The Former Cleveland Plant in Ohio —an experimental research facility for manufacturing mustard agent and magnesium arsenide during World War I —is now in the phases of project closeout after almost two decades of environmental investigations at the site.
In May, the U.S. Army Corps of Engineers Louisville District signed a Decision Document for the former Cleveland Plant recommending No Department of Defense Action Indicated (NDAI) after studies showed that no risks to human health or the environment were identified, no remnants persist either on the surface or subsurface such as buried drums and that ultimately no remedial action was necessary.
“Partnering between the Louisville District, the Ohio EPA, the Huntsville Center Ordnance & Explosives Directorate, and the community, as well as following the CERCLA process, have contributed to the successful completion of this project,” said Theresa Beckham, project manager, Louisville District. “This effort included diligent involvement of several project managers and PDT members over the years.”
The former Cleveland Plant, established in 1918 by the Chemical Warfare Service, was strictly a research facility and mustard was only produced at the Cleveland Plant from April to October for the purpose of developing and testing the equipment needed to produce it. Operations ceased after the war armistice was signed in 1918 and the property is now privately owned and used for light industrial and commercial purposes.
Since 1997, USACE conducted a number of investigation activities at the site, including initial assessments and gathering and analyzing historical photos. An Engineering Evaluation/Cost Analysis (EE/CA) was performed to characterize the nature and extent of any concentrations of suspected mustard agent, mustard agent breakdown compounds, or magnesium arsenide that were found; it was also, if necessary, to recommend an appropriate cleanup alternative.
During the EE/CA, 22 anomalies were investigated as possible disposal locations and trenches were excavated to investigate. Soil samples were collected from the anomalies and none of the samples had detections for mustard agent. Some samples showed arsenic and manganese at five locations, which are naturally occurring elements that have both been used for industrial and commercial products.
The remedial investigation was completed in 2013, which found no evidence of burial activity during the use of the site by the Department of Defense. There was also no evidence of DOD-caused contamination at the former Cleveland Plant, so there is no site risk from the DOD activities.
The Louisville District selected the response of No Further Action in accordance with Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, and the National Oil and Hazardous substances Pollution Contingency Plan (NCP). Ohio EPA concurred with USACE’s determination. The decision for the former Cleveland Plant was completed after publishing the
Proposed Plan for public comment and holding a public meeting in the fall of 2014 and the close of the public comment period during which no comments or feedback were received.
Because the No Further Action decision allows for unlimited use and unrestricted exposure, a statutory review of the protectiveness of the selected remedial action will not be required. Additionally, five-year reviews will not be required.