Record of Decision System (RODS)
CONTINENTAL STEEL CORP.
|Site Name:||CONTINENTAL STEEL CORP.|
|Address:||W MARKLAND AVE|
|City & State:||KOKOMO IN 46902|
|NPL Status:||Currently on the Final NPL|
|ROD Type:||Record of Decision|
|Operable Unit(s):||01, 02, 03, 04, 05, 06|
|Media:||Air, Groundwater, Sediment, Sludge, Soil, Solid Waste, Surface Water|
|Contaminant:||Base Neutral Acids, Dioxins/Dibenzofurans, Inorganics, Metals, PAH, PCBs, Pesticides, VOC|
Please note that the text in this document summarizes the Record of Decision for the purposes of facilitating searching and retrieving key text on the ROD. It is not the officially approved abstract drafted by the EPA Regional offices. Once EPA Headquarters receives the official abstract, this text will be replaced.
The Continental Steel site is located on West Markland Avenue in the City of Kokomo, Howard County, Indiana. The total site encompasses about 183 acres and consists of an abandoned steel manufacturing facility (Main Plant), pickling liquor treatment lagoons (Lagoon Area), a former waste disposal area (Markland Avenue Quarry), and a former waste disposal and slag processing area (Slag Processing). The site also includes nearly two miles of creeks (Kokomo and Wildcat Creek) and site-wide groundwater consisting of three separate, yet hydraulically-connected, aquifers.
The area surrounding the facility is a mixed residential, commercial and industrial area and is mainly zoned for general use. The closest residents to the plant are located within 100 feet east of the site, near the property fence line along South Leeds Street, and south of the Main Plant across Kokomo Creek. Highland Park, a recreation area, lies to the south of the Main Plant just across Kokomo Creek.
The Continental Steel Corporation was founded as the Kokomo Fence Machine Company in 1896. Site ownership changed numerous time throughout the site history through mergers and reorganizations. In 1985, the Continental Steel Corporation filed for Chapter 11 bankruptcy, and the facility closed in February 1986 when the bankruptcy filing converted to Chapter 7 liquidation. Throughout its history, the plant produced nails, wire, and wire fence from scrap metal. Operations included reheating, casting, rolling, drawing, pickling, annealing, hot-dip galvanizing, tinning, and oil tempering. The steel manufacturing operations at the plant included the use, handling, storage, and disposal of hazardous materials
The Lagoon Area was proposed for inclusion on the National Priorities List (NPL) in June 1988, and formally placed on the NPL in March 1989. The Markland Avenue Quarry and the Main Plant were proposed for aggregation to the site, and were added in May 1990.
In response to a State report ofcontaminated runoff being released from the drum storage area in the Markland Quarry, the Environmental Protection Agency (EPA) initiated a removal action in February 1990. This action involved construction of a trench, soil sampling, offsite disposal of 800 cubic yards of soil from the quarry area and 220 drums. The EPA also removed drums and storage tanks from the quarry pond between June 1991 and August 1991.
As a result of a site assessment of the Continental Steel facility itself, initiated in March 1990, the EPA arranged for the disposal of about a thousand empty, crushed drums, about 200 drums of product material, about 50 containers of lead cadmium batteries, and about 5,000 gallons of base-neutral liquids.
In 1993, the first phase of the remedial investigation (RI/FS) generated a significant amount of information about the nature and extent of contamination at the site. Phase II of the RI, in 1995, addressed the Markland Quarry, the Main Plant, and the Slag Processing Area and generated information to address data gaps for the site-wide groundwater, the Lagoon Area, and the Wildcat and Kokomo creeks.
The State conducted environmental radiation surveys in the Slag Processing Area, Lagoon Area, and the former laboratory area in the Main Plant in June 1996 and concluded there is no evidence of gross radiological contamination. The State recommended that radiation monitoring be performed on all materials removed from the site, prior to disposal.
Operable Unit (OU1):
Site-wide ground water includes a large area and quantity of affected groundwater from the three aquifers beneath the site: shallow, intermediate, and lower aquifers or water-bearing zones. Groundwater contamination appears to result from the Main Plant, the Markland Avenue Quarry, the Lagoon Area and/or other areas related to the site, and disposal of hazardous waste. A Record of Decision (ROD) was completed in September 1998 addressing OU1 through OU6.
The Lagoon Area is located approximately 0.3 miles west of the Main Plant. The area covers approximately 56 acres and includes five polishing lagoons, two acid (hazardous waste storage) lagoons, and three sludge-drying beds. The area is bordered on the south and west by Wildcat Creek and is within the 100-year floodplain. This area is primarily designated for commercial/industrial use; recreational use is limited to the creek corridor.
While in operation, spent pickle liquor (inorganic acid) generated at the Main Plant was transferred via a direct pipeline to two hazardous waste storage lagoons. The spent pickle liquor was then pumped to a neutralization and treatment system, and neutralized pickle liquor and sludge were deposited in one of five polishing lagoons. The treated liquid was then discharged to Wildcat Creek, and the sludge was placed into the three drying beds.
Phase I and II RI activities addressed contamination in the Lagoon Area. A ROD was completed in September 1998 addressing OU1 through OU6.
The Wildcat and Kokoo creeks extend some 20,000 feet within the Continential Steel site. These creeks have been impacted by direct discharge of material, runoff from the source areas, and upstream industrial sources. The creeks are generally 50 to 100 feet wide, with depths up to four feet. The creeks are designated for recreational use. A recreational corridor extends along most of the banks of the creeks. These two creeks run along the borders of the Main Plant, the Lagoon Area, and the Slag Processing Area.
Surface water and sediment sampling was performed as part of the Phase I and II RI activities. A ROD was completed in September 1998 addressing OU1 through OU6.
This 23-acre area was formerly a limestone quarry, covering nearly the entire are. The quarry was sold to Continental Steel Corporation in 1947. More than 1.2 million cubic yards of material from the steel operations were deposited in the quarry. The quarry varied in depth from 70 to 90 feet and includes a pond (4 acres). Continental Steel disposed of waste materials such as drums, slag, refractory brick, pig iron, baghouse wastes, and oil and solvent tanks at the quarry. According to former employees, the quarry served as drum reclamation area where drums were dumped directly on the ground and disposed of in the quarry pond. Previous EPA investigations in July 1986, and May 1988, revealed approximately 400 (mostly empty) drums, an abandoned storage tank, and slag, ash and refractory brick piles in the area. The quarry is located in a residential area.
Phase I RI activities included sampling of the quarry pond water and the shallow subsurface soil/fill. Phase II sampling activities performed in the quarry included surface soil sampling, a soil gas survey, groundwater screening, groundwater sampling and quarry pond surface water and sediment sampling. A ROD was completed in September 1998 addressing OU1 through OU6.
The Main Plant consists of about 94 acres and includes 127 structures, including 74 abandoned buildings with floor areas ranging from 10,000 square feet to 400,00 square feet. Many buildings have basements, some of which are flooded with groundwater. A network of underground sewers and utility lines are also located on-site. The Main Plant has numerous visitors/trespassers. It has an industrial-use-only deed covenant.
Phase I RI activities included sampling inside and outside the buildings. In addition to building sampling, Phase II RI activities included sampling of surface and subsurface soil, groundwater, process sewers, basement water, soil gas, adjacent residential surface soil, and high volume air.
The Main Plant buildings are being addressed under an August 1996 Interim ROD. The Interim ROD includes the decontamination and demolition of 127 structures and buildings, disposal of solid and liquid hazardous and nonhazardous wastes, and asbestos survey and abatement. In addition, a ROD was completed in September 1998 addressing OU1 through OU6.
The Slag Processing Area contains approximately 208,000 cubic yards of slag material, much of it in stockpiles. The current site disposition includes an open, graded area with seven piles of slag material, the largest pile having a maximum height of about 45 feet. Historical information indicates that the southwestern quarter of the area was formerly a quarry, approximately 30 feet deep, and is now filled with slag. The area is located between Wildcat Creek and Markland Avenue. The surrounding area is generally residential.
Phase II RI activities in this area included surface soil/slag sampling, a soil gas survey, and an evaluation of potential impacts to Wildcat Creek. A ROD was completed in September 1998 addressing OU1 through OU6.
For Operable Unit 1 (OU1), the selected remedy consists of the following actions: collect intermediate and lower groundwater at Martin Marietta Quarry to contain contaminated groundwater within current boundaries; dispose of collected groundwater off site at City of Kokomo Wastewater Treatment Plant (WWTP); invoke technical impracticability (TI) waiver for the intermediate and lower groundwater due to no active treatment and over 200 years to attain applicable or relevant and appropriate requirements (ARARs) through natural attenuation; collect shallow groundwater and dispose off site at WWTP; monitor groundwater until ARARs are attained; groundwater use restrictions.
Estimated Capital Costs: $13,000
Estimated First-Year O&M Costs: $244,000
Estimated 30-Year Net Present Worth Costs: $6,386,000
For OU2, the selected remedy consists of the following actions: excavate contaminated solids and consolidate on site; collect and contain shallow groundwater with expanded interception trench system and dispose off site at Kokomo WWTP; Resource Conservation and Recovery Act (RCRA) surface impoundment closure; deed & groundwater use restrictions.
Estimated Capital Costs: $43,919,000
Estimated First-Year O&M Costs: $146,600
Estimated 30-Year Net Present Worth Costs: $44,746,000
For OU3, the selected remedy consists of the following action: excavate contaminated sediment and consolidate in on-site corrective action management unit (CAMU)/landfill.
Estimated Capital Costs: $12,312,000
Estimated First-Year O&M Costs: $20,000
Estimated 30-Year Net Present Worth Costs: $12,560,000
For OU4, the selected remedy consists of the following actions: excavate contaminated sediment from Quarry Pond; backfill Quarry Pond; dispose of Quarry sediment in Lagoon Area CAMU/landfill; cover contaminated solids with common soil and vegetate; contain and collect shallow groundwater and dispose at WWTP; deed and groundwater use restrictions.
Estimated Capital Costs: $10,234,000
Estimated First-Year O&M Costs: $168,000
Estimated 30-Year Net Present Worth Costs: $11,163,000
For OU5, the selected remedy consists of the following actions: elevated volatile organic compound (VOC) solids removal and on-site disposal in CAMU/landfill; excavate PCB solids along Kokomo Creek and dispose on site in CAMU/landfill; install common soil cover and vegetate; collect and contain shallow groundwater and dispose off site at WWTP; deed and groundwater use restrictions.
Estimated Capital Costs: $7,000,000
Estimated First-Year O&M Costs: $36,000
Estimated 30-Year Net Present Worth Costs: $7,747,000
For OU6, the selected remedy consists of the following actions: regrade slag piles to level site; install protective common soil cover over contaminated solids and vegetate; deed restrictions; stabilize creek bank.
Estimated Capital Costs: $2,420,000
Estimated First-Year O&M Costs: $0
Estimated 30-Year Net Present Worth Costs: $2,420,000
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