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Case Summary: Corrective Action Order to address lead and VOC impacts to soil and groundwater at RCRA facility in Indiana

On May 9, 2017, the U.S. Environmental Protection Agency (EPA) issued an Administrative Order on Consent (AOC or order) under Section 3008(h) of the Resource Conservation and Recovery Act (RCRA) to Exide Technologies, Inc. (“Exide”) for its facility in Frankfort, Indiana. The order requires Exide to: (1) perform a RCRA Facility Investigation to identify the extent of contamination by metal (e.g., lead) and volatile organic chemicals (VOCs) known to be present in soils and groundwater, and (2) develop and propose any corrective actions needed to control any unacceptable risks to human exposures and groundwater.

In addition to the corrective action order under RCRA, the Agency’s Superfund removal program conducted cleanup activities at off-site properties from September 2015 to August 2016 to address contamination at nearby residential properties.

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Information about the Exide Facility in Frankfort, Indiana

The 13.7 acre Exide facility includes about 4.5 acres that formerly contained buildings for manufacturing lead-acid batteries and related operations. No above grade structures remain on-site. Approximately 12.1 acres of the facility are located within the perimeter of an existing security fence. The remaining 1.6 acres of the facility lies outside of the fence and has an open grass covered surface. The facility operated from 1963 to 1997. Operations at the facility resulted in contamination of soil and groundwater by lead and VOCs. The facility was used by Exide for equipment storage until the demolition project in October 2012. The facility is currently vacant.

Exide filed for bankruptcy under Chapter 11 on June 10, 2013 in the U.S. District Court for Delaware. A Final Order confirming Exide’s Plan of Reorganization was filed on March 27, 2015.

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Information on the Coordination with the Removal Program and the RCRA Order

In September 2014, the Indiana Department of Environmental Management (IDEM) screened nearby residential properties for metals and detected lead at high levels in residential yards adjacent to the western and northeastern property boundaries of the Exide facility. In addition, IDEM noted in a report that "results may indicate a significant vapor intrusion potential in the homes located adjacent to the Exide property boundaries."

In November 2014, IDEM referred the facility to EPA's Superfund Removal Program for a site assessment. Superfund personnel sampled soil from 16 residential properties and performed sub-slab or crawl space and indoor air sampling at seven properties. Superfund removal activities at off-site properties were conducted from September 2015 to August 2016. The activities included removing 1,497 tons of non-hazardous contaminated soil from 12 residential properties and installing one vapor intrusion mitigation system at a residential property.

The AOC requires Exide to describe the current conditions at the facility, submit a work plan for RCRA Facility Investigation, perform interim measures as needed to control current human exposures to contamination or to stabilize migration of contaminated groundwater, and propose final corrective measures necessary to protect human health and the environment from all current and future unacceptable risks due to releases of hazardous waste or constituents at the facility based on anticipated land use.

EPA anticipates that the completion of this investigation and corrective action work will position the facility for beneficial reuse within the Frankfort, Indiana community. Investigation and corrective actions will also benefit the immediately surrounding community by remediating a source of contamination that has previously affected surrounding properties.

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Contact Information

Peter Ramanauskas
RCRA Corrective Action Project Manager
U.S. Environmental Protection Agency
Region 5
Ralph Metcalfe Federal Building
77 West Jackson Blvd.
Chicago, IL 60604
(312) 886-7890

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