990640
FIFTH FIVE-YEAR REVIEW REPORT FOR
FIELDS BROOK SUPERFUND SITE
ASHTABULA COUNTY, OHIO
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Prepared by
U.S. Environmental Protection Agency
Region 5
Chicago, IL
6/11/2024
X Douglas Ballotti
Douglas Ballotti, Director
Superfund and Emergency Management Division
Signed by: DOUGLAS BALLOTTI
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e of Contents
LIST OF ABBREVIATIONS & ACRONYMS v
EXECUTIVE SUMMARY vii
FIVE-YEAR REVIEW SUMMARY FORM xi
I. INTRODUCTION TO FIELDS BROOK SITE xii
Site Background xiii
II. SITEWIDE FIVE-YEAR REVIEW PROCESS - Community Notification, Involvement & Site Interviews
xiii
III. ISSUES/RECOMMENDATIONS FOR FIELDS BROOK SITE xiv
IV. PROTECTIVENESS STATEMENTS FOR FIELDS BROOK SITE xvii
V. NEXT REVIEW xx
VI. OPERABLE UNITS 1 & 4: SEDIMENT AND FLOODPLAIN/WETLANDS 1
VI.1 OPERABLE UNITS 1 & 4: INTRODUCTION 1
OU Summary 1
Background, Land and Resource Use 1
History of Contamination 1
VI.2 OPERABLE UNITS 1 & 4: RESPONSE ACTION SUMMARY 1
Basis for Taking Action 1
Response Actions 2
Status of Implementation 8
Institutional Controls 9
Systems Operations/Operation & Maintenance 12
VI.3 OPERABLE UNITS 1 & 4: PROGRESS SINCE THE LAST REVIEW 14
Protectiveness Determinations/Statements from the 2019 FYR 15
Status of Recommendations from the 2019 FYR 15
VI.4 OPERABLE UNITS 1 & 4: FYR PROCESS 16
Data Review 16
Site Inspection 17
VI.5 OPERABLE UNITS 1 & 4: TECHNICAL ASSESSMENT 18
QUESTION A: Is the remedy functioning as intended by the decision documents? 18
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time
of the remedy selection still valid? 19
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 19
VI.6 OPERABLE UNITS 1 & 4: ISSUES/RECOMMENDATIONS 20
OTHER FINDINGS 21
VI.7. OPERABLE UNITS 1 & 4: PROTECTIVENESS STATEMENT 21
VII. OPERABLE UNIT 5: DETREX CORPORATION SOURCE AREA 22
Vll.l OPERABLE UNIT 5: INTRODUCTION 22
OU Summary 22
Background, Land and Resource Use 23
History of Contamination 23
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VII.2 OPERABLE UNIT 5: RESPONSE ACTION SUMMARY 24
Basis forTaking Action 24
Response Actions 25
Status of Implementation 28
Institutional Controls 32
Systems Operations/Operation & Maintenance 33
VII.3 OPERABLE UNIT 5: PROGRESS SINCE THE LAST REVIEW 35
Protectiveness Determinations/Statements from the 2019 FYR 35
Status of Recommendations from the 2019 FYR 35
VII.4 OPERABLE UNIT 5: FYR PROCESS 36
Data Review 36
Site Inspection 37
VII.5 OPERABLE UNIT 5: TECHNICAL ASSESSMENT 38
QUESTION A: Is the remedy functioning as intended by the decision documents? 38
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time
of the remedy selection still valid? 39
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 40
VII.6 OPERABLE UNIT 5: ISSUES/RECOMMENDATIONS 40
VII.7 OPERABLE UNIT 5: PROTECTIVENESS STATEMENT 42
VIII. OPERABLE UNIT 6: MILLENNIUM TICL4 PLANT SOURCE AREA 43
VIII.1 OPERABLE UNIT 6: INTRODUCTION 43
OU Summary 43
Background, Land and Resource Use 44
History of Contamination 44
VIII.2 OPERABLE UNIT 6: RESPONSE ACTION SUMMARY 46
Basis for Taking Action 46
Response Actions 46
Status of Implementation 47
Institutional Controls 49
Systems Operations/Operation & Maintenance 51
VIII.3 OPERABLE UNIT 6: PROGRESS SINCE THE LAST REVIEW 51
Protectiveness Determinations/Statements from the 2019 FYR 51
Status of Recommendations from the 2019 FYR 52
VIII.4 OPERABLE UNIT 6: FYR PROCESS 53
Data Review 53
Site Inspection 54
VIII.5 OPERABLE UNIT 6: TECHNICAL ASSESSMENT 54
QUESTION A: Is the remedy functioning as intended by the decision documents? 54
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time
of the remedy selection still valid? 55
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 55
VIII.6 OPERABLE UNIT 6: ISSUES/RECOMMENDATIONS 55
VIII.7 OPERABLE UNIT 6: PROTECTIVENESS STATEMENT 56
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IX. OPERABLE UNIT 7: NORTH SEWERS SOURCE AREA 56
IX.l OPERABLE UNIT 7: INTRODUCTION 57
OU Summary 57
Background, Land and Resource Use 57
History of Contamination 57
IX.2 OPERABLE UNIT 7: RESPONSE ACTION SUMMARY 58
Basis for Taking Action 58
Response Actions 58
Status of Implementation 59
Institutional Controls 61
Systems Operations/Operation & Maintenance 64
IX.3. OPERABLE UNIT 7: PROGRESS SINCE THE LAST REVIEW 64
Protectiveness Determinations/Statements from the 2019 FYR 64
Status of Recommendations from the 2019 FYR 65
Data Review 65
Site Inspection 65
IX.5 OPERABLE UNIT 7: TECHNICAL ASSESSMENT 66
QUESTION A: Is the remedy functioning as intended by the decision documents? 66
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time
of the remedy selection still valid? 66
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 66
IX.6 OPERABLE UNIT 7: ISSUES/RECOMMENDATIONS 66
IX.7 OPERABLE UNIT 7: PROTECTIVENESS STATEMENT 67
X. OPERABLE UNIT 8: ACME SCRAP IRON AND METALS AND SOUTH SEWERS SOURCE AREA 68
X.l OPERABLE UNIT 8: INTRODUCTION 68
OU Summary 68
Background Land and Resource Use 68
History of Contamination 69
X.2. OPERABLE UNIT 8: RESPONSE ACTION SUMMARY 69
Basis forTaking Action 69
Response Actions 69
Status of Implementation 71
Institutional Controls 72
Systems Operations/Operation & Maintenance 73
X.3 OPERABLE UNIT 8: PROGRESS SINCE THE LAST REVIEW 74
Protectiveness Determinations/Statements from the 2019 FYR 74
Status of Recommendations from the 2019 FYR 75
X.4 OPERABLE UNIT 8: FYR PROCESS 75
Data Review 76
Site Inspection 76
X.5 OPERABLE UNIT 8: TECHNICAL ASSESSMENT 76
QUESTION A: Is the remedy functioning as intended by the decision documents? 76
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time
of the remedy selection still valid? 77
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QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 77
X.6 OPERABLE UNIT 8: ISSUES/RECOMMENDATIONS 77
X.7 OPERABLE UNIT 8: PROTECTIVENESS STATEMENT 78
APPENDIX A REFRENCES 79
APPENDIX B SITE INSPECTIONS CHCECKLISTS 86
APPENDIX C SITE INSPECTIONS PHOTOGRAPHS 104
APPENDIX D SITE CHRONOLOGY FOR ALL OUs 171
APPENDIX E TABLES 184
APPENDIX F FIGURES 188
Report Tables
Table 1: Summary Implemented ICs at Sediment OU1 & FWA OU4
Table 2: OU1 & OU4 Protectiveness Determinations/Statements from the 2019 FYR
Table 3: OU1 & OU4 Status of Recommendations from the 2019 FYR
Table 4: Summary Implemented ICs at Detrex OU5
Table 5: OU5 Protectiveness Determinations/Statements from the 2019 FYR
Table 6: OU5 Status of Recommendations from the 2019 FYR
Table 7: Summary Implemented ICs at Millennium TiCU Plant OU6
Table 8: OU6 Protectiveness Determinations/Statements from the 2019 FYR
Table 9: OU6 Status of Recommendations from the 2019 FYR
Table 10: Summary Implemented ICs at North Sewers OU7
Table 11: OU7 Protectiveness Determinations/Statements from the 2019 FYR
Table 12: OU7 Status of Recommendations from the 2019 FYR
Table 13: Summary Implemented ICs at Acme Scrap Iron and Metal / South Sewers OU8
Table 14: OU8 Protectiveness Determinations/Statements from the 2019 FYR
Table 15: OU8 Status of Recommendations from the 2019 FYR
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LIST OF ABBREVIATIONS & ACRONYMS
ARAR Applicable or Relevant and Appropriate Requirement
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CIC Community Involvement Coordinator
CFR Code of Federal Regulations
cm/sec Centimeters per second
COC Contaminant of concern
CRG Confidence Removal Goal
CUG Cleanup Goal
DERR Division of Environmental Response and Revitalization
DNAPL Dense Non-Aqueous Phase Liquid
DNR Department of Natural Resources
DSW Division of Surface Water
DRE Destruction Removal Efficiency
DS Tributary Diamond Shamrock Tributary
EC Environmental Covenant
EPA United States Environmental Protection Agency
ESD Explanation of Significant Difference
ESMI Environmental Soil Management Companies
EU Exposure Unit
FBAG Fields Brook Action Group
FS Feasibility Study
FSCA Facility Stormwater Collection Area
FWA Floodplains/Wetlands Area (OU4)
FYR Five-Year Review
ft Feet
GLNPO Great Lakes National Program Office
GWIT Groundwater InterceptorTrench
HCB Hexachlorobenzene
HCBD Hexachlorobutadiene
IC Institutional Control
ICIAP Institutional Control Implementation and Assurance Plan
Koc Water partition coefficient or adsorption coefficient
LTS Long-Term Stewardship
mg/kg Milligram per kilogram
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
NCP National Oil and Hazardous Substances Pollution Contingency Plan
Ohio EPA Ohio Environmental Protection Agency
O&M Operation and Maintenance
OM&M Operation, Maintenance and Monitoring
OSWER Office of Solid Waste and Emergency Response
OU Operable Unit
PAHs Polycyclic aromatic hydrocarbons
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PCBs
Polychlorinated biphenyls
pCi/g
Pico-curies per gram
pH
Measure of acidity
PPm
Parts per million
PRP
Potentially Responsible Party
PVC
Polyvinyl chloride
QAPP
Quality Assurance Project Plan
RA
Remedial Action
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act
Rl
Remedial Investigation
ROD
Record of Decision
RMI
Reactive Metals Incorporated
RPM
Remedial Project Manager
SCOU
Source Control Operable Unit
SGWIT
Southern Groundwater Interceptor Trench
sq ft
Square Feet
Site
Fields Brook Superfund Site
SVOC
Semi-volatile organic compound
TBC
To Be Considered
TiCU
Titanium tetrachloride
TCE
Trichloroethylene
TSCA
Toxic Substances Control Act
UAO
Unilateral Administrative Order
UECA
Uniform Environmental Covenants Act
USACE
United States Army Corps of Engineers
UU/UE
Unlimited use/unrestricted exposure
VOCs
Volatile organic compounds
Hg/kg
microgram per kilogram
M-g/L
microgram per liter
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EXECUTIVE SUMMARY
This is the fifth Five-Year Review (FYR) for the Fields Brook Superfund Site (Site) located in Ashtabula,
Ashtabula County, Ohio. The purpose of this FYR is to review information to determine if the remedy is
and will continue to be protective of human health and the environment. The triggering action for this
statutory FYR was the signing of the previous FYR on June 25, 2019.
The Site is located in the city and county of Ashtabula, Ohio, in a six square-mile watershed (Fig. E-l,
Appendix F) of the Fields Brook where, from 1940 to the present, at least 19 separate facilities
operated. Activities range from metals-fabrication to chemicals production. Fields Brook flows into the
Ashtabula River (Fig. E-2, Appendix F), which flows into Lake Erie approximately 1.5 miles downstream
of the Site. Sediments and surface water of Fields Brook, and soils on the Fields Brook
floodplain/wetlands area (FWA), were contaminated with a wide variety of contaminants including
polychlorinated biphenyls (PCBs), volatile organic compounds (VOCs), polycyclic aromatic
hydrocarbons (PAHs), heavy metals, phthalates, and low-level radionuclides. Approximately 18,000
people live within one mile of the Site.
For this Site, an "Operable Unit" (OU) defines a portion of the Site with which actions are associated.
An "Exposure Unit" (EU) defines the area within the Fields Brook Sediment and FWA (OUs 1 & 4,
respectively). Site cleanup goals (CUGs) and confidence removal goals (CRGs) are used to determine if
clean up objectives are met in the EUs. Source Control OUs were remediated to address the risk of re-
contaminating the Fields Brook sediment at levels above the CUGs and to mitigate pathways of
contaminant migration from the Source Control OU to the Fields Brooks sediment. EUs are directly
relevant to the cleanup of Fields Brook OUs 1 & 4. They do not geographically extend into, nor are they
a part of the ROD for the source areas. The source area cleanups (OUs 5 through 10) were designed to
protect Fields Brook from recontamination and did not remediate the facilities involved. Source control
cleanups were not developed to address human health or ecological risks within each source area. The
scope of the required cleanups at OUs 5 through 10 were implemented pursuant to the remedial
action objective (RAO) of preventing Fields Brook from recontamination. Figure E-3 depicts how OUs
and EUs relate spatially.
Upper reaches of the Brook (EUs 4 through 8 on Fig. E-3, Appendix F) flow through areas that are
currently heavily industrialized. The expected future use in these areas is that they will remain
industrial. In these areas, the remedy included cleanup to meet industrial use scenarios and address
ecological risks.
Lower reaches of the Brook (EUs 1 through 3 on Fig. E-3, Appendix F) flow between residential
neighborhoods prior to discharge to the Ashtabula River adjacent to a rail yard. The expectation is that
the current residential neighborhoods will remain as residential use in the future and the rail yard will
remain in industrial use. Residential-use scenarios were used to create cleanup levels for EU1 though
EU3 to address ingestion and direct contact pathways at Fields Brook. Although not required by the
1997 Source Control Operable Unit (SCOU) Record of Decision (ROD) (EPA, 1997), the rail yard cleanup
also met a residential cleanup level.
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The remedies for the Site included the removal of contaminated sediment and floodplain soil from
Fields Brook. In addition, remedial actions were implemented at six separate source control OUs to
prevent additional contamination (Fig. E-4, Appendix F). The remedies in these areas were designed to
protect Fields Brook from recontamination but did not remediate the facilities involved. Institutional
controls (ICs) were included in the remedies to the extent necessary for protection of Fields Brook and
the components of the remedy.
Below is a summary of remedial actions at the Site by OU:
Fields Brook Sediment and Floodplain/Wetland Soils (OU1 and OU4) - Construction of an onsite
landfill was completed in the summer of 2000 (shown on Fig. 1-1, Appendix F as "Landfill Area").
Excavation of sediments and FWA soils contaminated with PCBs, low-level radioactive materials and
dense non-aqueous phase liquids (DNAPL) was completed in December 2002. Thermal treatment was
performed on-site for soils and sediment impacted by DNAPL, but not regulated under the Toxic
Substances Control Act (TSCA). Restoration activities were completed in the spring of 2003. IC
requirements are in place at the landfill and in the floodplain in EU8.
In 2009, the Fields Brook Action Group (FBAG) prepared a Focused Feasibility Study to evaluate
containment measures for EU8 (Gradient Corporation, 2009). FBAG rerouted the Brook in EU8 through
a lined sedimentation basin and diversion channel and completed the work in 2010. FBAG made
significant repairs to the liner system in 2012. During the third FYR period and in 2014-2015, routine
monitoring of the Brook's sediment and floodplain soil identified additional contamination. FBAG
conducted soil removal to address these areas of contamination in 2014 and 2016.
Source Control (OU2) - Source Control OU2 was broken down into OUs 5-10 (see below).
Ashtabula River (OU3) - The Ashtabula River OU3 was historically the northern portion of the
Ashtabula River (north of the confluence of Fields Brook) and Harbor. The entire length of the
Ashtabula River is not considered part of the Fields Brook Superfund Site, however the only a portion
of the river is part of the Superfund Site. The United States Environmental Protection Agency (EPA)
Great Lakes National Program Office (GLNPO) and the Army Corps of Engineers addressed the River's
contaminated sediments. EPA developed the Ashtabula River and Harbor Remedial Activities Summary
Report in June 2021 to summarize the review of documents, reports and data related to the Ashtabula
River OU3.
Detrex Corporation (OU5) - Detrex OU5 was issued a Unilateral Administrative Order (UAO) in 1997 to
address source control contamination (EPA, 1997). Detrex completed construction of a slurry wall in
2000. Detrex constructed the first phase of the DNAPL extraction system in 2002. An Explanation of
Significant Differences (ESD) signed in January 2014, revises the extraction well technology to be used,
and provides metrics for measuring progress and achieving closure of the UAO (EPA, 2014). Detrex
completed construction of the DNAPL passive collection well remedy in June 2016 and passive DNAPL
recovery is ongoing. ICs are in place on all Detrex-owned property. In 2012 and 2013, Detrex removed
contaminated sediments from the Diamond Shamrock Tributary (DS Tributary) and restored the box
culvert under State Road. In 2022, overflow from the Detrex Tank 004 was observed by Ohio EPA on
multiple occasions. Tank 004 contains contaminated groundwater comingled with manufacturing
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process waters. Detrex is evaluating the existing water management system to avoid future releases of
contaminated groundwater from the facility.
Millennium Titanium Tetrachloride Plant (OU6) - Millennium TiCI4 Plant OU6 was issued a UAO in
1997 to address source control contamination (EPA, 1997). Millennium completed excavation of
approximately 60,000 cubic yards of PCB and radium-contaminated soil and mining residuals in the fall
of 1999. Upon discovering Therminol FR DNAPL in the EU8 floodplain, the EPA issued a UAO to
Millennium in 2007 requiring the company to address the associated PCB contamination in sediment
and floodplain soils (EPA, 2007). Millennium completed this removal action in 2008. In 2011,
Millennium also placed ICs for its property in the EU8 floodplain where PCB contamination remains
above unlimited use/unrestricted exposure (UU/UE) criteria.
North Sewers (OU7) - A UAO was issued to Detrex Corporation, Occidental Chemical Company and
RMI Sodium in 1997 to address source control contamination (EPA, 1997). The PCB-contaminated
North Sewers, comprised of the Combined Sewer, Storm Sewer, and Detrex Facility Outfall Sewer,
were cleared out and closed by filling with cement grout. Work was completed in the fall of 2000. ICs
were placed in 2004 to prevent excavation.
Acme Scrap Iron and Metals / South Sewers (OU8) - A UAO was issued to Acme Scrap Iron and Metal;
Delta Associates; Ohio Power Company, Union Carbide Corporation and Centerior Energy Corporation
in 1997 to address source control contamination (EPA, 1997). The excavation and disposal of PCB-
contaminated soil and the cleaning of the south sewers was completed in the fall of 2000. ICs were
recorded in 2010 that limits the property to industrial land use only.
Conrail Bridge Yard (OU9) - Conrail OU9 was issued a UAO in 1997 to address source control
contamination (EPA, 1997). Physical construction was completed in December of 1998. All arsenic-
contaminated soil was excavated to residential cleanup standards and shipped for off-site disposal. No
ICs were required as UU/UE was met.
RMI Metals Property (OU10) - RMI OU10 was issued a UAO in 1997 to address source control
contamination (EPA, 1997). Excavation and disposal of PCB-contaminated soils to meet industrial use
standards, pursuant to TSCA voluntary cleanup standards, was completed in the summer of 2001. No
ICs were required because the material left on-site does not exceed residential Fields Brook cleanup
levels and UU/UE is met.
Operable
Description
Completion of
Unit
Remedial Action Date
OU1
Sediment
9/30/2003
OU2
Historically known as the Source Control OU2 was further
broken down into OUs 5 - 10 to allow for facility-specific
design and enforcement activities. No construction
completion date or status is therefore noted for this OU.
NA
OU3
The Ashtabula River OU3 was historically the northern
portion of the Ashtabula River, south of the confluence of
Fields Brook and Harbor, which is currently being addressed
NA
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outside of the EPA Superfund program by GLNPO. No ROD
was signed, and no construction completion date or status
is therefore noted in this OU.
OU4
Floodplain/Wetlands
9/30/2003
OU5
Detrex Corporation - The passive DNAPL collection system
was completed and is in on-going operation and
maintenance. System is being optimized to increase
removal of DNAPL. The ESD was signed by EPA on January
2014 and EPA approved the remedial action construction
completion on June 14, 2017.
6/14/2017
OU6
Millennium TiCI4 Plant
6/28/2000 and
5/18/2010
OU7
North Sewers
5/14/2001
OU8
Acme Scrap Iron and Metal / South Sewers
3/17/2003
OU9
Conrail Bridge Yard
4/17/2000
OUIO
RMI Metals Property
9/10/2002
This FYR focuses on the data collected, decisions made, and work completed since June 2019, although
the full history of the Site is also summarized. The review addresses the following OUs: Sediment OU1,
Floodplain/Wetlands Area OU4, Detrex OU5, Millennium TiCI4 Plant OU6, North Sewers OU7, and
Acme Scrap Iron and Metal / South Sewers OU8.
Limitation of FYR Scope
No review is required for the Ashtabula River OU3 because it is being addressed by GLNPO. No reviews
are required for the Conrail Bridge Yard OU9 and RMI Metals Property OUIO. EPA determined the
remedial actions conducted at these OUs were sufficient in protecting Fields Brook from
recontamination and meeting UU/UE standards. Specifically, the Conrail OU9 cleanup met the
residential CUG and did not leave soils on Site above health-based levels. The RMI OUIO cleanup also
met a health-based level for unrestricted land use (pursuant to TSCA voluntary cleanup standards). ICs
are not required as these two OUs meet the standard for UU/UE. The last FYR for these two OUs was
conducted in 2004 after which further FYRs were discontinued.
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FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name:
Fields Brook
EPA ID:
OHD980614572
Region: 5
State: OH
City/County: Ashtabula/Ashtabula
NPL Status: Final
Multiple OUs?
Yes
Has the site achieved construction completion?
No
Lead agency: EPA
Author name (Federal or State Project Manager): Anna Nguyen
Author affiliation: EPA Region 5
Review period: 6/20/2023 - 1/16/2024
Date of site inspection: 8/22-23/2023
Type of review: Statutory
Review number: 5
Triggering action date: 6/25/2019
Due date (five years after triggering action date): 6/25/2024
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I. INTRODUCTION TO FIELDS BROOK SITE
The purpose of a FYR is to evaluate the implementation and performance of a remedy in order to
determine if the remedy is and will continue to be protective of human health and the environment.
The methods, findings, and conclusions of reviews are documented in FYR reports such as this one. In
addition, FYR reports identify issues found during the review, if any, and document recommendations
to address them.
EPA is preparing this FYR pursuant to the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) Section 121, consistent with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP)(40 CFR Section 300.430(f)(4)(ii)), and considering EPA policy.
This is the fifth FYR for the Fields Brook Superfund Site (Site). The triggering action for this statutory
review is the completion date of the previous FYR dated June 25, 2019. The FYR has been prepared due
to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that
allow for UU/UE.
The Site consists of nine OUs (1 to 10, OU2 is broken down into OUs 5-10), six of which (Sediment OU1,
FWA OU4, Detrex OU5, Millennium TiCI4 Plant OU6, North Sewers OU7, and Acme Scrap Iron and
Metal / South Sewers OU8) are addressed in this FYR. The OUs and corresponding areas are
summarized in the Executive Summary.
The three OUs that are not addressed in this FYR are the Ashtabula River OU3, Conrail Bridge Yard
OU9, and RMI Metals OUIO. The Ashtabula River OU3 is not addressed in this FYR because it does not
have a CERCLA decision document and is being addressed by the EPA GLNPO. Conrail OU9 and RMI
OUIO are not addressed in this FYR because EPA had determined that they meet the standard for
UU/UE. The last FYR for Conrail OU9 and RMI OUIO was conducted in 2004 after which further FYRs
were discontinued.
The Fields Brook Superfund Site FYR was led by Anna Nguyen, EPA, Remedial Project Manager (RPM)
for the Site. Participants included Nick Roope of the Ohio Environmental Protection Agency (Ohio EPA),
Jenny Polster, EPA, RPM, Amy Gahala, EPA, Hydrogeologist, and Kristin Safakas, EPA, Community
Involvement Coordinator (CIC).
The relevant entities, such as the responsible party groups for FBAG (Sediment OU1 & FWA OU4),
Detrex Corporation (Detrex OU5), Millennium (Millennium TiCI4 Plant OU6), and Acme Scrap Iron
(Acme Scrap Iron and Metal and South Sewers OU8), were formally notified of the initiation of the FYR.
The review began on June 20, 2023.
Specific reviews of the Sediment OU1 & FWA OU4 and each of the source control (Detrex OU5,
Millennium TiCI4 Plant OU6, North Sewers OU7, and Acme Scrap Iron and Metal and South Sewers
OU8) are provided within this document. Sections VI through X below provide details on the
background, response action summary, description of the FYR process, and summary of the progress
since the last FYR for each OU. Appendix A lists the relevant decision documents, enforcement tools,
reports, and records for each OU. The Site Inspection checklists and photos are provided in appendices
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B and C, respectively. A chronology of significant response events is included in Appendix D. Any issues
impacting current and/or future protectiveness are presented in their respective OU-specific
discussion.
Site Background
The Site was placed on the National Priorities List (NPL) for hazardous waste sites on September 8,
1983. The Site consists of Fields Brook, its tributaries, and any surrounding areas that contribute,
potentially may contribute, or have contributed to the contamination of the Brook and its tributaries.
The Site consists of multiple OUs, as shown in Figure E-3 in Appendix F. Soil, sediments, groundwater,
and surface water, have been impacted with various contaminants, including PCBs, PAHs, chlorinated
solvents, chlorinated benzene compounds, radionuclides, and metals, although CUGs were ultimately
required only for soil and sediment. Recharge of the brook by contaminated groundwater and surface
water were eliminated because these contaminant transport processes could not result in sediment
concentrations higher than the CUGs.
The Fields Brook Site is divided into four areas, three of which have since been designated as OUs.
Sediment OU1 involves the cleanup of contaminated sediment in Fields Brook and its tributaries.
Source Control OU2 involves the location and cleanup and sources of contamination to Fields Brook to
prevent recontamination of the Brook and adjacent flood plains and wetlands area. Source Control
OU2 includes source control operable units 5-10. The contaminants of concern (COCs) for Source
Control OU2 include the COCs for both Sediment OU1 and FWA OU4. The areas identified in Source
Control OU2 were evaluated to determine the extent that contaminant movement could cause a CUG
exceedance in the Fields Brook sediment. The cleanups at Source Control OU2 were limited to actions
needed to prevent recontamination of Fields Brook and were not intended to fully remediate the
facilities involved. Source Control OU2 areas ultimately became OUs 5 through 10.
The Ashtabula River OU3 includes contaminated areas of the Ashtabula River and Harbor. The cleanup
of the Ashtabula River and Harbor has been addressed outside of the Superfund process using funding
through the Great Lakes Legacy Act.
The FWA OU4 encompasses contaminated floodplain and wetlands soils and sediments located within
the 100-year floodplain area surrounding Fields Brook and outside of the channel and side-slope areas
of Fields Brook.
II. SITEWIDE FIVE-YEAR REVIEW PROCESS - Community Notification, Involvement & Site Interviews
Activities to involve the community in the FYR process were initiated with a discussion in April 2023
between the RPM and CIC for the Site. A notice was published in the local newspaper, the Ashtabula
Star-Beacon, on June 20, 2023, stating that there was a FYR and inviting the public to submit any
comments to EPA (Fig. E-5, Appendix F). EPA did not receive comments from the public regarding the
FYR, however, one reporter from the Ashtabula Star-Beacon inquired about the frequency of the FYR
evaluation, status of public interaction regarding the public notice, the nature of the relationship
between the federal and state agencies regarding the Fields Brook site, and the potential for the FYR
evaluation to impact fishing in the area. The RPM and CIC provided responses to the reporter's
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questions via email on August 8, 2023. The results of the review and the report will be made available
at the Site information repository located at the Ashtabula County District Library, at 4335 Park
Avenue, Ashtabula, Ohio and at www.epa.gov/superfund/fields-brook.
III. ISSUES/RECOMMENDATIONS FOR FIELDS BROOK SITE
Issues/Recommendations Summary Tables
OU(s) without Issues/Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
OU(s): 1,4
Issue Category: Operations and Maintenance
Issue: Reassessment of OM&M sample collection method and
evaluation against CUGs
Recommendation: Update OM&M Plan to include composite
sample collection method and comparison against established
CUGs.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone
Date
No
Yes
PRP
EPA
12/31/2024
| Issues and Recommendations Identified in the FYR: |
OU(s): 1,4
Issue Category: Monitoring
Issue: Update QAPP based on anticipated use of the composite
sample collection method.
Recommendation: Update QAPP to reflect changes made in the
finalized OM&M Plan.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone
Date
No
Yes
PRP
EPA
6/25/2025
| Issues and Recommendations Identified in the FYR: |
OU(s): 1,4
Issue Category: Institutional Controls
Issue: Additional ICs may be to ensure long-term protectiveness of
Sediment 0U1.
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Recommendation: Evaluate existing ICs for long-term
protectiveness of OU1 and if applicable, identify which additional
ICs are necessary for Sediment OU1.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone
Date
No
Yes
PRP
EPA
12/31/2024
OU(s): 1, 4, 5, 6, 7,8
Issue Category: Institutional Controls
Issue: An ICIAP is needed to ensure that effective ICs are
implemented, monitored and maintained.
Recommendation: Develop and submit an ICIAP for approval
which describes the plan for ensuring that all remaining required
ICs at the Site are implemented, and for ensuring that all ICs, once
implemented, are monitored and maintained.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone
Date
No
Yes
PRP
EPA
6/25/2028
Issues and Recommendations Identified in the FYR:
OU(s): 5
Issue Category: Remedy Performance
Issue: Contaminated water from Tank 004 is overflowing during
wet weather events into the environment and potentially leaving
the site and impacting Fields Brook.
Recommendation: Continue to implement corrective measures to
ensure overflow of Tank 004 does not occur and ensure all
contaminated water is captured and treated prior to discharge.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone
Date
No
Yes
PRP
EPA
12/31/2026
Issues and Recommendations Identified in the FYR:
OU(s): 5
Issue Category: Monitoring
Issue: Additional data and OM&M practices needed to ensure
remedy performance of the slurry wall.
Recommendation: Expand piezometer and/or monitoring well
network along the slurry wall to determine whether contaminated
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groundwater is contained within the OU and does not impact Fields
Brook.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone
Date
No
Yes
PRP
EPA
12/31/2024
Issues and Recommendations Identified in the FYR:
OU(s): 5
Issue Category: Operations and Maintenance
Issue: The OM&M Plan and QAPP for the chlorinated DNAPL
passive collection system in the DNAPL source area have not been
finalized. The OM&M Plan and QAPP also needs to incorporate the
corrective measures related to overflow of Tank 004 and O&M
practices for the sedimentation occuring in the DNAPL perimeter
monitoring points.
Recommendation: Finalize the OM&M Plan and QAPP for the
chlorinated DNAPL passive collection system in the DNAPL source
area.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone
Date
No
Yes
PRP
EPA
12/31/2025
Issues and Recom
mendc
tions Identified in
the FYR:
OU(s): 6
Issue Category: Operations and Maintenance
Issue: OM&M procedures for the interceptor trench are not
memorialized.
Recommendation: OM&M procedures to monitor and respond to any
collected material in the interceptor trenches so that it is appropriately
removed for treatment and disposal, and to prevent recontamination of
Fields Brook should be included in the OU1 & OU4 OM&M Plan to be
submitted by FBAG.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
Issues and Recommendations Identified in the FYR:
OU(s): 7
Issue Category: Institutional Controls
-------
Issue: The ECs recorded or signed in 2020 were not signed by an
applicable agency, which is a requirement of Ohio's UECA.
Recommendation: Ensure all applicable parties sign the ECs and record
the instruments.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
Issues and Recommendations Identified in the FYR:
OU(s): 8
Issue Category: Institutional Controls
Issue: At the time the EC was recorded, the parcel was owned entirely by
Lakeside Industrial Park & Rail Yard. In the Spring of 2024, the EPA learned
the original parcel was subdivided into four parcels, two of which are
owned by Hubert Properties LLC, one of which is owned by State Road
Investments, and one of which continues to be owned by Lakeside
Industrial Park & Rail Yard. It is not clear whether Hubert Properties LLC
and State Road Investments received notice of the EC requirements when
they acquired ownership.
Recommendation: Contact the current parcel owners and ensure the
owners are aware of the EC requirements.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
IV. PROTECTIVENESS STATEMENTS FOR FIELDS BROOK SITE
Protectiveness Statements Summary Table (s)
Operable Unit: Protectiveness Determination:
OU1 and OU4 Short-term Protective
Protectiveness Statement:
The remedy for the Fields Brook Sediment and FWA OUs (OU1 and OU4) currently protects human
health and the environment. The response actions selected in the 1986 and 1997 RODs and subsequent
ESDs to remove and contain contaminated sediments and floodplain soils within an on-Site landfill, and
on-Site thermal treatment of the significantly contaminated or mobile sediments, have proven to be
effective in addressing the risks associated with the Site. Effective ICs in the form of Environmental
Covenants have been recorded. Based on historic soil, sediment and surface water data collected from
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annual sampling events from 2019 to 2021, the Sediment OU1 and FWA OU4 remedies are effective.
Historical OM&M data since 2004 supports this assessment of the remedy in the sediment and
floodplain. Landfill groundwater data collected from 2019 to 2022 indicate leachate is not impacting
the groundwater near the landfill. However, in order for the remedy to remain protective in the long
term, the following actions need to be taken to ensure protectiveness: update the OM&M Plan to
include composite sampling method, data evaluation against CUGs; update the QAPP to reflect the
anticipated changes made in the finalized OM&M Plan; evaluate existing ICs for long-term
protectiveness of OU1 and if applicable, identify which additional ICs are necessary for Sediment OU1;
and develop and submit an ICIAP which describes the plan for ensuring that all remaining required ICs
at the Site are implemented, and for ensuring that all ICs, once implemented, are monitored and
maintained.
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination:
OU5 Short-term Protective
Protectiveness Statement:
The remedy at Detrex OU5 currently protects human health and the environment by preventing
recontamination of Fields Brook from organic chemical contamination in Site soils. However, there are
engineering performance issues related to the operation of the remedy to ensure containment of
contaminated groundwater. The observed Tank 004 overflow events are a concern, however, at this
time, there is no evidence of untreated groundwater leaving the Detrex facility. Detrex is evaluating
water management alternatives to prevent Tank 004 overflow events and has implemented interim
measures to monitor and report site conditions during wet weather events and water levels in Tank
004. Detrex, FBAG, EPA, and OEPA are investigating if these overflow events have impacted the Brook.
The remedial actions outlined in the January 15, 2014, ESD modifying the DNAPL recovery system in
the Detrex source area to reduce releases to the Brook were implemented in 2016 and are proving to
be effective. The EC recorded in 2009 is in effect to ensure the Detrex facility is not used in a manner
that would interfere with the CERCLA remedy, limit the facility to commercial/industrial use, and
prevent consumptive use of groundwater on or off the facility. However, in order for the remedy to be
protective in the long-term, the following actions need to be taken to ensure protectiveness: continue
to implement corrective measures to ensure overflow of Tank 004 does not occur and ensure all
contaminated water is captured and treated prior to discharge; expand piezometer and/or monitoring
well network along the slurry wall to demonstrate contaminated groundwater is contained within the
OU and does not impact Fields Book; finalize the OM&M Plan and QAPP for the chlorinated DNAPL
passive collection system in the DNAPL source area; and develop and submit an ICIAP which describes
the plan for ensuring that all remaining required ICs at the Site are implemented, and for ensuring that
all ICs, once implemented, are monitored and maintained.
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination:
OU6 Short-term Protective
Protectiveness Statement:
The remedy at the Millennium TiCI4 Plant OU6 currently protects human health and the environment.
The cleanup in non-plant areas exceeded ROD requirements by excavating to a stricter cleanup level
and meets the RAO of preventing recontamination of Fields Brook in excess of PCB and radium cleanup
xviii
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goals. An effective IC is in-place in the plant area and on EU8 where excavation of PCB and DNAPL
contaminated soils occurred to prevent recontamination of the Brook. However, in order for the
remedy to be protective in the long-term, the following actions need to be taken to ensure
protectiveness: OM&M procedures to monitor and respond to any collected material in the interceptor
trenches so that it is appropriately removed for treatment and disposal, and to prevent
recontamination of Fields Brook should be included in the OU1 & OU4 OM&M Plan to be submitted by
FBAG; and develop and submit an ICIAP for approval which describes the plan for ensuring that all
remaining required ICs at the Site are implemented, and for ensuring that all ICs, once implemented,
are monitored and maintained.
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination:
OU7 Short-term Protective
Protectiveness Statement:
The remedy at North Sewers OU7 currently protects human health and the environment. The sewers
have been closed and grouted and are no longer in use, and there is no mechanism for any sediment
within the sewers to move to the Fields Brook for contamination, since it has been rendered
immobile. ICs are in place to prevent activities that would disrupt or disturb the grouted and sealed
sewers. However, in order for the remedy to be protective in the long-term, the following actions
need to be taken to ensure protectiveness: ensure all applicable parties sign the ECs and record the
instruments; and develop and submit an ICIAP which describes the plan for ensuring that all
remaining required ICs at the Site are implemented, and for ensuring that all ICs, once implemented,
are monitored and maintained.
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination:
OU8 Short-term Protective
Protectiveness Statement:
The remedy for the Acme Scrap Iron and Metals and South Sewers OU8 currently protects human
health and the environment. Cleanup at Acme included excavation of soils with PCB concentrations
equal to or greater than 50 ppm and the cleanout of the South Sewers. The cleanup remedy is
functioning as designed by preventing recontamination of Fields Brook sediment. Monitoring at Acme
Scrap Iron and Metals and South Sewers OU8 demonstrates that the risk of recontamination of the
Fields Brook has been abated. An EC was recorded with Ashtabula County on March 9, 2010, and will
be regularly evaluated for protectiveness in future FYRs to ensure land use remains industrial. Based
on the FYR August 2023 Site inspection and subsequent online research of the Acme parcels, it
appears that land use remains industrial. However, in order for the remedy to be protective in the
long-term, the following actions need to be taken to ensure protectiveness: contact the current
parcel owners and ensure the owners are aware of the EC requirements; and develop and submit an
ICIAP which describes the plan for ensuring that all remaining required ICs at the Site are
implemented, and for ensuring that all ICs, once implemented, are monitored and maintained.
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V. NEXT REVIEW
The next FYR report for the Fields Brook Superfund Site is required five years from the completion date
of this review.
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VI. OPERABLE UNITS 1 & 4: SEDIMENT AND FLOODPLAIN/WETLANDS
VI.1 OPERABLE UNITS 1 & 4: INTRODUCTION
OU Summary
The purpose of this FYR is to determine if the remedy selected to address the contamination at the Sediment OU1
and FWA OU4 of the Fields Brook Superfund Site is protective of human health and the environment (See Figs. E-l
and E-3, Appendix F). The remedy included excavation of contaminated sediment and soil, and placement into a
landfill constructed on-site; thermal treatment of soils and sediment impacted by DNAPL; long-term Operation,
Maintenance and Monitoring (OM&M); and ICs.
Sampling results from routine monitoring of the Fields Brook sediment and floodplain soil are below remedial
goals.
Background. Land and Resource Use
Sediment OU1 is considered to be the sediment of the main channel of Fields Brook and its tributaries. The 3.5-
mile main channel of Fields Brook flows through an industrial area that is one of the largest and most diversified
concentrations of chemical plants in Ohio. Industrial sources contaminated Fields Brook sediments and soils with
a variety of organic and heavy metal contaminants including PCBs.
FWA OU4 consists of the 100-year floodplain of Fields Brook. For risk assessment purposes, reaches of Fields
Brook were divided into ten exposure units (EU); each of the EUs is approximately 2,000 feet in length and
corresponds to areas where potential exposure to FWA soils would occur by either residential or industrial
groups. Only five of the EUs historically contained floodplain soils or concentrations above the CUGs: EU2, EU3,
EU4, EU6, and EU8. The other five EUs were not considered for several reasons. EU1, EU5, and EU7 do not have a
floodplain area and sampling results from EU9 and EU10 were below the CUGs.
History of Contamination
Sediment OU1 and FWA OU4 have been impacted by PCBs, radionuclides, chlorinated benzene compounds,
chlorinated solvents, hexachlorobenzene (HCB), hexachlorobutadiene (HCBD), PAHs, and metals. The sources of
these contaminants are nearby manufacturing operations, which have included metal fabrication and chemical
production since circa 1943.
VI.2 OPERABLE UNITS 1 & 4: RESPONSE ACTION SUMMARY
Basis for Taking Action
Between April 1983 and July 1986, EPA performed a Remedial Investigation/Feasibility Study (RI/FS) for the
Sediment OU1. EPA completed the Rl Report in March 1985 and the FS report in July 1986 (CH2M, 1985 & 1986).
The Rl included a baseline human health risk assessment that demonstrated human health risks from the brook
sediment. Fish consumption was evaluated as part of the 1985 Rl and found that the excess lifetime cancer risk
1
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from ingestion of contaminated fish fillet from the Fields Brook area, although the amount of contaminant
contribution from the brook is uncertain. Sediment OU1 COCs include VOCs, SVOCs, PCBs, and inorganics. Refer
to Table 1-1 in Appendix E for the full list of COCs and corresponding CUGs and CRGs.
The 1985 Rl also addressed health risks from exposure to soils in the floodplain area adjacent to Fields Brook. In
1993, the potentially responsible parties (PRPs) initiated a voluntary assessment of the nature and extent of
contamination in the FWA OU4 of Fields Brook. The PRPs' investigation of the FWA OU4 was conducted under the
oversight of EPA, Ohio EPA and the United States Army Corps of Engineers (USACE) and was completed by the
spring of 1995. FWA OU4 Soil COCs include VOCs, SVOCs, PCBs, and inorganics. Refer to Table 1-2 in Appendix E
for the full list of COCs and corresponding CUGs and CRGs.
EPA prepared a "Focused Ecological Risk Assessment" in 1997 to estimate post-remediation risk levels to
ecological receptors which are or may be exposed to the Brook (EPA, 1997). This focused assessment indicated
the potential for significant risks to ecological populations associated with exposure to PCBs and HCB. The
assessment concluded that hazard quotient (HQ) calculations for post-remediation average concentrations may
exceed 1.0 for several species involved. However, EPA believes that the Sediment OU1 remedy is protective of the
various populations of ecological receptors which exist within the Fields Brook or rely upon food sources
associated with the Fields Brook. The 1997 OU1 ESD incorporated the findings from the 1997 "Focused Ecological
Risk Assessment," and indicated the response actions would reduce the short- and long-term risks to ecological
populations and reduce these population's potential uptake of contamination via soil and food to acceptable
levels of exposure (EPA, 1997). It should be noted that the HQ calculations were developed using conservative
assumptions based on "no observable adverse effect levels" to ecological receptors, which would help provide for
protectiveness to ecological receptors.
Because it was recognized that the cleanup of the Fields Brook sediment should not be performed unless the
source(s) of contamination are addressed prior to the cleanup, EPA required the PRPs to investigate the industrial
area of the Fields Brook watershed. From 1992 to 1995, the PRPs evaluated 94 properties in the Fields Brook
watershed to determine whether the properties could cause future recontamination once the Brook cleanup is
underway. Contamination could be caused by discharges from pipes, the movement of contaminated soil or
sediment during rainstorms, and subsurface releases to the Brook from flowing groundwater. As a result of the
Source Control OU2 evaluation, EPA identified six industrial areas as possible sources of recontamination to Fields
Brook. Detailed information about the types and extent of contamination at the source areas can be found in the
Source Control Rl Report, which was approved by EPA in May 1997 (Woodward-Clyde, 1997).
Response Actions
A. Sediment QUI Decision Documents
Remedial actions for Sediment OU1 were selected in the September 30,1986 Fields Brook Sediment ROD. The
1986 Sediment ROD was subsequently clarified by ESDs issued in 1997, 1999, and 2001 (EPA, 1997, 1999, 2001).
Although an RAO was not specifically cited in the 1986 Sediment ROD, the goal for Sediment OU1 was to manage,
prevent or minimize the release of contaminants from the sediment of Fields Brook and its tributaries, and
therefore eliminate or reduce the risks to public health and the environment. Specifically, the risk associated with
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exposure to (including ingestion of) contaminated sediment would be reduced by sediment removal to levels that
are protective of public health, welfare and the environment. A chronology of significant response events is
included in Appendix D.
Ohio EPA concurred with the 1986 Sediment ROD, however, Ohio EPA did not agree with the 1997 FWA OU4 and
1997 SCOU RODs. Specifically, Ohio EPA recommended lower floodplain soil CRGsfor residential and occupational
areas of Fields Brook to ensure the remedy remains protective and permanent. Ohio EPA expressed concern
regarding EPA's overall approach to risk management for the SCOUs. In 1996, Ohio EPA relinquished its role in
providing joint oversight with EPA for Fields Brook and its role transitioned to a State Natural Resource Damage
and Restoration (NRDAR) Trustee that worked with the federal NRDAR Trustees (DOI/FWS and NOAA) on
assessment and restoration of natural resources trustee of natural resources. EPA and Ohio EPA continue to
coordinate closely on ongoing matters at the Site.
The remedy selected in the 1986 Sediment OU1 ROD involved excavation and containment of contaminated
sediments within an on-site landfill, and on-site thermal treatment of the significantly contaminated or mobile
sediments. Specifically, the 1986 Sediment OU1 ROD included the following components:
1. Excavation of organically contaminated sediment with a greater than lxlO 6 excess lifetime cancer risk
level, and inorganically contaminated sediment to health-based levels or background levels, whichever
was higher (based on residential use scenarios) in Fields Brook. The 1986 Sediment OU1 ROD estimated
that approximately 52,000 cubic yards would be excavated;
2. Construction of an on-site RCRA/TSCA landfill with separate cells for solidified sediments, solidified
sediments containing arsenic, and a temporary storage cell for sediment to be thermally treated;
3. On-site thermal treatment of both excavated sediments with PCB concentrations above 50 ppm, and
sediments with high potential for mobility that have a soil/water partition coefficient (Koc) below 2400.
Treated material would be disposed via landfilling in either: a) the on-site landfill if analysis of the ash
from thermal treatment indicates it requires management as a hazardous waste; or b) in the on-site
landfill or in an off-site solid waste landfill if analysis of the ash from thermal treatment indicates it does
not require management as a hazardous waste. The ROD estimated 16,000 cubic yards of sediment would
be thermally treated;
4. Solidification of the remaining quantity of excavated sediment, and disposal via landfilling in the on-site
landfill. The ROD estimated sediment volume before solidification was 24,000 cubic yards;
5. Treatment of wastewaters generated during construction activities in an on-Site treatment system, with
discharge to the Ashtabula Publicly Owned Treatment Works or directly to Fields Brook;
6. Pre-design studies;
7. Operation and maintenance (O&M) of the remedy;
8. An RI/FS to address any ongoing sources of contamination to Fields Brook; and
9. An investigation to address the nature and extent of contamination in the Ashtabula River.
An ESD was issued in August of 1997 to refine the work to be performed as part of the Fields Brook sediment
cleanup. The following significant changes were made to the remedial action:
1. Elimination of solidification requirements for excavated sediments landfilled on-site;
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2. Thermal treatment of the excavated sediments would be conducted at an off-Site facility instead of at an
on-Site facility;
3. Refinement of the CUGs/standards for the sediment to be excavated (identification of specific CUGs,
based on the desired risk endpoints established in the 1986 Sediment OU1 ROD);
4. Reduction of the excavated sediment estimated total volume from 52,000 cubic yards to 14,000 cubic
yards, including a reduction of the estimated thermal treatment sediment volume from 16,000 cubic yards
to 3,000 cubic yards; and
5. Elimination of the chemical waste landfill requirement of Section 761.75(b)(3), which specifies a fifty-foot
distance between the bottom liner and the historical high-water table.
When the remedial design (RD) for the cleanup of the Fields Brook sediment and the FWA soils was at an
approximately 90% complete stage, EPA received information regarding possible radionuclide contamination in
the Ashtabula River and the Fields Brook watershed. EPA evaluated the available data and the PRPs, under EPA
and Ohio Department of Health Bureau of Radiation Protection oversight, conducted sampling and then
determined that radium should be added as a COC for Sediment OU1 as well as FWA OU4, and the Millennium
TiCI4 Plant OU6. In particular, the 1999 site-wide ESD made the following modifications to the cleanup
requirements for the Brook's sediment:
1. Thermal treatment (incineration and/or low-temperature thermal desorption) was not appropriate for
sediment that contains levels of radium (and other radionuclides) above background. For sediment with
background levels of radionuclides, off-site thermal treatment would proceed as planned. For sediment
with levels of radionuclides above background, the sediment would be chemically stabilized prior to
disposal in the on-site landfill.
2. The design of the on-site landfill built to contain Site soils and sediment from Sediment OU1 and FWA OU4
would be upgraded. FWA OU4 is discussed further below.
3. Monitoring wells around the landfill would be routinely sampled, and the samples would be analyzed for
radionuclides. Air monitoring would be performed at the landfill to ensure that levels of radon gas
emanating from the landfill do not present any risk to human health.
4. Additional soil and sediment would be excavated from the Site to meet the radium cleanup level of 5
picocuries per gram (pCi/g) above background, for combined levels of radium-226 and radium-228 for
residential areas and 10 pCi/g above background for combined levels of radium-226 and radium-228 in
industrial areas of the Site.
5. Consistent with the decommissioning project at the RMI Extrusion property (adjacent to Fields Brook), EPA
utilized a 30 pCi/g cleanup level for uranium (U-238) in floodplain soils and Brook sediment.
In the summer of 2000, the Fields Brook landfill was constructed (Fig. 1-1, Appendix F) and cleanup of the
Sediment OU1 and FWA OU4 began. In the fall of 2000 during excavation, pockets of chlorinated DNAPL were
found below Brook sediments and floodplain soils. An ESD was issued in August of 2001 to address the newly-
identified DNAPL. Because the volume of highly-contaminated material at the Site had significantly increased with
the DNAPL discovery, it now made financial sense to reverse the earlier ESD that had moved the thermal
treatment off-site. Therefore, the 2001 ESD made the following modification to the Sediment OU1 cleanup
requirements:
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1. On-site thermal treatment of DNAPL-impacted soils;
2. Supplemental field sampling and pre-treatment monitoring to ensure that sediment and soils to be
thermally treated do not contain elevated levels of radionuclides; and
3. Off-site thermal treatment of liquid DNAPL.
B. FWA OU4 Decision Documents
Remedial actions for FWA OU4 were selected in the June 30,1997 FWA ROD (EPA, 1997). The RAOs for the 1997
FWA OU4 ROD included reducing: the potential for human health cancer and non-cancer risks; and ecological
risks to levels that would protect animal populations that exist in the FWA. The FWA OU4 RAOs also included an
objective to avoid or minimize destructive impacts to the FWA from construction activities and the final remedy
to the extent practicable in order to protect the ecological value and existing habitats of the FWA. The 1997 FWA
OU4 ROD was clarified by ESDs issued in 1999 and 2001(EPA, 1999 and 2001). The major components of the 1997
FWAOU4 ROD included:
1. Excavation or cover of contaminated soils and sediments in the FWA OU4 that exceed cleanup action
levels; backfill of all excavation and cover areas with hydric-compatible soil;
2. Removal of all trees in excavation areas, and removal of all trees below 12-inch diameter at basal height in
cover areas, with vegetation in response areas considered contaminated, and with live vegetation above
ground surface considered clean if it can be decontaminated;
3. Revegetation of all backfill and cover areas, and revegetation of all areas disturbed during construction,
using erosion mats and native vegetation;
4. Construction of a temporary access road to allow access to and along the floodplain from the roadways
during construction, made of crushed stone and 1/4-inch thick geonet liner, and to be removed after
construction and disposed of either in the on-site landfill or if clean in other on-site or off-site areas;
5. Consolidation of excavated soils and sediments, construction debris, and roadways constructed to
implement the remedy if determined to be contaminated, within an on-site fenced-in containment cell
(landfill) to be built on one of the industrial properties located within the Fields Brook watershed;
6. Construction of a minimum of three down-gradient and one up-gradient monitoring wells to evaluate the
long-term effectiveness of the landfill;
7. Long-term O&M and post closure care of the remedial action to help ensure its effectiveness;
8. Long-term monitoring, including sampling of FWA surface soils, sediments, backfill and cover areas, and
monitoring of wetland conditions at specific locations and for parameters defined in the ROD summary, to
verify the effectiveness of the remedial action;
9. Placement of ICs on deeds and titles for properties where: contamination will remain in the FWA; the
landfill will be constructed; or hazardous substances, pollutants or contaminants will remain above levels
that allow for UU/UE. For the landfill, the deed restrictions must prevent residential, industrial or other
development on the landfill. For all other properties, the deed restrictions must provide notice to any
subsequent purchaser or prospective developer of the presence of hazardous substances and of the
requirement to conduct all development activities in such a manner as to not release contamination; and
10. Implementation of access restrictions, including enclosing the entire landfill area with a fence and posting
warning signs.
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During the RD process, it was determined by all parties that the 6-inch soil cover was impractical since inspection
and long-term maintenance would be difficult. Therefore, the PRPs voluntarily agreed to excavate all soils in the
residential area of the FWA OU4 that contained 6 ppm or greater total PCBs thereby eliminating the need for ICs
in these areas.
As discussed in SectionVI.2.A above, the 1999 Site-Wide ESD included the following modifications for floodplain
soils:
1. Addition of cleanup criteria for radionuclides.
2. The design of the on-site landfill built to contain Site soils and sediment from Sediment OU1 and FWA OU4
would be upgraded.
3. Additional soil and sediment would be excavated from the Site to meet the radium cleanup level of 5
picocuries per gram (pCi/g) above background, for combined levels of radium-226 and radium-228 for
residential areas and 10 pCi/g above background for combined levels of radium-226 and radium-228 in
industrial areas of the Site.
4. Consistent with the decommissioning project at the RMI Extrusion property (adjacent to Fields Brook), EPA
utilized a 30 pCi/g cleanup level for uranium (U-238) in floodplain soils and
Brook sediment.
The discovery of DNAPL below the Brook and floodplain in the fall of 2000 impacted remedial work on the FWA
OU4. The August 2001 ESD allowed the on-site thermal treatment of DNAPL-impacted soil and sediment.
Since the issuance of the 1997 UAO for remedial design/remedial action (RD/RA) for Sediment OU1 and FWA OU4
and the subsequent negotiation and entry of a Consent Decree (CD), which supersedes the UAO, between EPA
and the PRPs, the sediment and FWA OUs 1 & 4 have been addressed together for design and construction as
required by the Sediment OU1 ROD and ESDs and the FWA OU4 ROD and ESD. This made sense because the
cleanup of the streambed and adjacent floodplain would be performed as a single project. The CD was entered on
July 7,1999 (EPA, 1999). Upon entry of the CD, the UAO for Sediment OU1 and FWA OU4 was vacated.
Cleanup Standards
The RDs for the Sediment and FWA OUs 1 & 4 were based on an area-wide averaging approach by dividing Fields
Brook into sections that were termed "Exposure Units (EUs)" (Fig. E-3, Appendix F). EUs are bounded by
geographical features such as roads and bridges and were used to quantitatively assess risk in each area. For the
Sediment OU1, the 1986 Sediment OU1 ROD and 1997 ESD together served as the basis for the selection of CUGs
for COCs. Each numerical CUG is established at a concentration that is protective of human health under the
exposure and risk assumptions used. CUGs for sediment in EUs 1 through 6 are based on residential use; whereas
the CUGs for EU7 and EU 8 are based on occupational (industrial use). The area between State Road and Route 11
is considered to be a "mixing zone" between the industry and residence CUGs, and while no residences exist
there, the area was remediated to residential development levels. CUGs for FWA OU4 soil in EUs 1 through 3 are
based on residential use; the CUGs for EU4 through 8 are based on occupational (industrial use). CUGs for soil
were only required for EU2 and EU3 and EU 4, 6, and 8. Land use is residential adjacent to EUs 1 through 3; and
industrial / vacant industrial for EUs 4 through 8.
6
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Using the assumption that no person would be repeatedly exposed to the exact same area for a long period of
time, the RD allowed an averaging approach over areas. The "Confidence Removal Goal" (CRG) is a statistical
approach to meet CUGs based on the arithmetic mean (average) of the contaminant concentrations within an
exposure unit. It is a value above which remediation is required so that the overall average concentration in each
exposure unit meets the CUGs. Because there are some areas with very low to no concentrations of
contaminants, the CRG can be significantly higher than the CUG, while achieving the CUG for the exposure unit.
As discussed earlier, Ohio EPA did not agree with the risk assumptions that supported the CRG approach and did
not concur with the 1997 FWA OU4 ROD. The Fields Brook CUGs and CRGs were developed by the PRPs in
coordination with the EPA and memorialized by EPA in the 1997 Sediment Operable Unit ESD and the 1997 FWA
OU4 ROD (EPA, 1997). The current values have been summarized by EPA in this FYR Report. Sediment Cleanup
Standards are presented in Table 1-1, and Soil Cleanup Standards are presented in Table 1-2. The CUGs and CRGs
for HCB and associated chlorinated organics, and PCBs, which have been the contaminants "driving" the risk for
the Fields Brook cleanup (Fig. 1-2, Appendix F).
The CUG for PCBs in sediment was set at 1.3 ppm for residential areas of the Brook and 3.1 ppm for industrial
areas of the Brook. For HCB, the sediment CUG was set at 6.38 ppm for residential areas of the Brook and 15 ppm
for industrial areas. Sediment CRGs varied within the Brook, depending on contaminant distributions. Upon
issuance of the 1999 site-wide ESD that addressed radionuclide contamination, a sediment cleanup standard of
10 pCi/g total radium (ra-226 + ra-228) above background was established for industrial areas of the Brook. For
residential areas, sediment would need to meet a standard of 5 pCi/g of total radium above background. A
uranium standard of 30 pCi/g was established for sediment within the Brook (both residential and industrial
areas) to be consistent with the United States Department of Energy cleanup of the RMI Extrusion facility.
For the FWA OU4, two indicator parameters were initially established to guide the cleanup, PCBs and HCB. Like
the Sediment OU1, the remedy for the FWA OU4 was based on an area-wide averaging approach and was
designed to result in a protective cleanup. The CUG for PCBs was set at 1 ppm, on average, for residential areas of
the Fields Brook floodplain and 6 to 8 ppm, on average, in industrial areas of the floodplain. As part of the RD,
supplemental chemical sampling was performed in the floodplain. The RD then developed grid-based excavation
cut lines based on PCB and HCB contamination. In industrial areas of the Brook, areas with total PCB
concentrations at or above 50 ppm and/or an HCB concentration of 200 ppm were to be excavated. In residential
areas, grids with 6 ppm total PCBs and/or 80 ppm HCB were to be excavated. As with the Sediment OU1, the
identification and ultimate excavation of additional soils due to radionuclide contamination is thought to have
further reduced residual chemical contamination to even lower levels. For industrial areas of the floodplain, a
cleanup standard of 10 pCi/g total radium (ra-226 + ra-228) above background was established. For residential
areas, soils were required to meet a standard of 5 pCi/g of total radium above background.
In June 2020, EPA and the FBAG discussed the use of a geospatial composite sampling approach for long term
OM&M sampling of Sediment OU1 and FWA OU4. EPA consulted with the Region 5 internal technical specialist
group, ERT, to advise on the use of a geospatial composite sampling method that more accurately represents the
level of contamination in the Brook utilizing statistics. FBAG agreed to the change in sample collection method
and comparison of the results to the more conservative CUGs versus CRGs. On July 21, 2021, FBAG submitted a
7
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revised draft of the Fields Brook sampling plan memo to EPA, which is currently in review. The revised sampling
and comparison will be memorialized in the future finalized OM&M plan.
Status of Implementation
Remedial action fieldwork began on May 25, 2000 with the construction of the on-site TSCA-equivalent landfill
(Fig. 1-1, Appendix F). The Fields Brook Landfill was built for the disposal of all excavated Fields Brook sediment
and floodplain soils that did not require thermal treatment. In addition, the on-site landfill was to be made
available to the PRPs for disposal associated with the remediation of the Source Control OUs. Landfill construction
was completed on September 6, 2000.
Excavation began in the Brook on September 22, 2000. Excavation of contaminated soil and sediment continued
until October 16, 2000 when chlorinated solvent DNAPL was discovered under sediment and floodplain soils in
the upper industrial reaches of the Brook. Additional field investigations were performed to determine the extent
of the problem and estimate the volume of additional material that would require thermal treatment. On May 7,
2001, excavation work recommenced in other areas of the Brook while work within the DNAPL-impacted areas
remained on hold. As noted above in this Section, EPA issued the August 17, 2001 Sediment and FWA ESD to
address the volume of DNAPL-impacted material by allowing on-site thermal treatment of that material.
A trial burn was conducted at the Site in October 2002. By the time the results of the trial burn were available, all
the contaminated material had been treated at the Site. The operation of the EMSI thermal desorption unit
ceased on December 20, 2002.
The excavation of Fields Brook sediments and floodplain soils was completed on December 16, 2002. Upon
placement of the final materials in the landfill, the landfill was closed.
53,094 cubic yards of contaminated sediment and floodplain soil were excavated from Fields Brook. Of this, 1,435
cubic yards of contaminated sediment and floodplain soil were sent off-site for thermal treatment (before the
discovery of the DNAPL-impacted area and the issuance of the 2001 Sediment and FWA ESD allowing on-site
treatment). 20,420 cubic yards of contaminated soil and sediment that were below background for radionuclides,
was thermally treated on-site. Treated soils were utilized for backfill on-site. Sediment that was not incinerated
because radionuclide levels are above background were solidified to minimize mobility and placed in the on-site
landfill. 30,514 cubic yards of excavated sediment and floodplain soil were sent to the on-site landfill, which
ultimately housed not only material from the Brook, but from Source Control OU2 cleanups as well.
Site restoration in the Brook and floodplain was performed in late 2002 and completed in March 2003. In addition
to the normal seeding and planting of impacted areas, the PRPs worked with EPA and Ohio EPA to determine
what additional activities would be necessary to allow the stream and floodplain system to return to a natural
state. Restoration activities included the addition of willow snags in the Brook, the placement of logs horizontally
on the ground to provide habitat, and the vertical placement of logs to provide perches for raptors. Vegetation
and wildlife have returned to the area.
8
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In 2009, EPA modified the Statement of Work for the 1999 CD necessary to achieve and maintain the
Performance Standards or to carry out and maintain the effectiveness of the remedy set forth in the RODs to
address contamination in EU8 of the Sediment OU1 and FWA OU4 at the Site (EPA, 2009). The FBAG relocated the
Fields Brook channel in EU8. This channel relocation was done to prevent exposure to contaminated sediments
and prevent contaminant migration into Fields Brook. The channel relocation effort included constructing a
DNAPL collection trench under the channel; constructing sedimentation basin in the Millennium excavation;
constructing lined connecting channels, re-routing the Brook to the south; covering the entire stream channel
with an impermeable liner and stone riprap; removing hot spots of contaminated soils; reconstructing Detrex
National Pollutant Discharge Elimination System (NPDES) Outfall; filling in the old Brook channel; and restoring
the EU8 Floodplain.
The drain on the west side of State Road in EU6 was installed to capture contaminants from the North Sewers
pipe bedding materials or bedding material under State Road. In 2009, the drain was removed by the City of
Ashtabula due to the bridge replacement on State Road. The lines connected to the drain were capped on the
east side of State Road.
The RDs for the Sediment and FWA OUs 1 & 4 were based on an area-wide averaging approach to address
samples that exceeded CRGs for specific COCs.
Locations of PCBs exceeding Site CRGs were discovered in the annual soil and sediment sampling activities from
2009-2013. On December 5, 2013, EPA approved an excavation work plan to address the removal and disposal of
remnant PCB contamination in the Fields Brook sediment and floodplain soils (EPA, 2013).
Remedial implementation began on June 12, 2014 and was completed on June 26, 2014. A total of 15 areas (8
sediment and 7 soil areas) were identified in the excavation work plan where PCB contamination levels exceeding
the established site-specific CRGs for PCBs required excavation. The excavation areas included EU1, EU2, EU3,
EU4, and EU6. Excavated sediment and soils were disposed of at the Ineos (formerly Millennium) Landfill in
Ashtabula, Ohio.
Soil and sediment samples collected during the August 2015 annual sampling event indicated PCB levels exceeded
the established site-specific CRGs for PCBs in EU4. FBAG conducted excavation and disposal activities in October
2016 to address PCB contaminated soil and sediment in EU4.
Institutional Controls
Table 1: Summary of Implemented ICs at Sediment OU:
& FWA OU4
Media,
engineered
controls, and
areas that do
not support
UU/UE
based on
ICs
Needed
ICs Called for
in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC Instrument
Implemented and Date
(or planned)
9
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current
conditions
Landfill: Soil,
Groundwater
Yes
Yes
P.P.N. 03-014-
00-05, Vol.
440/1373
Residential use,
groundwater
consumption, or
any other
intrusive use is
restricted
Environmental Covenant
pursuant to Ohio UECA,
plat map, recorded
9/27/10, SDMS #384258
Floodplain:
Soil,
Groundwater
Yes
Yes
EU8 Only
Detrex
Property
Restricts
residential use,
well installation
and ground water
use
Environmental Covenant
pursuant to Ohio UECA,
recorded 11/16/09, SDMS
#353273
Floodplain,
Soil,
Groundwater
Yes
Yes
EU8 Only
Millennium
Property
Restricted
Zone Survey
Drawing
Exhibit C of
Environmental
Covenant
Restricts
residential use,
well installation
and ground water
use
Environmental Covenant
pursuant to Ohio UECA,
recorded 2/10/11, SDMS
#421768
Fields Brook
Sediment
and Soils
Yes
No
EU4-EU8
Limits land use to
light or heavy
industrial
Ashtabula Township
Zoning Rules and
Regulations, Article 8
Section 831-832
Fields Brook
Fish
No
No
Fields Brook
Recommended
fish consumption
limits
2023 Ohio Sport Fish
Consumption Advisory for
Statewide waters, Lake
Erie, and Ashtabula River
Maps of the parcels with the recorded ICs are shown on Figures 1-8, 1-9 and 1-10 in Appendix F.
Status of Access Restrictions and ICs:
ICs are required to assure the long-term protectiveness for any areas that do not allow for UU/UE, and to
maintain the integrity of the remedy. ICs are required at Sediment OU1 and FWA OU4 because the remedy has
not achieved UU/UE.
An existing land use restriction is in place for Sediment OU1 and FWA OU4 that ensures the long-term
protectiveness of the remedy. Zoning ordinances by the City of Ashtabula identify the industrial portions of the
Site as a heavy manufacturing district under Section 832. The specific purpose of use of a heavy manufacturing
district includes the development of major manufacturing, processing, warehousing, and major research, and
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testing operations. As part of the City of Ashtabula zoning requirements, land uses must follow the permitting
process and are subject to enforcement for non-compliance.
The Clean Water Act (CWA) 404 regulations acts as an IC permitting tool to ensure proposed activities in
Sediment OU1 do not impact human health and the environment. The CWA 404 permit process is required for
any proposed work which disturbs sediment and soils in waterways; the CWA 404 permitting process is effective
in ensuring the use of Sediment OU1 remains compliant with the remedy.
The exposure units of Sediment OU1 and FWA OU4 are divided based on the designated land use of either
residential or industrial. EPA designated EUs east of State Road as industrial use; those EUs were remediated to
the cleanup goals. The 1999 Consent Decree can be used as an enforcement tool to ensure the land use for the
EUs continue to be used in the intended manner of either residential or industrial.
The EU8 floodplain is owned by Detrex Div., Elco Corp. (formerly known as (f/k/a) Detrex Corp.) and Ineos
Pigments (f/k/a Millennium Inorganic Chemicals, Inc.), and real estate is held in the name of ABC Chemicals, Inc.
Environmental covenants (ECs) were executed and delivered pursuant to Ohio UECA, Sections §§ 5301.80 to
5301.92 of Ohio Revised Code. These ECs were in place for each of these properties during this FYR period. See
also the Detrex OU5 and Millennium OU6 sections of this report for details about the ICs in this area. An EC was
executed and delivered pursuant to Ohio UECA for the Fields Brook Landfill and was in place during this FYR
period.
A State of Ohio Sport Fish Consumption Advisory has been in place for the section of the Ashtabula River that
includes the discharge point for Fields Brook since 1983. The Ohio Department of Health, in cooperation with
Ohio EPA and the Ohio Department of Natural Resources (Ohio DNR), issues this advice under Ohio law (Ohio
Revised Code Chapter 3701). The 2023 Advisory recommended limited fish consumption State-wide as well as for
specific species in segments of the Ashtabula River and tributaries to Lake Erie. The state-wide advice was first
published in 2007; prior to this, a state-wide "1 meal/week" was applied to all fish not specified in the advisory
due to mercury (Table 1-3, Appendix E). The advisory addresses information, including PCBs and mercury for a
variety of species. Fish move freely between the Ashtabula River and Fields Brook when water levels in the Brook
are sufficiently high. Fishing occurs both in the Ashtabula River and near the mouth of Fields Brook, where the
Brook is somewhat wider and deeper than farther upstream. Although Fields Brook was a significant pathway for
PCB contaminant movement to the river, fishing along upstream reaches of the Brook is not a significant risk
pathway due to its small size and lack of access.
As part of the GLNPO Ashtabula River Area of Concern (AOC), six beneficial use impairments (BUIs) applied and
act as remedial goals. BUI# 1 for the Ashtabula River AOC was to address restrictions to fish and wildlife
consumptions. In 2011, fish tissue samples were collected from the Ashtabula River and Lake Erie according to
the State of Ohio's Sport Fish Tissue Monitoring Program. The fish tissue concentrations in the Ashtabula River
AOC fish were lower than what was detected in the Lake Erie fish tissue samples for the same species. In 2013,
GLNPO completed the sediment removal and restoration of the Ashtabula River AOC. In 2014, the Ashtabula River
and Harbor-specific fish consumption advisory, BUI#1 Restrictions of Fish and Wildlife Consumption, was
removed by Ohio EPA based on the 2011 fish tissue data. The Ashtabula River is still subject to the State-wide and
Lake Erie fish advisories, which are considered background levels and not specific to Fields Brook or the Ashtabula
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River and Harbor. No new fish tissue data has been collected since 2011 which would support the revision of the
current Ashtabula River fish advisories. The Ashtabula River AOC was delisted in 2021. The State of Ohio and EPA
consider the Ashtabula River advisory, the State of Ohio Fish-wide advisory, and the Lake Erie advisory to be an
additional, but not required, component of the remedy which ensures protectiveness of potential contaminant
exposure from fish consumption in the Fields Brook if followed.
The Fish Consumption Advisory is posted on the Ohio EPA website and the Ohio Department of Health website
and is available where licenses are purchased (Table 1-3, Appendix E).
Current Compliance: Based on the FYR site inspection, EPA is not aware of Site or media uses that are inconsistent
with the stated objectives to be achieved by the ICs. The remedy appears to be functioning as intended.
IC Follow up Actions Needed: An Institutional Control Implementation and Assurance Plan (ICIAP) should be
developed for Sediment OU1 and FWA OU4. The purpose of the ICIAP is to conduct additional IC evaluation
activities to ensure that the implemented ICs are effective, to explore whether additional ICs are needed and
ensure their implementation, and to ensure that LTS procedures are in place so that ICs are properly maintained,
monitored, and enforced. IC evaluation activities will include, as needed, developing updated maps depicting
current conditions in areas that do not allow for UU/UE, reviewing current zoning and city or township
ordinances, and reviewing recording and title work for properties impacted by the Site. As part of the ICIAP
development, an evaluation should be conducted to determine if the existing ICs for Sediment OU1 are sufficient
and if additional ICs are appropriate to ensure long-term protectiveness of the Sediment OU1 remedy.
Long-Term Stewardship: Compliance with ICs is necessary to assure the protectiveness of the remedy. Planning
for LTS is therefore required to ensure that the ICs are maintained, monitored and enforced at OU1 and OU4
properties, so that the remedy continues to function as intended. An ICIAP should be completed to document LTS
procedures. LTS procedures should describe at a minimum: (1) monitoring activities and schedules; (2)
responsibilities for performing each task and parties responsible for completing those tasks; (3) reporting
requirements; and (4) a process for addressing any potential IC issues that may arise during the reporting period.
A report should be submitted regularly to EPA to demonstrate that the Site was inspected to ensure no
inconsistent uses have occurred; that ICs remain in place and are effective; and that any necessary contingency
actions have been executed. Results of IC reviews should be provided to EPA in an annual ICs report and with a
certification that the ICs remain in-place and are effective. Finally, development of a communications plan and
use of Ohio's one-call utilities notification system should be explored for broader information sharing of
applicable ICs implemented at Fields Brook (see notes related to North Sewers OU7).
Systems Operations/Operation & Maintenance
The "Operation, Maintenance and Monitoring (OM&M) Plan for the Sediment and Floodplain/Wetland Operable
Units" was approved on May 4, 2004 (O&M Inc., 2004). The OM&M Plan addresses post-remediation sampling
within the Brook, in terms of both scope and the duration. Since approval of the OM&M Plan, sediment and FWA
soils have been sampled and analyzed annually to monitor the status of the Brook. Samples are taken from
backfill areas within the floodplain and streambed (where excavation occurred, and clean fill materials have been
12
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placed) to ensure that residual contaminants have not contaminated what should be clean areas. In addition,
samples are also taken from areas that were not excavated to ensure that health-based levels are not exceeded
and to track residual contamination. The OU1 and OU4 remedies contemplate exceedances of cleanup goals in
the sediment and soils of Fields Brook and requires subsequent response actions to be taken. Under the 1999 CD,
FBAG is required to incorporate post-cleanup sampling requirements to evaluate the need for remedy repairs in
accordance with the NCP 40 CFR Part 300. Correction actions are to include descriptions of planned actions and
proposed schedule.
Currently, annual OM&M Sediment OU1 sampling involves collection and analysis of samples from 20 discrete
locations within the Fields Brook sediment. Floodplain and wetland sampling consists of collection and analysis of
samples from 25 discrete locations within floodplains along Fields Brook. Figures 1-3 through 1-7 in Appendix F
depict the OM&M sampling locations for each EU. OM&M sampling of EU7 is not performed as the reach does
not have a floodplain and soil "hot spots" were removed by excavation during the remedial action. Review of the
data is conducted against CRG action levels to determine if further sampling, or remedial activity, such as liner
repair or excavation is required. The current sediment sampling approach is biased towards depositional areas in
the Brook, and once finalized the proposed changes to the plan will allow for more uniform distribution of
sediment samples in each EU and more balanced spatial assessment of conditions within Fields Brook. The
current soil sampling approach is also biased towards areas of the floodplain that were previously remediated.
The utilization of composite sampling allows for more uniform and unbiased distribution of soil samples in each
EU, including areas not remediated.
On May 28, 2015, EPA recommended an Incremental Sampling Methodology (ISM) for Sediment OU1 and FWA
OU4 sampling vs collection of a single composite sample. EPA also recommended moving soil sample locations
annually. These recommendations were adopted in the OM&M draft dated July 21, 2021.
Since June 2020, EPA issued several comment letters pertaining to the use of geospatial sampling in the OM&M
Plan for the Sediment and Floodplain/Wetland OUs. Geospatial sampling uses a number of subsamples within
each designated decision unit (DU). All subsamples are then composited, and a single sample is drawn from the
composite. The analytical results are similar to calculating the average concentration from an equal series of
discrete samples for each DU. The 95% confidence interval is calculated using the global variance of triplicate
results. This provides a threshold value where there is 95% confidence that a decision unit less than the threshold
is less than the decision criteria.
This geospatial composite sampling approach was prepared by FBAG with the understanding that human
receptors at the Site may be exposed to accessible sediments, primarily along the banks of the Brook, and that
wading or other recreation activity within the Brook is extremely infrequent, if at all.
FBAG submitted the revised draft OM&M Plan, "Fields Brook Superfund Site, Post-Closure, Operations,
Maintenance, and Monitoring Plan," dated July 21, 2021, which incorporated the geospatial sampling method for
soil and sediment in Sediment OU1 and FWA OU4. As of the date of this review, EPA and FBAG continue to
address comments on the revised draft of the OM&M Plan. This FYR includes a recommendation in OPERABLE
UNITS 1 & 4: ISSUES/RECOMMENDATIONS to finalize an updated OM&M Plan is expected to be finalized before
the next FYR by December 31, 2024.
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In March 2023, EPA requested that FBAG collect sediment samples from EU5. The request was made due to
observed events at Detrex OU5 to determine whether they impacted the stretch of EU5 which is immediately
adjacent to OU5. On March 7, 2022, Ohio EPA was at the Detrex facility on EPA's behalf and observed the
overflow of untreated water from Tank 004. Later it was discovered that Tank 004 contains untreated
contaminated water, decanted groundwater the DNAPL recovery system, and other process water from the
chemical manufacturing processes at Detrex. VOC and SVOC contaminated groundwater is collected from the
DNAPL water (discarding the decanted water into the storm water inlet). The water is then conveyed through the
stormwater inlet to Tank 004 for treatment. Ohio EPA Division of Surface Water (DSW) was informed on May 5,
2022, via email that overflow events occur less than three times a year, and that these events do not happen
every year. The groundwater collection system consists of trenches installed along the slurry wall, DS Tributary,
and southern portion of the Detrex facility. The overflow from Tank 004 was observed to flow onto the northwest
lawn of the Detrex facility and past the slurry wall (Appendix C). The overflow of Tank 004 is discussed in further
detail in Section VII.2. EPA expressed concern of the potential groundwater pathway to effect EU5 and requested
FBAG collect samples from EU5 sediment. FBAG agreed to collect samples from EU5 to evaluate potential
contamination of the Fields Brook; three sediment samples were collected from EU5 during the 2023 August
OM&M sampling event. At the time of this review, the validated sample results from EU5 are not available.
In 2021, EPA requested FBAG collect water samples from the sentinel monitoring "French Drainage System"
under the sedimentation basin in EU8 as part of the surface water sampling required for OU1 and OU4. Since EU8
has historically been the location of where NAPL has been present in subsurface soils, a subsurface French drain
was installed lengthwise beneath the newly constructed EU8 basin and Brook. There are three sump locations
with risers for occasional sampling of the drain system. The East, Center, and West sumps will be monitored as
part of the OM&M Plan for OU1 and OU4. If sample results indicate the potential presence of NAPL, the drainage
system will be pumped, treated, and disposed of by either Detrex, Ineos, or an alternate off-site disposal source.
In addition to the sampling within the Brook, the "Fields Brook Superfund Site, Post-Closure, Operations,
Maintenance, and Monitoring Plan," dated July 21, 2021, includes long-term activities associated with the upkeep
of the Fields Brook on-site landfill. Other activities include the annual sampling regime for the groundwater
monitoring wells around the landfill, monthly inspections, routine maintenance of the landfill cover, and leachate
collection and disposal procedures. Appendix A includes a list of the monthly OM&M reports, including a landfill
cap inspection and leachate collection. EPA determined that radon as not a concern in the open air surrounding
the landfill. In 2004, the air-monitoring requirement was eliminated and not required as part of OM&M.
Annual OM&M sampling between 2019-2021 indicated soil and sediment samples are below the established
CRGs for the corresponding EU. EPA is not in receipt of the Final 2022 Annual OM&M report at the time of this
review due to a delay in analysis at the lab. As a result, FBAG conducted a focused resampling event to collect soil,
sediment, and surface water samples in June 2023. The validated data from the 2022 and 2023 annual OM&M
sampling events are not available at the time of this review, further evaluation is recommended once validated
data is available. The 2022 and 2023 annual OM&M reports will be included in the next FYR in 2029.
VI.3 OPERABLE UNITS 1 & 4: PROGRESS SINCE THE LAST REVIEW
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This section includes the protectiveness determinations and statements from the last FYR as well as the
recommendations from the last FYR and the current status of those recommendations.
Protectiveness Determinations/Statements from the 2019 FYR
Table 2: Protectiveness Determinations/Statements from the 2019 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
1,4
Short-term
Protective
The remedy for the Fields Brook Sediment and FWA OUs (OU1 and OU4)
currently protects human health and the environment. The response actions
selected in the 1986 and 1997 RODs and subsequent ESDs to remove and contain
contaminated sediments and floodplain soils within an on-Site landfill, and on-
Site thermal treatment of the significantly contaminated or mobile sediments,
have proven to be effective in addressing the risks associated with the site.
Effective ICs in the form of ECs have been recorded. However, in order for the
remedy to remain protective in the long term, the following actions need to be
taken to ensure protectiveness: update the OM&M Plan after additional field
work is completed; install warning signs on the fence surrounding landfill-
develop and submit an ICIAP which describes the plan for ensuring that all
remaining required ICs at the Site are implemented, and for ensuring that all ICs,
once implemented, are monitored and maintained; and develop and implement
a LTS Plan for monitoring and tracking compliance with existing ICs,
communicating with EPA, and providing an annual certification to EPA that the
ICs remain in place and are effective.
Status of Recommendations from the 2019 FYR
Table 3: Status of Recommendations from the 2019 FYR
OU#
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable)
1,4
Reassessment
of OM&M
requirements
Update OM&M Plan
after additional field
work is completed.
Addressed in
Next FYR
The recommendation has been
changed due to discussions with
FBAG since the last FYR. The OM&M
Plan update will include use of the
composite sample collection method
and comparison against established
CUGs. Completion of the updated
NA
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OM&M plan has milestone date of
12/31/2024.
1,4
An Institutional
Control
Implementation
and Assurance
Plan (ICIAP) is
needed to
ensure that
effective ICs are
implemented,
monitored and
maintained.
Develop and submit
an ICIAP which
describes the plan
for ensuring that all
remaining ICs at the
Site are
implemented,
monitored, and
maintained.
Ongoing
Ongoing coordination with FBAG to
submit an ICIAP for OU1/OU4.
Completion of the ICIAP has a
milestone date of 6/25/2028.
NA
1,4
Procedures not
in place to
ensure LTS of
ICs.
Develop and
implement a LTS
Plan for monitoring
and tracking
compliance with
existing ICs and
provide annual
certification to EPA.
Considered
But Not
Implemented
LTS procedures will be included in
the ICIAP; a separate LTS Plan is not
needed.
NA
1,4
Warning signs
missing from
fence
surrounding
landfill.
Install warning signs
on fence
surrounding landfill.
Complete
Warning signs were installed on the
fence surrounding the Fields Brook
Landfill.
6/25/2019
VI.4 OPERABLE UNITS 1 & 4: FYR PROCESS
Data Review
A list of technical reports and other documents reviewed for this FYR are included in Appendix A -Reference List.
Due to the missed analysis of VOCs on certain samples from the August 2022 annual OM&M sampling event,
samples were collected from the following sample locations in June 2023: SD-11, SD-12, SD-13, SD-17, SD-18, SD-
20, SD-21, SS-27, and SW-22. The validated data from the 2022 and 2023 annual OM&M sampling events are not
available at the time of this review, further evaluation is recommended once validated data is available. The 2022
and 2023 annual OM&M reports will be included in the next FYR in 2029. Tables 1 through 3 in the 2021 Annual
OM&M Soil, Sediment, and Surface Water Sampling Report includes data from the previous five years.
1. The collection of soil and sediment samples are required to demonstrate the effectiveness of the Sediment
OU1 and FWA OU4 remedies. Proposed soil and sediment sample locations are selected based on historical
"hot spot" concentrations of PCBs detected throughout the EUs and potential depositional areas within the
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Brook for Sediment 0U1 or locations where no excavation activities occurred in FWA 0U4. Surface water
samples are analyzed for PCBs and VOCs. FBAG submits soil, sediment, surface water, and landfill
groundwater data to EPA annually.
a. Soil samples from the August 2019, Aug 2020, and Aug 2021 monitoring events are below the CRGs
cleanup goals and achieve the Sediment OU1 RAO of minimizing the release of contamination from
the sediment of Fields Brook.
b. Between 2019-2021 sediment samples were unable to be collected from the following locations
within EU8 due to riprap obstruction at SD-14, SD-15, SD-16, and SD-19. However, soil and surface
water samples collected nearby the obstructed sample locations are below the CRG cleanup goals
and indicate recontamination of the Brook is not occuring.
c. Between 2019-2021 surface water samples detected low level concentrations of VOCs (ranging from
0.55 to 2.9 ug/L) which indicate recontamination of the Brook is not occuring.
d. The purpose of the landfill groundwater monitoring program is to provide for early detection of
leachate from the landfill if released into the groundwater. Groundwater samples collected from the
Fields Brook landfill monitoring wells between 2019 and 2022 remain below the analytical reporting
limit for VOCs, SVOCS, and PCBs.
2. There have been no CRG exceedances of VOCs, SVOCs, metals, PCBs, and radium-226 and -228 in EU8 soil
and sediment since the engineered Fields Brook relocation structure was completed.
3. In consultation with Region 5 EPA's Toxicologist, changes in COC toxicity characteristics used to calculate
cleanup goals were evaluated; no changes in toxicity except for TCE. The OM&M data show the current
conditions of the sediment and floodplain soils are within EPA's acceptable risk range.
4. The data collected from 2019 to 2021 is sufficient for the purpose of this FYR as the data demonstrates
there are no unacceptable impacts or exposures occurring from the Brook. The data collected from 2019 to
2021 is consistent with historic data collected from 2004 to 2018. In the event an exceedance is detected,
from the 2022 or 2023 data, the OU1 and OU4 remedies require the PRPs to take corrective action in the
event exceedances occur. It is unlikely that conditions of the brook have changed based on the observed
land use and conditions of Fields Brook during the OM&M sampling events and FYR site inspection. This is
substantiated by OM&M data collected since 2004 and corrective actions taken are in compliance with the
remedy.
Site Inspection
The inspection of the Fields Brook Site Sediment OU1 and FWA OU4 was conducted on August 22, 2023. In
attendance were Anna Nguyen, EPA; Jenny Polster, EPA; Amy Gahala, EPA; and Nick Roope, Ohio EPA. Bob Rule,
de maximis inc., representing the FBAG, participated. The purpose of the inspection was to assess the
protectiveness of the remedy. No formal interviews were conducted as part of the fifth FYR. Details of the
inspection are provided in the FYR Inspection Checklist (Appendix B) and FYR Inspection Photos (Appendix C).
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The weather during the Site inspection was partly cloudy with temperatures in the high 70's (Fahrenheit) in the
afternoon.
1. Monitoring well FB-05 of the Fields Brook Landfill appeared to have frost heave; this was raised to Bob
Rule during the Site inspection.
2. ICs and access controls were observed. No inconsistencies were noted with the objectives to be met by
the ECs that are on record for Sediment OU1 and FWA OU4.
3. On-site activity logs for the landfill were reviewed and determined to be complete. Details of OM&M
activities are regularly provided to EPA in monthly reports and are reviewed at the EPA office.
4. Landfill covers appeared to be well maintained.
5. In April 2023, approximately 1,200 yards of barbed wire from the top of the west boundary fence along
State Road and the top of the east boundary fence along the railroad yard was stolen. A police report was
submitted on April 28, 2023. The barbed wire has not been replaced as FBAG is waiting on
recommendations from the police on how to prevent theft from reoccurring.
Remedy components were observed to be in good repair and functioning properly. These include the EU8 Brook
Realignment Structure, groundwater and DNAPL interception trenches, and monitoring wells.
VI.5 OPERABLE UNITS 1 & 4: TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
Yes. The response actions selected in the 1986 and 1997 RODs and 1997, 1999, and 2001 ESDs to remove and
contain contaminated sediments and floodplain soils within an on-Site landfill, and on-Site thermal treatment of
the significantly contaminated or mobile sediments, have been shown to be effective in addressing the risks
associated with the Site. Effective ICs in the form of ECs have been recorded.
An ICIAP containing LTS procedures should be developed and implemented to ensure that the effective ICs are in
place, and are maintained, monitored, and enforced at Sediment OU1 and FWA OU4 so that the remedy
continues to function as intended. As part of the ICIAP development, an evaluation should be conducted to
determine if the existing ICs for Sediment OU1 are sufficient and if additional ICs are appropriate to ensure long-
term protectiveness of the remedy.
Routine monitoring from 2019 to 2021 indicates COC concentrations in soil and sediment remain below the
established CRGs. Low level concentrations of VOCs have been detected in surface water samples between 2019
and 2021, but do not indicate recontamination of the Brook sediments which would exceed CRGs. Additional
evaluation of the 2022 and 2023 validated data should be conducted once provided to the EPA.
The data collected from 2019 to 2021 is sufficient for the purpose of this FYR as the data demonstrates there are
no unacceptable impacts or exposures occurring from the Brook. The data collected from 2019 to 2021 is
consistent with historic data collected from 2004 to 2018. In the event an exceedance is detected from the 2022
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or 2023 data, the OU1 and OU4 remedies require FBAG to take corrective action. Based on conditions observed
during OM&M sampling events and the August 2023 FYR Site inspection, conditions of the brook have not
changed. This is substantiated by OM&M data collected since 2004 and corrective actions taken are in compliance
with the remedy.
The engineered Fields Brook relocation structure appears to be successfully isolating the Brook from the existing
contamination below it as there has been no CRG exceedance of VOCs, SVOCs, metals, PCBs, and radium-226 and
-228 in EU8 soil and sediment since it was completed. However, OM&M activities may identify pockets of
contamination due to random movement of COCs in the stream channel. Updates to the OM&M Plan and QAPP
are required to memorialize the anticipated composite sampling method collection and evaluation against the
CUGs.
Based upon a review of regular reporting, landfill groundwater data, and the Site inspection, the on-Site Fields
Brook landfill appears to be performing adequately. FBAG performs monthly monitoring of the Leachate
Collection System and Leachate Detection System. When leachate water is found in the Leachate Collection
System and Leachate Detection System, it is removed and transferred to the Ashtabula publicly owned treatment
works for treatment. Sediment and soils from Sediment OU1, FWA OU4 and some of the source control OUs were
disposed in the landfill. The landfill cover and access controls are in good condition.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the
remedy selection still valid?
Question B Summary:
Yes. The exposure assumptions used to establish the CUGs for the residential and industrial areas of the Brook are
still valid. Land use along the Brook is still consistent with the assumptions used to determine where residential
and industrial cleanups would be performed.
A review of IRIS shows that the toxicity data forTCE changed in 2011. A review of the sediment and soil O&M
data from the five-year review period show the cleanup levels of TCE remain within the EPA's acceptable risk
range.
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy?
No. According to the National Weather Service, the annual average of precipitation near Ashtabula, Ohio has
increased between 2019 to 2024; the increase in the average precipitation may indicate the increase in the
frequency and/or severity of wet weather events. Based on the monthly water inventory report by the Ohio
Geological Survey, the amount of precipitation from 2019 to 2024 in the Northeast area of Ohio deviates from the
historic level of precipitation by 2.61 to 8.53 inches of rainfall. There are no observed impacts or effects from
natural disasters which may affect the protectiveness of the remedy.
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VI.6 OPERABLE UNITS 1 & 4: ISSUES/RECOMMENDATIONS
OU(s) without Issues/Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
OU(s): 1,4
Issue Category: Operations and Maintenance
Issue: Reassessment of OM&M sample collection method and evaluation
against CUGS.
Recommendation: Update OM&M Plan to include composite sample
collection method and comparison against established CUGs.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
OU(s): 1,4
Issue Category: Institutional Controls
Issue: Additional ICs may be to ensure long-term protectiveness of
Sediment OU1.
Recommendation: Evaluate existing ICs for long-term protectiveness of
OU1 and if applicable, identify which additional ICs are necessary for
Sediment OU1.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
OU(s): 1,4
Issue Category: Institutional Controls
Issue: An ICIAP is needed to ensure that effective ICs are implemented,
monitored, and maintained.
Recommendation: Develop and submit an ICIAP which describes the plan
for ensuring that all remaining required ICs at the Site are implemented,
and for ensuring that all ICs, once implemented, are monitored and
maintained.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
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No
Yes
PRP
EPA
6/25/2028
OU(s): 1,4
Issue Category: Monitoring
Issue: Update QAPP based on anticipated use of the composite sample
collection method.
Recommendation: Update QAPP to reflect changes made in the finalized
OM&M Plan.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
6/25/2025
OTHER FINDINGS
In addition, the following are recommendations that were identified during the FYR and may improve
performance of the remedy, improve management of O&M, and/or accelerate Site close out, but do not affect
current nor future protectiveness:
1. During the September 2010 OM&M Site inspection, the impermeable liner of the Brook was observed to
be bulging and floating. Repairs were completed by FBAG in late 2011. As documented in the 2014 and
2019 FYRs, FBAG has not yet submitted a completion report for the liner repairs required in Part 4, of the
2009 SOW Modification, so EPA has not officially closed out this work under the CD (1999 CD Section XI
"EPA approval of Plans and other Submissions"). However, the work is documented in oversight reports
from EPA's RAC Contractor and appears to be complete. It is recommended that EPA issue a
memorandum to file to memorialize the documented work in the RAC Contractor oversight reports.
2. In December 2018, an energy company contacted EPA regarding a proposed installation of a gas pipeline
that appears to run along the right of way along the entire length of the North Sewers OU7. The specific
area of interest was located within the Fields Brook superfund site along the north side of EU5 and west
side of State Road between EU5 and EU6. Details of the coordination and response efforts between EPA
and the energy company are further discussed in Section IX. It is recommended that EPA follow up with
the energy company on a regular basis to confirm the active or inactive status of the pipeline project to
ensure coordination with EPA if the pipeline project proceeds.
VI.7. OPERABLE UNITS 1 & 4: PROTECTIVENESS STATEMENT
Protectiveness Statement(s)
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Operable Unit: Protectiveness Determination:
0U1 and OU4 Short-term Protective
Protectiveness Statement: The remedy for the Fields Brook Sediment and FWA OUs (OU1 and OU4)
currently protects human health and the environment. The response actions selected in the 1986 and
1997 RODs and subsequent ESDs to remove and contain contaminated sediments and floodplain soils
within an on-Site landfill, and on-Site thermal treatment of the significantly contaminated or mobile
sediments, have proven to be effective in addressing the risks associated with the Site. Effective ICs in
the form of Environmental Covenants have been recorded. Based on historic soil, sediment and surface
water data collected from annual sampling events from 2019 to 2021 indicate the Sediment OU1 and
FWA OU4 remedies are effective. Historical data since 2004 supports this assessment of the remedy in
the sediment and floodplain. Landfill groundwater data collected from 2019 to 2022 indicates leachate
is not impacting the groundwater near the landfill. However, in order for the remedy to remain
protective in the long term, the following actions need to be taken to ensure protectiveness: update
the OM&M Plan to include composite sampling method, data evaluation against CUGs; update the
QAPP to reflect the anticipated changes made in the finalized OM&M Plan; evaluate existing ICs for
long-term protectiveness of OU1 and if applicable, identify which additional ICs are necessary for
Sediment OU1; and develop and submit an ICIAP which describes the plan for ensuring that all
remaining required ICs at the Site are implemented, and for ensuring that all ICs, once implemented,
are monitored and maintained.
VII. OPERABLE UNIT 5: DETREX CORPORATION SOURCE AREA
VII.1 OPERABLE UNIT 5: INTRODUCTION
OU Summary
The purpose of this FYR is to determine if the Detrex Corporation Source Area OU5 (Detrex OU5) remedy is
protective of human health and the environment. The remedy included the construction of a partial slurry wall,
excavation of sediments within a retention basin and drainage ditch for transportation and disposal on-site,
installation of a soil cover over an area of low-level soil contamination, construction of a groundwater intercept
trench; installation of DNAPL extraction wells; and ICs. The extraction wells were replaced by DNAPL passive
collection wells.
The Detrex Site Map shows the remedy as presented in the 1997 SCOU ROD (Fig. 5-1, Appendix F). The Detrex
Map shows site features and soil borings as they exist currently (Fig 5-2, Appendix F).
The purpose of the cleanup at the Detrex OU5 was to address contaminated surface soils, sediment,
groundwater, and DNAPL that had the potential to migrate towards Fields Brook. The remedial action at Detrex
OU5 was initiated in August 2000 and became operational and functional in October 2002, with the startup of the
DNAPL extraction system. The 2014 ESD allowed for the DNAPL passive collection system, which was fully
operational in June 2016.
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This is the fifth FYR for the Detrex OU5 of the Fields Brook Site.
Background. Land and Resource Use
The Detrex Corporation (Detrex) property is in the northeastern portion of the Fields Brook watershed adjacent
to the north bank of the main channel of Fields Brook and encompasses 58 acres. Structures on the property
include a process building, office building, and numerous aboveground storage tanks that are either within diked
areas, paved areas, or on the ground surface. The northern one-third of the property is used for chemical
manufacturing and the southern two-thirds are largely undeveloped. The northeast portion of the property
includes former lagoons which were drained and capped with clay by Detrex in the late 1970's. Detrex currently
produces zinc dialkyldithiophosphates and hydrochloric acid, and previously produced trichloroethene and
tetrachloroethene via chlorination of acetylene.
The area is in the Lake Plain physiographic province of Ashtabula County. The elevation of the Lake Plain ranges
from 620 ft. mean sea level to 660 ft. In general, the subsurface geology of the Fields Brook watershed near
Detrex consists of three geologic formations. In descending order, these formations are glacial-lacustrine, glacial
till, and shale bedrock.
No drinking water wells are located within the industrialized portion of the watershed. The water supply for the
industries and residences in the area is from Lake Erie.
History of Contamination
The primary chemicals of interest at Detrex from current operations include furan, monomethyl amine, n-methyl
pyrrole (NMP), pyrole and ammonia, while the chemicals of interest from past operations include
trichloroethene, 1,1,2,2-tetrachloroethane, HCBD, HCB, and tetrachloroethene.
Results from sampling conducted during the 1997 Source Control Rl indicated that surface soil exceedances for
Fields Brook VOC and SVOC COCs were identified in several areas of the Detrex facility. These areas include: the
stormwater collection ditch on the northern property line, several abandoned retention ponds, construction
debris piles, sediment in the stormwater settling collection basin, and a catalyst pile. In addition, the 1997 Source
Control Rl identified DNAPL in groundwater at the Detrex facility. The Source Control Rl determined that the
following areas should be addressed to reduce possible sources of future contamination to Fields Brook:
1. Seven Closed Lagoons
The closed lagoons are in the northeastern portion of the Detrex property. Subsurface soil samples
collected from the area surrounding the lagoons were found to contain several VOCs and SVOCs at
concentrations exceeding occupational CUGs. In addition, DNAPL was identified in the shallow
groundwater bearing formation both in the closed lagoon area and at RMI Sodium, an adjacent property.
Four VOCs (1,1,2,2-tetrachloroethane, 1,2-dichloroethene, tetrachloroethene, and trichloroethene) and
three SVOCs were identified (HCB, HCBD, and hexachloroethane) in the DNAPL. The DNAPL plume was
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determined to be migrating to the northwest, consistent with groundwater flow and the structure of the
top of the underlying till layer.
2. Sources Within the Surface Water Treatment System
The surface drainage system in the northern industrialized portion of the Detrex property was modified to
collect and treat surface water. Of the area within the bounds of the surface water treatment system,
approximately 60,000 sq ft. of surface area had soil with CUG exceedances of VOCs and SVOCs. The
ponded area in the lagoon area covered approximately 4,000 sq ft. within the surface drainage system. In
addition, approximately 1,500 sq ft along the drainage ditch had surface soil CUG exceedances. The DNAPL
plume underlies the surface drainage system.
3. Catalyst Piles
During the Source Control Rl, the catalyst piles located on the southern portion of the Detrex property,
near Fields Brook were not considered a potential source of sediment recontamination. A surface soil
sample located downslope of the floodplain detected a concentration of 40 ppm PCBs. Subsequent
sampling of the catalyst material found the presence of PCBs greater than occupational CUGs for the
Fields Brook sediment.
VII.2 OPERABLE UNIT 5: RESPONSE ACTION SUMMARY
Basis for Taking Action
The scope of the Source Control remedy for Detrex is limited to those areas that have the potential to
recontaminate the Fields Brook sediment above the CUGs which poses a risk to human health. Specifically, the
risk associated with exposure to (including ingestion of) contaminated sediment would be reduced by sediment
removal levels that are protective of public health, welfare, and the environment. Evaluations of organic chemical
contamination in Detrex's soils and groundwater and the presence of DNAPL below the Detrex property led EPA
to believe that Detrex was a potential source of recontamination to the Brook. The primary chemicals of interest
at Detrex from current operations include furan, monomethyl amine, NMP, pyrole and ammonia, while the
chemicals of interest from past operations include trichloroethene, 1,1,2,2-tetrachloroethane, HCBD, HCB, and
tetrachloroethene.
Detrex OU5 soil COCs include VOCs, SVOCs and PCBs. Groundwater COCs include VOCS and SVOCs. DNAPL was
identified in the shallow groundwater bearing formation. Four VOCs were identified (1,1,2,2-tetrachloroethane,
1,2-dichloroethene, tetrachloroethene, and trichloroethene) and three SVOCs were identified (HCB, HCBD,
hexachloroethane).
In 1989, EPA issued a UAO to several PRPs, including Detrex Corporation, to complete a RI/FS of Detrex OU5 (EPA,
1989). From 1992 to 1995, the PRPs evaluated 94 areas within the Fields Brook watershed, including Detrex OU5
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as part of the Rl. Contamination could be caused by discharges from pipes, the movement of contaminated soil or
sediment during rainstorms, and subsurface releases to the Fields Brook from flowing groundwater.
As a result of this evaluation, the PRPs identified five industrial properties as sources of contamination or
potential contamination to Fields Brook. The industrial properties include Detrex. Detailed information about the
types and extent of contamination at the source areas, including Detrex, can be found in the Source Control Rl
reports. The final Phase 1 Source Control Rl was approved in May 1997. As part of the 1997 Source Control Rl,
source control operable units, such as Detrex OU5, were evaluated to determine the extent that contaminant
movement could cause a CUG exceedance in the Fields Brook sediment.
In conjunction with the preparation of the Source Control Rl Report, the PRPs prepared a Source Control FS to
identify and evaluate cleanup alternatives. The Source Control FS was finalized in June 1997.
Response Actions
Remedial actions for the Detrex OU5 were selected in the 1997 SCOU ROD. The selected remedy for the Detrex
source area required the containment and treatment of contaminated groundwater via the construction of a
partial slurry wall and vacuum-enhanced extraction wells followed by treatment of contaminated groundwater
with the existing water treatment system. Although a RAO was not specified in the 1997 SCOU ROD, the goal of
the Source Control OU is to remediate source areas that have the potential to cause sediment contamination to
Fields Brook and its tributaries, thereby preventing the recontamination of the areas that will be addressed by the
Sediment OU1 and FWA OU4. The remediation of Detrex OU5 was limited to actions needed to prevent
recontamination of Fields Brook. The cleanup at Detrex OU5 is not intended to fully remediate the facility. The
Source Control action supports the Sediment OU1 and FWA OU4 remediation by helping to ensure that human-
health based CUGs are maintained. See Fig. 5-1 in Appendix F for a map showing features relevant to the Site
remediation. A chronology of significant events is included in Appendix D.
The selected remedy for the Detrex OU5 consisted of the following:
1. Clear Debris and Vegetation, Remove Physical Hazards
In order to implement the remedial action, debris and vegetation were to be cleared in response and work
areas. Physical hazards that could threaten workers were also to be addressed prior to the remedial
action.
2. Construction of Partial Slurry Wall
A partial slurry wall was to be constructed to restrict the flow of groundwater contamination from the
Detrex property. The slurry wall component was to extend beyond the downgradient portion of the on-
site and off-site DNAPL and dissolved phase plume and be located outside of the DNAPL area of impact. In
addition, the slurry wall was to extend as necessary to ensure that the DNAPL and contaminated
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groundwater flowing towards Fields Brook or the DS Tributary, particularly along the northern and
western directions from the Detrex facility, would be contained or captured.
The slurry wall was to be constructed of a soil-bentonite slurry or other clay mineral slurry. The
permeability of the slurry wall was to be designed to be approximately 1 x 10~6 cm/sec. Due to the high
percentage of naturally occurring clay soil material in the proposed slurry wall area, the ROD noted that it
may be possible to reuse a portion of the excavation spoils by incorporating them into the slurry wall. The
remaining excavation spoils were to be temporarily stockpiled on-site and characterized to evaluate on-
site and off-site disposal options.
3. Passive DNAPL Recovery System to replace Vacuum-Enhanced Extraction Wells
The 1997 SCOU ROD required vacuum-enhanced extraction wells to be installed near the leading edge of
the DNAPL plume near the slurry wall and within the plume to lower groundwater and collect DNAPL in
source areas. The 1997 SCOU ROD also provided considerations for the evaluation of the performance of a
DNAPL extraction system. The 1997 SCOU ROD references EPA guidance that recommends that long-term
remediation objectives of DNAPL remedies should be to remove free-phase, residual and vapor phase
DNAPL "to the extent practicable". The 1997 SCOU ROD also notes that the DNAPL is a principal threat,
selects a remedy requiring a combination of containment and active removal of DNAPL and states that
"Complete removal of DNAPL in low permeability clay soils is not possible with currently available
technology and treatment to asymptotic levels is expected". While recognizing the difficulties of DNAPL
removal, the SCOU ROD emphasized DNAPL removal as an important element in the selected remedial
action for Detrex OU5.
The liquid phase from the knockout tank was to be conveyed to a DNAPL/water separator where DNAPL
will be separated from water. The separated DNAPL was to be collected and transported to an off-site
facility for treatment or recycling. The separated water was to be conveyed to the existing activated
carbon treatment system at the Detrex facility.
Performance challenges of the vacuum-enhanced DNAPL recovery system led to limited recovery of the
DNAPL. After additional investigations, on January 15, 2014, EPA issued an ESD (EPA, 2014). The 2014 ESD
eliminated the vacuum-enhanced DNAPL extraction wells installed at Detrex, as they were not effective.
The 2014 ESD provided metrics for well type, spacing and bounding of the DNAPL. It also provided criteria
for determining when DNAPL is no longer mobile, and for closing and abandoning the extraction wells. The
2014 ESD did not affect the previous RODs for Fields Brook sediment or floodplain. The number of wells,
their design, and location were required to be in place and operational by June 30, 2016.
4. Surface Water and Erosion Control / Soil Cover
Low-lying areas within the existing surface water collection system area on the Detrex facility and areas
with surface soil occupational CUG exceedances were to be filled and re-graded. In addition, these areas
were to be covered with 12-inches of soil cover, an erosion control blanket, and a vegetative or crushed
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stone layer surface. Clean clay soil would be used for backfill. Regrading and vegetative cover would
prevent ponding of surface water in former source areas and reduce infiltration of surface water into the
ground. Sediments lying within retention basin DET7 and in the drainage ditch on the northern boundary
that collects surface water were to be excavated and analyzed to evaluate disposal options. Following the
removal of sediments, the ditch was to be filled with gravel or cement.
5. Catalyst Pile Excavation and Disposal
The catalyst pile material was to be excavated, evaluated, characterized, and disposed of. Approximately
100 cubic yards of catalyst material contained in the three small piles and underlying soil was to be
removed along with 6-inches of soil beneath that material. This material removal was to be followed by
confirmation sampling, backfilling with clean soil and re-grading and re-vegetation.
6. Off-site Surface Water Control in the DS Tributary
In order to reduce the potential for subsurface DNAPL and associated COCs to enter the DS Tributary in
the northeast portion of the Site, a 30-inch diameter collection culvert was installed beneath DS Tributary
to contain surface water flow and keep groundwater from entering the stream flow. This culvert was used
to connect to the existing culvert beneath State Road and extend along the northern side of the railroad
spur, approximately 600 feet upstream. This configuration was meant to entirely contain the surface
water in the DS Tributary north of the Detrex facility, seal off potential groundwater seepage and prevent
soil erosion. All joints were to be sealed to eliminate seepage. Sediment beneath the culvert was to be
excavated to a depth of approximately 2 feet. The sediment excavated beneath the culvert would be
analysed to evaluate disposal options.
7. Chemical Monitoring and O&M
O&M activities for the vacuum-enhanced extraction well system were to include routine inspections of
blowers, electrical equipment, belts, fuses, and pertinent operating parameters. O&M requirements for
the slurry wall and re-graded areas were to consist of inspections, with regrading and re-vegetating, as
necessary. Routine sampling of selected extraction wells was to be required to monitor the effectiveness
of the system. At a minimum, annual groundwater monitoring was to be conducted at points of
compliance, with samples to be analyzed for DNAPL, VOC and SVOC parameters. In addition, water level
data is to be gathered on a semi-annual basis from all monitoring wells and piezometers installed inside
and outside of the slurry wall to evaluate groundwater gradients within the remedial response area.
Stormwater treatment system O&M activities, such as carbon replacement, were to remain the same as
are currently used at the facility; however, the frequency of replacement was expected to increase
depending on the concentration of contaminants in the water pumped out of the extraction wells. O&M
activities were to also include separator maintenance, handling, and disposal of DNAPL, and inspection
and periodic sediment removal from the settling pond at DET7.
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The outfall from the existing stormwater treatment system was to be monitored to ensure compliance
with NPDES monitoring requirements and DNAPL constituents not included as part of the current
monitoring program. Samples are to be collected at the same time as the NPDES monitoring.
8. Points of Compliance
In conjunction with completion of the remedial action and performance of required O&M, sheet flow
erosion and runoff from the Detrex facility would need to meet the occupational CUGs established for the
FWA and Sediment OUs. Tables 1-1 and 1-2 in Appendix E list the CUGs established for the FWA and
Sediment OUs. The points of compliance for surface runoff are the property boundary and the DS
Tributary. The Detrex facility site drainage map is depicted in Figure 5-4 in Appendix F. Groundwater
contamination also would need to meet the occupational CUGs for sediment and soils to prevent
recontamination of Fields Brook. The points of compliance for the contaminants present in groundwater
are the edge of the slurry wall or, for areas without the slurry wall, the property boundary, and the DS
tributary.
Contaminant levels at the Detrex outfall must meet CUGs to ensure that the 48-inch combined sewer can
meet CUGs when it discharges to Fields Brook. Treatment of contaminated groundwater is addressed
through Detrex's existing storm water treatment system which includes Tank 004, a 900,000-gallon above
ground plant effluent and stormwater collection tank and 100,000-gallon secondary tank. Tank 004 stores
co-mingled process water, storm water, and CERCLA-impacted groundwater collected from the passive
DNAPL recovery well system, partial slurry wall, DS Tributary InterceptorTrench, Groundwater Interceptor
Trench (GWIT), Southern Groundwater InterceptorTrench (SGWIT), and detention pond.
The 1997 SCOU ROD defines the points of compliance for the Detrex site as it relates to groundwater as
the edge of the slurry wall or, for areas without the slurry wall, the property boundary, and the DS
tributary. The slurry wall is located east of the NPDES berm. The NPDES Ohio EPA Permit No. 3IF00017*QD
is assigned to the Detrex facility and originally established in 1989.
9. The 2014 ESD
In addition to the passive well extraction system requirements as described in item 3 above, the 2014 ESD
incorporated the inclusion of a groundwater interception trench (constructed between 2006 to 2007) on
the southern property line and completion of the partial slurry wall from 1,500 feet to approximately 600
feet.
Status of Implementation
Because the design of the vacuum-enhanced DNAPL extraction system would take longer than the design of the
slurry wall, the designs were submitted separately so that remedial action work at the Site could proceed as soon
as possible. Construction of the slurry wall, installation of groundwater collection trenches, and the excavation of
accumulated sediment from drainage ditches began in August 2000 and were completed in mid-2001. The slurry
wall controls the movement of groundwater and provides for a system of drains that collect groundwater and
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runs it through Detrex's existing water treatment plant. Outfall 002 of the existing stormwater treatment system
is monitored for existing NPDES monitoring requirements and DNAPL constituents not included as part of the
current monitoring program. During this time, the catalyst piles were removed from the property and small areas
of surface soil contamination were re-graded and covered to prevent recontamination to the Brook.
EPA and Detrex agreed that the vacuum-enhanced DNAPL extraction system could be phased in to allow the
system to be optimized based on field performance data. Phase 1 of the vacuum-enhanced DNAPL extraction
system became operational in October 2002.
In 2009, Detrex installed two DNAPL collection trenches in the DS Tributary west of State Road. Detrex excavated
269 tons of sediment/soil from the DS Tributary based on visual observations of DNAPL under the box culvert
under State Road in 2011. The excavated area was lined with Aqua-block (a proprietary pea gravel/bentonite
mixture), and then the stream channel was lined with a grouted rock. Detrex removed two DNAPL collection
trenches and installed one larger replacement trench and riser pipe 130 feet downstream from the culvert (Fig. 5-
3, Appendix F).
Implementation of the passive recovery DNAPL remedy as required by the 2014 ESD, was initiated on April 8,
2014 and completed in three phases. A total of 151 four-inch diameter recovery points were installed between
June 2014 and August 2015. In addition to the four-inch recovery point installation, Detrex installed a total of 142
perimeter recovery points between August 2015 to June 2016.
On June 22, 2017, EPA, in consultation with Ohio EPA issued an Approval Letter (EPA, 2017) for the Final Passive
DNAPL Collection System Completion Report, dated June 5, 2017 (AECOM, 2017). The letter memorialized that
the construction of the remedy required by the ESD in Detrex OU5 has been completed and that Detrex is in full
compliance with the requirements of the 2014 ESD by having the Final Phase of the DNAPL collection system
operational by June 30, 2016.
Since the operation of the passive DNAPL recovery system, EPA has approved changes in the monitoring
frequencies of DNAPL passive collection points in accordance with the performance requirements of the 2014
ESD. At the time of this review, the DNAPL monitoring frequency is summarized below:
• Terminated monitoring at 48 recovery points;
• Quarterly monitoring at 1 recovery point;
• Monthly monitoring at 102 recovery points; and
• Annual monitoring at 142 perimeter recovery points.
The locations of the passive collection wells in the current program are in Figure 5-2 of Appendix F.
Based on the significant concentrations of TCE historically observed at MW-04S, Detrex began a voluntary vapor
intrusion investigation (VI) in January 2022. VI investigation and mitigation efforts of buildings within the Detrex
facility is outside the scope of the Fields Brook Site. The source control remedies were limited for practical
reasons to address the risk of recontaminating Fields Brook Sediment in excess of CUGs. Source control remedies
were not developed to address human health and ecological risks within each source area in order to focus
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remedial efforts on Fields Brook sediment. Any areas which present risk to receptors other than Fields Brook
sediment should be addressed separately under other regulatory programs, such as the Resource Conservation
and Recovery Act Corrective Action (RCRA CA). The VI pathway occuring within the Detrex facility does not impact
Fields Brook sediment and is not included as part of the Fields Brook Superfund site. Industrial source area
facilities are subject to other environmental regulations that may require additional cleanup or ICs outside the
scope of Fields Brook. Detrex is an operating facility and a RCRA CA eligible facility. The Region 5 Superfund
program concurs that VI matters occuring within Detrex and not impacting Fields Brook sediment should be
addressed under the RCRA CA program. Detrex is in coordination with the RPM, Region 5 VI technical experts, and
Ohio EPA DERR to mitigate the VI exposure pathways impacting the facility. In the interim of the RCRA CA referral,
the EPA Superfund program will continue to voluntarily monitor progress of VI mitigation within Detrex. VI within
the Detrex facility is categorized as "Other Findings" in Section VII.6.
Water Containment and Treatment
On March 7, 2022, following a wet weather event and reported water main break in the northwest lawn at
Detrex, Ohio EPA Division of Environmental Response and Revitalization (DERR) observed untreated water from
Tank 004 overflowing and spilling onto the northwest lawn of the Detrex facility while conducting oversight.
Overflow from Tank 004 ponded to the northwest lawn of the Detrex facility and extended beyond the slurry wall
and fence line on the west side of the facility, and up to the CSX railroad along the northside of the facility. Figure
5-6 in Appendix F depicts the current structures and groundwater containment components in the northwest
lawn of Detrex. EPA and Ohio EPA are concerned that untreated water beyond the slurry wall will seep into the
ground, potentially recharging the underlying groundwater, and will not be contained and routed to Pump Station
No. 2 (Pump 002) for ultimate treatment. On March 16, 2022, Ohio EPA DERR notified Ohio EPA Division of
Surface Water (DSW) of the observed Tank 004 overflow.
In May 2022, Ohio EPA DSW requested additional clarification on the frequency of Tank overflow events. The final
response indicated the Tank overflows less than three times per year but does not overflow every year. On May
13, 2022, Ohio EPA DSW issued Detrex a Notice of Violation (NOV) for the failure to report the overflow of Tank
004 within 24-hours of discovery. The NOV cites violations of ORC 6111.04(C), ORC 6111.07(A), and NPDES Permit
Part III 11.B.2. Unanticipated Bypass, requiring the permittee submit a notice of an unanticipated bypass within
24-hours.
In response to the Ohio EPA DSW NOV, Detrex submitted the proposed plan of action, "Management of T004
Water Level," dated August 2, 2022, to address preventing the overflow of Tank 004 or releases from the site
without required treatment. The proposed plan includes reducing the volume of incoming flow to Tank 004 by
shutting down Pump 1 and Pump 2. The proposed pump shutoff may result in contaminated groundwater
accumulating in certain collection points and increase the risk of contaminated groundwater migrating beyond
the Detrex facility. NPDES discharge point 3IF00017003 (Outfall 003), also referred to as the emergency spillway,
is linked to the detention pond (Fig. 5-4, Appendix F) and leads to EU8 of Fields Brook.
On September 27, 2022, following a wet weather event, Tank 004 overflowed onto the ground and ponded in the
northwest lawn of the facility. Detrex notified Ohio EPA DSW, Ohio EPA DERR, and EPA of the overflow on
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September 28, 2022. On September 30, 2022, Ohio EPA DSW conducted an on-site inspection at Detrex and
observed Tank 004 overflowing onto the ground.
On November 21, 2022, EPA issued a "Request for Additional Information Regarding the Detrex Water Treatment
System and CERCLA Remedy," with the purpose of obtaining information to assist in evaluating the proposed
pump shutoffs and understanding the existing water treatment system. Detrex submitted the "Response to
Request for Additional Information Regarding Detrex Water Treatment System and CERLCA Remedy," dated
January 25, 2023. It was confirmed that among other COCs, HCB and HCBD are not included as discharge
monitoring parameters as required by the 1997 SCOU ROD. Detrex's response acknowledges that 1989 NPDES
permit allows for excess stormwater to be stored in the detention pond and northwest berm area.
The 1989 NPDES design of the northwest lawn is intended for temporary storage of stormwater during extreme
wet weather events and specific requirements must be met; it does not contemplate contaminated groundwater.
Overflow from Tank 004 contains co-mingled stormwater, contaminated groundwater, and other processes
waters. The DNAPL from Detrex is considered to be K030 listed waste; groundwater that comes into contact with
the DNAPL is considered to be K030 hazardous waste. On-site management of contaminated groundwater
includes storage and treatment, which is authorized under the Clean Water Act via the NPDES permit. Any
releases outside the wastewater treatment system would cause the released wastewater to be subject to
hazardous waste management requirements.
In discussions with Detrex, it was discovered that decanted DNAPL water was discharged into a catch basin of the
storm sewer system and ultimately is routed to Tank 004. The storm sewer system was built in the 1950's; Detrex
indicated storm sewer OM&M practices are not conducted. On March 13, 2023, Detrex conducted a storm sewer
camera survey to obtain information on existing conditions of the storm sewer systems that received DNAPL-
contaminated groundwater and submitted the "Detrex Corporation Storm Sewer TV Inspection Camera Survey"
memo dated July 26, 2023. At the request of EPA, Detrex no longer discharges decanted DNAPL groundwater into
the catch basin or other parts of the storm sewer system as of July 14, 2023. Detrex now discharges the decant
water directly into the influent conveyance system line to the water treatment system. (Appendix C, Photo 34).
In concurrence with Ohio EPA DERR and Ohio EPA DSW, EPA issued the "Evaluation of the Water Collection and
Treatment System at Source Area Operable Unit 5, Detrex Corporation," dated July 7, 2023 (EPA, 2023), which
determined the proposed pump shutdown plan outlined in the "Management of T004 Water Level" memo is
inconsistent with the 1997 SCOU ROD, which requires the collection and treatment of contaminated groundwater
prior to discharge. Shut down on Pump 1 and/or Pump 2, heightens the potential for such releases. One of the
components of EPA's evaluation included requesting Detrex conduct daily wet weather inspections after rainfall
events. The purpose of the wet weather inspection is to produce a record of water levels in Tank 004, the
detention pond, and NW lawn in the event there is risk for overflow. At a minimum, the wet weather inspections
include collecting photographs, measuring water levels in Tank 004 and detention pond, noting conditions of
Outfall 003, and measuring water levels in the NW lawn. The inspections are provided to EPA and Ohio EPA within
24 hours of the end of the wet weather event.
Detrex submitted the "Detrex Facility Outfall Monitoring Plan" (EHS Support, 2023) and "Progress Update:
Evaluation of Water Collection and Treatment System at Source Area Operable Unit 5, Detrex Corporation" on
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August 3, 2023 (EHS Support, 2023). The outfall monitoring plan describes the use of Outfall 003 as the
emergency spillway for the detention pond located on the southern portion of the Detrex property.
Detrex submitted the "Detrex Facility Tank 004 Overflow Plan," dated October 13, 2023 (EHS Support 2023), and
evaluated potential corrective measures to eliminate overflows from Tank 004, prevent overtopping of the slurry
wall, and prevent discharge of untreated water from Outfall 003. At the time of this review, Detrex is in
coordination with EPA, Ohio EPA DERR and Ohio EPA DSW to address water treatment system issues to ensure
contaminated groundwater is contained and treated prior to discharge from the facility.
If Tank 004 overflow were to occur, Detrex will report the event to EPA and Ohio EPA within 24 hours in
accordance with the NPDES permit. Per the design of the water treatment system, any overflows from Tank 004
are expected to be directly or indirectly captured and routed back to Tank 004. Contingency plans are in effect to
sample water from Tank 004 and/or Outfall 003 in the unlikely event discharge occurs. A digital water monitoring
station was installed at Outfall 003, which automatically reports if discharge is occurring. Detrex continues to
conduct wet weather inspections and provide inspection reports within 24 hours of the rainfall event, discharge
decanted DNAPL water directly to the water treatment beds thus alleviating the need for storage in Tank 004.
Detrex, EPA, and Ohio EPA are discussing plans to modify the overflow area to further reduce the potential for
any overflows from Tank 004 to migrate beyond the slurry wall, and install a check-valve to divert water from the
southern groundwater collection trench from entering the catch basin to reduce the risk of contaminated
groundwater from entering Outfall 003.
Institutional Controls
Table 4: Summary of Implemented ICs at Detrex OU5
Media, engineered
controls, and areas
that do not support
UU/UE based on
current conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC Instrument
Implemented and
Date (or planned)
Soil, Groundwater
Yes
Yes
P.P.N. 03-
014-006,7
&8
Shall not affect
remedy components
of the SCOU ROD;
prohibits residential
land use or
consumptive use of
groundwater
Environmental
Covenant pursuant to
Ohio UECA, November
16, 2009
SDMS #353273
A map of the parcels with the recorded ICs for Detrex OU5 is shown in Figure 1-9 in Appendix F.
Status of Access Restrictions and ICs: For source areas at the Fields Brook Site, ICs are required where hazardous
substances, pollutants or contaminants could re-contaminate the Brook above cleanup levels, and to maintain the
integrity of the remedy. In November 2009, Detrex recorded an EC, pursuant to Ohio UECA. The EC, which applies
to the entire 58 acres of Detrex's property, prohibits any action that would conflict with the source control
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remedy and prohibits use of the property as a residence or as a drinking water source. The covenant also provides
for future right of access for EPA. The covenant extends from the plant operations property boundary on the
north, to the Fields Brook Relocation Structure sedimentation basin on the south. The Detrex covenant also
extends from State Road on the west to the CSX railroad right of way on the east (See Fig. 1-9, Appendix F).
Signs are posted and access controls (not themselves considered ICs) are in place in the form of fencing and Site
security to limit access to critical areas of the facility, where remedial structures are primarily located. Areas to
the south of the main production are posted with signs to discourage trespassers.
Current IC Compliance: Based on the FYR inspection, EPA is not aware of Site or media uses at Detrex OU5 that
are inconsistent with the stated objectives of the ICs.
IC Follow up Actions Needed: An ICIAP should be developed for Detrex OU5. The purpose of the ICIAP is to
conduct additional IC evaluation activities to ensure that the implemented ICs are effective, to explore whether
additional ICs are needed and ensure their implementation, and to ensure that LTS procedures are in place so
that ICs are properly maintained, monitored, and enforced. IC evaluation activities will include, as needed,
developing updated maps depicting current conditions in areas that do not allow for UU/UE, reviewing current
zoning and city or township ordinances, and reviewing recording and title work for properties impacted by the
Site.
Long-Term Stewardship:
Compliance with ICs is necessary to assure the protectiveness of the remedy. Planning for LTS is therefore
required to ensure that the ICs are maintained, monitored and enforced at Source Area properties, so that the
remedy continues to function as intended. An ICIAP should be completed to document LTS procedures. LTS
procedures should describe at a minimum: (1) monitoring activities and schedules; (2) responsibilities for
performing each task and parties responsible for completing those tasks; (3) reporting requirements; and (4) a
process for addressing any potential IC issues that may arise during the reporting period.
Detrex OU5 should be inspected/evaluated routinely to ensure no inconsistent uses have occurred, and that ICs
remain in place and are effective. Results of IC reviews should be provided to EPA in an annual submittal with a
certification that the ICs remain in-place and are effective.
Systems Operations/Operation & Maintenance
The 1997 SCOU ROD requires monthly monitoring as required by the NPDES permit and for any DNAPL
constituents listed in the SCOU ROD not addressed by the NPDES permit. Prior to September 27, 2023, DNAPL
constituents not included as part of the existing NPDES permit were not analysed as required by the 1997 SCOU
ROD. It is unclear how long the DNAPL constituents, including Detrex specific contaminant markers HCB and
HCBD, were excluded from monthly analysis of Outfall 002. Since September 2023, HCB and HCBD have not been
detected in the monthly Outfall 002 samples.
As of August 3, 2023, Detrex incorporated the analysis of DNAPL constituents in the monthly monitoring program
as required by the 1997 SCOU ROD. Detrex provides copies of its monthly status reports to EPA.
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The DNAPL passive collection system is operating as intended. Detrex submitted a "Draft Operations,
Maintenance, and Monitoring (OM&M) Plan for the Detrex Source Control Area" on November 29, 2017 and a
revised version on October 29, 2018. The revised "Draft Operations, Maintenance, and Monitoring (OM&M) Plan
for the Detrex Source Control Area," dated October 29, 2018, includes the inspection and upkeep of the passive
collection system and the sampling of monitoring wells. Detrex also submitted a revised "Draft Quality Assurance
Project Plan," dated November 2, 2018. At the time of this review, EPA is in the process of reviewing the
requirements of the draft revised "Draft Operations, Maintenance, and Monitoring (OM&M) Plan for the Detrex
Source Control Area," dated October 29, 2018, and the "Draft Quality Assurance Project Plan," dated November
2, 2018 and it is anticipated that these documents will be modified and finalized prior to the next FYR. Due to the
recent water management practices within the existing water treatment system observed since the last FYR and
ongoing review of water management alternatives, which are proposed options to upgrade, enhance, or
supplement the existing water treatment system, EPA will coordinate with Detrex to include appropriate OM&M
water containment practices in the revised OM&M plan to ensure the water treatment system adequately
contains contaminated groundwater within the Detrex facility.
Since the last FYR, perimeter recovery monitoring point clean out has not occurred. The intent of the perimeter
DNAPL recovery points are to monitor the potential migration of DNAPL emanating from the source area.
Sedimentation may affect recovery and observation of DNAPL. Sedimentation thickness of the perimeter recovery
points exceeds 2 feet, as reported in the "Annual Perimeter Recovery Point Monitoring, and Monitoring Well and
Groundwater Collection System Sampling Memo," dated August 18, 2023 (EHS Support, 2023). During the FYR
Site inspection, EHS indicated perimeter monitoring clean out or replacement will be implemented as part of the
passive DNAPL recovery system OM&M practices. EPA and Detrex will continue to coordinate on the
implementation of perimeter point cleanout and replacement to achieve sediment accumulation of less than 20%
of the screen length; this practice is used for the main passive DNAPL recovery well field.
The 1997 SCOU ROD requires water level data to be gathered on a semi-annual basis from all monitoring wells
and piezometers installed inside and outside the slurry wall to evaluate groundwater gradients. Currently, MW-
21, RMI-North and RMI-South, are the only monitoring wells installed outside or inside the slurry wall. Based on
the March 2022 and September 2022 Tank 004 overflow events, the installation of additional piezometers or
monitoring wells should be evaluated to ensure effectiveness of the slurry wall.
On June 7, 2023, Ohio EPA DSW conducted a Compliance Evaluation Inspection (CEI) at Detrex. During the CEI,
Ohio EPA DSW noted a temporary diesel pump was installed at Pump 002 on May 17, 2023, due to pump failure;
the diesel pump was connected to Tank 004. Detrex did not notify EPA of the Pump 002 failure in any of the
monthly monitoring reports. Pump 002 operates two pumps with a third pump on standby; the second pump of
Pump 002 was repaired in January 2024.
The "Draft Operations, Maintenance, and Monitoring (OM&M) Plan for the Detrex Source Control Area," dated
October 29, 2018 does not include OM&M procedures for the detention pond (located downgradient from the
groundwater interceptor trench), which holds surface water and untreated groundwater from the southern
groundwater interceptor trench and eastern surface sheet flow/runoff from Detrex. The detention pond is lined
with clay; however, the thickness of the clay was unclear at the time of this review. Therefore, water entering the
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detention pond may potentially re-enter ground water beyond the groundwater interceptor trench before
collecting below the barrier installed in EU-8 and daylighting down gradient toward EU-6.
The "Draft Operations, Maintenance, and Monitoring (OM&M) Plan for the Detrex Source Control Area," dated
October 29, 2018, should be revised to include, among other things, the new water containment procedures
implemented in response to the Tank 004 overflow events.
VII.3 OPERABLE UNIT 5: PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last FYR as well as the
recommendations from the last FYR and the current status of those recommendations.
Protectiveness Determinations/Statements from the 2019 FYR
Table 5: Protectiveness Determinations/Statements from the 2019 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
5
Short-term Protective
The remedy at Detrex OU5 currently protects human health and the
environment by preventing recontamination of Fields Brook from
organic chemical contamination in Site soils, groundwater, and
DNAPL. The remedial actions outlined in the January 15, 2014, ESD
modifying the DNAPL recovery system in the Detrex source area to
reduce releases to the Brook were implemented in 2016 and are
proving to be effective. An effective IC in the form of an EC was
recorded in 2009. However, in order for the remedy to be protective
in the long-term, the following actions need to be taken to ensure
protectiveness: finalize the OM&M Plan and QAPP for the
chlorinated DNAPL passive collection system in the DNAPL source
area; and develop and implement a LTS Plan for monitoring and
tracking compliance with existing ICs, communicating with EPA, and
providing an annual certification to EPA that the ICs remain in place
and are effective.
Status of Recommendations from the 2019 FYR
Table 6: Status of Recommendations from the 2019 FYR
OU#
Issue
Recommendations
Current Status
Current Implementation
Status Description
Completion
Date (if
applicable)
5
The OM&M Plan
and QAPP for the
chlorinated
Finalize the OM&M
Plan and QAPP for
the chlorinated
Addressed in Next
FYR
EPA is in receipt of the draft
OM&M Plan and QAPP dated
2018; due to the water
NA
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DNAPL passive
collection system
in the DNAPL
source area have
not been
finalized.
DNAPL passive
collection system
in the DNAPL
source area.
management issues
identified in the last five
years, EPA will ensure the
OM&M Plan and QAPP also
address additional
requirements from water
management corrective
measure.
5
Procedures are
not in place to
ensure LTS of ICs
at the Site.
Develop and
implement a LTS
Plan for monitoring
and tracking
compliance with
existing ICs,
communicating
with EPA, and
providing an
annual certification
to EPA that the ICs
remain in place
and are effective.
Considered But Not
Implemented
LTS procedures will be
included in the ICIAP; a
separate LTS Plan is not
needed.
NA
VI 1.4 OPERABLE UNIT 5: FYR PROCESS
Data Review
A list of technical reports and other documents reviewed for this FYR are included in Appendix A-Reference List.
The data were analyzed, and the general observations include:
1. As of November 2023, Detrex has recovered over 35,241 gallons of DNAPL from the source area.
2. At the time of this review, Detrex conducts semi-annual groundwater sampling events at eight wells
installed throughout the Detrex property. Groundwater monitoring and recovery/collection trench data
are not indicative of an ongoing DNAPL release towards Fields Brook.
a. Groundwater samples collected from monitoring wells placed on the outer edge of the slurry wall
DETMW-21 and RMI-N between 2019 and 2023 are below the VOC method detection limits.
b. Groundwater samples collected from sumps 1-3 have concentrations of TCE ranging from non-detect
to 8.14 |ag/l and surface water samples collected from the collection basin detected concentrations
of TCE (1.07 |ag/l to 106 |ag/l), 1,1,2,2-Tetrachloroethane (non-detect to 177 |ag/l), and 1,1,2-
Trichloroethane (non-detect to 12 |-ig/l).
3. November 2023 discharge data from Outfall 002 is not indicative of an ongoing DNAPL release towards
Fields Brook as the DNAPL constituents are not detected. However, prior to September 27, 2023, Outfall
002 was not monitored for the complete list of DNAPL constituents as required by the 1997 SCOU ROD.
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4. A surface water sample collected on March 18, 2022, from northwest pooled area as a result of the March
7, 2022 overflow of Tank 004 detected concentrations of aluminum (115 |ag/L), 1,1,2,2-tetrachloroethane
(5.72 |-ig/L), chloroform (8.85 |ag/L), and TCE (3.52 |ag/L); all detections are low concentrations.
Groundwater samples collected from the monitoring well downgradient from the overflow are below the
VOC method detection limits.
5. Validated data from the OU1 & OU4 OM&M 2023 August sampling event is not available at the time of
this review. Once validated data is provided, further evaluation of EU5 should be conducted.
6. The 2019 to 2023 groundwater monitoring results from the outer edge of the slurry wall, DETMW-21 and
RMI-N, for DNAPL constituents are below the method detection limits which indicate groundwater is not
migrating based on the existing monitoring points. An expansion of monitoring points between Detrex and
EU5 should be evaluated to ensure performance requirements of the remedy is met.
7. Semi-annual groundwater results for MW-04S have been consistently high in concentration for TCE,
ranging from 42,100 |ag/L to 205,000 |ag/L. MW-04S is located within the north side of the Detrex facility.
Between 2019 to 2023, TCE concentrations from monitoring well RMI-N located downgradient of MW-04S
and beyond the slurry wall are below the method detection limit, indicating the DNAPL plume is
contained.
8. Between 2019 and 2021, the annual OM&M sampling of Fields Brook sediments and FWA soils have not
shown exceedances of CRGs attributable to Detrex-related contaminants, although there are trace
detections of VOCs in the annual reporting. Tables 1 through 3 of the Final 2021 Annual OM&M Soil,
Sediment, and Surface Water Sampling Report includes data from the previous five years. Data from the
2022 and 2023 OM&M sampling events are not validated at this time. At the time of this review, EPA,
Ohio EPA, FBAG, and Detrex are in coordination to address additional sediment sampling of EU5.
a. The data collected from 2019 to 2021 is sufficient for the purpose of this FYR as the data
demonstrates there are no impacts and exposures occuring from the Brook. The data collected from
2019 to 2021 is consistent with historic data from 2004 to 2018. It is unlikely that conditions of the
brook have changed based on the observed land use and conditions of Fields Brook during the
OM&M sampling events and FYR site inspection.
Based on the samples collected from the sentry monitoring wells from Detrex and OM&M monitoring results
from OU1 and OU4, there are no impacts to protectiveness and no unacceptable exposures are occuring.
Site Inspection
The inspection of the Detrex OU5 was conducted on August 23, 2023. In attendance were Anna Nguyen, EPA;
Jenny Polster, EPA; Amy Gahala, EPA; and Nick Roope, Ohio EPA. Martin Schmidt, Tom Edmunds, and Patrick
Krott, representing Detrex Group participated. The purpose of the inspection was to assess the protectiveness of
the remedy. No formal interviews were conducted as part of the fifth FYR. Details of the inspection are provided
in the FYR Inspection Checklist (Appendix B) and Photos (Appendix C).
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The weather during the Detrex 0U5 inspection was cloudy with temperatures in the high 90's (Fahrenheit).
1. The inspection targeted components of the water containment and treatment system: slurry wall, Tank
004, SGWIT, detention pond, carbon units, water treatment control system, DNAPL passive recovery
well system, and monitoring wells.
2. At the time of inspection, two of the three pumps of Pump 002 were down for maintenance for
approximately 2-3 months. Detrex indicated replacement parts were ordered to repair Pump 002.
3. The water treatment system computer program was observed and has the capability to control
influent and effluent pumping rates within the system and provide real time capacity of Tank 004.
4. EPA, Ohio EPA, and Detrex discussed current OM&M practices conducted at Detrex and noted the need
for piezometers inside and outside the slurry wall and the need for sediment cleanout at perimeter
DNAPL recovery wells.
5. EPA and Ohio EPA observed the clearing and grubbing of the detention pond on the south end of the
Detrex property.
6. EPA and Ohio EPA observed Detrex's direct hook up to introduce contaminated groundwater from the
passive DNAPL recovery system to the carbon treatment beds.
The passive DNAPL recovery well system appears to be operating as intended.
VII.5 OPERABLE UNIT 5: TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
Yes. The 1997 SCOU remedy requires the containment and treatment of contaminated groundwater. Regular
sampling of sentry monitoring wells west of the slurry wall and Outfall 002 demonstrates the DNAPL constituents
are not detected, and the water containment and treatment portion of the remedy is functioning as intended.
Although the observed overflow events of Tank 004 in March and September 2022, demonstrate the failure to
contain the untreated water within the tank, per the design of the water containment and treatment system, any
overflows from Tank 004 are expected to be directly or indirectly pumped back into Tank 004. Moreover, after
the March and September 2022 overflow events, samples collected from the monitoring point downgradient
from the overflow did not indicate untreated water migrated offsite. Nonetheless, due to the potential for
overflows of Tank 004 to result in migration of contaminated groundwater beyond the slurry wall under certain
conditions, the overflow of Tank 004 is an engineering performance issue of the water containment and
treatment system. In response to the overflow events, Detrex has implemented interim actions and proposed
plans to ensure the water containment and treatment system continues to meet the requirements of the remedy
in the 1997 SCOU ROD. Additional data collection from an expanded monitoring well and piezometer network is
recommended to ensure compliance with the 1997 SCOU ROD. Prior to September, 2023, DNAPL constituents
identified in the 1997 SCOU ROD were not included in the monthly NDPES monitoring from Outfall 002. Detrex
has incorporated the analysis of DNAPL constituents as required by the 1997 SCOU ROD. In coordination with
Ohio EPA DSW, the DNAPL constituents will be part of the existing NPDES permit and Detrex will ensure this
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requirement is included in the OM&M plan. Based on OM&M sample results from OU1 and OU4, there are no
unacceptable impacts to the portions of Fields Brook near Outfall 002.
Sediment sample collection from EU5 was discontinued in 2011 after Detrex performed excavation of the DS
Tributary in EU5 due to observed DNAPL released from the box culvert under State Road. Samples collected from
the DS Tributary were below CRGs. In 2011, Detrex completed the excavation in the DS Tributary, lined the
excavated area with Aqua-block, lined the stream channel with grouted rock, and installed a DNAPL collection
trench. Due to the March 2022 and September 2022 Tank 004 overflow events, EPA and Ohio EPA raised concern
of the potential release of overflowed contaminated water from the Detrex facility impacting the EU5 sediment.
EPA is coordinating with FBAG and Detrex to address additional sediment sampling of EU5.
Since the 2022 overflow events, Detrex has cooperated with EPA by implementing temporary preventative
measures such as wet weather inspections, changes in routing contaminated water to Tank 004, and identifying
an appropriate water management solution to ensure overflow from Tank 004 does not occur and that
contaminated groundwater is contained within the Detrex facility for treatment.
Based upon monthly inspection reports and the Site inspection, the passive DNAPL recovery well remedy appears
to be performing as intended by the decision documents. As of November 2023, more than 35,241 gallons of
DNAPL have been collected from the source area, thereby reducing the potential for future releases to the Brook.
Based on the data from the OM&M sediment sampling of Fields Brook, CRG exceedances chemically attributable
to Detrex have not been seen since 2008. Based on the historic overflow events of Tank 004 the following is
recommended to demonstrate water containment practices conducted at Detrex do not impact the Brook:
additional groundwater monitoring along the slurry wall, sediment sample collection from EU5, improved water
containment and treatment practices, and consistent analysis of DNAPL constituents identified in the 1997 SCOU
ROD. At the time of this review, Detrex is in coordination with EPA, Ohio EPA DERR and Ohio EPA DSW to address
water treatment system issues related to ensuring contaminated groundwater is contained and treated prior to
discharge from the facility.
An ICIAP containing LTS procedures should be developed and implemented to ensure that the effective ICs are in
place, and are maintained, monitored, and enforced at Detrex OU5 so that the remedy continues to function as
intended.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the
remedy selection still valid?
Question B Summary:
Yes. There has been no change to the hexachlorobenzene cleanup requirements for Fields Brook. The RAOs for
the Detrex Corporation Source Area are still valid. The goal of the Detrex source cleanup is to ensure that
contaminants do not move from the facility to the Brook in excess of CUGs. This is achieved by OM&M sampling
conducted at Detrex, groundwater containment through the groundwater collection trenches and slurry wall,
treatment of groundwater prior to discharge, and reducing contamination from DNAPL plume via the passive well
recovery system.
39
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A VI exposure pathway occuring within onsite occupied buildings of the Detrex facility was confirmed. The
intended limits of the source control remedies were made for practical reasons to address the risk of
recontaminating Fields Brook Sediment in excess of CUGs and the source control remedies were not developed to
address human health and ecological risks within each source area. The VI exposure pathway occuring within the
Detrex facility does not impact Fields Brook sediment and is outside the scope of the Fields Brook Superfund site.
This is supported by the 1997 SCOU ROD which recognizes areas which present risk to receptors other than Fields
Brook sediment should be addressed separately under other regulatory programs, such as RCRA CA. The limited
scope of the source control remedies was made for practical reasons to address necessary actions to protect
Fields Brook sediment. Industrial source area facilities are subject to other environmental regulations that may
require additional cleanup or ICs outside the scope of Fields Brook.
Since Detrex is an operating facility and eligible for RCRA CA for VI matters, the Region 5 Superfund program
concurs that VI matters occuring within Detrex and not impacting Fields Brook sediment should be addressed
under the RCRA CA program. In the interim of the RCRA CA referral, the Region 5 EPA Superfund program will
continue to voluntarily monitor progress of VI mitigation within Detrex as the VI matter at is not part of the Fields
Brook Superfund site. Vapor intrusion within the Detrex facility is categorized as "Other Findings" in Section VII.6.
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy?
No. At this time no other information has come to light that would cause the Agency to question the
protectiveness of the remedy. According to the National Weather Service, the annual average of precipitation
near Ashtabula, Ohio has increased between 2019 to 2024; the increase in the average precipitation may indicate
the increase in the frequency and/or severity of wet weather events. Based on the monthly water inventory
report by the Ohio Geological Survey, the amount of precipitation from 2019 to 2024 in the Northeast area of
Ohio deviates from the historic level of precipitation by 2.61 to 8.53 inches of rainfall. The increase in frequency
and intensity of wet weather events increases risks the of Tank 004 overflow and potential release of untreated
groundwater from the facility. However, Detrex has cooperated with EPA in implementing temporary
preventative measures such as wet weather inspections, changes in routing contaminated water to Tank 004, and
identifying an appropriate water management solution to ensure overflow from Tank 004 does not occur and that
contaminated groundwater is contained within the Detrex facility for treatment.
VII.6 OPERABLE UNIT 5: ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
40
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OU(s): 5
Issue Category: Institutional Controls
Issue: An ICIAP is needed to ensure that effective ICs are implemented,
monitored, and maintained.
Recommendation: Develop and submit an ICIAP which describes the plan
for ensuring that all remaining required ICs at the Site are implemented,
and for ensuring that all ICs, once implemented, are monitored and
maintained.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
6/25/2028
OU(s): 5
Issue Category: Remedy Performance
Issue: Contaminated water from Tank 004 overflowing during wet
weather events into the environment and potentially leaving the facility
and potentially impacting Fields Brook.
Recommendation: Continue to implement corrective measures to ensure
overflow of Tank 004 does not occur and ensure all contaminated water is
captured and treated prior to discharge.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2026
OU(s): 5
Issue Category: Monitoring
Issue: Additional data and OM&M practices needed to ensure remedy
performance of the slurry wall.
Recommendation: Expand piezometer and/or monitoring well network
along the slurry wall to demonstrate contaminated groundwater is
contained within the OU and does not impact Fields Book.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
OU(s): 5
Issue Category: Operations and Maintenance
Issue: The OM&M Plan and QAPP for the chlorinated DNAPL passive
collection system in the DNAPL source area have not been finalized. The
OM&M Plan and QAPP also needs to incorporate the corrective measures
41
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related to overflow of Tank 004 and O&M practices for the sedimentation
occuring in the DNAPL perimeter monitoring points.
Recommendation: Finalize the OM&M Plan and QAPP for the chlorinated
DNAPL passive collection system in the DNAPL source area.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2025
OTHER FINDINGS
In addition, the following are recommendations that were identified during the FYR and may improve
performance of the remedy, improve management of O&M, and promote protective measures within the facility,
but do not affect current or future protectiveness:
• In January 2022, Detrex began a voluntary VI investigation of on-site facility buildings; this
investigation was initiated based on the significant concentrations of TCE historically observed at
MW-04S ranging between 42,100 |ag/L to 205,000 |ag/L. Since Detrex OU5 is a source control area
identified in the Fields Brook Superfund Site for the risk of contaminating the Brook sediment in
exceedance of CUGs, VI investigation and mitigation efforts of buildings within the Detrex facility is
outside the scope of the Fields Brook Site. The 1997 SCOU ROD recognizes areas which present risk
to receptors other than Fields Brook sediment should be addressed separately under other
regulatory programs, such as RCRA CA, and highlights the intention to focus on investigation and
remedial needs of the Brook sediment. The source control remedies were not developed to
address human health or ecological risks within each source area. Therefore, ongoing and future VI
mitigation efforts should be addressed independent of the Site and referred to a more appropriate
environmental program, such as RCRA CA.
VII.7 OPERABLE UNIT 5: PROTECTIVENESS STATEMENT
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination:
OU5 Short-term Protective
Protectiveness Statement:
The remedy at Detrex OU5 currently protects human health and the environment by preventing
recontamination of Fields Brook from organic chemical contamination in Site soils. However, there are
engineering performance issues related to the operation of the remedy to ensure containment of
42
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contaminated groundwater. The observed Tank 004 overflow events are a concern, however, at this
time, there is no evidence of untreated groundwater leaving the Detrex facility. Detrex is evaluating
water management alternatives to prevent Tank 004 overflow events and has implemented interim
measures to monitor and report site conditions during wet weather events and water levels in Tank
004. Detrex, FBAG, EPA, and OEPA are investigating if these overflow events have impacted the Brook.
The remedial actions outlined in the January 15, 2014, ESD modifying the DNAPL recovery system in
the Detrex source area to reduce releases to the Brook were implemented in 2016 and are proving to
be effective. The EC recorded in 2009 is in effect to ensure the Detrex facility is not used in a manner
that would interfere with the CERCLA remedy, limit the facility to commercial/industrial use, and
prevent consumptive use of groundwater on or off the facility. However, in order for the remedy to be
protective in the long-term, the following actions need to be taken to ensure protectiveness: continue
to implement corrective measures to ensure overflow of Tank 004 does not occur and ensure all
contaminated water is captured and treated prior to discharge; expand piezometer and/or monitoring
well network along the slurry wall to demonstrate contaminated groundwater is contained within the
OU and does not impact Fields Book; finalize the OM&M Plan and QAPP for the chlorinated DNAPL
passive collection system in the DNAPL source area; and develop and submit an ICIAP which describes
the plan for ensuring that all remaining required ICs at the Site are implemented, and for ensuring that
all ICs, once implemented, are monitored and maintained.
VIII. OPERABLE UNIT 6: MILLENNIUM TICL4 PLANT SOURCE AREA
VIII.1 OPERABLE UNIT 6: INTRODUCTION
OU Summary
The purpose of this FYR is to determine if the remedy selected to address the source area contamination at the
Millennium titanium tetrachloride (TiCU) Plant OU6 of the Fields Brook Superfund Site remains protective. The
remedy, which only addressed potential sources of recontamination to Fields Brook, included the excavation of
PCB and radium-contaminated soil and mining residuals. The cleanup was performed from July to October 1999.
Excavated soils and mining residuals were sent to Millennium's existing, permitted solid waste industrial landfill
located within the Fields Brook watershed. The 1997 SCOU ROD indicates OM&M would include maintenance of
soil erosion cover, stormwater drainage ways and vegetated areas (if any); chemical monitoring requirements
include annual collection of total PCBs in surface and groundwater samples. No formal on-Site O&M was required
as an erosional soil cover was not implemented; instead, excavated areas within the Millennium Plant site was
covered with geosynthetic material and stone cover or paved with asphalt. Millennium's OM&M responsibilities
for its landfill were and are defined by the permit issued by Ohio EPA, with the only addition being the expansion
of the monitoring parameters to include PCBs and radionuclides.
Upon discovery of the Therminol FR (Therminol) DNAPL in the EU8 floodplain, a UAO was issued to Millennium in
2007 requiring the company to address the associated PCB contamination in sediment and floodplain soils. This
removal action included construction of interceptor trenches along the northern edge of the facility to capture
any Therminol DNAPL that might be present and excavation of PCB-contaminated soils with disposal off-site. This
work was completed in 2008, and a completion report was submitted to EPA in 2009 (Millennium Inorganic
43
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Chemicals, 2009). The EU8 portion of Fields Brook was subsequently relocated by the FBAG into the area of the
Millennium PCB soil removal. This relocation project is discussed in the Section VI.2 for OUs 1 & 4 of this FYR
Report. In 2011 Millennium implemented ICs to ensure land use remain commercial/industrial, prohibit activities
that may disturb any residual PCBs or relocation of the brook, and prohibit consumptive use of groundwater at
the property without notification to the EPA for its property in the EU8 floodplain.
Background. Land and Resource Use
Millennium TiCU Plant OU6, is located in the south-central portion of the industrialized area near Fields Brook.
The structures currently at the facility include several process buildings, numerous aboveground storage tanks, a
clarifier, and three settling ponds. The western half of the property contains most of the process-related
structures, whereas the eastern half remains largely undeveloped and was historically covered by a large pile of
mining wastes and filter residue.
The TiCU plant was designed, constructed and initially operated by the Stauffer Chemical Company. Construction
was completed in 1956. The facility was sold to National Distillers and Chemicals in 1959 and was operated for
the next five years by National Distillers (and its affiliates Mallory-Sharon Metals and RMI Titanium). Cabot Titania
acquired the plant in 1963 and operated it until 1972, when it was leased to Gulf and Western Industries, Inc. Gulf
and Western purchased the plant in 1975. SCM purchased the TiCU facility in 1983. The name of the company
was changed to Millennium Inorganic Chemicals in 1997. Lyondell Chemical acquired the facility in 2004. The
National Titanium Dioxide Company of Saudi Arabia, known as Cristal Global, purchased the facility in 2007.
Cristal Global changed the name of its Millennium operations to Cristal USA, Inc. in 2012. INEOS Enterprises
(Ineos) acquired Cristal USA, Inc. in May 2019 and changed the name of its operations to Ineos Pigments.
History of Contamination
At the commencement of operations at the TiCU facility, the plant utilized a heat transfer system that used
Aroclor-based fluids (Therminol FR). This system remained in use until Gulf and Western had pure Aroclor
removed from the heat transfer system in 1974 and replaced it with Monsanto PCB-free Therminol.
The 1997 Source Control Rl of Millennium OU6 identified the Mining Residuals Pile, the Non-Traffic Area and the
North Traffic Area as areas that possess the potential to re-contaminate Fields Brook. Remedial action was also
planned for the Laydown Area; the Plant Process Area; and the Existing Soil Piles, other plant areas that have PCB
concentrations greater than 50 ppm. These three plant areas were evaluated during the Source Control Rl and
determined not to be potential sources of recontamination of Fields Brook. Groundwater samples collected
throughout the plant site during the Source Control Rl indicated that no compounds of concern were identified in
excess of occupational CUGs in groundwater. Descriptions of the six plant areas and analytical results are
summarized in the following sections. See Fig. 6-1 in Appendix F for a facility diagram showing the various areas
of historical contamination.
44
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1. Non-Traffic
Site investigations identified PCBs in surface soils (approximately the upper 6 feet) in the west-central
portion of the facility, extending north beyond the existing security fence-line. The area extending north
beyond the fence-line to the 100-year floodplain is the Non-Traffic Area. PCB concentrations in surface
soils in the Non-Traffic Area ranged from 3.1 ppm to 50 ppm. However, a few sampling locations near the
old outfall were found to have concentrations of PCBs greater than 50 ppm, and some borings had soils
containing greater than 500 ppm.
2. North Traffic Area
Site investigations identified PCBs in surface soils (approximately the upper 6 feet) in the west-central
portion of the facility, extending north beyond the existing security fence-line. The area south of the
fence-line and north of the Plant Process Area is defined as the North Traffic Area. The surface area in the
North Traffic Area was covered with pavement, structures, or gravel. The gravel was placed to prevent
further contact with on-site surface soils in this area and to reduce the potential for erosion of the surface
soils. PCB concentrations in surface soils in the North Traffic Area were identified in the range of 3.1 ppm
to 50 ppm.
3. Laydown Area
The Laydown Area was located immediately south of a concrete pad in the east central portion of the
plant. The Laydown Area consisted of bare soils and vegetated soils. The average PCB concentration in the
Laydown Area was 3.5 ppm, and the maximum concentration was 37.9 ppm (at 1.5 to 3.0 ft depth). The
1997 Source Control Rl found neither groundwater nor overland erosion to be pathways for
recontamination of Fields Brook.
4. Plant Process Area
The Plant Process Area was the active, operating portion of the TiCU facility. The Plant Process Area is
almost completely covered with either pavement or structures. PCB concentrations in surface soils in the
Plant Process Area were identified in the range of 3.1 ppm to 50 ppm. However, a few scattered sampling
locations have identified PCB concentrations greater than 50 ppm and a small area was found with PCB
concentrations greater than 500 ppm. The primary area with elevated PCB concentrations was associated
with the old Therminol system.
5. Soil Piles
The Soil Piles were located on a concrete storage pad in the east central portion of the TiCU facility.
Standard plant maintenance and upgrades occasionally required the excavation of small amounts of soil.
These soils were stockpiled on the concrete pad. The soil piles were not designated as having the potential
for recontamination to Fields Brook.
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6. Mining Residuals Pile
The inactive Mining Residuals Pile was located in the eastern portion of the facility between Middle Road
and Fields Brook. The pile received "Bevill" exempt mining residuals (e.g., iron hydroxide) from previous
plant operations prior to Millennium's operations. As stated in the Bevill exemption, the mining residuals
are neither hazardous wastes nor hazardous substances.
Although the mining residuals were not hazardous wastes, sample results revealed that PCBs were
present in the Mining Residuals Pile at concentrations ranging from non-detect to 760 ppm.
Based on a review of historical radionuclide data from the Fields Brook site in 1998, EPA determined there was a
likely source of additional radioactivity from the Millennium TiCU facility. For additional site background
information, a chronology of significant events for the Site is included in Appendix D.
VIII.2 OPERABLE UNIT 6: RESPONSE ACTION SUMMARY
Basis for Taking Action
Evaluations of PCB and radium contamination at the Millennium TiCU Plant as described above led EPA to believe
that it was a potential source of recontamination to Fields Brook. COCs for the Millennium TiCU Plant OU6 soils
include PCBs and radium.
From 1989 through 1997, as part of the RI/FS process for the Source Areas, FBAG evaluated areas of potential
contamination within the Fields Brook watershed to determine whether they were a source of past
contamination or could cause future recontamination once the Fields Brook cleanup is underway. The Millennium
TiCU Plant was determined as one of the sources of contamination or potential contamination to Fields Brook.
Additional details about RI/FS for the Source Areas are discussed in Section VI.2 "Basis for Taking Action."
Response Actions
Remedial actions for the Millennium TiCU Plant OU6 were selected in the September 29, 1997, SCOU ROD and in
the April 8, 1999, Site-Wide ESD. Although a RAO was not specified in the 1997 SCOU ROD, the goal of the
selected Source Control Ous remedies is to remediate source areas that have the potential to cause sediment
contamination to Fields Brook and its tributaries, thereby preventing the recontamination of the areas that will
be addressed by the Sediment OU1 and FWA OU4. The Source Control action supports the Sediment OU1 and
FWA OU4 remediation by helping to ensure that human-health based CUGs are maintained. Where Ics were
required, those controls were intended to limit the future use of areas that are not UU/UE to ensure that
contamination does not migrate to Fields Brook.
46
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The cleanup of the Millennium TiCU plant was developed to address contaminated soils and mining residual piles
that were and could potentially be a source of PCBs and radionuclides to Fields Brook. The 1997 SCOU ROD
required the following remedial actions for Millennium TiCU Plant OU6:
1. Excavation of soil and mining residual pile with PCB concentrations greater than or equal to 50 ppm.
2. Excavated soils to be disposed at either an on-site or off-site TSCA landfill.
3. Following completion of excavation activities, the excavated areas were to be backfilled with clean soil
and graded to allow for adequate drainage.
4. Remaining surface soils included in the remedial response area were to be contained on-site with a 12-
inch soil cover and an erosion control blanket and vegetated to reduce erosion. For traffic and work areas,
a geotextile and 6 inches of gravel were to be used.
EPA issued a "stop work" directive to Millennium (effective June 10, 1998) to halt work on the RD under the UAO
pending investigation of radionuclide contamination in the Ashtabula River and the Fields Brook watershed.
Millennium conducted follow-up sampling. The results of the sampling identified unacceptable levels of radium at
the Millennium TiCI4 facility and in FWA soils near the Millennium facility. EPA determined that radium should be
added as a COC for the cleanup of Millennium TiCU Plant OU6 and for the Fields Brook sediment and the FWA
soils. Because of the presence of radium, specific components of the remedial action were modified to address
soils and sediment that contain radium. The 1999 Site-Wide ESD made changes to the remedy for both Fields
Brook and the Millennium TiCI4 property. The 1999 Site-Wide ESD required that soil and mining residuals be
excavated from the Millennium TiCI4 property to meet an industrial radium cleanup level of 10 pCi/g above
background for combined levels of radium-226 and radium-228.
Due the significant amount of PCB-contaminated soils disposed of at Millennium's landfill from the original 1999
cleanup and 2007 EU8 removal, the 1999 Site-Wide ESD issued to address radionuclide contamination includes a
requirement for 30 years of groundwater monitoring to ensure the landfill is securely containing wastes and there
are no unacceptable releases to the environment. The Millenium landfill operates as a RCRA Subtitle D landfill and
is under regulation by Ohio EPA.
On September 23, 2009, EPA issued an ESD changing the IC requirements for three of the Fields Brook Source
Areas, including Millennium TiCU Plant OU6 (EPA, 2009). The current requirement, for deed restrictions to limit
the future use of the Site and to protect the cover system and drainage controls, was replaced with the following:
1. Deed restrictions will be implemented to restrict future use of the plant property to industrial uses; and
2. Maps of areas which require restrictions will be developed as part of the IC Work Plan.
Status of Implementation
EPA issued a UAO (V-W-98-C-449) for the performance of the Millennium RD/RA on December 24, 1997 (EPA,
1997). A modification to the UAO became effective February 13, 1998 (EPA, 1998).
Millennium elected to exceed the requirements of the ROD and proposed the following:
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1. Excavation of soil and mining residuals containing 33.1 ppm total PCBs within the Mining Residual Pile or
outside the Facility Stormwater Collection Area (FSCA);
2. Excavation of soils containing 350 ppm total PCBs inside the FSCA;
3. Excavation of soils containing total radium 312 pCi/g. The 12 pCi/g is based on 10 pCi/g above background,
which is estimated at 1 pCi/g Ra-226 background and 1 pCi/g Ra-228 background; and
4. Site restoration.
The RD and the RA work plan were approved on July 7, 1999.
Millennium proposed using its own landfill, which is part of the Millennium complex of facilities within the Fields
Brook watershed. In consultation with Ohio EPA and Ohio Department of Health/Bureau of Radiation Protection,
EPA made the determination that it met the definition of "on-site" and that the construction of the landfill was
consistent with the requirements of TSCA and allowed for the disposal of remediation-related material from the
Millennium Source Control cleanup.
The physical cleanup at the Millennium TiCU property began in July of 1999. Approximately 700,000 cubic yards of
PCB and radionuclide-contaminated soil was sent to the Millennium landfill for disposal.
The 1997 SCOU ROD cleanup requirements for the Millennium TiCU Plant OU6 were based on the risk of
recontamination of the Brook. Millennium exceeded the ROD-required PCB and radium cleanups and expanded
the cleanup to plant areas (within the FSCA) not deemed necessary under the 1997 SCOU ROD for the protection
of Fields Brook.
Remedial Action excavation was officially completed with the approval of the Completion of Remedial Action
Report on June 28, 2000 (Millennium Inorganic Chemicals, 2000). Additional work was later determined to be
necessary and included:
1. Completion of Additional PCB Response Action under UAO V-W-08-C-883
In 2005, FBAG discovered pockets of DNAPL contamination in Fields Brook during its OM&M sediment
monitoring. During follow-up excavation sampling in September 2007, liquid PCB product was discovered
between the northern boundary of the fenced Millennium TiCU Plant OU6 and the Fields Brook stream, in
EU8. Liquid PCBs and highly contaminated PCB soils were found during these excavation activities.
On October 18, 2007, EPA issued a UAO to Millennium to address the PCB contamination.
The closure data from the response action is presented in the "Final Report, Administrative Order V-W-08-
C-883, Millennium Inorganic Chemicals TiCI4 Facility, Ashtabula, OH," dated November 2009 (Millennium
Inorganic Chemicals, 2009). Some of the report's conclusions include:
1. All soils were excavated in EU6 and EU8 with observed DNAPL or above PCB confidence removal
goals (50 ppm). See Fig. 6-2 in Appendix F for excavation locations.
2. A total of 24,644 tons of contaminated soils were shipped offsite for disposal.
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3. Four groundwater interceptor trenches were installed between the Millennium operations area
and Fields Brook. The trenches are periodically pumped out, treated, sampled, and then
discharged to the Millennium process water ponds.
On July 10, 2009, EPA issued a modification to the Fields Brook Statement of Work, that addressed the
work completed by Millennium, and authorized the re-routing of Fields Brook in EU 8 by FBAG (EPA,
2009). The Fields Brook re-routing project is discussed in the Section VI.2 for Sediment OU1 and FWA OU4
of this FYR Report, because it was carried out under the oversight of the FBAG. On May 18, 2010, EPA
notified Millennium that it had completed all of its obligations under the UAO (EPA, 2010).
2. Groundwater Monitoring at Millennium Landfill
Significant quantities of PCB-contaminated soils were disposed of in Millennium's own industrial landfill,
located approximately two miles east of its facility in Ashtabula. These soils were generated during the
original cleanup of the plant in 1999, and during the more recent EU8 removal action in 2007. The 1999
Site-Wide ESD issued to address radionuclide contamination includes a requirement for 30 years of
groundwater monitoring.
The landfill is under regulation by Ohio EPA. It operates as a RCRA Subtitle D landfill, pursuant to Ohio
Administrative Code (OAC) 3745-29 (Permit & Operations), OAC 3745-30-08 (Ground Water Monitoring),
and OAC 3745-37 (License). Under its current license, Ohio EPA requires semi- annual monitoring for PCBs
in groundwater near the landfill to ensure the landfill is securely containing wastes.
On December 10, 2015, Cristal made a request to discontinue the EPA requirement for quarterly PCB
sampling at the Cristal Ashtabula Landfill. Cristal had regularly sampled leachate between 1999 to 2015. In
that time, PCBs had not been detected in the leachate. On December 22, 2015, EPA approved Cristal's
request to discontinue quarterly sampling. Semi-annual sampling for PCBs is expected to continue under
terms of the Ohio EPA permit. The contaminated soils at Ineos Ashtabula Landfill are now covered with
approximately 50 ft of filter cake material, and approximately half of the area was permanently capped in
2011.
Institutional Controls
Table 7: Summary of Planned and/or Implemented Ics at Mi
lennium TiCU Plant OU6
Media,
engineered
controls, and
areas that do not
support UU/UE
based on current
conditions
Ics
Needed
Ics Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC
Instrument
Implemented and
Date (or planned)
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A. Entire 28-acre plant
Entire 28-acre
plant property
property is restricted to
commercial/ industrial use,
and consumptive use of
groundwater is prohibited.
Environmental
Soil and
Groundwater
and 1.5 acres
designated as
Covenant
pursuant to Ohio
Yes
Yes
the "Restricted
Zone," as
depicted in Fig.
1-10 in
Appendix F.
B. 1.5 acre "Restricted Zone"
is further restricted to
prohibit any intrusive
activity that might disturb
any residual PCB DNAPL or
Fields Brook.
UECA, recorded
February 10,
2011, SDMS
#421768
A map of the parcel with the recorded ICs is shown on Fig. 1-10 in Appendix F. The plant property is outlined in
yellow, and the Restricted Zone is shaded gray.
Status of Access Restrictions and ICs: For source areas at the Fields Brook Site, the 1997 SCOU ROD required ICs
where hazardous substances, pollutants or contaminants will remain above levels that could re-contaminate
Fields Brook sediment above cleanup levels, and to maintain the integrity of the remedy.
On September 23, 2009, EPA issued an ESD which modified the remedies regarding IC requirements for the
Millennium TiCU Plant OU6 and Acme Scrap Iron and Metal/South Sewers OU8 and clarified how IC requirements
will be applied to support the 1997 SCOU ROD. Per the EC recorded on February 10, 2011, the IC requirements of
the 2009 ESD are implemented for Millennium TiCU Plant OU6.
Millennium recorded an EC, pursuant to the Ohio UECA, in February 2011. The EC ensures protectiveness of the
remedy identified in the 1997 SCOU ROD, 1999 ESD, and 2007 UAO. The EC restricts the entire plant property to
industrial use, prohibits consumptive use of groundwater, and applies additional restrictions on intrusive activity
in a zone immediately north of the Millennium plant boundary in the Fields Brook floodplain (roughly
corresponding to the "Non-Traffic Area"), in the area of the PCB excavation into which Fields Brook was
relocated. See Section VI.2 for OUs 1 & 4 of this FYR Report for a discussion of the EU8 Fields Brook relocation
project.
Current Compliance: Based on the FYR site inspection, EPA is not aware of Site or media uses which are
inconsistent with the stated objectives to be achieved by the implemented Ics. The remedy appears to be
functioning as intended.
IC Follow up Actions Needed: An ICIAP should be developed for Millennium TiCI4 OU6. The purpose of the ICIAP is
to document additional IC evaluation activities necessary: to ensure that the implemented Ics are and continue to
be effective, to explore whether additional Ics are needed and ensure their implementation, and to ensure that
LTS procedures are in place so that Ics are properly maintained, monitored, and enforced. IC evaluation activities
will include, as needed, developing updated maps depicting current conditions in areas that do not allow for
UU/UE, reviewing current zoning and city or township ordinances, and reviewing recording and title work for
properties impacted by the Site.
50
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Long-Term Stewardship: Compliance with ICs is necessary to assure the protectiveness of the remedy. Planning
for LTS is therefore required to ensure that the Ics are maintained, monitored and enforced at Source Area
properties, so that the remedy continues to function as intended. As part the LTS procedures, inspections of the
geosynthetic material and stone cap of the FSCA should be conducted to ensure the remedy identified in the
1997 SCOU ROD remains protective as required under the EC recorded in 2011. An ICIAP should be completed to
document LTS procedures for the Site. LTS procedures should describe at a minimum: (1) monitoring activities
and schedules; (2) responsibilities for performing each task and parties responsible for completing those tasks; (3)
reporting requirements; and (4) a process for addressing any potential IC issues that may arise during the
reporting period.
A report should be submitted regularly to EPA to demonstrate that: the Site was inspected to ensure no
inconsistent uses have occurred; that ICs remain in place and are effective; and that any necessary contingency
actions have been executed. Results of IC reviews should be provided to EPA in an annual/biennial ICs report and
with a certification that the ICs remain in-place and are effective. Finally, development of a communications plan
and use of Ohio's one-call utilities notification system should be explored for broader information sharing of
applicable ICs implemented at Fields Brook (see notes related to North Sewers OU7).
Systems Operations/Operation & Maintenance
OM&M at the Millennium landfill, which includes groundwater monitoring for PCBs and radionuclides, is being
performed in conjunction with Ineos Ashtabula Landfill's license requirements with the State of Ohio.
Between 2007 and 2008, interceptor trenches were installed between the Plant operational area, upland area
and the floodplain to intercept any migration from potential sources of PCBs remaining on-site (for example,
under process equipment that is effectively capped). The trenches were constructed to capture any free product
migrating towards Fields Brook in sumps located in the center of each trench. The trenches span the length of the
operational areas of Millennium TiCU Plant OU6 to capture any material migrating from these areas (See
discussion in Section VIII.2, Status of Implementation, Part 1). The terms of the UAO do not require Ineos to
provide EPA with monitoring information from these trenches, but data voluntarily provided in March 2019
through June 2023 show that groundwater in these trenches is currently non-detect for PCBs. Development and
implementation of an OM&M Plan to support long term monitoring and reporting of the trenches would be
beneficial to ensure that the source control activities implemented have and will continue to be effective in
preventing migration of any PCBs into the interceptor trenches.
VIII.3 OPERABLE UNIT 6: PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last FYR as well as the
recommendations from the last FYR and the current status of those recommendations.
Protectiveness Determinations/Statements from the 2019 FYR
Table 8: Protectiveness Determinations/Statements from the 2019 FYR
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ou#
Protectiveness
Determination
Protectiveness Statement
6
Short-term Protective
The remedy at the Millennium TiCI4 Plant Source Area OU6
currently protects human health and the environment. The cleanup
in non-plant areas exceeded ROD requirements by excavating to a
stricter cleanup level and meets the remedial action objective of
preventing recontamination of Fields Brook in excess of PCB and
radium CUGs. An effective IC is in place in the plant area on EU8
where excavation of PCB and DNAPL contaminated soils occurred to
prevent recontamination of the Fields Brook. However, in order for
the remedy to be protective in the long-term, the following actions
need to be taken to ensure protectiveness: develop and implement
an OM&M Plan to monitor and respond to any collected material in
the interceptor trenches so that is appropriately removed for
treatment and disposal, and to prevent recontamination of the
Brook; and develop and implement a LTS plan for monitoring and
tracking compliance with existing Ics, communicating with EPA, and
providing an annual certification to EPA that Ics remain in place and
are effective.
Status of Recommendations from the 2019 FYR
Table 9: Status of Recommendations from t
he 2019 FYR
OU#
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable)
6
There is
Develop and
Addressed in
EPA anticipates OM&M
NA
inadequate
implement and
Next FYR
procedures for monitoring and
monitoring of
OM&M Plan to
responding to contaminated
the interceptor
monitor and respond
material in the interceptor
trenches for
to any collected
trenches, if observed, to be
potential
material in the
included in the OU1 & OU4
recontamination
interceptor trenches
OM&M Plan to be submitted by
of Fields Brook.
so that it is
appropriately
removed for
treatment and
disposal, and to
prevent
recontamination of
the Brook.
FBAG. At the time of this review,
EPA is coordinating with FBAG
to review the draft OM&M Plan.
Completion of the updated
OM&M plan has a milestone
date of 12/31/2024.
6
Procedures are
Develop and
Considered
LTS procedures will be included
NA
not in place to
implement a LTS Plan
But Not
in the ICIAP; a separate LTS Plan
ensure LTS of Ics
for monitoring and
Implemented
is not needed.
at the Site.
tracking compliance
with existing Ics,
52
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communicating with
EPA, and providing an
annual certification to
EPA that the Ics
remain in place and
are effective.
VIII.4 OPERABLE UNIT 6: FYR PROCESS
Data Review
A list of technical reports and other documents reviewed for this FYR are included in Appendix A-Reference List.
As discussed in Section VI.4, validated data from the 2022 and 2023 Annual OM&M sampling events for OU1 and
OU4 are not available at the time of this review. Tables 1 through 3 of the Final 2021 Annual OM&M Soil,
Sediment, and Surface Water Sampling Report includes data from the previous five years. The data were
analyzed, and the general observations include:
1. Soil samples taken in EU8 were evaluated for PCBs, VOCs, and SVOCs between 2019 to 2021 and do not
exceed applicable CRGs.
2. Sediment samples collected from SD-17, SD-18, and SD-19 in EU8 between 2019 and 2021 were evaluated
for PCBS, VOCs, and SVOCs, and do not exceed the applicable CRGs.
3. Surface water sample SW14 from EU8 was analyzed for PCBs and VOCs between 2019 and 2021. PCBs
were not detected in SW14; low concentrations of cis-l,2-dichloroethene was detected at SW14, with a
maximum concentration of 1.3 ug/l in 2020. Surface water sample SW14 indicates that detected low level
concentrations of COCs would not cause a recontamination of the Fields Brook sediment that would
exceed CUGs, and the liner system is effectively protecting Fields Brook.
4. From 2019 to 2023, voluntarily monitoring of the interceptor trenches by Ineos outside of the 1997 SCOU
ROD and 2007 UAO show that source control activities implemented appear to be effective in preventing
the migration of any PCBs into the interceptor trenches from the Ineos property.
5. FBAG reports the results of its required monitoring in the Fields Brook (see Section VI for Sediment OU1
and FWA OU4 above). The results of the soil, sediment, and surface water data from 2019-2021 from the
grids in EU8 were not found to contain PCBs above the allowable residual level. EU8 is located directly
north of Millennium TiCU Plant OU6.
a. The data collected from 2019 to 2021 is sufficient for the purpose of this FYR as the data
demonstrates there are no impacts and exposures occurring from the Brook. The data collected from
2019 to 2021 is consistent with historic data collected from 2004 to 2018. It is unlikely that
conditions of the brook have changed based on the observed land use and conditions of Fields Brook
during the OM&M sampling events and FYR site inspection.
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Site Inspection
The inspection of the Millennium TiCU Plant OU6 was conducted on 8/23/2023. In attendance were Anna
Nguyen, EPA; Jenny Polster, EPA; Amy Gahala, EPA; and Nick Roope, Ohio EPA. Robert Schmude, representing
Ineos Pigments participated. The purpose of the inspection was to assess the protectiveness of the remedy. The
Millennium TiCU Plant OU6 inspection included observations of EU8 of Fields Brook and the northern interceptor
trench. See the Site Inspection Checklist (Appendix B) and Photos for additional details (Appendix C). The
Millenium landfill is under regulation by Ohio EPA and was not included as part of the FYR inspection.
The weather during the Millennium TiCU Plant OU6 inspection was cloudy with temperatures in the high 90's
(Fahrenheit).
1. The interceptor trenches appeared to be in good condition and functioning as intended.
2. Ineos informed EPA that the trenches are sampled quarterly, and the samples are analyzed by an external
lab. Ineos indicated that the purpose of the trench is to detect migrating contaminants.
After the inspection, EPA requested copies of the trench OM&M records, trench pumping records, and quarterly
sample results. All sample results for PCB have been non-detect since March 2019. Since sample results indicate
no detection of PCBs, the trenches have not required pumping from 2019 to the time of this review.
All source control activities implemented appear to be effective in preventing the migration of any PCBs into the
interceptor trenches from the Ineos property. Ineos indicated the OM&M procedures for the interceptor trenches
were provided to de maximis in July 2021 for memorialization in the Sediment OU1 & FWA OU4 OM&M plan.
Ineos made this request due to the minimal O&M activities required for Millennium TiCU Plant OU6. At the time
of this review, EPA and FBAG are in the process of amending the draft Sediment OU1 & FWA OU4 OM&M Plan.
VIII.5 OPERABLE UNIT 6: TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
Yes. The remedy is functioning as intended by the decision documents. Soil, sediment, and surface water samples
collected from EU8 in 2019 through 2021 did not contain PCBs above the allowable residual levels. Voluntary
monitoring of the groundwater interceptor trenches located on the northside of the Ineos property indicate PCBs
were not detected. The soil and sediment removal performed under the 2007 UAO was completed in accordance
with established removal objectives for the Site. The OM&M data collected from 2019 to 2021 for Fields Brook
OU1 Sediment and OU4 FWA indicates cleanup standards are met. This observation is consistent with historic
OM&M data.
Effective ICs are in-place. An ICIAP should be developed for Millennium TiCI4 OU6 to have procedures
documented for ensuring that the implemented ICs are and continue to be effective, to explore whether
additional ICs are needed and ensure their implementation, and to ensure that LTS procedures are in place so
that ICs are properly maintained, monitored, and enforced. Though occurring voluntarily currently, the OM&M
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procedures for the interceptor trenches should be memorialized in the Sediment OU1 and FWA OU4 OM&M Plan
to ensure these necessary procedures continue and that the implemented remedies remain effective.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the
remedy selection still valid?
Question B Summary:
Yes. There have been no changes to the PCB or radium cleanup requirements for the facility. The RAOs for the
Millennium TiCU Plant Source Area OU6 are still valid. Industrial land use of Millennium TiCI4 OU6 is consistent
with the IC requirements. Since issuance of the 1997 SCOU ROD, the recommended slope factor to evaluate
relevant potency for PCB was modified in 1999. The slope factor used to develop the Fields Brook cleanup
standards is slightly more conservative than that currently used. No additional remedial actions are needed based
on the re-evaluation of PCB toxicity.
EPA has evaluated the types and concentrations of the radionuclides present at the Site and determined the
radium-226 and radium-228 were appropriately identified as the primary radionuclide COC. Any thorium
contamination would have been co-located with the radium, and thus sufficiently addressed at the time of
cleanup. The EPA found the radionuclide cleanup standards implemented at the Site remain protective.
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy?
No. There are no observed impacts or effects from natural disasters which may affect the protectiveness of the
remedy.
VIII.6 OPERABLE UNIT 6: ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
OU(s): OU6
Issue Category: Operations and Maintenance
Issue: OM&M procedures for the interceptor trench are not
memorialized.
Recommendation: OM&M procedures to monitor and respond to any
collected material in the interceptor trenches so that it is appropriately
removed for treatment and disposal, and to prevent recontamination of
the Brook should be included in the OU1 & OU4 OM&M Plan to be
submitted by FBAG.
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Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
OU(s): 6
Issue Category: Institutional Controls
Issue: An ICIAP is needed to ensure that effective ICs are implemented,
monitored, and maintained.
Recommendation: Develop and submit an ICIAP for approval which
describes the plan for ensuring that all remaining required ICs at the Site
are implemented, and for ensuring that all ICs, once implemented, are
monitored and maintained.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
6/25/2028
VIII.7 OPERABLE UNIT 6: PROTECTIVENESS STATEMENT
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination:
OU6 Short-term Protective
Protectiveness Statement:
The remedy at the Millennium TiCI4 Plant OU6 currently protects human health and the environment.
The cleanup in non-plant areas exceeded ROD requirements by excavating to a stricter cleanup level
and meets the remedial action objective of preventing recontamination of Fields Brook in excess of
PCB and radium cleanup goals. An effective IC is in-place in the plant area and on EU8 where excavation
of PCB and DNAPL contaminated soils occurred to prevent recontamination of the Brook. However, in
order for the remedy to be protective in the long-term, the following actions need to betaken to ensure
protectiveness: OM&M procedures to monitor and respond to any collected material in the interceptor
trenches so that it is appropriately removed for treatment and disposal, and to prevent
recontamination of Fields Brook should be included in the OU1 & OU4 OM&M Plan to be submitted by
FBAG; and develop and submit an ICIAP for approval which describes the plan for ensuring that all
remaining required ICs at the Site are implemented, and for ensuring that all ICs, once implemented,
are monitored and maintained.
IX. OPERABLE UNIT 7: NORTH SEWERS SOURCE AREA
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IX.l OPERABLE UNIT 7: INTRODUCTION
OU Summary
The purpose of this FYR is to determine if the remedy selected to address the source area contamination at the
North Sewers OU7 of the Fields Brook Superfund Site is protective of human health and the environment. The
remedy included the closure, grouting and replacement of three storm and industrial outfall process sewers that
contained sediment with elevated levels of PCBs and other organic constituents. The cleanup of the North Sewers
was initiated in September 2000 and completed in October 2000. EPA issued a letter on May 14, 2001, approving
the completion of RA and the submittal of the Remedial Action Report (EPA, 2001).
Background. Land and Resource Use
The North Sewers are located in the northwest portion of the industrialized area near Fields Brook (top half of Fig.
7-1, Appendix F). Three sewers were identified as part of the North Sewers OU7:
Combined Sewer - The 1997 Source Control Rl identified this sewer, commonly referred to as the North
Sewer, as a 48-inch diameter reinforced concrete combined storm and facility outfall sewer. The sewer
was later found to be 42 inches in diameter. The sewer is approximately 2,400 feet in length and runs
along the west side of State Road, north of Fields Brook. The sewer was partially blocked in certain parts
by debris which includes bricks, wood, sediment, and pieces of concrete. The North Sewer accepted
surface and facility outfall water, which at several locations included plant surface water run-off, process
water and sanitary effluent. On-site treatment of sanitary waste was handled by all facilities that
discharged to the sewer. No untreated process and sanitary effluent water entered the combined sewer
system. The combined sewer collected outfall water from three facilities (the former Occidental Chemical
facility, RMI Sodium, and Detrex) through three outfalls located at East 6th Street and State Road.
Storm Sewer - A 6-inch vitrified clay storm water sewer was identified and is approximately 250 ft in
length. It runs from the southwest corner of the intersection of State Road and East 6th Street, south to
join the north end of the combined sewer on the west side of State Road, north of Fields Brook. This sewer
line collected storm water from the RMI Sodium property and discharged into a manhole located at the
former Occidental Chemical outfall.
Detrex Facility Outfall Sewer - This sewer connected the Detrex facility with the Combined Sewer. A
portion of the sewer was constructed of polyvinyl chloride (PVC) and was relatively free of sediment. This
PVC sewer section discharged to a manhole that contains an older section of sewer line that crosses under
State Road to connect to the combined sewer. This sewer transferred water from the Detrex water
treatment system to the Combined Sewer.
History of Contamination
57
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The 1997 Source Control Rl found that sediment in these storm and process outfall facility sewers were a source
of potential recontamination to Fields Brook.
Combined Sewer - Sediment samples from the combined sewer had concentrations of benzo(a)pyrene
and hexachlorobenzene that ranged from 1.9 ppm to 11 ppm and 13 ppm to 5,800 ppm, respectively.
Storm Sewer - A sediment sample from this storm sewer had a 5.4 ppm concentration of benzo(a)pyrene.
Detrex Facility Outfall Sewer - A sediment sample was collected within a manhole on the east side of State
Road in the northwest corner of the Detrex property. This manhole is between the Detrex facility sewer
and the Combined Sewer that eventually discharges to Fields Brook on the west side of State Road. The
sediment sample was collected from the bottom of the manhole where the sediment accumulates. This
sediment had concentrations of 1,1,2,2-tetrachloroethane, 1,1,-dichloroethene, tetrachloroethene,
benzo(a)pyrene, HCB, HCBD, hexachloroethane, heptachlor and gamma-BHC (Lindane).
For additional site background information, a chronology of significant events is included in Appendix D.
IX.2 OPERABLE UNIT 7: RESPONSE ACTION SUMMARY
Basis for Taking Action
From 1989 through 1997, as part of the RI/FS process for the Source Areas, the PRPs evaluated areas of potential
contamination within the Fields Brook watershed to determine whether they were a source of past
contamination or could cause future recontamination once the Brook cleanup is underway. The sediments in the
storm and outfall sewers of the North Sewers OU7 were identified as a potential source for recontamination of
Fields Brook sediment. COCs of the North Sewers OU7 sediments include 1,1,2,2-tetrachloroethane, 1,1,-
dichloroethene, tetrachloroethene, HCB, HCBD, hexachloroethane, heptachlor, benzo(a)pyrene, and gamma-BHC
(Lindane). Additional details about RI/FS for the Source Areas are discussed in Section VI.2 "Basis for Taking
Action."
Response Actions
Remedial actions for the North Sewers OU7 were selected in the 1997 SCOU ROD. Although a RAO for the remedy
selected for this OU was not specified in the 1997 SCOU ROD, the goal of the selected Source Control remedies,
including for this OU, is to remediate source areas that have the potential to cause sediment contamination to
Fields Brook and its tributaries, thereby preventing the recontamination of the Fields Brook sediment areas that
will be addressed by the Sediment OU1 and FWA OU4. The Source Control action is intended to support the
Sediment OU1 and FWA OU4 remediation by helping to ensure that human-health based CUGs are maintained
and not exceeded.
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The selected remedy for the North Sewers 0U7 required the cleaning or grouting of the Combined Sewer. Where
ICs were required, those controls were intended to limit the future use of areas that are not UU/UE to ensure
that contamination does not migrate to Fields Brook. Specifically, the selected remedy for OU7 included the
following remedial actions:
1. Cleaning of Sewer Lines and Catch Basins
For portions of the sewer that could be cleaned, the remedy required the removal of sediment and debris
from inside the sewer lines and the associated catch basins to reduce the potential of recontamination of
the Fields Brook sediments in excess of CUGs. Sediment removal would be accomplished by cleaning the
inside of the sewer using manual and mechanical techniques to remove sediment, followed by rinsing. The
equipment selected would be capable of removing sediments, dirt, grease, rocks, and other foreign
materials.
2. Sediment Containment
Sewer sections that could not be cost-effectively cleaned were to be filled with grout to contain
contaminated sediment and debris. This containment approach will be used for a portion of the 48-inch
diameter combined sewer. The sediments in this sewer segment would be contained by filling the sewer
pipe with a cement grout to restrict flow in the sewer and prevent migration of sediments into Fields
Brook. Sections of the existing sewer line that were to be grouted were to be abandoned and replaced
with a new sewer diversion line.
3. Institutional Controls
ICs were to be implemented to control excavation into sewers that have been sealed to contain
contaminants and to define handling and disposal requirements for such sewers.
Status of Implementation
EPA issued a UAO (V-W-98-C-446) for the performance of the North Sewers Source Area RD/RA on December 24,
1997 (EPA, 1997). A modification to the UAO became effective February 18,1998 (EPA, 1998).
The North Sewer Source Area Group evaluated the possibility of cleaning and restoring the existing sewers.
However, because of the depth and condition of the sewers and the large amount of utility lines running near the
sewers, the North Sewer Source Area Group determined that it was more practical to close the sewers and build
new sewer lines. The 1997 SCOU ROD accepted either approach.
Prior to the abandonment and closure of North Sewers OU7, each facility completed rerouting of stormwater and
wastewater that formerly discharged into the Combined Sewer. Each facility individually rerouted its NPDES
outfalls in the summer of 2000. EPA did not oversee the design and construction of the rerouted outfalls as they
were reviewed and approved by Ohio EPA DSW prior to construction.
59
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The following connections from the RMI and Occidental Chemical facilities to the Combined Sewer were closed as
part of the North Sewer Remedial Action:
1. The former RMI outfall constructed of 36-inch reinforced concrete pipe;
2. The former Occidental outfall constructed of 24-inch reinforced concrete; and
3. The 6-inch Storm Sewer constructed of vitrified clay.
After the brick-and-mortar closure of the Occidental Chemical and RMI outfalls had cured, concrete was poured
into the manholes to a level corresponding with the ground surface. The 6-inch Storm Sewer was plugged with a
commercial expansion plug.
The former Detrex Facility Outfall Sewer was abandoned on Detrex property when the new outfall was installed.
The old line was not grouted, but a large section was cut and removed to allow for the installation of the slurry
wall on the Detrex property. The former Detrex Facility Outfall to the Combined Sewer was located west of the
slurry wall. Due to the interception of the slurry wall, the former Detrex Outfall is no longer connected to the
Combined Sewer.
In addition to the closure of connections for sewers entering the Combined Sewer, the Combined Sewer outfall to
Fields Brook was also closed. As part of the remedial action, a wooden form was constructed around the North
Sewer outfall at Fields Brook and the pipe was filled with concrete, forming a plug five feet in length.
Within the Combined Sewer itself, lean concrete grout was poured into the sewer through vertical access shafts
to immobilize sediment within the sewer. Concrete was poured at three access shaft locations to ensure
adequate sewer closure.
The abandonment of the North Sewers was completed during September and October of 2000, with the
Completion of Remedial Action report approved on March 27, 2001 (EPA, 2001). Since the abandonment of the
North Sewers, EPA determined no further monitoring or maintenance was required per the Acceptance of Work -
Completion of Remedial Action Letter dated March 27, 2001. The sewer ends and connections were capped, the
length of the sewers were grouted to prevent future use, and replacement sewers were constructed.
As part of an evaluation of the DNAPL migration analysis from Detrex, FBAG collected soil samples near the
Combined Sewer between 2006 and 2008. Samples were collected from depths ranging between 10 to 12 feet
bgs near the Combined Sewer; results were below the CUGs for HCB and HCBD. Based on the samples collected
from the 2006 to 2008 investigation, the is no evidence of contamination from the utility corridor near the
Combined Sewer.
Some additional contaminated soil removal occurred near the former outfall of the Combined Sewer when
Ashtabula County replaced the State Road Bridge over Fields Brook in 2010. Environmental oversight was
provided by FBAG and Ohio EPA to ensure that disposal requirements were met and that the bridge construction
did not re-contaminate Fields Brook. No active remedial activities have taken place at the North Sewers OU7
since 2010. A summary of implemented ICs for the OU7 area of the Site are provided in Table 10 below.
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Institutional Controls
Table 10: Summary of Planned and/or Implemented ICs for the North Sewers OU7
Media, engineered
controls, and areas
that do not support
UU/UE based on
current conditions
ICs
Needed
ICs Called for
in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC
Instrument
Implemented
and Date (or
planned)
Soil and Grouted Pipe
Yes
Yes
2400 feet Sewer
Easement.
Properties are
depicted in Figure
7-2 in Appendix F.
Public shall be
notified and no
construction or
other activity should
be undertaken
which would
disrupt, disturb,
interfere or
otherwise breach
pipe.
Affidavit of Facts
Related to Title
to Real Property,
10/25/04
Soil and Grouted Pipe
Yes
Yes
Gabriel
Performance
Products, LLC
property P.P.N 03-
014-00-030-00
No construction or
other activity should
be undertaken
which would
disrupt, disturb,
interfere or
otherwise breach
pipe until written
consent of the EPA
is first obtained.
Environmental
Covenant,
recorded
12/29/2020,
SDMS #986875
Soil and Grouted Pipe
Yes
Yes
Ineos Pigments
USA Inc. property
P.P.N 03-014-00-
028-00
No construction or
other activity should
be undertaken
which would
disrupt, disturb,
interfere or
otherwise breach
pipe until written
consent of the EPA
is first obtained.
Environmental
Covenant,
recorded
12/23/2020,
SDMS #986874
Soil and Abandoned
Pipe
Yes
Yes
Detrex
Corporation
property P.P.N.
03-014-006-08
No activity should
be taken that would
interfere or
adversely affect the
integrity or
protectiveness of
the remedy unless
Environmental
Covenant
pursuant to Ohio
UECA, November
16, 2009
SDMS #353273
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written consent of
the EPA is first
obtained.
Soil and Grouted Pipe
Yes
Yes
Ashtabula County
Port Authority
property P.P.N 03-
014-00-029-00
No construction or
other activity should
be undertaken
which would
disrupt, disturb,
interfere or
otherwise breach
pipe until written
consent of the EPA
is first obtained.
Environmental
Covenant, signed
1/17/2021, NOT
RECORDED AND
NOT IN SEMS
A map of the Exhibit recorded with the Affidavit of Facts, showing the North Sewers location and adjacent
property owners is shown on Figure 7-2 in Appendix F.
Status of Access Restrictions and ICs: For source areas at the Fields Brook Site, ICs are required where hazardous
substances, pollutants or contaminants remain above levels that allow for UU/UE and could re-contaminate
Fields Brook above cleanup levels and are required to maintain the integrity of the remedy. ICs are required at
the Combined Sewer line portion of the North Sewers OU7 because contaminated sediment remains contained
within the sewer. On November 30, 2004, a notice was provided to EPA that transmitted an Affidavit of Facts
(also called a "deed notice") that was recorded in October 2004, on three parcels overlying the North Sewer. The
Affidavit states that "the public be notified of such work and made aware that no construction or other activity
should be undertaken which would disrupt, disturb, interfere with or otherwise breach such grouted and sealed
sewer pipe." The deed notice is intended to provide public notice and ensure activities do not disturb the
grouted and sealed sewer.
ICs are in place for the 6-inch Storm Sewer and Detrex Facility Outfall Sewer to ensure no construction or other
activity will take place that would jeopardize the remedy. The Gabriel Performance Products Environmental
Covenant includes the 6-inch Storm Sewer. The Detrex Corporation EC encompasses the location of the Detrex
Facility Outfall Sewer.
The Affidavit of Facts was recorded in 2004, prior to Ohio promulgating the Ohio UECA. EPA conducted an ICs
review in 2020 and determined three ECs are required to ensure the ICs run with the land to meet Ohio's UECA
requirements. The identified owners requiring EC recordings for the Combined Sewer are Ineos Pigments USA Inc.
(f/k/a Cristal USA Inc.), Gabriel Performance Products, LLC (Gabriel), and the Ashtabula City Port Authority (Port
Authority).
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Two ECs were signed and recorded by the corresponding property owners for portions of the Combined Sewer.
On December 23, 2020, the Ineos Pigments USA Inc. EC instrument was recorded. On December 29, 2020, the
Gabriel EC instrument was recorded. The third EC instrument for the Combined Sewer was signed by the Port
Authority on January 27, 2021, but not recorded. However, under Ohio's UECA, ECs must also be signed by the
"applicable agency." Thus, while the two recorded ECs are sufficient to act as deed notices, there is a need for
them to be re-executed, with the signature of the applicable agency, and re-recorded, to ensure that they run
with the land are enforceable as ECs under Ohio's UECA. At the time of this FYR, EPA is seeking to replace the two
EC recordings for the Ineos and Gabriel properties with ECs established pursuant to Ohio's UECA, and to put in
place an EC established pursuant to Ohio's UECA for Port Authority property.
Current Compliance: Based on the FYR site inspection in August 2023, EPA is not aware of site or media uses
which are inconsistent with the stated objectives to be achieved by the ICs. The remedy appears to be functioning
as intended.
The deed notice intended to provide public notice and ensure activities do not disturb the sewer appears to have
been effective in making an entity that was interested in conducting excavation in the area aware of the
restrictions. Specifically, in December 2018, an energy company contacted EPA regarding a proposed installation
of a gas pipeline that appears to run along the right-of-way along the entire length of the North Sewer.
In April 2019, the energy company conducted a Phase II Environmental Site Assessment (ESA) to evaluate if soils
and other materials within its area of interest were or may have been impacted by former adjacent property
operations. The area of interest was located within the Fields Brook Superfund site along the north side of EU5
and west side of State Road between EU5 and EU6. The 2019 Phase II ESA included the collection of soil and in-
situ groundwater samples.
EPA issued a "Letter Regarding Dominion Energy Group's Proposed Pipeline Project at the Fields Brook Superfund
National Priorities List Site, Ashtabula Ohio," dated December 15, 2021 (EPA, 2021), to the energy company which
suggests the expansion of environmental investigation activities to mitigate the risk of causing or threatening to
cause release of contamination to Fields Brook. The energy company conducted a second Phase II ESA in
December 2021 along the west side of State Road; in discussions with EPA, the energy company evaluated
moving the pipeline further west along State Road away from North Sewers (OU7). Based on this event with the
energy company, EPA will explore options to develop a communication plan with Ohio's one-call utility
notification program to expand the public's awareness of existing ICs in Fields Brook, specifically for parties with
interests in construction or development projects in or near the Fields Brook site.
On November 21, 2022, the energy company notified EPA that the pipeline project is on hold indefinitely and EPA
will be notified when the project will resume activity. In May 2024, the energy company indicated the pipeline
project remains at a standstill and will reach out when the project is resumed.
IC Follow up Actions Needed: An ICIAP is needed and should be developed for the North Sewers OU7. The
purpose of the ICIAP is to document additional IC evaluation activities that would be conducted to ensure that the
implemented ICs are effective, and to explore whether additional ICs are needed and ensure their
implementation. The purpose of the ICIAP is also to document LTS procedures being put in place for implemented
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ICs to help ensure they are properly maintained, monitored, and enforced. Documented IC evaluation activities
will include, as needed, developing updated maps depicting current conditions in areas that do not allow for
UU/UE, reviewing current zoning and city or township ordinances, and reviewing recording and title work for
properties impacted by the Site. LTS procedures, such as regular inspection of the engineering controls and access
controls at the Site and review of the ICs for the Site should be included in the ICIAP. The plan should also include
a requirement for certification to EPA that ICs are in place and effective. Finally, development of a
communications plan and use of Ohio's one-call utilities notification system should be explored for broader
information sharing of applicable ICs implemented at Fields Brook.
To ensure IC effectiveness and enforceability, the two previously recorded Combined Sewer ECs for the Gabriel
and Ineos properties should be re-executed with property owner and agency signature and re-recorded, and the
Combined Sewer EC for the Port Authority property should be executed, with property owner and agency
signature, and recorded. At the time of this FYR, EPA is coordinating with FBAG to complete this process.
Systems Operations/Operation & Maintenance
The Combined Sewer, Storm Sewer, and Detrex Facility Outfall Sewer have been abandoned and no further
monitoring or maintenance is required. The process of routine site inspections for ICs will be incorporated in the
ICIAP. The sewers were grouted to prevent future use, the ends of the sewer and connections were capped, and
replacement sewers were constructed.
IX.3. OPERABLE UNIT 7: PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last FYR as well as the
recommendations from the last FYR and the current status of those recommendations.
Protectiveness Determinations/Statements from the 2019 FYR
Table 11:
Protectiveness Determinations/Statements from the 2019 FYR
OU#
Protectiveness
Determination
Protectiveness Statement
1
Short-term
Protective
The remedy for the North Sewers OU7 currently protects human health and the
environment. The sewers have been closed and grouted and are no longer in use,
and there is no mechanism for any sediment within the sewers to move to the Fields
Brook since it has been rendered immobile. ICs are in place to prevent activities that
would disrupt or disturb the grouted and sealed sewers. However, in order for the
remedy to be protective in the long-term, the following actions need to be taken to
ensure protectiveness: evaluate the effectiveness of the current ICs; and develop
and implement a LTS Plan for monitoring and tracking compliance with existing ICs,
communicating with EPA, and providing an annual certification to EPA that the ICs
remain in place and are effective.
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Status of Recommendations from the 2019 FYR
Table 12: Status of Recommendations from the 2019 FYR
ou#
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable)
7
Procedures are not
in place to ensure
LTS of ICs at the
Site.
Develop and
implement a LTS
Plan for monitoring
and tracking
compliance with
existing ICs,
communicating
with EPA, and
providing an
annual certification
to EPA that the ICs
remain in place and
are effective.
Considered
But Not
Implemented
LTS Procedures will be included
in the ICIAP; a separate LTS Plan
is not needed. A new issue and
recommendation to develop an
ICIAP that also includes those
LTS procedures has been
included as part of this current
FYR.
NA
7
The deed notice
was recorded in
2004, prior to Ohio
promulgating the
UECA.
Evaluate
effectiveness of the
current ICs.
Completed
It was determined that the ECs
need to be re-executed and
recorded to meet the
requirements under Ohio's
UECA.
3/20/2023
IX.4 OPERABLE UNIT 7: FYR PROCESS
Data Review
Since the abandonment of the North Sewers, EPA determined no further monitoring or maintenance was
required in 2001. Since there is no monitoring of environmental media, there was no data to review during the
FYR period.
Site Inspection
The inspection of the North Sewers OU7 was conducted on August 22, 2023. In attendance were Anna Nguyen,
EPA; Jenny Polster, EPA; Amy Gahala, EPA; and Nick Roope, Ohio EPA. Bob Rule, de maximis inc., representing the
FBAG, participated. The purpose of the inspection was to assess the protectiveness of the remedy. No formal
interviews were conducted as part of the fifth FYR. The weather during the Site inspection was partly cloudy with
temperatures in the high 70's (Fahrenheit) in the afternoon.
1. A visual observation of the land along the right-of way overlying the abandoned Combined Sewer for
North Sewers OU7 showed that there did not appear to be any recent construction in areas along State
Road where the Combined Sewer is located.
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2. Due to the remedy being the abandonment of underground sewers, EPA did not take photos or interview
owners of the properties overlying the abandoned Combined Sewer as part of this FYR.
IX.5 OPERABLE UNIT 7: TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
Yes. The abandonment of the sewers comprising North Sewers OU7 has addressed concerns about accumulated
sediment moving from the sewers to Fields Brook. Since the Combined Sewer, Storm Sewer, and Detrex Facility
Outfall Sewer have been closed and the Combined and Storm Sewers grouted, historical sediment and debris
accumulated in the sewers can no longer flow into Fields Brook. ICs in the form of the 2004 deed notice and two
2020 ECs that are serving as deed notices are in place to prevent disturbance of the grouted sediment within the
Combined Sewer and appear to be effective. At the time of this FYR, EPA and FBAG are coordinating on executing
and recording/re-recording the three ECs pursuant to Ohio UECA. An ICIAP should be developed and
implemented with procedures to ensure the ICs remain effective, by being maintained and monitored.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the
remedy selection still valid?
Question B Summary:
Yes. The RAOs for the North Sewers OU7 Source Area is still valid. The goal of the cleanup was to eliminate
sources of possible recontamination to Fields Brook. Issues related to cleanup standards are not relevant to this
cleanup, because historical sediment within the North Sewers OU7 sewers has been immobilized or contained.
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy?
No. There are no observed impacts or effects from natural disasters which may affect the protectiveness of the
remedy.
IX.6 OPERABLE UNIT 7: ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
OU(s): 7
Issue Category: Institutional Controls
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Issue: An ICIAP is needed to ensure that effective ICs are implemented,
monitored, and maintained.
Recommendation: Develop and submit an ICIAP which describes the plan
for ensuring that all remaining required ICs at the Site are implemented,
and for ensuring that all ICs, once implemented, are monitored and
maintained.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
6/25/2028
OU(s): 7
Issue Category: Institutional Controls
Issue: The ECs recorded or signed in 2020 were not signed by an
applicable agency, which is a requirement of Ohio's UECA.
Recommendation: Ensure all applicable parties sign the ECs and record
the instruments.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
IX.7 OPERABLE UNIT 7: PROTECTIVENESS STATEMENT
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination:
OU7 Short-term Protective
Protectiveness Statement:
The remedy at North Sewers 0U7 currently protects human health and the environment. The sewers
have been closed and grouted and are no longer in use, and there is no mechanism for any sediment
within the sewers to move to the Fields Brook for contamination, since it has been rendered
immobile. ICs are in place to prevent activities that would disrupt or disturb the grouted and sealed
sewers. However, in order for the remedy to be protective in the long-term, the following actions
need to be taken to ensure protectiveness: ensure all applicable parties sign the ECs and record the
instruments; and develop and submit an ICIAP which describes the plan for ensuring that all
remaining required ICs at the Site are implemented, and for ensuring that all ICs, once implemented,
are monitored and maintained.
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X. OPERABLE UNIT 8: ACME SCRAP IRON AND METALS AND SOUTH SEWERS SOURCE AREA
X.l OPERABLE UNIT 8: INTRODUCTION
OU Summary
The purpose of this FYR is to determine if the remedy selected to address the source area contamination at the
Acme Scrap Iron and Metal and South Sewers OU8 of the Fields Brook Superfund Site is protective of human
health and the environment. The remedy required the excavation of PCB-contaminated soil and the cleaning of
the sewers, with long-term monitoring to ensure that residual PCB-contaminated soil and sediment do not move
into Fields Brook that could lead into an exceedance of the PCB CUG. The scope of the cleanup was limited to
actions necessary to protect Fields Brook from recontamination.
The Acme Scrap Iron and Metal and South Sewers OU8 remedial action included the cleaning of the property's
storm sewers, commonly known as the South Sewers, to remove accumulated sediment that could adversely
impact Fields Brook. The storm sewer from the Acme Scrap Iron and Metal property still empties into Fields Brook
and sediment that accumulated in the discharge pipe was collected with a temporary weir and analyzed for PCBs.
Since not all eroded soils were collected in the storm sewer system, samples were also collected from a drainage
ditch on site. Monitoring commenced in 2001. The monitoring of sediment from stormwater runoff demonstrated
that the risk of recontamination was abated. No additional sediment or surface water monitoring was required by
EPA after 2006.
Background Land and Resource Use
Physical Characteristics
The Acme Scrap portion of OU8 is located in the southwest portion of the industrialized area near Fields Brook
(Fig. 8-1, Appendix F). Structures at the Site include former manufacturing plant buildings, loading and unloading
areas, drum storage areas, and an oil retention lagoon.
The South Sewer portion of OU8 consists of a 36 to 48-inch diameter sewer east of State Road that runs between
the Acme facility and Fields Brook. A 30-inch outfall sewer connects the former oil retention pond on the Acme
property to the catch basin at the corner of the intersection of State and Middle Roads. See bottom half of Fig. 7-
1 in Appendix F.
Land and Resource Use
The site is currently vacant but was previously a scrap recycling facility. The site was owned by the U.S.
Government in the late 1940's and was later sold to National Carbide Corporation. Specific industrial activities by
the U.S. Government and National Carbide are not known. However, the Acme site was operated as a calcium
carbide manufacturing plant from 1943 until 1952. The facility was then vacant until 1974, when Acme purchased
the property and used it as a recycling facility. The property was purchased in December 2001 by Lakeside
Industrial Park & Railyard, Inc. Subsequently, the property was subdivided and ownership of portions of it was
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transferred. Current owners of the original Acme property include: Lakeside Industrial Park & Rail Yard, Inc. State
Road Investments, and Hubert Properties, LLC.
History of Contamination
In the past, Acme dismantled and recycled transformers to recover copper, aluminum, and steel for resale as
scrap metal. On several occasions, the cutting operation used to dismantle the transformers would set the
residual oil on fire. Oil containing PCBs may have been released into the environment from the transformers
during this process. A preliminary assessment of the Acme facility in 1985 identified the chemicals of interest to
include PCBs and several metals, including aluminum, arsenic, copper, iron, lead, mercury and zinc. A chronology
of significant events is included in Appendix D.
X.2. OPERABLE UNIT 8: RESPONSE ACTION SUMMARY
Basis for Taking Action
Evaluations of PCB concentrations of sediment in the storm sewer system at the Acme property and in the
surface soils of the Acme property which exceeded the CRGs led EPA to believe that Acme was a potential source
of recontamination to the Fields Brook sediment. PCBs were identified as the COC for soils and sediments at the
Acme property.
From 1989 through 1997, as part of the RI/FS process for the Source Areas, the Fields Brook PRPs evaluated areas
of potential contamination within the Fields Brook watershed to determine whether they were a source of past
contamination or could cause future recontamination once the Fields Brook cleanup is underway. Groundwater
monitoring wells were installed at the Acme property as part of the Rl; COCs were not found in groundwater at
concentration greater than the soil and sediment CUGs (EPA, 1997). The Acme property was determined as one
of the sources of contamination or potential contamination to Fields Brook. Additional details about RI/FS for the
Source Areas are discussed in Section VI.2 "Basis for Taking Action."
Response Actions
Remedial actions that were required for the Acme Scrap Iron and Metal property and the associated South
Sewers were selected in the 1997 SCOU ROD. Although a RAO was not specified in the 1997 SCOU ROD, the goal
of the selected Source Control OUs remedies is to remediate source areas that have the potential to cause
sediment contamination to Fields Brook and its tributaries, thereby preventing the recontamination of the areas
that will be addressed by the Sediment OU1 and FWA OU4.
For source areas at the Fields Brook Site, ICs are required where hazardous substances, pollutants or
contaminants will remain above levels that are UU/UE and that could re-contaminate the Fields Brook above
cleanup levels, and to help ensure long-term protectiveness of the remedy. The 2009 ESD clarified that as the
intent of the IC objectives in the 1997 SCOU ROD. Specifically, the 2009 ESD stated that ICs were required for the
Acme Scrap Iron and Metal and South Sewers OU8 to prevent recontamination of Fields Brook, limit land use to
industrial use, and to provide EPA access.
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The Source Control action supports the Sediment OU1 and FWA OU4 remediation by helping to ensure that
human-health based CUGs are maintained.
Acme Scrap Iron and Metal: The selected remedy for the Acme property included the excavation of soil with PCB
concentrations greater than or equal to 50 ppm. The 1997 SCOU ROD called for the excavated soil to be either
disposed of at the on-site landfill or at an off-site landfill, whichever was more cost-effective. More specifically,
the selected remedy included the following components:
1. Clear Scrap, Debris and Vegetation / Remove Physical Hazards
In order to implement the remedial action, scrap, debris and vegetation were to be cleared in response
and work areas. Physical hazards (i.e., unstable building sections) that could threaten workers also had to
be addressed prior to implementation of the remedial action.
2. Excavation of Soils with Total PCB Concentrations > 50 ppm
The ROD required excavation of soils with total PCB concentrations greater than or equal to 50 ppm.
Based on existing data, it appeared that limiting excavations to a depth of approximately 1 foot would
remove all TSCA-regulated soil (> 50 ppm PCBs). However, the remedy required removal of all TSCA-
regulated soils, regardless of depth.
Upon excavation, the soil was to be placed in lined roll-off containers or dump trucks for transportation to
either the on-site landfill or to an off-site landfill. Following completion of excavation activities, the
excavated areas were to be backfilled with clean soil and graded to allow for adequate drainage. Any
disturbed areas not receiving an erosion control cover were to be graded and seeded, as necessary.
3. Refinement of Area to Be Covered
The 1997 SCOU ROD required soil calculations to be performed during the RD to further define the extent
of excavation and/or cover necessary to prevent recontamination of Fields Brook. The cover areas were
developed based on current operations at the time and included the proposed excavation area since it
was located within the cover interior.
4. Construction of Cover, Surface Drainage Controls
For the cover areas, the erosion control cover materials will consist of a 12-inch-thick layer of clean soil, an
erosion control blanket and will be vegetated to reduce the potential for erosion. For anticipated future
traffic areas, a 6-inch gravel layer underlain by geotextile will be used instead of the soil.
5. Institutional Controls
Specifically, the 2009 ESD modified the remedies regarding IC requirements and clarified how IC
requirements will be applied to support the 1997 SCOU ROD. The 2009 ESD stated that ICs were required
to prevent recontamination of Fields Brook, limit land use to industrial use, and to provide EPA access.
South Sewers: The South Sewers discharge into Fields Brook and potentially discharged run-off with
contaminated soils and sediment. There was concern that such accumulated material could move into Fields
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Brook and lead to exceedances of sediment and soil CUGs. The 1997 SCOU ROD selected the following remedial
actions to eliminate the risk of recontamination of Fields Brook from the South Sewers:
1. Removal of sediment and debris from inside the sewer lines and the associated catch basin.
2. For any portions of sewers that were blocked and difficult to clean, these sections were to be closed off,
and the sediment within the sewers contained. The sediments in these sewer segments were to be
contained by filling the sewer pipe with cement grout to restrict flow in the sewer and prevent migration
of sediments into Fields Brook.
3. For areas where sewers were to be closed-off, replacement sewers were to be constructed to connect the
remaining sections of the sewers that have been cleaned.
4. Specifically, the 2009 ESD stated that ICs were required to prevent recontamination of Fields Brook, limit
land use to industrial use, and to provide EPA access.
Status of Implementation
EPA issued a UAO (V-W-98-C-451) for the performance of the Acme Scrap and South Sewers RD/RA on December
29, 1997 (EPA, 1997).
Acme Scrap Iron and Metal
The cleanup requirements at the Acme Scrap property were based on erosion of Acme soils through the storm
sewer system to Fields Brook. Therefore, the cleanup standard was determined based on an evaluation of
anticipated erosion from the property. First Energy Corporation and American Electric Power implemented the
RD and RA at the Acme property and South Sewers. Pre-design studies concluded that soils with PCB
contamination equal to or greater than 50 ppm would need to be removed to ensure that erosion would not lead
to an exceedance of the PCB CUG at Fields Brook. Design studies also found that with the removal of soils with 50
ppm or greater PCBs, no cover would be required to ensure erosion would not exceed the cleanup standard at
Fields Brook.
Construction commenced on September 11, 2000 and was completed on September 26, 2000. Approximately
2,085 cubic yards of PCB-contaminated soil was excavated and disposed in the Fields Brook on-site landfill.
Excavation of delineated PCB-contaminated soils occurred east of the former ACME building as seen in Figure 8-1
of Appendix F. The underground stormwater collection system at the excavation area was filled and sealed. EPA
issued a letter on March 17, 2003, approving the completion of the remedial action and the submittal of the
Remedial Action Report (EPA, 2003).
South Sewers
As part of the RD for the South Sewers (which was included as part of the Acme Scrap RD), it was determined that
the sewers could be effectively cleaned. Because of the limited amount of sediment within the sewers, it was
agreed that a follow-up video inspection would not be required. Each length of sewer line was cleaned a
minimum of two times. Approximately 12,000 gallons of wash water was collected and sent to the Fields Brook
water treatment system for treatment prior to discharge to Fields Brook. Collected sediment was transported to
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the Fields Brook landfill for disposal. The cleaning of the sewers was performed in September 2000. EPA issued a
letter on March 17, 2003, approving the completion of the remedial action and accepting the report documenting
the work performed at the Site (EPA, 2003).
Institutional Controls
Table 13: Summary of Planned and/or Implemented ICs for Acme Sera
Media,
engineered
controls, and
areas that do not
support UU/UE
based on current
conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted Parcel(s)
IC
Objective
Title of IC
Instrument
Implemented and
Date (or planned)
Soils
Yes
Yes
As presented in Recorded
Covenant SDMS #357785
(Fig. 8-2, Appendix F).
P.P.Ns: 03-014-00-011-00,
03-014-00-011-03, 03-014-
00-011-04, and 03-014-00-
011-05
Limited to
industrial
use, EPA
provided
unrestricted
access.
Environmental
Covenant pursuant
to UECA, recorded
on March 9, 2010
p Iron and Metal and South Sewers OU8
A map of the parcel with the recorded IC is shown on Figures 8-2 through 8-5 in Appendix F.
Status of Access Restrictions and ICs: An EC pursuant to Ohio's UECA was recorded on March 9, 2010 for the
Lakeside Industrial Park and Railyard, Inc. property (former Acme Scrap property). A copy of the location of the
ICs is included in the Deed. Paragraph 6 of the EC states that "This Environmental Covenant shall be binding upon
the Owner and all assigns and successors in interest, including any Transferee, and shall run with the land,
pursuant to ORC § 5301.85, subject to amendment or termination as set forth herein. The term "Transferee", as
used in this Environmental Covenant, shall mean any future owner of any interest in the Property or any portion
thereof, including, but not limited to, owners of an interest in fee simple, mortgagees, easement holders, and/or
lessees."
A recent review of the Ashtabula County land records in the fall of 2023 showed that the parcel for which the EC
was recorded, which, at the time of the recording, was designated as PPN 03-014-00-011-00 and owned entirely
by Lakeside Industrial Park & Rail Yard, is now divided into four parcels, which are owned as follows: Hubert
Properties LLC owns the parcels identified as permanent parcel number (PPN) 03-014-00-011-03 and 03-014-00-
011-05, State Road Investments owns PPN 03-014-00-011-00, and Lakeside Industrial Park & Rail Yard owns PPN
03-014-00-011-04 (Figs. 8-3 through 8-5, Appendix F).
EPA does not have a record of receiving notice in accordance with Paragraph 11 "Notice of Conveyance" when
these properties were transferred. EPA attempted to contact Lakeside Industrial Park & Rail Yard via letter to
inquire as to whether notice had been provided, utilizing the contact information on file with the Agency.
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However, the letter was returned as undeliverable, and the Agency is now attempting to obtain current contact
information. In addition, at the time of this review, EPA is in the process of contacting Hubert Properties LLC and
State Road Investments to ensure their awareness of the restrictions.
Current Compliance: Based on the FYR Site inspection in August 2023, EPA is not aware of Site or media uses
which are inconsistent with the stated objectives to be achieved by the implemented IC. The cleanup component
of the remedy was met, previous O&M monitoring demonstrated risk of contamination has been abated and no
additional environmental monitoring was required after 2006 . However, the IC requirements for land restriction
still apply. The entry roads leading to the parcel provide a line of sight to areas where the land use restriction is
placed. Visual observations conducted during the August 2023 FYR Site inspection show the property remains as
industrial use. Furthermore, Acme Scrap Iron and Metal and South Sewers OU8 is zoned for industrial use by the
City of Ashtabula. Online parcel searches and satellite imagery of the parcels indicate the landuse remains
industrial.
IC Follow up Actions Needed: An ICIAP is needed and should be developed for Acme Scrap Iron and Metal and
South Sewers OU8. The purpose of the ICIAP is to document additional IC evaluation activities that would be
conducted to ensure that the implemented ICs are effective, and to explore whether additional ICs are needed
and ensure their implementation. The purpose of the ICIAP is also to document and ensure that LTS procedures
are in place so that ICs are properly maintained, monitored, and enforced. Documented IC evaluation activities
will include, as needed, developing updated maps depicting current conditions in areas that do not allow for
UU/UE, reviewing current zoning and city or township ordinances, and reviewing recording and title work for
properties impacted by the Site. An ICIAP should be developed and implemented to include procedures to ensure
LTS such as regular inspection of the engineering controls and access controls at the Site and review of the ICs for
the Site occurs. The plan should also include a requirement for certification to EPA that ICs are in place and
effective. Finally, development of a communications plan and use of the State's one call system shall be explored.
EPA needs to ensure the current owners of parcels to which the recorded EC applies are aware of the EC
requirements. EPA does not have a record of receiving notice in accordance with Paragraph 11 "Notice of
Conveyance" when these properties were transferred. It is also recommended to evaluate the existing ICs and
determine whether additional ICs are needed.
Systems Operations/Operation & Maintenance
Acme Property
From 2001 to 2006, post removal sediment monitoring was required to ensure that Fields Brook was protected
from recontamination from the upland Acme Scrap Iron and Metal and South Sewers OU8. The results of the
sampling demonstrated that residual PCB contamination from the Acme property was not moving off-site at
concentrations that could lead to an exceedance of the PCB CUG in Fields Brook. In February 2007, First Energy
and American Electric Power submitted a letter which demonstrates the sampling requirements specified in the
UAO have been meet and the risk of recontamination from stormwater run-off has been abated (Washington
Group International, 2007). The 2009 FYR further documented that no further sediment sampling was required,
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and no additional OM&M was necessary, other than to assure that ICs remain in place and are effective in
preventing restricted uses (EPA, 2009).
South Sewers
The South Sewers were fully cleaned and remain in use. Because the storm sewer outfall at Fields Brook was one
of the three monitoring points discussed above, the post removal OM&M for the South Sewers was addressed as
part of the overall Acme facility OM&M. Since the storm sewers had been cleaned, the monitoring was used for
evaluating recontamination of the sewers from the Acme property. The results from OM&M demonstrated that
Acme Scrap Iron and Metal and South Sewers OU8 was not causing PCB CUG exceedances in Fields Brook. The
2009 FYR documented that no additional OM&M was necessary, other than to assure that ICs remain in place and
are effective in preventing restricted uses.
X.3 OPERABLE UNIT 8: PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last FYR as well as the
recommendations from the last FYR and the current status of those recommendations.
Protectiveness Determinations/Statements from the 2019 FYR
Table 14: Protectiveness Determinations/Statements from the 2019 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
8
Short-term Protective
The remedy for the Acme Scrap Iron and Metals and South Sewers
Source Area (OU8) currently protects human health and the
environment because it is functioning as designed. Monitoring
demonstrates that the risk of recontamination of the Fields Brook
has been abated. An EC was recorded with Ashtabula County on
March 9, 2010 and will be regularly evaluated for protectiveness in
future FYRs. However, in order for the remedy to be protective in
the long-term, the following actions need to be taken to ensure
protectiveness: conduct a title search to identify parcel owners and
ensure the owners are aware of the EC requirements; and develop
and implement a LTS Plan for monitoring and tracking compliance
with existing ICs, communicating with EPA, and providing an annual
certification to EPA that the ICs remain in place and are effective.
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Status of Recommendations from the 2019 FYR
Table 15: Status of Recommendations from the 2019 FYR
ou#
Issue
Recommendations
Current
Status
Current Implementation Status
Description*
Completion
Date (if
applicable)
8
Procedures are not
in place to ensure
LTS of ICs at the
Site.
Develop and
implement a LTS
Plan for monitoring
and tracking
compliance with
existing ICs,
communicating
with EPA, and
providing an
annual certification
to EPA that the ICs
remain in place and
are effective.
Considered
But Not
Implemented
LTS procedures will be included
in the ICIAP; a separate LTS Plan
is not needed. A new issue and
recommendation to develop an
ICIAP that also includes those
LTS procedures has been
included as part of this current
FYR.
NA
8
A recent review of
the parcel
information shows
that Lakeside
Industrial Park &
Rail Yard, Inc.
property (the
property with the
recorded EC) has
been subdivided
into three parcels.
EPA was not
notified in
accordance with
the EC's Paragraph
11, "Notice of
Conveyance"
when these
properties were
transferred.
Conduct a title
search to identify
parcel owners and
ensure the owners
are aware of the EC
requirements.
Addressed in
the Next FYR
The title search was completed
and the current owners of the
ACME parcel have been
identified. A new
issue/recommendation for this
FYR is included to contact the
current owners and notify them
of the EC requirements.
N/A
X.4 OPERABLE UNIT 8: FYR PROCESS
75
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Data Review
As discussed previously, environmental monitoring has not been required since 2006 and there was no data to
review for this FYR period.
Site Inspection
EPA attempted to contact representatives of Lakeside Industrial Park & Rail Yard, Inc. and the listed owners on
the title, however, was unable to reach any representatives prior to the August 2023 FYR Site visit. EPA drove to
the property entrance road on August 22, 2023 to see if a contact was on-site but did not observe anyone on the
property. EPA was unable to conduct a site inspection but was able to observe the Site and evaluated compliance
with the ICs from the Acme property from two locations on State Road.
1. Based on observations from the driveways which provided lines of sight to parcels where industrial land
use restrictions are placed, the property remains as an industrial property and scrap yard and meets IC
requirements.
Many of the buildings were in poor condition and the roof had collapsed on parts of the building. The Ashtabula
County has been involved in addressing the building issue. Due to the integrity of the buildings on-site, EPA did
not walk around. A checklist was not completed for this inspection, however general observations are included in
the Photolog (Appendix C).
After the FYR site inspection on August 22, 2023, EPA conducted an online search of the Ashtabula County GIS
records and confirmed the parcels within Acme Scrap Iron and Metal and South Sewers OU8 are categorized for
industrial use. Online satellite imagery of the parcels show land use remains industrial.
X.5 OPERABLE UNIT 8: TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
Yes. Previous monitoring data collected confirms that the soils eroding from the Acme property (through the
storm sewer system to the outfall at Fields Brook and in the drainage ditch at the northwest corner of the
property) would not cause an exceedance of the PCB CUG in Fields Brook. An EC was recorded for the Lakeside
Industrial Park & Railyard, Inc. property (former Acme Scrap property) in 2010; visual observations during the Site
inspection from two adjacent public roads, as well a review of the zoning ordinance and deed records show the
EC was being complied with regarding the property remaining (i) classified as and (ii) used for industrial use only.
However, EPA did not receive notice in accordance with Paragraph 11 "Notice of Conveyance" when portions of
the property were transferred. At the time of this FYR, EPA is in the process of obtaining current contact
information for Lakeside Industrial Park & Rail Yard, Inc. and contacting State Road Investments, Inc. and Hubert
Properties LLC to ensure they are aware of the EC requirements. To ensure long-term protection for the Acme
Scrap Iron and Metal and South Sewers OU8, confirmation of the current property owners' awareness of the EC
requirements is needed. Also, an ICIAP should be developed for Acme OU8 to have procedures documented for
76
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ensuring that the implemented ICs are and continue to be effective, to explore whether additional ICs are needed
and ensure their implementation, and to ensure that LTS procedures are in place so that ICs are properly
maintained, monitored, and enforced.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the
remedy selection still valid?
Yes. There has been no change to the PCB cleanup requirement for Fields Brook. The RAOs for the Acme Scrap
Iron and Metals and South Sewers Source Area are still valid.
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy?
No. There are no observed impacts or effects from natural disasters which may affect the protectiveness of the
remedy.
X.6 OPERABLE UNIT 8: ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
OU(s): 8
Issue Category: Institutional Controls
Issue: An ICIAP is needed to ensure that effective ICs are implemented,
monitored, and maintained.
Recommendation: Develop and submit an ICIAP which describes the plan
for ensuring that all remaining required ICs at the Site are implemented,
and for ensuring that all ICs, once implemented, are monitored and
maintained.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
6/25/2028
OU(s): 8
Issue Category: Institutional Controls
Issue: At the time the EC was recorded, the parcel was owned entirely by
Lakeside Industrial Park & Rail Yard. In the Spring of 2024, the EPA learned
the original parcel, was subdivided into four parcels, two of which are
77
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owned by Hubert Properties LLC, one of which is owned by State Road
Investments, and one of which continues to be owned by Lakeside
Industrial Park & Rail Yard. It is not clear whether Hubert Properties LLC
and State Road Investments received notice of the EC requirements when
they acquired ownership.
Recommendation: Contact the current parcel owners and ensure the
owners are aware of the EC requirements.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
12/31/2024
X.7 OPERABLE UNIT 8: PROTECTIVENESS STATEMENT
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination:
OU8 Short-term Protective
Protectiveness Statement:
The remedy for the Acme Scrap Iron and Metals and South Sewers 0U8 currently protects human
health and the environment. Cleanup at Acme included excavation of soils with PCB concentrations
equal to or greater than 50 ppm and the cleanout of the South Sewers. The cleanup remedy is
functioning as designed by preventing recontamination of Fields Brook sediment. Monitoring at Acme
Scrap Iron and Metals and South Sewers OU8 demonstrates that the risk of recontamination of the
Fields Brook has been abated. An EC was recorded with Ashtabula County on March 9, 2010 and will
be regularly evaluated for protectiveness in future FYRs to ensure land use remains industrial. Based
on the FYR August 2023 Site inspection and subsequent online research of the Acme parcels, it
appears that land use remains industrial. However, in order for the remedy to be protective in the
long-term, the following actions need to be taken to ensure protectiveness: contact the current
parcel owners and ensure the owners are aware of the EC requirements; and develop and submit an
ICIAP which describes the plan for ensuring that all remaining required ICs at the Site are
implemented, and for ensuring that all ICs, once implemented, are monitored and maintained.
78
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APPENDIX A
REFERENCES
79
-------
Date
Title of Document
SDMS
Document Review for Fields Brooks Sitewide
6/7/2004
First Five-Year Review
218688
6/2/2009
Second Five-Year Review
330312
4/8/1999
Site-Wide Explanation of Significant Differences
95179
5/23/2014
Third Five-Year Review
461766
6/25/2019
Fourth Five-Year Review
948754
Data Review for Fields Brooks Sediment and Floodplain Soils (OU1& OU4)
2/10/2010
Final Project Construction Completion Report, Fields Brook Relocation & EU8
Floodplain Restoration, de maximis, inc.
939489
5/12/2010
Additional Information for EU8 Completion Report
365838
7/11/2012
Remediation Construction Completion Report for 2009-2011 DNAPL in DS
Tributary
910594
12/5/2013
Work Plan Approval of Excavation of Soils and Sediment Work Plan
911069
9/10/2014
Relocation & Floodplain Restoration Final Completion Report/Construction
Completion Report
559854/
939428
5/28/2015
EPA Response Letter to Discussion Points and ITRC Sampling
939442
6/27/2018
Quality Assurance Project Plan, Fields Brook Superfund Site Revision 4
941824
6/21/2019
Site Monitoring Report Groundwater Sampling Performed April 2019
986858
4/22/2020
Soil, Sediment, and Surface Water Sampling, Performed Aug 2019
986859
10/2020
Site Monitoring Report Groundwater Sampling Performed May 2020
961101
11/2020
Soil, Sediment, and Surface Water Sampling, Performed Aug 2020
986860
7/2021
Revised Draft Post-Closure Operations, Maintenance, and Monitoring
(OM&M) Plan for Oul & OU4, dated July, 2021
DRAFT
NOT IN
SDMS
3/2022
Site Monitoring Report Groundwater Sampling Performed May 2021
986861
5/2022
Soil, Sediment, and Surface Water Sampling, Performed Aug 2021
986862
1/2023
Site Monitoring Report Groundwater Sampling Performed April 2022
982786
5/5/2023
Monthly Report Operation & Maintenance Fields Brook Superfund Site, April
2023
982791
5/24/2023
De maximis Email RE: August 2022 Site Monitoring Report Rescheduling
986863
8/30/2023
OEPA Sediment Re-Sampling Event Photograph Log, Fields Brook Superfund
Site
986864
Document Review for Fields Brooks Sediment and Floodplain Soils OU1 and OU4
3/28/1985
Final Remedial Investigation Report
142669
7/3/1986
Fields Brook Site Sediment Operable Unit Feasibility Study
91200
80
-------
9/30/1986
Record of Decision for the Sediment Operable Unit
91201
Feasibility Study for Floodplain/Wetlands Area Fields Brook Site Ashtabula,
10/17/1986
Ohio
93401
Fields Brook Sediment Operable Unit Focused Ecological Risk Assessment
2/1/1997
Ashtabula, Ohio
91692
5/30/1997
Final Source Control Remedial Investigation Report
91855
Phase 1 Feasibility Study Detailed Analysis of Alternative (Revision 3) Source
6/12/1997
Control Operable Unit RI/FS
91849
6/30/1997
Record of Decision for the Floodplain/Wetland Operable Unit
119128
8/15/1997
ESD for the Sediment Operable Unit
91698
Record of Decision for the Source Control Operable Unit of the Fields Brook
9/29/1997
Superfund Site
91944
Unilateral Administrative Order for the performance of the RD/RA for the
Sediment and Floodplain /Wetland Operable Units (OU1/OU4) (V-W-98-C-
12/17/1997
449)
499254
Explanation of Significant Differences Sediment Operable Unit Fields Brook
4/7/1999
Site, Ashtabula Ohio
91696
Consent Decree entered for Performance of Remedial Design and Remedial
7/7/1999
Action for OU1 / OU4 (Case No. 5:89CV1866)
141408
8/1/2000
Final Remedial Action Work Plan
257606
8/17/2001
ESD to address DNAPL-lmpacted Soils and Sediment
150306
Post-Closure Operations, Maintenance and Monitoring (OM&M) Plan for the
5/4/2004
Sediment and Floodplain/Wetland Operable Units, de maximis, inc.,
946428
10/18/2007
Unilateral Administrative Order issued to Millennium
281598
2/2/2009
EU8 Focused Feasibility Study Fields Brook Superfund Site Ashtabula, Ohio
911060
7/10/2009
Modification to CD
939490
10/6/2009
Environmental Covenant, Detrex Property
353273
7/27/2010
Environmental Covenant, Fields Brook Landfill
384258
2/10/2012
Environmental Covenant, Millennium Property
421768
Detrex (OU5) Document Review
3/22/1989
Administrative Order RI/FS (V-W-89-C-008)
135939
Record of Decision for the Source Control Operable Unit of the Fields Brook
9/29/1997
Superfund Site,
91944
Unilateral Administrative Order for the performance of the Detrex
12/24/1997
Corporation RD/RA (V-W-98-C-450)
143973
Amendment to Unilateral Administrative Order for the performance of the
2/17/1998
Detrex Corporation RD/RA (V-W-98-C-450)
496533
7/10/2009
Modification to CD
939490
10/6/2009
Environmental Covenant
353273
1/15/2014
ESD for Fields Brook Superfund Site, Detrex Corp. Source Area (OU5)
461558
81
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Detrex (0U5) Technical Report and Data Review
7/21/1986
104(e) Response - Detrex Chemical Industries Inc.
90969
Detrex Corporation, Ashtabula Ohio Plant, Collection & Treatment
986973
8/1989
Improvements, Burgess & Niple, Limited
12/9/2008
DNAPL Memo
467845
8/9/2011
Letter Report, DS Tributary Monitoring Results, Gradient Corp., .
911000
Report for Additional Excavation of DS Tributary & State Rd Culvert
7/11/2012
Restoration
910594
4/8/2014
Draft DNAPL Recovery Point Installation Work Plan
559849
5/1/2014
EPA Approval of Draft DNAPL Recovery Point Installation Work Plan
939429
6/5/2017
Final Passive DNAPL Collection System Completion Report
934353
6/22/2017
EPA Approval Letter Final Passive DNAPL Collection System Completion Report
934352
1/22/2018
Request for ESD DNAPL Monitoring Modification
942657
3/21/2018
EPA approved DNAPL Monitoring Frequency Schedule
942658
Draft Operations, Maintenance, and Monitoring (OM&M) Plan for the Detrex
DRAFTN
Source Control Area on November 29, 2017 and a revised version on October
OTIN
10/29/2018
29, 2018
SDMS
Recovery Point Cleanout, Annual Perimeter Passive Recovery Point
Monitoring, and Monitoring Well and Groundwater Collection System
986888
7/3/2019
Sampling
Annual Perimeter Passive Recovery Point Monitoring, and Monitoring Well
8/20/2020
and Groundwater Collection System Sampling
986889
U.S. EPA Review of the Request for ESD DNAPL Monitoring Modification,
Detrex Source Control Area - Fields Brook Superfund Site, Detrex
10/1/2020
Corporation, Ashtabula, Ohio dated September 18, 2020
961102
Recovery Point Clean Out, Annual Perimeter Recovery Point Monitoring, and
986890
7/19/2021
Monitoring Well and Groundwater Collection System Sampling
Semi-Annual Monitoring Well and Groundwater Collection System Sampling
12/17/2021
and Recovery Point Repair
984469
Monthly Technical Status Reports for Detrex Source Area (January 2019 to
2019-2023
October 2023)
986972
Detrex Facility Northwest Lawn Pooled Water - CWM Environmental, LLC.
986892
4/1/2022
Analytical Report
4/28/2022
OH EPA EMAIL RE: FW: DETREX - 3IF00017 - TANK T-004 OVERFLOW
988368
DRAFT
NOT IN
8/3/2022
Detrex Management of T004 Water Level
SDMS
Annual Perimeter Recovery Point Monitoring, and Monitoring Well and
8/19/2022
Groundwater Collection System Sampling
981202
8/30/2022
Subject: 8/30/22 CWA / CERCLA Remedy at Detrex Facility
986893
82
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9/28/2022
Italmatch Email Re: Detrex - 24 Hour Bypass
980222
10/3/2022
OH EPA EMAIL RE: Detrex - Overflow On 9-30-22
980223
10/14/2022
OH EPA MEMO RE: Ohio Environmental Protection Agency NDPES Inspection
980225
Request for Additional Information Regarding the Detrex Water Treatment
11/21/2022
System and CERCLA Remedy
981208
Detrex Letter RE: Response to Request for Additional Information Regarding
1/25/2023
the Detrex Water Treatment System and CERCLA Remedy
981209
Monitoring Well Pad Repair and Semi-Annual Monitoring Well and
2/17/2023
Groundwater Collection System Sampling
981205
6/15/2023
Ohio Environmental Protection Agency NPDES Inspection
986894
7/12/2023
Detrex Facility Wet Weather Daily Inspections (July 2023 to August 2023)
986895
Evaluation of the Water Collection and Treatment System at Source Area
7/12/2023
Operable Unit 5, Detrex Corporation
983979
7/26/2023
Detrex Corporation Storm Sewer TV Inspection Camera Survey
984484
Progress Update: Evaluation of the Water Collection and Treatment System at
8/3/2023
Source Area Operable Unit 5, Detrex Corporation
984005
8/3/2023
Detrex Facility Outfall 003 Monitoring Plan
984006
Annual Perimeter Recovery Point Monitoring, and Monitoring Well and
8/18/2023
Groundwater Collection System Sampling
986896
DRAFT
NOT IN
10/13/2023
Detrex Facility Tank 004 Overflow Plan
SDMS
US EPA Letter Re: US EPA Review of the Request for ESD DNAPL Monitoring
Modification, Detrex Source Control Area - Fields Brook Superfund Site,
11/7/2023
Detrex Corporation, Ashtabula Ohio Dated September 1, 2023
986518
Millennium (OU6) Document Review
Record of Decision for the Source Control Operable Unit of the Fields Brook
9/29/1997
Superfund Site,
91944
EPA issued a Unilateral Administrative Order for the performance of the
12/24/1997
Millennium RD/RA (V-W-98-C-449)
143970
2/11/1998
EPA Letter with UAO Modification (2/18/1998?)
242253
Letter: U.S. EPA Conditions For Use Of The Millennium Industrial Waste
Landfill for Disposal Of PCB-Contaminated Soils From The
4/8/1998
Millennium Source Control Area
142398
Approval Letter to Waste Stream Modification, Millennium Ashtabula Plant II
Landfill, Letter from Kimberly Reese, Solid & Infectious Waste Division, Ohio
6/16/1999
EPA
142405
7/7/1999
EPA Memo-Approval of RD and RA Workplan
142204
EPA issued a Unilateral Administrative Order for the performance of the
12/24/1999
Millennium RD/RA (V-W-98-C-449)
143970
83
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5/1/2000
Millennium Remedial Action Report
942676
6/28/2000
EPA Approval of RA Report-Millennium OU
239727
10/18/2007
Unilateral Administrative Order issued to Millennium No. V-W-08-C-883
281598
7/10/2009
Modification to 1999 CD Statement of Work
939490
9/23/2009
Explanation of Significant Difference (OU6, OU8, OU9)
352346
11/1/2009
Final Report, Millennium Inorganic Chemicals TiCI4 Facility, Ashtabula, Ohio,
Administrative Order V-W-08-C-883
397675
2/10/2010
Completion Report
939489
5/18/2010
EPA Closes out UAO No. V-W-08-C-883
365852
11/16/2011
Cristal Letter Regarding Landfill Leachate Analysis
559859
2/10/2011
Environmental Covenant, Millennium Property
421768
8/29/2013
Excavation of Soils and Sediments Work Plan, de maximis, inc.
911070
3/7/2014
Cristal Ashtabula Landfill Sampling Report
939430
12/10/2015
Cristal requested to discontinue PCB monitoring at the Cristal Ashtabula Landfill
559862
12/22/2015
EPA Approved Request to Discontinue Sampling at the Cristal Ashtabula
Landfill
939458
2019-2023
Ineos Quarterly Wastewater Sampling and Analysis of Plant 2 North
Interceptors (March 2019 to June 2023)
986865
North Sewer (OU7) Document Review
9/29/1997
Record of Decision for the Source Control Operable Unit of the Fields Brook
Superfund Site
91944
12/24/1997
EPA issued a Unilateral Administrative Order for the performance of the
North Sewers RD/RA (V-W-98-C-446)
143972
2/18/1998
Amendment-EPA issued a Unilateral Administrative Order for the
performance of the North Sewers RD/RA (V-W-98-C-446)
239910
1/11/2000
Final 100% design of North Sewer Source Area
142673
10/3/2000
Remedial Action workplan, North Sewer Source Area
142630
1/31/2001
Remedial Action Report, North Sewer Source Area
496564
3/27/2001
EPA letter with approval of Remedial Action and no monitoring required
239815
11/30/2004
Letter sent to EPA for Recorded Institutional Controls Recorded with
Ashtabula County on October 25, 2004
504699
1/15/2014
ESD for Fields Brook Superfund Site, Detrex Corp. Source Area (OU5)
461558
12/23/2020
Environmental Covenant, INEOS Pigments USA Inc. (f/k/a Cristal USA, Inc.)
986874
12/29/2020
Environmental Covenant, Gabriel Performance Products, LLC
986875
1/27/2021
Environmental Covenant, Ashtabula City Port Authority (NOT RECORDED)
NOT IN
SDMS
12/15/2021
Letter Regarding Dominion Energy Group's Proposed Pipeline Project at the
Fields Brook Superfund National Priorities List Site, Ashtabula Ohio
986866
Acme Scrap Iron (OU8) Document Review
84
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Record of Decision for the Source Control Operable Unit of the Fields Brook
9/29/1997
Superfund Site,
91944
12/29/1997
Unilateral Administrative Order (V-W-98-C-451)
143976
2/18/1998
Amendment to Unilateral Administrative Order (V-W-98-C-451)
496534
2/20/1998
Memo on UAO Amendment
240023
7/1/1998
Remedial Design Work Plan-Map with PCBs (PCB Sampling Locations)
142642
12/28/2000
Remedial Action Construction Quality Assurance Report
323730
2/13/2001
Completion of Remedial Action Report
504544
2/20/2001
Operations, Maintenance, and Monitoring Plan
504680
3/17/2003
Unilateral Administrative Order (V-W-98-C-451) Close out letter
239758
9/1/2006
Results of Post-Remedial Action OM&M Sampling
323737
2/1/2007
Acme Post Remedial Action O&M Sampling
361496
9/23/2009
ESD (OU6, OU8, OU9)
352346
3/9/2010
Environmental Covenant, Acme Property
357785
85
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APPENDIX B
SITE INSPECTIONS CHCECKLISTS
86
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Appendix B: Section 1
Fields Brook Sediment (OU1) & Floodplains/Wetlands (OU4) Site Inspection Checklist
1. SITE INFORMATION
Site name:
Fields Brook NPL Site-Sediment (OU1) and
Date of inspection:
8/22/2023
Floodplains/Wetland Area (OU4)
Location and Region:
EPA ID:
Ashtabula, OH
OHD980614572
Agency, office, or company leading the FYR:
U.S. EPA
Weather/temperature:
High of 78°F, 40% chance of rain, partly cloudy in
the afternoon
Remedy Includes: (Check all that apply)
IS Landfill cover/containment
~ Monitored natural attenuation
IS Access controls
IS Groundwater containment (landfill leachate)
IS Institutional controls
~ Vertical barrier walls
~ Groundwater pump and treatment
~ Other: Click or tap here to enter text.
IS Surface water collection and treatment
Attachments:
~ Inspection team roster:
IS Site map attached (see Figures 1-1 to 1-7)
Nick Roope, Ohio EPA
Bob Rule, de maximis, inc.,
Anna Nguyen, U.S. EPA
Jenny Polster, U.S. EPA
Amy Gahala, U.S. EPA
1
87
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Appendix B: Section 1
Fields Brook Sediment (OU1) & Floodplains/Wetlands (OU4) Site Inspection Checklist
I. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1. O&M Documents
IS O&M manual
IS As-built drawings
IS Maintenance logs
Readily available
Readily available
Readily available
~ Up to date
~ Up to date
~ Up to date
~ N/A
~ N/A
~ N/A
Remarks: OM&M activities and figures are provided to EPA in monthly reports. Logs are available
in the warehouse adjacent to the landfill.
2. Groundwater Monitoring Results
Remarks: This information is provided to EPA in monthly reports
Readily available
3. Leachate Extraction Records
IS Readily available ~ Up to date
Remarks: This information is provided to EPA in monthly reports.
~ N/A
4. Daily Access/Security Logs
IS Readily available
Remarks: Click or tap here to enter text.
~ Up to date
~ N/A
IV. O&M COSTS
1. O&M Organization
~ State in-house
~ PRP in-house
~ Federal Facility in-house
Remarks:
~ Contractor for State
IS Contractor for PRP
~ Contractor for Federal Facility
V. ACCESS AND INSTITUTIONAL CONTROLS
IS Applicable
~ N/A
1.
Fencing Damaged ~ Location shown on site map
Remarks: Click or tap here to enter text.
IS Gates secured
~
N/A
2.
Other Access Restrictions IS Location shown on site map
Remarks: See Figure 1-1 of FYR Report
~ Gates secured
3.
Institutional Controls (ICs)
88
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Appendix B: Section 1
Fields Brook Sediment (OU1) & Floodplains/Wetlands (OU4) Site Inspection Checklist
A. Implementation and Enforcement
Site conditions imply ICs not properly implemented
~ Yes IS No ~ N/A
Site conditions imply ICs not being fully enforced
~ Yes IS No ~ N/A
Type of monitoring (e.g., self-reporting, drive by)
Self-monitoring
Frequency
Click or tap here to enter text.
Responsible party/agency
FBAG
Contact: Robert Rule, Title , 8/22/2023, P: Phone Number
Reporting is up-to-date
IS Yes ~ No ~ N/A
Reports are verified by the lead agency
IS Yes ~ No ~ N/A
Specific requirements in deed or decision documents have
been met
IS Yes ~ No ~ N/A
Violations have been reported
~ Yes ~ No IS N/A
Other problems or suggestions:
Click or tap here to enter text.
B. Adequacy IS ICs are adequate ~ ICs are inadequate ~ N/A
Remarks: Required ICs are appropriate, however an ICIAP And LTS is recommended (see FYR).
4. General
A. Vandalism/Trespassing ~ Location shown on site map
~ No vandalism evident
Remarks: In April 2023, trespasser(s) stole approximately 1,200 years of barbed wire from the
top of the west boundary fence along State Road and east boundary fence along the railroad
yard. A police report was submitted on April 28, 2023.
B. Land use changes on site |x| N/A
Remarks: Click or tap here to enter text.
C. Land use changes off site |x| N/A
Remarks: Click or tap here to enter text.
VI. GENERAL SITE CONDITIONS
1. Roads ~ Applicable
IS N/A
A. Roads damaged ~ Location shown on site map
~ Roads adequate IS N/A
Remarks: Click or tap here to enter text.
B. Other Site Conditions
Remarks: Click or tap here to enter text.
89
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Appendix B: Section 1
Fields Brook Sediment (OU1) & Floodplains/Wetlands (OU4) Site Inspection Checklist
VII. LANDFILL COVERS
1. Landfill Surface IS Applicable ~ N/A
A. Settlement (Low
~ Location Shown on Site Map IS Settlement Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter text,
Remarks: Click or tap here to enter text.
B. Cracks ~ Location Shown on Site Map IS Cracking Not Evident
Lengths: Click or tap , , Depths: Click or tap here to
Widths: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
C. Erosion ~ Location Shown on Site Map IS Erosion Not Evident
Areal Extent: Click or tap here to enter text. Depth: Click or tap here to enter
Remarks: Click or tap here to enter text.
D. Holes ~ Location Shown on Site Map IS Holes Not Evident
Areal Extent: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
E. Vegetative Cover IS Grass
~ Cover Properly
Established
~ Tress/Shrubs (indicate size and locations on a diagram IS No Signs of Stress
Remarks: Click or tap here to enter text.
F. Alternative Cover (armored rock, concrete, etc.) IS N/A
Remarks: Click or tap here to enter text.
G. Bulges ~ Location Shown on Site Map IS Bulges Not Evident
Areal Extent: Click or tap here to enter text. Height: Click or tap here to enter text.
Remarks: Click or tap here to enter text.
H. Wet Areas/Water Damage IS Wet Areas/Water Damage Not Evident
„ i-i . .. r, .. Areal Extent: Click or tap here to enter
~ Wet Areas LJ Location Shown on Site Map r
text.
,, c.. Areal Extent: Click or tap here to enter
~ Ponding L-l Location Shown on Site Map r
text.
,—, , Areal Extent: Click or tap here to enter
~ Seeps LJ Location Shown on Site Map
90
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Appendix B: Section 1
Fields Brook Sediment (OU1) & Floodplains/Wetlands (OU4) Site Inspection Checklist
~ Soft [-] |_ocat:jon Shown on Site Map Areal Extent: Click or tap here to enter
Subgrade text.
Remarks: Click or tap here to enter text.
1. Slope
Instability ^ '-ocat'on Shown on Site Map IS Slope Instability Not Evident
~ Slides
Areal Extent: Clickortap here to enter
text.
Remarks: Click or tap here to enter text.
2.
Benches ~ Applicable
IS N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the
slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a
lined channel.)
3.
Letdown Channels ~ Applicable
IS N/A
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the
steep side slope of the cover and will allow the runoff water collected by the benches to move off
of the landfill cover without creating erosion gullies.)
4.
Cover Penetrations IS Applicable
~ N/A
A. Gas Vents ~ Active
IS Passive
IS Properly secured/locked
IS Functioning IS Routinely sampled
IS Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
~ N/A
Remarks: Click or tap here to enter text.
B. Gas Monitoring Probes
~ Properly secured/locked
~ Functioning ~ Routinely sampled
~ Good condition
~ Evidence of leakage at penetration
~ Needs Maintenance
IS N/A
Remarks: Click or tap here to enter text.
C. Monitoring Wells
IS Properly secured/locked
IS Functioning IS Routinely sampled
IS Good condition
~ Evidence of leakage at penetration
IS Needs Maintenance
~ N/A
Remarks: MW FB05 at the landfill demonstrated evidence of frost heave; remaining wells at
the landfill appear in good condition.
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Appendix B: Section 1
Fields Brook Sediment (OU1) & Floodplains/Wetlands (OU4) Site Inspection Checklist
D. Leachate Extraction Wells
IS Properly secured/lockec IS Functioning IS Routinely sampled
IS Good condition ~ Evidence of leakage at penetration
~ Needs Maintenance ~ N/A
Remarks: Currently, no evidence of leakage, however the volume of leachate in the leachate
detection system exceeds the volume in the leachate collection system.
E. Settlement Monuments ~ Located ~ Routinely Surveyed IS N/A
Remarks: Click or tap here to enter text.
5. Gas Collection and Treatment ~ Applicable IS N/A
6. Cover Drainage Layer ~ Applicable IS N/A
7. Detention/Sediment Ponds ~ Applicable IS N/A
8. Retaining Walls
~ Applicable
IS N/A
9. Perimeter Ditches/Off-Site
Discharge
~ Applicable
IS N/A
IX. OVERALL OBSERVATIONS
1. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as
designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain
contaminant plume, minimize infiltration and gas emission, etc.).
1. Photos of the site inspection are presented in Appendix C (Photos 1 - 21), with observations
noted in the captions.
2. The inspection was targeted to those elements of the Brook and source area remedies that
were pertinent to completing the FYR.
3. ICs and access controls were observed. No inconsistencies were noted with the CERCLA
decision documents or ECs that are recorded for the site.
4. No on-site OM&M documents, costs or site records were reviewed during the inspection. This
information is regularly provided to EPA in monthly reports and reviewed at the office.
5. Landfill cover appears to be well maintained.
6. MW FB05 demonstrated signs of frost heave.
Enginered elements of the remedies, e.g. EU8 Brook realignment structure, groundwater and
DNAPL interceptor trenches, monitoring wells, are generally functioning as currently required.
2. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures.
In particular, discuss their relationship to the current and long-term protectiveness of the remedy.
92
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Appendix B: Section 1
Fields Brook Sediment (OU1) & Floodplains/Wetlands (OU4) Site Inspection Checklist
Sample collection scope and methodology, such as the use of the preferred composite sampling
method and comparison to CUGs, as discussed in this FYR, will be resolved in upcoming revisions
to OM&M plans.
93
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Appendix B: Section 2
Detrex Corporation (OU5) Site Inspection Checklist
1. SITE INFORMATION
Site name:
Date of inspection:
Detrex Corporation (OU5)
8/23/2023
Location and Region:
1100 State Road
Ashtabula, OH 44004
EPA ID:
OHD980614572
Agency, office, or company leading the FYR:
Weather/temperature:
U.S. EPA
High of 68°F, cloudy, rain in the afternoon
Remedy Includes: (Check all that apply)
~ Landfill cover/containment
~ Monitored natural attenuation
IS Access controls
IS DNAPL Groundwater containment
IS Institutional controls
IS Vertical barrier walls
IS Groundwater pump and treatment
~ Other: Click or tap here to enter text.
IS Surface water collection and treatment
Attachments:
IS Inspection team roster:
IS Site map attached (See FYR Figure 5-2)
Nick Roope, Ohio EPA
Anna Nguyen, U.S. EPA
Jenny Polster, U.S. EPA
AmyGahala, U.S. EPA
Tom Edmunds, Detrex Corporation
Patrick Krott, Detrex Corporation
Marty Schmidt, EHS Support
94
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Appendix B: Section 2
Detrex Corporation (OU5) Site Inspection Checklist
II. INTERVIEWS (Check all that apply)
1. O&M Site Manager
Dptrex
Patrick Krott, „ 8/23/2023
Corporation
Interviewed: |x| at site
~ at office ~ by phone Phone Number: Click here to enter text.
Problems, suggestions:
~ Report attached
Interview answers in checklist
2. Consultant
Marty Schmidt, EHS Support 8/23/2023
1 Consultant
Interviewed: |x| at site
~ at office ~ by phone Phone Number: Click here to enter text.
Problems, suggestions:
~ Report attached
Interview answers in checklist
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1.
O&M Documents
~ O&M manual ~ Readily available
~ Up to date
IS N/A
IS As-built drawings IS Readily available
~ Up to date
~ N/A
~ Maintenance logs ~ Readily available
~ Up to date
IS N/A
Remarks: O&M Plan was in draft form at the time of the Site Visit
2.
Site-Specific Health and Safety Plan
IS Readily available
~ Contingency Plan/Emergency Response Plan
~ Readily available
Remarks: Click or tap here to enter text.
3.
O&M and OSHA Training Records
~ Readily available
IS Up to date
~ N/A
Remarks: Click or tap here to enter text.
4.
Groundwater Monitoring Records
IS Readily available
~ Up to date
~ N/A
Remarks: Groundwater monitoring records are up to date and submitted to EPA regularly.
5.
Discharge Compliance Records
~ Air ~ Readily available
~ Up to date
~ N/A
ISWater (effluent) IS Readily available
~ Up to date
~ N/A
Remarks: Discharge records are submitted to EPA monthly.
6.
Daily Access/Security Logs
95
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Appendix B: Section 2
Detrex Corporation (OU5) Site Inspection Checklist
Readily available
~ Up to date
~ N/A
Remarks:
Oi
enter text.
IV. O&M COSTS
1. O&M Organization
~ State in-house
IS PRP in-house
~ Federal Facility in-house
Remarks: Click or tap here to enter text.
~ Contractor for State
~ Contractor for PRP
~ Contractor for Federal Facility
2. O&M Cost Records
ISReadily available ~ Up to date ~ Funding mechanism/agreement in place
Original O&M cost estimate The O&M staff at Detrex is full time to
keep track of wells. The gaging and DNAPL extraction records are
submitted to EPA in monthly reports. DNAPL is sent offsite to Ross
Incinerator in Grafton, IN or Akron, OH.
~ Breakdown attached
V. ACCESS AND INSTITUTIONAL CONTROLS
Applicable
~ N/A
1. Fencing Damaged ~ Location shown on site map
Remarks: Click or tap here to enter text.
Gates secured ~ N/A
2. Other Access Restrictions ~ Location shown on site map
Remarks: Click or tap here to enter text.
Gates secured
3. Institutional Controls (ICs)
A. Implementation and Enforcement
Site conditions imply ICs not properly implement sd
Site conditions imply ICs not being fully enforced
~ Yes
~ Yes
IS No
~ No
~ N/A
IS N/A
B. Adequacy IS ICs are adequate
Remarks: Click or tap here to enter text.
~ ICsare inadequate
~ N/A
4. General
A. Vandalism/Trespassing ~ Location shown on site map
Remarks: Click or tap here to enter text.
No vandalism evident
B. Land use changes on site
IS N/A
96
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Appendix B: Section 2
Detrex Corporation (OU5) Site Inspection Checklist
Remarks:
C. Land use changes off site
IS N/A
Remarks:
VI. VERTICAL BARRIER WALLS
IS Applicable
~ N/A
1.
Settlement IS Location Shown on Site Map IS Settlement Not Evident
Areal Extent: 600'long along the northwest corner of the
r ... Depth: L ick or ter text,
facility. K K
Remarks: Click or tap here to enter text.
2.
Type of Monitoring: Groundwater sampling and groundwater
Performance Monitoring measurements collected at certain points of the slurry wall semi-
annually.
~ Performance Not Monitored
~ Evidence of Breaching
Frequency: Semi-annual
Head Differential: Click or re to enter text.
Remarks: Limited performance monitoring conducted at the slurry wall; piezometers are not installed
inside and outside the slurry wall. Monitoring wells installed inside and outside of the slurry wall at the
far northeast end in the adjacent RMI property.
VII. DNAPL COLLECTION & GROUNDWATER/SURFACE WATER REMEDIES
IS Applicable
~ N/A
1.
Groundwater Extraction Wells, Pumps, and Pipelines IS Applicable ~ N/A
A. Pumps, Wellhead Plumbing, and Electrical
~ N/A
IS Good Condition ~ All Required Wells Properly Operating ~ Needs Maintenance
Remarks: Click or tap here to enter text.
B. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
IS Good Condition
~ Needs Maintenance
Remarks: Click or tap here to enter text.
2.
Surface Water Collection Structures, Pumps, and Pipelines IS Applicable ~ N/A
A. Collection Structures, Pumps, and Electrical
~ Good Condition IS Needs Maintenance
Remarks: At the time of inspection, Pump 002 had two of the three pumps down for maintenance.
The two pumps have been out of maintenance for approximately 2-3 months at the time of
inspection.
97
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Appendix B: Section 2
Detrex Corporation (OU5) Site Inspection Checklist
B.
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
IS Good Condition ~ Needs Maintenance
Remarks: Click or tap here to enter text.
3. Treatment System |x| Applicable ~ N/A
A.
Treatment Train (Check components that apply)
~ Metals removal ~ Oil/Water Separation ~ Bioremediation
~ Air Stripping IS Carbon Absorbers
~ Filters Click or tap here to enter text.
~ Additive (e.g. chelation agent, flocculent) Click or tap here to enter text.
~ Others Click or tap here to enter text.
IS Good Condition ~ Needs Maintenance
IS Sampling ports properly marked and functional
~ Sampling/maintenance log displayed and up to date
IS Equipment properly identified
~ Quantity of groundwater treated annually Click or tap here to enter text.
~ Quantity of surface water treated annually Click or tap here to enter text.
Remarks: Click or tap here to enter text.
B.
Electrical Enclosures and Panels (properly rated and functional)
IS N/A ~ Good Condition ~ Needs Maintenance
Remarks: Click or tap here to enter text.
C.
Tanks, Vaults, Storage Vessels ~ N/A
~ Proper Secondary Containment ~ Good Condition IS Needs Maintenance
Remarks: Carbon tanks appear to be in good condition; overflow of untreated water from storage
Tank 004 and secondary containment was observed on several occasions in 2022. Overflow of Tank 004 is
currently being addressed by Detrex.
D.
Discharge Structure and Appurtenances
~ N/A IS Good Condition ~ Needs Maintenance
Remarks: Click or tap here to enter text.
E.
Treatment Building(s)
~ N/A IS Good condition (esp. roof and doorways)
98
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Appendix B: Section 2
Detrex Corporation (OU5) Site Inspection Checklist
~ Needs repair ~ Chemicals and equipment properly stored
Remarks Click or tap here to enter text.
F. Monitoring Wells (DNAPL Passive collection remedy) ~ N/A
IS Properly secured/locked IS Functioning
IS Routinely sampled ~ All required wells located
IS Good condition ~ Needs Maintenance
Remarks Passive collection wells appeared to be in good condition based on visual observations.
Discussed the sedimentation clean-out O&M procedures for the perimeter passive DNAPL recovery
wells.
4. Monitoring Data
A. Monitoring Data:
IS Is Routinely Submitted on Time ~ Is of Acceptable Quality
Remarks: Historically, monthly water sampling of Outfall 002 discharge was not analyzed for the full list of
COCs identified in the 1997 Source Control ROD; Detrex is currently addressing the required monthly analysis
of contaminants of concern specified in the 1997 Source Control ROD.
B. Monitoring Data Suggests:
~ Groundwater plume is effectively contained ~ Contaminant concentrations are declining
Remarks: Additional data is needed to determine if the groundwater plume is effectively contained.
IX. OVERALL OBSERVATIONS
1. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
The remedy requires containment and treatment of contaminated groundwater. Based on the observed
overflow of Tank 004 several times in 2022 and other water management practices, there are engineering
performance issues of the containment remedy.
2. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
Identified the need to install piezometers along the slurry wall for adequate O&M monitoring. Identified
the need to clean out perimeter DNAPL monitoring points to address sedimentation.
3. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be
compromised in the future.
99
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Appendix B: Section 2
Detrex Corporation (OU5) Site Inspection Checklist
Observed overflow from Tank 004 indicates engineering performance issues related to containment
remedy. This may be an early indicator to future remedy issues related to containment and treatment of
contaminated groundwater.
4. Early Indicators of Potential Remedy Problems
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Observed overflow of untreated groundwater co-mingled with process and surface water from Tank 004
in March 2022 and September 2022. Insufficient water management practices for untreated groundwater
indicates the potential remedy issues related to the containment and treatment of contaminated
groundwater as required by the 1997 Source Control ROD.
100
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Appendix B: Section 3
Millennium (0U6) Site Inspection Checklist
1. SITE INFORMATION
Site name:
Millennium (OU6)
Date of inspection:
8/23/2023
Location and Region:
Ashtabula, OH
EPA ID:
OHD908614572
Agency, office, or company leading the FYR:
U.S. EPA
Weather/temperature:
High of 68°F, cloudy, rain in the afternoon
Remedy Includes: (Check all that apply)
~ Landfill cover/containment
IS Access controls
IS Institutional controls
~ Groundwater pump and treatment
~ Surface water collection and treatment
~ Monitored natural attenuation
~ Groundwater containment
~ Vertical barrier walls
IS Other: Interceptor Trench along northern
property line.
Attachments:
~ Inspection team roster:
Nick Roope, Ohio EPA
Anna Nguyen, U.S. EPA
Jenny Polster, U.S. EPA
AmyGahala, U.S. EPA
Robert Schmude, Ineos Pigments
IS Site map attached Site map attached (FYR
Figure 6-1)
101
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Appendix B: Section 3
Millennium (0U6) Site Inspection Checklist
II. INTERVIEWS (Check all that apply)
1. O&M Site Manager Robert Schmude, Title
8/23/2023
Interviewed: |x| at site ~ at office ~ by phone Phone Number: Clic
< here to enter text.
Problems, suggestions: ~ Report attached
Click or "e to enter text.
V. ACCESS AND INSTITUTIONAL CONTROLS
IS Applicable ~ N/A
1.
Fencing Damaged ~ Location shown on site map IS Gates secured ~ N/A
Remarks: Click or ter text.
2.
Institutional Controls (ICs)
A. Implementation and Enforcement
Site conditions imply ICs not properly implemented ~ Yes IS No ~ N/A
Site conditions imply ICs not being fully enforced ~ Yes ~ No IS N/A
Type of monitoring (e.g., self-reporting, drive by) Self-monitoring
B. Adequacy IS ICs are adequate ~ ICs are inadequate ~ N/A
Remarks: Click or tap here to enter text.
3.
General
A. Vandalism/Trespassing ~ Location shown on site map IS No vandalism evident
Remarks: Click or tap here to enter text.
B. Land use changes on site IS N/A
Remarks: Click or tap here to enter text.
C. Land use changes off site IS N/A
Remarks: Click or tap here to enter text.
IX. OVERALL OBSERVATIONS
1.
Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as
designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain
contaminant plume, minimize infiltration and gas emission, etc.).
The Site inspection included observations of the northern trench and sumps. See the Site Photos
(Appendix C Photos 39-40). After the inspection, EPA followed up to request the quarterly sample
results from the northern trenches between 2019 to 2023. All sample results for PCBs have been
102
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Appendix B: Section 3
Millennium (0U6) Site Inspection Checklist
non-detect since March 2019. All source control activities appear to be effective in preventing the
migration of PCBs into the interceptor trenches from the Ineos property.
Excavated soils and mining residuals were sent to Millennium's existing, permitted solid waste
industrial landfill located within the Fields Brook watershed. The portion of the landfill containing
the PCB waste materials was capped in 2011. Millennium's OM&M responsibilities for its landfill
are defined by the permit issued by Ohio EPA, with the only addition being the expansion of the
monitoring parameters to include PCBs and radionuclides.
The landfill is under regulation of Ohio EPA. The landfill operates as a RCRA Subtitle D landfill,
pursuant to Ohio Administrative Code (OAC) 3745-29 (Permit & Operations), OAC 3745-30-08
(Groundwater Monitoring), and OAC 3745-37 (License). Under its current license, Ohio EPA
requires annual monitoring for PCBs.
103
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APPENDIX C
SITE INSPECTIONS PHOTOGRAPHS
104
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Ashtabula River NPL Site
Five Year Review Inspection
August 22-23, 2023
by Anna Nguyen, RPM
(Photos 1-39)
-------
Photo 1
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Fields Brook Land Fill cap and passive gas vents.
Direction: North
-------
Photo 2
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Fields Brook Landfill leachate collection system.
Direction: North
-------
Photo 3
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Fields Brook Landfill monitoring well FB05 demonstrating signs of frost heave.
Direction: North
-------
Photo 4
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Fields Brook Land Fill fencing from north side of the landfill.
Direction: Southeast
-------
Photo 5
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Exposure Unit 5 facing west from State Road,
Direction: West
-------
Photo 6
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Box culvert under State Road in Exposure Unit 5; water was observed flowing from the culvert.
Direction: East
-------
Photo 7
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Culvert on the north side of the CSX train tracks in Exposure Unit 7 on east side of State Road; culvert connects to box culvert
observed on the west side of State Road in Exposure Unit 5 as seen in Photo 6.
Direction: Northwest
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Photo 8
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Exposure Unit 8 facing east from State Road; one of two French Drains shown on south side of the Brook,
Direction: East
-------
Photo 9
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Detrex Corporation NDPES outfall 002 discharge into Exposure Unit 8,
Direction: Northwest
-------
Photo 10
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Exposure Unit 8 sedimentation pond
Direction: Southeast
-------
Photo 11
Date: 8/22/2023
Operable Unit: 1 & 4
Description: South sewer culvert from Millennium on east side of State Road at Exposure Unit 8.
Direction: Southeast
-------
Photo 12
Date: 8/22/2023
Operable Unit: 1 & 4
Description: North sewer culvert (plugged) on east side of State Road and north of the brook at Exposure Unit 8.
Direction: North
-------
Photo 13
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Abandoned French Drain off the west side of State Road in Exposure Unit 6.
Direction: West
-------
Photo 14
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Exposure Unit 6 facing State Road,
Direction: East
-------
Photo 15
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Exposure Unit 6 brook.
Direction: West
-------
Photo 16
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Exposure Unit 4 brook.
Direction: South
-------
Photo 17
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Soil sampling location (SS07) in Exposure Unit 3.
Direction: West
-------
Photo 18
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Exposure Unit 2
Direction: West
-------
Photo 19
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Con rail
Direction: Northwest
-------
Photo 20
Date: 8/22/2023
Operable Unit: 1 & 4
Description: Exposure Unit 2
Direction: West
-------
Photo 21
Date: 8/22/2023
Operable Unit: 3
Description: Ashtabula River (OU3) facing Lake Erie.
Direction: Northeast
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Photo 22
Date: 8/22/2023
Operable Unit: 8
Description: ACME Parcel (OU8) from State Road and E. 21st Street; buildings appear vacant and dilapidated.
Direction: Southeast
-------
Photo 23
Date: 8/23/2023
Operable Unit: 5
Description: Perimeter DNAPL recovery wells.
Direction: Northwest
-------
Photo 24
Date: 8/23/2023
Operable Unit: 5
Description: Sump Pump Station 1 of the Southern Groundwater Interceptor Trench.
Direction: East
-------
Photo 25
Date: 8/23/2023
Operable Unit: 5
Description: Effluent from Outfall 002 discharge point, covered under grass. Bio sheen observed in photo.
Direction: Northwest
-------
Photo 26
Date: 8/23/2023
Operable Unit: 5
Description: Pump station near cleared detention pond at the south end of the Detrex property.
Direction: Southeast
-------
Photo 27
Date: 8/23/2023
Operable Unit: 5
Description: Cleared detention pond, catch basin, and paved emergency spillway (Outfall 003).
Direction: Southeast
-------
Photo 28
Date: 8/23/2023
Operable Unit: 5
Description: : Catch basin located within the detention pond and 4" pipe feeding into the detention pond; pipe is believed to be connected to EU8 trench
system. In the event DNAPL is observed in the EU8 French Drain, the contaminated water is pumped to the Detrex detention pond for subsequent
treatment onsite.
Direction: Southeast
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Photo 29
Date: 8/23/2023
Operable Unit: 5
Description: Emergency spillway (Outfall 003) from detention pond leading to EU8.
Direction: South
-------
Photo 30
Date: 8/23/2023
Operable Unit: 5
Description: Passive DNAPL recovery we 11 field
Direction: Northeast
-------
Photo 31
Date: 8/23/2023
Operable Unit: 5
Description: Interior of Mobile DNAPL Recovery Unit.
Direction: North
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Photo 32
Date: 8/23/2023
Operable Unit: 5
Description: Totes of DNAPL and groundwater collected from the passive DNAPL recovery wells and labeled as "IN-PROCESS DNAPL," to indicate
gravity separation process of DNAPL and groundwater.
Direction: Northeast
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Photo 33
Date: 8/23/2023
Operable Unit: 5
Description: Anticipated influent equipment to be used to introduce decanted water from DNAPL passive well recovery system to onsite water
treatment system. Untreated water from Tank 004 is noted on the right of the valve.
Direction: East
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Photo 34
Date: 8/23/2023
Operable Unit: 5
Description: One of the carbon beds used for onsite water treatment.
Direction: East
O
if
Ei jfe
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Photo 35
Date: 8/23/2023
Operable Unit: 5
Description: Northwest lawn area with berm shown on the left of the photo.
Direction: North
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Photo 36
Date: 8/23/2023
Operable Unit: 5
Description: Northwest lawn area with Pump 002, slurry wall and berm shown on the right.
Direction: South
-------
Photo 37
Date: 8/23/2023
Operable Unit: 5
Description: Sampling station for Outfall 002 effluent; sampling station located in northwest lawn,
Direction: South
-------
Photo 38
Date: 8/23/2023
Operable Unit: 6
Description: Interceptor trench system at Ineos facility; EU8 is located north of the fence.
Direction: East
-------
Photo 39
Date: 8/23/2023
Operable Unit: 6
Description: Interior of one of three sumps of the interceptor trench system at Ineos.
Direction: South
-------
Photos of Detrex Tank 004 Overflow
(Photos 40-42)
by Nick Roope (Ohio EPA)
March 7, 2022
-------
Photo 40
Date: 3/7/2022
Operable Unit: 5
Description: Pooled water from overflow of Tank 004 and watermain break in northwest lawn of Detrex,
Direction: East
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Photo 41
Date: 3/7/2022
Operable Unit: 5
Description: Overflow of Tank 004 occuri
Direction: East
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Photo 42
Date: 3/7/2022
Operable Unit: 5
Description: Pooled water from Tank 004 overflow and watermain break along northern property and fence line of Detrex,
Direction: East
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APPENDIX D
SITE CHRONOLOGY FOR ALL OUs
149
-------
SEDIMENT AND FLOODPLAIN/WETLANDS OU1 & OU4 SITE CHRONOLOGY
Event
Date
Site is finalized on the National Priorities List (NPL)
September 8, 1983
Sediment Rl Report Completed
March 1985
Sediment FS Completed
July 1986
Record of Decision for the Fields Brook Sediment (OU1)
September 30, 1986
Source Control Rl Completed
May 1997
Source Control FS Completed
June 1997
Record of Decision for the Floodplain / Wetland (OU4)
June 30,1997
Explanation of Significant Differences (ESD) - Sediment (OU1)
August 15, 1997
Record of Decision for Source Control (OU2 originally, OUs 5-10 now)
September 29, 1997
EPA issued a Unilateral Administrative Order for the performance of the
RD/RA for the Sediment and Floodplain / Wetland Operable Units (OU1 /
OU4) (V-W-98-C-449)
December 17, 1997
EPA issues Unilateral Administrative Orders for the performance of RD/RA at
the Source Control Operable Unit. OU2 broken into OUs 5 through 10.
December 1997
Site-Wide ESD Modifying the Decisions for the Sediment,
Floodplain/Wetland and Source Control OUs (addition of radionuclide
cleanup requirements)
April 8, 1999
Consent Decree lodged for Performance of Remedial Design and Remedial
Action for OU1 / OU4
May 14,1999
Consent Decree entered for Performance of Remedial Design and Remedial
Action for OU1 / OU4
July 7, 1999
PRP Contractor Mobilization at the Site
April 28, 2000
Start Landfill Excavation
May 25, 2000
EPA approves landfill design / Start of landfill construction
July 2000
Start Liner Installation
July 20, 2000
EPA approves Remedial Design / Commencement of Remedial Action
August 9, 2000
Complete Landfill
September 6, 2000
Begin Excavation in OU1 / OU4
September 22, 2000
Encounter DNAPL / Commence Shutdown
October 16, 2000
DNAPL Investigation
Oct. 2000-Mar. 2001
Re-commence excavation activities in OU1 / OU4
May 7, 2001
ESDs to address the presence of DNAPL-impacted soil and sediment.
August 17, 2001
150
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SEDIMENT AND FLOODPLAIN/WETLANDS OU1 & OU4 SITE CHRONOLOGY
Event
Date
Begin Thermal Treatment with Soil Pure, Inc.
October 19, 2001
Thermal treatment resumed with ESMI of New York - commence trial runs
to prepare for performance demonstration
June 17, 2002
Thermal treatment shutdown pending approval of performance
demonstration plans and scheduling of trial burn
Aug. 2 - Sept. 29,
2002
Performance Demonstration Performed
October 8 - 10, 2002
Site Mitigation - Placement of Plantings
Oct. 2002-Mar. 2003
Complete Sediment and Soil Excavation
December 17, 2002
Thermal treatment completed
December 20, 2002
Demobilization
Dec. 2002-Feb. 2003
Conditional Approval of Final Construction Report
September 30, 2003
EPA Approval of Quality Assurance Project Plan for OM&M
March 19, 2004
EPA Approval of OM&M Work Plan
May 4, 2004
First FYR Completed
June 7, 2004
PCBs & Chlorinated Solvent DNAPL found in the Brook during OM&M
sampling
May 14, 2005
PRPs Mobilize to Excavate Soil & Sediment Pockets with PCB and
Chlorinated Solvent DNAPL
August 20, 2007
PRPs discover oily DNAPL - Determined to be Therminol (Arochlor 1248)
August 29, 2007
EPA issued Unilateral Administrative Order to Millennium to address
potential for release of PCB contaminants
October 18, 2007
Millennium installs interceptor trench and commences soil/sediment
excavation
Winter 2007/2008
Fields Brook Action Group submits proposal for relocating and isolating
Fields Brook as part of a Focused Feasibility Study
February 2, 2009
Second FYR Completed
June 2, 2009
Modification to Statement of Work for the Fields Brook Superfund Site
United States of America v. GenCorp, Inc., et al.
Case No. 5:89CV1866
July 10, 2009
FBAG submits Final Construction Completion Report, Fields Brook Relocation
& EU 8Floodplain Restoration
February 10, 2010
151
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SEDIMENT AND FLOODPLAIN/WETLANDS OU1 & OU4 SITE CHRONOLOGY
Event
Date
EPA approves repairs to the EU SFields Brook Relocation Structure
November 30, 2011
URS and Detrex complete remediation report for 2009-2011 DNAPL
excavation work in DS tributary (EU5)
June 11, 2012
FBAG submits Excavation of Soils and Sediments Work Plan to address
isolated areas of contamination found during O&M sampling in EU 2 through
EU 6.
August 29, 2013
EPA Approves Excavation of Soils and Sediments Work Plan
December 5, 2013
Third FYR Completed
May 23, 2014
Excavation of Soils and Sediments in EU1, EU2, EU 3, EU 4, and EU 6. FBAG
submit a Completion Report submitted ot EPA on September 10, 2014.
June 12-26, 2014
Excavation of Soils and Sediments in EU4
October 3 -
November 7, 2016
FBAG submits Fields Brook Superfund Site, Excavation of Soils and Sediments
Final Completion Report
November 23, 2016
Quality Assurance Project Plan Revision 4, to update sampling procedures
under the OM&M plans, dated June 19, 2018 was reviewed and approved by
EPA
June 27, 2018
Fourth FYR Completed
June 25, 2019
152
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DETREX CORPORATION SOURCE AREA (OU5) SITE CHRONOLOGY
Event
Date
Detrex facility constructed
1947
EPA initiated negotiations for the performance of a Source Control RI/FS.
1986
EPA issued a Unilateral Administrative Order for performance of a Source
Control RI/FS
1989
Fields Brook PRPs investigated possible source control areas.
1992 -1995
EPA approved the PRPs' Source Control Rl
May 1997
EPA approved the PRPs' Source Control FS
June 1997
EPA issued the Source Control ROD, which addressed six individual source
control areas, including Detrex Corporation.
September 29, 1997
EPA issued a Unilateral Administrative Order for the performance of the
Detrex Corporation RD/RA (V-W-98-C-450) and Amendment 2/17/1998
(496533)
December 1997
EPA issued an Amendment to Unilateral Administrative Order for the
performance of the Detrex Corporation RD/RA (V-W-98-C-450)
Note-UAO SOW provided on Feb 26, 1998
February 17,1998
EPA approval of Phase 1 (slurry wall & earth work) RD
May 22, 2000
EPA approval of Phase 1 Remedial Action (RA) Work Plan
August 30, 2000
Earth work, including construction of slurry wall
August 2000 - July
2001
EPA approval of Phase II (DNAPL Recovery) RD
October 4, 2001
EPA approval of Phase II RA Work Plan
December 6, 2001
Construction of DNAPL extraction system
Summer 2002
DNAPL extraction commenced
October 2002
EPA completes First FYR
June 7, 2004
153
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DETREX CORPORATION SOURCE AREA (OU5) SITE CHRONOLOGY
Event
Date
PCBs & Chlorinated Solvent DNAPL found in the Brook during OM&M
sampling
May 14, 2005
Detrex investigates southern portion of property for evidence of DNAPL
movement towards Fields Brook
August 2005
Detrex installs interceptor trenches north of Fields Brook and south of the
plant and former lagoon area
Winter 2006/2007
EPA observes DNAPL at North Sewer outfall
December 5, 2006
Detrex completes borings and test trenches along North Sewer to
investigate possible migration of DNAPL. Excavation of North Sewer outfall
area and installation of sump
December 2006
Detrex installs additional extraction wells (with alternative design)
September 2007 -
February 2008
Additional chlorinated solvent DNAPL pockets found in the Brook during
Millennium removal action
October 2007 -
October 2008
Detrex submits revised draft work plans for investigation of DS Tributary
and expansion of DNAPL extraction system
June 2008
State Road bridge reconstruction and identification of additional
chlorinated DNAPL at North Sewer outfall location
December 2008 -
February 2009
Detrex conducts additional investigation with soil borings along western
edge of facility and in State Road north of the bridge
January 2009
EPA completes Second FYR
June 2, 2009
Detrex performs limited sediment removal in DS Tributary immediately
west of State Road
November 2009
Detrex completes "Sediment/DNAPL Delineation Report"
May 4, 2010
Detrex performs additional sediment removal in DS Tributary and
restoration of box culvert under State Road
October- December
2011
Detrex submits "Report for Additional Excavation of DS Tributary and State
Road Culvert Restoration"
July 11, 2012
EPA Issues " ESD" to modify the extraction well remedy at Detrex.
January 15, 2014
EPA approved a DNAPL Recovery Point Installation Work Plan
May 1, 2014
EPA completes Third FYR
May 23, 2014
154
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DETREX CORPORATION SOURCE AREA (OU5) SITE CHRONOLOGY
Event
Date
DNPAL System Phase 1, Phase II, III wells installed
June-Aug 2015
EPA approved "Final Passive DNAPL Collection System Completion Report"
June 14, 2017
EPA approved DNAPL Monitoring Frequency Schedule
March 21, 20218
EPA completes fourth FYR
June 25, 2019
EPA approved DNAPL Monitoring Frequency Schedule
October 1, 2020
OEPA observes overflow of untreated water from Tank 004 at the Detrex
facility.
March 7, 2022
Detrex collects a surface water sample after the Tank 004 overflow event
from the ponded water in the northwest lawn.
March 18, 2022
Detrex submits the "EHS-ASH-Water-1 Memo" to address prevention of
Tank 004 overflow.
August 3, 2022
Detrex reports overflow of untreated water from Tank 004 at the Detrex
facility.
September 28, 2022
EPA issues "Request for Additional Information Regarding the Detrex Water
Treatment System and CERLCA Remedy" to Detrex
November 21, 2022
Detrex submits the "Response to Request for Additional Information
Regarding Detrex Water Treatment System and CERLCA Remedy"
January 25, 2023
Detrex conducts a storm sewer camera survey to examine the condition of
existing storm sewers which received DNAPL-contaminated groundwater.
March 13, 2023
EPA issues "Evaluation of the Water Collection and Treatment System at
Source Area Operable Unit 5, Detrex Corporation"
July 7, 2023
Detrex submits the "Detrex Facility Outfall Monitoring Plan" and "Progress
Update: Evaluation of Water Collection and Treatment System at Source
Area Operable Unit 5, Detrex Corporation"
August 3, 2023
Detrex submits the "Detrex Facility Tank 004 Overflow Plan"
October 13, 2023
EPA approved DNAPL Monitoring Frequency Schedule
November 7, 2023
155
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MILLENNIUM TICL4 PLANT SOURCE AREA (OU6) SITE CHRONOLOGY
Event
Date
TiCU Plant constructed by Stauffer Chemical Company and began
operations
1956
National Distillers and Chemicals bought and operated TiCU Plant
1959
Cabot Titania purchased and began its operation of the TiCU Plant
1963
TiCU Plant leased to Gulf and Western Industries, Inc.
1972
Gulf and Western purchased the TiCU Plant
1975
SCM purchased the TiCU Plant
1983
EPA initiated negotiations for the performance of a Source Control RI/FS.
1986
EPA issued a Unilateral Administrative Order for performance of a
Source Control RI/FS
1989
Fields Brook PRPs investigated possible source control areas.
1992 -1995
SCM changed its name to Millennium Inorganic Chemicals, Inc.
1997
EPA approved the PRPs' Source Control Rl
May 1997
EPA approved the PRPs' Source Control FS
June 1997
EPA issued the Source Control ROD, which addressed 6 individual source
control areas, including the Millennium TiCU Plant
September 29,1997
EPA issued a Unilateral Administrative Order for the performance of the
Millennium RD/RA (V-W-98-C-449)
December 24, 1997
Letter and Amendment to 1997 UAO (V-W-98-C-449)
Feb 11, 1998
Effective date of EPA "stop work" directive issued to Millennium to allow
evaluation of project direction pending investigation of radionuclide
contamination
June 10, 1998
EPA issued site-wide ESD to address radionuclide contamination at
Millennium and in Fields Brook
April 8, 1999
156
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MILLENNIUM TICL4 PLANT SOURCE AREA (OU6) SITE CHRONOLOGY
Event
Date
EPA approved the Remedial Design and the Remedial Action Work Plan
for the Millennium TiCU Plant Operable Unit
July 7, 1999
Commencement of soil and mining residual excavation
July 26, 1999
Completion of excavation
October 15, 1999
EPA approved the Completion of Remedial Action Report
June 28, 2000
EPA approves reduction in PCB and radium monitoring frequency for
leachate at the Millennium landfill. Leachate monitoring was reduced
from monthly to quarterly.
February 4, 2003
EPA completes FYR
June 7, 2004
Lyondell Chemicals acquires the facility
2004
Fields Brook PRPs Mobilize to excavate pockets of PCB contamination
and DNAPL from Fields Brook
August 20, 2007
Fields Brook PRPs discover oily DNAPL - Determined to be Therminol
(Aroclor 1248)
August 29, 2007
EPA issued Unilateral Administrative Order to Millennium to address
potential for release of contaminants (response work commenced under
verbal order) (V-W-08-C-883)
October 18, 2007
Millennium installs interceptor trenches on the northern portion of its
property as a protective measure to ensure that any DNAPL within the
facility cannot move to Fields Brook
November- December
2007
Millennium collects soil borings from facility perimeter and from
potential DNAPL source areas within its facility
April 2008
EPA completes Second FYR
June 2, 2009
Consent Decree Modified by EPA to incorporate relocation of Fields
Brook in EU 8through the PCB-contaminated soil excavation area
July 10, 2009
ESD for OU6, OU8, and OU9
September 23, 2009
Final Report approved by EPA for soil and sediment investigation, and
removal work considered complete pursuant to UAO
May 18, 2010
Millennium Inorganic Chemical changes name to Cristal USA
October 12, 2012
Most Recent Sampling report submitted to EPA for Cristal Ashtabula
Landfill
March 7, 2014
EPA completes Third FYR
May 23, 2014
EPA approved Cristal's request to discontinue quarterly sampling at the
Cristal Ashtabula Landfill
December 22, 2015
EPA completes Fourth FYR
June 25, 2019
INEOS Enterprises acquires Cristal USA and changes the name to INEOS
Pigments.
May 1, 2019
157
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NORTH SEWERS SOURCE AREA (OU7) SITE CHRONOLOGY
Event
Date
EPA initiated negotiations for the performance of a Source Control RI/FS.
1986
EPA issued a Unilateral Administrative Order for performance of a Source
Control RI/FS
1989
Fields Brook PRPs investigated possible source control areas.
1992 -1995
EPA approved the PRPs' Source Control Rl
May 1997
EPA approved the PRPs' Source Control FS
June 1997
EPA issued the Source Control ROD, which addressed 6 individual source
control areas, including the North Sewers
September 29,1997
EPA issued a Unilateral Administrative Order for the performance of the
North Sewers RD/RA (V-W-98-C-446)
December 24, 1997
Amendment-EPA issued a Unilateral Administrative Order for the
performance of the North Sewers RD/RA (V-W-98-C-446)
February 18, 1998
Approval of Remedial Design for North Sewers
June 1, 2000
Abandonment of Sewer Lines
September - October,
2000
EPA approves Completion of Remedial Action Report (dated January 31,
2001)—no monitoring is required
March 27, 2001
EPA completes First FYR
June 7, 2004
Institutional Controls Recorded with Ashtabula County (Letter sent to EPA
on November 30, 2004)
October 25, 2004
EPA completes Second FYR
June 2, 2009
EPA completes Third FYR
May 23, 2014
EPA completes Fourth FYR
June 25, 2019
Energy company conducts first Ph II ESA in area of interest which overlaps
with OU7
April 2019
Environmental Covenant for Ineos Pigments-Owned Portion of OU7
recorded with Ashtabula County
December 23, 2020
Environmental Covenant for Gabriel Performance Products, LLC -Owned
Portion of OU7 recorded with Ashtabula County
December 29, 2020
158
-------
Energy company conducts second Ph II ESA in area of interest which
overlaps with OU7
December 2021
EPA issues "Letter Regarding Dominion Energy Group's Proposed Pipeline
Project at the Fields Brook Superfund National Priorities List Site,
Ashtabula, Ohio"
December 15, 2021
Energy company indicates the pipeline project is on hold indefinitely
November 21, 2022
159
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ACME SCRAP IRON AND METALS AND SOUTH SEWERS SOURCE AREA (OU8) SITE
CHRONOLOGY
Event
Date
Acme Scrap property owned by U.S. government
Late 1940's
Site operated as a calcium carbide manufacturing facility
1943 -1952
Site was vacant
1952 -1974
Acme purchased the property
1974
EPA initiated negotiations for the performance of a Source Control
RI/FS
1986
EPA issued a Unilateral Administrative Order for performance of a
Source Control RI/FS
1989
Fields Brook PRPs investigate possible source control areas
1992 -1995
EPA approved the PRPs' Source Control Rl
May 1997
EPA approved the PRPs' Source Control FS
June 1997
EPA issued the Source Control ROD, which addressed 6 individual
source control areas, including Acme Scrap and the South Sewers
September 29, 1997
EPA issued a Unilateral Administrative Order (V-W-98-C-451) for the
performance of the Acme Scrap and South Sewers RD/RA
December 29, 1997
EPA issued a Unilateral Administrative Order (V-W-98-C-451) for the
performance of the Acme Scrap and South Sewers RD/RA Amendment
February 18,1998
EPA approved the Remedial Design for the Acme Scrap and South
Sewers operable units
August 30, 2000
Performance of the Remedial Action
September 2000
Completion of Remedial Action Repot
February 13, 2001
Operations, Maintenance, and Monitoring Plan for Acme Scrap and
Metal
Feb 20, 2001
Acme Scrap property purchased by Lakeside Industrial Park and
Railyard, Inc.
December 2001
EPA approved the 12/28/2000 Remedial Action Construction Quality
Assurance Report for Acme Scrap and South Sewers
March 17, 2003
EPA completes First FYR
June 7, 2004
160
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ACME SCRAP IRON AND METALS AND SOUTH SEWERS SOURCE AREA (OU8) SITE
CHRONOLOGY
Event
Date
Routine monitoring of sediment from stormwater runoff
September 2001 -
September 2006
EPA completes Second FYR
June 2, 2009
ESD for OU6, OU8, and OU9
September 23, 2009
Institutional Controls Recorded
March 9, 2010
Hubert Properties LLC identified as the owner of a portion of the OU8
parcel (PIN#: 03-014-00-011-03)
July 21, 2010
State Road Investments Inc. purchases portion of OU8 parcel (PIN# 03-
014-00-011-00) from Lakeside Industrial Park & Rain Inc. EPA was not
notified of the sale.
June 29, 2012
EPA completes Third FYR
May 23, 2014
Hubert Properties LLC identified as the owner of a portion of the OU8
parcel (PIN#: 03-014-00-011-05)
February 4, 2019
EPA completes Fourth FYR
June 25, 2019
161
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APPENDIX E TABLES
162
-------
Table 1-1 Sediment Clean Up Goals
Sediment
Clean Up Goals (CUG)
Sediment
Confidence Removal Goals (CRG)
Residential
Industrial /
Occupational
EU-1
EU2
EU3
EU4
EU5
EU6
EU7
EUS
Chemical
Hg/kg
Hg/kg
1,1-dichloroethene
17,OOC
40,OOC
trans- 1,2-sichloroethene
87,433,OOC
170,333,OOC
chloroform
1,672,OOC
3,909,OOC
1,1,1-trichloroethane
393,451,OOC
766,500,OOC
benzene
352,00C
822,OOC
benzidine
4(
IOC
tetrachloroethene
196,00C
459,OOC
392,000
trichloroethene
927,00C
2,168,OOC
1,854,000
1,854,000
4,366,000
4,366,000
toluene
874,335,00C
1,000,000,OOC
1,1,2-trichloroethane
179,00C
418,OOC
chlorobenzene
87,433,00C
170,333,OOC
ethyl benzene
437,167,00C
851,667,OOC
1,1,2,2-tetrachloroethane
51,00C
119,OOC
102,000
102,000
238,000
238,000
1,2,4-trichlorobenzene
43,717,00C
85,167,OOC
1,2-dichlorobenzene
393,451,00C
766,500,OOC
1,4-dichlorobenzene
425,00C
994,OOC
methylene chloride
1,360,00C
3,180,OOC
vinyl chloride
5,40C
13,OOC
10,800
Phenols
1,000,000,OOC
1,000,000,OOC
2-chlorophenol
21,858,00C
42,583,OOC
acenaphthene, acenaphthalene
262,300,OOC
511,000,OOC
hexachloroethane
729,OOC
1,703,OOC
nitrobenzene
2,186,OOC
4,258,OOC
isophorone
10,737,OOC
25,102,OOC
naphthalene
174,897,OOC
340,667,OOC
diethyl phthalate
1,000,000,OOC
1,000,000,OOC
dimethyl phthalate
437,167,OOC
851,667,OOC
fluorene
174,867,OOC
340,667,OOC
n-nitrosodiphenylamine
2,081,75C
4,867,OOC
hexachlorobenzene
6,38C
15,OOC
NA
39,000
40,000
39,000
45,000
1,500,000
1,500,000
Hexachlorobutadiene
131,OOC
306,OOC
Anthracene
1,000,000,OOC
1,000,000,OOC
di-n-butyl phthalate
437,167,OOC
851,667,OOC
fluoranthene
174,867,OOC
340,667,OOC
pyrene
1,000,000,OOC
1,000,000,OOC
bis(2-ethylhexyl)phthalate
729,OOC
1,703,OOC
benzo(a)anthracene
13,97C
33,OOC
chrysene
139,73C
327,OOC
di-n-octyl phthalate
87,443,OOC
170,333,OOC
benzo(b)fluoranthene
13,97C
33,OOC
benzo(k)fluoranthene
13,97C
33,OOC
benzo(a)pyrene
1,40C
3,30C
indeno(l,2,3-cd)pyrene
14,OOC
33,OOC
dibenzo(a,h)anthracene
1,40C
3,30C
PCBs (total)
1,30C
3, IOC
6,800
6,000
4,700
9,200
7,000
42,000
Inorganics
units are mg/kg (ppm)
antimony
174<
340:
arsenic
27i
21
beryllium
2/
5.5
cadmium
2,18£
4,25£
chromium - Cr6
21,85£
42,583
Chromium - Cr3
1,000,OOC
1,000,OOC
copper
161,75;
315,117
nickel
87,43;
170,333
thallium
26;
511
zinc
847,335
1,000,OOC
lead
TIT
O
LD
50C
selenium
21,85?
42,583
mercury
13i;
2555
cyanide
87,43;
170,333
radium -226, radium 228 (combined)
5 pCi/g
10 pCi/g
Notes:
Units are as shown.
CUGs which were calculated to exceed 100% are capped at 100%.
Sources:
CUGs - ESD-Sediment OU - August 1997
CRGs - Various reports from FBAG and Detrex.
163
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Table 1-2 Soil Clean Up Goals
Chemical
Soil Clean Up Goals (CUGs)
Soil Confidence Removal Goals (CRGs
Exposure Unit
Residential
Cancer risk Non-cancer controlling
Industrial / Occupational
Cancer risk Non-cancer controlling
EU-1
EU2
EU3
EU4
EU5
EU6
EU7
EU8
acenaphthene
65,000,000
65,000,000
460,000,000
460,000,000
acetone
97,000,000
97,000,000
710,000,000
710,000,000
anthracene
300,000,000
300,000,000
2,100,000,000
1,000,000,000
beta-BHC
90C
90C
7,500
7,50C
gamma-BHC (Lindane)
1,300
200,000
1,300
10,300
1,400,000
10,30C
bis (2 -ethylhexyl)phthalate
43,500
5,400,000
43,500
349,000
35,000,000
349,00C
2-butanone
580,000,000
580,000,000
4,300,000,000
1,000,000,000
butylbenzylphthalate
96,000,000
96,000,000
820,000,000
820,000,000
ca rbazole
75,700
75,700
605,200
605,20C
carbon disulfide
97,000,000
97,000,000
710,000,000
710,000,000
chlorobenzene
19,000,000
19,000,000
140,000,000
140,000,000
chloroform
411,600
9,700,000
411,600
3,274,100
71,000,000
3,274,100
4,4-DDE
6,300
6,300
50,500
50,50C
4,4-DDT
6,300
330,000
6,300
50,500
2,400,000
50,50C
dibenzofuran
4,300
4,300
31,000,000
31,000,000
1,2-dichlorobenzene
44,000,000
44,000,000
390,000,000
390,000,000
1,3-dichlorobenzene
44,000,000
44,000,000
390,000,000
390,000,000
1,4-dichlorobenzene
63,100
63,100
504,400
504,40C
1,1-dichloroethane
97,000,000
97,000,000
710,000,000
710,000,000
1,1-dichloroethene
4,200
8,800,000
4,200
33,300
64,000,000
33,30C
trans-l,2-dichloroethene
19,000,000
19,000,000
140,000,000
140,000,000
diethyl phthalate
380,000,000
380,000,000
3,300,000,000
1,000,000,000
dimethyl phthalate
4,900,000,000
1,000,000
42,000,000,000
1,000,000,000
di-n-butyl phthalate
48,000,000
48,000,000
410,000,000
410,000,000
endrin ketone
230,000
230,000
1,800,000
1,800,000
fluoranthene
40,000,000
40,000,000
280,000,000
280,000,000
fluorene
43,000,000
43,000,000
310,000,000
310,000,000
hexachlorobenzene
CO
o
_Q
370,000
80C
6,700
3,100,000
6,70C
80,000
80,000
200,000
39,000
200,000
hexachlorobutadiene
19,400
990,000
19,400
155,200
8,600,000
155,20C
hexachloroethane
108,100
490,000
108,100
864,600
4,300,000
864,60C
methylene chloride
333,600
58,000,000
333,600
2,654,100
430,000,000
2,654,100
4-methylphenol
2,500,000
2,500,000
22,000,000
22,000,000
naphthalene
20,000,000
20,000,000
170,000,000
170,000,000
PCBs
1,000
1,00C
6,000
6,00C
6,000
6,000
50,000
50,000
50,000
pyrene
31,000,000
31,000,000
210,000,000
210,000,000
benzo(a)anthracene
3,300
3,300
26,500
26,50C
benzo(b)fluoranthene
3,300
3,300
26,500
26,50C
benzo(a)pyrene
30C
30C
2,600
2,60C
chrysene
333,000
333,000
2,649,800
2,649,800
dibenz(a,h)anthracene
30C
30C
2,600
2,60C
indeno (l,2,3-cd)pyrene
3,300
3,300
26,500
26,50C
1,1,2,2-tetrachloroethane
11,700
11,700
93,400
93,40C
102,000
tetrachloroethene
52,700
11,000,000
52,700
418,800
76,000,000
418,80C
392,000
1,1,1-trichloroethane
88,000,000
88,000,000
640,000,000
640,000,000
1,1,2-trichloroethane
42,400
3,800,000
42,400
337,500
27,000,000
337,50C
toluene
190,000,000
190,000,000
1,400,000
1,400,000
1,2,4-trichlorobenzene
4,700,000
4,700,000
40,000,000
40,000,000
trichloroethene
267,800
7,500,000
267,800
2,125,800
50,000,000
2,125,800
1,854,000
xylenes
1,900,000,000
1,000,000,000
14,000,000,000
1,000,000,000
vinyl chloride
1,300
1,300
10,500
10,50C
M-g/kg
M-g/kg
Hg/kg
M-g/kg
ns"
-------
Table 1-3 Fish Advisory Consumption for Fields Brook Site
(Source: 2023 Ohio Sport Fish Consumption Advisory located online at
)
Body of Water
Area Under
Advisory
Species
Meal Frequency
Contaminant
Statewide-All waters
Yellow perch,
Sunfish (bluegill,
green, longear,
redear)
Two/week
N/A
Flathead catfish
23" and over,
Northern pike 23"
and over,
Steelhead trout
from Lake Erie
and its tributaries
One/month
N/A
All other Ohio
sport fish not
specified in this
table
One meal per
week
N/A
Lake Erie
Tributaries
All waters
(Ashtabula,
Common Carp 27"
and larger
One/two months
PCBs
Cuyahoga, Erie,
Smallmouth Bass
One/month
PCBs, Mercury
Lake, Lorain,
Brown Bullhead
One/month
Mercury
Lucas, Ottawa,
Sandusky
counties)
Channel Catfish,
Common Carp 19"
- 27", Freshwater
Drum, Lake Trout,
White Bass,
Whitefish 21" and
larger
One/month
PCBs
Bluegill Sunfish
Unrestricted
NA
Ashtabula River
U.S. Route 20
(Prospect Road)
to mouth (Lake
Erie) (Ashtabula
County)
Common Carp,
Freshwater Drum
One/month
PCBs
165
-------
APPENDIX F FIGURES
166
-------
4,000
Approximate
Scale in Feet
Legend
¦ Sediment Operable Unit and
Floodplain/Wetlands Area
Operable Unit
Source Control Operable Unit
Ashtabula River Investigation
Approximate Current
Watershed Boundary
Figure E-l
Location Map
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9
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-------
Conneaut Creek Watershed
Grand River Watershed
Ohio River Watershed
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3ffman:Rd:
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]Q Reservoir
:Dodgevl
:Montgomery-Rdi
iNew.HudsortRd:
:Huntley;Rti.
lUnderwood-.R.dr
TRUMBULL COUNTY
Figure E-2
Ashtabula County
Watershed
Transportation
Interstate Highway
Federal Highway
State Highway
Hydrography
/X/ Rivers
Streams
Watershed Boundaries
Local Roads and Streets
Municipal Streets
Ashtabula County Watersheds
County Boundaries and Transportation, ODOT, 2007 0 1.25 2.5 5 7.5 10 Map Created: May 9,2012
Watershed Boundaries - USDOA, NRCS, 1999 Created by: Ohio Department of Natural Resources
Miles Office of Coastal Management
-------
Ashtabula River
Sediment Disposal
Landfill
FieldsjB^odk'
Landfill
-------
2000
Scale In Feet
Gonrail
n
E. 23rd St,
w#-
L 21 SI Si.
, RMI Metals
Detrex
Millenium
Acme
Figure E-4 Source Control
Locations FIGURE 1
Source Control Site Map
(Industrial Portion of Fields Brook Watershed)
-------
A6
STAR BEACON
FRIDAY, JUNE 30, 2023
SCOTUS: Ruling says colleges cannot use race in considering applicants
FROM PAGE A1
Besides the conser-
vative-liberal split, the
fight over affirmative
action showed the deep
gulf between the three
justices of color, each of
whom wrote separately
and vividly about race in
America and where the
decision might lead.
Justice Clarence Thom-
as — the nation's second
Black justice, who had
long called for an end
to affirmative action —
wrote that the decision
"sees the universities'
admissions policies for
what they are: rudder-
less, race-based prefer-
ences designed to ensure
a particular racial mix in
their entering classes."
Justice Sonia Soto-
mayor, the court's first
Latina, wrote in dissent
that the decision "rolls
back decades of prec-
edent and momentous
progress."
Both Thomas and Soto-
mayor, the two justices
who have acknowledged
affirmative action played
a role in their admis-
sions to college and law
school, took the unusual
step of reading summa-
ries of their opinions
aloud in the courtroom.
hi a separate dissent,
Justice Ketanji Brown
Jackson — the court's
first Black female justice
— called the decision
"trulv a tragedy for us
all."
Jackson, who sat out
the Harvard case be-
cause she had been a
member of an advisory
governing board, wrote,
"With let-them-eat-cake
obliviousness, today,
the majority pulls the
ripcord and announces
'colorblindness for all'
by legal fiat. But deem-
ing race irrelevant in law
does not make it so in
life."
The vote was 6-3 in the
North Carolina case and
6-2 in the Harvard case.
Justice Elena Kagan was
the other dissenter.
Biden, who quickly
stepped before cameras
at the White House, said
of the nation's colleges:
"They should not aban-
don their commitment
to ensure student bodies
of diverse backgrounds
and experience that
reflect all of America,"
He said colleges should
evaluate "adversity over-
come" by candidates.
In fact, an applicant
for admission still can
write about, and colleges
can consider, "how race
affected his or her life,
be it through discrimina-
tion, inspiration or oth-
erwise," Roberts wrote.
But the institutions
"may not simply estab-
lish through application
essays or other means
the regime we hold un-
lawful today," he wrote.
Presidents of many
colleges quickly issued
statements affirming
their commitment to
diversity regardless of
the court's decision.
Many said they were still
assessing the impact but
would follow federal law.
"Harvard will continue
to be a vibrant commu-
nity whose members
come from all walks of
life, all over the world,"
school President Law-
rence Bacow said in a
statement.
President Reginald
DesRoches of Rice Uni-
versity in Houston said
he was "greatly disap-
pointed" by the decision
but "more resolute than
ever" to pursue diversi-
ty. "The law may change,
but Rice's commitment
to diversity will not," he
said in a campus mes-
sage.
Former Presidents
Donald Trump and
Barack Obama offered
starkly different takes
on the high court ruling.
The decision marked "a
great day for .America.
People with extraordi-
nary ability and every-
thing else necessary
for success, including
future greatness for
our Coimtry, are finally
being rewarded," Trump,
the current Republican
presidential frontrun-
ner, wrote on his social
media network.
Obama said in a state-
ment that affirmative
action "allowed genera-
tions of students like Mi-
chelle and me to prove
we belonged. Now it's up
to all of us to give yoimg
people the opportunities
they deserve — and help
students everywhere
benefit from new per-
spectives."
The Supreme Court
had twice upheld
race-conscious college
admissions programs in
the past 20 years, includ-
ing as recently as 2016.
But that was before
the three Trump ap-
pointees joined the
court. At arguments
in late October, all six
conservative justices
expressed doubts about
the practice, which had
been upheld under Su
preme Court decisions
reaching back to 1978.
Lower courts also had
upheld the programs at
both UNC and Harvard,
rejecting claims that the
schools discriminated
against white and Asian
American applicants.
The college admissions
disputes were among
several high-profile cases
focused on race in Amer-
ica, and were weighed by
the conservative-domi-
nated, but most diverse
court ever. Among the
nine justices are four
women, two Black peo-
ple and a Latina.
The justices earlier in
June decided a voting
rights case in favor of
Black voters in Alabama
and rejected a race-
based challenge to a
Native American child
protection law.
The affirmative action
cases were brought by
conservative activist
Edward Blum, who also
was behind an earlier
challenge against the
University of Texas as
well as the case that led
the court in 2013 to end
use of a key provision
of the landmark Voting
Rights Act.
Blum formed Students
for Fair Admissions,
which filed the lawsuits
against both schools in
2014.
The group argued that
the Constitution forbids
the use of race in college
admissions and called
for overturning earlier
Supreme Court decisions
that said otherwise.
Roberts' opinion
effectively did so, both
Thomas and the dissent-
ers wrote.
The only institutions
of higher education
explicitly left out of the
ruling were the nation's
military academies,
Roberts wrote, suggest-
ing that national security
interests could affect the
legal analysis.
VIEW: Supreme Court decision is a blow to the American dream
FROM PAGE A4
The death knell for
affirmative action has
been sounding for years.
Critics claim affirmative
action policies benefit
Black and Latino stu-
dents, as well as others
from underrepresented
communities, at the ex-
pense of white and Asian
students. Both lawsuits
included in the Supreme
Court ruling were filed
by Students for Fair Ad-
mission, whose litigation
is largely funded by an
organization that also
supports white suprem-
acist groups, according
to reports in Salon and
Media Matters for Amer-
ica. Not surprisingly,
the leader of the group
also filed a lawsuit that
gutted the Voting Rights
Act.
California's two public
university systems have
been banned from using
race as a factor in admis-
sions since voters passed
Proposition 209 in 1996.
(A ballot measure to
repeal it in 2020 failed.)
Instead, public universi-
ties have tried to expand
the racial and economic
diversity of the student
body through other
means. For example, the
UC system no longer
requires applicants'
test scores or letters of
recommendation, which
tend to benefit wealth-
ier and white students.
In addition, six of its
campuses participate in
the Transfer Admission
Program, which guar-
antees admission for
community college stu-
dents who fulfill certain
requirements. Communi-
ty colleges tend to enroll
higher rates of Latino
and Black students.
The Supreme Court rul-
ing will likely reduce the
numbers of Latino and
Black students and other
underrepresented groups
at selective colleges,
unless those higher edu-
cation institutions figure
out other ways to ensure
diverse student bodies.
Colleges and univer-
sities must radically
transform their admis-
sions processes. Notably,
they must do away with
preferential treatment
NM ROOFING AND
CONSTRUCTION, LLC
SPECIALIZING IN
for students who can
use legacy, athletic
ability and donations or
connections by family
as a leg up. At Harvard,
applicants benefiting
from these preferences
made up about 43% of
admitted white students
between 2009-14, in
contrast to less than 16%
of non-white students,
according to a study.
Without this pref erential
treatment, about three-
fourths of the white
applicants would have
been rejected.
Banning affirmative
action in college ad-
missions hardly makes
America race-blind. Its
institutions are still
steeped in racial and
economic inequities,
reflected in dispropor-
tionately high infant
mortality rates in Black
communities, high-
er pollution levels in
working-class communi-
ties and discriminatory
school policies, such as
harsher discipline meted
out to Black and Latino
students.
Ironically, this is the
most diverse Supreme
Court in history and two
justices have acknowl-
edged that they benefited
from affirmative action
in education. But they
have opposite stances on
the policy, reflecting its
divisive nature. Justice
Clarence Thomas has
said, "God only knows
where I would be today"
without affirmative ac-
tion, though he has been
a staunch opponent of
the policy for decades.
In a concurring opinion
in Thursday's decision,
Thomas wrote that he
has yet "to understand
exactly how racial diver-
sity yields educational
benefits."
Sotomayor called
affirmative action a
"door-opener" that
changed her life.
The kind of inequities
that Thomas and Soto-
mayor endured contin-
ue to exist for many,
particularly as the gap
between the rich and
poor has widened. Now,
the Supreme Court has
made it more difficult
for the nation to address
these inequities.
svEPA
EPA Begins Review
of Fields Brook Superfund Site
Ashtabula, Ohio
U.S. Environmental Protection Agency is conducting a five-year review of the Fields
Brook Superfund site in Ashtabula, Ohio. The Superfund law requires regular checkups
of sites that have been cleaned up - with waste managed on-site - to make sure the
cleanup continues to protect people and the environment. This is the fifth five-year
review of this site.
U.S. EPA completed the cleanup of PCBs, metals, and chlorinated solvents found in the
sediment and soil of the Fields Brook channel and floodplain, including six industrial
areas, in 2002. The channel comprises a six-square-mile watershed that flows into the
Ashtabula River, eventually draining into Lake Erie, about one-and-a-half miles
downstream of the site. The industrial area surrounding the channel has been utilized
since 1940 by nearly 20 separate facilities' operations.
More information is available at the Ashtabula County District Library, 4335 Park Ave.,
Ashtabula; the Kent State Library, 335 W 44th St., Ashtabula; and additionally, and at
www,epa. gov/superftmd/fields-brook. Hie review should be completed by May 2024.
The five-year review is an opportunity for you to tell EPA about site conditions and any
concerns you have. Contact:
Kirstin Safakas
Community Involvement Coordinator
312-886-6015
safakas.kirstin@epa.gov
Anna Nguyen
Remedial Project Manager
312-886-6798
nguyen.anna@epa.gov
You may also call EPA toll-free at 800-621-8431, 9:30 a.m. to 5:30 p.m., weekdays.
Enjoy Year-
Outdoor Living
Tui ill I ^
Enjoy your yard all year long with a beautiful,
comfortable sunroom or enclosed patio,
Call us today for a free consultation and estimate!
-Serving Ashtabula County for Three Generations Since 1941-
_WSA
Inc
WEATHER SEALCO
^^SqCJjUGI/
Manufacturing Corp.
4707 State Road
ASHTABULA
992-9181
1-800-992-9181
MONDAY-FRIDAY
8:00AM-4:30PM
Evenings & Saturdays
by Appointment Only
wuvinr.inieathersealco.com
Shingles - Complete Tear Offs
Repairs - Siding - Decks & Gutters
Fully Insured* FREE Estimates
Amish Owned and Operated Call:
1 -440-904-0372
-------
V:
Drawing Status Date- Initials
Proj Mgr.
Reviewed
Date-
Source Reference:
CRA Remedial Action Plan
Fields Brook Superfund Site
Ashtabula, Ohio
O &M, Inc.
45 0 Montbrook Lane
Knoxville, TN 37919
Figure 1-1
Fields Brook
Superfund Site Map
-------
EU5 Sediment
Hexachlorobenzene
Hexachlorobenzene
Hexachlorobenzene
1,1,2,2-Tetrachloroethane 102,000
Hexachlorobenzene 39,000
No Soil CRGs Calculated
6000
Tetrachloroethene
Trichloroethene
EU3 Sediment
EU4 Sediment
EU1 Sediment
EU2 Sediment
Hexachlorobenzene
Hexachlorobenzene
See Note
Ashtabula
Martdlo-Qr
EU6 Sediment
1,1,2,2-Tetrachloroethane
102,000
Hexachlorobenzene
45,000
PCBs (Total)
7,000
Tetrachloroethene
392,000
T richloroethene
1,854,000
Vinyl chloride
10,800
EU8 Sediment
1,1,2,2-Tetrachloroethane 238,000
Hexachlorobenzene 1,500,000
PCBs (Total) 42,000
Tetrachloroethene 918,000
Trichloroethene 4,366,000
EU7 Soil
No Soil CRGs Calculated
EU7 Sediment
1,1,2,2-Tetrachloroethane
238,000
Arsenic
53,000
Hexachlorobenzene
1,500,000
Tetrachloroethene
918,000
Trichloroethene
4,366,000
EU6 Soil
Hexachlorobenzene 200,000
PCBs 50,000
EU8 Soil
Hexachlorobenzene 200,000
PCBs 50,000
Exposure unit
Exposure unit division
Fields Brook
Notes:
CRG = Confidence Removal Goal
EU = Exposure Unit
Units: ng/kg
Imagery Source: Esri
Note: As part of the original clean up., all sediment from EU2 was to be excavated.
DETREX ESD
FIGURE 1-2
CONFIDENCE REMOVAL GOALS (CRG)
BY EXPOSURE UNIT
EPA REGION 5 RAC 2 | REVISION 1 | APRH2019
FIELDS BROOK
ASHTABULA COUNTY, OHIO
-------
Figure 1-3
EU-2 Sample Locations
Fields Brook Superfund Site
Ashtabula, Ohio
Description:
Map adapted from 2011
imagery.
Plot Info:
File: Figure_17.2_EU2
Project No.: 3075F
Plot Date: 7/21/2014
Arc Operator: El
Reviewed by: BR
ddttis
Map Legend:
Sediment Sample
+ Soil Sample
| Surface Water Sample
Coordinate System:
OH State Plane North
g F)PS Zone: 3401
" Units: US Survey Feet
y Datum: NAD83
Spatial Projection:
-------
Figure 1-4
EU-3Sample Locations
Fields Brook Super fund Site
Ashtabula, Ohio
Map Legend'
SedimentSample
Soil Sample
| Surface Water Sample
Spatial Projection:
121
Coordinate System
OH State Plane North
FiPSZone: 3401
Units: US Survey Feet
Oatum: NAD 83
Plot Info:
File: Figure. 17.3_EU3
Project No.: 3Q75F
Rot Oate: 7/21/2014
Arc Operator: El
Reviewed by: BR
Vddms
www. ttdcn • i n c. com
Description:
Map adapted from 2011
imagery
-------
Figure 1-5
ELM Sample Locations
Fields Brook Superfund Sits
Ashtabula, Ohio
Description'
Map adapted from 2011
imagery
Map Legend:
Sediment Sample
+ Soil Sample
| Su rface Wate r Sa mple
Spatial Projection:
EZJ
Coordinate System-
OH State Plane North
RPS Zone: 3401
Units: US Suivey Feet
Datum: NAD83
Plot Info:
File: Figure_17.4_EU4
Project No,: 307SF
Plot Date: 7/21/2014
Arc Operator El
Reviewed by: BR
**ddms
-------
Figure 1-6
EU-6 Sample Locations
Fields Brook Superfund Site
Ashtabula, Ohio
Description:
Map adapted from 2011
imagery.
Spatial Projection:
121
Coordinate System:
OH State Plane North
FIPS Zone: 3401
Units: US Survey Feet
Datum: NA083
Plot Info:
File: Figure_17.5_EU6
Project No.: 3075F
Plot Date: 7/21/2014
Arc Operator: El
Reviewed by: BR
Vddms
Map Legend:
^ Sediment Sample
Soil Sample
| Surface Water Sample
-------
Figure 1-7
EU-8 Sample Locations
Fields Brook Superfund Site
Ashtabula, Ohio
Description:
Map adapted from 2011
imagery.
Plot Info:
File: Figure_17.6_EU8
Project No.: 307SF
Plot Date: 7/21/2014
Arc Operator: El
Reviewed by: BR
**d elms
Map Legend'
Sediment Sample
+ Soil Sample
| Surface Water Sample
El
Coordinate System
OH State Plane North
FlPS Zone: 3401
Units: US Survey Feet
Datum: NAD83
Spatial Projection:
-------
567
-4}
Figure 1-8
Fields Brook Landfill
-------
Figure 1-9
EU8 IC Map for Detrex-Owned Portion
-------
Restricted Area Course Table
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-------
RMI SODIUM
LANDFILL
LEGEND
AREAS TO BE REGRADED TO REDUCE
HHI SURFACE PONDING OR AREAS WHERE
SEDIMENT WILL BE REMOVED
SOURCE AREA
SLURRY WALL
@ EXTRACTION WELLS
CATALYST PILES
(PLANNED EXCAVATION)
OUTFALL -
COLLECTION AREA
DETREX Site Map
Figure 5-1
Detrex Facility Map from 1997 ROD
-------
NOTE:
RECOVERY POINT, RMI-N, AND RMI-S
PIEZOMETER LOCATIONS ARE
APPROXIMATE.
SCALE 1 = 150
LEGEND
STAINLESS STEEL RECOVERY WELL
^ MONITORING WELL
^ PIEZOMETER
~ RMI PIEZOMETER
APPROXIMATE LOCATION OF
| | FORMER LAGOON AREAS
PASSIVE DNAPL RECOVERY POINT OR
MONITORING POINT WITH NO DNAPL
OBSERVED SINCE INITIATION OF ESD
PASSIVE DNAPL RECOVERY POINT OR
MONITORING POINT WITH NO DNAPL
OBSERVED IN CURRENT MONTH
PASSIVE DNAPL RECOVERY POINT OR
MONITORING POINT WITH 0.01 TO 1.00
FOOT OF DNAPL THICKNESS
OBSERVED SINCE INITIATION OF ESD
PASSIVE DNAPL RECOVERY POINT OR
MONITORING POINT WITH 1 FOOT OR
GREATER DNAPL THICKNESS
OBSERVED SINCE INITIATION OF ESD
142 - 1-INCH PERIMETER DNAPL
RECOVERY POINTS MEASURED
ANNUALLY (JUNE 27 - 28, 2023 - NO
DNAPL OBSERVED)
EHS Support
FIGURE 5-2
NOVEMBER 2023 DNAPL OCCURRENCES
AND PERIMETER DNAPL RECOVERY POINTS
DETREX CORPORATION
ASHTABULA, OHIO
DRAWN BY: AMH
REVIEWED BY: MLS
SCALE:
1" = 150'
DATE DRAWN: 12/20/2023
DATE REVIEWED: 12/20/2023
PLOT DATE:
12/20/2023
PROJECT NO.:
LLC.02144.0000
-------
SLURRY
WALL
NEW 1B-INCH WIDE
INSPECTION TRENCH
FORMER
TRENCH 1
GROUNDWATER
FORMER
TRENCH 2
EXCAVATED
MATERIAL
STOCKPILE
AREA
SCALE 1" = 15'
NOTE:
1 TRENCH 1 & 2 WERE REMOVED AS PART OF
EXCAVATION ACTIVITIES
2. SEE FIGURE 2 FOR EXCAVATION DETAILS
3. NEW INSPECTION TRENCH PLACED 10 FT
DOWN-GRADIENT OF EXCAVATION
LEGEND
H~H | RAILROAD TRACKS
PROPERTY BOUNDARIES
Q INSPECTION TRENCH (2011)
LIMITED EXCAVATION AREA (2009)
IZZ3 EXCAVATED AREA (2011)
FORMER INSPECTION TRENCHES (2009)
DBS
DETREX CORPORATION
ASHTABULA, OHIO
Figure 5-3
DS TRIBUTARY REMEDIATION
DRAWN BY:
AMH
CHECKED BY:
WEC
PROJECT No:
13814613
DATE:
12/19/11
FIGURE No:
1
GABRIEL PERFORMANCE PRODUCTS
GABRIEL
PRODUCTS
DISCHARGE
APPROXIMATE EXCAVATION AREA
12'WIDE
125' LONG
APPROXIMATELY 3* DEEP
STAND PIPE
DS TRIBUTARY
COLLECTION
TRENCH
I x FORMER RMI SODIUM LANDFILL
15" DRAIN
PIPE
(PLUGGED
WITH
GROUT)
DETREX
CORPORATION
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BENCH MARK #1 CHISELED SQUARE AT
N.W. CORNER OF CONCRETE VALVE VAULT
ELEV. 633.09
EXISTING FENCE
EXISTING PIPE
NEW PIPE
1. EMBANKMENT FOR DIKE SHALL BE FROM OFF SITE
2. THE AREA WITHIN THE LIMITS OF THE DIKE EMBANKMENT
SHALL BE CLEARED AND GRUBBED. IN THE EMBANKMENT
AREA THE TOP SOIL SHALL BE SCALPED TO A DEPTH
OF 4" BEFORE BEGINING CONSTRUCTION.
3. THE DIKE EMBANKMENT SHALL BE A CLAYEY SOIL
SHALL BE PLACED IN 8" LAYERS AND COMPACTED
TO 95 PERCENT OF MAXIMUM DENSITY.
¦L SHALL BE DISPOSED OF
ON SITE WHERE AND AS DIRECTED BY THE OWNER
DISPOSAL AREA SHALL BE GRADED AND SEEDED.
6. LOCATION OF THE 6" WATER LINE IS APPROXIMATE AND
SHALL BE FIELD VERIFIED PRIOR TO START OF CONSTRUCTION
OF PUMP STATION 002.
SPENT CARBON TANK
37'-0" -
TANK LAYOUT PLAN
SCALE 1" 20'
©
Figure 5-5
Detrex 1989 NPDES Design of
Stormwater Overflow Area
HO.
REV 191 QMS
DATE
Burgess & Niple, Limited
Engineers and Architects
Ijn
1912
DETREX CORPORATION
ASHTABULA, OHIO PLANT
COLLECTION AND TREATMENT IMPROVEMENTS
DESIGNED BY: R.H.S.
002 PUMP STATION SITE PLAN
AND TANK LAYOUT PLAN
AS SHOWN
DRAWN BY: M.J.M.
CHECKED BY: R.H.S.
6
21
Akron, 0B . Cincinnati. 0B ¦ Cl.mrt.nd. 0B ¦ Colu«bu* OB ¦ Covington. KY
APPROVED BY: M.R.R.
Bou.ton.T* ¦ Mentor, OH ¦ Parkcburg. »V ¦ P^n. AZ • Phooni*. AZ
DATE: Au^UtfT, \^gA
002 PUMP STATION SITE PLAN
SCALE 1 =20'
NEW mH "X"
OUTFALL STATION
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Milennium TiCI4 Site Map
Figure 6-1
Millennium Facility Site Map
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100 Year Flood Elevation
(Sampling Extent)
EAST TRENCH #2
M i I ! e nr n
u m
Property
LEGEND
<| Confirmation Sample Location
~ GeoProbe Sample Location
A MLSS Sample Location
t|? Sump Location
—St— Millennium Fence
Trench Location
Millennium Property Line
Millennium Ponds
Asphalt/Gravel Drive
2001 DNAPL Removal Limits
~ Temporary Fields Brook Channel
during soil excavations
X Excavation Location of DNAPL trenching
August 2007 and pooled DNAPL in 2005
Zone B and C intersection with Excavation Trench
I I
I I
Former Fields Brook Channel
Southern Wall of Excavation
Excavation Floor
0 25 50
100
150
200
I Feet
de maxims, inc.
de maximisData ddms
Management Solutions, Inc.
FIGURE 6-2
Soil Excavations arid
Soil Sampling Locations
Millennium Inorganic Chemical Co. Site - Ashtabula, Ohio
Mapping By: CMC
Version: 24 Sept2009
Checked By:
Dde: 24 Sept 2009
ddms Project». 1547-3206
File: 090924_millen nium_figure2_EU8_11x17,mxd
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Sewers North
Sewers North and South Site Maps
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APPROXIMATE SCALE IN FEET
Figure 7-2 SITE MAP
NORTH SEWER REMEDIAL ACTION ACTIVITIES
DRAWN BY: TBC
CHECKED BY: KMA
PROJECT NUMBER: 3S-BE06013
DATE: 9/27/00
FIGURE NO: 1
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E. 21st.
LIMIT OF POTENTIAL
RESPONSE AREA
Acme Scrap Iron & Metal Company Site Map
Figure 8-1
Acme Iron & Scrap Metal Site Map
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RUl TITANIUM CO.
VOLUME 51, PAGE 2972
p.p.fos-oti-oo-oa-oo
ISbSsn BHX
Station 57+MJ3
Middle Roa
Road Number 400, Section A
N 06°24'21"E
100.05'
0.234 Ac. N 14.16.sg..E
P.P.fOS—Qti—OO—OIO—OQ 100.05',
Parcal I-
749.98'
N 25°18*32"E
GRAPHIC SCALE - FEET
$<»/ , Alxo i.
t VJ
900
Figure 8-2
Acme Iron & Metal IC Map
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Figure 8-3
Acme Scrap Iron & Metal IC Map for Hubert
Properties, LLC-owned Portion
1 inch = 376 feet
1 inch = 376 feet
Property Lines are graphic representations and are NOT survey accurate.
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Figure 8-4
Acme Iron & Metal IC Map for State Road Investments,
INc.-Owned Portion
1 inch = 376 feet
1 inch = 376 feet
Property Lines are graphic representations and are NOT survey accurate.
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Figu re 8-5
Acme Iron & Metal IC Map for Lakeside Industrial Park & rail
Yard Inc.-Owned Portion
1 inch = 376 feet
1 inch = 376 feet
Property Lines are graphic representations and are NOT survey accurate.
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