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Hazardous Waste Cleanup: C&D Technologies, Attica, Indiana

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Congress amended the Resource Conservation and Recovery Act (RCRA) in November 1984, expanding the Act's cleanup provisions and prompting EPA and its state partners to develop the RCRA Corrective Action Program. The program oversees the investigation and cleanup of nearly 4,000 hazardous waste sites across the country, including many with risks comparable to Superfund sites.

In January 2007, EPA Region 5 and C&D entered into a RCRA Section 3008(h) Corrective Action Order (Corrective Action Order) that required C&D to investigate and address all historic releases of hazardous waste and constituents at or from the site. C&D’s RFI report identified chlorinated organic solvents and metals contamination in the surface soil and subsurface soil based on exceedances of the IDEM Industrial Default Closure Levels (IDCL) and ecological risk screening criteria.

Cleanup Status

The Remedial Active Objectives of the selected Remedy are to:

  1. Meet the cleanup goals for soil gas to protect workers from indoor air vapor intrusion
  2. Minimize the potential for worker exposure to hazardous materials in surface soil
  3. Control the potential for releases of hazardous substance to groundwater

The remedial efforts put together by C&D met objectives 1 and 2. Ongoing operation and maintenance of surface capping in various impacted areas would ensure objective 3 is met with periodic inspections and repair. The SVE system that operated from September 2016 to November 2017 with intermittent shut down met the remedial active goal of reducing the TCE levels in soil gas from 89,000 ug/m3 to less than 880 Ug/m3 for TCE. However, the residual concentration of TCE in shallow soil in few locations remained above the IDEM industrial direct contact criteria and IDEM soil to groundwater migration protection criteria.

  • In addition to the remediation of VOC contamination in Areas 9 and 4, C&D implemented corrective measures in other areas of facility to address human health and ecological risk. To account for metal contamination (i.e. lead and zinc) in Riverbank area, C&D placed a revetment grade riprap placed over geotextile fabric to protect the ecological receptors. As part of the final remedy, C&D capped areas 5 and submitted a maintenance report for routine inspection of existing concrete caps in areas 3,7 and 11. The concrete caps prevent potential worker exposure to residual metal contamination in these areas. Lead exceedance in groundwater required monitoring until lead level in groundwater did not exceed the IDEM Residential Direct Contact Levels (residential direct contact criteria) for two consecutive rounds six months apart. The total lead concentration in groundwater in MW-4s during May 2017 and November 2017 sampling event was found to be lower than IDEM residential direct contact criterion of 15 ug/L.
  • To address residual concentration of VOCs in area 9 and 4, C&D excavated 20 cubic yards of contaminated soil and capped the area with concrete after backfilling the excavated area with clean fill.

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Site Description

C&D owns and operates a battery manufacturing plant at 200 West Main Street in the City of Attica, Fountain County, Indiana. The Facility is located on approximately 12.5 acres in the north-northwestern portion of the city. The Wabash River borders the Facility on the west and northwest. Residential and commercial properties surround the remaining sides of the Facility (Figure 1).  The Facility contains an active battery manufacturing area, a former landfill, and riverbank property along the Wabash River.

The Attica plant manufactures lead acid batteries for commercial, industrial and military applications.  Manufacturing processes include casting or curing lead battery parts, pasting battery grids, plate processing, battery assembling, charging and finishing.

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Contaminants at this Facility

Through focused human health and ecological risk evaluations performed on the RFI data collected from 2007 through 2009, the following areas at the site were identified for corrective action:

  • Areas 4 and 9 soil (trichloroethylene (TCE) and tetrachloroethylene (PCE));
  • Riverbank Area Soil (CD-SB-59 for lead);
  • Areas 3, 5, and 11 soil (arsenic and lead);
  • Area 7 soil (arsenic); and
  • MW-4S - Groundwater (lead).

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Institutional and Engineering Controls at this Facility

EPA’s selected remedies require C&D to conduct routine inspection and maintenance to ensure the integrity of the concrete and pavement in on-site cleanup locations and the exposure barrier in the Riverbank area.

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Land Reuse Information at this Facility

C&D will establish an enforceable institutional control to restrict the land use of the C&D property to industrial or commercial use now and in the future. EPA’s selected remedies require C&D to conduct routine inspection and maintenance to ensure the integrity of the concrete and pavement in on-site cleanup locations and the exposure barrier in the Riverbank area.

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Site Responsibility at this Facility

Concrete floors in Areas 3, 7, and 11 and the PCC pad in Area 5 were required to evaluate if integrity of these protective barriers have been compromised from general site activities. Routine inspections have been completed by either AECOM or a designated C&D facility personnel since construction of the PCC pad was completed in general accordance with the inspection schedule set forth in the O&M document. Results of the monthly inspections for each of these areas indicate the protective barriers are functioning as intended and continue to effectively isolate localized impacted soils. No corrective actions for any of the inspected areas have been recommended as a result of the inspections.

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