The Columbus Steel Drum Co., Inc. began operations in 1955, changing its name to the Franklin Steel Co. in 1979. Columbus Steel Drum constructed the current 55-gallon drum reconditioning facility in 1971 at 1385 Blatt Blvd. in the Gahanna Industrial Park in Blacklick, Ohio, in Franklin County. Franklin Steel owned and operated the drum reconditioning and recycling facility from 1971 through 1997 under the Columbus Steel Drum name. Franklin Steel sold the drum reconditioning facility operations to Evans Industries, Inc. in 1997. Evans Industries operated the facility from 1997 through the end of 2002, when Queen City Barrel Company leased the site. The facility was operated by Container Recyclers, Inc. a subsidiary of Queen City Barrel doing business as Columbus Steel Drum from the end of 2002 until December 2007. Franklin Steel sold the facility property in 2007 to Queen City Barrel, which was immediately acquired by Industrial Container, and continues to do business as Columbus Steel Drum.
Franklin Steel processed closed-head and open-head 55-gallon drums. Prior to 1986, when drum inventory was at its peak, approximately 450,000 "RCRA empty" (less than 1 inch of liquid) drums were being stored at the site. At that time, approximately 38 acres were being used by Franklin Steel for drum storage and processing; consisting of two separate 10-acre drum storage areas and the main 18-acre processing/drum storage area. Since 1988, only the main 18-acre drum processing facility has been used for the drum reconditioning operations. Currently, approximately 56,000 empty drums are being stored on the ground with an additional 11,000 drums stored inside numerous semi-truck trailers.
The current 18-acre facility reconditions approximately 5,000 used 55-gallon drums per day for resale. Closed-head drums are placed on a conveyor belt and transported to the process building. In the process building, the drums are cleaned with a hot caustic solution, rinsed, shot blasted to remove the old paint and then repainted. Open-head drums are turned upside down before they enter the oxidizer to drain any liquids. The oxidizer (furnace) burns off any residual material remaining in the drum. The open-head drums are then sent into the process building for caustic rinse, shot blasting and repainting.
The Jefferson Township Taylor Road Water Treatment Plant public water supply well field is located approximately 2,600 feet to the northeast of the facility. Drainage ditches from the facility feed into on-site storm water holding ponds, which discharge into a small tributary, Unzinger Ditch, of Blacklick Creek.
An Ohio EPA Emergency Response incident report dated Feb. 25, 1980, documented a spill of 15,000 to 20,000 gallons of hazardous waste sludge from the Franklin Steel caustic clarifier, caused by an overflow of the system. The released sludge entered the Blacklick Creek drainage system. Sediment and surface water samples collected by Ohio EPA on March 27, 1980, found elevated levels of cadmium, chromium, lead, zinc and phenol. Water samples from the storm water holding pond collected by Ohio EPA on Dec. 5, 1985, found elevated levels of arsenic, cadmium, chromium, cyanide and lead and various volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs).
An Ohio EPA March 20, 1987, site inspection determined that contaminants had been released to the soil in seven different areas at Franklin Steel. Subsequent sampling of these areas found elevated levels of arsenic, cadmium, chromium, lead, ethanol, proponol, toluene, xylenes and mineral spirits. On Dec. 5, 1987, Ohio EPA requested Franklin Steel to remove the contamination at five of the seven areas by excavating the first 18 inches of soil in a 15-foot radius, by February 1988.
In April and May 1989, U.S. EPA, conducted a Preliminary Review/Site Visit Inspection (PR/SVI) at the facility. The purpose of the PR/SVI was to evaluate risk to the environment from the facility through potential migration pathways. The PR/SVI report concluded that two areas of concern had potential releases to the environment: the oxidizer and associated waste management units and the dust collector storage pad.
Ohio EPA entered into an administrative consent order with Franklin Steel on June 23, 1992. The order requires the performance of an environmental assessment of the site by completing a Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI). The RFI includes an investigation of chemicals present in ten different solid waste management units (SWMUs), ground water conditions and site geology/hydrogeology. The 10 SWMUs are:
SWMU S101, stormwater drainage system;
SWMU S102, sanitary sewer lines and valve pit;
SWMU S103, shot blast dust collectors;
SWMU S104, former shot blast storage area;
SWMU S105, former caustic rinse system and caustic sludge holding tank;
SWMU S106, oxidizer system;
SWMU S107, Drum Storage Area #1;
SWMU S108, Drum Storage Area #2;
SWMU S109, Drum Storage Area #3; and
SWMU S201, Drum Storage Area #4.
In April 1993, Ohio EPA approved the RFI's Phase I RFI work plan for the site, with the submission of the RFI Phase I Report to Ohio EPA on Feb. 11, 1994. In November 1995, the Revised, Amended Scope of Work for the RFI's Phase II was submitted to Ohio EPA, which was approved in December 1995. Due to financial constraints, the RFI's Phase II activities were scaled back at Franklin Steel's request in 1995, with another request to extend the RFI's completion schedule into 1998.
Franklin Steel submitted a draft RFI Report to Ohio EPA in October 1998 to summarize the RFI's Phase I and Phase II environmental investigation activities. These activities include the installation of 11 monitoring wells and six piezometers and the collection of at least six groundwater samples from each monitoring location. A total of 14 water and 14 sediment samples were collected from the drainage ditch system and stormwater holding pond by Franklin Steel. From 138 different locations, a total of 336 soil samples were also collected for the RFI.
The soil sampling results for the 18-acre main drum processing area had elevated levels of many metals (arsenic, cadmium, chromium, lead, nickel, zinc, etc.); SVOCs (benzo(a)anthracene, benzo(a)pyrene and bis(2-ethylhexyl)phthalate); and VOCs (acetone, chloroform, methylene chloride and vinyl chloride). The ground water monitoring indicated elevated levels of numerous metals (aluminum, arsenic, barium, chromium, lead, etc.); the SVOC bis(2-ethylhexyl)phthalate; and VOCs (chloroethane; methylene chloride and vinyl chloride). The surface water samples had elevated levels of metals (arsenic, chromium, and lead); SVOCs (benzo(a)pyrene, bis(2-ethylhexyl)phthalate, and isophorone); and VOCs (chloroform and acetone). The sediment sampling indicated elevated levels of metals (arsenic, barium, cadmium, chromium, lead, manganese, and zinc); SVOCs (anthracene, benzo(a)pyrene, bis(2-ethylhexyl)phthalate, carbazole and fluoranthene); and the VOC acetone.
The RFI activities were performed in accordance with the RFI work plans (Phase I in 1993 and Phase II in 1995) and approved by Ohio EPA. The areas investigated during the RFI include the main 18-acre drum processing facility (SWMUs S101 through S108), the noncontiguous 10-acre former drum storage areas (SWMUs S109 and S201), and Unzinger Ditch.
Additional investigation of Unzinger Ditch was conducted from late 2000 through early 2001. Sampling of Unzinger Ditch found elevated levels of metals (lead, chromium and zinc) and the SVOC bis(2-ethylhexyl)phthalate in the stream’s sediment. Ohio EPA Division of Surface Water also published a report on Feb. 12, 2001, summarizing the ecological survey of the stream titled “Biological and Sediment Quality Study of Unzinger Ditch.”
The RFI Report was approved by Ohio EPA on March 13, 2009. The RFI risk assessment evaluation showed that the site contamination posed unacceptable risks and/or hazards to human and ecological receptors and that there is a need for clean-up actions. The exposure risks associated with the site result from direct contact and/or ingestion of contaminated soil, sediment and ground water.
The Corrective Measures Study (CMS) was approved by Ohio EPA on June 24, 2009. A total of 11 clean-up alternatives were assessed in the CMS: four for soil, four for sediment and three for ground water.
The Ohio EPA has prepared a Preferred Plan for the proposed clean up of the site. The Preferred Plan summarizes information from the RFI and CMS Reports; identifies and explains the selected clean-up alternative and solicits public review and comments. The selected clean-up alternative is a combination of three of the 11 alternatives discussed in the CMS and addresses the three contaminated environmental media, soil, sediment and ground water.
Attachment 4: 2008 Risk Assessment Assumptions Document
Attachment 5: 2009 RFI Report
Attachment 6: 2009 RFI Report Appendices
Attachment 7: 2009 RFI Report Figures
Attachment 8: 2009 RFI Report Tables
Attachment 9: 2009 RFI Report Addendum
Attachment 10: 2009 CMS Report
Attachment 11: 2010 Preferred Plan
Attachment 12: 2010 Preferred Plan Attachments
Attachment 13: Preferred Plan Fact Sheet
Attachment 14: 2010 Decision Document
Photograph 1: Main plant entrance, looking northeast, Dec. 9, 2002.
Summary date: March 2010