-------
~age Nc>.
O'j/28/87
. "
SUBjECT
OPERATION ~ IllAI~'TENMtE ~: II£T/W£ GAS V'.NTH13
WELL I~~TALLATIONS & PRELI"INRRY ~ITORING RESULTS
ADr.INISTRAT!VE RECORDS
INDUSTRIAL EXCESS LANDFILL ( IEL )
I'1~H~E GAS VENTI~ DOCUME:N'TS
AUTHOR
PEl ASSOC. & SCS ENGIr£ERS
SCS ENG iNEERS
~ING or PRESSURIZED TOXIC GASES IN ~ZARDOUS ~STE LANDFILLS
PAUL C. RI ZZO
HI Total fH
DATE PiiGES
12/ /86 50
12/11/84 '3
18
77
-------
Page No. 10
03/2BIB7
ADMINISTRATIVE RECOR~S
INDL~TRIAL EXCESS LANDFILL ( !EL )
UN I ONTO;.JN, OHIO
AIR ~ONITORING - ~ETHANE CONTROL
~BJECT
AUTHOR
&lIR ANALYSES : ~E CONTRa.
ENVIRE5~E INC.
AIR ANALYSIS BY GC 1 ~5
CAROL S. KIM & GEORGE KLI~~ER
GAS ~~L EMISSION SA~PLrNG PROPOSAL
WADSWORTH TESTI~G LABO~TORIES
S1JI'fIHRY REKJRT o.~ GAS SAMPLING
SARY GIFFORD
ERi's AIR ~ONITORING GUIDES FOR UNCONTROLLED HAZARDOUS WASTE SITE RODNEY D. TURPIN
1I:lL. INSTALLAilONS AND PRELI!'IINARY ~ONITORi/\b ~5tJLTS
O. E. P.A.
It.~iAl~TION 0; GAS Io'ELLS TO EXTRACT ~ETHA~E
JAY PLUCINSKI
~L!. rNST~UmONS ~~D PREl.I~!~RY /l!iJNlTDRING R£SJLTS
~ E.~Glt£ERS
Co/.FIR:,:,.:r;-ION :'4E~Sr iiB"JL!T MEETING WI SUSAN iIIIJ.E2 & S7E~~~1 REILLY
SiE~hEN ~. REILLY
[;IS lolL.' I~~ST~LhTIQ1. PiPORT
ELDq::DGE 2:3I!\EERIN:i HS20C.
r.ET~'.E RECCrvE~Y sysm; ( TDD#S - 8410 - ::;4 )
ROY F. WESTGN
'+B Tcta~ HI
D:1TE PAGES
1/6-91B6 10
2/3/86 4'j
.,
4/11/85 5
3
12/!!/85 15
B
11/19/84 10
12/25/el!
12/1:/:1, 32
lli27/S4 ! ~
.,)
146
-------
Page No.
09/30/87
i(EC TiiLE
1 PRP ~NTS ON FFS
~ PRP ~ENTS ON FrS
3 PRP ~TS ON FrS
... PUBlIC COMNT
ADNINISTRATlVE RECORDS
INDUSTRIRl EXCESS LANDFILL (lEU
PRP / PlJBL.IC / COMNTS ON FFS
FlREsm.£ TIRE P/iI) RUBBER CO., B. F. 6CD>RlDi, 9/9/87
GOODYEAR
CDlEHTS ON FFS FOR IE!. ca:\RLES KITTINGER, Cba KITTINGER TRLCI
-------
''''~C- ....,.
..
09/30/87
REI: TITLE
"lie:.
U. CO.T'.IIO ~
31 l:.'"TIER: CQNCERNIPot; WATER
-. ,"'\. ..;'\(
(;'."',-L I .
32 N.-CIIS ARTIClE
33 t;E~ AR7IC~E
34 ~E',.I5 ~R;IC'..E
35 :..: I ;I:rl: c:J~ENiS ON IEl.
~ ;~::..;: ::~~G,i."'~;;CN hANDOUT
37 P~2~:: :NFQ~~iION HAN~GUT
33 RS=E~ TO ~!TER
?1 NE"IoiS AR7IQ.E
40 ~r~s ARiIClE
4! ~:;7ER ~,CE~~!~G :GP:CS Ai
~!.JGl.iS: 25, 81 ~iI~
42 LITTER: D:sa.;SION Cf jEt.
I 5SL~S
43 1,£,105 ~RTI CLE
44 ~:77ER: CD,tER~ C!ijZ~
4\5 CD."VERSATI~ RECORD
50 LETTE~: REGARDING FFS
51 ~VERSAT!O~ RE:SF.D: ~ITrl
RICAMRD RASlkSKI
52 LETTE~: CCtjCER~.ED crr:ZE'I
AD"INISTRATIVE RECORDS
INDUSTRI~L EXCESS LANDfILl. lIEU
PRP / PUBLIC / CQIIIENTS ON FFS
DESCRIPTION
AUTHOR
~TE
~
aJNCi:RNIr-:3 ALTE~T1VE ~TER WATER SUPPLY SYSTEM
St.JP~ '(
~7 L:TTER: AlTERNATIVE WATER - 3 /!IILE ~Il.5 WAITR SijPPLY SHOUlD BE
UNrOOOltN, OHIO IJIIPlDIENTED
25 ~ER ~R()I QHIO ~TER 5£RVICI I~7ERST IN SERVI~ l.NIO~OWN, CJ1ID
29 LETTER CG''''!E~~It1G :JUBlII: REQUEST THAT EPA EXTEND CITY IiATER,
roo£HT BRIH6 ~TER FR()I NJRTH CAHT~
30 LETTER FRO:" CITIZEN REGl£ST THAT ALTERNATIVE WATER !iUPRY BE SKR'tt L. cmy
BRC1S1T TO 3 "ILE RAD IUS
IJHOOCU/ sam. WATER WELL,
GR~,OW~ EU-~~THri1 SChOOL ~~LL,
P!..'l:fPISS OF S:~i!C T~S III UNICN:Q'~
. L~I~TOWN PU;:LS ~PCRT TO som. .
. GN:""EN7C\1~ SCFCG~ ;';';i:R P':;S5~3 :E57 .
. r£AI.. TH SU RVEY DE";.A Y S::.f:-IT .
GiNERAL CG~~iS CCrNCER:,!r.G ASPECS CF
WATER CDNTA?!I\~TIC~
~l ';'E;;.,.TIVES 70 r"_':;Z~RjJi:";S M:~SEI"IlD
CJ-eI! CALS
JI" & CAROlYN Q'BRIEN
917/87 '
MER.~ILL 6. SlOfW
VICTOR E. 1T.tif~
9/9/87
'3/10/87'
9/8/B7
C~CTER L. 8ROOI
-------
~ge No.
09/30,67
3
REC TJ -;- ..£
UC
.51 COO/TIN".":
53 ;"::-iER: CCftCEfitIED c: TI Z2f
5~ L£T7~~: CO~RNED C!TIZS~
S5 CIT!Z~ ~TION PLATFO~ FOR
!M)UST~IAL EXCESS LANDF'IU
56 LEiTER: R£5ARD!SG FrS
57 LE7~": RE6ARDlt~ B/~5/B7
~mir;G
58 LETiER: CuNCER~ED CITiZEN
59 :..~T::,~: CONai\:-<~ [17::91
60 _::i~ER: C~;CER\ED CI7!Z::N
Ht Tota: ..t
AD~l~ISTRATlVE RECORDS
INDUSTRI~L EXCESS U\HDFIU lIEU
PRP / PUBLIC / C()t£NTS ON FFS
. DE5CRI~jION
ACT! ON
COCE?N Cf C:.EARl Y !C£~TInED TESTED
k~!..LS
PROiESi ~ROPOSE~ PLAN TO PROVIDE ~TER
AT UNIONTCWN SITE
PfTITICJj: Sl~ BY CITIZENS WANTING
U. S. Eo P. A. TO FOU.CII THIER IUICl.'S
.ATERLINE PROJECT - LAK~RE TO
UN I ONT~N
COO~DIt~ JF Ii!EETlt.G ~N~ FrS
AGAINST U.S.E.~.A ~~ rrS
~G;W"ST r=S
EX~TION OF EPA DECISIONS TO
UNIONi~~ E~:?ENTARY SCHOOL
'.
AUOOR
PETER J. £iJI~
~ILIP SOHDT
CITIZEN ~IZATION
ERJ€ST E. DIRRIG
REP. R~PH REGl.lJ1
LI NDA PUT! NSX I
!'lIKE PUTINSKI
MIKE & L!kDA PUTINSK!
DATE
P~E~
.'
8/31/87
9/I+iB7
8/21/87 '1-4
9/1187
Bi31iBi
9/7 i87
9/ij/B7
9/4/B7
"
~.
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
INDUSTRIAL EXCESS LANDFILL
SITE LOCATION AND DESCRIPTION
The Industrial Excess Landfill is a closed sanitary landfill located in
northeastern Ohio (southeast of Akron, and north of Canton) in the unincorporated
town of Uniontown, in Lake Township of Stark County. It is located approximately
a quarter mile southeast of the intersection of Cleveland Avenue and State
Route 619 (figures 1-1 and 1-2).
The IEL site is located on a tract of approximately 30 acres which had previously
been the site of mining operations (sand and gravel and possibly coal). The
site is relatively flat with respect to the adjacent land on its north and west
boundaries and slopes to the Metzger Ditch to the east and south. The landfill
has a relatively. pervious soil cover. The site is covered with a significant
growth of vegatation and shrubs, especially on its sloped surfaces, and is
partially fenced. About 80 percent of the site is believed to be underlain by
buried solid waste materials. There are over 400 residential homes located
within a 0.5 mile radius of the landfill. Most of the houses are to the north
and west of the site.
Uniontown is one of several communities in the area which has no municipal
water supply. All of the residents rely entirely on individual or private well
supplies. Groundwater resources are available throu9hout Stark County. The
major water-yeilding units for Stark County and the part of Summit County
immediately northwest of .Uniontown are sand and gravel deposits that occur as
glacial outwash filling buried valleys. These thick and permeable sediments
yield as much as 1000 gallons per minute or more to properly constructed
industrial and municipal water wells. In the immediate area of Uniontown,
t~ese outwash deposits are thin or not present and domestic supplies can
locally be secured from wells developed in the poorly sorted sand and gravel
kame deposits. However, the majority of domestic wells in and around Uniontown
obtain water from the upper portion of the underlying Pottsville Group (Mas-
sillon Sandstone and equivalents). The lower part of the Pottsville group, the
Sharon Conglomerate, is an aquifer of moderate to high quality and a few high
capacity industrial wells are developed in this deeper unit.
u
Due to the rolling nature of the topography at and near the IEL site, the depth
to the surface of the water table ranges from zero, at Metzger Ditch, to 55
feet below the top of the hills to the north of the site. A number of domestic
wells near the landfill, including all of the homes and businesses immediately
to the west of the site between the landfill and Cleveland Avenue, tap the sand
and gravel aquifer to their Hater supply. Near the site, these glacial deposits
of sand, gravel, silt, and clay range in thickness from 60 feet to about 200
feet. This range in thicknesses is due to both variation in the surface
topography and variation on the pre-glacial topography carved into the buried
-2-
-------
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INDUSTRIAL
EXCESS!
lANDFill SITE
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INDUSTRIAL EXCESS LANDFILL
STARK COUNTY,OAIO
FiGURE I - I
REGIONAL LOCAilON MAP
NOT TO SCALE
CC.JOHNSON a MA:"'HOTRA,PC.
-------
LOCATION
P LAN
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~ :/ ." LANDFILL
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INOU STRI ALE X CESS LANDFiL~
STARK COUNTY, OHIO
FIGURE I - 2
LOCATION PLAN
APPROXIMATE SCALE 1:20000
c ': ~ C H 'J S C N 8
.\' J. L ~ () 7' ::I A . =' c.
N
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"
,
J
-------
bedrock. The private wells that draw water from this glacial deposit typically
are open to the aquifer some 20 to 60 feet below the top of the water table.
As noted above, the majority of private wells at Uniontown obtain water from
the bedrock. These wells are cased through the glacial deposits and are open
to the bedrock sandstone, siltstone, or shale from 20 to 80 feet below the top
of the bedrock and as much as 160 feet below land surface. Examination of the
drillers logs from private wells near the landfill and logs obtained during
installation of monitoring wells around the site confirm that there are no
laterally continuous low permeability layer or layers within the sand and gravel
or within the upper portion of the bedrock. This finding indicates that, over
long periods of time, the sand and gravel and immediately underlying bedrock at
IEL will act as a single aquifer.
Bedrock in the area of the site consists of the Pennsylvanian age Pottsville
Group. At the area of the site, the upper quarter of one half of this unit has
been removed by erosion. At IEL the Pottsville group consistes of an upper
unit (Massi110n Sandstone and equivalents) of interbedded sandstone, siltstone,
shale and minor limestone. This portion is 50 to 150 feet thick. Below this
is the approximately 150 feet thick Sharon Conglomerate that, in the area of
Uniontown, consists of pebbly sandstone with some interbedded siltstone and
shale.
SITE HISTORY
The property where the landfill is located may have Jeen utilized first as a
coal mine and later was used for mining sand and gravel up until 1961. ~rad-
ua11y the mining pit/excavation was converted into a landfill which received
a variety of municipal, cOOlmercial, and industrial wastes. The site was used
to store fly ash, masonry rubble, paper and lumber scrap between 1964 and 1968.
From 1968 to 1980 the site was operated as Industrial Excess Landfill for the
disposal of a variety of solid waste materials.
Ouri ng thi s time, the 1 andfi 11 accepted muni ci pal, cOOlmerci al, i ndustri a1, and
chemical wastes of substantially undetermined and unknown composition, primarily
from the rubber industry in Akron, Ohio. Large quantities of chemical and
liquid waste were dumped onto the ground either from 55-gallon drums or from
tanker trucks. Although much of the liquid wastes were listed as latex and oil
at the time of disposal, witnesses have described the disposal of solvents and
volatile industrial chemicals with foul odors.
The Stark County Board of Health (SCBH) ordered a stop to the dumping of chemical
(liquid) wastes on January 24, 1972. In 1980, due to public concern and because
the facility was reaching its volumetric maximum capacity, ~he SCBH and Stark
County Court of Common Pleas ordered closure of the landfill. A closure plan
was developed by Steven Hovanscek and Associates, a consulting engineering
firm in Cleveland, under contract to owners. The landfill site was then
covered and seeded.
-3-
-------
In 1983, complaints by community residents prompted investigations to ascertain
whether drinking water was contaminated and if health risks existed because of
the site. The results of these investigations and the continued concern of the
community provi"ded the basi s for the State of Ohi 0 I s s ubmi ss i on of the site to
the U"ited States Environmental Protection Agency (U.S. EPA) as a National
Priority List (NPL) condidate. In October 1984, U.S. EPA announced the
inclusion of the site on the NPL. On December 26, 1984, a Work Assignment was
issued for performance of a Remedial Investigation (RI) and Feasibility Study
(FS) for the Industri a1 Excess Landfill site.
During the course of the comprehensive RIfFS, U.S. EPA discovered contamination
of several private drinking water wells near the site. The Agency determined
that the cause of the contamination was the migration of hazardous substances
from the Industri a1 Excess Landfill. U.S. EPA imp1 emented interim emergency
actions to protect the residents in the short term until it could conduct a
Focused Feasibility Study (FFS) to evaluate long term alternatives for the
provision of safe drinking water to threatened and potentially threatened
residents, in accordance with Section 118 of CERCLA. The FFS and resulting
remedial action constitute an operable unit of the overall remedy for the site,
in accordance with ~300.68(c) of the National Contingency Plan. The comprehensjve
RI/FS will evaluate the overall remedy for the site and will be available in
the future.
CURRENT SITE STATUS
Results of the U.S. EPA's Remedial Investigation at the site indicate the.
regional groundwater flow is east to west and that contaminants have ~igr(~ed
approximately 600 feet from the western edge of the landfill, impacting the
groundwater of 10 homes. Some of the residential wells sa~pled contained
organic contaminants (vinyl chloride and ch1oroethane) which are attributable
to the landfill and inorganic contaminants (barium, copper, cadmium, and nickel)
above background levels, also attibutable to the landfill. Some tentatively
identified compounds (TICs), which are not part of the hazardous substance list
(HSL), were also detected, as well as other organic compounds which cannot be
at t rib u t ed to t he 1 and fill.
Similarly, a number of organic and inorganic substances, as well as TICs, were
detected above background levels in groundwater samples taken from shallow
monitoring wells located onsite near the site borders.
A well-by-well comparison of chemical substances found in the residential wells
to applicable or relevant and appropriate requirements (ARARs) for drinking
water and other guidance and criteria, reveals that the observed levels of
vinyl chloride (2 ppb to 7 ppb) in three of the 51 wells sampled are equal to
or exceed the Safe Drinking Water Act Maximum Contaminant Level (MCL) of 2 ppb,
Maximum Contaminant Level Goal (MCGL) of zero and Clean Water Act Ambient Water
Quality Criterion (AWQC), adjusted for drinking water and corresponding to 10-6
excess lifetime cancer risk of 2 ppb.
"
-4-
-------
The arsenic levels observed «2 ppb to 7.1 ppb) are above the drinking water
health advisory to protect sensitive members of the population and the AWQC,
but significantly below the MCL of 50 ppb. However, arsenic appears to be
naturally occurring in the area. Barium levels observed (2.1 ppb to 1,160 ppb)
exceed the MCL of 1,000 ppb and the Ohio EPA standard of 1,000 ppb in two of the
wells, but are less than the proposed MCLG of 1,500 ppb. All other chemicals
on the HSL observed are either at levels below stc~dards or are co~pounds that
do not have standards.
Monitoring well data from onsite wells located near the site borders, especially
from shallow monitoring wells, indicate that 1,2-dicloroethsne, benzene. barium,
chromium. lead and nickel are present in the groundwater at the peripheries of
the site at levels which exceed standards.
A risk assessment of the levels of contaminants found in the residential wells
and monitoring wells near the IEL site indicates that the short-term (2 years)
and long-term consumption of groundwater from contaminated residential wells
may result in unacceptable health r)sks (greater than 10-6 excess lifetime
cancer risk). Also. adverse health risks may be associated with long-term
(life ti~e) consumption of groundwater containing the level of contaminants
detected in the shallow monitoring wells.
This is demonstrated in Table 1.
ENFORCEr~ErJT
Federal enforcement activities at the IEL site began in April 1985 with the
issuance of notice letters to Hyman Budoff. an owner.'operator, and several
large tire companies who were generators of wastes disposed of at IEL. The
notice letter requested that these PRPs voluntarily undertake the RI/FS.
Negotiations with the generators did not result in a settlement to conduct
the RIIFS. As a result, I).S. EPA conducted the RI/FS as a fund-lead project.
After discovering residential well contamination by hazardous substances
migrating from IEL and taking short-ter~ emergency actions to protect affected
residents. U.S. EPA conducted an Operable Unit Focused Feasibility Study (FFS)
for the provision of a long-term alternative water supply to affected and
potentially affected residents. The FFS was released for public comment in
August 1987. At the same time. U.S. EPA issued special notice letters to the
owners/operators and several generators for the impl~mentation of the FFS
remedy. A 60-day statutory time period. with associated moratorium on remedial
action. was establ ished for receipt of a "goo<1 faith" proposal from the noticed
PRPs. U.S. EPA will evaluate this proposal and determine whether an additional
60-day negotiation period. and associated moratorium on remedial action, is
warranted.
-5-
-------
COMPARISON TO APPLICABLE
TABLE 1
MONITORING WELLS
AND RELEVANT AND APPROPRIATE REQUIREKENTS
INDUSTRIAL EXCESS SITE
(AHAR) AID OTHER GUIDANCE AND CRITERIA
ChemIcal
1,l-Oichloroethane
1,2-0ichloroethane
Benzene
Toluene
Chlorobenzene
Ethylbenzene
Xylenes
1,4-01chlorobenzene
6is(2-ethylhexyl)
phthalate
6uium
ChromIUm
lead
Nickel
Zinc
(all concentratIons are ppb)
Standard or CrIterion
ConcentratIon in( )
MonItoring Well a
Geol1letric
Hean
Max I ilium
3.~ 25
2.6 10
2.a 9
1.2 5
3.0 26
3.4 68
3.7 240
10 13
NR 2
390 1,740
16 65
13 108
44 250
79 1,179
DrinkIng Water Health AdvIsorIes
MCl
HClG
AWQC
5
5
o 0.94(c) 740 74() 740 2,600 RA
o 0.67(c) 233 233 HA ItA ItA
2,OOO(p) 15,000 18,000 6,000 10,800
461J l.aOO 1,800 9,000 30,000 3,150
2.400 21,000 2,100 3,400
440(p) 12,000 7,600 7.80U 27,300 2,200
75 470 10,700 10,700 10,700 37,500 3,750
NA
0.35
NA
HA
NA
HA
ItA
NA
HA
0.031
NA
75
21,000
1,000 1 ,500 ( p) 1,800
50 120(p) 50 1,400 1,400 240 840 170
50 20(p) 50 10 10 10
15.4 1,000 350
5,000(0)
aValues
-------
In mid-1987 U.S. EPA
currently developing
and, if appropriate,
PRPs.
received disposal records from the owner/operator. We are
this information in order to "issue information requests
notice letters to any additional generator or transporter
COMMUNITY RELATIONS
Community involvement at the IEL site has been very high. Residents, the press
and State and Federal officials have maintained a constant and serious interest
in U.S. EPA activities at the site.
Copies of the FFS..were made available to the community on August 12,1987. An
information repository is located at the"Lake Township trustees office in
Hartville, Ohio. The U.S. EPA issued a press release announcing the availability
of the FFS, location of the repository, the August 12 - September 10, 1987
public comment period, and on August 25, 1987 public meeting at the Uniontown
Coomunity Public Hall in Uniotown, Ohio.
The public meeting was attended by 200-300 very interested residents, news
media and public officials. During the meeting, the U.S. EPA presented the
FFS, described the alternatives considered, recommended connection to the
Village of Lakemore Water System as the Preferred Alternative, answered
questions reg~rding the study, and accepted public comments.
Many of the cooments received during the pUblic comment period asked that U.S.
EPA expand the area receiving the alternate water and that sources other than
the Village of Lakemore be considered. The Responsi-teness Summary to the
public comments is attached to this document..
ALTERNATIVES EVALUATION
The major objective of the FFS conducted for the IEL site was to evaluate
remedial alternatives using criteria consistent with the goals and objectives
of the Comprehensive Environmental Response, Compensa:ion, and Liability Act of
1980 (CERCLA), as amended by SARA. The National Oil and Hazardous Substances
Contingency Plan (NCP), 40 CFR 300.68, outlines the procedures and criteria to
be used in selecting the appropriate remedial alternative that is cost effective,
implementable and effectively mitigates and minimizes threats to, and provides
adequate protection of, public health and welfare and the environment.
Response action may be conducted as an operable unit which is a discrete response
measure that may precede selection of an appropriate final remedial action. This
is consistent with 40 CFR 300.68 (c) and the practice of phasing remedial
actions at sites that present complex cleanup problems. The primary objective
of the FFS operable unit is to protect human health by providing a reliable
supply of safe, potable water to residents whose groundwater is currently
contaminated or has the potential for being contaminated by IEL before the site
-6-
-------
itself is remediated.
Eleven alternatives and technologies were initially identified and evaluated
for about 100 homes in the potentially affected area. (Shown in Figure 1-3).
U.S. EPA used a logical approach for determining the extent of the area to
receive alternate water. U.S. EPA calculated the rate of contaminant migration
based on hydrogeological data collected during the Remedial Investigation. The
Agency then used this rate to project how far from the site contaminants may
migrate over a five year period. Five years was used as the time which would
be necessary to design and implement an aquifer restoration remedy. The
potentially impacted area includes approximately 40 homes (Scenario 1 in FFS).
Recognizing that groundwater flow and contaminant migration predictions are not
exact sciences, and that predictions concerning the timing and effectiveness of
remedial action are not always fulfilled, U.S. EPA used its discretion to supply
water to an additional area (approximately 60 more homes) that includes a margin
of safety and does not separate blocks of homes. If any error is made judging
the progress of groundwater contamination or the timing of the future aquifer
restoration, the Agency believes it is better to protect more homes than
necessary rather than fewer. While U.S. EPA has attempted to map as accurately
as possible the likely spread of contamination before a permanent remedy halts
further migration, it also included a safety margin to ensure adequate protection
of public health. In addition, the incremental cost for including the 60
additional homes is relatively minor when compared to benefits derived
from provision of maximum protection. The alternatives were screened and
evaluated based on their effectiveness, implementabilty and cost. A summary
can be found in Table 2.
. Four of the original eleven alternatives passed the initial screening and a
detailed evaluation was conducted. The four alterna:ives include:
o
No action;
o
Construct a new community well supply into the Pottsville Group aquifers
upgradient of the IEL site;
o
Connect to the City of North Canton water system;
o
Connect to the Village of Lakemore water system.
These four alternatives were then subjected to detailed evaluation of their
effectiveness, implementability and costs. The results of the detailed
evaluation are presented in Table 3.
DESCRIPTION OF ALTERNATIVES
No Action
The "No Action" alternative is designed to provide a basis for comparing the
other alternatives. It may include some monitoring and analysis, but primarily
-7-
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THlE 3
~TER ~PlY ALTtRAATIVES FUR P01EKTIMY AfFECTED MA ~1IR USERS (f 1If1(){I{W
Cost (U .0)))
Capital Present ~ CartNni t.fY
Altemdtive 51 l~ P\tIl1e I'k!alth Concerns Env1n:maltal CCXj(PfT1S Tedv1i ca I Cm:ems Response Concerns Other>
Calstruct new ~II I,WI 1,~ 1,799 Redoce pbllc health -6 Does oot mltl!)3te K1y have sore difficulty tb1e to I Hard ~tef" ant ioval'
lak IJTDI'e wa ter threat to less than 10 c.mtanloalioo problt5l1 y Hili! leakJWrst 1009 tnd line.
syStffil risk
InchrleS capital, ~I O.!H ~ amJaliJl!d eqJlpTa1t replarorent. cost
Estimated ~ m participatioo in the local pbl1c aM other lll!etings during rme:lial tll'RStiljation
These alternatives Me rot plamed to mitigate the coot.aninatim pnblen
-------
provides an assessment of what would happen with the unhampered continuation of
the existing situation.
Construct a New Well Supply
This alternative involves the construction of primary and stand-by wells located
upgradient from the IEL site. The wells would be completed in the Sharon
Conglomerate Unit of the Pottsville group of aquifers. A distribution system
also would be constructed to convey the water. The Pottsville group is the
bedrock group of aquifers underlying the unconsolidated glacial deposits (the
glacial deposits are approximately 50 feet to 100 feet thick). The Pottsville
group consists of an upper unit of interbedded sandstone, siltstone, shale and
minor limestone underlain by the coarse, water-bearing pebbly sandstones of the
Sharon Conglomerate. The Sharon Conglomerate unit is considered the most
productive of the Pottsville Group aquifer and lies from 200 feet to 300 feet
below ground surface.
This alternative makes use of pressure (hydropneumatic) tanks to provide storage.
It does not include provisions for fire demand. It includes chlorination to
meet health requirements but no softening of the hard water generally encountered
in the Uniontown area. The community wells would be located in the vicinity of
the residences to be serviced.
This alternative would supply an adequate amount of water. The water may be
somewhat harder than that currently used by many of th~ residents in the
potentially affected area. To meet health requirements, the water should be
chlorinated. This alternati' ~ relies on proven technologies and should not
present any engineering problems in implementation. T1is alternatives would
not require unusual water quality or operational monitJring.
Connect to City of North Canton
The City of North Canton is located south of Uniontown and obtains its drinking
water from wells. The water is softened to a hardness of 100 mg/l to 120 my/1
. as calciuln carbonate (CaC03). The North Canton system is currently operating at
about 50 percent of its design capacity of 4.0 mgd. The City has a policy of
serving customers outside the city limits without annexation of the service area.
However, customers outside the city limits are charged a surcharge of
approximately 100 percent of the basic city rate. The nearest city water main
currently available is located east of the Akron-Canton Airport at the
intersection of Cleveland Avenue and Lee Stre~t, about four miles south of
Uniontown. This alternative would require construction of a trunk line from
North Canton to the affected area, a booster pump station, and a distribution
system to supply individual residences.
This alternative relies on proven technologies and should ~resent ~ engineering
problems in its implementation. This alternative would not require water
quality or operational monitoring and will provide adequate quantities of good
quality water.
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Connect to Village of Lakemore
The Village of ~akemore is located approximately 2.5 miles northwest of Uniontown
and obtains its water from wells completed in a bedrock aquifer. The well
water has a hardness of about 220 mg/l as CaC03. The Village water system is
currently operating at about 40 percent to 50 percent of its design capacity of
0.57 mgd. The village has a policy of serving customers outside of village
limits without annexation of the service area. However, outside customers are
charyed a surcharge of about 30 percent. The Village of Lakemore water rates
are the lowest of all the major water systems investigated in the vicinity of
Uniontown. Lakemore is currently in the process of enlarging their service
area.
The provision of water to Uniontown would involve the extension of an existing,
adequately sized main from Waterwork Park to the intersection of Cleveland
Avenue and Sanitarium Road (about 2,000 feet closer to the Uniontown service
area). The nearest village water main currently available with adequate capacity
is located northwest of the Cleveland Avenue and Sanitorium Road intersection,
about four miles northwest of the affected area.
This alternative would
system, a booster pump
users. Because of the
water, the users would
require construction of a trunk line from the Lakemore
station and a distibution system to supply water to the
relatively high hardness and iron content of the Lakemore
have to continue using their existing water softeners.
This alternative relies on proven technology and sho~ld present no engineering
problems in its implementation.. This alternative. would not require unusual
water quality or operational monitoring an~ ~ill provide adequate quantitie~ of
good quality water. .
As a result of comments received during the public comment period, U.S. EPA
preliminarily evaluated a fifth alternative, connection to the Summit County-
Country Club Village Community Water Supply.
Country Club Village Community Water Supply
The Count~ Cluo Village Community Water Supply is located approximately two
miles west-southwest of Uniontown and obtains its wat2r from two wells completed
in the Sharon Congolmerate of the Pottsville Group. The system includes a
400,000 gallon elevated storage facility. The well water has a hardness of
about 200 to 250 mg/l as CaC03 and, like most well water in the area, contains
relatively large amounts of iron and manganese. The water system, whic1 is
owned and operated by Summit County, is currently operating at 30-45 percent of
its design capacity of 0.75 mgd. Summit County has tentative plans to drill
another well to augment the existing system. Existing wells are equipped with
chlorination units. A 12-inch water main is available just south of the inter-
section of Raber Road and Gleneagles Boulevard.
The provision of water to Uniontown would require the construction of both a
trunk line from Country Club Village and a distribution system to supply water
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to the users. Due to uncertainties regarding system hydraulics, a booster pump
station having at least two pumps has also been included in the cost estimates.
The pumps would be capable of pumping 500 gpm at 50 to psi; and would be
regulated automatically using pressure switches installed downstream of the
booster pump station. The pump station would be located near the intersection
of Raber Road and Gleneagles Boulevard. Water supplied to Uniontown would be
metered at this station. Most of the required equipment (booster pumps, valves,
flow meter, and controls) would be housed in a brick and block building measuring
approximately 12 feet by 12 feet in dimension. .
The water obtained from the Country Club Village Community Water Supply is hard
and the use of this water in Uniontown would warrant continued use of existing
home softeners. No additional treatment or water quality monitoring would be
required. Summit County would operate and maintain the booster pump station
and that part of the 12-inch diameter trunkline located within Summit County.
The remaining portion of the 12-inch trunkline and the distribution system
itself, consisting of 3,200 feet of 6-inch diameter mains, 6,700 feet of 8-inch
diameter mains, and 100 service lines, would be operated and maintained by the
users or their designee, such as Lake Township, Stark County or Summit County.
Evaluation of Alternatives
The "No Action" alternative would not assure protection of human health, because
the exposure threat from drinking contaminated water would remain. Selection
of this alternative would also have low community acceotance. Because this
alternative does not meet the response o9jective for protecting human health,
it was not evaluated f'lrther.
In accordance with Section 121(b)(1)(D) of CERCLA as amended by SARA, the four
remaining alternatives rank equally in their ability to protect public health
and the environment by eliminating exposure to contaminated groundwater through
the provision of drinking water that would attain the ARARs, as required by
Section 121(b)(1)(C). None of the alternatives address reduction of toxicity,
mobility and persistence since they all involve replacement of an existing
contaminated water supply with a new water supply. These factors will be
addressed in the remedy.to remediate groundwater contamination in the aquifer.
The four alternatives all provide long-term effectiveness by replacing
conta~inated water supplies within the present and potential areas of contam-
ination. Implementability varies for each of the alternatives. Each
alternative relies on proven technology and should present no engineering
problems in implementation and operation. Therefore, the potential for failure
and future remedial action costs are minimal. This satifies Section 121(b)(1)(F).
The time to implement is similar for all four alternatives. Costs are also
within an order of each other, ranging from $1.7 million to $2.3 million.
Establishing a new community well for such a small portion of the community
would have major administrative implementation problems. A community water
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district would have to be formed, and a recognized governmental body will have
to serve as backup for system operation. However, if the area receiving the
water is expanded, as indicated by comments received, administrative problems
with developing a water district for a larger geographic area may beco~e less
significant when weighed against the advantage of the community having its own
water system.
The three remaining alternatives are differentiated by cost [initial capital'costs,
replacement costs, and long-term maintenance costs, per Section 121(b)(1)(E)],
with connection to the Country Club Village system being the least costly, and
connection to the City of North Canton being the most costly. The Ohio
Environmental Protection Agency has indicated that both the Country Club
Village system and the Village of Lakemore system may be required to install
iron removal facilities in the near future. This may result in a cost increase
for the two alternatives that, if substantial, would result in their being less
cost effective than the connection to the City of North Canton. North Canton's
system has a much larger capacity than either the Country Club Village or
Village of Lakemore syste~s. If the community does formally commit to fund an
expanded area, the North Canton option would be more viable. There are,
however, questions remaining concerning the quality of that water, as low
levels of VOCs have been detected in several wells which are not currently
utilized to supply water.
Due to the nature of this operable unit, Section 121(b)(1)(A,R, and G) were
not applicable to the evaluation of alternatives.
SELECTED REMEDY
The National Oil and Hazardous Substances Contingency Plan (NCP) [40 CFR Part
300.68(i)J states that the appropriate extent of remedy shall be determined by
the lead agency's selection of the remedial measure which the agency determines
is cost-effective (i.e., the lowest cost alternative that is technologically
feasible and reliable and which effectively mitigates and minimizes damage to
and provides adequate protection of public health, welfare, or the environment).
Based on the evaluation of effectiveness, implementability and cost of each
proposed alternative, the comments received from the public and the Ohio EPA
and the State and Federal envi ronmental requi rements, connect i on of approx-
imately 100 homes to an alternate water supply has been determined to be the
most appropriate alternative. This alternative is fully protective of human
health, cost effective, and will attain all applicable or relevant and
appropriate federal and state requirements.
The selected remedy involves providing alternate water to an area comprised of
approximately 100 homes located west of the IEL site. Connection to the Village
of Lakemore had been U.S. EPA's recommended alternative. However, based on
numerous comments asking that U.S. EPA consider sources of water other than the
Village of Lakemore, as well as concerns regarding water quality and capacities,
U.S. EPA is deferring the decision on the source of the water. T~is decision
will be made after initial design activities are completed and more detailed
technical rlata pertaining to the water systems considered in the preceeding
Evaluation of Alternatives section have been reviewed. The evaluation of the
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water supply to be utilized will be submitted as part of the preliminary design
report when the design is 30 percent complete.
This remedial action meets the two conditions established by Section 300.68(c)(1)
and (3) of the NCP: 1) the measures to be undertaken must be cost effective;
and 2) they must be consistent with a permanent remedy. This remedial action
is cost effective. Numerous remedial alternatives were evaluated considering
technological feasibility, cost, reliability, pub,ic health, and administrative
criteria. Based on this evaluation, a cost-effective remedial alternative that
effectively mitigates threats to, and provides adequate protection of, public
health was selected.
The selected remedy does not adversly effect any of the potential final
remedial actions, including minimization and mitigation of the groundwater
contamination. Although this operable unit will not eliminate the groundwater
contamination, it will minimize the threat posed by the IEL site until such
time as a overall site remedy is selected by U.S. EPA. Any such remedial action
will take time to implement. In the meantime, contaminants will continue to
migrate from the landfill and threaten drinking water supplies. Providing
alternate water supplies will protect public health until an overall remedy can
take effect. This is fully consistent with a permanent remedy.
The 30 year present
rate of 10 percent,
Club Village system
. system.
worth value for the recommended alternative, at a discount
can range from $1,715,870 for connection to the Country
to $2,289,060 for connection to the City of North Canton
SCHEDULE
o
Approval of Remedial Action (sign ROD)
Complete Design
9/87
3/88
3/88
4/88
5/88
6/88
12-18 months
12/89
o
o
Advertise for Competitive Bids
o Open Bids
0 Contract Award
0 Notice to Proceed
0 Est imated Const ruct i on Period
o Construction Complete
FUTURE ACTI ONS
U.s. EPA recently completed Phase II Field Activities of the comprehensive
RIIFS for the site. The remaining tasks of the RI/FS will be completed in late
1987. The FS will recommend a remedial action for the site. A Record of
Decision for the site is scheduled for March 1988.
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INDUSTRIAL EXCESS LANDFILL SITE
UNIONTOWN, OHIO
RESPONSIVENESS SUMMARY
The United States Environmental Protection Agency (U.S. E?A) recently held a
public comment period, August 12 - September 10, 1987, for interested parties
to comment on U.S. EPA's August 1987 Focused Feasibility Study (FFS) and
Proposed Plan for providing alternate water at the Industrial Excess Landfill
(IEL) site. At the time of the public comment period, U.S. EPA had announced
its recolJlTIended alternative for the provision of alternate water.
The purpose of this responsiveness summary is to document U.S. EPA's responses
to comments received during the public comment period. All of the comments
summarized in this document will be factored into U.S. EPA's final decision.
This responsiveness summary is divided into the following sections:
III.
I.
Responsiveness Summary Overview - This section briefly outlines
the proposed remedial alternatives as presented in the FFS,
including the recommended alternative.
II." Background on Community Involvement and Concerns - This section
provi des a Dri ef history of community interests and concerns
regarding the IEL site.
Summar of Comments Received Durin the Public Comment Period
an U.. s esponses - 1S sect10n summar1zes ot wr1tten
and oral comments received from the public and provides U.S. EPA's
responses. These comments are organized by subject area. Comments
froln the Potentially Responsible Parties (PRPs) appear
separately from the other comments.
I V .
Remaining Concerns - This section describes concerns that U.S. EPA
feels need to be addressed in greater detail, and before the
design and implementation of the remedial alt2rnative.
Attachment A - This attachment includes a list of the community
relations activities conducted, to date, at the IEL site.
Attachment S - This attachment includes a list of Tentatively
Identified Compounds (TICs) found in on-site and off-site
groundwater samples.
Attachment C - This attachment contains a brief analysis of the
Country Club Village Community Water Supply, which was submitted
by tile PRPs as an alternate source of water.
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I.
RESPONSIVENESS SUMMARY OVERVIEW
A.
Proposed Alternative and Recommended Alternative
The FFS identifies and evaluates alternate water supplies for the area
impacted by the I EL site. El even a lternat i ves and techno logi es were
initiallj identified and evaluated for about 100 users in the poten-
. tially affected area. The alternatives were screened and evaluated
based on their effectiveness, implementability, and costs.
Four of the original eleven alternatives passed the initial screening
and a detailed evaluation was conducted. The four alternatives
included:
1.
No action;
2.
Construct a new.community well supply upgradient of
the IEL site;
3.
4.
Connect to the City of North Canton water system;
Connect to the Village of Lakemore water system.
These four alternatives. were then subjected to a detailed evaluation
of their effectiveness, implementability and costs. U.S. EPAls recom-
mended alternative was to connect the approximately 100 homes in the
potentially affected area to the Village of Lakemore's water system.
The groundwater contamination problem will be further addressed in the
overall RIfFS for the site.
B.
Public Comments on the Remedial Alternatives
Forty parties submitted formal written comments to U.S. EPA during the
pUblic comment period: Congressman Regula, State Representative Johnson,
Concerned Citizens of lake Township (CClT), Families for Safe Water,
Northeast Ohio Four County Regional Planning Organization (NEFCO),
Hammontree & Associates (consulting engineers), Lake Township Tr~stees,
Stark County Metropolitan Sewer District, and local citizens. In
addition, a number of comments were received at the public meeting from
the aforementioned groups. A petition containing approximately 1200
names of area residents was also submitted to U.S. EPA during the
meeting. Formal comments were also submitted )y law firms .represe~ting
the PRPs, including: Hyman Budoff, Firestone ~ire & Rubber Company,
B.F. Goodrich Company, Goodyear Aerospace Corporation and Goodyear Tire
-2-
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~
and Rubber Company.
In general, the commenters (except the PRPs) acknowledged the need for
an alternate water supply at the IEl site. However, most commenters
felt that the area proposed by U.S. EPA to receive this water should be
expanded to include all homes within a three-mile radius of the site.
Consequently, many citizens .requested that U.S. EPA consider connecting
to the North Canton water system, since it has a greater capacity than
the lakemore system and can therefore, provide water to a larger area.
The PRPs felt that the FFS and U.S. EPA's recommended alternative for
obtaining an alternate water supply from the Village of lakemore are
~remature. They do not agree that an alternate water supply is neces-
sary, and that any alternate water supply proposal can only be properly
evaluated once the RIfFS for the entire site has been completed. In
addition, the PRPs feel that U.S. EPA has not adequately evaluated
available alternatives.
II.
~ACKGROUNO ON COMMUNITY INVOLVEMENT AND CONCERNS
The major concerns of the Uniontown Community have been the following:
1. Potential groundwater contamination and associated public health
risks, 2. Explosive levels of methane gas in nearby residences and
management ~f landfill gases through controlled venting~ and
3. Property devaluation. The Industrial Excess Landfill (IEL) operated
from 1968 to 1980, during which time it accepted reJidential, commercial
and industrial wastes. Initial sampling of groundwater and leachate by
the Ohio Environmental Protection Agency (OEPA) indicated that low
levels of organic contaminants, including phenol, xylene, methylene
chloride and tetrachloroethylene, were present. Current interest in
the IEl site developed in mid-1983. Members of the community were
concerned about a perceived high rate of miscarriages and other health
problems in several nei9hborhoods located near the landfill. Residents
claimed that these problems, or health complications, resulted from
drinking water that was contaminated with substances from the landfill.
In 1984, community concern increased after elevated levels of methane
gas were detected offsite. In the fall of 1984, explosive levels of
methane gas were detected in the basements of several homes, resulting
in the limited evacuation of two residences and a day care center.
The level of community interest has remained high throughout the remedial
investigation. In March 1987, U.S. EPA found levels of vinyl chloride
and barium exceeding federal drinking water standards in approximately
ten residential wells near the landfill. The agency determined that
the cause of the contamination was the migration of hazardous substances
from the Industrial Excess landfill. The citizens have expressed
concern that the extent of contamination is greater than w~at has been
identified by the U.S. EPA. Although U.S. EPA's Focused Feasibility
Study (FFS) specifically addresses contaminated and potentially affected
,
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residential wells, the community feels strongly that it is only a
matter of time before the contamination will migrate beyond the area
identified by U.S. EPA, thus contaminating additional private wells.
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I I 1.
SUMMARY OF COMMENTS RECEIVED. DURING THE PUBLIC COMMENT PERIOD AND
U.S. EPA RESPONSES TO THESE COMMENTS
This responsiveness summary addresses both oral and written comments received
by U.S. EPA concerning the Focused Feasibility Study (FFS) for the Industrial
Excess Landfill site. The comment period was held from August 12, 1987 to
September 10, 1987. A public meeting was held at Uniontown Community Park Hall
on August 25,1987, as 'an opportunity for the public and other interested
parties to present oral and written comments to U.S. EPA. These comments are
recorded in a transcript of the meeting which is available at .the Information
Repository in Hartville, Ohio, and the U.S. EPA Region V office in Chicago.
The written and oral comments are summarized and organized into the following
cateyories: A) area included in the remedial action, B) remedial alternative
preferences,' C) costs and funding, D) health issues and, E) miscellaneous.
U.S. EPA received a number of comments pertaininy to the overall RI/FS during
the public comment period. Since the purpose of this comment period was to
receive comments specifically related to the FFS, comments related to the
overall RI/FS will be addressed at a later time. Written comments from the
PRPs are addressed separately. U.S. EPA responses are provided for each
comment.
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PUBLIC COMMENTS, EXCLUDING COMMENTS FROM THE PRPS
The following. section summarizes written and oral comments received from the
public, excluding comments received from the PRPs. The comments are organized
into the following categories: A) area included in the remedial action, B)
remedial alternative preferences, C) costs and fundlng, D) health issues, and
E) miscellaneous. U.S. EPA responses are provided for each set of like comments.
A.
Area Included in the Remedial Action
The majority of the comments received (including a citizen's petition
containing approximately 1200 names) requested ~hat U.S. EPA expand the
area to be included in the preferred remedial action. Specifically, many
commenters urged that alternate water be supplied to all homes within a
three-mile radius of the IEL site.
U.S. EPA RESPONSE:
The purpose of Superfund is to remedy areas that have been adversely impacted
by NPL sites. As explained in the FFS, U.S. EpA has determined that-the ground-
water of 10 homes west of IEl has been contaminated by the site. If unchecked,
contamination will continue to migrate westward, arfec~ing the groundwater of
approximately 100 homes in a 15 year time period. U.S. EPA expects to implement
a remedy for the IEl site before contaminants can migrate beyond this projected
area. Section 104 of CERCLA limits U.S. EPA to providing alternate water only
to those areas impacted by the site. Expanding the remedial area to include
all homes within a 3-mile radius of the site can be implemented only if the
State, or political subdivisions thereof, pay for all incremental costs.
B.
Remedial Alternative Preferences
All commenters agreed with U.S. EPAls recommendation for an alternate
water supply. However, the majority of the commenters suggested that
water be obtained from the City of North Canton rather than the Village
of Lakemore. These comments were divided into two categories:
1. Capacity of System
{omments regarding the capacity of the proposed water system fell
into the following areas:
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a.
Capacity for expanded area
A number Jf comments were directly related to requests that U.S.
EPA expand the area designated to receive the alternate supply.
Commenters noted that the Village of Lakemore does not have the
capacity to provide water to all homes within a three-mile radius
of the site. Commenters suggested that U.S. EPA consider
obtaining water from the City of North Canton, since it has to
much larger capacity and would be able to provide water to
additional homes.
U.S. EPA RESPONSE:
U.S. EPA acknowledges that the Village of Lakemore water system does not have
the capacity to provide water to all homes within a 3-mi1e radius of the IEL
site. However, U.S. EPA only has authority to provide water to areas impacted
or potentially impacted by the site, in this case, approximately 100 homes west
of IEL. The Village of Lakemore water system has the capacity to provide water
to these homes.
b.
Accomodate add; t i ona 1 hook-ups and fut:] re growth
Several commenters noted that the currently designed system for
obtaining water from the Village of Lake~ore would not be able
to provide water for homes wishing to tie into the system, or
for future growth of the community.
U.S. EPA RESPONSE:
As stated in the "Guidance Document for Providing Alternate Water Supplies",
U.S. EPA cannot design a system to accomodate hook-ups beyond the impacted area
or future growth, because Superfund only corrects problems within an existing
syste~ or supply. Superfund cannot improve upon a sY5tem or supply. therefore.
U.S. EPA does not provide specific consideration for fJture development.
c.
Technical and cost issues
Both Congressman Regula and Representative Johnson Qoted that
U.S. EPA utilized a larger water line in designing the preferred
alternative than what currently exists. Representative Johnson
also noted that the length of the proposed water line from
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Lakemore, therefore construction costs would be lower for the
North Canton alternative. Congressman Regula noted that since.
cost differences between the North Canton and Lakemore alternatives
are minimal, U.S. EPA should select the North Canton alternative.
U.S. EPA RESPONSE:
U.S. EPA acknowledges that a twelve inch line at the intersection of Canton and
Sanitorium roads does not yet exist. However, in contacting the Village of
Lakemore, U.S. EPA representatives were advised that the planned twelve inch
line would be constructed and available well within the time frame required for
hook-up of the proposed alternate water supply.
With regard to cost issues, calculations presented in the FFS agree with the
commenters' point that capitol costs would be lower for the North Canton
alternative. However, information obtained from North Canton and the Village
of Lakemore show that yearly operation and maintenance (O&M) costs would be
substabtially lower for the Lakemore alternative. Lower O&M offset higher
capital costs, therefore the total cost is lower. Even though cost differences
ar minimal, U.S. EPA is required to select the less expensive alternative,
given that effectiveness a.nd implementability are equal.
2. Water Quality
Many commenters stated that obtaining water from North Canton was
preferred because the water is treated for hardness. In addition,
several people suggested that the water from both Lakemore and North
Canton be tested for priority pollutants. One commenter noted" that
carbon tetachloride was reported in North Cantons' water.
U.S. EPA RESPONSE:
The purpose of Superfund is to replace or restore a lost resource, not i~prove
upon it. The uncontaminated water in the Uniontown area is of similar quality
to the water from Lakemore, including hardness levels. To select the more
expensive North Canton alternative because it offers softer water is consid~red
betterment and not allowed under the Superfund program. .
With regard to testing the water of North Canton and Lakemore, the water of
both these municipalities must meet Ohio drinking water standards. Rumors of
carbon tetachloride present in North Canton water are unsubstantiated. However,
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(;
low levels of volatile organic compounds have been detected in several of North
Cantons. wells. u.S. EPA plans to request, or perform, additional testing of
both systems.
C. Cost and Funding Issues
A large number of commenters urged that
water to the. community free of charge.
noted that the PRPs should be forced to
the community.
U.S. EPA provide alternate
In addition, several citizens
fund the provision of water to
U. S. EPA RESPONSE: .
Before U.S. EPA can fund any of the subsequent activities at the site,
Superfund legislation requires that the PRPs be given the opportunity to
properly and promptly conduct the proposed remedial action. If the PRPs refuse
to do so, U.S. EPA wi 11 fund 90% of construction costs and 90% of the first
year of O&~. The State of Ohio must provide a 10% match for capital costs as
well as the first year O&M. U.S. EPA and the State of Ohio are allowed to take
legal action against the PRPs to try and recoup these ~8stS. After the first
year of operation, the State of Ohio will assume all future maintenance thru
user fees assessed by the ut~lity supplying potable wa:er.
D. Health Isssues
Several cOlnmenters expressed considerable concern regarding the effect
of the landfill on the health of surrounding residents. Specifically,
citizens noted that there are a high number of cancer cases in the
area, which they feel are due to the IEL site.
U.S. EPA RESPONSE:
It is very difficult to link specific health problems t:) anyone source. Data
obtained during U.S. EPAls remedial investigation at the site do not establish
a link between the IEL site and citizen health complaints. A more detailed
health st:.Jdy or exposure SJrvey would have to be candcJ':ed by a health agency,
sue!, as the Ohio Department of Heal!:l or tne Agency for Toxic Substances and
Dise~se ~eJistry (ATSDR). Citizens with s~ecific conC~~1S should have their
pnysicians contact these agencies.
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.
E. Miscellaneous
1. Additional Well Testing
A few commenters requested that U.S. EPA test their wells for
priority pollutants.
U.S. EPA RESPONSE:
The Ohio Department of Health is currently developing a protocol to address
individual requests for private well sampling. Interested citizens should
contact that agency. U.S. EPA has completed its remedial investigation at the
site, and does not plan to do any additional sampling at this time. We feel we
have enough information to characterize the extent of contamination and evaluate
alternatives for a site remedy. Additional sampling will be done if new
- information becomes available that would ",arrant it.
2. Boundary of Potentially Contaminated Area
Several citizens felt that the boundary for the potentially.
contamjr.:ted area was arbitrary. One citizen noted that this boundary
line bisects her property, and wondered if only half of her yard was
"safe".
U.s. EPA RESPONSE:
The boundary line depicted in the FFS circumscribes the area designated to
receive the alternate water supply. Criteria used to detennine the the
potentially contaminated area are described in the FFS. In determining the
area to receive the alternative water, U.S. EPA added an area representing a
margin of safety to the potentially impacted area. U.S. EPA plans to implement
a site remedy that will mitigate groundwater contamindcion before it reaches
that marginal safety area. The boundary line is 'Nith;., that marginal safety
area. Therefore, one side of the line is not necessarily "safer" than the
ot her.
3. PRP Response
A few citizens expressd int~rest in how the PRPs responded to the
FFS.
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.
U.S. EPA RESPONSE:
In general. the PRP response to the FFS was negative. The PRPs felt that the
study failed to prove that contaminants were migrating offsite. therefore. they
did not recognize the need for an alternate water supply. They also felt that
any decisions regarding the necessity of alternate water could not be made
until the overall RIfFS was completed. PRP comments and U.S. EPA responses are
stated in more detail in the PRP Comments of this document.
4. Inadequate Testing to Determine Groundwater Flow Direction
One commenter felt very strongly that the testing done to establish
groundwater flow direction was inadequate and. therefore. the area
including 100 homes does not accurately depict those who have been
impacted by the site.
U.S. EPA RESPONSE:
Preliminary indications that groundwater flow was to the southwest were. based
. on measurements from only 2 groundwater monitoring wells. Since that time.
U.S. EPA has installed a total of 28 groundwater monitoring wells at shallow.
medium and deep levels. and in ~ll directions from the landfill. Six separate
sets of measurements have been taken from these wells during the last year.
Data from these measurements indicate that groundwater flow is due west, not
southwest as was originally thought.
Based on information gathered from these monitoring wells. over 50 residential
wells. 2 rounds of indoor air sampling, methane monitoring wells, and numerous
surface soil, sediment. surface water and well core samples. U.S. EPA has
determined that contaminants have migrated approximately 600 feet from the
western edge of the landfill, impacting the groundwater of 10 homes.
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COMMENTS FROM POTENTIALLY RESPONSIBLE PARTIES
The following section addresses written comments submitted by the Firestone Tire
& Rubber Company, B.F. Goodrich Company, Goodyear Aerospace Corporation, and
Goodyear Tire & Rubber Company. Comments were subm'tted on behalf of these
parties by IT Corporation and Squire, Sanders and Dempsey. Comments were also
submitted by Day, Ketterer, Daley, Wright and Rybolt on behalf of Hyman Budoff.
These comments are addressed point by point beginning with the general comments
submitted by Squire, Sanders and Dempsey, followed by comments submitted by IT
Corporation. U.S. EPA judged comments submitted on behalf of Hyman Budoff to be
identical to those submitted by the other PRPs; hence we did not address them
separately.
COMMENT
U.s. EPA lacks the authority to perform the proposed remedial action, since it
has not established that the action is necessary as a result of a release or
threatened release of hazardous substances from the site.
U.S. EPA RESPONSE
Under Section 104 of CERCLA, U.S. EPA is authorized to provide for remedial
action whenever any hazardous substance is released or there is a substantial
threat of such a release into the environment. U.S. EPA has established that
there is a release and threatened release of hazardous substances from the IEL
site. Oryanic and inor9anic compounds on the Hazardous Substance List (HSL)
were found both in on-site groundwater monitoring wells and in 10 of 51 resi-
dential wells sampled. The 10 wells are located immediately to the west of the
site. As stated in the FFS, U.S. EPA has determined the re9ional groundwater
flow to be east to west and, tnerefore, concluded that contaminants were
mi9rating from tne IEL site.
In contending that contaminants detected in the residential drinking water
wells of homes adjacent to the landfill are from some other source, the PRPs
are ignoring the presence of the landfill which accepted hazardous wates, is
located in permeable soils without an impermeable liner, and for which a con-
siderable amount of data indicate that these substances are moving off-site in
the ground water towards the adjacent homes. If household wastes are the
source of the contamination, vinyl chloride should be randomly distributed
throughout the residential wells sampled. This is not the case. The wells
containing vinyl chloride are concentrated on the western (down ground-water
gradient) border of the landfill.
u
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.
The PRPs criticize U.S. EPA's use of data pertaining to Tentatively Identified
Compounds (TICs), contending that such data cannot be used to justify remedial
action. This criticism is based on a misinterpretation of the Agency's purpose
in describing the movement of TICs. The Agency is using the TIC data to make a
complete analysis of the migration of hazardous substances, pollutants and
contaminants from the IEL site. The Agency collected this information during
the RI and would ~e remiss if it did not present it and an interpretation of
its meaning. Futhermore, the Agency is not relying solely on the TIC data to
prove that remedial action is necessary. The TIC data is only one more piece
of information that indicates actual and potential migration of hazardous
substances from the landfill to residential drinking water.
In sum, we respectfully disagree with the PRPs and believe objective review of
the existing data clearly indicates that a release of hazardous substances has
occurred from IEL, and that the pathway of migration has led directly to the
contamination of nearby receptors, specifically drinking water wells.
COMMENT
It does not make sense to separate the FFS and the proposed remedial action
from the RIfFS and recommended alternative for the e1tire site.
u.S. EPA RESPONSE
The PRPs' criticism of the timing of the proposed operable unit presupposes
that the Focused Feasibility Study and the comprehensive site Feasibility Study
are entirely independent. In reality, the FFS is a portion of the overall
RIfFS which was separated out as an operable unit in order to address threats
to public health as quickly as possible.
Contra~ to the PRPs contention, U.S. EPA has the legal authority to proceed
with an operable unit before the release of the RIfFS. The National Contingency
Plan establishes two basic conditions which must be m:t in order to proceed
with the remedial action as an operable unit in advance of the selection of an
overall remedy: 1) ,the measures to be undertaken mus~ be cost effective; and
2) they must be consistent with a permanent remedy. In addition, before Fund-
financed remedial action is initiated, states must agree to pay for a share of
the costs, in accordance with Section 104(c}(3} of CERCLA.
U.S. EPA maintains that each of these conditions have been met. First, the
operable unit is consistent with a permanent remedy. A permanent remedy at IEL
will almost certainly involve some sort of groundwater treatment to reduce the
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level of contamination. However, any such remedial action will take time to
implement. It could be years before a significant reduction of contamination
is achieved. I~ the meantime, migration of contaminants from the landfill will
continue t9 threaten drinking water supplies in the vicinity. Providing
alternative water supplies will protect public health until an overall cleanup
can take effect. This is fully consistent with a permanent remedy.
Second, the proposed remedial action is cost effective. As described in the
FFS, U.S. EPA evaluated numerous remedial alternatives. Once an alternative
was determined to provide adequate protection of pUblic health, U.S. EPA cal-
culated the cost to implement it, compared relative costs, and chose the
alternative which was least expensive. It must be emphasized, however, that
the threshold consideration here was protection of public health. Of course,
it can be argued that it would cheaper to provide water to fewer than the 100
residences EPA is ~roposing in its preferred remedy. The PRPs argue that
contamination may never reach some of the residences that would be connected to
an alternative water supply. U.S. EPA acknowledges that this may be the case.
U.S. EPA, however, used a logical approach for determining the area to receive
alternative water. U.S. EPA calculated the rate of contaminant migration based
on hydrogeological data collected to date. The Agency then used this rate to
project how far from the site contaminants may migrate over a five-year period.
Five years was used as the time which may be necessary to design and implement
an aquifer restoration remedy. This potentially impacted area includes
approximately 40 ~omes. Recognizing that groundwater flow prediction is not
an exact science and that projections concerning the :iming and effectiveness
of remedial action are not always fulfilled, U.S. EPA used its discretion to .
supply water to an additional area (approximately 60 homes) that includes a
margin of safety and does not separate blocks of homes. If any error is made
in judging the progress of groundwater contamination, it is better to protect
more homes than necessary rather than fewer. While the Agency has attempted
to map as accurately as possible the likely spread of contamination before a
permanent remedy halts further migration, it feels strongly that a safety
margin must be included and that it is within the Agency's discretion to
delimit such an area. In addition, the incremental cost for hooking up 60
additional homes is relatively minor, and U.S. EPA concluded it was worth the
incremental cost to ensure full protection of pUblic health.
Finally, U.S. EPA has kept the State of Ohio fully infJrmed concerning the
proposed operable unit and does not expect difficulties concerning the state
financing requirements.
The PRPs have conducted a markedly different analysis of the legal authority
for conducting the operable unit. In essence, the PRPs' argument is that
neither cost effectiveness nor consistency with the final remedy can be
assured until a final remedy is chosen. They conclude, therefore, that there
is no legal basis for an operable unit until after the overall RIfFS report
is released, the pUblic has the opportunity to comment, and so on. This
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conclusion. which logically applies to any operable unit in advance of a
final remedy. is contradicted by the clear language of the NCP which explicitly
provides for implementation of operable units before selection of a final
remedy. See 40 C.F.R. ~ 300.68(c)(3). Nevertheless, haviny concluded that
U.S. EPA~decision to proceed with an operable unit is illegal, the PRPs
emphasize the imminence of a final RIfFS report, as if it were somehow worse
to proceed with an operable unit when a final remedy selection is close than
when it is far in the future.
The PRPs contention that this alternative water supply remedy should not be
selected at this time because the overall RIfFS is projected to be released in
November 19H7, does not take into account that this date is a projection, not a
hard and fast deadline. In fact, the U.S. EPA has historically exceeded
projected RIfFS release dates, especially at sites. such as IEL. with complicated
environmental and public health issues. Recognizing the uncertainty with
projected schedules. and probability that the overall IEL RIfFS may not be
released in accordance with the projected schedule. U.S. EPA contends it is
prudent to go forward at this time with the selection of a remedy for the pro-
vision of safe drinking water.
Moreover. U.S. EPA notes that the NCP does not impose any condition on the
timing of an operable unit relative to the selection of a final remedy. It
simply requires the Agency to ensure that a pre-final remedy operable unit is
consistent and cost effective. This the Agency has done.
COMMENT
U.S. EPA lacks legal authority to perform the Focused Feasibility Study and to
take the proposed remedial action under Section 118 of the Superfund Act.
U.S. EPA RESPONSE
As discussed in the responses to the previous two comments. U.S. EPA's legal
authority to perform the FFS and to take the ~roposed remedial action is based
upon Section 1U4 of CERCLA and the National Contingency Plan. Besides meeting
the legal requirements established in the NCP. the proposed operable unit is in
accord with the mandate of Section 118 of CERCLA which requires the Agency. for
purposes of taking action under Section 104. to give a high priority to facilities
where the release of hazardous substances. pollutants, or contaminants has
.contaminated a principal drinking water supply. The PRPs object that Section
118 gives priority to "facilities" and does not call for implementation of
remedial action by operable units. In response. U.S. EPA maintains that part
of "giving priority to facilities for purposes of taki'1g action under Section
104" is to proceed expeditiously to address pUblic health problems when a
drinking water source has been contamin~ted, as is the case at IEL. An operable
unit is a vehicle provided by the NCP to enable the Agency to speed up certain
kinds of remedial action. Its use in this case to provide an alter~ative water
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supply is entirely consistent with the thrust of Section 118.
The PRPs object further that contamination of a few private wells is not
contamination of a principal drinking water supply. They cite no statutory or
administrative authority for this conclusion. The legislative history of
Section 118 makes it cleart howevert thatt for purposes of this sectiont
Con~ress intended the Agency to have broad discretion over what constitutes a
principal drinking water supply. The original version of Section 118 tied the
definition of a principal drinking water supply to the Safe Drinking Water Act.
The Conference substitute eliminated this connection. The Conference Report
explains this modification as an assurance "that the EPA administrator not be
constrained in .implementing this provision to existing interpretations of Is01e
or principal drinking water sources' under the Safe Drinking Water Act." H.R.
Rep. No. 99-962t 99th Cong't 2d Sess. 232. For purposes of implementing Section
118t U.S. EPA views residential wells in the vicinity of IELt wells which
constitute the sole source of water for area residentst as a principal drinking
water source.
The PRPs attempt to bolster their argument by sugggesting that the air strippers
the Agency has installed eliminate the need to go forward with the operable unit
in advance of selection of an overall remedy. While the air strippers effectively
- deal with vinyl chloride contaminationt they will not remove other hazardous
sUbstancest such as heavy metals and semi-volatile organics, which threaten to
mi~rate from the IEL site. Under Section 104 of CERCLA, U.S. EPA is authorized
to undertake remedial action not only when there is an actual release, but when
there is a substantial threat of a release of hazardous substances into the
environl~ent. Given the threat of a release of a whole host of hazardous sub-
stances, pollutants and contaminants which the FFS has documented are present
at IEL, the Agency determined to "0 forward with a per~anent alternative water
supplYt rather than continuing to proceed on a pieceme~l basis with air strip-
pers, whose long-term ability to protect public health cannot be guaranteed.
In sum, U.S. EPA's legal authority to proceed is not dependent upon Section
11~. Section 118 of CERCLA simply reinforces the Agency's view that Congress
was keenly concerned with threats to pUblic drinking water and wanted the
Agency to respond to such threats as expeditiously as pJssible. U.S. EPA
maintains that the proposed operable unit is fully in keeping with the intent
of Congress.
COMMENT
The Agency cannot properly support its proposed remedia1 action with a Risk
Assessment that is incomplete and which has not been made available to the
public.
U.S. EPA RESPONSE
The Hisk. Assessment is incolnp1ete only in the sense that it does not examine
a11 sources, pathways and receptors of potential contamination (e.g., direct
contact wit~ leachate, ingestion of site soils, etc.) However, the Risk Assessment
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did evaluate the major exposure pathways via groundwater, such as inhalation
and ingestion, and it was established that a threat to public health did exist
through this pathway. Furthermore, Federal drinking water standards (MCLS)
were exceeded for vinyl chloride and b~rium. U.S. EPA's remedial program uses
MCLs to determine need for action. Since the publication of the FFS, recent
data revealed that levels of nickel exceeded Ambient Water Quality Standards
(AWWS). While AWQS do not establish requirements, they provide guidance on
pollutant levels that pose threats to human health.
COMMENT
U.S. EPA has impro~erly rejected certain Remedial Alternatives and failed to
consider others.
U.S. EPA RESPONSE
U.S. EPA maintains that it evaluated remedial alternatives appropriately. The
relative cost of remedial alternatives does not become a criterion for choosing
bet~een remedies until remedial alternatives are screened for their ability to
protect public health. With respect to the alternative of drilling deeper
wells, U.S. EPA concluded that there is a possibility that contaminants could
reach deep aquifers because the sha1low and deep aquifers are continuous and
linked to one another. In contrast, there is virtually no possibility of
contamination of water piped from ~ municipal water supply. Hence, U.S. EPA
rejected the alternative of drilling deeper wells becd;Jse this alternative was
not fully protective of public health. U.S. EPA did not reach the stage of
evaluating its relative cost.
U.S. EPA gave due consideration to comments from the PRPs and the publi~ con-
cerning the water syste~s U.S. EPA evaluated and other public water systems.
U.S. EPA has decided to 90 forwar~ with a Record of Decision to design and
construct an alternative public water supply system, leaving open the choice of
which water source to use from among the three alternatives considered in the
detailed evaluation of the FFS and the Summit County source suggested by the
PRPs. Since U.S. EPA is not choosing a specific source at this time, a response
to the PRPs' comments regarding the four specific sources mentioned above is
premature. U.S. EPA will respond to these comments at the time it selects a
source.
CUMMENT
U.S. EPA has improperly failed to calculate and consider the administrative
costs associated with constructing and implementing an alternative water supply.
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u.s. EPA RESPUNSE
The administritative costs associated with individual options were considered
on a qualitative basis within the FFS report. This approach is in line with
U.S. EPA published guidance which re~uires the feasibility study to provide
overall capital and operation and maintenance cost estimates which are within a
range of -30% to +5U%. The provisions of specific administrative costs are not
stipulated, and in any case will probably not be cov~red under the provisions
of Superfund. We believe that the actual magnitude of administrative costs
will be small in comparison with the magnitude of the capital and O&M costs for
those options undergoin~ detailed analysis. The types of detailed considerations
the PRPs refer to will be considered as a part of the next phase of the
remediation process, the remedial design.
U.S. EPA gave due consideration to comments from the PRPs and the public
concerning the water systems U.S. EPA evaluated and other public water systems.
U.S. EPA has decided to go forward with a Record of Decision to design and
construct an alternative pUblic water supply system, leaving open the choice of
which water source to use from among the three alternatives considered in the
detailed evaluation of the FFS and the Summit County source suggested by the
PRPs. Since U.S. EPA is not choosing a specific source at this time, a
discussion of relative administrative costs is premature. U.S. EPA will
respond to this comment at the time it selects a source.
At this point, U.S.
Corporat ion.
EPA will respond to the specific comments from IT
COMMENT:
The Focused Feasibility Study (FFS) was prematurely issued and consequently is
based on an incomplete data base. It is our understanding these data will be
available for the U.S. EPA and their contractors to utilize in preparing the FFS.
o Analytical results of the following Phase II Remedial
Investigation (RI) sampling efforts:
- Site groundwater monitoring wells
- Approximately 16 area residential wells (These data
.are critical! These results of analysis are necessary
to confirm the presence of certain contaminants which
were found in low concentrations, oftentimes at or near
detection limits)
- Soi 1 gas Ivapor ana lyses
o
Finalized site risk assessment report
o
A complete quality assurance/quality control report of all
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analytical data generated during the RI. This project has
been historically plagued with laboratory QA/QC problems,
according to raw data provided to us by the U.S. EPA.
Indications to date from the U.S. EPA have been these data will be available as
part of the project RI/FS report. As a result, no action towards evaluating
the necessity of an alternative water supply should have been taken until all
the data is available and has been reviewed; i.e., the RI/FS report has been
issued.
U.S. EPA RESPONSE
.
Although the overall RI/FS for the site is not complete, U.S. EPA has collected
sufficient data on the hydrogeologic characteristics, contaminent occurence, and
site leachate and waste characteristics to support the FFS. Analytical results
for site groundwater monitoring wells (as opposed to residential wells) were
available and in the FFS. In addition, site leachate and waste-analytical
results were also available and used in the fFS. Soil/gas vapor analyses were
not used, but are not necessary to make the conclusions reached by U.S. EPA in
the FFS, especially in light of the large amount of other data mentioned above
which fully supports the U.S. EPA conclusions.
The confirmatory ddta for the residential wells was not available at the time
the FFS was released for public comment. These results have since become
available and indeed support the conclusions in the.FFS. These data were put
into the Admtnistrative Record, delivered to the PRPs on September 24, 1987,
&~d are available for review in the Regional Office in Chicago upon request.
The full site risk assessment, like the overall RI/FS, is not yet available.
However, the risk assessment for the particular release and threat of release,
which is the subject of the FFS, is complete and clearly indicates that an
unacceptable risk to pUblic health exists from this actual and threatened
release.
Each separate data package for all the data used in the FFS has been through a
ri~orous quality assurance/quality control (QA/QC) process. The QA/QC
documentation for all the data (which is comprised of numerous documents) is
not normally sent with raw data, although any QA/QC problems are noted on the
raw data sheets. The QA/QC documents for all raw data used in the FFS are a
part of U.S. EPA's administrative record. The PRPs were informed in U.S. EPA's
special notice letter dated August 13, 1987 that the ad~inistrative record was
available for review in the Regional Uffice, upon request. To date, a request
from the PRPs to review the administrative record has not been received by U.S.
EPA.
COMMENT
The lack of pertinent data, as detailed in Comment No.1 above, makes it
difficult, if not impractical, for interested parties to properly review and
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comment upon the FFS. Similarly, the U.S. EPA cannot be in a position to fully
and adequately respond to comments until the RI report is issued.
U.S. EPA RESPONSE
The apparent lack of the PRPs' initiative to review the large amount of data
available in the administrative record, not the absence of such data, has made
the PRPs' review and comment on the FFS difficult~ The administrative record
has been and continues to be available for review by the PRPs upon request.
U.S. EPA has reviewed the available data and is confident that this Responsi~e-
ness Summary fully addresses the contentions made by the PRPs. .
COMMENT
U.S. EPA claims that Section 118 of CERCLA provides authority for issuance of a
FFS and separate remedial activity when the release 6f hazardous substances has
resulted in the contamination of a principal drinking water supply. However,
to date the U.S. EPA has failed to conclusively demonstrate that the landfill
is the source of those contaminants found in the residential wells west of the
site.
o
Vinyl chloride has, according to the U.S. EPA, Deen detected in low
concentrations in groundwater samples from the residential wells west of
the site. Vinyl chloride has not been detected in any groundwater
samples obtained from on-site monitoring wells.
o
The FFS contends that vinyl chloride is found in off-site residential
wells due to the degradation of unsaturated chlorinated ethenes which
are found on site. However, such compounds are found only rarely (very
few locations at low concentrations) in site groundwater samples. If
such compounds do constitute an on-site source of the vinyl chloride
detected in the residential wells, they should be present in much greater
concentrations. Dilution and dispersion (as well as degradation) of the
compounds could possibly account for the amounts of vinyl chloride seen
in groundwater off site only if greater concentrations of the precursor
these compounds were present over a greater area of the site.
Additionally, the degradation product or products should be present in
combination with the parent product or products, as the parent product
would gradually degrade into corresponding degradation products. The
transformation would be ~radual. The fact that vinyl chloride was not
detected in site groundwater samples indicates such transformations are
not taking place in site groundwater and, thus, the site is not the
source of the trace amounts of vinyl chloride found in three off-site
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wells.
o
Althouyh vinyl chloride was detected on site in soil and drum samples,
the fact that vinyl cl1loride was not detected in site ground water
samples reveals that no route of miyration can be established for vinyl
chloride to be leaviny the site and entering area residential wells.
Thus, the agency has failed to establish a source-pathway-receptor
relationShip between the site and the affected wells.
o
Along these lines, the FFS states that chloroethane was detected in a
site leachate sample and is therefore present in a liquid media where it
may degrade into vinyl chloride. According to the data provided by the
U.S. EPA, three leachate samples were collected as part of the Phase I
RI effort and chloroethane was not detected in any of these samples.
The FFS names several Tentatively Identified Compounds (TICs) which the
U.S. EPA claims were found on site and in off-site wells. The data
provided by the U.S. EPA were evaluated for TICs and the resultant Table
I (attached) was prepared, which compares all TICs detected in residential
wells against those detected in site monitoring wells. Residential well
analyses were conducted by U.S. EPA's contract laboratory; monitoring
well analyses were conducted on sample splits obtained from U.S. EPA's
site RI contractor and analyzed according to Contract Laboratory Program
(CLP) protocol by an independent CLP-certified laboratory.
The table shows that only six TICs were found in both on-site and off-site
groundwater samples. The table generally shows that TIC values are
either estimated at low concentrations, found in equal or greater
concentrations in field or laboratory blanks (all of which are related
to the sampling of re~idential wells), or are found in concentrations in
residential wells which are at or near those found in site monitori~g
wells. Due to dilution and dispersion, larger 31110unts on site than off
site would be expected if the site was the source of those TICs detected
in residential wells. Consequently, the data do not tend to confirm
U.S. EPA's contention that the TIC's offer proof of off-site migration
of contamination.
U.S. EPA RESPONSE
U.S. EPA di sagrees wi th the PRPs I content i on that the Agency ha.s not demonstrated
that the landfill is the source of contaminants in residential wells west of
the site. U.S. EPA has provided a great deal of.evidence and data regarding
this matter and believes the data indicate that the SOJrce of the residential
well contamination is the landfill.
The PRPs' contention that because vinyl chloride has not been detected in on-
site groundwater monitoring wells, the vinyl chloride in residential wells
cannot be attributed to the site, ignores the individual transport characteristics
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of various compounds. Vinyl chloride is a very mobile compound and moves
rapidly through permeable media such as the soil at and around the site. Vinyl
chloride's parent compounds (ch10roethenes) have been found in soil, waste,
and on-site yroundwater samples. U.S. EPA contends that vinyl chloride has
migrated off-site quickly, comprising an actual release from the site, while
its parent compounds pose a threatened release from the site because they are
migrating at a slower rate.
u.S. EPA has found the parent compounds (ch1oroethenes) of vinyl chloride
in higher concentrations onsite than the concentrations of vinyl chloride
found off-site. Taking into account dilution and dispersion, these
parent compounds are a probable source of vinyl chloride. The PRPs'
argument that we should see greater concentrations of the parent compound
across a broad area of the site presumes that U.S. EPA has conducted
waste characterization over a broad area of the site and has not
consistently detected ch10roethenes. The fact of the matter is that U.S.
EPA has not done a site-wide waste characterization because of the danger
of drilling through waste containing explosive levels of methane. Drums
'~were uncovered during excavation for the methane extraction system, and
sampling of drum contents and residues showed the presence of chloroethenes.
In addition, chloroethenes have been found in the surface soil, soil cores from
site monitoring wells, and in the site groundwater. Although vinyl chloride
has not been found in site monitorin~ wells, this phenomenon is due to
tne rapid transport of vinyl chloride from the site.
The PRPs contend that vinyl chloride has been detected in on-site soil
and drum samples. U.S. EPA's data shows that chloroethenes ~ere found,
but did not detect vinyl chloride. If the PRPs have data which shows
that vinyl chloride was present in on-site soil and drum samples this
data should be provided to U.S. EPA immediately. U.S. EPA contends that vinyl
chloride is migrating more rapidly than its parent compunds and therefore is
not being detected ~n site monitoring wells.
The PRPs have mistakenly interpreted the FFS in regard to chloroethane.
Chloroethane, as stated in the FFS, was detected in leachate samples. The FFS
does not contend that the presence of chloroethanes in liquid media lead to '
vinyl chloride in off-site groundwater.
The PRPs' TIC list is not in agreement with U.S. EPA data, which indicate
excellent correspondence between landfill monitoring well TICs and TICs
found in residential wells bordering the landfill (Attachment B). The
concentrations of on-site TICs were, in most cases, greater than those
found off-site. U.S. EPA's data indicates that TICs are an indicator of
contaminant migration. Furthermore, the PRPs did not"collect the split
samples in accordance with an approved Sampling Plan or QAPP, and therefore,
the resulting data's quality cannot be ,determined. U.S. EPA's data,
however, have undergone rigorous QA/QC and are of a known yuality.
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COMMENT
The fact that vinyl chloride was not found in Monitoring Well MW-IIM but was
detected in two adjacent residential wells (RW05 and RW38) suggests in-well or
near-well contamination (particularly at the low levels which were detected)
rather than regional contamination of vinyl chloride~ U.S. EPA should fully
evaluate other potential sources of the detected vinyl chloride. such as the
~resence of PVC or other plastics in the pump. piping or water distribution
systems of each affected residential well. or the relationship of the well
location to septic tank drain fields. floor ~rains. or other potential sources.
The theory posed by U.S. EPA that vinyl chloride was detected in the two
residential wells and not in the nearby monitoring well due to pumpage of the
residential wells is purely speculative. Not enough data exists to evaluate
the potential for a preferential flow to the residential wells. Published
accounts have recently indicated that one of the residential wells (RW05) has
not been utilized for quite some time. The entire issue warrants further
investigation.
u.S. EPA RESPONSE
The PRPs' concern that the vinyl chloride contamination may be caused by a source
other than the landfill. such as pumping or piping in the water distribution
system or septic tank drain fields or floor drains. is not likely. The residential
wells are steel. not PVC. In addition. one would exp~ct to find a more random
distribution of contaminants detected in residential wells if septic tanks were
the source. However. these contaminants are found directly adjacent to and down
ground-water gradient from the landfill. U.S. EPA be1ieves that strong source-
pathway-receptor evidence indicates that the landfill is responsible for the
contamination in the residential wells immediately downgradient from the site.
The fact that the residential wells are in constant use (as opposed to monitoring
wells which are pumped only periodically) is a plausible reason for the anomalous
readin~ in U.S. EPA's monitoring well MW-IIM.
COMMENT
The health effects of TICs are not discussed in the FFS. Their additive or
mixitive effects are speculated upon but cannot be quantified. TICs cannot be
considered hazardous substances due to the lack of toxicological data on the
vast majority of them. Moreover. TICs are not on the list incorporated
in the FFS since CERCLA limits U.S. EPA's response to conditions where releases
of hazardous substances have impacted drinking water supplies.
u.S. EPA RESPONSE
In regard to health effects. U.S. EPA agrees that toxicological data for many
TICs do not exist. However. some toxicological data are available for a
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number of TiCs, as was demonstrated in Table B-9 of the FFS. Even if TICs are
not considered hazardous substances, their presence, both on and off-site, in
conjunction with .HSL compounds, is indicative of off-site contaminant migration.
In establishing the IEL site as the source of contaminant migration, and in
determining the extent of contamination, U.S. EPA did not focus on the data for
a specific compound, such as vinyl chloride. Rather, an overall approach was
taken. U.S. EPA examined the relationship between compounds found in 51
residential wells and compounds found on the IEL sit~. HSL organic and inorganic
compounds related to the site were found in 10 wells immediately to the west
and down groundwater gradient of the site. TICs that are associated with
solvents, reagents o~ chemical fee~stocks of the sort that were dumped at the
site were found in on-site monitoring wells.
The groundwater of ten homes immediately west of the IEL site contained the
same industrial-related TICs that were found on-site. The groundwater flow has
been established to be east to west. U.S. EPA concluded that the HSL compounds
and TICs were migrating from the IEL site. U.S. EPA did not rely on TIC data
to conclud~ that an alternative water supply was necessary to protect public
health. U.S. EPA did, however, present the TIC data collected as further
evidence of contaminant migration from the IEL site.
COMMENT
The FFS approach to calculating the area of future potentially contaminated
. groundwater via Scenario 1 and 2 (and thus used in determining. tile area which
will require corrective actions) appears to assume that even short-term exposure
to low-level contaminants is sufficient to warrant implementation of alternative
water supplies. Realistically, the FFS should have focused on those homes (if
any) where long-term exposure to known contaminants is known to have occurred
and might reasonably be expected to continue until site remediation is completed.
U.S. EPA RESPONSE
The PRPs have apparently mistaken the risk assessment process, which examines
the risk posed in a no action scenario, and the procedures used by U.S. EPA to
determine the area to receive the alternative water supply. In accordance with
standard procedures, which prescribe assessment of riSK when no remedial or
cleanup action is taken, U.S. EPA examined the risk posed by the consumption of
drinking contaminated with vinyl chloride, barium, and other contaminants
mi~rating from the IEL site. In this particular case, where health based
standards were exceeded, the risk assessment was straight forward. Once the
presence of an unacceptable risk was established, U.S. EPA then examined the
area which should receive an alternative water supply, based on the actual
and ~otential threat and taking into account future actions at the site.
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COMMENT
The vinyl chloride level of 2 ppb detected in Residential Well RW39 was at (not
exceeding) the MCL. Therefore, it should not have been evaluated further-in
the FFS.
u.s. EPA RESPONSE
The PRPs' assertion regarding the use of vinyl chloride levels in Residential
Well RW39 is tenuous, since the 2 ppb vinyl chloride level in question is a
potential threat considering, under a no action scenario, that level is likely
to increase. More importantly, there are other residential wells with vinyl
chloride in excess of the MCL, which made the risk posed by the site unaccept-
able, whether or not vinyl chloride data from Residential Well RW39 was used in
the FFS.
COMMENT
The FFS contention that vinyl chloride levels decrease ~ith increasing distance
away from the western edge of the landfill is misleading. The FFS, utiliziny
Wells Nos. RW-5, RW3Y, and another unspecified well to the west demonstrates
that vinyl chloride levels decrease from 7 ppb to none detected within 500 to
60U feet of the landfill. While it is true that RW05 was found to contain 7
ppb of vinyl chloride, another equidistant Residential Well (RW38) contained
only 2 ppb vinyl chloride (not significantly different from that found in RW39
to the west), while a monitoring well placed midway between residential wells
RW39 and RW38 contained no detectable vinyl chloride. The data could potentially
(and just as validly) be interpreted to say that vinyl chloride levels decrease
with increasing distance away from RW05 in all directions, including to the
east toward the landfill, as no vinyl chloride was dete:ted in groundwater
sa~ples obtained on site.
u.S. EPA RESPONSE
u.S. EPA believes clear source-pathway-receptor evidence exists to establish
that contaminants, such as vinyl chloride, barium, chloroethane, and TICs are
migrating via groundwater froln the landfill to residential drinking water wells.
The PRPs' explanation ignores one basic fact, the presence of the IEL landfill,
which was constructed in ~er~eable soils without an imp2r~eable liner, which
accepted for disposal hazardous substances, including li~uid industrial solvent
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wastes, and which is located immediately adjacent to and up groundwater gradient
from contaminated residential drinking water wells.
COMMENT
Chloroethane is discussed as a site contaminant with potential off-site effects,
yet no water quality standards or similar health effects standards (MCL, MCLG,
AWQC, etc.) exist for chloroethane. Additionally, Table 2.1 of the FFS utilizes
chloroethane data for three residential wells where chloroethane in one instance
(RW38) was not detected (less than 1.5 ppb) while at a nearby well (RW39) an
apparently different detection limit was used and a value of 1 ppb was reported.
U.S. EPA RESPONSE
U.S. EPA used the chloroethane data, not as
indicator of contaminant migration frorn the
on- and-off site indicate that chloroethane
residential drinking water wells.
an indicator of risk, but as an
IEL site. The data collected both
is migrating from the IEL site to
COMMENT
Barium levels exceed the MCL but not proposed MCLG. MCLs are typically
enforceable standards which are considered achievable via present-day technology,
while MCLGs are goals which the agency cannot enforce but tends to encourage.
Normally, MCLGs are lower than the corresponding MCL. However, for barium, the
MCL is 1,000 ppb while the MCLG is 1,500 ppb. This tends to indicate that the
U.S. EPA is proposing to relax the current water quality standards for barium.
When first proposed (50 FR 46936, November 13, 1985, Page 46964), the agency
stated the recomrnended MCLG of 1,500 ppb "contains a several-fold safety factor
and should be sufficiently protective against adverse effects." The U.S. EPA
cannot justify enforcing the barium MCL in this instance when the MCLG set by
the agency exceeds it by 1.5 times. Additionally, it appears quite likely that
barium is a regional component of area groundwater resources, much in the same
way as is arsenic, perhaps due to geologic sources.
U.S. EPA RESPONSE
In accordance with U.S. EPA's established risk assess:nent fJrocess, current
enforceable health-based standards, such as MCLs, are utilized as target levels
to be attained when they exist for the compounds of concern. In the absence of
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such standards, a full-blown risk assessment is conducted for the compounds.
The current MCL for barium is 1000 ppb and was correctly used as the target
level. As stated in the FFS, levels of barium in two residential wells
violate this standard, and one is at the standard. Levels of barium found in
on-site groundwater samples are greater than the elevated levels found in
residential wells near the site. These homes are located west of the site.
the groundwater flow is east to west, indications are that barium is movin9
with the groundwater off-site.
As
COMMENT
It appears that the Risk Assessment of the FFS has misapplied the concept of
the Hazard Index for the various contaminants. If the Hazard Index for an
individual compounds is less than one, it is of no consequence and the global
hazard index should not reflex its presence. Hazard Indices are not meant to
be additive for a subgroup, thus artificially creating an index which exceeds a
value of one. The Hazard Index should be calculated on an individual compound
basis.
u.s. EPA RESPONSE
The PRPs' comment is incorrect. The Superfund Public Health Evaluation Manual
(EPA 540/1-86/U60, October 1986) states on page 98:
This approach [the Hazard Index] assumes that multiple sub-
threshold exposures could result in an adverse effect and
that the magnitude of the adverse effect will be proportional
to the sum of the ratios of the sub-threshold exposures to
acceptable exposures [i.e., an additive effect]. If the
hazard index results in a value greater than unity, segregate the
compounds in the mixture by critical effect and derive separate
hazard indices for each effect.
This approach derives from EPAls guidelines on the assessment chemical mixtures
(51 FR 34014-34025).
COMMENT
Exposure assessment documentatio~ presented in the FFS is incomplete. Details
on how such things as exposure to volatiles via inhalation while showering are
not presented (e.g., duration and frequency of showering) and cannbt be properly
reviewed and evaluated at this time. We would urge the U.S. EPA to make the
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project risk assessment report available in its entirety for public review and
comment before goin~ forward with the Record of Decision and implementation of
alternative water supplies.
u.s. EPA RESPONSE
.
The Risk Assessment is incomplete only in the sense that it does not examine
all sources, pathways and receptors of potential contamination (e.g., direct
contact leachate, ingestion of site soils, etc.). However, the Risk Assessment
did evaluate the major exposure pathways via groundwater, such as inhalation
and ingestion, and it was established that a threat to public health did exist
through this pathway. In addition, federal drinking water standards (MCLs)
were exceeded for vinyl chloride and barium. U.S. EPA's remedial program uses
MCLs to determine need for action. Since the publication of the FFS, recent
data revealed that levels of nickel exceeded Ambient Water Quality Standards
(AWQS). While AWQS do not establish requirements, they provide guidance on
pollutant levels that pose threats to human health.
COMMENT
The FFS exposure assessment for the short-term exposure scenario appears to
need to be. reevaluated. The FFS data indicate that a two-year exposure is more
severe than the lif~time exposure scenario to the same dri.nking water. This
is completely opposite of most exposure assessments, as long-term exposure
would be expected to have certain cumulative effects.
u.S. EPA RESPONSE
The exposure assessment examined the short- and long-term exposure scenarios
for both carcinogens and non-carcinogens. For carcinogens, the long-term
exposure scenario was worse than the short-term exposure scenario. For non-
carcinogens, the short- and long-term exposure scenarios for adults are equal
because exposures are averaged over the specified time period. For non-carcino-
gens in children, the short-term exposure is most harrnful because of the sen-
sitivity of the population, while long-term exposures are usually not applied
to children.
COMMENT
The FFS does not provide the groundwater contour maps utilized by ~he Agency in
evaluating groundwater flow direction from the site.
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U.S. EPA RESPONSE
U.S. EPA provided the groundwater elevation data (Appendix 0 of FFS) from which
our conclusion that groundwater is moving from east to west was reached. U.S.
EPA contends that such data should ~e more than sufficient for the PRPs to
evaluate U.S. EPAls conclusion regarding groundwater flow direction.
COMMENT
After our conversations with the Ohio Environmental Protection Agency (OEPA),
we suggest that obtaining water from Lakemore may not be the best alternative.
OEPA noted that Lakemore has had both supply and quality problems in the past.
Water would contain both iron and manganese. Operationally, the line from
Lakemore to the affected area poses a problem, since it passes through
unincorporated Summit County and then unincorporated Stark County. If not
owned and operated entirely ~y Lakemore, problems with obtaining agreements
with either or both of the counties for ownership and operation of the lines
may be difficult to obtain.
U.S. EPA RESPONSE
U.S. EPA gave due consideration to. comments from the PRPs and the public con-
cerning the water systems U.S. EPA evaluated and other public water systems.
U.S. EPA has decided to go forward with a Record of Decision to design and
construct an alternative public water supply system, leaving open the choice of
which water source to use from among the three alternatives considered in the
detailed evaluation of the FFS and the Summit County source suggested by the
PRPs. Since U.S. EPA is not choosing a specific sourc~ at this time, responding
to the PRPs comments regarding the four specific sources mentioned above is
premature. U.S. EPA will respond to comments regarding the four potential
sources of water at the time it selects a source.
COMMENT
The FFS states Residential Wells RWOS, RW39, and RW41 are located "west and,
hence. down groundwater gradient from IEL." Well No. RW41 is located northwest
of IEL and thus would be north of any emanating from the landfill.
U.S. EPA RESPONSE
Although Well No. RW41 is located just north (and west) of the landfill, it is
also close enough to being due west that a contaminant plume could arguably
spread northward as it travels west, therefore reaching RW41.
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COMMENT
While it is true that barium levels in samples from residential wells RW08 and
RW09 exceed the MCL of 1,000 ppb, their barium concentrations also exceed the
barium concentrations found in monitoring wells on the landfill. If the landfill
were the source of elevated barium levels observed ir RW08 and RW09, somewhat
~reater concentrations would be expected in the on-site wells (at the supposed
source) than at off-site locations where the contaminant would be somewhat
dispersed and diluted.
U.S. EPA RESPONSE
U.S. EPA disa~rees with the PRPs and contends that the data shows that levels
of barium found in on-site groundwater samples are greater than the elevated
levels found in residential wells near the site:--
COMMENT
Tables 2-4, 2-5, and 2-6 provide a range and geometric mean for various detected
contaminants, although in many instances the contamina~t was only dectected
once in a number of well sam~les. In some instances, the mean is greater than
the highest value presen~ed in the range. It 'is not possible to gave a range
of values based on only one observation.
U.S. EPA RESPONSE
The following provides a brief description of the nature of analytical data
received following a field sampling event and how the approach was derived.
The data reports receipt from analytical laboratories typically include a
listing of the compounds for which analyses were run and the observed concen-
trations of chemical components which were detected in environmental samples.
The compounds which were not detected during the analysis are cited accordingly.
The finding that a constituent is not detected does not mean that the constituent
is not present in the sample, but rather that the compound is not present at
levels equal to or yreater than the detection limit. Thus, an "undetected"
compound could be present in the environmental sample at any concentration from
0% to 99% of the detection limit.
In light of this situation, it was felt that some consideration should be given
to the possibility that there may be contaminants present in samples where
laboratory analytical results indicated that no contaminant had been. detected.
The decision on how this should be handled needed to balance the protection of
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public health with the uncertainty associated with the nature of the analytical
data, and the desire not to derive results which were unrealistically stringent.
As a result the decision was made to consider "undetected" compounds as being
present at concentrations equal to 50% of the detection limit.
While the above paragraph provides a general picture of the manner in which we
viewed data, this approach was actually used within the risk assessment in
certain sit~ations. If a constituent was detected at a frequency of one in
samples from a particular media, the yeometric mean was calculated based on the
detected value and a value equal to 1/2 of the lowest observed detection limit
for that constituent. If a constituent was not detected at all, then a geometric
mean for that constituent was not reported. In some rare instances, a laboratory
may have been able to provide an estimated value for the constituent which was
below the detection limit. In this situation, the geometric mean was also not
reported. The notes at the end of the tables referenced in the comment and the
text found within the document provide an explanation of the manner in which
these calculations were performed. The tables do not contain geometric mean
values greater than the maximum values in the range column for any constituent.
COMMENT
A closer ~ublic water supply, the Summit County-Country Club Village supply, is
located at Raber and Mayfair Road in Green Township, Summit County. The system
has adequate capacity to serve the affected area and has a 400~OOO gallon
elevated stroage tank. Gravity serivce without additon3l pumping may be possible.
JEPA noted that iron and manganese contents are lower ~han that of Lakemore.
A spokesperson for the county noted that the county would be willing to operate
and maintain the entire system as well, even that portion of the system in
Stark County. A well field expansion is also planned. If a rural easement is
available, 9,500 feet of 12-inch pipe would be required. If road right-of-way
is used, 16,500 feet of pipe would be required. It appears a cost savings
could be incurred by one of these alternatives. The FFS, before being finalized,
should fully investigate the proximity, capacity, and water quality of Summit
County system.
u.S. EPA RESPONSE
u.S. EPA conducted a brief analysis of the Summit County alternative suggested
by the PRPs (see Attachment C), and determined that the Summit County pUblic
water supply may oe a viable source of water. U.S. EPA gave due consideration to
comments from the PRPs and the pUblic concerning the water systems U.S. EPA
evaluated and other public water systems. U.S. EPA has decided to go forward
with a Record of Decision to design and construct an al:ernative public water
supply system, leaving open the choice of which water source to use from among
the three alternatives considered in the detailed evaluation of the ~FS and the
Summit County source suggested by the PRPs. Since U.S. EPA is not choosing a
specific source at this time, a full response to the PRPS comments regarding the
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four specific sources mentioned above is premature. U.S. EPA will respond to
comments regarding the four potential sources of water at the time it selects a
source.
COMMENT
The FFS rapidly dismisses the alternative of drilling new, deeper wells to
replace the three to ten affected residential wells. Three reasons are give~:
(a) a fear of contaminants migrating over time to deeper wells (this discounts
the effects of attenuation and dispersion of contaminants, but more importantly,
it does not consider the beneficial effects of site remediation); (b) the need
for frequent monitoring (a comparatively minor issue; the frequency of monitoring
is debatable (as is the analytical effort) at and needs to be defined before
this option is dismissed); and (c) fear that plugging of existing wells and
construction of new deeper wells may contaminant deeper aquifers. (This
concern is unfounded, as this type of well installation is routinely done;
also, this concern again discounts the impact of site remediation). This
alternative action warrants further consideration. This option has the lowest
costs associated with it in comparison to the other evaluated alternatives and
thus, depending on the scope of the project as finally determined, may be the
most cost-effective alternative.
U.S. EPA RESPONSE
The PRPs appear to be emphasizing cost. Alternatives are first evaluated on
their effectiveness and implementability, and finally on cost. As the FFS
states, the alternative which involves deepening existing residential wells in
the contaminated area was rejected because, with regard to public health, it
is not as effective as the recommended alternative. The most important factor
considered is that the shallow aquifer (sand and gravel) is continuous with the
deeper aquifer (bedrock), as there is no imper~eable jarrier separating the two
aquifers, so that downward migration of contaminants is not prevented.
COMMENT
Construction of a new community well supply is also a viable alternative. Two
or three wells located upgradient of Industrial Excess Landfill would probably
be adequate to supply the 100 homes. Pressure (hydropneumatic) tanks or ground
storage with booster pumps could be utilized. It is likely that iron removal
treatment would ~e reyuired by OEPA, but the water should 10t be any harder
than currently being ~sed. Costs should not be as high as indicated in the FFS
estimate for this alternative. One of the problems of a water system such as
this is ownership and cJntinued operation and maintenance of the system once
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constructed. In Ohio, the common forms of ownership are by a homeowners'
association, a public utility company, or a pUblic entity. In this case, the
public entity could ~e the Stark County Engineers or Lake Township. It is not
likely that Lake Township would have the wherewithal to operate the system,
although it is a possibility. Stark County does not operate any other water
systems at this time to our knowledge, although they do operate many wastewater
systems.
u.S. EPA RESPONSE
u.S. EPA gave due consideration to comments from the PRPs and the public
concerning the water systems U.S. EPA evaluated and other pUblic water systems.
U.S. EPA has decided to go forward with a Record of Decision to design and
construct an alternative public water supply system, leaving open the choice of
which water source to use from among the three alternatives considered in the
detailed evaluation of the FFS and Summit County source suggested by the PRPs.
Since U.S. EPA is not choosing a specific source at this time, responding to the
PRPs comments regarding the four specific sources mentioned above is premature.
U.S. EPA will respond to comments regarding the four potential sources of water
at the time it selects a source. .
COMMENT
The Lakemore., Country Club Village, and North Canton ~ater supplies have all
been analyzed for 38 volatile organic chemicals (VOC) by OEPA. The Lakemore
and Country Club water supplies were free of the VOCs. North Canton found
small amounts of several vac compounds in two wells. This is presently being
investigated by OEPA and the city.
u.S. EPA RESPONSE
u.S. EPA has received and appreciates the provision of this water quality data.
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I V .
REMAINING CONCERNS
Almost all of the comments received requested that U.S. EPA expand the area
designated to receive the alternate water supply. In conjunction with expansion
requests, many commenters preferred that North Canton be the chosen alternative,
as its water system has a larger capacity and the water is softer than what
would be obtained from the Village of Lakemore. Also, a few commenters recognized
that U.S. EPA is limited by law as to its ability to fund an expanded system.
These same commenters recogni zed that it then becomes a 1 oca 1 res pons i bi 1 ity to
pay for an expanded system.
As previously stated, the purpose of the Superfund program is to restore or
replace, and not improve upon, a resource that is lost due to contamination
from an NPL site. U.S. EPA has determined that the area currently and potentially
impacted by the IEL site consists of approximately 100 homes west of the site,
and that, to be protective of public health, alternate water should be provided
to that area. However, based on the comments which have asked that U.S. EPA
, consider sources of water other than the Village of Lakemore, specifically from
- the City of North Canton and from Summit County-Country Club Village Community
Water Supply, U.S. EPA is deferring the decision on the source of the water
until after initial design activities are completed. The design engineers will
meet with State and local engineers and other personnel familiar with the
operation of the water supply systems in order to develop detailed technical
data not available during the RIfFS. This data can be used to decide which
water supply to utilize. The evaluation of the water supply to be used shall
be submitted as part of the preliminary design repor: when the overall design
ejfort is approximately 30 percent complete.
Regarding the many comments on expansion, to design and construct a system
larger than what has been determined to be protective, or to provide a better
quality of water than what previously existed, is termed betterment. Betterment
is allowed only if the State, or political subdivision thereof, pays for all
casts related to it. If U.S. EPA receives a formal committment which defines
the size of the area to be served, including provision of incremental funding
for design and construction, from the State, local government or community,
U.S. EPA will work with those entities to determine the funding of such a
project and the appropriate source of water, given the change in the design
criteria.
Under this scenario, U.S. EPA would transfer responsibility for the project
to the State of Ohio, through a cooperative agreement between U.S. EPA
and the State. An agreement between the State and the community would
have to be entered into, in order to fund all incremental costs of
the water system. If such a formal commitment is not received by U.S.
EPA within 60 days after signing the Record of Decision (ROD) document,
U.S. EPA will proceed to desig'l and imple'nent its recommended alternative of
connecting the 100 homes to a new source of water. U.S. EPA will address any
significant changes in compliance with Sections 117(b) Final Plan and 117(c)
Explanation of Differences of SARA.
-34-
-------
.
ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE IEL SITE
Community relations activities conducted at the IEL site to date have included:
U.S. EPA finalized a community relations plan on August 15, 1985 that
outlined community relations activities to be conducted during the RI/FS;
In March 1985, U.S. EPA established an information repository in the site
community at the Lake Township Trustee's Office;
In July 1985, U.S. EPA held a public meeting to present the work plan
for the R.I/FS at the site;
In July 1986, U.S. EPA held a public meeting to describe the Phase I
Remedial Investigation sampling results and present the proposed Phase
II RI activities; .
From October 1985 to August 1987, U.S. EPA prepared 18 updates and/or
fact sheets describing on-going RI activities at the site;
On April 20 and 21, 1987, U.S. EPA held a public availability session.
to answer resident's questions about the IEL site. At this time, U.S.
EPA also formed the IEL Information Committee;
In April, May, and July 1987, U.S. EPA attended facilitated meetings of
the IEL Info~ation Committee;
In August 1987, U.S. EPA held a public meeting in Uniontow.; to answer
questions and accept oral and written comments on tre Proposed Plan and
the Focused Feasibility Study (FFS) evaluating alternate water supplies
for the IEL site. Transcripts of this meeting are available at the U.S.
EPA Region V office in Chicago, and at the Information Repository located
in Hartville, Ohio. Additional comments on the FFS were accepted
during the public comment period, which ran from August 12, 1987 through
September 10, 1987.
-------
AfTI'!
",n "0" (SQQ nolQs al "nd ()f tablgs)
COHPh... .>rm Of TWfAflVEU' IDEtHIfIED COHPOUNDS fOUND IN RESIDENflAL ~ELlS
ftllO TIIOSE FOUND IN HONlfORING ~ElLS
RESIDENTIAL ~ELLS
TENrllfJ VEU' IOENfI fI ED COHPOUNDS (CASE 11>2%)
SAHPLES
----------------------------------------------------------------------------------------------------------------------------
RANGE (PPO)
1.1.2-rRICHLOROfrHANE
l.l'-OKVBISErHAIIE
1.3.I>-rRIOXOCAHE
1-[ fttOX\'OllrANE
1.1'-rHIOBIS(Z-CI.I-DIHErHVLErHVL)-S...PHEHOL
1-ACErVlHORPHOLINE
1-(I.I-DIHEfHLErHYl) OENZDIC RCID
DICHLOROfLUOROHETIIAHE
OIHHVL EsrER PflOSPHORIC ACIO
HEXADECANOIC HClD
HONO (Z-EfHVLHEX\'U ES rER HEXAttEDI 01 C RCI D
51 LOXANE
SULfUR
rEfRAH\'OROfllRAH
rETp.AHErHVlUp.EA
THI A20! E
TRICHLOROfLUOROHErHANE
flU au:
R~OS.R~on.R~09.R~II(2)
P.~OS.R~UI>
Rlill
RillS
Riloa
RIlIl
RIIOS
PoIIII(Z)
RII09. P.1I11
RIIOZ.RII03.R~12.R~13.RIlII>.RII17.RII20.f9.F9.HB
RII11
RIIOI.R~07.R~II(2)
RIWS
RIIOS. Rlill (2)
Rill)'}
fLU DU: (2)
CJCJ
11-22
11-17
I>
3
5
1
o
3
1-7
3-1>
2
1-7
CJ
3
2
11
e.
-------
AI TflCHt1ENT "0" conlinu"d
RfSI~ENTIAL ~[LLS. conl.
CASE '1>577
SRMPLES
------------------------------------------------------------------------------------------------------------------------------
RANGE (PPO)
1.1,2-TRICHLORO-t,2,2-TRIFLUOROETIIAtiE
1. 2-01 ETHOX'r'-E IIIflNE
1.3.6-TRIOXACR~E
2-HETH'r'L-BUTANOIC ACID
2-HETH'r'L-CYCLUPENTANOL
2-NETHYL-...PROPHNOIC ACID
3.3.3-TRICHlORO-l PROPENE
R~
-------
ATTI~C.
"0" conl.
R~SJOENTIAL UELLS. conl-
CASE '&&3&
SAHPLES
-----------------------------------------------------------------------------------------------------------------------
RANGE (PPO)
1.I'-OKVOISETHRHE (ETHVL ETHER)
1.2-01 HUOXV-EfltAU£
1.3,~-TRI0XACAU£
1.1-0IH£rUOKV-2.3,5,&...BEN2ENE
I-HHOKVBUTANE
I-HHHVl-IH-IHIOR2UlE
2-HErUOKV-...B£HZF.HEPROPANOl
2-HErHVl-2-PROPAHOL
1-flCETVl-HORPHOlINE
1-Burmw-BUIAtWI C Rei 0
1- E TH\'l-HORPUOLI HE
1-(1.1-DIHETHVl.--) OENZOIC ACID
&-HETHOKV-...1,2-CRESOTIC ACID
AZflCVClorRIOECAN-2-0NE
BI 5 (PEHTAFlUOROPIIEH. .. )BEHZEHAHI t4E
DI S (PEHTAFlUOROPIIEti. . . )PHOSPHI NE
RU05.RI-I07
R"05.RI-I08,R"09.RUI1
R"05(2) .R~OU.HB
R"l1
R"Oa.RI-I09
R"l1
R~oa
RUB
~oa, RI-I09
R~OO. RI-I09
R"OO
RU09, Rl-Il1
R"09
R"09, Rl-ll1
RU 10. Rl-ll1.R~15.FB
RU01.RI-I05(2).RUO&.R~Ol.RI-I09.RUII.
. RUI3(2).RU11.RUI5.RUI9.RU51.FB.HB
RUOS -
R"09
R~OI,RI-I05.RU01.RU09
R~08. RI-I09
R"OS(2).R~07.R~OO.RU09.RUll
H. H--OI .. .BEH2EtlECnRBOXI HI OAHIDE
O-HE THVlOKI HE - 3-PEHTAHOttE
SULFUR
TURAHHVL-DI PHOSPIIORI C RCID
TE.TRAH\'OROFURAti
1-10
0-31
5-19
5
5-12
o
1
1
3-6
1-1
2
3-5
{,
2-3
3
2-1&
1
5
2-10
1-5
1-10
..
-------
ArrACHHEHf "B",cooL
HOHr fORI t4G ~HL 5
fEHTAflVElY IDENTIFIED COHPOUNDS (CASE .5909)
SAHPlES
RANGE (PPO)
--------------------------------------------------------------------------------------------------------------
1.1'-OV.YBISETIIAHE
1.1.7-TRIHEfH~l-BICYClO[2.2.1]HEPTAH-2-0NE
l-IIEXYl-A2rRIOIHE
1-(2-HETHOXY-I-HfTHYlEfHOXV)-2-PROPANOl
1-[I-HETHVl-2-(2-PROPEHYlOXV)EfHOXY]-2-PROPANOl
1- [2- (2-HHHOXY-I-NEflWlHHOXV)-1-HE THVl-2-PROPANOL
2-CVClOHEPfEN-I-0NE
2-HETH\'l-CYClOPEtHAHONE
2-HE fHYl-IRANS-c\'ClOPfNfANOl
2-PROPENYl-CVClOPENfAHE
1-ETHYl-1H-l.2,1-TRIA20l-3-RHIHE
1-HETHYl-2-PENfAtfOl
9-EI COSYt~E
C\'ClOHEPTAHOl
CVClOHEPTANOHE
CVClOHEXAtfE
OIETHYl ESTER PIIOSPIWRIC ACID
FURAt~
HEXADECANOIC ACID
HONAt~AHI DE
H'-CYClOOCTVL-N.N-OIHEfHYl-UREA
N-PHENVl-IH- I HI DflZOlE -'1-CARDOXAt1I Of
TE T RAHVDROFURAt~
TflRAHETHVl UREA
TEfRAHETHYl-THIOUREA
.BETA.,DEfA.-DIHETHVl-BENZENEPROPAHOIC RCID
. HU015,HU03S
HU03S
HUOIS
NU03S
HU03S
NU03S
HI-I020.NU03D
HUOtS,NO
HUOtS.HO
HU03S .
HU02D
HU03S
"HUO 15
HU035
HU035
HU035
HU035
HUOt5
HI-I035
HU030,HO
HU035
HUOJS
HI-I03S
HU03S
HU03S
HU03S
1')-12
2'1
39
3')
22
100
12-70
39
20
'10
21
27
32
130
110
26
36
15
11
1'1
33
60
11
20
15
11
.
-------
An.
.HT "0", cont.
MOtn TORIHG ~EllS. cont.
TENTATIVELV IDEHTIFIEO COMPOUHDS (CRSE 17009)
SAMPLES
RAHGE (PPO)
-----------------------------------------------------------------------------------------------------------------------
1.I'-OXVOISHIIANE
i. 3.5- rRi tiEHiYL -BENZENE
1.3-0I
-------
AI TACIfHENT "0". cout.
HONITORING ~ELLS. couto
TENlnrIVELY IDENTIFIED CO"POUHDS (CASE 17037)
SAHPLES
RANGE (PPO)
----------------------------------------------------------------------------------------------------------------------
II>
12-17
1.2-01 HHOXYHHRltE
1- ( 1. 1-01 HETHYLE 11I\'l) -2-HETH'r'l-l. ]-PROPANE -2-HETH'r'l-PROPANOI C ACID
20H)-OEN20THIAZOLOHE
1-ACn'r'l-HORPHOU HE
HEHt1NOIC ACID ANII'r'ORIDE
PROr'r'L-C'r'ClOPEUTHItE
TETRAHYOROFURAH
TETRAHETH'r'l-UREA
"~03S
""12D.H"IID.H~02D(2).H~10H.H~0ID.
H"105.H~12"(2).H~IIS
""035
""035
FB
""03S
H"035
""035
51
<)
31
12
10
21
".
-------
AfTf
'ENT "8",
cont.
TENATATIVELY IDENTIFIED CDMPDUND5 THAT EXACTLY HATCH
BET~EEN RESIDENTIAL AND MONITORING ~ELLS - IEL
TENTATIVELY IUENTIFIED COMPOUND5
SAMPLE5
RANGE (PPB)
-----------------------------------------------------------------------------------------------------
I,I'-OXYBISETHAHE
1, I' -OXYBI SETI lANE
l,l'-OXYBISETHANE
1,1'-OXYBISETIIANE
1,2-DIETHDXY-ETHANE
1,2-DIETHDXY-ETHANE
1,2-DIETHDXY-ETHAHE
4 -ACETYL -HORPI IOL I HE
4-ACETYL -HORPIIOL I NE
4-ACETYL-HORPHOLINE
DIETHYL ESTER PHOSPHORIC ACID
DIETHYL ESTER PHOSPHORIC ACID
HEXADECANOIC ACID
HEXADECANOIC ACID
TETRAHYDROFURAN
TETRAHYDRDFURAN
TETRAHYDROFURflN
TETRAHYDROFURAN
TETRAHYOROFURAN
TETRAHYOROFURAN
TETRAMETHYL lIREA
TEIRAt-IETHYL UREA
TETRAMETHYL UREA
N!-!Q?S,MHOlS
RWOS,RH08,R~09,RHll(2)
H~015,MH035
RHOS,RH07
HH035
RH38,FB
R~OS,RH08,R~09,RHII
RH08
HH035
RH08,RH09
RHll(2)
t1H035. .
RH09, RWll
M~03S
t1H075
U~035
R~OS(2),R~07,RW08,RH09.RWll
RHOS
RH38
MH035
t1H035
R~08, RHll(2)
UH035
1n-1D
&"" &V
11-22
19-42
4-10
16
I-S
8-31
5
9
3-6
3
36
4-7
14
13
18
4-10
9
3
14
28
3
24
Notes:
"RH" and "MH" sample numbers refer to residential and monitoring wells, respectively
"FB" refers to Fields Blanks collected during sampling and "MB" refers to Method
Blanks run at the laborator-y during analysis.
All samples analyzed by EPA CLP laboratories.
..
-------
lit
ATTACHMENT C
COUNTRY CLUB VILLAGE COMMUNITY WATER SUPPLY
The Country Club Village Community Water Supply is located approximately two
mil es Wt~st-southwest of Uniontown and obtai ns its water from two well s compl eted
in the Sharon Conglomerate of the Pottsville Group. The system includes a
400,000 gallon elevated storage facility. The well water has a hardness of
about 200 to 250 mg/l as CaC03 and, like most well water in the area, contains
relatively large amounts of iron and manganese. The water system, which is
owned and operated by Summit County, is currently operating at 30-45 pe~cent of
its design capacity of 0.75 mgd. Summit County has tentative plans to drill
another well to augment the existing system. Existing wells are equipped with
chlorination units. A 12-inch water main is available just south of the
intersection of Raber Road and Gleneagles Boulevard.
The provision of water to Uniontown would require the construction of both a
trunk line from Country Club Village and a distribution system to supply water
to the users. Due to uncertainties regarding system hydraulics, a booster pump
station having at least two pumps has also been included in the cost estimates.
The pumps would be capable of pumping 500 gpm at 50 to 60 psi; and would be
regulated automatically using pressure switches installed downstream of the
booster pump station. The pump station would be located near the intersection
of Raber Road and Gleneagles Boulevard. Water supplied to Uniontown would be
metered at this station. Most of the required equipment (booster pumps, valves,
flow meter, and controls) would be housed in a brick and block building measuring
approxi~ately 12 feet by 12 feet in dimension.
The water obtained from Country Club' Village Community ~~ater Supply is hard and
the use of this water in Uniontown would warrant continued use of existing home
softeners. No additional treatment or water quality monitoring would be
required. Summit County would operate and maintain the booster pump station
and that part of the 12-inch diameter trunkline located within Summit County.
The remaining portion of the 12-inch trunkline and the distribution system
itself, consisting of 3,200 feet of 6-inch diameter mains, 6,700 feet of 8-inch
diameter mains, and 100 service lines, would be operated and maintained by the
users or their designee such as Lake Township, Stark Cou~ty, or Summit County.
-------
ALTIRNATIVE 80. 4
PURCHASI VATla fROK COONTRY CLUB VILLAGK VATIR SUPPLY, SO!KIT CODITY
CAPITAL COSTS'
INDUSTRIAL IlCISS LARDriLL
fOCDSID fKASIBILITY STDDY
UK II
09/22/81
-------------------------------------------------------------------------------------
'"
: . . ITKK : OMITS: QOANTITY : DB IT COST: TOTAL COST:
:-----------------------------------------:-------:----------:-----------:------------:
, I I I I I
I I I , t I
: 1. Kobilhation : LS: 1: $50,000: $50,000:
I I I t I I
I I I tit
: 2. Booster PiliP Station : LS: 1: $80,OOQ.: $80,000:
I I I I I I
I I I I t I
: 3. Furnish & Illstall 6-illch Waterlaill : n : .3,200: $25: $80.000:
I I I I , I
I t I I I t
: 4. furllish & Install 8-inch Matenain : n : 6,700: $30: $201,000:
I I I I I ,
I I I I I I
: 5. furllish & Illstall 12-inch Trunk Line: fT : 11,000: $40: $440,000:
I I I 1 , I
I I 1 I 1 I
: 6. Bouse Servi'Ce : U: 100: $1,200: $120,000:
I I I I I I
I I I , I I
: 7. Abandon hiisting Wells : U: 100 : $500: $50 I 000 :
I I I 1 1 I
I I 1 I I I
I I 1 I I I
I I I I I I
I I I I I ,
I I 1 I I I
I , I , 1 ,
I I , I I I
I I I , I I
I I I I 1 I
, I I I I I
I , 1 I I ,
I I , , I I
I I I I I I
I , I , , ,
I I I I I I
I , , I I I
, I t t I I
, I , t , I
I I I I , ,
1 I I I 1 I
1 I I I t I
I t I I I I
I I , , I I
t I I I I ,
t I I It'
, , I I I ,
I , I I t t
, I I , I I
I , I , I ,
'-------------------------------------------------------------------------------------'
, '
1 SUBTOTAL $1,021,000.:
: COHTIMGIBCIKS @ 101 $102,100 :
: SUBTOTAL $1,123,100 :
'-------------------------------------------------------------------------------------'
I '
: IIG1!lIi1!G DISIGB @ - 101 $112.310 :
: COSSTRUCTIOI & STARTUP !SSISTARCI @ 101 $112,310 :
:-------------------------------------------------------------------------------------:
- : TOTAL $1,341 ,1-20 :
-------------------------------------------------------------------------------------
-------
ALTERNATIVE 80. 4 .
r~RCHASE MATIR rRO~ COOSTRY CLOB VILLAGI WATER SOPPLY, SUKBIT COOKTY
OPIRATIOH . KAIHTEHA8CE COSTS
IKDOSTRIAL EICiSS LARDrlLL
focaSED FEASIBILITY STUDY
UK II
09/22/81
--------------------------------------------------------------------------------
:'
: IUBS : COST:
:-----------~-------------------,------------------------------------:------------:
I I I
t I I
: 1. Mater Purchase Costs - 15 Ig/year @. $1,700/lg : $25,500:
1 ' I
I I I
: 1. Labor - 4 hoars/veek @ $20/hour : $4,160 :
1 I I
I I I
: 3. Distibation Syste. Repairs and Kaintenance : $2,000 :
I I I
I 1 I
: 4. Ad.inistrative and Kiscellaneoas Expenses : $2,500 :
: : ------------: .
: ARROAL O&K: $34,160:
1 I I
I I I
: 5. Annaal Iqaiplent Replacelent Costs (AIRC) ::
: a. 5 percent discount rate: $46.000 x 0.055 : $2,990 :
: b. 10 percent discount rate: $46,000 x 0.106 : $4.880 :
I I
I I
: 6. Annual O&~ PIns AIRC (Inclades PUlP Station Operating Costs) :
: a. 5 percent discount rate. : $37,150:
: b. 10 percent discount rate : $39,040:
1 I I
I I I
: 7. Preaent Morth of Capital Costa : $1.341,120 :
I I I
I I I
: S. total Present North of 0 & B Costs ::
: a. 5 percent discoant rate : $571,000:
: b. 10 percent discount rate : $368,150':
, 1 ,
I I ,
: 8. total Present North of Capital and 0 & B Costs : :
I. 5 percent discount rate : $1,918,120 :
b. 10 percent dlsconnt rate : $1,115,870 :
I 1
I I
I I
I I
I I
, I
--------------------------------------------------------------------------------
-------
Annuali:ed equiplent replacelent coata (AiRC) lere estilated by
lultiply1ng replacelent costs by the Capital Recovery Factor (CRr).
n D
CRr : i(1 f i) / (1 f i) .1
Where: D: Period in years: 30 years
.1 : Discount rate: 1 : 5 percent; CRr : 0.065
: 1 : 10 percent i CRr : 0.106
Equiplent replacelent costs throughtout the project life are
estilated as [011088 :
a. PUlPS and lotors
- Replace every 10 years @ '18,OOO/replacelent
$36,000
b. Riscellaneoos replaceleats
$10,000
---------
TOTAL
$46,000
, .
I
I
I
I,
Present vorth of annual costs are estilated by lultiplying the annual
costs by the Present Marth Factor (PWF).
n n
pwr : (1 + 1) -1 I 1(1 + i)
Where: n: Period in years: 30 years
1 : Discount rate: i : 5 percent; PMr : 15.37
: i : 10 percent; pwr : 9.43
-------