Division of Emergency and Remedial Response
Site Cleanup Summary
NEWARK PROCESSING
Background
Newark Processing was a secondary aluminum recycling facility. In 1980, they began operations at the 66-acre East Main Street facility adjacent to the Licking River. They ceased operations in late 1996 due to bankruptcy.
Newark Processing processed aluminum dross, which is a by-product of primary and secondary aluminum smelting. Dross consists of varying concentrations of aluminum, aluminum oxides, free metals, and salts. They received the dross from several aluminum smelting companies and processed it on a tolling basis.
Newark Processing received two types of dross: (1) white dross, which contained a high enough aluminum content to be fed directly into a rotary furnace for smelting, and (2) black dross, which needed to be processed through a wet mill to concentrate aluminum before smelting. Both the furnaces and wet mill generated by-products (saltcake and dross fines, respectively) that were stockpiled on-site. The by-product from the wet mill was screened by size, and the larger particles were recovered and reprocessed. The smaller particles flowed to a series of cement-lined settling ponds. The sludge that accumulated in these ponds was called “dross fines.” The dross fines that accumulated in the settling ponds were periodically removed and stockpiled on-site. Newark Processing claimed that the dross fines would either be re-processed or sold.
At the time of its bankruptcy, Newark Processing estimated that approximately 374,000 tons of dross fines and 175,000 tons of aluminum dross remained at the site.
Regulatory Status
Several efforts were made in the 1980s to determine the regulatory status of the material stockpiled on the site. On September 16, 1980, Newark Processing applied for a Part A permit under the federal Resource Conversation and Recovery Act (RCRA) because of uncertainty regarding their regulatory status under federal law; however, on September 13, 1982, it withdrew the Part A permit application. On April 1, 1985, Ohio EPA Division of Solid and Hazardous Waste Management (DSHWM) re-evaluated the federal regulatory status of the material. DSHWM determined that the incoming dross was not regulated under RCRA, and the dross fines were not regulated under state solid waste regulations because Newark Processing intended to recycle or reuse it.
On May 13, 1986, Ohio EPA Division of Water Pollution Control informed Newark Processing that it had violated water pollution regulations. On June 6, 1988, Ohio EPA issued Director’s Final Findings and Orders (DFF&Os) to Newark Processing for these violations. The DFF&Os found that (1) wastewater was being discharged to an impoundment, bypassing the enclosed recycle system; (2) the recycle pits were overflowing; (3) aluminum oxide (i.e., dross and dross fines) was being stockpiled that contained aluminum nitride, which hydrolyzes in water to create ammonia; (4) leachate outbreaks were occurring on the bank of the Licking River; and (5) pollutants were being discharged to waters of the state without a National Pollution Discharge Elimination System (NPDES) permit. The DFFOs required that Newark Processing (1) stop bypassing the settling lagoon system; (2) monitor surface water in the Licking River and Shawnee Run; and (3) submit monitoring data to Ohio EPA on a monthly basis. Newark Processing complied with the DFF&Os until October 1996, when it ceased operations.
On June 8, 1995, Ohio EPA Division of Surface Water (DSW) inspected the site and documented that the Licking River was eroding toward the stockpiled material. They also noted dross in the Licking River. DSW requested that Newark Processing obtain a storm water permit. On June 21, 1995, Ohio EPA issued an NPDES storm water permit to Newark Processing, which expired in April 1996. On April 9, 1996, DSW requested that Newark Processing submit a storm water prevention plan, Newark Processing complied with the request.
On February 24, 1997, Newark Processing informed DSW that it was going to file for bankruptcy. DSW asked Ohio EPA’s Division of Solid and Infectious Waste Management (DSIWM) if Newark Processing was subject to solid or hazardous waste regulations because the stockpiled material was no longer going to be recycled or sold. DSIWM replied that if Newark Processing did not want the stockpiled material, it may be subject to solid or hazardous waste regulations. In March 1997, Newark Processing filed for Chapter 7 bankruptcy.
On November 11, 1997, the AGO filed a claim with the bankruptcy court on behalf of the state of Ohio. On April 17, 2002, the bankruptcy court awarded Ohio EPA approximately $300,000.
On June 8, 2001, Ohio EPA Division of Emergency and Remedial Response (DERR) evaluated the site under the federal Comprehensive Environmental Response, Compensation and Liability Act (i.e., CERCLA) and submitted a pre-CERCLIS screening assessment to U.S. EPA. DERR recommended a no further remedial action planned (NFRAP) determination due to a score of less than 28.5 and no observable impacts to potential receptors. U.S. EPA gave Newark Processing a NFRAP determination on June 27, 2001.
Investigation Summary
In addition to determining the regulatory status of the site, several attempts were made to characterize the material stockpiled on site.
In 1980, Newark Processing analyzed the material stockpiled on site at the request of Ohio EPA. Metals and ammonia were detected in the sample; however, Ohio EPA concluded that the stockpiled material did not require regulation. On February 28, 1991, Newark Processing sampled the dross fines for total metals, pH, percent solids, and chlorides. Results indicated relative high metal content with a pH of 9.6; however, no conclusions were drawn from this data. On January 8, 1992, Newark Processing sampled the aluminum dross fines for organics and metals using the toxicity characteristic leaching procedure (TCLP). All organics were below detection limits. Barium, cadmium, chromium, lead, were detected, but the concentrations were below the TCLP regulatory limit (i.e., the material was not a characteristic hazardous waste). On April 29, 1994, Newark Processing sampled dross fines for total metals. The results indicated high metal content; however, no conclusions were drawn from this data.
In May 1999, at the request of Ohio EPA through the AGO and bankruptcy court, the Newark Processing bankruptcy trustee contracted URS Greiner Woodward Clyde (URS) to conduct an investigation of the stockpiled material and ground water. URS conducted the investigation on May 4 and 5, 1999. URS installed eight direct push (GeoprobeTM) borings, collected surface and subsurface dross samples, and collected a composite dross sample of the West Dross Pile.
URS analyzed the material for metals. Results indicated high metal content in the waste material but all concentrations were below the TCLP regulatory limit. High concentrations of ammonia and chloride were detected, and the pH range was 7.9-10.5. URS analyzed the ground water samples for total and dissolved metals, pH, ammonia, chloride, and fluoride. Ground water samples indicated arsenic, barium, cadmium, nickel, selenium, and fluoride were above their respective maximum contaminant levels (MCLs) for drinking water. Also, high ammonia and chloride concentrations were detected.
URS stated the following conclusions: (1) the stockpiled material throughout the site was similar in physical and chemical composition; (2) the material was not a characteristic hazardous waste; (3) the waste material was not leaching significant concentrations of metals to ground water; and (4) the waste material could be treated as a solid waste.
In 2004, the city of Newark contracted Civil and Environmental Consultants, Inc. (CEC) to complete a Phase II investigation of the property using the $300,000 in bankruptcy funds that had been awarded to Ohio EPA. In addition, Ohio EPA contributed resources (personnel, GeoprobeTM, and monitoring well installation) through a grant from U.S. EPA.
CEC and Ohio EPA collected samples of soil, dross, dross fines, ground water, surface water, and sediment. Ohio EPA also assessed macroinvertabrate communities in the Licking River and Shawnee Run. All environmental media were analyzed for metals, ammonia, nitrate-nitrite, and volatile organic compounds and all dross stockpiles were analyzed for dioxins.
The sample results were compared to the Ohio EPA Voluntary Action Program generic standards. The highest contaminant concentrations detected are summarized in Table 1. It was determined that (1) no contaminant detected in soil, dross, or surface water/sediment exceeded generic standards; (2) ground water exceeded unrestrictive potable use standards for ammonia, selenium, and nitrate-nitrite; (3) multiple chemical adjustment indicated the dross and soil exceeded property-specific applicable standards for some complete pathways (e.g., direct contact with ground water and direct contact, inhalation, and ingestion of dross and impacted soil); and (4) no biological impairment was indicated in the Licking River and Shawnee Run.
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Table 1
Maximum Contaminant Concentrations
2004 Phase II Data
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COC
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Dross
(mg/kg)
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Subsurface Soil
(mg/kg)
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Surface Soil (mg/kg)
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Ground Water
(mg/l)
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Surface Water
(mg/l)
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Sediment
(mg/kg)
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Aluminum
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229,000
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39,000
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185,000
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<0.2
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1.260
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9910
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Barium
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1720
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188
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392
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0.384
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0.0420
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65.7
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Cadmium
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12.8
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0.91
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7.73
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<0.01
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<0.01
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0.574J
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Chromium
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1070
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133
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356
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<0.1
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<0.02
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39.3
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Cyanide
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6.01
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0.769
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1.7
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0.0323
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<0.01
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<1.01
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Fluoride
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1430
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189
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202
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73.1
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0.19
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9.33
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Nickel
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473
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34.5
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188
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0.0393
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0.0065
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16
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Selenium
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46.5
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11
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42.8
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0.116
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<0.1
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<8.53
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Zinc
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4370
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517
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2360
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0.0632
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<0.02
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155
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Lead
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2040
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NS
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NS
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NS
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NS
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NS
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Ammonia
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1030
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1400
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56.9
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2700
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2.24
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34.1
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Nitrogen
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220
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950
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65
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75.1
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2.45
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NS
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Dioxin
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.004855*
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|
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|
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NS=Not Sampled
*Total of 10 dioxin congeners detected in one sample at West Pile with total toxic equivalency factor of 212.3.
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Potential Ecological Effects
Because the high metallic content of the dross may adversely impact sediment-dwelling organisms as it enters the river, Ohio EPA utilized the document, Development and Evaluation of Consensus Based Sediment Quality Guidelines for Freshwater Ecosystems (MacDonald et al, 2000), to determine the potential impact to sediments. This document provides consensus-based “threshold effect concentrations” (TEC) and “probable effect concentrations” (PEC) for metals and organics in sediment. The TEC is the concentration in sediment below which harmful effects will not likely be observed. The PEC is the concentration above which harmful effects are likely to be observed. Therefore, the concentration of metals at or above the PEC indicates the sediments are polluted and would adversely impact organisms. Table 2 summarizes the comparison of the concentrations of metals in the dross piles adjacent to the Licking River to the TEC and PEC.
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Table 2
Sediment Ecological Based Quality Standards for Metals (mg/kg)
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Metal
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TEC
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PEC
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Sediment (2004)
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Dross Range**
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Cadmium
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0.99
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4.98
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0.574
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0.64-12.8
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Chromium
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43.4
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111
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39.3
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123-523
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Copper*
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31.6
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149
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NA
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1763-84,600
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Lead
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35.8
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128
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NA
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234-2040
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Mercury*
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0.18
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1.06
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NA
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0.2-0.26
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Nickel
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22.7
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48.6
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16
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63.2-337
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Zinc
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121
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459
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155
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599-4370
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* Copper and mercury were not analyzed in Phase II Investigation; used URS (1999) data.
**Data from east and south piles, which are adjacent to Licking River
NA=not analyzed
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As shown in Table 2, the metal concentrations in the dross are much higher than the TEC and PEC. Continued erosion of the waste dross will increase the overall metallic concentration in the sediment and adversely affect sediment dwelling organisms.
Licking River Bank Stabilization Project
In 2004, Ohio EPA noted that the Licking River was beginning to erode into the stockpiled material. The material is not as resistant to erosion as native soil and prior attempts by Newark Processing to stabilize the bank had been breached. In 2005, the Ohio EPA decided to approach the United States Army Corp of Engineers (USACE) for assistance due to their expertise with designing and constructing stream bank stabilization projects.
A memorandum of agreement was signed between Ohio EPA and USACE on December 14, 2006 and a support agreement on March 14, 2007. On April 16, 2007, Ohio EPA provided USACE $2.8 million dollars for the stabilization project.
To commemorate the 37th anniversary of Earth Day, Ohio EPA Director Chris Korleski hosted a media event in Newark with the USACE and the city of Newark on April 20, 2007. USACE contracted TAB Construction of Canton, Ohio to complete the work. Surveying, engineering and design of the bank stabilization features were completed by August 2007. Construction was delayed during 2007 due to access issues. The final surveying and design work were completed during January-February 2008. Construction began in March 2008.
The first phase of construction was completed in July 2008, a month ahead of schedule and 20% under budget. The first phase consisted of the construction of a stone slope along the north bank of the Licking River at the site. The remaining funds were used to protect the west end of the site from erosion by a small stream, Shawnee Run, build a fence around the perimeter of the site, install a culvert under the existing road that crosses over Shawnee Run, and plant trees and grass at the top of the stone slope. These projects were completed in September 2009.
Clean Ohio Fund
In July 2009, the city of Newark applied for a Clean Ohio Revitalization Fund grant. On November 20, 2009, the City received a $2 million grant to grade and cap the exposed aluminum dross at the site.
Photograph 1: Erosion of the site by the Licking River in 2004.
Photograph 2: Erosion of the site by the Licking River in 2005. Note the partial disappearance of the road as seen in the 2004 photograph.
Photograph 3: Erosion of the site by the Licking River in 2007. Note the disappearance of the road and the monitoring well as seen in the 2005 photograph.
Photograph 4: Erosion on the site by the Licking River in 2008.
Photograph 5: Media event hosted by Ohio EPA on April 20, 2007.
Photograph 6: Artist’s rendition of the river bank once the stabilization project is complete.
Photograph 7: Looking west at the stone slope of the stabilization project, July 2008.
Photograph 8: Looking northwest from river level at the stone slope, July 2008
Photograph 9: Erosion protection on the east bank of Shawnee Run, July 2008
Photograph 10: The new culvert beneath the access road over Shawnee Run, November 2009
Photograph 11: Trees and grass planted at the top of the stone slope erosion control feature, November 2009.
Summary date: December 2009
For further information on this site, contact:
Fred Myers
Ohio EPA, Central District Office, DERR
PO Box 1049
Columbus, OH 43216-1049
(614) 728-3830
Also see PIC’s Newark Processing media kit