UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
STATEMENT OF BASIS
FORMER CARBOLINE COMPANY
125 Fairgrounds Road
Xenia, OH 45385
EPA ID No.: OHD030963615
April 2017
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U.S. ENVIRONMENTAL PROTECTION AGENCY
STATEMENT OF BASIS
Former Carboline Company
125 Fairgrounds Road
Xenia, OH 45385
EPA ID#: OHD 030 963 615
INTRODUCTION
This Statement of Basis for the Former Carboline Company (Carboline) facility in Xenia, Ohio
discusses the past remedial actions that have taken place at the facility and explains the remedy
proposed by the United States Environmental Protection Agency (EPA) to address residual
contamination at the facility. EPA will select the final remedy for the facility only after the
public comment period has ended and EPA has carefully reviewed and considered the
information submitted by the public.
EPA is issuing this Statement of Basis as part of its public participation responsibilities under the
Resource Conservation and Recovery Act (RCRA). The public comment period begins on
5/30/2017 and ends on 6/30/2017. This document summarizes information found in greater
detail in the Report on Subsurface Investigation dated June 1992; the Preliminary Assessment
and Visual Facility Inspection (PA/VSI) Report dated November 1992 completed by PRC
Environmental Management (PRC), on behalf of EPA; the Ohio Cessation of Regulated
Operations (CRO) Final Inspection Letter dated March 14, 2001; the Facility Inspection Letter
Report dated April 2009 written by Hull and Associates, on behalf of Brownfield Restoration
Group, LLC; the Final Field Sampling Activity Report for Carboline Company, Xenia, Ohio
written by TechLaw, Inc., on behalf of EPA, in November 2011; and other documents in this
facility's Administrative Record. EPA and the State of Ohio encourage the public to review
these documents in order to gain a more comprehensive understanding of the facility and the
corrective actions conducted by past owners Carboline and RPM, Inc. (RPM). Xenia Township
Board of Trustees is the current owner of the property.
EPA may modify the proposed remedy or select another remedy based on public comments or
new information. Therefore, EPA encourages the public to review and comment on the
Statement of Basis. Documents upon which this proposal is based are available for public
review at the EPA Region 5 in Chicago, Illinois, and locally at the Xenia Community Library.
EPA has provided specific details on these locations and viewing hours at the end of this
document. If citizens request a public meeting, EPA will publish a newspaper notice of the
meeting prior to the meeting date.
PROPOSED REMEDY
EPA is proposing that the owner should implement the following remedy to address
contaminated soils at the Facility:
• Establish institutional controls at the Former Carboline facility to limit current and future
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land uses to those consistent with industrial or commercial activities and protect
construction workers from exposure to contaminated subsurface soils at two areas of the
Facility.
• Provide Financial assurance to ensure remedies are implemented and maintained.
FACILITY BACKGROUND
The Carboline facility is located in the northern portion of the City of Xenia, Greene County,
Ohio. The entire Carboline facility comprises approximately 7.5 acres; it is relatively flat in the
northeastern portion of the facility and slopes to the south in the southwestern portion of the
facility. The facility is bordered on the north by the Greene County fairgrounds and a residential
area, on the west by a residential area and Saint Brigid's School (K-8), on the southwest by
Shawnee Creek, and on the east by Greene, Inc., a small nonprofit corporation providing
vocational and rehabilitation services to the community.
The earliest available land use records for the Carboline facility indicate that a farm implement
dealer conducted commercial activities on the facility between 1944 and 1950. In 1953, the
Moran Paint Company of Xenia, Ohio (Moran) initiated operations involving manufacturing of
paint finishes for the automotive and appliance industries. Carboline purchased the facility in
1963, and continued manufacturing products under the Moran name. A historic facility layout
map can be found as Attachment A and a current facility map is Attachment B.
Carboline specialized in manufacturing epoxy coatings. The facility blended various grades of
liquid and solid paint materials and solvents to match the specifications of a particular order.
The manufacturing process consisted of milling and high speed dispersal of raw materials (i.e.,
pigments, fillers, solvents, resins, and other additives) into a liquid or paste. Carboline stored
approximately 700 different virgin chemicals at the facility for production purposes.
Sun Chemical Company purchased Carboline in 1980, and later sold the Moran product line in
1982 (paint finishes for the automotive and appliance industries). Sun Chemical continued the
same manufacturing operations at the facility for the remaining products. In 1986, Sun Chemical
sold the assets of the Carboline Division to RPM, who continued manufacturing operations until
it closed the facility in December 2000. RPM sold the property to Cherokee BBI, LLC
(Cherokee) in July 2001. Mr. Ken Weaver bought the property from Cherokee on December 10,
2006. Xenia Township Board of Trustees, Greene County, OH, 8 Brush Row Rd, Xenia OH
45385, bought the six properties from Ken Weaver on July 28, 2016.
When in active operation, the Carboline facility consisted of four primary buildings: raw
materials and product storage warehouse, a three-story manufacturing building, dry pigment
warehouses, and an office building. The storage building on the northwestern side of the facility
was destroyed by a tornado between 2005 and 2008.
The former tenants are Elsome Trucking and Seek & Destroy Paint Ball (SDPB) (Attachment B,
Current Facility Layout). Elsome Trucking was in business from April 2005 through December
2008. Elsome Trucking utilized the front office building and the large parking area to the west
of the office. SDPB was in business from June 2006 through October 2009. The paint ball
company utilized the former dry pigment warehouse and western half of the facility. Heart of
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Ohio All Stars utilized the former dry pigment warehouse. Heart of Ohio All Stars was a
competitive cheerleading and dance training service. Heart of Ohio All Stars was in business at
the facility from May 2010 through January 2014. Trophy Sports Center (TSC), was in business
at the facility from September 2013 to June 2016. TSC customized sports apparel and products
for business. TSC utilized the former dry pigment warehouse in the back of the facility for
storage.
Hydrogeologic Setting
The soils at the facility consist of a clay rich glacial till that is approximately 20 to 40 feet thick
with occasional sand and gravel lenses. The soils have low permeability and may have a
seasonally high water table. These glacial outwash deposits are underlain by thin bedded
limestones and calcareous shales of the upper Ordovician Richmond group. Precipitation,
averaging approximately six inches annually, is the major recharge mechanism for groundwater
in the area. People in the Xenia area use groundwater as a primary source for both industrial and
municipal water. The City obtains its drinking water from well fields located approximately 1.8
miles northeast of the facility. Surface water at the facility drains to stormwater sewers that
empty into Shawnee Creek.
Ecological Setting
The facility is 7.5 acres in size and used for industrial operations since 1944. The facility is
relatively flat in the northeastern portion of the facility and slopes to the south in the
southwestern portion of the facility. The ground surface, where not covered by roads, concrete
pads, or buildings, has been disturbed and is of such poor quality the vegetation growing on-
facility consists primarily of invasive and opportunistic herbaceous and wood plants. In general,
the limited on-site habitats have been heavily influenced by historical land use. Although there
are no permanent aquatic habitats on-site, Shawnee Creek borders the Facility to the southwest.
RCRA Regulatory History
During active manufacturing operations, the facility generated multiple RCRA hazardous waste
streams, including waste paint thinners, waste paint materials, and dust from miscellaneous
sources. At the peak of production, Carboline was generating approximately 180 tons of waste
paint thinner and 95 tons of other waste paint materials per year.
In July 1981, Carboline submitted a Notification of Regulated Waste Activity form and Part A
permit application indicating its status as a RCRA treatment, storage, or disposal facility (TSDF)
to the EPA. RCRA hazardous waste codes ("codes") Carboline identified on the application
included D001, D005, D007, D008, F003, F005, K078, K079, K081, K082, U002, U013, U031,
U069, U088, U102, U112, U124, U125, U140, U154, U159, U160, U161, U169, U220, U238,
and U239. According to the application, these wastes were occasionally stored at the Hazardous
Waste Storage Area and in the D-Waste Storage Tank for longer than 90 days. On March 31,
1982, EPA sent a letter to the facility requesting that it prepare and submit a full RCRA Part B
permit application. In late 1982, Carboline representatives notified EPA that Carboline removed
hazardous wastes previously stored at the Hazardous Waste Storage Area, and that Carboline
closed the unit in accordance with RCRA requirements. Carboline also stated that it removed all
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accumulated waste paint from the facility and requested that its Part A permit application be
withdrawn. On April 1, 1985, the Ohio EPA (OEPA) granted Carboline a change in its RCRA
status from a TSDF to a hazardous waste large quantity generator, allowing for only less-than-
90-day waste accumulation. Accordingly, EPA rescinded its request for submittal of the
Carboline Part B permit application.
Interim Measures
Remediation work was performed in the past at six solid waste management units (SWMUs) and
three areas of concern (AOCs) at the site:
SWMU 1: Baghouse
SWMU 2: Hazardous Waste Storage Area
SWMU 3: D-Waste Storage Tank
SWMU 4: F-Waste Storage Tank
SWMU 5: Kettle Cleaning Area
SWMU 6: Back Pad
AOC 1: Solvent Blending Tank Area
AOC 2: National Pollutant Discharge Elimination System (NPDES) Outfall
AOC 3: Burn Pit Area
Before the former owner of the Carboline facility, RPM Inc., ceased operation at the facility in
December 2000, it conducted area-specific closure, corrective action, and inspection efforts in
several locations. OEPA issued a Final Inspection Letter on March 14, 2001, that indicated that
"all contaminated equipment, structures, and soil were properly disposed of or decontaminated"
during the final closure period and that "hazardous wastes [generated during closure activities]
were handled in accordance with all applicable [RCRA] requirements." The OEPA inspection
did not identify any further violations of Ohio Cessation of Regulated Operations (CRO) laws.
INVESTIGATION RESULTS
Carboline and subsequent owners investigated and mitigated any risks posed by SWMUs 1, 3, 4,
5, 6 and AOC 1 and 2, and two other areas (two stormwater discharge outfalls and AOC 3). The
EPA reviewed the facility files and determined that based upon sampling data collected at the
facility surface water and groundwater were not a concern. Pursuant to EPA review, SWMU 2, a
Hazardous Waste Storage Area, and AOC 3, a Burn Pit Area, were identified as areas of concern.
SWMU 2, Hazardous Waste Storage Area: According to available documentation, all hazardous
wastes stored at SWMU 2 (150 feet by 175 feet) were removed in late 1982, and Carboline
decommissioned and closed the unit in accordance with RCRA regulations. Hazardous waste
that was stored included waste paint thinners/codes F001, F003, and F005; waste paint
materials/codes F003, F005, D001, D005, D007, and D008; miscellaneous dust/chromium/code
D007; and lead/code D008. Carboline secured a professional engineer who certified this closure
and OEPA approved the closure in 1984.
OEPA issued a Final Inspection Letter on March 14, 2001, that indicated that "all contaminated
equipment, structures, and soil were properly disposed of or decontaminated" during the final
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closure period at SWMU 2, and that "hazardous wastes [generated during closure activities] were
handled in accordance with all applicable [RCRA] requirements." The OEPA inspection did not
identify any further violations of Ohio CRO laws. A subsequent inspection conducted by Hull
and Associates in early 2009 at the facility's request found no stained soil, distressed vegetation,
or other contamination indicators for the former storage area at SWMU2.
EPA soil sampling conducted in April 2011, at SWMU 2, did not find concentrations of
contaminates of concern above EPA's RSL for industrial soils (Attachment C). One surface soil
sample, CC-S2-SS-02, showed antimony at 58 milligrams per kilogram (mg/kg), which is above
the EPA RSL for residential soils of 31 milligrams per kilogram, but below the RSL for
industrial soils of 410 micrograms per kilogram. The area of SWMU-2 is well vegetated, which
limits direct contact.
SWMU 3, D-Waste Storage Tank: RCRA D coded wastes, or D-wastes, are wastes that exhibit
the characteristics of ignitability, corrosivity, reactivity, or toxicity. According to available
documentation, Carboline emptied the tank associated with SWMU 3 and drummed and shipped
the residuals to Envirosafe in Oregon, Ohio for disposal (Carboline Company Final Cessation of
Regulated Operations Inspection, OEPA March 2001). Carboline then cut the tank into pieces,
and shipped the scrap metal to Xenia Iron and Metal on April 29, 1993. Carboline contracted
with IT Corporation to formally "clean close" the tank and surrounding area pursuant to the
requirements of RCRA. Carboline submitted appropriate final closure documentation on
removal of regulated substances and equipment from SWMU 3 to OEPA in November 2000. A
Final Inspection Letter issued by OEPA on March 14, 2001, indicates that "all contaminated
equipment, structures, and soil were properly disposed of or decontaminated" during the final
closure period at SWMU 3, and that "hazardous wastes [generated during closure activities] were
handled in accordance with all applicable [RCRA] requirements." The OEPA inspection did not
identify any violations of Ohio CRO laws and no soil staining that "would warrant further
investigation". A Hull and Associates subsequent inspection conducted in early 2009 found no
stained soil, distressed vegetation, or other contamination indicators at the former SWMU 3 tank
location. TechLaw in April 2011 collected surface soil and subsurface soil samples in SWMU 3
area; the contractor did not report any contaminants of concern above residential or industrial
soil RSLs.
AOC 3, Burn Pit Area: In 1997, Carboline discovered a former burn pit on site during
installation of new sewer lines. OHM Remediation Corporation (OHM) performed an
environmental site investigation of the area in May 1997. OHM detected lead and
poly chlorinated biphenyls (PCBs) in soil samples at concentrations that exceeded OEPA
Voluntary Action Program (VAP) cleanup standards. Carboline conducted four rounds of
excavation to remove impacted soil and ash between May 15 and November 13, 1997.
Carboline properly disposed of all excavated materials off site. OHM conducted confirmation
soil sampling which showed that residual PCB of 2.6 parts per million (ppm) and lead
concentrations were below detection limits and applicable OEPA VAP cleanup standards. The
OEPA VAP industrial cleanup standard for PCBs is 18 ppm. Carboline backfilled and re-graded
the area. EPA's industrial soil cleanup standard for PCB is up to 25 ppm without a barrier. The
chemical highlighted in Table 1 indicates that the samples results were above the EPA Regional
Screening Level.
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After an initial review of the facility records, EPA conducted further sampling to investigate the
areas of SWMUs 2 and 3, and AOC 3 (the Burn Pit Area) through its contractor, TechLaw, Inc.
Specific details of this investigation are contained in the discussions below. EPA contractor
TechLaw collected 18 soil samples at the former Carboline facility on April 26 and 27, 2011
(Attachment C). TechLaw collected samples to evaluate if releases to environmental media
occurred as a result of historical operations at the Carboline facility, and whether contaminants
of concern were present at concentrations which exceed applicable EPA Regional Screening
Levels (RSLs), including both residential and industrial standards. In SWMU 2, the metal
antimony was detected above the EPA RSL for residential use. In AOC 3, PCBs were detected
above the EPA RSL for residential use. EPA contractor Booz Allen Hamilton re-sampled four
locations in AOC 3 for dioxin and furans, where results from the 2011 sampling found PCB
concentrations above the EPA RSL for PCBs. Dioxin and Furans were not detected above the
EPA RSL. See Table 1, Soil Analytical Results, below for the results of TechLaw's and Booz
Allen Hamilton's analysis.
Table 1: Regional Screening Levels Summary of Soil Sample Results
Location
Chemical or
Metal
Sample
Result
Residential
Standard
Industrial
Standard
Basis of Standard
SWMU 2
Antimony
58 mg/kg
31 mg/kg
410 mg/kg
EPA Regional Screening Level
AOC 3
PCB 1254
0.00463
mg/kg
0.001 mg/kg
Up to 25 ppm
without a barrier
40 CFR§761.61(a)(4)(i)(A) and
(B)
For a routine
worker, the limit
is 18 mg/kg
(Table II).
For a construction
worker it is 42
mg/kg (Table III).
15 OAC rule 3745-300-08(C)(3)
AOC 3
PCB 1260
0.00077
mg/kg
0.001 mg/kg
up to 25 ppm
without a barrier
40 CFR§761.61(a)(4)(i)(A) and
(B)
For a routine
worker, the limit
is 18 mg/kg
(Table II).
For a construction
worker it is 42
mg/kg (Table III).
15 OAC rule 3745-300-08(C)(3)
AOC 3
Dioxin/Furans
39.5ng/kg
50 ppt-TEQ
Under a future
industrial land use
only condition,
the current EPA
risk protective
screening level is
640 ppt-TEQ
which applies to
an on-site worker.
EPA Regional Screening Level
Dibenz(a,h)
Anthracene
AOC 3
302 ug/kg
0.015 mg/kg
0.210 mg/kg
EPA Regional Screening Level
mg/kg = mi
ligram per kilogram
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ppm = parts per million
|ig/kg = micrograms per kilogram
ng/kg = nanogram per kilogram
TEQ = Toxic Equivalent
ppt = parts per trillion
SUMMARY OF FACILITY RISKS
EPA allows owners or operators of facilities regulated under RCRA to perform site-specific risk
assessments to evaluate any human health risks posed by residual site contaminants, and to
provide a basis for management of any risks found. The risk assessment will express the risk
resulting from cancer-causing compounds as a probability; for example, a risk quantified as one
in one million is a risk level at which one additional person in one million would develop cancer
due to exposure to the compound. Risk assessments express non-cancer causing risks as a
hazard quotient or hazard index, with the sum of the hazard quotients representing the total
hazard.
Alternatively, owners or operators who detect concentrations of site contaminants can compare
the concentrations to risk-based standards for soil, groundwater, surface water, and sediment
under specific land use scenarios. Residential and industrial land uses are the two scenarios EPA
most commonly considers for human health risk assessment purposes. Under the industrial land
use scenario, EPA expects workers to be routinely exposed to contaminated media within a
commercial area or industrial facility. EPA estimated levels of risk include the possibility of
heavy equipment usage and traffic, and resultant dust generation and surface disturbance in the
vicinity of contaminated soil. However, EPA generally limits industrial risks to adult receptors
and considers a limited (albeit lengthy) exposure duration (i.e., exposures over a typical 40-hour
work week and over the limited years associated with an individual's average lifetime work
span). For residential land use scenarios, EPA expects residents to be more frequently and
repeatedly exposed to contaminated media. Residential exposures consider potential impacts to
both adults and children in daily contact with the contaminants over a lifetime. Residential
scenarios commonly result in the highest levels of potential exposure and, accordingly, the most
stringent cleanup criteria.
HUMAN HEALTH RISKS - SOIL - GROUNDWATER- SEDIMENTS - SURFACE WATER
EPA used risk based standards for the industrial scenario to support decision-making at the
former Carboline facility. The current and anticipated future use of the facility is industrial.
EPA summarized the risks associated with the former Carboline facility below by location.
SWMU1 (Baghouse): The PA/VSI report recommended no further action for this area, and
EPA's investigation and review of facility documentation did not identify any risks in SWMU 1.
The current property occupants do not use this area.
SWMU 2 (Hazardous Waste Storage Area): The PA/VSI Report indicated that Carboline did not
conduct a site-specific soil investigation. A Final Inspection Letter issued by OEPA on March
14, 2001, indicates that "all contaminated equipment, structures, and soil were properly disposed
of or decontaminated" during the final closure period at SWMU 2, and that "hazardous wastes
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[generated during closure activities] were handled in accordance with all applicable [RCRA]
requirements." The inspection further identified no violations of Ohio CRO laws. In order to
confirm the conditions at SWMU 2, in April 2011, EPA contractor TechLaw collected surface
soil and subsurface soil from the SWMU 2 area. The area was observed to be well vegetated.
These samples contained several analytes with concentrations above the laboratory reporting
limits, with one metal and one SVOC detected above residential soil RSLs in two surface soil
samples. Specifically, in surface soil sample CC-S2-SS-02, the result of 58 mg/kg antimony
exceeded the residential soil RSL of 31 mg/kg. The industrial screening level for antimony is 410
mg/kg and was not exceeded in any soil sample. In surface soil sample CC-S2-SS-01, 87.6
ug/kg benzo(a)pyrene exceeded the residential soil RSL of 15 ug/kg. The industrial screening
levels for benzo(a)pyrene is 2,100 ug/kg and was not exceeded in any soil sample. EPA's
investigation and review of facility documentation identified residual risks applicable to
residential uses in SWMU 2.
SWMU 3 (D-Waste Storage Tank): In April 2011, EPA contractor TechLaw collected surface
soil and subsurface soil samples in SWMU 3. The area was observed to be well vegetated.
These samples contained several analytes above the laboratory reporting limits, but no analytes
were reported above residential or industrial soil RSLs. EPA's investigation and review of
facility documentation did not identify any risks in SWMU 3.
SWMU 4 (F-Waste Storage Tank): The PA/VSI report recommended no further action for this
area, and EPA's investigation and review of facility documentation did not identify any risks in
SWMU 4.
SWMU 5 (Kettle Cleaning Area) : The PA/VSI report recommended no further action for this
area, and EPA's investigation and review of facility documentation did not identify any risks in
SWMU 5.
SWMU 6 (Back Pad): Given satisfactory inspection results and Carboline's contention that
Carboline never used the Back Pad for hazardous waste storage, EPA determined that no further
RCRA action is necessary for this SWMU. EPA's investigation and review of facility
documentation did not identify any risks in SWMU 6.
AOC 1 (Solvent Blending Tank Area) : The only significant release of hazardous constituents
from this AOC took place as a result of the March 1992 spill of MEK. The OEPA investigation
conducted as part of the spill cleanup effort confirmed that there were no exceedances of OEPA
VAP standards for the three VOCs detected in surface soil. Furthermore, Carboline did not
detect VOCs in a groundwater sample collected in the vicinity of the spill. The investigation
also determined that significant impacts to soil at depth (i.e., below 2.5 feet below ground
surface) were unlikely. EPA's investigation and review of facility documentation did not
identify any risks in AOC 1.
AOC 2 (NPDES Outfall): OEPA inspection results show that no spills were ever conveyed to
Shawnee Creek through the NPDES Outfall. EPA's investigation and review of facility
documentation did not identify any risks in AOC 2.
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Underground Storage Tanks: Based on the lack of evidence suggesting previous releases from
these tanks, and based on the fact that the tanks were removed prior to RCRA regulation, EPA
determined that no further action was necessary.
Building No. 6: OEPA did not require further action in this area. EPA's investigation and
review of facility documentation did not identify any risks in Building No. 6.
AOC 3 (Burn Pit Area): Confirmation soil sampling by Carboline conducted after excavation of
contaminated soil and ash indicated concentrations below the OEPA VAP cleanup standards for
soil. In April 2011, EPA's contractor TechLaw sampled surface and subsurface soils in the burn
area. TechLaw collected four surface soil samples at 0-1 foot depth and two subsurface soil
samples at two to three feet depth which had concentrations of PCBs above EPA's RSL for
industrial soil of 0.7 ppm, but less than the 40 CFR§ 761.61(a)(4)(i)(A)(B) standard of up to 25
ppm, without a barrier. EPA found one surface soil and one subsurface soil sample to have
Dibenz(a,h)anthracene above the RSL for industrial soil. The human health risk associated with
an industrial worker for Dibenz(a,h)anthracene was calculated by using the maximum
concentration of 0.3 mg/kg. Dibenz(a,h)anthracene has an excess cancer risks of 1.4"06 and does
not have a hazard quotient number. EPA calculated the excess cancer risk from sample data with
a result of 8.6 "6 and a hazard quotient of 0.42. The cumulative excess cancer risk is below l"05,
so therefore the risk due to exposure from residual contamination is acceptable if this area
continues to remain in a commercial industrial land use.
On September 14, 2013, EPA's contractor Booze Allen Hamilton re-sampled four locations in
AOC 3, the Burn Pit Area, for dioxin and furans. When PCBs burn, dioxins and furans can be
produced during combustion. Four surface samples collected at 0-1 foot depth and two
subsurface soils collected at two to three feet depth in the burn area showed concentrations of
PCB's were above residential and industrial EPA's RSL for soils (See Attachment D).
EPA conducts risk assessment based on the future use, which in this case was assumed exposure
to industrial workers at a frequency of 250 days for 25 years. EPA chose the maximum
concentration it observed in surface soil and subsurface soil for each COC as the exposure point
concentration for the facility so as to compensate for the uncertainty due to the number of
sampling locations (four surface and two subsurface samples in AOC 3). Dioxin/furan data are
analyzed and reported as a mixture of 17 toxic congeners. EPA does not have a numerical
toxicity factor for each congener. Instead, the Agency uses a system in which each congener is
assigned a "Toxic Equivalence Factor" (TEF) for comparison to the most toxic congener, which
is 2,3,7,8-tetrachlorodibenzo-para-dioxin (2378-TCDD). 2378-TCDD has been assigned a TEF
of 1.0 and the other congeners have been assigned TEF values ranging from 0.0003 up to 1.0.
The mixture of congeners in a soil/waste sample is assigned a Toxic Equivalent (TEQ)
Concentration by multiplying the reported concentration of each congener by its TEF value and
summing up the results. The resulting TEQ concentrations were compared to EPA's risk
screening concentration for soil under specific scenarios, for example, the residential land use
and industrial land use scenarios.
The data was compared to the risk protective EPA soil screening level of 50 part per trillion (ppt)
TEQ based on residential land use. The 50 ppt-TEQ level is considered protective for a child
who could potentially be exposed to contaminated soil on a daily basis (i.e., 350 days/year) with
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no consideration for reduced frequency due to local climate conditions. Under a future industrial
land use only condition, the current EPA risk protective screening level is 640 ppt-TEQ and
applies to an on-site worker. The surface and subsurface soil samples analyzed for dioxin/furan
were not above the TEQs for residential land use and industrial land use scenarios.
ECOLOGICAL RISK
EPA used the soil sampling results for the facility and the ecological screening levels to
determine the potential for adverse ecological risks at the facility. To do this, EPA compared the
maximum level detected for each contaminant of potential ecological concern (COPEC) to the
screening levels for contaminants in particular substances (soil, sediment, water) that are known
to cause harmful effects in plants or animals. By comparing known, maximum concentrations of
contaminants at a site to screening levels, the possibility of ecological risk can be estimated
through a hazard quotient (HQ). If the numerical comparison results in a HQ that is greater than
one (1.0), the potential for ecological risk by that COPEC is present and further study is needed
to clarify that risk. The benchmark values are significantly conservative so that chemicals
detected at concentrations below the benchmarks are not expected to exhibit significant
ecological effects, even if fully bioavailable.
Table 2 includes the calculations of HQs. Those COPECs and HQs that are highlighted indicate
HQs above 1.0. The areas found to have HQs higher than 1.0 are discussed in the "Risk
Characterization" section below.
Table 2: Ecological Hazard Quotient Summary of Soil Sample Results
Area Name
Contaminant
Highest
Ecological Screening Level
Basis of
Hazard
of Concern
Level
Standard
Quotient
(OPEC)
detected
SWMU-2
Antimony
58 mg/kg
78 mg/kg soil invertebrates
Eco-SSLs
0.74
10 mg/kg herbivores
5.8
0.27 mg.kg insectivore
214.81
4.9 mg/kg carnivore
11.84
AOC 3
PCB 1254
4.63 ug/kg
0.332 ug/kg
R5ESLs
13.95
AOC 3
PCB 1260
0.77 ug/kg
0.332 ug/kg
R5ESLs
2.32
AOC 3
Dibenz(a,h)
302 ug/kg
18,400 ug/kg
R5 ESLs
0.016
anthracene
mg/kg = milligram per kilogram
|ig/kg = micrograms per kilogram
Eco-SSLs = Ecological-Site Screening Levels
R5 ESLs = Region 5 Ecological Screening Levels
Exposure Pathways and Potential Receptors
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Soil
Based on the information provided, the facility appears to provide only low quality terrestrial
(land) habitat that may be utilized by common urban/suburban wildlife (e.g., sparrows, robins,
blue jays, field mice or voles, etc.). The primary potential receptors of organic contaminants in
soil would be worm-eaters such as robins or raccoons. The exposure pathway includes ingestion
of bioaccumulated substances in earthworms and incidental ingestion of soil. Insectivores (an
air-breathing invertebrate animal arthropod with a body that has well-defined segments,
including a head, thorax, abdomen, two antennae, three pairs of legs, and usually two sets of
wings) could be exposed by eating the earthworms is another pathway for exposure to soil
bioaccumulative contaminants. The facility is located by Shawnee Creek, so soil erosion could
result in transport of particle-bound contaminants to the creek ecosystem.
Sediment
The use of the adjacent Shawnee creek by wildlife is possible. The primary receptors of creek
sediment contaminants would be benthic invertebrates and rooted aquatic plants. Fish (if
present) could be exposed through eating benthic invertebrates, consumption of plants, and
ingestion of sediments. Terrestrial organisms (e.g., raccoons, herons, kingfishers) could be
exposed to bioaccumulative contaminants through consumption of fish or larger benthic
invertebrates; and insect-eating animals such as swallows and bats might be exposed through
preying on emergent aquatic insects (i.e., insects that have aquatic stages in their life-cycles).
Surface Water
The primary pathways are direct exposure and bioaccumulation. Terrestrial receptors could be
exposed directly through drinking, and indirectly through consumption of aquatic organisms.
Historical spills into Shawnee Creek would have had minimal impact to the surface water due to
the type of contaminates released (e.g., volatile compounds such as solvents), which would have
volatized or photo decomposed soon after the spill.
Groundwater
Groundwater contaminants can become potential ecological concerns when they discharge to
surface waters, the Shawnee Creek in this case. Groundwater samples at the facility, however,
did not show any contaminants above the EPA's maximum contaminant levels.
Threatened and Endangered Species
A Section 7 review of the listed Threatened and Endangered (T&E) species in Greene County
did list four endangered species and one candidate species. Three of the endangered species are
mussels. Given the close proximity of Shawnee Creek to the facility, EPA contacted the United
States Fish and Wildlife Service (U.S. FWS) and the Ohio Department of Natural Resources
(ODNR) directly to obtain input on the potential presence of these species within site influences.
The U.S. FWS determined that the following endangered species and/or habitat were within two
miles of the facility: Indiana bat (Myotis sodalist), rayed bean (Villosa fabalis), snuffbox
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((Epioblasma triquetra), and Clubshell (Pleurobeme clava) mussels. The U.S. FWS determined
that the following federal candidate species, the eastern massasauga (Sistrurus catenatus), a small
rattlesnake, was in the range of the facility. The ODNR determined the Arnoglossum
plantagineum-Fen Indian-plantain and Zigadenus elegans-White Wand-lily are the only rare
species within one mile of the facility, and neither were found in Shawnee Creek.
Risk Characterization
As presented in Table 2 above, antimony and PCBs were the only constituents found to exceed
their respective ecological soil screening levels. Antimony screening levels were exceeded in
one area in SWMU 2, and the exceedance appears to present potential adverse risks to four
ecological receptors. However, antimony was only detected in one surface soil sample on-site.
Furthermore, in view of the limited size of the impacted area of concern (approximately 10 feet
by 10 feet), EPA has determined that the potential risk is low. EPA also found that PCBs were
detected in soil samples in the Burn Pit area. Likewise, EPA has determined that the potential
risk is low due to the limited size of the impacted area of concern (approximately 100 feet by 100
feet).
SCOPE OF CORRECTIVE ACTION
EPA's short-term goals for this site are:
• All current human exposures to contamination at or from the Facility must be under
control. That is, significant or unacceptable exposures do not exist for all media known
or reasonably suspected to be contaminated with hazardous wastes or hazardous
constituents above risk-based levels, for which there are complete pathways between
contamination and human receptors.
• Migration of contaminated groundwater at or from the Facility must be stabilized. That
is, the migration of all groundwater known or reasonably suspected to be contaminated
with hazardous wastes or hazardous constituents above acceptable levels is stabilized to
remain within any existing areas of contamination as defined by monitoring locations
designated at the time of the demonstration. In addition, any discharge of groundwater to
surface water is either insignificant or currently acceptable according to an appropriate
interim assessment.
EPA's short-term goals have already been achieved. August 11, 2009, EPA determined that both
RCRA Corrective Action Environmental Indicator (EI) RCRIS code (CA725) Current Human
Exposures Under Control and RCRIS code (CA750) Migration of Contaminated Groundwater
Under Control had been achieved.
EPA's long-term goals for the remedy being proposed are:
Protecting human health and the environment and
establishing and maintaining Institutional Controls
As a result of past cleanup actions described above, and the determination that the most likely
future use scenario for the facility is industrial, EPA believes that no additional remediation is
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required at the former Carboline facility. Based on the remaining risks identified above, EPA
determined that appropriate corrective action objectives for the former Carboline facility include
maintaining industrial and/or commercial land uses across portions of the facility previously
occupied by SWMU 2 and AOC 3, and preventing contact with and/or exposure to any residual
contamination that may be present in subsurface soil in these locations above unrestricted,
residential risk-based concentrations.
EPA's proposed remedy for the Carboline facility is establishing and maintaining institutional
controls for the areas formerly occupied by SWMU 2 and AOC 3. For these portions of the
property, the owner of the facility will design and implement institutional controls to: (1) ensure
that the land use will remain industrial or commercial; (2) ensure that current and future owners
or operators will not change the land use to residential unless they conduct further investigation
and conduct any necessary cleanup actions; (3) prevent unauthorized excavation or disturbance
of potentially impacted subsurface soil, and maintain a vegetative cover; and (4) ensure that
access to the facility is restricted by maintaining the existing fence. EPA anticipates that the
current owner will prepare a Declaration of Covenant and Restriction for these locations, and
that the owner will record the deed in the Greene County Recorder's Office in Xenia, Ohio.
EPA has determined that the remaining portions of the Carboline facility do not require land use
controls because there was no release of hazardous constituents or because Carboline has already
satisfactorily cleaned up the soils and EPA does not require additional corrective action in those
areas. Similarly, EPA has not identified any contamination in groundwater, or surface water at
the Carboline facility; therefore, EPA does not require corrective actions for these media.
SUMMARY OF ALTERNATIVES
EPA has not identified any reasonable alternatives to the proposed remedy due to the limited
nature of any residual environmental contamination at the Carboline facility and the progress that
Carboline and RPM has already made toward environmental cleanup.
No Further Action
The "No Action" alternative is not a reasonable option because it would fail to meet the
corrective action objectives EPA identified above in the event that any residual contamination
above unrestricted residential use levels remains in soil at this facility.
Proposed Remedy:
• Establish institutional controls at the former Carboline facility to limit current and future
land uses to those consistent with industrial or commercial activities and protect
construction workers from exposure to contaminated subsurface soils at two areas of the
Facility.
• Financial assurance to ensure remedies can be implemented and maintained.
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EVALUATION OF THE PROPOSED REMEDY (WITH NO ALTERNATIVES)
EPA has expectations for remediation against which corrective measures being considered are
evaluated against prior to final remedy selection. As outlined below, the EPA proposed remedy
for the Carboline facility adequately addresses these criteria.
1. Protect human health and the environment:
Carboline removed contaminated equipment, structures, soils and wastes from the facility
during prior closure and corrective action activities (see above). Based on all available
information, EPA determined that any residual soil contamination will not pose any
unacceptable risk to human health and the environment if the land use remains industrial in
the areas formerly occupied by SWMU 2 and AOC 3.
2. Achieve media cleanup objectives:
Investigations, monitoring and corrective actions taken by former owners of the facility
resulted in OEPA's approval of closure of most of the facility's SWMUs and AOCs. EPA's
sampling of on-site soils demonstrated that the contaminants found remaining at the facility
were below the industrial RSLs, so media cleanup objectives have been met. EPA
determined that no significant unevaluated areas of contamination remain at the Carboline
facility. Therefore, implementation of EPA's proposed institutional controls is an
appropriate approach for preventing unacceptable exposure to potential residual contaminant
concentrations in subsurface soil at SWMU 2 and AOC 3. The proposed institutional
controls will assure that these areas of the facility stay in industrial/commercial land usage
only, and not for residential use.
3. Control the source of the release to prevent further releases at levels that may pose a
threat to human health or the environment:
Carboline removed the most highly contaminated equipment, structures, and soils from the
Carboline facility during historic RCRA closure and cleanup activities. Groundwater was
sampled at AOC 1 and was found to contain no detectable VOCs. Based on the absence of
groundwater contamination above media cleanup objectives, EPA does not consider any
residual contamination in soil at the Carboline facility to be an ongoing source of
groundwater impacts. The proposed institutional controls are adequate to control future
releases and exposures at SWMU 2 and AOC 3 by assuring that the areas are vegetated,
maintained, and restricted from residential use.
4. Compliance with Standards for Management of Wastes:
This criterion assesses how owners or operators will ensure that they utilize proper protective
waste management techniques during required future corrective actions. Carboline has
previously removed contaminated equipment, structures, and soils from the facility; EPA
does not expect any additional waste generation due to future corrective action.
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5. Long-Term Reliability and Effectiveness:
This evaluation criterion addresses the results of a remedial alternative in terms of the risks
remaining to human health and the environment at the facility after the owner or operator
meets remediation goals. EPA has concluded that the residual contamination in the soil at
the facility is below OEP VAP residential standards, except for two areas, SWMU 2 and the
Burn Pit Area. In these two areas, specifically, the owner must properly institute and
maintain the proposed institutional controls to reliably and effectively prevent current or
future owners or operators from converting those areas to residential land use and to prevent
unauthorized disturbance of subsurface soil at SWMUs 2 and the Burn Pit Area. Maintain a
vegetative cover at SWMUs 2 and the Burn Pit Area and existing fence and gates to limit
access to the site. Implementation and maintenance of the institutional controls proposed for
the facility will effectively control risks at the Former Carboline facility in the future. The
requirement of financial assurance will insure that the controls remain in place.
6. Reduction of Mobility, Toxicity, or Volume of Wastes or Contaminants:
This evaluation criterion assesses the level to which the remedial alternative reduces the
potential toxicity, mobility, or volume of wastes or contaminants. Carboline has already
implemented corrective measures that have greatly reduced the toxicity and volume of wastes
and contaminated media at the facility. Implementation and maintenance of the institutional
controls proposed for the facility will assure reduction/control of the mobility and toxicity of
the waste/contaminants at the facility.
7. Short-Term Effectiveness:
This criterion addresses the remedial alternative's effect on human health and the
environment during the construction and implementation phase of the remedial action. The
proposed remedy is consistent with current facility conditions and use. Implementation and
maintenance of the institutional controls proposed for the facility will assure that these
conditions consistent with industrial/commercial use are maintained. Based on the current
facility usage and the administrative nature of the proposed remedy, EPA has not identified
any short-term effectiveness concerns.
8. Implementability:
The proposed institutional controls to address potential risks associated with subsurface soil
involve no further construction and incorporate common deed restrictions and covenants.
The work required to implement the proposed remedy is primarily administrative and should
not be difficult to implement.
9. Cost:
The proposed remedy is expected to incur only those administrative costs associated with
preparation and filing of the deed restriction. Other costs will be associated with maintance
of the fence and cover at SWMU 2 and AOC 3, the Burn Pit Area. These costs are on the
lower end of those typical for corrective action at RCRA sites.
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PUBLIC PARTICIPATION
EPA solicits input from the community on the proposed remedy. If requested, EPA will hold a
public meeting in Xenia, Ohio, to present this Statement of Basis, answer questions, accept both
oral and additional written comments, and discuss any additional corrective actions the public
proposes. The public comment period is 30 days.
The Administrative Record for this Statement of Basis is available at:
U.S. Environmental Protection Agency, Region 5
Land and Chemical Division Records Center
77 West Jackson Boulevard, 7th Floor
Chicago, Illinois 60604
(312) 353-5821
Hours: Mon-Fri, 8:00 am to 4:00 pm
Xenia Community Library
76 East Market Street
Xenia, Ohio 45385
(937) 352-4000
Hours: Daily, but variable; refer to www.greenelibrarv.info/Branches/Xenia-Communitv-
Library.html for specific details.
After considering any comments received, EPA will summarize the comments and provide its
responses to the comments, and formalize the selected remedy in a Final Decision and Response
to Comments document. This document will be incorporated into the Administrative Record.
To send written comments or obtain further information, contact:
John Nordine
U.S. Environmental Protection Agency
77 West Jackson Boulevard, LU-16J
Chicago, Illinois 60604
(312) 353-1243 or nordine.iohn@epa.gov
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Administrative Record
Rek-rena.-
Document l)nIt-
Ti Ik-
Author
1
August 15, 1980
Waste Report
Ardell E. Pitt
2
November 11, 1980
Letter From Carboline to EPA
Region 5
W. J. Stewart,
Carboline Co.
3
March, 30 1982
RE: Interim Status
Acknowl edgment
Karl Klepitsch
Jr.,
EPA
4
August 26, 1982
Letter From Carboline to EPA
Region 5
William J.
Stewart
Carboline Co.
5
December 17, 1982
Letter From Carboline to EPA
Region 5
Thomas Carlisle,
Carboline Co.
6
September 28, 1984
RE: Withdrawal of RCRA Part A
Permit Application, Rescission of
Part B Call-In
Karl Klepitsch,
Jr.
Carboline Co.
7
April 1, 1985
Letter From OEPA to Carboline
Thomas Crepeau,
OEPA
8
June 22, 1992
Report on Subsurface
Investigation of Carboline
Browser-Morner
9
November 6, 1992
Preliminary Assessment / Visual
Site Inspection Final Report
PRC
Environmental
Management,
Inc.
10
November 2, 1994
RE: Visual Site Inspection -
Carboline Company
Carboline
Company
11
March 14, 2001
Carboline Company Final
Cessation of Regulated Operations
Inspection
Cathy Altman
OEPA
12
April 30, 2003
ASTM Transaction Screen Report
Brownfield
Restoration
Group, LLC
13
June 27, 2007
Letter from Carboline to EPA
Region 5 Regarding "Your June 6,
2007 Letter to Carboline Co."
Ken Weaver,
Owner
14
April 27, 2009
RE: RCRA 2020 Corrective
Action Universe at RPM -
Carboline Facility
Hull &
Associates, Inc.
15
May 14, 2009
Booz Allen Teleconference With
EPA Region 5
John Nordine,
EPA
16
May 15, 2009
RE: RCRA Closure at RPM-
Carboline Facility
Cherokee BGI,
LLC
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Relercncc
Document Dale
Ti Ik-
Author
17
June 11,2009
Phone Log of Conversation with
Cathy Altman of OEPA
Christopher Rees,
Booze Allen
Hamilton
18
June 11,2009
RCRA Info Facility Information
for Carboline Co.
EPA RCRA Info
Database
19
August 11, 2009
Environmental Indicator Current
Human Health Under Control
CA725, Migration of
Contaminated Groundwater Under
Control CA750
John Nordine,
EPA
20
November 3, 2011
Final Field Sampling Activity
Report for Carboline Company,
Xenia, Ohio
Tech Law, Inc.
21
December 5, 2012
US FWS Review Letter to USEPA
Mary Knapp,
US FWS
22
December 7, 2012
ODNR Wildlife Review Letter to
USEPA
Greg Schneider,
ODNR
23
September 12, 2013
Sampling Trip Report for Soil
Sampling at Carboline Company,
Xenia, Ohio
Booze Allen
Hamilton
24
February 25, 2014
Carboline Site - Report on
Dioxin/Furan congener analysis
Mario Mangino,
EPA
19
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ATTACHMENTS
Attachment A
Attachment B:
Attachment C:
Attachment D
Facility Layout
Current Facility Layout
Sample Location Map 1
Sample Location Map 2
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SWMU4
Fortnei
Tank
Faim
Attachment A Historic Site Layout
I w *-
Parking Lot
Main Office
Pigment
Warehouse
S'vYMU-b
SWMU3
SVVMU2
Uo O
FORMER .
f WkAF EHOUSt-^LftG « ^ "
v- . _ | • Production
Manufacturing
Building
SWMU5
agho
U9
* XV f .
Shawnee
c,eek bJfes
Outfalls
Balt'
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Attachment C
Sample Location Map 1
Final Field Sampling Activity Report
Carboline Company
125 Fairground Road, Xenia, Ohio
Carboline Company
CC-BG-SS-01
CC-BG-SB-01
Ar<
N
$
'1
9^
v
Ohio
/¦"
CC-BA-SS-02
CC-BA-SF-02
CC-BA-SS-03
CC-BA-SF-03
Legend
Approximate Subject
Property Boundary
Approximate Hand Auger
Location for Composite
Sample
Approximate Hand Auger
Location for Composite
Sample with VOC Discrete
Sample
Approximate Hand Auger
Location for Discrete
Backaround Samole
Sample Dates: 9/26-27,
2011
Not to Scale
Figure 2 Sampling
Locations Map
Aerial Date: 2010 Google
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Attachment D
Sample Location Map 2
Booze Allen Hamilton
Field Sampling, September 14, 2013
Carboline Company
125 Fairgrounds Road, Xenia, Ohio
w jj** t:
Oho
Legend
Approximate Subject
Property Boundary
Approximate Hand Auger
Location for Composite
Sample
Not to Scale, sampte locators
based on GPS coordinates
and f*4d observations
AOC 3 Burn Pit, Dioxin
Sample Locations
Aerial Date: 2010 Google
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