Mixed-Use Redevelopment in Indiana at the Continental Steel Superfund Site in Kokomo, Indiana
Source: Case Study provided by United States Environmental Protection Agency
In Indiana, Kokomo city government led the successful redevelopment of the Continental Steel Superfund site. Once an abandoned steel manufacturing plant, the site now serves as an excellent model of mixed-use redevelopment supporting recreational soccer facilities, solar energy production, flood mitigation, road improvements and boat ramp access.
Introduction
Beginning in 1914, steel manufacturing operations thrived in an industrial area north of Indianapolis. At one point, the Continental Steel Corporation was the largest employer in Kokomo, Indiana. The plant produced nails, rods, wire and fencing from scrap steel. The corporation continued to operate through the Great Depression and provided materials for the military during the Second World War. For nearly 70 years, facility operations contaminated the site and nearby soil, sediments, surface water and groundwater. A stream was left polluted and lead was found in nearby residential yards. The corporation declared bankruptcy and closed in 1986.
In 1989, EPA listed the site on the Superfund program’s National Priorities List (NPL). A long-term environmental cleanup by EPA and the Indiana Department of Environmental Management (IDEM) followed. Today, the site is now a valuable community asset. This case study tells the remarkable story of the cleanup and reuse of the Continental Steel Superfund site.
Returning the site to productive use was a long road for the community. As a major employer in the region, the impact of the shuttered Continental Steel factory was felt across Kokomo. The scope of the cleanup over nearly two decades required persistence and flexibility on the part of local leaders and agency partners. Kokomo city government (the City) worked diligently to plan for redevelopment, leveraging resources and forging partnerships. By planning for redevelopment during the cleanup, forward-thinking decisions laid the groundwork for the site’s successful redevelopment of the blighted land and provided new hope for the community.
Today, the site has been cleaned up and returned to a range of beneficial uses. The Wildcat Creek Soccer Complex provides recreation opportunities. A solar energy array provides enough energy to power up to 1,000 homes. Cleanup of Wildcat Creek allowed for flood mitigation and boat ramp access. In turn, improved water quality means that people can once again fish and canoe in the area. Other redevelopment outcomes at the site include a storm water retention pond, wind turbines, landscaping and road infrastructure improvements.
This case study explores the tools and partnerships that have led to successful cleanup and mixed-use redevelopment of the Continental Steel Superfund site. The following pages trace the evolution of cleanup and reuse efforts, highlighting the Kokomo city government’s leadership, project partnerships, and coordination of remedy and reuse considerations. The case study provides information and lessons learned for parties interested in Superfund site redevelopment, municipal improvements, recreation-based land revitalization and solar energy development.
Steel production took place on site for over 70 years. During the Second World War, the Continental Steel Corporation produced barbed wire, nails and sheet steel for military use and provided bulk material for products manufactured by defense industries. These products included fuel containers, bombs and landing mats for air strips. It is believed that steel produced at the plant provided material for the Golden Gate Bridge and fencing for the world’s fair in Chicago. Facility activities ranged from melting scrap metal to manufacturing finished products from start to finish. Operations included reheating, casting, rolling, drawing, pickling, annealing, hot-dip galvanizing, tinning and oil tempering. Facilities at the site included stock yards, water towers, rail yards, soaking pits, acid lagoons and 64 buildings. The buildings included mills, offices, laboratories and factories.
Improper materials handling and waste disposal practices and regular facility operations at the 183-acre site resulted in extensive contamination of soil, sediments, surface water and groundwater with volatile organic compounds (VOCs), polychlorinated biphenyls (PCBs) and several metals, including lead, arsenic, cadmium and chromium. Sampling also detected lead contamination in some nearby residential soils. EPA placed the site on the NPL in 1989. To address immediate risks to the surrounding community, IDEM and EPA removed and treated contaminated soils, oil and buried drums. By 1992, removal actions were complete. The agencies also decontaminated an abandoned chemical laboratory and dredged the lagoon and creek areas. In 1996, EPA and IDEM signed an agreement to decontaminate and demolish buildings in the main plant area, including asbestos abatement. In 1998 EPA issued a Record of Decision that selected the site’s long-term remedy. To manage the cleanup, EPA divided the site into six areas, or operable units (OUs), and chose a remedy for each area:
EPA and IDEM led the 12-year cleanup. During cleanup, the agencies worked with the community and developers to support the return of parts of the site to productive use (see page 3). The $40 million cleanup finished in 2011. Groundwater treatment and monitoring is ongoing. IDEM will take over management of the treatment system and some other operation and maintenance responsibilities in 2021. The City will also be responsible for some of the operation and maintenance responsibilities at the site.
Initial Reuse Considerations and Site Acquisition
When the Continental Steel Corporation closed its doors in 1986, it left behind a vacant, contaminated property. After EPA placed the site on the NPL in 1989, a decade of site investigations, interim cleanups and long-term cleanup planning followed. Throughout the process, Kokomo city government played an active role in planning for the site’s reuse, with the City’s development department considering options even before the locality acquired the site property. Demolition and decontamination of the plant began in 1999. At the time, there was growing interest in reuse and revitalization of contaminated lands nationwide. EPA began offering pilot grants to support community-based reuse planning efforts in each of EPA’s 10 regions. The City applied for and received one of EPA’s second-round pilot grants in 2001 – it provided $100,000 for site reuse planning efforts. EPA Region 5 Superfund Redevelopment Coordinator Tom Bloom recalled what set the community apart from other applicants. “It was remarkable, the City had such an organized development department that their proposal didn’t call for any administrative expenses,” he said. “All of the pilot money would go toward producing a conceptual plan. That really caught our eye.” Grant money was used to hire consultants to work with the community to determine what they would like the site to look like.
Integrating Cleanup and Reuse Considerations
The City finalized the site’s reuse plan in 2004. Though not outlined in the site reuse plan, later redevelopment focused on OU5, the former main plant area, as a solar energy facility. It also called for development of a soccer complex on OU2, the former lagoon area. Coordination with EPA and IDEM meant that the conceptual plan took site features and cleanup considerations into account. With half of the site located in a floodplain, for example, it called for adequate backfill and drainage to make sure that flooding would not impact site reuses. EPA and IDEM expertise also helped inform the plan’s development. “A similar site in Indianapolis had just completed a solar project,” recalled IDEM project manager Jessica Fliss. “We also knew of a site where soccer fields had been successfully installed over a 24-inch cover without an engineered cap.” A follow-on traffic study by the City in 2005 enabled the local government to incorporate road and stormwater management infrastructure enhancements into the remedy. As cleanup moved forward, EPA and IDEM highlighted areas as they became available for reuse. However, it would take more than a decade for reuse to flourish. The City first needed to work with Howard County and EPA to address its environmental liability concerns. City Acquisition of the Site Property In 2013, the City acquired the site property for $5,000 from Howard County at a special commissioners’ tax certificate sale. The transaction marked the end of nearly 10 years of legal discussions between the City, Howard County and EPA to make sure the locality was protected against potential environmental liabilities. EPA provided the City with comfort letters specifying that the site’s remedy was compatible with planned uses. “There was an abundance of caution. Liability after contamination was a big issue for the City to deal with,” city engineer Carey Stranahan recalled. “Ultimately, the City decided it would have to acquire the site in order to put the land back into use. The City stepped up as a leader.” Within three years, large parts of the site would be returned to beneficial use. The next section discusses how cleanup and reuse considerations came together for each part of the site.
“This isn’t just a story about turning a contaminated site into a solar plant. The City worked hard and didn’t give up. Their long-term thinking led to recreation and business opportunities as well as the elimination of flooding through their thoughtful planning of the remedy and reuse. The result is an impressive example of a site with multiple reuses.”
– Tom Bloom, EPA Region 5
Superfund Redevelopment Coordinator
Site Reuses, by OU
OU1 (Site-wide Groundwater)
In 2009, EPA received almost $6 million in American Recovery and Reinvestment Act (ARRA) funding, accelerating groundwater cleanup and providing local employment. In total 15 Indiana contracting firms were involved, creating at least 45 short-term jobs. Today, three wind turbines provide up to 60 percent of the energy needed to power the groundwater extraction system. Other redevelopment improvements for OU1 included a traffic system redesign that was put in place at the same time as the groundwater extraction system. A traffic circle at the junction of Markland Avenue and Park Avenue improves the flow of traffic at one of the busiest intersections in the area and helps address flooding concerns. The $2 million circle helps the flow of traffic by removing the need for a traffic signal. As outlined in the site’s soil management plan, the circle’s raised design meant that contaminated soil could be left undisturbed under a cover. During construction, the City also added new trees and landscaping to the area.
OU2 (Lagoon Area)
Toward the end of the OU2 cleanup, the City unveiled reuse plans for a 60-acre soccer facility – the Wildcat Creek Soccer Complex. Coordination with EPA and IDEM meant that after the cleanup was finished, the agencies planted the right kind of turf grass for the soccer fields over the cap covering residual soil contamination. The Indiana Office of Tourism Development awarded the Kokomo-Howard County Convention and Visitors Bureau a $50,000 grant to build a facility with a concession stand, bathrooms and storage for maintenance equipment. Project stakeholders believe the facility will enhance recreation and outdoor opportunities in the community. “For decades to come, the Wildcat Creek Soccer Complex will serve Kokomo and the region’s demand for youth soccer facilities,” said Kokomo Mayor Greg Goodnight. “Our community has waited a long time for this land to be put back into use, and I could not have imagined a better outcome.” Plans for the Complex include 30 full-size playing fields and vehicle parking and may include a future connection to the Wildcat Creek Walk of Excellence recreation trail. The Kokomo Soccer Club will lease the Complex when construction is complete. To date, four full-size fields, parking lots and a concession stand have been built. The Kokomo Soccer Club held the first youth soccer match at the Complex in October 2015. Future enhancements could include additional walking trails and more parking.
OU3 (Wildcat and Kokomo Creeks)
Cleanup at OU3 involved creek cleanup and flood mitigation. Dredging the creeks for contaminated soil improved water quality and reduced PCB levels in fish tissue samples. The community now uses the creek for recreation. “Before you would have never even thought about going near the creek, let alone fishing in it,” said city engineer Carey Stranahan. “The cleanup helped to improve water quality and meet regulatory standards. People practice catch-and-release fishing and schools use the creek for canoeing. The City is working on a riverwalk path downtown and having a clean creek really helps with that. The creek is now a community asset rather than an environmental burden.” After the creek cleanup, a boat ramp and parking area were put in to facilitate access to the water. A joint effort by the Wildcat Guardians, the City, Martin Marrieta Aggregates and the Northern Indiana Public Service Company (NIPSCO) made the project possible. The City owns the land and contributed materials and labor to build the access point. Martin Marrieta Aggregates provided materials and NIPSCO contributed $5,000 through its Environmental Action Grant program. The Steel Mill Public Access Point is located on Park Road, south of the intersection of Park and Markland avenues. The area includes a gravel parking lot and walkway to the creek for fishers, kayakers, canoeists and other outdoor recreation enthusiasts.
OU4 (Markland Quarry)
Redevelopment success at the former Markland Avenue Quarry is providing a range of benefits, and is also the result of sustained local, state and federal coordination. At the time of the cleanup, the City was building a retention pond in another location to separate stormwater and raw sewage. The City needed a place to dispose of the unwanted fill material left over from the pond installation. At the same time, EPA and IDEM needed material to fill the deep quarry. EPA was able to use the fill, saving the City the time and expense of disposing of the material. Using the fill material saved EPA an estimated $5 million and accelerated the cleanup schedule. Final plans called for grading the former quarry area so that a stormwater retention pond could be located there. OU4 cleanup finished in 2009. Today, this pond, collects clean stormwater, helping to mitigate flooding in an area that has experienced two 100-year floods in the last two decades. IDEM worked with the City to plant prairie grasses, native plants and trees on the property.
OU5 (Main Plant Property)
In June 2016, the Kokomo Plan Commission approved construction of a $9 million solar array on 25 acres at OU5. Inovateus Solar and Alterra Power Corp. coordinated closely with the City, IDEM and EPA on the project’s design and construction to make sure it was compatible with other site uses and the site’s remedy; the solar array began operating in December 2016. The array consists of over 21,000 fixed photovoltaic panels, making it one of the largest solar arrays in Indiana. Alterra manages the project and sells the energy produced to Duke Energy Indiana under a 20-year power purchase agreement. The array has a capacity of 7.2 megawatts and produces about 9.1 million kilowatt-hours of solar energy a year, enough to power up to 1,000 homes. Inovateus Solar and Alterra Power Corp. identified the site for the solar project because of its existing energy infrastructure, the area’s high energy demand and the community’s support for the project. To address the developers’ concerns about the site’s Superfund status, EPA and IDEM helped them understand the cleanup and how to adapt their approach to fit with remedial constraints on the property. EPA also issued a comfort letter for future owners or leasers. A restrictive covenant limits operator liability as long as the cap is maintained and any work on the site is pre-approved. To gain approval, developers had to ensure the solar panels would not disturb the 18-inch soil cap that was part of the site’s remedy. Inovateus Solar worked with EPA to design a racking foundation for the solar panels that minimized their impact on the cap. The panels are mounted to a single-axis tracking system, allowing them to follow the sun’s path throughout the day. Today, the solar array has revitalized part of the site that was vacant for decades; it now provides long-term economic benefits for the City. The City receives revenue from the facility’s $36,000 annual lease agreement and saves money in reduced maintenance costs as well. Inovateus Solar is responsible for maintaining the cap, mowing the grass and regularly checking the solar array. The area is fenced; cameras enable remote monitoring of the area. Based on community feedback, EPA also retained and reinforced a wall in the northeast corner of OU5. The wall provides a privacy screen and serves as a reminder of the plant’s history.
OU6 (Slag Processing Area)
The former slag processing area at OU6 has been cleaned up. It is the only OU at the site not yet in reuse. Located next to Wildcat Creek, future uses could include a boat launch or camping area.
Continental Steel Corporation: From Boom to Bust
At the height of its operations, with over 3,000 employees, the Continental Steel plant was the largest employer in Kokomo. The company survived the Great Depression and thrived during the Second World War, producing metal and other products in support of the war effort. At one point, the company produced about 90 percent of nails made in the United States. During the 1960s, the company diversified its operations, producing a wide range of products, including fences, gates, posts, welded wire fabric, nails, wires, clothes lines, rivets and copper steel sheets. The 1970s marked the start of the company’s decline, as it struggled to modernize its facilities and compete in the global marketplace. In 1986, Continental Steel Corporation filed for bankruptcy. More than 700 people lost their jobs.
“When the plant was torn down, it was a big deal. Many retired folks wanted to see it come down. IDEM built a platform for people to sit and observe. It was emotional. The fact that we could help make something positive out of the site after it being a wound for the community for so long, that was a really good feeling. I’m glad we could help make this happen.”
