®EFA	EPA Proposes Cleanup Plan

ST1™"	for Polluted Industrial Site

Chemical Recovery Systems Inc.

Elyria, Ohio	July 2007

Public comment period

EPA will accept written comments
on its proposed cleanup plan during
a public comment period from July
16 to Aug. 14, 2007. This fact sheet
provides a pre-addressed form for
you to send to EPA, or you can fax,
mail, or use a special EPA Web site
(www.epa.gov/region5/publiccomment/
crs-pubcomment.htm) to make
comments. Comments must be
postmarked no later than Aug. 14.

Public meeting

EPA will hold a public meeting to
explain and answer questions about
its proposed cleanup plan. We will
also accept oral and written
comments at the meeting.

Date: July 26, 2007
Time: 6 p.m.

Place: Elyria City Hall

City Council Chambers
2nd Floor
131 Court St.

If you need special
accommodations to attend this
meeting, please contact Susan
Pastor at least one week prior to the
meeting, toll-free at:

800-621-8431, Ext. 31325
weekdays, 10 a.m. - 5:30 p.m.

EPA Web site

This fact sheet and other related
documents can be found at:

www.epa.gov/region5/sites/crs

The entrance to the former solvent reclamation facility at the Chemical
Recovery Systems Inc. site.

To contain pollution on a former industrial location in Elyria, Ohio, U.S.
Environmental Protection Agency is proposing to place a soil cover over
the site and also dig up and dispose of the most contaminated debris lying
in the northwest corner of the property. These actions should keep
chemicals from moving into a nearby river and underground water supplies
(called ground water in environmental terms). This proposal is one of seven
alternatives considered for managing pollution at the Chemical Recovery
Systems Inc. site and preventing humans and wildlife from coming into
contact with hazardous chemicals. The seven alternatives are described in
more detail later in this fact sheet.

EPA will pick one of the alternatives as the official cleanup plan after a
public meeting and 30-day public comment period. The selected alternative
will be published in a local newspaper notice and in an EPA document
called the record of decision. These proposed cleanup measures' will be
presented at a public meeting on Thursday, July 26, in Elyria, and people
will have until Aug. 14 to submit written comments about the proposed
plan (see box, left). EPA could alter the proposed cleanup plan further, pick
another alternative or even develop a new plan based on public comments.

'Section 111(d) of the Comprehensive Environmental Response. Compensation, and Liability Act
(CERCLA known as the Superfund law) requires publication of a notice and a proposed plan for site
cleanup. The proposed plan must also be made available to the public for comment. This fact sheet
summarizes information in the remedial investigation, feasibility study, and technical proposed plan
documents in the administrative record for the CRS site. Please consult these documents for more
detailed information.


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EPA examined the protectiveness, costs and effectiveness
of each of the cleanup alternatives and decided its
recommended option is a $1.7 million plan that calls for
covering 2 acres of the site with 2 feet of clean soil. Also,
the most highly contaminated soil in the northwest corner
will be excavated and backfilled with clean material plus 2
feet of clean soil so that contamination levels will no
longer pose a health threat to people or wildlife. Two
abandoned buildings on the site will also be torn down and
the riverbank graded and covered with erosion control
material under the proposed cleanup plan. Hazardous
ground water will also be monitored, and legal controls
will be placed on the site to prevent using the ground
water until it is safe and to prohibit digging into the cover
system without approval from EPA.

Health risks to people and the environment

Health risks from the CRS site if nothing is done are
mainly to industrial employees who could work there in
the future. These people have the potential of being
exposed to the harmful chemicals in the soil by accidental
swallowing, skin contact, and breathing hazardous gases
released by the site (if a building was placed on top of the
soil).

Scientists conducted an extensive study to find out what
the health risks could be for people who are exposed to
pollution on the CRS site. The study, called a health risk
assessment, assumed the site will continue to be used for
industrial and commercial purposes and not for homes that
will draw their drinking water from private wells. The
health study found that if the contamination is not
contained, employees working on-site for many years at
some future industrial facility would face a slightly higher-
than-normal risk for getting cancer and non-cancer
illnesses from the chemicals in the soil.



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A map of Elyria showing the location of the CRS site.

or surface water of the nearby East Branch of the Black
River.

About Chemical Recovery Systems Inc.

The site covers about 2.5 acres on a peninsula in the East
Branch of the Black River in an industrial-commercial area
near the central business district of Elyria. Currently the
site is owned by an Obitts family trust and is leased to
M&M Aluminum Siding Co.

The only structures remaining at the location are a
warehouse-office and the shell of a former still building.
The site is fenced except for the portion facing the steep
riverbank.

The most harmful chemicals include arsenic, benzene,
tetrachloroethylene (known as PCE) and trichloroethylene
(TCE). Scientists said people could be exposed to the
pollution through incidental swallowing of dirt, skin
contact, and inhaling soil gases that seep into buildings.
The risk assessment found slightly lower cancer and non-
cancer health risks for construction workers who may
happen to work on the site temporarily. Those risks were
still too high to be considered safe if nothing is done. The
health study also considered whether children trespassing
on the site would be in danger from the pollution but
concluded their risks were low.

The health risk study found site contamination in the soil
could also negatively affect animals. The river also had
some contamination, but the levels were below state
standards for fish that live around or in the mud (sediment)

Russell Obitts operated two companies on the site from
1960 to 1974 that obtained used solvents from other
businesses and then recycled them using a distilling
process. The solvent reclamation operations continued
under Chemical Recovery Systems Inc. from 1974 to
1981.

The location first came to the attention of Ohio EPA in
1978 when it appeared pollution from the site was
affecting the East Branch of the Black River. In 1980 EPA
became involved when it filed a lawsuit against CRS. In
1981, in response to the lawsuit, CRS stopped operations
and removed tanks, drums and containers from the site.
The company then filed for bankruptcy. Pollution studies
were done throughout the 1980s and "90s. In 2003, a
remedial investigation and feasibility study was done. The
studies showed soil and ground water were contaminated

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with a variety of chemicals and metals at levels considered
unsafe if people or wildlife were exposed to them over
many years.

Cleanup options

EPA set three cleanup goals for the CRS site:

•	Reduce the health risk posed by direct contact with
polluted soil and site debris;

•	Reduce further pollution from contaminating surface
and ground water; and

•	Restore the ground water so it meets Safe Drinking
Water Act standards.

The Agency looked at seven alternatives for meeting these
goals. The alternatives were compared with the nine
evaluation criteria set by federal regulation (see box on
Page 4).

Several actions will take place under all the options under
consideration: The two existing buildings on the site will
be demolished and the concrete and brick crushed and
used for fill. Metal, glass and asbestos-containing debris
from the buildings will be separated and disposed of off-
site. Wood chips and dead vegetation near the former
storage tank area will also be disposed of off-site, and the
entire location will be covered with 2 feet of clean soil,
graded and seeded. The sloping riverbank of the Black
River will also be graded and have erosion protection
applied. A new fence will be placed around the site, and
restrictions put in place to ensure future uses of the
location remain commercial-industrial and not residential.
A process called "natural attenuation" (by which a
contaminant degrades over a period of time) will allow the
chemicals in the ground water to degrade. The ground
water will be monitored for 30 years to make sure the
chemicals are degrading.

Here is a summary of the seven cleanup options:

Alternative 1 - No action: A no action alternative is
always included in all EPA proposed cleanup plans as a
comparison point for the other options. Cost - $0

Alternative 2 - Soil cover with partial geo-synthetic
membrane: This alternative consists of a 4-foot soil cover
over 2 acres plus a "geo-synthetic membrane" (plastic
liner) and soil combination covering the half-acre
northwest corner of the site. Cost - $1.3 million

Alternative 3 - Stone cover with partial geo-synthetic
membrane: This alternative consists of a 1-foot-thick
stone cover over 2 acres with fabric underneath and with a
soil cover and liner laid over the remaining half acre. Cost
- $1.3 million

Alternative 4 - Asphalt cover with partial geo-synthetic
membrane: Under this alternative, a cover consisting of 6
inches of gravel and 4 inches of asphalt along with
geotextile fabric would cover the 2-acre parcel with the
soil and liner laid over the remaining half acre.

Cost - $1.4 million

Alternative 5 - Concrete cover with partial geo-
synthetic membrane: This cover would consist of 6
inches of gravel and 4 inches of concrete over the 2-acre
area with the soil cover and liner laid over the remaining
half acre. Cost - $1.4 million

Alternative 6 - Soil cover with excavation and disposal:

(This is EPA's recommended cleanup plan) This
alternative consists of a 2-foot-thick soil cover over the
site to eliminate direct contact by people or wildlife with
the hazardous chemicals in the soil. The most
contaminated soil in the half-acre hot spot in the northwest
portion of the site would also be excavated and disposed of
off-site. Cost - $1.7 million.

Alternative 7 -Excavation and disposal: Under this
alternative, the entire 2.5 acres would be dug up and
disposed of in an off-site waste disposal facility instead of
containing and managing the chemical pollutants. The site
would then be backfilled with clean material and seeded.
Cost - $7.9 million (for disposal at a municipal waste
facility) $24 million (if disposal is required at a hazardous
waste facility)

Evaluation of Alternatives

EPA evaluated each cleanup alternative against the nine
criteria required by the Superfund regulation (see the
comparison chart on Page 7). The community acceptance
criterion will be evaluated after public comments are
received and the public meeting held.

All of the various kinds of covers proposed for the site
would protect people and the environment. Alternative 6,
soil cover and excavation, was selected as the best, most
cost-effective cleanup option.

Alternatives 2-5 would protect the public and wildlife from
direct contact with the site contaminants, but are not as
effective as Alternative 6 in preventing further
contamination to the ground water.

Every trace of pollution cannot be eliminated, but under
Alternative 6, EPA would remove contaminated soil to a
depth of 4 feet where the most highly contaminated soil is
found in the northwest corner. After soil removal, samples
would be collected and analyzed to determine the level of
contamination remaining, if any, after excavation. The

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excavation would also prevent rain and surface runoff
from soaking through the soil and moving contamination
down into the underground water.

The ground water would be monitored until the

concentrations of all contaminants of concern reach safe
drinking water standards.

Alternative 7, excavating and removing all the pollutants,
would also be effective but would be much more
expensive than the other options.

Next steps

EPA, in consultation with Ohio EPA, will evaluate public
comments received during the comment period before
choosing a final cleanup plan. EPA will respond to
comments in a document called a "'responsiveness
summary." This document is attached to the record of
decision, which will outline the final cleanup plan.

EPA will publish a notice in the local newspaper when the
final cleanup plan is selected and send copies of the
decision document to the locations on Page 7. It will also
be posted on EPA's Web page. After a final cleanup plan
is chosen, it will be designed and implemented.

For more information

For more information about the CRS site cleanup, please
contact:

Susan Pastor

EPA Community Involvement Coordinator
312-353-1325 or 800-621-8431
fax 312-353-1155

pastor.susan@epa.gov

Gwendolyn S. Massenburg
EPA Remedial Project Manager
312-886-0983 or 800-621-8431
fax 312-886-4071

massenburg.gwcndolyn@cpa.gov

Larry Antonelli
Site Coordinator

Ohio EPA Division of Emergency and Remedial Response

Ohio Northeast District Office

330-963-1127

larry.antonelli@epa.state.oh.us


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Use This Space to Write Your Comments

EPA is interested in your comments on the proposed cleanup plan for the Chemical Recovery
Systems Inc. site. You may use the space below to write your comments. You may submit
this at the July 26 public meeting, or detach, fold, stamp and mail to Susan Pastor. Comments
must be postmarked by Aug. 14. If you have any questions, please contact Susan directly at
312-353-1325, or toll free at 800-621-8431, weekdays 10 a.m. - 5:30 p.m. Comments may
also be faxed to Susan at 312-353-1155 or sent by the Internet at
www.epa.gov/region5/publiccomment/crs-pubcomment.htm.

Name	

Affiliation	

Address	

City	State	ZIP

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Chemical Recovery Systems Inc. Comment Sheet

fold

fold

Place
First
Class
Postage
Here

Susan Pastor

EPA Community Involvement Coordinator

Office of Public Affairs (P-19J)

EPA Region 5

77 W. Jackson Blvd.

Chicago, IL 60604-3590


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Comparison of Cleanup Alternatives

Evaluation Criteria

Alternative

1

2

3

4

5

6

7

1. Overall protection of Human 1 lealth and
the Environment

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2. Compliance with ARARs

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3. Long-Term Effectiveness and Permanence

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4. Reduction of Toxicity, Mobility, and
Volume Through Treatment

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5. Short-Term Effectiveness

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6. Implementability

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7. Cost - Capital Construction Cost

(including 30-yr. operation & maintenance
period of approx. $50,000 annually)

$0

$1.3

million

$1.3

million

$1.4
million

$1.4

million

$1.7

million

$7.9-$24

million*

8. State Acceptance

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9. Community Acceptance

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~Does not meet criteria BPartially meets criteria ¦Fully meets criteria TBI): To be determined after public

comment period.















**I>ust produced during demolition, excavation and regrading of the CRS site is temporary with short-term exposure.

*Smaller amount is for disposal at a municipal facility;

larger amount is for disposal at a hazardous waste facility.

A soil vapor extraction treatment system was also evaluated to treat the "'hot spot" area located in the northwest corner.

However, it was determined that SVE had a high potential for being inefficient and problematic.





Site-related documents may be reviewed at:

Elyria Public Library

11 T 1 *	,	i

320 Washington Ave,

Ohio EPA Northeast District Office

2110 E. Aurora Road
Twinsburg, Ohio

EPA Region 5 Record Center

S-7/-T TT 7- T 1	T\1 1 ^»th ri

77 W Jackson Blvd., 7 Floor
Chicago, 111.

Certain information, including the record of decision, proposed plan and this fact sheet will be available
electronically at: www.epa.gov/region5/sites/ers.

An administrative record, which contains detailed information upon which the selection of the cleanup plan will be
based, is also located at the library and at EPA's Chicago office.

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