PROJECT OVERVIEW
EXIDE BANKRUPTCY AND ESTABLISHMENT OF THE EXIDE ENVIRONMENTAL RESPONSE TRUST
The former Exide Technologies facility located at 555 North Hoke Avenue in Frankfort, Indiana operated from 1963 (and possibly earlier) to 1997 as a lead-acid battery manufacturing and distribution facility. Other manufacturing operations may have occurred onsite dating back to the early 1900’s.
Exide Holdings, Inc. filed for Chapter 11 debt relief in May 2020. In Bankruptcy filings, the Frankfort facility was designated as a non-performing property (NPP). The Exide Environmental Response Trust was created by an Environmental Trust Agreement within the framework of the Bankruptcy and is not affiliated with the former Exide Company or its former officers.
As part of the Consent Decree and Settlement Agreement entered by the Bankruptcy Court, ownership of the former Exide facility was transferred to the Trust. The Trust is responsible for paying the property taxes and performing all activities at the Site necessary to maintain compliance with applicable environmental permits and rules.
The Trust will fund remedial activities at the Site until the property is sold, at which point the new owner will take over the remedial activities, or until the Trust Fund is depleted.
EXIDE ENVIRONMENTAL RESPONSE TRUST
The Exide Environmental Response Trust was created following Exide's Bankruptcy and became effective on October 26, 2020. The Trust is not affiliated with Exide Technologies. The Trust is a bankruptcy court-appointed entity that manages the funds set aside during the Bankruptcy to address environmental operations and remediation at numerous former Exide facilities throughout the United States. Each facility has been assigned a portion of the Trust funds to address contamination created by Exide Technologies as a result of their operations.
The EPA and Indiana Department of Environmental Management (IDEM) are beneficiaries of the Exide Trust for the Frankfort facility and EPA is the Lead Agency for the Site.
FACTS ABOUT ENVIRONMENTAL CONDITIONS AT THE FORMER EXIDE TECHNOLOGIES FACILITY
The Site previously was comprised of lead-acid battery manufacturing operations. Battery manufacturing operations ceased in 1997 and the Site was used by Exide for equipment and document storage until a building demolition project was completed in January 2013. The Site is currently vacant.
The Facility is inaccessible due to a perimeter security fence and locked gates. The Site is monitored by the Trust’s contractor.
The Site encompasses approximately 13.7 acres. Approximately 12.1 acres are enclosed by a perimeter security fence and the majority of this area consists of intact asphalt pavement and remnant concrete floor slabs from the former buildings. The remainder of the Site is an open grassy area outside of the fence on the north side of the Site.
Stormwater from the paved surfaces is collected by a combination of on-site and off-site stormwater inlets that convey water to an unnamed tributary of the Prairie Creek located approximately 300-feet north of the Site. In 2019, Exide installed filter fabric in on-site stormwater inlets as well as silt sock along portions of the Site to limit sediment transport.
Unconsolidated groundwater in the region (Tipton Complex Aquifer) is typically encountered at a depth of 200 – 400 feet below ground surface (bgs). Impacted perched water observed in the on- and off-site monitoring well network has been observed at a depth of approximately 10-feet bgs. However, the Site is not located within an area supplying a public water system.
Since the demolition project concluded in January 2013, Exide had undertaken various steps to address the remaining environmental concerns at the Site. This included:
Removal of underground storage tanks (USTs) associated with heating oil and fuel;
Remediation of soils associated with historic UST releases;
On-site investigations associated with site contaminants of concern (COCs) utilizing on-site soil borings, perimeter surface soil sampling, camera inspection of on-site stormwater piping, sampling of on-site manholes and stormwater piping, installation of on and off-Site monitoring wells.
The Primary Contaminants of Concern (COCs) for the Site related to battery manufacturing are lead and arsenic. These inorganic COCs have been detected in shallow soil samples collected on-site. However, in locations that exceed IDEM industrial standards, the soil is covered by pavement. The Trust and EPA are evaluating whether removal of soils affected by lead and/or arsenic is necessary as these COCs do not have a clear direct exposure pathway for the public.
During UST removal, chlorinated solvents such as Trichloroethene (TCE) and related compounds associated with the degradation of TCE were encountered. During Exide’s Site Investigation, these compounds and others related to petroleum-based fuels were encountered in groundwater samples collected near Kelley Avenue. The next phase of the investigation work is focused on addressing this location.
In mid-October 2021, the Trust implemented an EPA-approved work plan to conduct field activities on and adjacent to the Site in order to collect groundwater, surface water, soil, and soil vapor samples in order to assess the presence and/or movement of contaminated impacted media (soil, groundwater, surface runoff) in the surrounding areas. Follow-up groundwater monitoring and related activity was performed in December 2021 and March 2022.
The Trust has prepared, and EPA has approved, an Interim Measures Workplan to address subsurface impacts onsite. Field work associated with the Interim Measures is anticipated to begin in the near future.