestern portion of the city. The Wabash River borders the
Facility on the west and northwest. Residential and commercial
properties surround the remaining sides of the Facility.
The Attica plant manufactures lead acid batteries for commercial,
industrial and military applications. Manufacturing processes
include casting or curing lead battery parts, pasting battery grids,
plate processing, battery assembling, charging and finishing. The
Facility is located in the Wabash River Valley, which is underlain
by approximately 140 feet of unconsolidated deposits containing
sand and gravel. Groundwater production wells owned by the City
of Attica are located approximately 300 to 400 feet to the southwest
of the site.
Pollution Investigations
In January 2007, EPA Region 5 and C&D entered into a RCRA
Section 3008(h) Corrective Action Order (Corrective Action Order)
that required C&D to investigate and address all historic releases of
hazardous waste and constituents at or from the site. C&D collected
and analyzed groundwater, surface water, sediment, soil, sub-slab
soil gas and indoor air samples.

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Investigators found elevated levels of metals in the
soil, sediment and underground water. Most of the
hot spots could be traced to sewers and waste
material storage areas and the Riverbank Area.
Some of the contaminants involved were metals
such as lead, arsenic and cadmium. Solvents such
as trichloroethylene and tetrachloroethylene were
found in sub slab soil gas with a potential for
indoor vapor intrusion in former waste and
container storage room.
Summary of Site Risks
After the pollution investigation, a human health
risk assessment was performed to determine the
health problems that could result if contamination
at the facility was not cleaned up. A key
assumption of the health assessment was that
future use of the property will be restricted to
industrial activity. Health risks were then
calculated for routine exposures to the pollution by
industrial workers who would be present on the
property over many years.
The health assessment computes the chances of
developing an additional case of cancer from the
contamination found in soil. Unfortunately, zero
risk is impossible to achieve in the highly
industrialized United States.EPA sets an
acceptable risk range as 1-in-a million chance of
getting cancer from pollution to 1-in -ten-
thousand.
For this cleanup project, EPA selected Indiana
standards that land on the midpoint of EPA's
acceptable cancer target limits. If contaminants are
not cancer causing chemicals but cause other
health problems, EPA uses what is called a hazard
quotient. To be acceptable to the Agency, the
hazard quotient for individual chemicals must be
less than one. Sections of the facility with
contaminants that exceed Indiana's cleanup
standards will be cleaned up or the pollution
adequately shielded to protect human health and
environment.
The human health risk evaluated for receptors
from the residential and commercial properties
surrounding the site did not indicate any risk based
on the Indiana cleanup standards.
EPA determined from the baseline ecological risk
assessment that there are potential adverse
ecological effects at the Riverbank soil due to soil
erosion or surface water run-off from the C&D
facility. EPA did not identify any site-related
contaminants in surface water or sediment in the
Wabash River. One of the monitoring wells from
the site showed a potential for lead from the
groundwater to discharge to the Wabash River.
Cleanup goals
Considering the anticipated industrial use of the
property, the goals for the corrective measures
proposed for the areas within the facility are to
protect workers health. The ecological clean up
goals are designed to protect the sensitive receptors
such as Short Tailed Shrew and American Robin at
the Wabash River bank area near the C&D facility.
A long term monitoring plan for under- ground
water will also be part of the cleanup plan to
ensure that the river is protected from lead
contamination. The city drinking water is
currently treated due to the contamination from a
distant source.
Cleanup alternatives
Clean up alternatives were developed for three
areas of concern: on site soil contamination,
primarily concentrated in four separate hot spots in
former hazardous waste storage areas; sub-slab soil
gas contamination at the former waste and dust
storage area and storm sewer; and the Wabash
River bank area owned by the C&D facility.
On-site soil hotspot remedial options
Alternative 1- No further Action. This option is a
baseline scenario to which the other options may
be compared. Under this option, EPA would not
require C&D to conduct a remedial action to
mitigate potential lead and arsenic exposure from
the surface soil to facility workers. Cost: $0
Alternative 2 - Land use restrictions and
engineering controls such as pavement and soil
cover. (EPA's preferred alternative) Under this
alternative, engineering controls would include
maintaining the present concrete surface cover to
shield the workers from lead and arsenic exposure.

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This option also includes paving the uncovered
surface soil with concrete consistent with other
paved areas at the facility.
Cost: $ 10,000
On-site soil vapor intrusion remedial
options
Alternative 1: No further Action. This option is a
baseline scenario to which the other options may be
compared. Under this option, EPA would not
require C&D to conduct a remedial action to
mitigate potential lead and arsenic exposure from
the surface soil to facility workers. Cost: $0
Alternative 2 - Excavation and Offsite Disposal
of Contaminated Soil: C&D will leave soils
contaminated with PCE and TCE beneath active
manufacturing areas in place. C&D will excavate
accessible soil to a depth of five feet below ground
surface and dispose an estimated volume of 231
cubic yards. Cost: $91,500
Alternative 3 - Soil Vapor Extraction (SVE) and
capping (no off-gas treatment): C&D will use this
in-situ remedial technology to reduce
concentrations of VOCs adsorbed to soils in the
unsaturated (vadose) zone. The SVE system will
utilize three extraction wells screened across the
shallow contaminated zone to maximize soil vapor
collection. C&D estimated that a 20ft effective
radius of influence will be around each SVE well.
The extracted vapors from each SVE well would be
released in to the atmosphere without treatment. As
established by an enforceable institutional control,
C&D will conduct routine monitoring and will
maintain the integrity of the concrete foundation
slab. Cost: $95,000
Alternative 4 - Soil Vapor Extraction (SVE) with
off-gas treatment: C&D will use this in-situ
remedial technology to reduce concentrations of
VOCs adsorbed to soils in the unsaturated (vadose)
zone. C&D will treat the extracted vapors
discharged over time with an appropriate vapor
treatment system (activated carbon) before
discharging to the atmosphere. The existing
concrete foundation slab in Area 9 will continue to
serve as the cap and C&D will conduct routine
monitoring and will maintain the integrity of the
concrete foundation slab. Cost: $105,000
Alternative 5 - Excavation and Off- site Disposal
and SVE: With this alternative, C&D will excavate
contaminated soil from the outdoor alleyway and
dispose of the soil off-site at an EPA approved
landfill. C&D will backfill the excavated area with
clean fill and restore the area to the pre-excavation
condition. C&D will use a modified a SVE system
to treat PCE and TCE contaminated soils that are
not excavated from beneath the active
manufacturing areas. As established by an
enforceable institutional control, C&D will conduct
routine monitoring and will maintain the integrity of
the concrete foundation slab. Cost: $165,000
River Bank Area Remedial Alternatives
Alternative 1 - No Further Action: EPA would
not require C&D to conduct a remedial action to
mitigate potential metal exposure to ecological
receptors. Cost: $ 0
Alternative 2 - Immobilization and Exposure
Barrier: This alternative involves excavation of
lead contaminated soil and on-site treatment
(immobilization) with Triple Super Phosphate
(TSP). C&D will place treated soil back in the
excavation footprint and cover the soil with an
exposure barrier. C&D will construct the exposure
barrier with a permeable geo-textile fabric covered
with appropriately sized riprap. Such a measure will
aid in bank stabilization and erosion control. As
established by an enforceable institutional control,
C&D will conduct routine monitoring and will
maintain the integrity of the geo-textile exposure
barrier. Cost: $76,500
Alternative 3 - On-Site Treatment and Off-Site
Disposal with Exposure Barriers: This alternative
involves excavation of lead contaminated soil, on-
site treatment (immobilization), and off-site
disposal at an EPA approved landfill. The C&D
proposed excavation Area covers 800 square feet.
Approximately 30 cubic yards of contaminated soil
will be removed for off-site disposal.
Cost: $ 88,000
Alternative 4 - Exposure Barrier: This alternative
involves construction of an exposure barrier to
contain and isolate lead-contaminated soils
associated with a hotspot. C&D will construct the

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exposure barrier to cover approximately 800 square
feet of the Riverbank Area. C&D will construct the
cap using a permeable geo-textile fabric overlain
with riprap. As established by an enforceable
institutional control, C&D will conduct routine
monitoring and will maintain the integrity of the
geo-textile exposure barrier. Cost: $61,000
Evaluation of Alternatives
Each of the cleanup alternatives was evaluated
against nine criteria listed in the box on the back
page. All of the cleanup options would protect
human health and the environment. On-site soil hot
spot removal alternative 2 is preferred since the
remedy protects facility workers exposure to soil
and also prevent migration of soil contaminants to
groundwater. For on-site soil vapor intrusion
remedy, alternative 4 is preferred since it would
reduce the release of VOCs in the soil to
groundwater, indoor air and outdoor air. For
Riverbank Area, alternative 4 is preferred since the
exposure barrier would protect the ecologically
sensitive receptors from the metal contamination in
the surface soil.
EPA's proposed Cleanup Plan
On-site hotspot removal. EPA's proposed remedy
for onsite soil hot spot contamination is to prevent
the human exposure by either constructing the
pavement and/or maintaining surface cover
(Alternative 2). The proposed remedy also includes
an enforceable institutional control requiring routine
inspection and maintenance to ensure the integrity
of the exposure barrier.
On-site soil vapor intrusion: EPA's proposed
remedy for Area 9 and 4 is SVE and capping with
off- gas Treatment (Alternative 4). C&D will use
in-situ remediation technology to reduce PCE and
TCE concentration in the soil underneath the
manufacturing building. Approximately 2.4 to 5
pounds of PCE and 8 to 16 pounds of TCE are
present in the subsurface soil in Area 9 and 4. The
SVE system will utilize three extraction wells
screened across the shallow contaminated zone to
maximize soil vapor collection. Treatment will
continue until the soil vapor levels do not exceed
the IDEM IDCL of 880 |ig/m3 of TCE. The PCE
level in the soil gas is already below the IDEM
IDCL of 17,500 ug/m3.C&D will treat the extracted
vapor if necessary (based on the nature,
concentration, and total mass discharged over time)
with an appropriate vapor treatment system
(activated carbon) before discharging to the
atmosphere. With the exception of well installation,
C&D will not modify the existing concrete
foundation slab in Area 9 so that the existing slab
will continue to serve as the cap. During system
operation, C&D will monitor influent soil gas vapor
concentrations on a routine basis. C&D will pave
areas where surface soil contamination exceeds the
IDEM groundwater protection criteria. The paved
area would act as an exposure barrier to workers
and limit infiltration of precipitation into the
subsurface. The proposed remedy also includes an
enforceable institutional control requiring routine
inspection and maintenance to ensure the integrity
of the exposure barrier.
River Bank Area: EPA's proposed remedy for the
Riverbank Area is construction of an exposure
barrier (Alternative 4). This barrier will have
minimal impact to the native soils and will help
stabilize the stream bank and prevent erosion. Prior
to construction, C&D will remove the understory
vegetation and visible surface debris from the work
area. Since mature trees are present with in the
footprint of the exposure barrier, C&D will cut and
fit the geo-textile around the base of each tree.
Riprap will be placed over the geo-textile fabric.
Riprap will be sized based on the velocity of the
Wabash River during flood stage. During
installation, soil will be trenched along the hillside
at the base of the work area to provide a base and
reduce the potential for erosion during the flood
events. In addition, riprap on the upstream and
downstream sides of the exposure barrier will also
be keyed in to prevent dislodging. C&D will
conduct routine inspections of the exposure barrier
after heavy rain or flood events.
Groundwater Monitoring: C&D will sample and
analyze monitoring well 4S twice a year for metals.
Monitoring will continue until the lead level in
groundwater does not exceed the IDEM RDCL for
two consecutive rounds six months apart.

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EPA proposes
Clean up plan
For Polluted
Soil
C&D Technologies,
Attica, IN
C&D Technologies Site: EPA proposes Clean up Plan
Evaluation criteria
The proposed cleanup alternatives discussed
inside this fact sheet for the C&D Technologies
were evaluated against these nine criteria:
1.
Overall protection (determines

whether the option protects human

health and the environment by

eliminating, reducing or controlling

pollutants).
2.
Attaining cleanup standards.
3.
Controlling pollutant releases.
4.
Compliance with waste

management standards (disposal of

the waste must meet state and federal

regulations).
5.
Long-term effectiveness.
6.
Reduction of toxicity, mobility or

volume of contaminated waste.
7.
Short-term effectiveness.
8.
Implementability (how easy can the

cleanup option be installed given
\7trn
United States
Environmental Protection
Agency
Region 5
Office of Public 11> i*m
77 w. Jackson Blvd.
Ctllcaw, II 60604-3590

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Use This Space to Write Your Comments
EPA is interested in your opinion about the proposed cleanup plan for the C&D Technologies site. You may use
the space below to write your comments. Please detach the sheet, fold, stamp and mail to Rafael P. Gonzalez at
the EPA. Comments must be postmarked by July 24th, 2013. If you have any questions, please contact Rafael
directly at 312-886-0269, or toll free at 800-621-8431, 9:30 a.m. - 5:30 p.m., week days. Comments may also
be faxed to 312-582-5865 or sent via the Internet at URL:
http://www.epa.gov/region5/cleanup/rcra/cdtechnologies/index.html
Name	
Affiliation	
Address	
City	State	ZIP

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C&D Technologies Comment Sheet
fold
fold
Place
First
Class
Postage
Rafael P. Gonzalez
EPA Public Affairs Specialist
Land and Chemicals Division
(LU-9J)
EPA Region 5
77 W. Jackson Blvd.
Chicago, IL 60604-3590

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