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United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EPAIROD/ROS-881067 .( )
June 1~8 ~
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a, tEPA
Superfund'
Record of Decision:
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Coshocton Landfill, OH
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U.S: Environmental Protection Agency'
Region III Information Resource
Center (3PM52). .
841 Chestnut Street ;r :::
Philadelphia, fA 1919z ," ~ ~.;..~:;;~~.~~
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Hazardous Waste CoUection
informatiOn Resource Center
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EPA Report Ct,!l9i:tion
Information Resource Cer.:ar
US EPA Region 3
Philadelphia, PA 19101
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50272 -101
REPORT DOCUMENTATION 11. REPORT NO. / '/ 05 88/067
PAGE ' EP A RO D R - .
2.
3. Recipient"s Acce..lon No.
.
.. Title end Subtitle
SUPERFUND RECORD OF DECISION
(' 'octon Landfill, OH
t. .t Remedial Action - Final
5. Re'm; ~~, /88
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6.
7. AuthorCs)
8. ~erforming Organization Rept. No.
9. Performing Org8nl%ltlon Neme 8nd Addre..
10. Project/Task/Work Unit No.
.- _n ----
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11. Contr8ctCC) or GrantCG) No.
(CI
(G)
--.--
12. Sponsoring Or.8niz8tlon N8me and Address
U.S. Environmental Protection
401 M street, S.W.
Washington, D.C. 20460
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Agency
13. Type of Report & Period Covered
800/000
1..
15. Supplement8ry Notes
18. Abstract (Umlt: 200 words)
The Coshocton City Landfill (CCL), an aO-acre landfill, is located in Franklin
Township, Coshocton County, Ohio. The landfill is built on abandoned, subsurface strip
mines, where an extensive network of mine shafts were developed. CCL is located between
two small intermittent creeks that drain toward the Muskingum River, 1.5 miles to the
west of the site. The area is characterized by considerable topographic relief, with
11 streams situated between steep rolling hills. Most of the surrounding land is
~ .aer woodlands or pasture land used for cattle grazing. The landfill property was
used in the early 1900s, and again from the mid-l950s until mid-1979, for subsurface
shaft mining of coal. The city conducted landfill operations at the site between
1968 and 1979; however, the operations were not well recorded. The waste received at
the landfill consisted of mixed municipal refuse and industrial wastes including
relatively inert solid scrap wastes, nonhazardous materials, and hazardous liquid waste
types sucn as spent chlorinated solvents, non-chlorinated flammable solvents, .resins,
an~ prasticizers. Much of the landfilled waste is situated in the void created by
abandoned strip mine operations. Some waste was also reportedly placed in shallow
excavations in the southern portions of the site. Currently, portions of the landfill
site are covered with what appears tb be mine spoil materials. The cover on the site
. (See Attached Sheet)
17. Document An81ysls e. Descriptors
~ ;;Record of Decision
Coshocton Landfill, OH
First Remedial Action - Final
-Contaminated Media:- gw, sw
Kev Contaminants: metals (arsenic),
b. 1dentlfiers/Open.Ended Terms
organic (PAHs), VOCs (TCE)
,- 1SATI Field/Group
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18. .
,4Ibility Statement
~. Security Class-iThiS Report)
None
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21. No. of Pages
90
. ----...........,
20. Security, Class (This Pagel
NOne
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTI5-3S) .
Department of Commerce
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EP~/ROD/R05-88/067
locton Landfill, OH
'P.~st Remedial Action - Final
b 16.
ABSTRACT (continued)
however is, not consistent, with little or no cover in some areas. In addition,
standing water is observed in several areas. Scattered surface deposits of drums and
other metal objects are present at the site. Numerous leachate seeps exist on portions
of the landfill. The primary contaminants of concern affecting the surface and ground
water at this site include: carbon disulfide, TCE, PAHs, chlorinated and
non-chlorinated solvents, and heavy metals (mostly arsenic).
The selected remedial action for this landfill includes: installation of a 2-foot
low permeability soil cap over the landfill, with top soil and vegetation: imposition of
deed restrictions, including fencing; filling and grading the necessary areas; and
possible installation of a gas collection and venting system, as well as a leachate
collection system and a drainage layer. This remedial action will also include routine
ground and surface water and sediment monitoring to identify changes in contamination
concentrations. The implementation of this remedial action will entail a capital
investment of $8,010,000 with a present value of O&M cost of $910,000 associated with
the remedy.
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Record of Decision
Site Name and Location
Coshocton City Landfill
Coshocton, Ohio
Statement of Basis and Purpose
This decision document presents the selected remedial action for the Coshocton
City Landfill site developed in accordance with the Comprehensive Environ-
mental Response, Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 and is consistent with
the National Oil and Hazardous Substances Pollution Contingency Plan to the
extent practicable.
This decision is based upon the contents of the administrative record for the
Coshocton City Landfill site.
The State of Ohio concurs on the selected remedy.
Description of the Remedy
The selected remedial alternative for the Coshocton City Landfill site is to
cover the 1 andfi11 with a low permeabil ity cap and undertake other actions
required by State sanitary landfill closure requirements. The major
components of the selected remedial alternative are:
Complete site fencing and posting
The recordation of notice in the chain of title regarding uses to
which the property has been put, and any restrictions on its future
use, referred to herein as "deed restrictions"
Site grading to promote precipitation runoff and reduce infiltration
Site capping which meets State solid waste landfill requirements
and which minimizes leachate generation and prevents direct contact
with contaminated materials
Top cover of topsoil and revegatation
Site monitoring including groundwater monitoring, surface water
monitoring and landfill gas monitoring to determine the effectiveness
of above measures and to provide early alert as to the need for other
actions
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The following components will be evaluated during the Remedial Design (RD) and
will be included if necessary:
Landfill gas collection and venting system
Leachate and groundwater collection and on-site storage system
with facilities for truck loading
Provisions for on-site or off-site treatment and disposal of
collected leachate and groundwater at a local POTW (The Coshocton
POTW was used for evaluation and cost estimation) .
Consistent with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300, I have
determined that, at the Coshocton City Landfill site, the selected remedial
alternative is cost-effective, provides adequate protection of public health,
welfare and the environment, and utilizes treatment to the maximum extent
practicable.
The action will require operation and maintenance activities to ensure
continued effectiveness of the remedial alternative as well as to ensure
that the performance meets applicable State and Federal surface and ground-
water criteria.
I have determined that the action being taken is consistent with Section 121
of SARA. The State of Ohio has been consulted and concurs with the selected
remedy.
Declaration
The selected remedy is protective of human health and the environment and
attains Federal and State requirements that are applicable or relevant and
appropriate to this remedial action and is cost effective.
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This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this site. However,
because treatment of the principal threats of the site was not found to be
practicable, this remedy does not employ treatment as a principal element of
the remedy. .
Because this remedy will result in hazardous substances remaining on-site,
a review will be conducted within five years after commencement of remedial
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action to ensure that the remedy continues to provide adequate protection of
human health and the erlvironment. .
41
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Valdas V. Adamkus
Regional Administ ator
DATE
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I.
SITE NAME, LOCATION, AND DESCRIPTION
The Coshocton Landfill is located on approximately 80 acres in the
east half of Section 3, Franklin Township, Coshocton County, Ohio, 3.5
miles southeast of the City of Coshocton, Ohio. Site access is by an
unimproved road south of State Highway 83.
The Coshocton Landfill is located between two small intermittent
creeks that drain toward the southwest into the Muskingum River, 1.5
miles west of the site. Within a quarter mile of the site,
topographic relief exceeds 200 feet, the elevation varies from about
800 to 1,000 feet msl. . .
Coshocton County is on the western edge of the Appalachian Plateau.
The area is characterized by considerable topographic relief with
small streams situated between steep hills. The topography is steeply
rolling; level land available for tillage is primarily in the river
valley bottom lands.
Active, abandoned, and reclaimed coal strip mines are scattered
throughout the region. Coshocton Landfill is built on abandoned,
strip-mined land. Until early 1986, an active coal strip mine was
operating to the immediate east of the site. Much of the land to the
south and to the west of the site has been mined and reclaimed.
The uplands area around the landfill is sparsely populated. Homes are
generally associated with small farms. Drinking water in the area is
supplied by individual private wells. The steep topography in the
immediate vicinity of the landfill limits the use of the surrounding
land for agriculture. Most of the land is either woodlands or pasture
land used for cattle grazing. Livestock have been observed using the
two small intermittent creeks as a source of drinking water.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The earliest documented economic development activity at the Coshocton
Landfill property was subsurface shaft mining of the Middle Kittanning
Coal in the early 1900's. An extensive network of mine shafts was
reportedly developed under portions of what is now the landfill
property, but the full extent and date of termination of mining
activities are unknown.
Portions of the landfill property were strip mined for further removal
of the Middle Kittanning Coal from the mid-1950's until mid-1979. In
July 1978, the City of Coshocton signed a coal lease with the Conotton
Land Company, which subsequently relinquished the mineral rights to
Cravat Coal Company. Cravat Coal Company has mined portions of the
Coshocton Landfill property. .
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During strip mining, overburden and coal were removed to track the
No.6 coal seam into the hillside. The stripping operation removed
material down to the base of the Middle Kittanning Coal seam that
occurs across the site at approximately elevation 870 to 860 feet
msl. Historical air photos show that the overburden or mine spoils
were deposited behind the active mining operation, in areas where
overburden and coal had already been removed. This was typical
practice for strip mining in the area.
Mining probably ceased at the Coshocton site when the over-burden
thickness rendered coal recovery uneconomical. When mining ceased,
an exposed steep rock face known as the "high w~ll" remained.
At the conclusion of mining operations, portions of the gap between
the spoil bank and high wall filled with water from groundwater or
surface water, creating what are known as "spoil ponds". At least
four spoil ponds existed along the abandoned high wall at the
Coshocton Landfill site as of 1965. One of these spoil ponds remains
and is located west of the site just outside the City of Coshocton
property 1 ine.
ENFORCEMENT HISTORY
On March 30, 1984, U.S. EPA issued a unilateral administrative order
to the City of Coshocton requiring it to undertake some interim
measures, primarily to protect surface water and to address the
leachate being generated. (V-W-84-C-006)
On November 29, 1984, U.S. EPA determined that the City's proposal,
with amendments specified by EPA, complied with the terms of the
order. By letter dated April 16, 1986, U.S. EPA agreed to, relieve
the City of its obligation to perform quarterly sampling.
COMMUNITY RELATIONS
The Remedial Investigation (RI) and Feasibility Study (FS) were put
out for public comment on February 8, 1988. The Administrative
Record, which included the Endangerment Assessment (EA), was added on
February 25, 1988. The comment period was extended twice and closed
on March 17, 1988. All of these materials, including the proposed
plan, were available for review at the Coshocton Public Library.
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A public meeting was held on February 23, 1988. A presentation on the
RI and FS was made and then a question and answer session, as well as
an opportunity for making public comments, was held. Public comments
were also submitted to U.S. EPA by mail. A Responsiveness Summary to
these comments was compiled and it is attached~
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IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedial alternative for the Coshocton City Landfill is
to cover the landfill with a cap. Unless the continued monitoring at
the site identifies additional problems which need to be addressed,
this will be the final remedy for the site. The cap which is placed
on the site in conformance with the State sanitary landfill closure
requirements, should prevent any migration of the hazardous substances
which have been identified as having been placed in the landfill.
V.
SITE CHARACTERISTICS
During active operation, the landfill accepted a variety of industrial
wastes, including hazardous substances from several local industries.
Based on data from city files and information submitted by local
industries as reported in the endangerment assessment, materials
listed below were accepted as drummed waste liquids:
o Alcohol 0 Xylene
0 Acetone 0 Perchloroethylene
o Epoxy resin 0 Mineral spirits
o Phenolic resin 0 Plasticizers
o Melamine resin 0 Neoprene
Other industrial solid waste dispOSed of at the site included
rotocyclone.scrubber dust, plastic. particles, paper coloring pigments
(brown iron oxide, calcium carbonate, chrome green, and tan iron
oxide), paraffin wax, sawdust, waste-activated sludge, scrap plastic,
scrap rubber, floor sweepings, and miscellaneous trash.
VI.
SUMMARY OF SITE RISKS
The Coshocton Landfill site is releasing contaminants to the
environment. The major release mechanism is leachate migrating to
surface water. However, the extent of the leachate's migration to
ground water is unclear. Results of samples taken from leachate,
ground water, surface water, and sediment identified approximately 30
chemical constituents. Based on this as well as other data relevant
to the site, indicator chemicals identified at the site include 2-
butanone (methyl ethyl ketone), carbon disulfide, l,l-dichloroethane,
polynuclear aromatic hydrocarbons (PAH), l,l,l-trichloroethane,
pentachlorophenol, heptachlor and heptachlor epoxide, phthalates,
toluene, vinyl chloride, xylene, copper, nickel, and zinc. The fate
and transport information, as it relates to groundwater. indicates
that for the inorganics. arsenic. copper. nickel, and zinc, sorption
will be the main process that will influence their migration. Nickel
. is expected to be the most mobile of this group. Of the organics,
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2-butanone, carbon disulfide, toluene, and xylene may move with the
bulk water flow, but are subject to biodegradation; phthalates, PAHs,
and heptachlor may sorb to particles and not move with the bulk water
flow; and vinyl chloride may move with the bulk flow. In surface
water, the inorganics are subject to sorption and complexation; sorp-
tion may decrease mobility while complexation may increase mobility.
The organics that will most likely volatilize form surface water are
2-butanone~ carbon disulfide, 1,1-dichloroethane, 1,1,1-trichloro-
ethane, toluene, vinyl chloride, and xylene. Phthalates, PAHs, and
heptachlor are expected to sorb to particles and deposit in the
sediments.
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The following risks were identified at th~ site:
A.
Ingestion of Contaminated Ground Water
Incremental carcinogenic risks from the ingestion of ground water
exceeded a risk of 1E-06 based on the maximum concentrations for
the following contaminants: Upper aquifer-arsenic (3E-04) and
bis(2ethylhexyl) phthalate (4E-06).
The levels of all contaminants, which have MCLs established and
were identified at the site, were below these MCLs. MCLs are
considered protective of human health and are the maximum amount
of these contaminants allowable in drinking water.
8.
Ingestion of or direct contact with contaminated Surface water
Incremental carcinogenic risks from the ingestion of surface
water exceeded a risk of 1E-06 for arsenic (3E-06) only.
Concentrations of some constituents in the surface water and
sediment were close to chronic concentration values of concern
for aquatic life, but these chronic concentration values were not
exceeded.
C.
Ingestion of or direct contact with contaminated leachate
Incremental carcinogenic risks from the ingestion of leachate
was below 1E-06 for all contaminants.
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D.
Ingestion of contaminated soil
Incremental carcinogenic risk from the ingestion of soil exceeded
a risk of 1E-06 only for arsenic (3E-06) when pica behavior was
assumed.
DISCUSSION OF CHANGES FROM PROPOSED PLAN.
CERCLA Section 117(b) requlres that the final selected remedial action
plan be accompanied by a discussion of any significant changes from
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VIII.
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the proposed plan and of the reasons for such changes. U.S. EPA has
received additional information since the publication of the proposed
plan, which it has reviewed and analyzed together with information
which was already in its possession.
Such new information and data received by the Agency in response to
the publication of the proposed plan include the following:
1. A letter dated March 16, 1988 was received from
Richard L. Shank, Director of the Ohio ~nvironmental Protection
Agency, commenting on the Feasibility Study. That letter clarified
the Ohio Solid Waste regulations as they pertain to the type of
material which may be used to construct a barrier over a solid waste
landfill, the depth of cover which must be applied over the barrier,
whether a sand drainage layer is necessary, whether a gas ventilation
system is required to be constructed, and whether a leachate collec-
tion system is appropriate at this time. Generally, the Director
recommended that a determination as to each of these issues be
deferred to the remedial design stage of the process.
2. A copy of a letter dated August 28, 1980 from
Richard Anderson, Project Engineer for General Electric, to
Deborah J. Berg of the Ohio EPA with accompanying analytic test
results, and a copy of a letter in response, dated December 16, 1980,
from Berg to Anderson, were obtained. Said correspondence indicates
that the waste generated by General Electric referred to as "Roto
Clone Sludgell was determined by Ohio EPA to be IInon hazardousll. Since
large volumes of this waste were disposed of in the Coshocton Land-
fill, such a determination has implications for whether regulations
and standards governing hazardous wastes or those governing solid
wastes are more lIappropria~ell in selecting a remedy for this site.
Given this new information, U.S. EPA reviewed and analyzed some of the
information already in its possession. Specifically, it revisited
the lIapplicable or relevant and appropriatell issue, as discussed
herein. In general, the state's clarification of its solid waste
regulations and the factoring of the roto-clone sludge information
into an analysis of the relative volumes of hazardous and solid
wastes, all support a modification of the proposed remedy.
DESCRIPTION OF ALTERNATIVES
Alternatives 1 (AA-1) thru 5 (AA-5) were described in the Proposed
Plan. As a result of the pUblic comments and a review of the
alternatives with regard to those comments, a new alternative which
will be referred to as the IIchosen alternative", was developed. The
chosen alternative is described between aTternative 3 and alternative
4, hereafter. -. .
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Alternative 1 (AA-l) is the no action alternative. This alternative
will not provide protection for the public health or the environment.
The substantial. threat. of release of contamfnants that may present an
imminent and substantial danger to public health and welfare and the
environment would remain because there is reasonable evidence that
there are substantial quantities of hazardous substances and pollut-
ants remaining in the waste mass. These substances could pose a threat
to pUblic health if released and public exposure should occur. Alter-
native 1 would not meet applicable State landfill closure and post-
closure care regulations.
Alternative 2 (AA-2) incorporates legal deed restrictions, fencing and
posting for the property. Groundwater, surface water and sediment
would be monitored on regular bases.
AA-2 addresses the risks associated with soil contact through deed
restrictions to prohibit excavation for future development and fencing
to restrict and reduce the probability of direct soil contact. AA-2
would not reduce infiltration and potential future transport of con-
taminants from the landfill contents. Groundwater monitoring would be
focused on metals, selected indicator p~rameters, and selected organic
priority pollutant and Hazardous Substances List (HSL) compounds. The
specific list of metals and" organic compounds to be monitored would be
det~rmined by U.S. EPA in cooperation with OEPA. Sediment and surface
water monitoring would also be aimed at triggering appropriate respon-
ses if releases increase in the future.
Fencing requires routine maintenance for prolonged useful life.
Monitoring would be effective in detecting water quality changes
and identifying the need for future protective response actions; as
appropriate.
AA-2 addresses current and future exposure risks. However, AA-2 is
similar to no actinn in that the substantial threat of release of
contaminants that may present an imminent and substantial danger to
public health and welfare and the environment would remain. There is
reasonable evidence that there are substantial quantities of uncon-
trolled hazardous substances and pollutants remaining in the waste
mass. These substances could pose a threat to public health if
released and public exposure occurs.
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AA-2 has no major 0 + t1 requirements for process or structural
performance. Fencing would require routine 0 + M.
AA-2 would not meet applicable State solid waste landfill closure
regulations.
Alternative 3 (AA-3) consists of soil filling and grading with topsoil
and revegetation at the site. AA-3 also includes the same deed
restrictions and site fencing included with AA-2. Groundwater,
surface water and sediment would be monitored regularly.
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Filling and grading the site would effectively reduce the possibili~y
of direct contact with the landfill waste mass. Soii cover and grad-
ing would reduce the infiltration percolation through the waste mass
and, therefore, reduce the transport of contaminants. Deed restric-
tions and fencing would support and strengthen the effectiveness of
the soil cover in limiting direct contact.
The site cover and grade require regular maintenance to remain
protective. The useful life of the site cover would depend on proper
O+M to maintain the finished grades against the effects of erosion and
settlement. With proper O+M, the protectiveness of the cover should
last indefinitely.
Routine monitoring of groundwater, surface water, and sediment would
be effective in identifying changes in contaminant concentrations and
causes for possible future protective response actions. Monitoring of
groundwater is important to periodically check the effectiveness of
the site cover installed.
Alternative 3 would not meet-applicable Sta~e solid waste landfill
closure regulations.
The Chosen A1ternati~e consists of a 2 foot low permeability soil cap
of the andfi 1, with a top 50i1 cover and revegetation. This
alternative also includes the deed restrictions, fencing, filling and
grading and the monitoring program incorporated into AA-3. During
Remedial Design (RD) the system would be evaluated for the need to
include gas collection and venting, leachate/groundwater collection
and disposal, and a drainage layer. Capping would effectively reduce
the possibility of direct contact with the landfill contents. The cap
would substantially reduce contamination transport caused by percola-
tion of infiltration through the waste mass. Deed restrictions and
fencing would support and strengthen the protectiveness of the cap-
ping in limiting direct contact.
The site cap would require regular maintenance to remain protective.
The useful life of the site cap would depend on proper O+M, the
protectiveness of the cap should last indefinitely.
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Routine monitoring of groundwater, surface water, ~nd sediment will be
effective in identifying changes in contamination concentrations and
causes for possible future protective response actions. Monitoring of
groundwater is important to periodically check the effectiveness of
the capping system installed.
The chosen alternative would meet all State solid waste landfill
closure regulations, as well as all other applicable or relevant and
appropriate requirements (ARARs).
Alternative 4 (AA-4) consists of a comprehensive capping of the land-
fill property. The capping system used as the basis for the cost
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estimate of AA-4 was a clay, soil and sand .system, which would include
gas collection and venting and leachate/groundwater collection and
disposal. AA-4 also includes deed restrictions, fencing, filling and
grading, and the monitoring program incorporated into AA-3.
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Capping would effectively reduce the possibility of direct contact
with the landfill contents. The cap would substantially reduce
contaminant "transport caused by percolation of infiltration through
the waste mass. Deed restrictions and fencing would support and
strengthen the protectiveness of capping in limiting direct contact.
The site cap would require regular maintenance to remain protective.
The useful life of the site cap would depend on proper O+M, the
protectiveness of the cap should last indefinitely.
Routine monitoring of groundwater, surface water, and sediment is
effective in identifying changes in contaminant concentrations and
causes for possible future protective response actions. Monitoring
of groundwater is important to periodically check the effectiveness
of the capping system installed. "
AA-4 also incorporates a landfill gas venting/collection system to
prevent gas" accumulation under the cap and a leachate collection
system at the toe of the slope to prevent fluid pressure from building
up under the cap and to control releases of potentially contaminated
leachate/groundwater. Both the gas and leachate collection systems
would be periodically monitored to determine the need for possible
future protective response actions such as treatment additions or
modifications.
Alternative 4 would meet all ARARs.
Alternative 5 (AA-S) consists of capping with a multil~yer cap system
incorporating a synthetic membrane as typically used for RCRA closure
at an existing facility. The capping system used as the basis for the
cost estimate of AA-S was soil, synthetic membrane, and clay. AA-S
also includes deed restrictions, fencing, filling and grading and the
monitoring program incorpOrated into AA-3 and AA-4.
Capping would effectively reduce the possibility of direct contact
with the landfill contents. The membrane cap system would sub-
stantially reduce contaminant transport caused by percolation of
infiltration through the waste mass. Deed restrictions would support
and strengthen the protectiveness of capping in limiting direct
contact.
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The site cap will require regular maintenance to remain protective.
The useful life of the site cap would depend on proper O+M. With
proper O+M, the protectiveness of the cap should last indefinitely.
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Routine monitoring of groundwater, surface water, and sediment
would be very effective in identifying changes in contaminant
concentrations and causes for possible future protective response
actions. Monitoring of groundwater is important to periodically
check the effectiveness of the capping system installed.
AA-S also incorporates the same gas vent and leachate collection
systems as AA-4. Both the gas vent and leachate collection systems
would be periodically monitored to determine the need for possible
future protective response actions such as treatment.
AA-S would meet,all ARAR's.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
Overall protection of human health and the environment.
Alternative 1 would not be effective in protecting either human
health or the environment.
Alternative 2 would provide some protection from direct contact
through fencing and disturbance of the subsurface through deed
restriction.
Alternative 3 would provide protection from direct contact and
would help prevent groundwater and surface water contamination.
The chosen alternative, alternative 4 and alternative 5 would
provide increasing protection from direct contact, groundwater
and surface water contamination.
B.
Compliance with ARARs.
SARA requires that remedial actions meet legally applicable or
relevant and appropriate requirements of other environmental
laws~ These laws may include: the Toxic Substances Control Act,
the Safe Drinking Water Act, the Clean Air Act, the Clean Water
Act, the Solid Waste Disposal Act (RCRA), and any state law which
has stricter requirements that the corresponding federal law.
Applicable requirements are cleanup standards, standards of
control, and other substantive environmental protection requi-
rements, criteria or limitations promulgated under Federal or
State law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location or other
circumstance at a site. A requirement is "applicable" if
the remedial action or circumstances at the site satisfy all
of the jurisdictional prerequisites of the requirement.
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Relevant and appropriate requirements are cleanup standards,
standards of control, and other environmental protection
requirements, criteria or limitations promulgated under Federal
or State law that, while not legally "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location or
other circumstance at a site, address problems or situations
sufficiently similar to those encountered at the site that their
use is well suited to that site~
"A requirement that is judged to be relevant and appropriate must.
be complied with to the same degree as if it were applicable.
However, there is more discretion in this determination: it is
possible for only part of a requirement to be considered relevant
and appropriate, the rest being dismissed if judged not to be
relevant and appropriate in a given case" . (Interim Guidance on
Compliance with Applicable or Relevant and Appropriate Require-
ments, 52 FR 32496, August 27, 1987).
1.
Landfill Closure Requirements
The regulations promulgated pursuant to the Resource Conservation
and Recovery Act (RCRA), 42 U.S.C. Sections 6901, et. seq., are
not "applicable" to this site. The RCRA regulations which govern
Hazardous Waste Treatment, Storage and Disposal facilities (4Q
CFR Parts 264 and 265) did not become effective until November
19, 1980. The Coshocton Landfill ceased accepting wastes prior
.to that date.
Those RCRA regulations addressing solid waste disposal activities
(40 CFR Parts 241 and 256, primarily) do not have direct applica-
tion to individual facilities but rather provide for an enforce-
ment program to be administered by the states pursuant to a Solid
Waste Management Plan.
Though RCRA regulations are not jurisdictionally applicable to
the remediation of the site, they are certainly "relevant" to
the actions occurring thereon. Both subtitle Cof RCRA, which
applies to hazardous waste activities and facilities, and
subtitle D of RCRA, which applies to Solid Waste Facilities, have
a logical bearing upon a landfill which contains both hazardous
and solid waste materials.
\! -
Though both Subtitle C and Subtitle D are relevant to the remedy
for the CoshoctonLandfil1, the Subtitle D provisions relating
to ca pping/coveri ng the 1 andfi 11 are deemed more appropri ate.
(None of the alternatives under consideration involve excavation,
physical redistribution or treatment of the waste so as to make
those subtitle C regulations which are applicable to "management"
of waste). The appropriateness determination is dependent
on whether substantive requirements are meant to address
.
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sufficiently similar circumstances as those present at the
specific site to make them particularly well suited to that
site. It is, of necessity, a case by case determination
relying on the opinions and judgment of experts, as well as
on objective information and evidence.
The following factors were considered in reaching a conclusion
that the Subtitle C capping/cover requirements are not
appropriate for this site:
1. Estimated proportion of repor.ted hazardous substances
to total landfill waste.
2. General toxicity and mobility of the reported hazardous
substances constituents.
3.
Results of the endangerment assessment.
!stimated Hazardous Substances Proportion. The proportion or
fraction of reported hazardous substances to total landfill
wastes was estimated. The estimate was based on calculated
landfill volume, reported wastes disposed by six major local
industries (assumed to be hazardous based on the descriptions
given in the CERCLA Section 104(e) responses) and estimated
densities for the landfill materials and hazardous substances.
The ,estimated proportion ranged from 0.7 ~o 1.3 percent with an
estimated maximum fraction of 2.4 percent by weight. 'This range
and maximum were calculated by adjusting assumptions on the
variables in the estimates.
General Toxicity and Mobility. The industrial wastes considered
hazardous were mostly described as spent chlorinated solvents,
waste dirty oil, paint sludges including cleaning solvents and
caustic sludges. Many of these wastes would now be listed IIF
wastes" or meet the RCRA definition of ignitib1e, i.e., charac-
teristic hazardous wastes.
. "
The spent chlorinated solvents included trichloroethylene (TCE)
and methylene chloride. Both solvents are relatively mobile in
groundwater. TCE has a MCL of 5 ppb (ug/L) and a MCLG of 0 ppb
(ug/L) based on suspected carcinogenicity.
The other flammable solvents (including mineral spirits, xylene,
toluene and methyl ethyl ketone) are considered mobile and are
not suspected carcinogens and have relatively low toxicity
compared with some of the chlorinated solvents.
~
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Paint sludges and caustic cleaning sludges are relatively
immobile. Some leaching of heavy metals could be expected but
this would tend to occur relatively slowly as the paint sludges
deteriorate.
Results of the Endan erment Assessment. The endangerment
assessmentd1d not find a pattern 0 release from the landfill
that was causing current unacceptable risks to human health or
the environment.
In summary, Subtitle C landfill closure requirements are not
deemed appropriate for the following \easons:
a. The majority of total wastes deposited was general
municipal garbage, industrial refuse and inert yard-type trash
(tree stumps and demolition debris). The estimated fraction of
drummed hazardous substances was less than 2.5 percent by weight.
b. Some of the specific hazardous substances are suspected
carcinogens, however, most of the reported hazardous substances
were relatively low toxicity flammable materials.
c. The site does not show a pattern of hazardous substance
release causing a demonstrated risk to human health or the
environment based on the endangerment assessment.
However, Subtitle D provisions are deemed appropriate to that
portion of the chosen remedy requiring that the site be covered
to protect against direct contact with the waste and to minimize
the production of leachate and discharges to ground and surface
water. Said provisions are embodied as IIGuidelinesli at 40 CFR
Part 241. In order to meet the requirement of section 241.209-1
that cover material be applied lito minimize fire hazards.infil-
tration of precipitation...II, section 241.209-3 recommends that
lithe thickness of the compacted final cover should not be less
than 2 feetll. .
It should be noted that the subtitle D guidelines were enacted
in 1974 and that amendments reflecting experience gained in the
intervening years are anticipated in the near future. Moreover.
the existing guidelines assume the landfill wastes to be that.
generated by residential and commercial sources. They advise
that IIIf techniques other than the recommended procedures are
used, or wastes other .than municipal solid wastes are disposed,
it is the obligation of the proposed facility's owner and
operator to demonstrate to the responsible agency in advance by
means of engineering calculations and data that the techniques
employed will satisfy the requirementsll. 40 CFR 241.100(b)
II -
As a part of the public comment process. a group of PRPs has
proposed an alternate remedy for the site. To the extent such
.
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alternate remedy may be considered, Subtitle 0 indicates that
engineering calculations and data should be provided which
demonstrate that such alternative will as effectively minimize
infilt~ation of precipitation as the recommended procedures.
There are no "applicable" state hazardous waste regulations since
no hazardous materials were disposed of in the landfill
subsequent to the promulgation of the Ohio Hazardous Waste
Management regulations in 1981. For the reasons enunciated
previously in the discussion of the a~ropriateness of Subtitle C
and Subtitle 0 of RCRA, the state's hazardous waste regulations
are not addressed to circumstances sufficiently similar to these
site conditions to make them ~appropriate".
However, the State of Ohio does have Solid Waste Disposal
Regulations (Ohio Administrative Code, Chapter 3745) which are
applicable to this site, and which were identified in a timely
manner. (See correspondence from Ohio EPA to U.S. EPA dated
August 18, 1987, November 5, 1987, and March 16, 1988). The
regulations were adopted on July 29, 1976 and were in effect
during times when the Coshocton Landfill was in operation.
Moreover, correspondence obtained from state records indicates
that said landfill has never been properly closed pursuant to
the Ohio regulations, specifically section 3745-27-10.
The chosen alternative is intended to be consistent with the
State Solid Waste regulations. The PRP group has proposed an
alternate remedy, as a part of the pUblic comment process, which
on its face does not appear to satisfy the State regulations.
However, the State regulations contemplate a waiver of specific
regulatory provisions if an applicant demonstrates that under
specific terms and conditions the facility will not harm the
public health or the environment, OAC ~ 3745-27-11. If during
the remedial design stage or during consent decree negotiations
the PRP group demonstrates that an alternate closure design would
satisfy the requirements of such a waiver under state solid waste
regulations, U.S. EPA may consider modifying the chosen remedy,
if it determines that such an alternate plan is equally
protective.
2.
Other Requirements
If a leachate collection system and/or a gas venting system is
determined to be necessary during the design process, applicable
and relevant and appropriate standards will be complied with for
all systems. These may include the following: .
.
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-14-
Law, Regul at.ion
or Standard
Source of Regulation
Safe Drinking Water
Act, 40 CFR 141
through 143
Safe Drinking Water Act
Maximum Contaminant Limits
(MCl's)
Intergovernme
Nat iona 1 Po 11 utant
Elimination System
Pe rm i t
Discharge
(NPOES)
CWA Section 402,
40 CFR 122, 123,
125 Subchapter N
40 CFR 403 Subchapter
N, FWPCA
Pretreatment Regulations
for Existing and New
Sources of Poll~tion
Occupational Safety and
Health Act (OSHA)
29 CFR 1910
STATE
Ohio NPDES Permit
.OAC 3745-31-05 (A) (3)
Ohio NPDES Regulations
Ohio Administrative
COde: 3745-33-01
through 3745-33-10.
Authority granted by
Ohio Water Pollution
Control Act, ORC 6111.03.
Ohio Water Quality
Standards
Ohio Administrative
Code: 3745-l.
Authority granted by
Ohio Water Pollution
Control Act, ORC 6111.041.
Ohio Pretreatment
Regulations
Ohio Administrative
Code: 3745-3.
Authority granted by
Ohio Water Pollution
Control Act, ORC 6111.03.
J -
Ohio Water Pollution
Control Act
Ohio Revised Code:
6111.01 to 6111.08.
.
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-15-
Law, Regulation,
or Standard
Source of Regulation
Ohio Administrative
Code: 3745-15-04.
Ohio General and
Miscellaneous Air
Pollution Regulations
Ohio Administrative
Code: 3745-15-07.
Ohio administrative
Code: 3745-15-08.
Ohio Air Pollution
Control Laws
Ohio Revised Code:
3704.03.
Ohio regulation on Air
Permits to Operate
and Variances
Ohio Administrative
Code: 3745-35
C.
Long-term effectiveness. and. permanence
Alternative 1 would not be effective in addressing contamination
from the site.
Alternative, 2 would provide only limited long term effectiveness
and would require long-term care of the fence.
Alternative' 3, the chosen alternative, and alternatives 4 and 5
would provide increasing effectiveness as the quality of the cap
is improved.
All would require long-term maintenance in order to retain their
effectiveness.
D.
Reduction of toxicity, mobility or volume
None of the alternatives will reduce the toxicity or volume of
the wastes at the site because all landfill waste will remain in
place.
Alternative 1 and 2 will have no effect on the mobility of the
wastes.
Alternative 3, the chosen alternative, and alternatives 4 and 5
are all designed to reduce the mobility of the wastes. As the
, quality of the cap is improved in moving from the alternative 3
to alternative 5 the 'reduction in mobility becomes more
effective.
.
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G.
-16-
Water Balance calculations by assembled alternative
Alternative Runoff (in/yr) Percolation (in/yr)
No action AA-1 and AA-2 6.1 21.3
Surface Controls AA-3 10.1 4.3
Chosen Alternative 10.1 2.2
Soil-Clay Cap AA-4 10.1 2.2
Soil-Membrane-Clay Cap AA-S 10.1 0.3
E.
Short-term effectiveness
Alternative 1 would not be effective in addressing contamination
from the site.
Alternative 2 would help restrict access to the site once the
fence is completed.. It would also monitor conditions at the
site.
Alternative 3, the chosen alternative, and alternatives 4 and 5
would cause short term impacts due to construction of the cap.
These would include. noise from heavy equipment, dust and
increased chances for direct contact with wastes by construction
per~onnel.
F.
Implementability
All of the alternatives are readily implementable. The chosen
alternative, and alternatives 3, 4 and 5 utilize proven'
techniques for capping the landfill. The leachate collection
and gas venting techniques used for alternatives 4 and 5 and
potentially the chosen alternative are also commonly used and
proven techniques.
'" .
Cost
COST ESTIMATE SUMMARY
AA-l No action (Cost estimates not
applicable)
AA-2 Site Restrictions
AA-3 Site Grading
.
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-17-
Chosen Alternative Soil and Clay Capping
AA-4 Soil and Clay Capping
AA-5 Soil, Synthetic Membrane,
and Clay Capping
Description
AA-2 AA-3
Chosen
Alternative
AA-4
AA-5
Sitework $0 $3,800,000 $2,850,000 $6,190,000 56,190,000
Clay Barrier $0 $0 $2,060,000 52,060,000 $2,060,000
Geomembrane $0 $0 $0 $0 $1,250,000
Leachate/Groundwater $0 $0 $0 $475,000* $475,000
Collection Storage and
Treatment
Gas Collection $0 $0 $0 $374,000* $374,000
Health and Safety $0 $23,000 $46,000 $46 ~ 000' $57,000
Deed Restriction/ $176,000 $176,000 $176,000 $176,000 $176,000
Fencing
Design, Contingencies and
Other Costs $251,000 $3,080,000 $2,880,000 $6,950,000 $7,800,000
Total Capital $427,000 $7,080,000 $8,010,000 $16,300,000 $18,400,000
Cost Estimate
Annual 0 + M Cost $69,500 $82,000 $96,,000 $129,000 $129,000
Estimates
° + M Present $655,000 $773,000 $910,000 51,220,000 51,220,000
Worth (10% interest,
30-yr)
Tota 1 Present
Worth
51,080,000 $7,850,000' $8,920,000
$17,500,000 519,600,000
* These items are potentially included with the cost estimate for the chosen
alternative if determined to be necessary by OEPA during the design.
.
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-18.-
H.
Support Agency Acceptance
The Ohio EPA has indicated that it fully supports the chosen remedial
alternative. A letter from the director of the Agency indicating this
support is attached.
I.
Community Acceptance
The community appears to be divided on the benefits to be derived from
a protective remedy. Because the City of Coshocton is one of the PRPs,
many of the taxpayers in the City oppose the expenditure of the funds
required for alternative 4. The citizens of Coshocton do not feel
that the threat identified in the Endangement Assessment supports the
expenditure of substantial amounts of city tax money. The people who
live near the landfill, however, are strongly in favor of a protective
remedy, whatever the cost.
x.
SELECTED REMEDY
The selected remedy has the following major components;
Complete site fencing and posting
Recordation of Notice in the chain of title designating the
site as a restricted use property, used to manage hazardous
waste
Site grading to promote precipitation runoff and reduce
infiltration
Site capping which meets State solid waste landfill
requirements and which minimizes leachate generation and
prevents direct contact with contaminated materials
Top cover of topsoil and revegatation
Monitoring of groundwater, surface water and landfill
gas to determine effectiveness of above measures and to
provide early alert as to the need for other actions
The following components will. be evaluated during the Remedial Design
(RD) and wil.l be included if required:
Landfill gas collection and v~nting system
.
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-19-
Leachate and groundwater collection and on-site system with
faci1ities for truck loading
Provisions for on-site or off-site treatment and disposal of
collected leachate and groundwater at a local POTW or on site
treatment
XI.
STATUTORY DETERMINATIONS
A.
Protection of Human Health and the Environment
The remedy selected is based on potential future endangerment to
public health, welfare and the environment. Site file records
provide reasonable evidence that substantial quantities of
hazardous substances and pollutants exist in the landfill waste -
mass. The substantial threat of release of these materials may
present an imminent and substantial danger to public health,
welfare and the environment if these substances were released
and public exposure occurred.
The chosen alternative is p'rotective of human health and the
environment. The fencing, deed restrictions and capping all
provide protection from direct contact with contaminated
materials. Capping of the landfill also reduces the percolation
through the landfill and thus the migration of hazardous sub-
stances into groundwater and surface water. Monitoring of the
groundwater and surface water will identify any failures of the
containment system installed at the landfill. Once alerted to an
elevated level of contaminants, additional corrective actions can
be taken to abate any threat.
B.
Attainment of Applicable or Relevant and Appropriate Requirements
The U.S. EPA's selection of site capping and relat~d facilities
for the Coshocton Landfill is intended to comply with applicable
state solid waste landfill regulations.
The selected remedial alternative would also comply with specific
public health and environmental requirements. These ARARs are.
called "chemical-specific" requirements. Public health and
environmental ARARs expressed as chemical-specific limits or
requirements would be addressed as follows:
o
Routine monitoring of groundwater at the site to
check for migration of releases into ground~ater,
surface water and gas.
..
.
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-20-
If a need is indicated during design for these actions, the
following actions may also be taken:
o
Leachate/groundwater treatment at a local POTW;
o
Routine monitoring of collected leachate/ground-
water to detenmine loading to the POTW.
C.
. .
Cost-effectiveness
The selected remedy is prescribed by compliance with solid waste
landfill closure ARARs. The range of alternative actions to meet
closure requirements is very limited. Therefore, the chosen alter-
native is essentially cost-effective because it is the least expensive
alternative which satisfies said regulations. Cost-effectiveness of
the chosen alternative is established relative to alternatives AA-4 and
AA-S which would cost more without increasing the df!gree of compliance
with ARARs.
The actual cost of implementing the remedial action is expected to be
different than the order-of-magnitude cost estimate prepared in the
feasibility study (FS). During design, some construction details may
be developed to produce a closure system that will be lower in cost
than the order-of-magnitude FS estimate. Conversely, factors may cause
the cost to be higher than the estimate. The final implementation cost
is expected to fall within the range of accuracy expected for the
order-of-magnitude estimate developed.
D.
Utilization of Permanent Solutions and .Alternative Treatment
Technologies to the Maximum Extent Practicable
SARA mandates a preference for the selection of permanent remedies
that completely or probably produce a 1I....permanent and significant
decrease in the toxicity, mobility or volume of the hazardous sub-
stance, pollutant or contaminant."
SARA also specifies that the selected remedial action must use "...
pe~anent solutions and alternative treatment technologies or re-
source recovery technologies to the maximum extent practicable". If
the selected remedial action is not appropriate for the pe~anence and
treatment preferences cited above, an explanation of why a remedial
action not incorporating these features was selected is required.
A permanent remedy involving treatment or recovery technologies was not
selected for the Coshocton Landfill. Permanent remedies using thermal
oxidation treatment technologies were evaluated and were judged .to be
not practicable for the Coshocton Landfill site. Application of
.
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. "
-21-
treatment at the Coshocton Landfill would be impracticable for the
following reasons:
o
Hazardous substances were apparently placed
haphazardly within the landfill waste mass during
operation. Segregation of hazardous from non-
hazardous waste would be impractical. Therefore
treatment would be required for the entire waste
mass. This was considered: 1) not technically
practicable, 2) not prudent because of the
potentially greater risk to human hea1th and
environment caused by ex~avation.
The estimated cost of thermal treatment would be
extremely high and require many years to complete.
o
o
Full ARAR compliance would be achieved by landfill
closure which would be prot~ctive of human health
and cost effective.
.
-------
-"
StT "If 0tU0 EnW'arunenta£ Prot.ectton Agency
a ,I
T(f8IGrd "
cJltllfllf'
Irr1fIlflltll :
f)r9 ,..-..." ../
-'~~~"1d' I
.. ~. ,....,I
--~. '
P.L. ~.JX 1049. 1800 WaterMark Dr.
Columbus. Ohio 43266-0149
Richaro F. Celeste
Governor
June 8, 1988
Re:
Coshocton Landfill
Coshocton County
Superfund S1te
Mr. .Ya1das Y. Adamkus
Reg10nal Actffiio1strator
U.S. EPA, Region Y
230 South Dearborn Street
Ch1cago 111in01s 60604
Dear Mr. Adamkus:
After rev1ew of the draft Record of Dec1sion (ROD) for the Coshocton Landfill
sHe in Coshocton County, Ohio EPA concurs w1th' the selected rerncd~Jl
alternative proposed for the sHe. The selected remedial alternative, .tHled
the Chosen Alternat1ves 1n the ROO, 1s d1fferent from the preferred remed1al
alternative outlined in the Publ1c Comment Feasib11ity Study Report dated
February 3, 1988. The selected remedial a1ternat1ve in~ludes:
- Complete slte fenclng and posting;
- The recordation of notice in the chain of title regarding uses to which
the property has been put, and any restrictions on 1ts future uses;
- SHe grad1ng;
- Site capp1ng which meets State so11d waste 1andf111 requirement;
.'
-------
,
Mr. Valdas V. Adamkus
Page 2
The est1mated present worth of the selected remed'al alternat've 's $8.92
m1111on. Est'mated cost of operat'on and ma'ntenance of the constructed
remedy 1s $96.000 per ~ear.
S1ncerely,
[)~~. \-J ,11
\J\\L,t\a.~cX. 7---. ~l~K
R'chard L. Shank, Ph.D.-
D'rector
RLS/RH/lz
cc:
Maury Walsh. Deputy D'rector
Dave Strayer, CAS
Roger Hannahs,- CAS
Scott Bergreen, SEDO
\> .
,
.
-------
Final
Responsiveness Summary
Coshocton Landfill Site
Coshocton, Ohio.
WA 82-SLC5.0
May 31, 1988
EPA Contract No. 68-01-7251
GLT147/53
.
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CONTENTS
Chapter
1
2
3
Appendix A.
Appendix B.
GLT147/54
Introduction
Purpose of the Responsiveness Summary
Background
Feas.ibili ty Study Overview
Site Background
Endangerment Assessment Summary
Preferred Remedial Action Summary
Public Comments--U.S. EPA Res~onses
Comments on RI/FS Reports
Past Landfill Practice and Conditions
Public Health Risks
Remedial Action Costs and Economic
Effects
Proposed Alternative Actions
Legal Issues Regarding ARARs and
Other Provisions of CERCLA/SARA
List of Individuals Who Commented on the
Coshocton Landfill Feasibility Study
Public Comments
~
.
Page
1-1
1-1
1-1
2-1
2-1
2-2
2-4
3-1
3-2
3-8
3-9
3-9
3-9
3-10
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5:hapter 1
INTRODUCTION
The U.S. EPA has investigated the Coshocton Landfill site
for the nature and extent of actual or threatened release of
hazardous substances. Based on these investigations, the
U.S. EPA has prepared an endangerment assessment and feasi-
bility study to evaluate remedial actions and describe the
preferred set of remedial actions for implementation. The
preferred remedial actions were presented for public review
and comment at a public meeting in Coshocton on February 23~
1988.
PURPOSE OF THE RESPONSIVENESS SUMMARY
Before the U.S. EPA makes the final decision to select and
implement remedial actions, it must consider public co~~ents
and criticism. Public participation is required in Super-
fund projects according to the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA) as
amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA)..
This document summarizes the verbal and written public com-
ments received on the feasibility study and preferred reme-
dial actions. It describes the U.S. EPA's responses with
explanation of how the comments were incorporated in the
U.S. EPA's decisionmaking process.
BACKGROUND
The Feasibility Study (FS) for the Coshocton Landfill site
was issued on February 3, 1988. The FS was based on site
investigations conducted between 1983 and 1987. These
investigations were conducted and reported in two phases:
Phase I was done from 1983 to 1985 and reported in the Final
Remedial Investigation Report on May 24, 1985; Phase II was
done from 1985 to 1987 and reported in the Final Remedial
Investigation Report Phase II on October 9, 1987.
The Endangerment Assessment (EA) for the site was prepared
based on the Remedial Investigation reports. The EA was pre-
pared by PRC Engineering and issued on January 4, 1988.
A public meeting on the FS was held on February 23, 1988 in
the City of Coshocton. Written public comments were received
by U.S. EPA through March 17, 1988.
GLT147/55
1-1
.
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Chapter 2
FEASIBILITY STUDY OVERVIEW
The Feasibility Study summary below covers only the major
features and issues addressed in the document which was
issued on February 3, 1988. For a complete discussion of
the issues and evaluations regarding remedial actions con-
sidered, the full report should be reviewed with the Endan-
germent Assessment (dated January 4, 1988) and the two Reme-
dial Investigation reports (Phase I dated May 24, 1985, and
Phase II dated October 9, 1987).
SITE BACKGROUND
The Coshocton Landfill is located on approximately 80 acres
immediately south of State Highway 83 southeast of the City
of Coshocton, Ohio. The site is a former coal strip mine.
Between 1968 and 1979, the City conducted landfill opera-
tions at the site.
The wastes received at the Coshocton Landfill consisted of
mixed municipal refuse and industrial wastes including solid
scrap, drummed liquids, and free liquids. Through CERCLA 104
responses submitted in 1984, eight industries reported to
U.S. EPA the waste quantities and types they disposed of at
the landfill. In addition to relatively inert solid scrap
wastes and nonhazardous materials, the liquid waste types
included hazardous substances such as spent chlorinated sol-
vents, nonchlorinated flammable solvents, resins, and
plasticizers.
The physical site is characterized by considerable topographic
relief. Much of the landfilled waste is situated in the void
created by abandoned strip mine operations: i.e., between the
mine face or "high wall" and the spoils pile set apart from
the high wall. In addition to the mine filling, some waste
was also reportedly placed in shallow excavations in the
southern portions of the site.
o Q
Site geology generally consists of a series. of related strata
(Pennsylvanian Alleghany series) with the uppermost member
being sandstone followed by coal (Middle Kittanning Coal or
No.6), clay, shale, coal, and clay. The nominal bottom of
the Coshocton Landfill waste mass in the mine fill areas is
at the bottom of the No.6 coal. .
Landfill operations were not well recorded. Although speci-
fic locations of waste materials are not clearly defined,
three relatively distinct disposal areas have been described
through conversation with local people, historical. air pho-
tography, and geophysical data. These three areas are
2-1
.
-------
termed the northern fill area, the "bad weather" fill area,
and the southern fill area.
Currently, portions of the landfill site are covered with what
appears to be mine spoil materials. The cover of the site
is inconsistent: some areas have very little or no cover and
standing water is common. Scattered surface deposits of
drwns and other metal objects are present. Nwnerous leachate
seeps exist on the western and southern portions of the site.
The Coshocton Landfill site was ranked by the U.S. EPA on the
National Priorities List (NPL) for further investigation and
study under CERCLA. Investigation work by CH2M HILL and War-
zyn Engineering at the site began in 1983 with preparation
of a remedial action master plan.
Remedial investigation of the site began in late 1983 and
continued through 1986 in two phases. The investigations
developed information on site mapping, waste locations,
hydrogeology, and chemical releases through groundwater,
runoff, and leachate. These results are reported in detail
in two separate remedial investigation reports.
ENDANGERMENT ASSESSMENT SUMMARY
An endangerment assessment was prepared for the Coshocton
Landfill by PRC Engineering under a separate contract with
U.S. EPA. This endangerment assessment was based on the
site data developed during the remedial investigation.
A summary of conclusions from the endangerment assessment is
presented below: .
o
Based.on the data from the remedial investigation,
the Coshocton Landfill site is releasing contami-
nants to the environment.
o
Information reviewed by PRC identified a number of
chemicals that were disposed of in the landfill
during its operations. Results of analyses of
site samples taken from leachate, groundwater,
surface water, and sediment identified approxi-
mately 30 chemical constituents. However, PRC
concluded that several contaminants reportedly
disposed of in the landfill have not been identi-
fied in site samples.
o
A number of contaminants disposed of in the land-
fill have not been identified in samples of the
various media. The RI reports (CH2M HILL, 1985
and 1987) suggested four general hypothetical
explanations. First, a fire that occurred in 1977
may have either oxidized the organics or caused.
2-2
.
-------
them to volatilize to the atmosphere. Second, the
landfill may not have reached hydraulic saturation,
but releases may begin in larger quantity after
saturation is achieved. Third, releases may have
occurred and are occurring but the contaminants
have not yet reached th'e sampl'ing points. Fourth,
much of the hazardous liquid substances were
placed in the landfill as drummed wastes and a
majority of the drums have not yet started to
lealc.
PRC developed several exposure scenarios, identi-
fied populations potentially at risk, estimated
the extent of exposures, and characterized risks
from these exposures. The following exposure sce-
narios were developed: .
Human Population Exposures
o
Ingestion of contaminated groundwater
Ingestion of or direct contact with surface
water
Direct contact with leachate
Ingestion of soil
Aauatic and Animal Populations Exposures
Direct contact with surface water
Direct contact with sediments
Direct contact with leachate
Potentially siqnificant noncarcinogenic and car-
cinogenic risks were identified based on four
exposure scenarios:
o
Ingestion
Ingestion
Ingestion
Ingestion
of groundwater
of surface water
of leachate
of soil
The risk estimates for each scenario were based on
maximum concentrations observed in the RI and are
very conservative, that is, very cautious estimates.
Concentrations of some constituents in the surface
water and sediment were close to chronic concentra-
tion values of concern for aquatic life, but these
chronic concentration values were not exceeded.
o
2-3
.
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o
Uncertainty exists regarding whether RI data rep-
resent the leading edge of a contaminant release
episode or whether the observed releases represent
a steady-state condition. If future releases
increase, .then.potential risks to human health and
environment will increase with time.
o
It is not possible to predict whether contamina-
tion will migrate offsite or what receptor doses
could be. . The potential exists that releases will
occur. Because of the uncertainty of the releases
from the site, any future risk cannot be quantita-
tively or qualitatively evaluated except to note
that the potential for risk exists.
PREFERRED REMEDIAL ACTION SUMMARY
At the conclusion of the feasibility study in January 1988,
the U.S. EPA selected AA-4 as the preferred set of remedial
actions for implementation at the Coshocton Landfill site.
In summary, the overall selected remedial action would con-
sist of the following features:
o
o
o
o
o
Complete site fencing and posting
Attachment of a note to the deed or title designat-
ing the site as a restricted use property, used to
manage hazardous substances
o
o
Site grading
Site capping with a compacted clay and soil system
to form a cap with lower permeability than the'
natural landfill base material
o
- Landfill gas collection and passive venting system
Leachate and groundwater collection and onsite tank
storage system with facilities for truck loading
Provisions for offsite treatment of collected
leachate and groundwater at a local POTW (the
Coshocton POTW was used in this study for eval-
uation and cost estimation)
.-. ,J
Site monitoring including groundwater monitoring,
collected leachate/groundwater monitoring, and
landfill gas monitoring
This set of preferred remedial actions was termed Assembled
Alternative No.4 (AA-4) in the Feasibility Study. It was
the proposed remedial alternative presented at the Febru-
ary 23, 1988 public meeting for comments.
GLT147/56
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Chapter 3
PUBLIC COMMENTS--U.S. EPA RESPONSES
Public comments on the Feasibility Study report for the
Coshocton Landfill were received by the U.S. EPA at a public
meeting on February 23, 1988 and through written documents
. received by U.S. EPA at the Region V Chicago office until
March 17, 1988. The list of all individuals who submitted
public comments is given in Appendix A. The comments them-
selves are attached as Appendix B. .
Several comments were directed at detailed legal interpreta-
tions of CERCLA/SARA and NCP requirements, particularly inter-
pretation of the "applicable or relevan~ and appropriate.
requirements" or ARARs. This Responsiveness Summary addresses
these legal comments in the last portion of this. chapter.
Responses to comments on law were prepared by U.S. EPA
Regional Counsel.
Public comments on the Coshocton Landfill FS fell into the
following major categories:
o
Remedial Investigation (RI) reports and Feasibility
Study (FS) report comments by the City
o
Past waste disposal practices and landfill
conditions'
o
Public health risks, both present and future
Remedial action costs and- local economic conditions
o
o
Proposed alternative remedial actions
o
Legal issues regarding ARARs and other provisions
of CERCLA/SARA
Comments and U.S. EPA responses are organized below according
to these categories. .
COMMENTS ON RI AND FS REPORTS
. Q
The comments on the RI reports are contained in a document
submitted by the potentially responsible parties (PRPs),
"Comments Report for the Coshocton Landfill Superfund Site
Coshocton, Ohio" dated March 16, 1988 and prepared by Dames
and Moore (D&M Job No. 14211-002-17). Comments from this
report are summarized and addressed below.
Comment. With regard to the results of the Phase I RI, the
relatively predictable geologic conditions at the site, the
lack of significant contamination identified during the
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remedial investigation, and Dames and Moore's, routine site
monitoring suggested that the site presented no threat to
human health and the environment (Comments Report at 2).
U~S. EPA Response. U.S. EPA believed that the Phase I RI
results were not conclusive. Phase I findings were not con-
sistent with releases that could be reasonably expected given
the reported past practices of bulk liquids disposal and
drummed waste solvent disposal at the landfill. Phase II RI
work was deemed warranted to increase confidence in the
results. The U.S. EPA Endangerment As~essment conclusions
agree with the general finding that releases observed from
the site during the RI do not present a clear risk to human
health and the environment. .
Comment. Given the negligible present risk and speculative
future risk, the remedy would not seem to meet any kind of
test for cost-effectiveness (Comments Report at 3).
u.S. EPA Response. The EA concludes that future releases
from the site are uncertain and future risks cannot be quan-
titatively or qualitatively evaluated except to note that
the potential for risk exists. In the face of this uncer-
tainty, the U.S. EPA selected a conservative position on.
stating the nature of the potential future risk caused by
release of hazardous substances. The selection of the pre-
ferred remedial alternative was based on the application of
landfill closure ARARs, particularly Ohio sanitary landfill
closure requirements which were considered applicable. Pro-
per landfill closure to restrict public access, minimize
public contact and reduce infiltration while maintaining
surface water and groundwa~er was deemed cost-effective.
Comment. In the absence of any significant present threat
to human health and the environment, EPA appears to rely on
the potential threat of future releases and their postulated
impact on human health and the environment as a justification
for requiring corrective ~ction at the site (Comments Report
at 4).
u.S. EPA Response. U.S. EPA considered the. potential threat
of future releases as one of the major factors in the selec-
tion of the preferred remedy. Other major factors were the
fact that the amount and condition of hazardous substances
remaining in the waste mass could not be quantified, future
hazardous substance release rates and characteristics could
not be quantified, future site development was unrestricted,
infiltration and runoff was uncontrolled, and site monitor- .
ing was not established.
"" .
Under these circumstances, the U.S. EPA decided that closure
of the site using a properly graded and compacted low-perme-
ability cap with related site restrictions and monitoring
3-2
.
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features was reasonable and consistent with applicable or
relevant and appropriate environmental requirements.
Comments. The Comments Report prepared by Dames and Moore
-addressed each of the four hypotheses presented in the FS
regarding why major releases of hazardous substances have
not been identified during the RI (from Comment Report pages
4 and 5). These comments are summarized below:
4.
1.
The 1977-Fire. This hypothesis clearly has merit.
Such a fire would have had the capacity to oxidize a
substantial volume of organic waste. The fire report-
edly covered a 5-acre area where drums were disposed of.
2.
Landfill Hvdraulics. It seems unl~kely that the land-
fill has not reached an equilibrium condition with
respect to hydraulic saturation. It is reasonable to
assume that current leachate flow conditions are rea-
sonably typical of those to be expected in the future
from a hydraulic standpoint.
3.
Leading Edge Hypothesis. Spoil.bank wells must be rep-
resentative of leachate chemistry. It is difficult to
believe that contaminants would not have reached the
sampling points in a 10- to 20-year period.
Drummed Waste Hypothesis. The 1977 fire is likely to
have accounted for much of the liquid content of the
landfill. The likelihood that large numbers of drums
have maintained their integrity over this prolonged
period is low. Conditions would 'not-be expected to get
significantly worse given a similar rate of deteriora-
tion of remaining drums in the future.
u.S. EPA Response. Each of these comments on the four hypo-
theses is addressed below.
1.
2.
The 1977 fire probably oxidized and volatilized some
organic hazardous substances in a limited area of the
landfill. The "capacity" of the fire in terms of the
fraction of total organic waste affected is unknown.
The fire reportedly covered about 5 acres, however,
drums were disposed over a wide area of the landfill as
evidence by drum appearances at the surface. Therefore,
it is reasonable to assume that many drums of wastes
were not affected by the fire.
The hydraulic equilibrium of the waste mass can be deter-
mined only by borings into the waste and in situ head
measurements. Surface seepage observed on slopes follow-
ing wet weather could be from channelled or perched infil-
tration flowing out of the slopes. .
3-3
.
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3.
Leachate chemistry could change over time as drums or
liquid pockets become available for release by waste
shifting or drum deterioration. A "leading edge" could
have been generated only recently.
4.
The amount of organic hazardous substances "accounted
for" in the 1977 fire is not known. The "likelihood"
of drum integrity is speculation without evidence such
as drum examination. Whether chemical release behavior
or "conditions" will remain the sarne or get worse is
unknown.
Comment. EPA's analysis of groundwater flow directions in
the lower Kittanning Coal and Harnden Member appears to be
suspect. The groundwater elevation in MWD-S was ignored,
whereas that in MW-21, a well which has' clearly behaved
erratically throughout the period of record, was included.
The level in MW-21 appears unreasonably low. Revised inter-
pretation would show a northwesterly groundwater flow towards
North Creek and southerly and southeasterly flow into drain-
ages tending in those directions. There is no evidence of
southwesterly groundwater flow.
u.s. EPA Response. The groundwater gradient interpretation
for the lower Kittanning Coal and Harnden Member in the Com-
ments Reports is noted. The high groundwater deviation in
MWD-S was disregarded during RI data interpretation because
of the possibility that "the well seal had failed and water
from the mine drift above was seeping through the seal.
MWD-S was not considered a reasonable recharge area as sug-
gested by the suspect water eleva~ions.
As noted in the Comments Report, the groundwater flow trend
toward the south and southeast in the Harnden Member is in
the direction of two private wells screened below the lower
Ki ttanning Coal. " Future property development and well con-
struction in this area could increase the number of persons
affected. Finally, the potential for fracture flow cannot
be disregarded. As the RI noted, specific groundwater flow
directions may not follow gradients exactly as in porous
media flow because of fracture flow path.
'omment. Dames and Moore in the Comments Report concurs
with the general conclusion of the endangerment assessment,
that the present risk to human health and the environment
appears to be negligible. The calculated levels of risk
serve to demonstrate that remediation is "difficult to justify
on the basis of either current or realistic future risks to
human health and the environment (Comments Report at 8).
u.s. EPA Response. Present calculated risks are low as dis-
cussed in the endangerment assessment. The endangerment
assessment alsQ noted that future risks could not be
3~4
.
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4.
5.
6.
evaluated quantitatively or qualitatively given uncertainty
of f~ture releases, but the potential for future risk exists.
The potential for future release and future risk from hazard-
ous substances remaining onsite within the waste mass in com-
bination with the need to comply with applicable or relevant
and appropriate environmental regulations led to the u.s. EPA
decision to prefer landfill closure as the remedial alterna-
tive. The types, conditions and amounts of hazardous sub-
stances remaining in the waste mass are unknown, but data
from CERCLA 104 responses collected from PRPs in 1984 indi-
cated that approximately 6.4 million pounds of hazardous
substances were disposed of in the landfill. Therefore, the
endangerment assessment concluded that future risk cannot be
evaluated qualitatively or quantitative~y--"realistic" future
risks are very difficult to judge.
Comment. The Comments Report addressed each of the components
of the u.s. EPA preferred remedial alternative. Each of these
comments is summarized below.
1.
Regrading. No specific comment was provided except to
rephrase the work description from the FS.
2.
Engineered Clay/Soil Cap. The estimated incremental
cost of the incremental reduction of infiltration is
130 percent of the. total cost estimated for regrading.
3.
Leachate Collection/Treatment. The endangerment assess-
ment suggests no significant risk caused by leachate dis-
charge.' Leachate collection capital cost is significant.
O&M costs could be higher than estimated because pretreat-
ment may be needed prior to POTW, likely reduction of
iron and manganese rather than removal of synthetic
organic compounds.
Gas Collection. There is no evidence of gas production
at the site. Sealing of the landfill is likely to cause
more of the fill material to change from aerobic to
anaerobic conditions. A low permeability cap may
increase gas pressure. The proposed gas collection
system appears to be excessively elaborate. Sampling
discrete gas vents would seem more appropriate.
Revegetation. The Comments Report concurred that this
is the standard means of stabilizing landfill covers.
Fencing. Fencing will effectively limit access to con-
taminated soil and leachate. These risks are then
reduced to zero.
3-5'
.
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3.
7.
Site Restrictions. Legal restrictions are another effec-
tive way .of eliminating exposure pathways and reducing
associated risks to zero.
8.
Monitoring. It is reasonable to ensure that a properly
designed monitoring program will allow time for response
to any deterioration in conditions before they become
threatening to human health.
u.S. EPA Response. Each of these comments on the preferred
remedial alternative components is addressed below.
1 .
Regrading. This would be a part of any landfill cap-
ping configuration because existing site grades are not
acceptable. .
2.
Engineered clay/soil cap. The incremental cost for
infiltration reduction is high. The engineered clay/
soil cap is an Ohio sanitary landfill closure require-
ment. The "clay" portion of the cap must be a "well
compacted cover material" according to state regula-
tions and can be loam, silty loam, sandy loam, clay
loam, silty clay, or sandy clay. The Fs used the term
clay and unit costs representative of suitable material.
In response to public comments including those of the
PRPs, the configuration for the engineered clay/soil
cap was modified within the specific requirements for
Ohio solid waste landfill closure. These changes to
the preferred remedial alternative are generally as
follows: .
o
Delete the sand drainage layer and drainage piping
(Defer to final design decision) .
Plan to use low permeability compacted cover mate-
rial as both a portion of the fill and for the
finished cap.
o
These changes reflected a more economical conceptual
design while still conforming to Ohio solid waste land-
fill closure requirements.
Leachate collection/treatment. Leachate collection was
included in the preferred alternative in the Fs as a
conservative measure to be in place if future releases
developed. Capital cost of installing a leachate col-
lection system as part of a low permeability cap may be
lower than as a later retrofit. O&M is difficult to
estimate and could be higher than assumed in the Fs
because of pretreatment requirements. The expressed
concern over possible pretreatment for iron and man-
ganese is unsupported.
.
3-6
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5.
6.
7.
In response to public comments including those of the
PRPs, the decisions as to whether to construct leachate
and groundwater collection and treatment facilities
were deferred to final design. Leachate and groundwater
collection .may be required to comply with Ohio solid
waste landfill closure requirements or as a possible
contingency response in the event of a future release.
4.
Gas collection. The RI did not look for methane gas.
Gas probes were not installed to seek landfill gas at
the site. There is no direct evidence of gas produc-
tion: however, landfill gas (mostly carbon dioxide and
methane) is a typical feature of municipal landfills
that have received garbage.
Conversion from aerobic to anaerobic conditions is not
expected. Rather, the assumption is that anaerobic
conditions prevail now assuming this is a typical muni-
cipal/industrial landfill. A well compacted cap would
tend to trap landfill gas that may otherwise escape
through the surface.
In response to public comments including those of the
PRPs, the decision as to whether to construct the land-
fill gas collection and passive venting system was
deferred to final design. In the event that gas col-
lection and venting is incorporated in final design, a
more simple gas venting arrangement then shown in the
FS may be acceptable. Boring into the landfill waste
mass to install gas collection wells was not considered
acceptable in the FS. This was the reason why the FS
alternatives were based on a network of surface gas
collectors installed in porous media immediately under
the low permeability cap.
Revegetation. Revegetation is an important part of any
site grading or capping work. Revegetation increases
release of water by transpiration and controls erosion
through soil anchoring in root structure.
Fencing. Fencing would reduce ease of public access to
the site and thereby reduce direct contact risks. Fenc-
ing cannot completely prevent determined persons from
entering the site, so direct contact risks cannot be
assumed to be reduced to "zero."
Site Restrictions. Legal restrictions are a means of
preventing future uncontrolled site development. How-
ever, legal restrictions can be changed over time and.
effectiveness can be decreased, therefore, potential
risks associated with future site development cannot be
assumed to be reduced to "zero."
3-7
.
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-
8.
Monitorinq. A well designed monitoring program would
serve to verify the effectiveness of remedial actions
and trigger additional actions as needed.. The time for
response in the event of a detected release would prob-
ably be sufficient for protection of human health and
the environment. . .
Comment. Given the previous history of the situation, the
entire episode is beginning to reek of "self-justification"
on the part o~ the EPA officials both federal and state. It
almost seems as if the agencies feel they are in a face-saving
situation and that something has to be done to make previous
expenditures seem justified. To' ask the community to spend
$17.5 million on an unproven problem borders on abuse of regu-
latory power. (Mr. Bruce W. Wallace's ~omment.) .
u.s. EPA Response. Previous expenditures on the remedial
investigations and feasibility study were required by law
and the NCP and were, therefore, already justified. The
selection of the preferred remedial actions was based on the
need to comply with all applicable or relevant and appropri-
ate environmental laws and'regulations. The preferred alter-
native would meet requirements for landfill closure which was
deemed an applicable requirement since the landfill was never
closed in accordance with State regulations.
Comment. The FS report uses words like "could," "possibly"
and "potentially"--these terms show guessing and hedging on
inconclusive work rather than standing up and saying "yes"
or "no." (Mr. Howard s. Beall's comment.)
.u.S. EPA Response. The U.S. EPA often must" use these kinds
of words to describe judgments on current conditions subject
to uncertainty and future situations or conditions that may
or may not occur. In all hazardous waste projects, informa-
tion is limited and complex problems require that statements
use qualified te~s. These terms express accurately the
uncertain nature of the situation and acknowledge the prob-
abilistic basis for conclusions and assumptions.
PAST LANDFILL PRACTICE AND CONDITIONS
Comment. I am 100 percent behind the EPA spending whatever
it takes to make that old landfill safe. I am not in favor
of leaving this problem in the hands of the City of Coshocton.
The landfill has caused us hardships. . . the fires, explo-
sions, smoke, flies, gup {sic} running free, dead animals,
garbage on top of the ground--rats and dog packs which ulti-
mately menaced neighboring farms and residences. (Mrs. Robert
L. Jacobs' comment.)
u.S. EPA Response. With regards to the remedial action work
being in the hands of the City of Coshocton, the U.S. EPA may
3-8
.
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, .
enter into a written, agreement with the City for the City to
do the work which would be enforceable as an order as spec-
ified by U.S. EPA. Often this kind of agreement can expedite
work. The City's work would be supervised by U.S. EPA and,
if it were deemed deficient or unduly delayed, then U.S. EPA
would take action, either on its own or by asking the court
for relief. The "hardships" reported due to the landfill
are noted.
PUBLIC HEALTH RISKS
Comment. We want our water supplies tested in this area and
some consideration for our health and property for a change.
(Mr. James V. Cognion's comment.)
U.S. EPA Responses. U.S. EPA found very low concentrations
of organic solvent releases in the groundwater wells nearest
to the buried waste mass and no evidence of release in wells
further away. Contamination of current private wells near
the landfill is not expected. The U.S. EPA will evaluate
the need for private well sampling during the remedial
design., '
REMEDIAL ACTION COSTS AND ECONOMIC EFFECTS
Comment. The estimated $17.5 million for the selected pre-
ferred site remedy would cause undue economic stress on the
community. (Comment by Coshocton County Commissioners,
Coshocton Area Chamber of Commerce, and many others.)
U.S. EPA Response. It is not the intention of U.S. EPA to
place the community in economic hardship by the selection of
remedial actions at the site. The cost of the remedial
actions must be reasonable in terms of current future risk
reduction. Serious consideration has been given and will
continue to be given to cost reduction and control in'the
implementation of any remedial action at the site.
PROPOSED ALTERNATIVE ACTIONS
Comment. City officials have taken every step to comply with
EPA directives and the site is now being monitored with no
evidence of hazard to our citizens. (Comment by Mr. John L.
West/Stone Container Corporation and many others.)
U.S. EPA Response. The City has monitored the landfill site
in compliance with an agreement between the City and U.S. EPA.
However, the older records of the landfill indicate that the
landfill was never closed in accordance with Ohio EPA sani-
tary landfill closure regulations after landfill operations
ceased in 1979.
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.
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Comment. Reconsideration of the plan is urged. Give closer
study to past actions and the monitoring plan submitted by
the City and PRPs. (Comment by Coshocton County Commission-
ers, Coshocton Area Chamber of Commerce, and many others.)
u.s. EPA Response. U.S. EPA, on the basis of public comments,
additional information regarding the types of wastes, clari-
fication of Ohio regulations, and an alternative proposal
submitted by PRPs for remedial actions has reconsidered the
selected remedy. The alternative remedial proposal submitted
by the PRPs on March 16, 1988 called for more site work than
monitoring alone. The PRPs proposed plan called for site
fencing, regrading to achieve minimum and maximum slopes,
surface revegetation with topsoil cover to promote growth,
establishment of site restrictions, lo~g-term monitoring of
leachate surface water and groundwater, and a commitment to
take further remedial actions in the event that monitoring
shows the need for further actions.
Comment. There is no simple solution for this landfill's
problems and there will be a definite impact on our lives no
matter what is decided. There is differing opinion on pre-
sent danger but all seem to agree as to the potential for
future release from the site. It is time to get a good well
drained cover on the site and let it rest. (Mr. Donald
Wells' comment.)
u.s. EPA Response. The goal of u.s. EPA's decisions is to
minimize the effect of the landfill on the health and wel-
fare of local citizens and the environment. The present
danger or risk posed by the landfill appears minor, however,
U.S. EPA is concerned that future releases could occur and
cause .threats to human health or environment. The position
of the PRPs has been that there is little potential for
future release. A properly constructed cover or site cap
would be a major improvement over existing site conditions
because it would reduce infiltration of water and practically
eliminate probability of casual contact with surface wastes.
LEGAL ISSUES REGARDING ARARs AND OTHER
PROVISIONS OF CERCLA/SARA
[The following comments were prepared by u.S. EPA Regional
Counsel for incorporation into this Responsiveness Summary.]
A group of the PRPs submitted a 22-page comment over the sig-
nature of Paul J. Lambert~ legal counsel to General Electric
(letter dated March 16, 1988).* A significant portion of the
*Stone Container submitted a comment, on its own, which
restates the issues raised in the Lambert letter. This
response is meant to respond to the Stone Container comment
as well. -
3-10
.
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comment is devoted to legal argument, particularly of the
"applicable or relevant and appropriate" concept embodied in
CERCLA Section 121. The legal issues addressed by the com-
ment have not yet benefitted from a direct, dispositive
court interpretation, as evidenced by the dearth of authority
cited in the comment. Moreover, a significant number of
these issues are the subject of evolving EPA policy as it
gains experience in the implementation of the 1986 Amend-
ments to the law and as courts render decisions on the mean-
ing of specific provisions. Thus, this response is necessar-
ily a function of the above factors, is limited solely to
the Coshocton Landfill site, and does not represent a general
Agency position or policy. Moreover, should litigation ensue,
the Agency reserves its riqht to amend the views expressed
hereafter.
The following are the summary comments of the PRPs set forth
in pages 2 to 3 of their letter and the Agency's responses
to each.
Comment. "A. As a matter of law, no remedy can be justified
under CERCLA in the absence of a substantial danger to present
or future public health or welfare or the environment. See
CERCLA 9 104 and definition of remedy in CERCLA 9 l01(24r:-
The Endangerment Assessment of this site does not support a
finding of such an endangerment."
u.s. EPA Resconse. This comment is, in essence, a statutory
construction argument. Though it is undeniable that words
such as "substantial" and "significant" are subject to inter-
pretation, and though parts of CERCLA are arguably ambiguous,
it is the Agency's position that fundamental rules of statu-
tory construction. support its choice of remedy in this matter.
The present context is not appropriate for a full briefing
of the position contrary to that offered by the PRPs. How-
ever, there exists an ample factual basis in the administra-
tive record for u.S. EPA's choice of remedy, and the follow-
ing nonexclusive list of commonly articulated rules of con-
struction support the Agency's disagreement with the PRP
comment.
1.
Inasmuch as CERCLA is a remedial statute, courts are to
liberally interpret any ambiguous language so as to
effectuate the statutory purpose. United States v.
Mottolo 60~ F. Supp. 898, 902 (D.N.H. 1985).
2.
The same liberal construction is required because CERCLA
was enacted for the "protection and preservation of pub-
lic health." United States v. Conservation Chemical
Co. 619 F. Supp 162, 192 (D.C. Mo. 1985).
3~11
.
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3.
An administrative agency's regulatory interpretation of
ambiguous provisions, as well its practices, are enti-
tled to substantial deference, particularly where the
subject. matter is of a technical or scientific nature.
See Artesian Water Co. v. Gov. of New Costle County
659 F. Supp. 1269, 1290-91 (D. Del. 1987) and cases
cited therein. U.S. EPA has promulgated regulations at
40 C.F.R. 9 300.68 which set forth procedures and stan-
dards to guide the selection of a remedy at an NPL site.
The remedy chosen at the conclusion of that process is
entitled to a strong presumption that it is consistent
with CERCLA. u.S. v. Northeastern Pharm. and Chern. Co.
579 F. Supp. 823, 850-51 (W.D. Mo. 1984).
In summary, the Agency believes there ~s a more than suffi-
cient factual and legal basis to conclude that remedial
action is necessary at the Coshocton Landfill site. Not-
withstanding the PRPs' reservation of their aforesaid argu-
ment, they have offered to perform an alternative remedy.
Comment. "B. Without prejudice to foregoing argument, the
City and local industry support the remedial action described
in detail in Section IV below and in the Dames and Moore
report: entitled "PRP's Proposed Alternative Plan for the
Coshocton Landfill Superfund Site." This remedial plan is
substantially the same as "Assembled Alternative No.3" as
described in the FS and contemplates, in addition, a commit-
ment to take further action in the event that predetermined
groundwater, surface water, and leachate standards are
exceeded. This alternative remedy would be protective of
human health and the environment and cost effective as
required by CERCLA 9 121(b) (1) and it would attain a degree
of control that assures protection of health and the environ-
ment as required by CERCLA 9 121(d)."
U.S. EPA Response. U.S. EPA's position is that with further
specificity and with certain revisions so as to make the PRP
alternative equivalent to the state solid waste closure
requirements, and with a readily enforceable mechanism to
compel necessary, future remedial action, it is possible
that the PRPs' proposal could be determined to be sufficient
to protect the public health and the environment. The PRPs'
proposal suggests a remedy which is less costly, initially,
but which could be substantially more expensive should the
monitoring system detect changed conditions. Generally, it
is EPA's preference to undertake a comprehensive containment
action early on, so as to minimize the chance that further
remedial actions may be required in the future. The PRPs,
on the other hand, have expressed a preference for a less
comprehensive (and less costly) initial containment action,
with the understanding that should said initial action not
be sufficient, the ensuing remedy could be more costly.
While it may not be appropriate for the federal government
3-12
.
-------
to "gamble" in this way, if financially viable private enti-
ties agree to undertake the remedy and are willing to enter
into an enforceable court order by which they would be obli-
gated to quickly act in response to changed conditions, the
government may be willing to consider a remedy by which the
PRPs explicitly assume such a risk. .
Comment. "C. The EPA Preferred Remedv is not required or
justified by the ARARs identified in the FS. Those ARARs
are action-specific in nature and both CERCLA 9 121 and EPA's
Interim Guidance on ARARs make clear that such ARARs may not
dictate a remedy that is not otherwise required to conform
to statutory mandates. In addition, the identified ARARs
are neither applicable nor relevant and appropriate to this
site."
u.s. EPA Response. Much of the PRP argument in support of
the summary comment, above, is consistent with the EPA's
general position. However, it reflects a misunderstanding
of the process leading to the chosen remedy in this matter.
The PRP comment assumes that but for ARARs, no remedy at all
would have been proposed for this facility. To the contrary,
the historical evidence of the substances disposed in the
landfill, coupled with the-evidence of releases (albeit in
relatively low concentrations) mandated a remedy. The Agency
rejected remedies involving treatment, destruction, and exca-
vation/removal in favor of a containment approach. Once a
remedy was selected which depended upon utilizing methodo-
logies to prevent the hazardous substances from migrating,
action-specific ARARs became appropos.
As discussed in the Record of Decision (ROD), the Agency has
been persuaded that neither the state nor the federal hazard-
ous waste regulations are "appropriate" to this site, though
they are certainly ."relevant." However, contrary to the PRP
position, the Agency continues to believe that state solid
waste regulations are "applicable," for the reasons set forth
in the ROD. Moreover, the federal RCRA Subtitle D "Guide-
lines" regarding solid waste landfill closures are "relevant
and appropriate."
The PRP discussion which contends that the state regulations
defining solid wastes makes those regulations inapplicable
to CERCLA substances and the argument based on the "more
stringent" phrase are inventive, but not persuasive to the
Agency. The Agency believes that Congress intended that.
cleanup activities conform to state laws which are implicated
by remedial actions. For example, zemedial actions occur-
ring in wetlands must presumably comply with state wetland
regulations. Similarly, remedial actions occurring on solid
waste landfills must, at a minimum, comply with state solid
waste standards.
3-13
.
-------
- -------.- .
However, even if the PRP's argument regarding state solid
waste regulations were accepted, the RCRA Subtitle D guide-
lines, which set forth virtually the same capping specifica-
tions, are appropriate. .
In summary, then, .EPA agrees that neither the state nor the
federal standards regarding hazardous wastes are "applicableft
or "appropriate,n but it deems standards regarding the clo-
sure of solid waste facilities to be "applicable" and "appro-
priate" to this site.
Comment. "D. To the extent that the Preferred Femedy is
required by ARARs, compliance with them is excused pursuant
to the exceptions stated in CERCLA 9 121(d) (4) (D) because
the alternative remedy proposed by the City and local indus-
try will achieve an equivalent standar~ of control and will
be fully protective of public health and environment."
u.S. EPA Response. The PRPs assert that their proposed alter-
native remedy would provide equivalent protection to that
which the Agency has under consideration. As acknowledged
in the ROD and above, there may be an alternative approach
which, if embodied in an enforceable court order requiring
viable parties to take further actions specified by EPA,
could be sufficiently protective. However, until such time
as an alternative methodology is specified in detail and
made a part of an enforceable order, any equivalency dis-
cussion is speculative. As noted, the PRP proposed alter-
native of March 16, 1988, absent certain revisions and
enforceability mechanisms, cannot be deemed to be equivalent.
The PRPs have requested that the Agency exercise its "waiver"
authority pursuant to CERCLA 9 121(d) (4) (D), on the basis
that their alternate proposal will attain an equivalent
standard of performance. As noted, such an action would be
premature, and it is not clear that a modified alternate
proposal in the nature of that proposed by the PRPs might
not meet "applicable" or "appropriate" state and federal
standards. Until the waiver issue is'ripe for determina-
tion, the Agency defers its response on the availability of
the proffered waiver authority.
GLT147/58
3-14
.
-------
;
Appendix A (Page 1 of 7)
LIS! OF INDIVIDUALS
WHO COHHEN'IED ON mE COS1iOC'I0N LANDFILL FS
Company or Individual Name Representative Date
1. The Beach Co. James W. Beach Undated
2t.0 Brown I sLane President
Coshoc:ton, OR t.3812-0538
61t./622-0905
2. Farley & Sons, Inc. Shirley F. Farley Undated
51 Pine Street
Coshocton, OR t.3812
3. John P. Hamlmayer* Undated
DDS
t.. Thomson McKinnon Securities, Inc. Dorothy S. Outzs 03/03/88
12t. Chestnut Financial Consultant
Coshocton, OR t.3812
61t./623-0315
5. Coshocton Brake & Supply Co. James M. Baylor 03/02/88
Box 665 Manager
Coshocton, OR t.3812
61t./622-0595
6. Banner Fibreboard Co. James R. Shanklin 03/04/88
t.7849 Papermill Road Resident Manager
Coshocton, OR t.3812
7. A. Altman Co. (AAC) Robert Al tm4n 03/03/88
1201 Bldg. 30th St. NW
Cantou, 08 44709
614/492-t.202
8. Carns-Lowe Insurance Agency Inc. !eny L. Lowe Undated
119 South Sixth Street
Coshocton, 08 t.3812
61t./622-0733
9. Colonial Flag Co. Vane S. Scott Undated
P.O. Box 507 General Manager
Coshocton, OR 43812
614/622-4.447
10. Esther F. Matis 02/2t./88
19074 t.R. t.50
Coshoc:ton, OR t.J812
u. Coshocton !owne Centre Realty Judith E. Whitaker Undated
Broker
12. Buckeye Fabric Finishing Co. Kevin E. Lee 03/04/88
Coshoc:ton, OR 43812 President
614/622-3251
13. BryCo Paul E. Bryant 03/09/88
P.O. Box870 Owner
Coshocton, OR t.J812
61t./623-0830
1t.. Wise Jewelers, Inc. Greg Fisher 03/04/88
419 Main Street Manager
Coshocton, OR t.3812
61t./622-0478
* . Handwritten Signature.
Spelling is uncertain.
.
-------
Appendix i.. (Page 2 of 7)
15.
Comoany or Individual Name
BryDet Development Corp.
P.O. Box 870
Coshocton, OR 43812
614/622-0478
16.
Main Office Supply Sprint
504 Main Street
Coshocton, OR 43812
614/622-7U5
Print
17.
Ohio AMCO Inc.
P.O. Box 207
Coshocton. OK
614/623-0660
43812
18.
Shannon Temporary Services Inc.
415 Walnut Street
Coshocton, OK 43812
614/622-2600
19.
Shaw-Barton Inc.
545 Walnut Street
Coshecton, OK 43812
614/622-4422
20.
Roes Fashions of Coshecton
423 Main Street
Coshocton, OR 43812
21.
Coshecton Area
Chamber of Commerce
124 Chestnut Street
Coshocton, OR 43812
614/622-54U
22.
Mutual Federal Savings & Loan Assoc.
100 Downtowner Plaza
Coshocton, OK 43812
Three Rivers Dental Arts
304 Chestnut Street
Coshocton, OK 43812
614/622-9557
23.
24.
Edward E. ~.ontgomery
Roscoe Village
Coshecton, OK 43812
SanCaat Inc.
535 Clov Lane
Coshecton, OH
614/622-8660
25.
43812
26.
Robert D. Mauch
Certified Public Accountant
305 Main Street
Coshocton, OH 43812
614/622-8101
27.
Beutenmiller
Local & Long Distance Moving
P.O. Box 339
Coshecton, OR 43812
614/622-6U4
* ~ HAndwritten Signature.
Representative
Ronald C. Deeter
Vice President
Joy Ann Padgett*
Owner
Paul E. Bryant
President
Edward A. Seitz
President
Charles E. Fetterolf
President, CEO
Tom and Carol Matteson*
Owners
'Pat Brown
Executive Director
Roger L. Bennett
Vice President
Randy L. Kreuter
DDS
R.P. Geyer
President
Paul R. Wiggins*
Secretary-Treasurer
Spelling is uncertain.
.
Date
03/09/88
Undated
03/09/88
03/04/88
03/07/88
Undated
03/01/88
03/03/88
Undated
03/05/88
03/03/88
03/03/88
Undated
-------
39.
28.
Company or Individual 1fame
Edwin F. Mulligan
Box 386
Coshocton, OH ~3801
29.
BancOhi0 National Bank
413 Main Street
Coshocton, OH 43812
61~/622-2211
30.
BancOhio
413 Main Street
Coshocton, OK 43812
61~/622-2211
31.
BancOhi0 National Bank
413 ~fain Street
Coshocton, OK ~3812
614/622-2211
32.
BancOhi0 National Bank
~13 Main Street
Coshocton, 08 ~3812
614/622-2211
33.
BancOhio National Bank
413 Maut Street
Coshocton, OR 43812
614/622-2211
34.
Pretty Products
437 Cambridge Road
. Coshocton , 08 43812
614/622-3522
35.
Pretty Products
437 Cambridge Road
Coshocton, 08 43812
614/622-3522
36.
; .
Appendix A (Page 3 of 7)
Representative
Ben E. Roadruck, Jr.*
Gary E. Atkinson*
Jean M. Bak~r*
Melvin Contrell*
Richard L. Richissin
Area President
Gene Border
Manager of Personnel
Daniel L. Penrod
Vice President
Treasurer
Ohio House of Representatives
95th House District
Coshocton, Guernsey & Holmes Counties
P.O. Box 367
Senecaville, OR ~3780
District: 614/685-2877
Columbus: 614/466-6935
37.
Coshocton County Memory Gardens
25580 St. Rt. No. 621
Coshocton, 08 43812
614/622-7157
38.
Rea & Associates Inc.
P.O. Box 607
Coshocton, OR 43812
614/622-8783
Rea & Associates Inc.
P.O. Box 607
Coshocton, OH 43812
614/622-8783
* .. Handwritten' Signature.
Joe Secrest
Chairman
Ohio House Energy and
Environment Committee
Carla E. Zinken
District Office Manager
Gene E. Flowers
CPA
David M. Cain
CPA
Spelling is uncertain.
.
Qill
03/08/88
03/02/88
Undated
Undated
Undated
03/02/88
03/03/88
03/07/88
03/15/88
Undated
03/03/88
03/0/388
-------
Appendix A (Page 4 of 7)
Company or Individual Name Representative ~
40. Rea & Associates Inc. 0..1. Muse 03/03/88
P.O. Box 607 CPA
Coshocton. OH 43812
614/622-8783
41. Dr. .1..1. McConnell* Undated
42. Coshocton County Convention and Harold F. Turner 03/07/88
Visitors Bureau: Secretary
P.O. Box 905
Coshocton. OR 43812
614/622-9314/800/338-4724
43. KeMeth and !Caye Noble 03/05/88
19519 C.R. 7
Coshocton. OR 43812
614/622-0847
44. United States House of Representatives Douglas Applegat$ 03/17/88
18th District. Ohio Member of Congress
2183 Rayburn House Office Bldg.
Washington. DC 20515 John Glenn
202/225-6265 United States Senator
45. United States House of Representatives Douglas Applegate 03/17/88
18th District. Ohio Member of Congress
2183 Rayburn House Office Bldg.
Washington. DC 20515 John GleM
202/225-6265 United States Senator
46. McDonald's of Tuscarawas & Dana J. Lewis* Undated
Coshocton Counties Owner /Operator. ..
1200 West High Avenue
New Philadelphia. OH 4663
216/339-6416
47. Shriver Tire Service Charles E. Shriver Undated
123 Mulberry Street
Coshocton. OR 43812
614/622-6746
48. Robert F. McCoy 03/08/88
2216 Forest Hill Drive
Coshocton, 08 43812
49. Scheeff Chevrolet Gary E. Scheeff Undated
1hird & Walnut President
P.O. Box 637
Coshocton, OH 43812
614/622-0626
50. Carroll's Buckeye Motors James L. Carroll 03/UIB8
U02 Chestnut Street
P.O. Box 278
Coshocton, OH 43812
614/622-8350
51. Robert P. Glazier*. Undated
..
52. Harold E. Hunt 03/09/88
Attorney at Law
448 Chestnut Street
Coshocton, OH 43812
* . Handwritten Signature.
Spelling is uncertain.
'"
.
-------
Appendix A (Page 5 of 7)
Company or Individual Name
53. Coshocton City Schools
1207 Cambridge Road
Coshocton, OH 43812
614/622-1901
Ret)resentative
Date
John Berg
PhD "
Superintendent
03/03/88
54. Bordenkircher Electric, Inc.
P.O. Box 776
Coshocton, 08 43812
614/622-5557
55. Wagner's Supply. Inc.
South Second Street
Coshocton. OR 43812
614/622-5711
56. Jacobs Insurance Service, Inc.
530 Main Street
P.O. Box 367
Coshocton. 08 43812
614/622-1796
57. Fern Woodie*
U49 Stewart Lane
Coshocton. OH 43812
58. Stone Container Corporation
500 North Fourth Street
Coshocton, 08 43812
614/622-6543
59. Stone Container Corporation
and Coahocton Mill
60. Bingham, Dana & Gould
1724 Massachusetts Ave. NW
Suite 400
Washington. DC 20036
202/822-9320
61. Bingham, Dana & Gould
1724 Massachusetts Ave. NW
Suite 400
Washington, DC 20036
202/822-9320
62. Bingham, Dana & Gould
1724 Massachusetts Ave. NW
Suite 400
Washington, DC 20036
202/822-9320
63. General Electric Company
1350 South Second Street
Coshocton, OH 43812
614-622/5310
64. Coshocton County Commissioners
~9 1/2 ~Ain Street
Coshocton. 08 43812
614/622-1753
Walter Bordenkircher
Secretary/Ireasurer
Undated
Gordon R. Wagner
Genera I Manager
03/08/88
Roy J. Snyder
03/08/88
03/08/88
John L. West
03/02/88
John L. West
General Manager
Coshocton Mill
03/17/88
Paul J. Lambert:
03/15/88
Paul J. Lambert
03/15/88
Paul J. Lambert:
03/16/88
Richard F. Anderson
Project Engineer
08/28/80
Harold F. Turner
03/07/88
James R. Ross
John E. Porteua
* . Handwritten Signature.
Spelling is uncertain.
.
"
-------
Appendix A (Page 6 of 7)
65.
Company or Individual Name
Ross Bros., Inc.
Box 46
Adams Mill, OH 43801
Edward R. Ross*
Re!)resentative
66.
Howard S. Beall
1020 Cambridge Road
Coshocton, OH 43812-2703
James V. Cognion*
19487 CR 7
614/622-3952
67.
68.
Pearldene Schaeffer*
45660 CR 58
Coshocton, OH 43812
69.
Marilyn'S Natural Foods
430 Main Street
Coshocton. OH 43812
. Marilyn J. Share
70.
Russ Mossman*
71.
Marilyn J. Wiley
1685 South 14th Street
Coshocton. OH . 43812
Coshocton Broadcasting Co.
745 South Sixth Street
Coshocton, .OH 43812
614/622-1770
Bruce Wallace
President
72.
73A Mrs. Robert L. Jacobs
19020 'IR 450
~ ,Coshocton, OH 43812
74.
Donald G. Wells*
---
75.
Kahoun Kabinets
K1t~hen Bath Center
316 \.1est Main
West Lafayette, OH 43845
Coshocton Lumber Company, Inc.
1200 Walnut
Cosh oct on. OH 43812
614/ &22.-0199
Elaine L. Kahoun*
Manager
76.
Chris WellY*
President
77.
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box 577
Coshocton, OR 43812
Victor A. Reidenbach*
78.
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box 577
Coshocton, OH 43812
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box ,577
Coshocton, OH 43812
Melva R. HaWthorne*
79.
Elizabeth M. Green*
* . Han~itten Signature.
Spelling is uncertain.
.
~
Undated
03/U/88
03/08/88
03/08/88
03/15/88
Undated
03/15 /88
03/13/88
03/14/88
Undated
Undated
Undated
03/09/88
.. .
03/09/88
03/09/88
-------
80..
Company or Individual Name
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box 577
Coshocton, OR 43812
81.
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box 577
Coshocton, 08 .43812
82.
Lawrence Insurance Agency
147 Soutb 2nd Street
P.O. Box 577
Cosbocton, 08 43812
83.
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box 577
Coshocton, OR 43812.
84.
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box 577
Coshocton, 08 43812
85.
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box 577
Coshocton, OR 43812
86.
Lawrence Insurance Agency
147 South 2nd Street
P.O. Box 577
Co.hocton, OR 43812
GLn47/61
* . Handwritten Signature.
Appendix A (Page 7 of 7)
Representative
Margaret A. Prindle*
~
03/09/88
Joseph P. Sapp*
03/09/88
Janice C. O'Bryon*
03/09/88
Marilyn A. r:.~uvray*
03/09/88
Vernon J. Saybar*
03/09/88
Mrs. A. Abbot*
03/09/88
Robyn It. Abbot*
03/09/88
Spel1ing is uncertain.
.
-------
i :',3:U:.1 0
(i;:) i'~;)<.:~d\m:s ::r.J tc:chr.i4~h.:S ror c:1mp:.!<.:ting and
co\',;:ir.:z W:.l~~;: materi:.lb: ;:nu
(i\') ~je:hod~. if any, used' for COiltiO! of odors.
IIluisc. litter :.!nd 1:::.Ich:lte: and
Iv) wei:;hts and typ~s of equipment used to operate
site or facility: ~nd
~
\ \.;) l:"~~~ u( '.."~:.,~~..": ;:;\.",: :~:J. ;:::.j ;~:"i.;."~:::~P:~:'; "":.:~:~.
Iy quantity of c:.Ich typ~; and .
(c) a description of how the facility ",iJ! be closed.
(K) (I) the operator of each solid waste disposal
facility which was nor subject to Chapter 3745-26 of the
Regulations of the Ohio EP A shall submit the report as
described in paragraph (J) above. and may submit
applications for waivers under Regu'lation 3725-27-11.
in accordance with the foHowing schedule:
County
Deadline for Operational
Report Submission
January I. 1978
Cuyahoga
Lucas
Franklin
Butler
Columbian
Hamilton
lake
Lorain
Mahoning
Montgomery
Stark
\Summit
~"\Jmbull
n
f\shtabula
Clark
April I, 1978
July I. 1978
October I. 1978
Cr;,.'."" - .
Erie
Fairfield
Fulton
Geauga
Hancock
licking
Marion
Medina
Miami
Muskingum
Portage
Richland
. U Sandusky
Tuscarawas
Wayne
" Wood
All Other Counties
January I, 1979
April I. 1979
July I. 1979
STl,TE s"'_~L!a \'/ASTE-LAj.:O l:JS:
'...
,:n For f;!,;jjjtics ~uhjcct to r:'~:r:.lgi<.:ph (I) JOCVC Wh:C!l
wen: e~t~olishedon or aile:. .bv..I, 195)). lh-c l)ircC:()T
r11"Y n:quin: th:: operator to' submit detail plans.
srccifi.:aticns. and information in acco.daot.:e ",..ith
Reguluti0n 3745-27-6 in acdit:or. to the oper
r~:,~~" Th.: f):,C'::tor sh:!11 jmr.0~c Ihi~ rcm:i"(:rr.::rr
:~..; :',..," \.,~' :.i~'~;-. !'~~I':~('Ir~ ,~.; ::'IC !,.;~U:;\.'I.. ;-'.";::
hydrulogy of the site: the characteristics of the
mat~rjals received; or the operation of the facil
detcrmines that there exists a substantial threat 0
poJ/ution or a potential health hazard. The operate
submit such detail plans. specifications. and infor.
within one hundred eighty days after being noli
this requirement.
(3) If detail plans. specifications. and informat:
disapproved. and all remedies for such disapprov:
been exhausted or waived by failure to timely pursl . - - --.
remedies. the operator shall cease receipt of waste
materials not later. than 60 days after. such disapproval
becomes effective.
3745-27-10 CLOSURE OF SANITARY LANDFILLS
(A) Closure of a sanitary landfill shall be deemed to
occur If:
(I) the operator declares the facility closed; or
(2) a solid waste disposal license held by the sanitary
. landfill expires. and no further license has been applied
for in the manner prescribed in Chapter EP.33; and
(3) a solid waste disposal license held by the sanitary
landfill has expired. a further license has been applied for
and denied. and all remedies for such denial have either
been exhausted, or waived by timely failure to pursue
such remedies; or .
(4) a solid waste disposal license held by the sanitary
iand!!JI h:'5 !-:een~;:::;::.en~e: or n:'/oked. and
-------
(::":1': s''::.:o 'V'Jl\ST.~ C1:~'r::;::'.'.~.. F~!":;"::S
:0 0;';,) Re\'i~d Cr:dc ~l';,;tjl)r, .~73~.(J::;. t!H': DI;':'::C1r.
si!;.I;~ ;.It ',It:.=ts.t" once .....::stes gener::ted on the
premises where the facility is loc:lted.
.. (C) Not later than 60 days after closure of a sanitary
landfill, the operator shall com pie:: the following ac-
(I) All waste materials deposited in the sanitary land-
fill shall be covered with at least two feet of well com-
pacted cover material that meets the requirements set
~ th in Regulatio 745-27-09(F); and
L2) The site shall be seeded with such grasses or
other vegetation as will grow to form a complete and
dense cover, which seeding shall be done as many times
as necessary to insure compHance with this requireme:1t:
and
. 9) All land surfaces shall be 2r~d~d ~o slopes of no l~
than 1 percent and no greater than 2:> percent; and
(4) All land shaH be graded and drainage facilities shall
be provided so as to direct surface water off the site, and
not allow ponding of water on the site; and
rn Ventilation structures shall be installed and main-
~aine
-------
"11i~, ;'.'P'';; :.:nd Ih:: Difl:t.:tur ~!~ 5(.1011 :!~ l'r:.iellt.:(lI~:C, ;1I:d ill
. ;H) e:!;.(; I..~'r:: lh::n .10 <.laj's :\i',er l!H: waiver i~ gr;!n!:::1.
([;) ,".rH' cC:jscn ..,ho wisl;~s tu oOla.in :J'~~;'II~'~r.of a!1Y
''>jJI~,,;'..ion' ~r Regu/:llion }745.27-/i(/).- 37';5-27-07.
137.!5-:7-08, 3745-27-09. exe::pt 374)-27-09(('). or
37-;5-27-10 shall :lpply in writing 10 t,he: D~:e~.t?r,
~'~;;"~ ;;~~'\~~~)~~~~~~i~'~:~:~~~,~:~1~;~:; .~=~ t;.: ~~ ;~l.~~ ::~':"'~~: ;:;~;.; ,.I;~~
-------
a~IC SCLiiJ '/.}..'\:;T~ C:S?::.2,~~ ;::n..:LSS
(D) (I) (<.1) F:i~iIities subject, to ,P.<:gulati,on
.Yi..5-:7-09(.K.) si:aIL a;:>ply:to:" tne iniwd so!:d ,W:lstc a:s-,
pos~i license withi:1 thirty days of. submitting the
operati0r.al repor:.
(b) All subsequent solid waste disposal lic~nse: f~r
, f:lciJities $ubje~t ~o thi~ para~raph sh~il, be ,ar-~!:,ed ror In
l11= 1i~;.:n:1;r s:t ~~i ~j} :n ~:.1...~~.:;;;,.;:: \~,\",'i . .-1'"....
(2) E.¥.cept C!S provided in paragraph (I) above.
applications for solid waste disposal licer:ses shall be
made
(a) prior to start-up. and
(b) during the month of September. if the facility will
continue operations beyond December 31.
Any license application not tiled in the manner set
forth in this Regulation, 3745-37-02(D), shall not be con-
sidered. ,
3745-37-03 CRITERIA FOR ISSUING SOLID
WASTE DISPOSAL LICENSES
The Board of Health or the Director, whichever is
applicable, shall not issue a solid waste disposal license
unless
(A) a permit to install, if required by Chapter EP-30 of
the Regulations of the Ohio' EP A, has been obtained by
the appficant; and' ..
(B) detail plans have been approved by the DIrector. If
required by Ohio Revised Code Section 3734.05, or by
Regulation 3745-27-06 unless plan review and approval is
pending under Regulation 3745-27-09(K)(2); and
(C) in the case of a previously or currently operating
site or facility, the applicant operated the facility in sub-
stantial compliance with all applicable provisions of.
ORC Chapter 3734 and with these Chapters, 3745-27
and 3745-37, or Chapter 3745-26 (repealed], during the
period of effectiveness of the last license held for the
'1cility: and
(D ) ;;~ Io"'.~ ~~~ lwi4 .~;;;.. :",'-a~~..~_";. ,,~..;;;.:;..~~u~:' i'6 "~-"''''1~~''>
Iy prepared for operations, and has been inspected by the
Health Commissioner and by the Director or his
authorized representative; and
(E) the person identified as the operator of the facility
is competent and qualified to operate the facility in sub-
stantial accordance with ORC Chap. 3734 and these
Chapters, 3745-27 and 3745-37. '
3745-37-04 ACTION BY BOARD OF HEALTH OR
DIRECTOR
(A) The Board of Health or. the Dir~ctor sha.1I :ither
grant or deny a solid waste disposal hcense ~Ith~n 9.0
days of the date upon which a complete applJcatlon IS
received, unless detail plans required by Regulation 3745-27-
06 have not been approved and pennits required by Chapter
3745-37 of the Regulations of the Ohio EPA have not
..
~~:2,(;513
been issued by the Director prior :0 c.\~i.<:!io" 0; :his :;0
day period. in which case.a ,Iice~s~ sr.a~l- be i$5~ed or,
denied not' I~ter than 30 days after tt:~ errectl'iC: C:lte of
the Director's approval of such d::tail pians Jnc.J issu.ln<.;c
of such permits.
u (~) .~II_li,::~?_s,e~ .appli~d for pursuan:.to.:~eg~!:1tio~
;;':.:.":-Jj-C_"'.,1;:~.~:j .,;:~:.:... .;:J;;:~~:. ~:;: <:.:,......'.. :; ....,.:.; '....
J~n~ary 1. \ Lice~;es app!ied for purSUJnt to Reg'.:j~tion
3745-37-02 (D)( I) or (D)(2)(a) shaH be effective
upon the date of issuance. '
3745-37-05 EXPIRA TION OF LICENSES
. All solid waste disposal licenses shall expire on
December 31 of the year in which they become eifective.
unless the license is for a facility subject to Regulation
3745-27-09(K)(3), in which case the license shall expire
on the date set forth herein.
3745-37-06 TRANSFER OF LICENSES
(A) A pers'On holding a solid waste disposal license
shall not transfer said license to another person unless the
license holder notifies the Board of Health and the Direc-
tor in writing of the identity of the transferee and of the
transferee's assumption of his obligations. at least 60
days prior to the effective date of the transfer.
(B) Not later than 60 days after receiving such notice,
the Board of Health or the Director may disapprove the
transfer. if the Board or the Director concludes, based on
the transferee's, previous operations, that the transferee
will not operate the facility in substantial compliance
with Ohio Revised Code Chapter 3734 and these
Chapters, 3745-27 and 3745-37. or that the facility can-
not be brought into substantial compliance. The Board of
Health or the Director shall promptly notify the
transferee and the transferor of his or its decision in
'''::.:n~ a,.~ :;!-'l!l state :he reasons for his or its con-
-":,U~j\,,;..).
(C) A solid waste disposal license may not be
transferred from one fal.:ility to another.
3745-37-07 PROCEDURES FOR GRANTING.,
DENYING. SUSPENDING. ,MODIFYING.
REVOKING. OR DISAPPROVING TRANSFER OF
SOLID WASTE DISPOSAL LICENSES.
(A) In granting, denying, suspending, modifying,
revoking, or disapproving transfer of solid waste disposal
licenses. the Director shall act in accordance with the
provisions of Ohio Revised Code Chapters 119 and 3745,
and Chapter 3745-47 of the Regulations of the Ohio
EPA. '
(B) In granting, denying, suspend.ing, mOd.ifying.
revoking, or disapproving transfer of solid waste disposal
5-24-85
PubliS/'led by THE BUREAU OF NATIONAL AFFAIRS. INC.. WaSl'lington. D,C. 20037
319
.
-------
F:'~...'~' ~~._. :f;.: Sourd of ri.~:.:~h sh~;i ~i':t 1:1 ::H"~'t~rci;.ij,(';:,: \':;r!1
~):~'..:. S~\..tjur:s J73~,09. 3709,20. a:Jd J70~I,2f. alia ORC
C"~' 1'9 ' .' .
..":;".. ... .
"':;:.~5-]7-08 .-IP?ROVED LIST OF HEALTH
.'J 1ST:?ICTS
(.~'.) Th~ Director shall survey ani:uaJly ~:1ch Health
! <;.:=-I~~ i:..::::~:,.:';:,;:\' :;: ',,:::::.~ I~~~ :~,~,.:...; ;, ::;:.::~J. ~... ;'.'"
;:j by Ohio r:~\'i~~d Cede S::ction 37.34,U~. to cetc:;;li:i::
wh~ther there is suostantial com~!iance with ORC
Chapt'er 3i34 and with these Chapters. 3745-27 and
3745'-37. Substantial compliance shall be de:emed to
exist if: .
(J) Applications for solid waste disposal licenses arc on
file for each licensed solid, waste disposal facility in the
Health district, and .
(2) Applications are properly completed with all re-
quired information, and. .
(3) AIl known solid waste disposal facilities operating
rn the Health district and required to hold licenses by this
Chapter 3745-27. and ORC Sec. 3734.05 do hold valid
and unexpired licenses. and: '.
. (4) No license has been issued for any new solid waste
disposal facility prior to the Director's issuance' of reo
quired permits and approval of required detaH plans. and
(5) Certification of inspection and compliance has been
made to the Director within thirty days after issuance of
a solid waste disposal license, as required by ORC Sec.
3734.07, and, '. . .
(6) The Board of Health inspects solid waste disposal
"facilities subject tci these Chapters. i745-27 and 3745-37.
Iwith sufficient frequency to insure substantial compliance
therewith. and in any event inspects each such solid waste
disposal facility at least quarterly, and inspects each such
new solid waste disposal facility at least bi-weekly durin:.
~:.~ ,':;",':~ ~~-'-:" ~,-_.'....- .. "'.", ..,~.:~ -,' ~:--'f
(7) The Board of Health maintains a tile of informa-
tion relating to each licensed solid waste disposal facility,
and to each sanitary landfill closed, within the last five
years, which file shaU include applications for solid waste
~ 'disposal . licenses,. certification records,. inspect,ion
records: approved plans, litigation information (except
that privileged by the attorney~lient relationship). and
other pertinent ii1formation~and . .
, (8) The Board of Health undertakes appropriate ac-
tions against persons holding solid waste disposal licenses
and against persons who operate solid waste disposal
facilities without holding required solid waste disposal
licenses. and against other persons, whenever necessary
to bring about substantial compliance with ORC Chap.
3734 and these Chapters, 3745-27 and 3745-37. and
)
--'~'-""~"- '......_.._~.- --- - I:_-.~-~~
(9) The Board of Hc<:!Lh t:lkc~ irr.;-;:c:.lia.e aC~::;:1 ,0
ubate: serious hazards to the public health rc~uitin£:: fr0r71
violations of ORC Chap: 3734 and. these Ch:irJte~s.
3745-27 arid 3745-3i. and . '
(10) The Board of Health complies with Reg~l
-------
........ .,.., ..,...;.~r"Q.~.. '.'.''';-' "- -.-, ~.~.- ,,-----
, \:?I :Ii ,n;lkil1g lht:d(;lC:mil1i1lion icqi..:in:d ii1 p;;r::;r:(i;;"
(:~.,I ;d~v\'I.:. ir.C Din:c:or sh;~11 t:lke ii1tO I:l)n:iid.;::ti!:;~
(I )(a) Ch:lng~5 in or Jdl!itit,1r.s to tht: st;\ff. Jnd
. ~b) incrcJs:s in the: 'funds :n:ailablc:" to the Board ni
H;;.:lJth for enforcement of ORC Chap. 373~ and .hese
Ch:lotcrs. 3i..S-27 and 3i45-37; and
(2') writt::n assurances from the Buard of Health of in-
\,;!\::,::,\."J t.:;",'.. ~...: ,<, t:.; ~::.-~ ,:i ~:.''; 30::r::. :~~ :
(3) decn:~scs i'n the number of complexity of tilt: seEd'
waste disposal fOlcilities that would be within the Board of
HeaJlh's jurisdiction. and
(4) any other factor that indicates to the Director that
the board of Health meets the criteria set forth in
paragraph (A) above. .
(C) If the Director makes the determination described
in paragraph (A) above. he shall promptly
(I) enter such determination into his journal. and
(2) notify the Board of Health of his determination by
certified mail. and
(3) publish notice of his determination in the Ohio
EPA Weekly Review, and .
(4) publish notice of his determination in a newspaper
of general circulation in the area within the jurisdiction of
the Board of Health
3745-37-10 TIME FOR INSPECTIONS
Whenever a person requests in writing that the Health
Commissioner or the Director or his authorized represen-
tative make any inspection required by these Chapters.
3745-27 and 3745-37. the Health Commissioner of the
Director or his authorized representative shall mak~ such
inspection within 15 calendar days of receipt of the re-
quest.
3745-37-11 CONDITIONAL SOUD WASTE DIS-
,- :"SAL UCENSES
. 0
~ :;\) :::;..;-.:;.-: ~~:.; ~ ~ -. - w... .:. ~ : . :- .;~' ~. .; ~.: i.. .. .": ..
make final the suspension. denial. or revocation of any
solid waste disposal license held by any political subdivi-
sion. the Board or the Director shall issue a proposed
suspension. denial, or revocation in the manner set forth
in Regulation 3745-37-07. . '
(B) If the political subdivision to which the proposed
suspension, denial. or revocation is issued requests an
adjudication hearing to' contest the proposed denial.
suspension. or revocation, the political subdivision may.
at the adjudication hearing. present evidence relating to
its financial ability to comply with Chapter 3745-27. such
evidence shall show
(I) that the political subdivision is levying taxes that
re\'enues from which may be expended to comply with
Chapter 3745-27 at the maximum rates imposed by the
Ohio Constitution and the applicable statutes. and
--.- .__.._,_. _. ,....-_.-.- .". .._-
;:tt(~:;~lr~~/r\' \:;\~rL:';;~;~~~~;:; [~il~I';~~~.:::;~~u=;~ :<:~ ,:~~;:f~,~:::~
l1~ ~,'p:,:~ci;d to CO:"1;J!V \','it:l Ch~::~r 37";:...2i b=''':1~j ti~'~.
.Iimits nOimail): i:nr.o~::d by lhe 'appiicaok' stJt~:::~ ....-:
-------
(!'i \\.!hc;;c\'c:r .: po/iticJi subdi...isiun helding <.! con-
. diri(1:i;J! o;.:cr..ting lic::nse" or a solid waste disP9S;.:1
lic:::1:::: mcaified' pursu:lnt to par:.:gr:lph (D) above, is re-
'\;!Jiid by ~l:gulatioJj 3745.37-02(D) to apply for another
1i':(;:1);:': bl.'c:Ju~e of the impending expiration of the
'::::':I::Hly ~.ffec,tiv~. !ic~ns,=, such political sUbdi,vision shall
:~I:;:..~ ;';'~!:C~l~:i:~ ::: tt:~ ~.;::::= ~~l::!1~:.;r ~-=.~ ~~:~~;;:::.h:',,~ ::--:
;:1;:(i;: for nlh::r sulid '..':l.'le disposallicensc:s. The: Board of
' Hc::lth or the Director shall process such application in
the same: manner as other applic:ltions are required to be
~ - _. ~._----- ~......---~---- --------...._-.--_.-~,'.'I' ~ ''-''''''''';
-------.--.-
--...------
f1rocc~,~ct1 by [hi:; Ch::i'tc..37',!5-3i. If. UpC:1 r:ccjvii1~
notic:; of ;1:: Soard's or ,the DirC::::O~'5 prepo$:d d~:1iJ! of
the appJi<::Hion. the l'oiitic:.:1 subdi~'isjei1 determim:s t;,at
it wishes to obtain another conditional operating license,
it shall proceed as pro\'ic!::d in p:Iragraphs (B) through
(E) above. ,
(~) l'~v :".,;;:d ..,';::::: d::j~(;~C!l. f(:._~;::\' ':~::':-~:::;.': ::;~:1.,.;' .:
conditional Iicen!ic shaH '0:: permitted to re;ei~~e se:wag:
solids, semi-solids and liquids. o:her semi-solids or li-
quids, or hazardous wastes.
Environment Aego"et
.
-
, .
~
< .
322
-------
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10 I
MILES
OHIO
.
COSHOCTON
.
FIGURE ,.,
SITEytCINITY MAP
COSHOCTON FS
-------
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\\. ,~.,'", , ~,,-.,. ,= 1m' '24034 1900, "
1: " '" C " ~' : "--'r---.JI!, "I -- m ,.J 40025;, :\ -- ,..('Q
: ,...-.- ' t.t.'#. I ".. -' t ~O J 70 ; ;/ a
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-"'--" ./' .. , , 0 ' ~ '-l." 9
.;?,,~"1.( )~ , ~I' ,'.'., :..-~/T~,~,,~-,.COS~OCTONPR ERTY'
-_.~. .' ,00, J J'" , 'oJ' )~'
..:~} J ...', ," "", ' , ' ~ ,
~, " ,cr:: L__--....._~ m.-".,-, ':.- ' '11' 7 ",', ,.-
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LEGEND
o PRIVATE WELL LOCATION AND NUMBER
I
o
,
SCALE IN FEET
2000'
I
o ADDITIONAL HOMES (NO PRIVATE WELL
DATA CURRENTLY AVAILABLE)
NOTE: P"yate well locations obtaIned
, from PermIt 1006, Hydrology Map'
Cravat Coal Co,
. AddItIonal home locatIons from
W;If,s Creek U,S G,S, TOpOgraphIc
'-1ao
FIGURE ',3
SITE LOCA'T'<::\
,tOSHOC~ON Lf.'.:uFI.
~
..
-------
~O.'. "'""111' hCOITO..
8IIA&.II
....... aIT1'A....a COAL
IIOAU
....... --
~a... .,n...... CO....
PREMINING CROSS SECTION
NOT TO SCALE
r;'\
I
I
/.
--'-
~OW" nil'"" I...ITO..
IMAU
.'00"1 IITT&.....a COA"
...u .
".80.. .......
1.0... .
A..... C
POST MINING CROSS seCTION 1'3\
NOT TO SCALE
-\-----
--¥ ..
'., .
\i
...~-
\
LOC.."IO. "-". \
a...... CI... ....... . \i:.
'\
N~
1/
i/
8.
L-~
~ g,.....
ACU.'. ... '"11
- 500. .
~O.I. '.""111' '.80111'0"
'''au
..au 1111'1'....... COAL
..au
""80.. ......
1.0... IIITTA...a COAl.
ACTive !t1INING CROSS seCTION
NOT TO SCALe
r2\
La... "'..JI>Oa,. t&-o81'O..
IMAU
anOD...& C"TA...llta co....
........
....... ...1..
1.0... I. '.".Q COal.
POST LANDFILLING CROSS SECTION
NOT TO SCALe
17)
NOTE: Thesl sections are general in na.ure and
are nOt intended to provide detailed
reoresentation 0# geologic conditions.
These sections should be used onlv to
obtain a general knowledge of mining
and/or filling aCtivities.
FIGURE 1.5
COSHOCTON SITE MINING AND
LAf\JDFILLi!\IG GENERAL
CRO&$ SEt.: (IONS
COS;.,C:70~.. -.
-------
General Response
Action
Nu Action
Access
K~st r Ictions
.
Containment
Table ]-2 (Page 1 of 6)
API'LICABI.E TEC/INOLOGIES AND PROCESS OPTIONS FOR T/IE COSIIOCTON LANDf'ILL WASTE MASS
Remedial Technology and Process Option
NONE
Leave a1te aa 1t la.
DEED RESTRICTIONS
All deeda for property within potentially
contaminated areas would include restrictions on
use of property.
SITE FENCING'
Fencing around the afte and drainage ditches.
All fencing would be maintained as necesssry.
MONITORING
Collect and analyze groundwater, surface water,
and sediment runoff to detect changes In quality.
SURFACE CONTROLS
Grading. Reshape surface contours to manage
surface water. '
Rev:f~~atlon. Establish vegetative cover to
sta ze aurface soila.
Duat Control. Prevent exceaa dust condltiona by
the use of water spray or chemical agents.
Soil Cover. Cover site with aoll and
establish vegetative cover to reduce potential
for direct contact, eroalon, volatilization or
duat generation.
CAP
~le 1.8yer. Cover contaminated landfill
contents with a sln81e layer of low permeability
material such 8S clay, asphalt, or concrete.
Retained
for
Further
Analysis
Yea
Yea
Yea
Yea
Yes
Yea
No
Yea
Yea
Applicability Screening Commenta
The NCP requires No Action to be carried
through to detailed 8nalysla of alternatives.
Potentially feasible.
Potentially feaalble.
Potentially feasible.
Potentially feasible.
Potentially feasible.
Exlstlnl vegetative cover provldea adequate
dust control.
Potentially feasible.
Potentially feasible. /lowever, effectiveness
Is severely limited becauae of probable cracks
and fractur~s caused by weathering, wet sIte
cundltlons and settlement of landfill contents.
,j
-------
i I
I ,
I'
I '
I'
!
.,
"
I
I,
"
~neral k~sponse
Action
Containment (Cont'd)
kemoval
Table ]-2 (Page 2 of 6)
Remedial Technology and Process Option
:~:~:::f;!~uc~:I::i~:v:;::h~:r~r:e::r~~~~rand
clay to provide crosion and moisture control In
addi tion to containing the landft 11 contents.
Hay require preloadlng landfill to control
settlement problems.
VERTICAL BARRIERS
Use of slurry walls, grout curtains,
or vibrating beam methods to prevent
contaminant migration.
sheetpllea
horizontal
IIORIZONTAL BARRIERS
Use of block displacement or Injection groutfng
to prevent downward mlaratlon of contaminants
Illto saturated zone.
SOLIDIfiCATION/STABILIZATION
In ectlon Crout In. Stabilization of
Contalll nate an 111 contents by fnJecting
Into the ground through well polnu.
grout
C-ementiltlon. Contaminated fl1l excavated, mixed
wlth,cement or lime, water, and silicious
lIIaterlill to physically stabl1he the waste and
replace onalte or dispose of at a HCRA landfill.
EXCAVA1'£
Mechanical Excavation. Employ construction
equipment such as a 6ac~loe, dragllne crane, or
scraper and front end loader, to dig up
contaminated landfill contents.
Retained
for
Further
Analysis
Yes
No
No
No
No
No
Yes
Applicability Screening Comments
Potentially feasible.
Very limited application because landfill
waste mass fa located almost entire ly above the
water table. Vertical barriers may possibly be
used to block downgradlent contalliinant
migration In the lower shale and lIamden Dlember.
Vertical barrier would Cause groundwater
mounding to fill without groundwater/leachate
collection ay.tem.
Not applicable because of dffffculty In
determining the Integrfty of the barrIer.
Difficult to determine fntegrfty of barrier.
Not feasIble for landfill contents because
large amount of organic wastes not amenilble to
ce~entatlon process.
Not practical with heterogenous waste type.
Potentially feasible. Hay require lhllted
dewatering of the lower fraction of landf 11 I
waste mass below the water table.
-------
(~neral Response
Action
Disposal
.
Treatment
Table ]-2 (Page] of 6)
Remedial Technology and Process Option
ONSITE DISPOSAL
RCRA Type landfill. Perm.nent storage facility
onalte. double lined with clay and a synthetic
membrane liner and containing a leachate
collection/detection system.
Vault. Dlspoeal of landfill content. In a
concrete vault above grade onsite.
OFFSITE DISPOSAL
RCRA Landfill. Transport excavated landfill
contents to a RCRA approved landfill. Hay
require dewatering or solidification prior to
transport.
TSCA Landfill. Transport excavated landfill
contents to a TSCA approved landfill.
BIOLOGICAL TREATMENT
Aerobic Processes. Landfill contenta placed In a
controlled environment such as a compost pile
with the addition of air to aid microbial
degradation of organics.
Anaerobic Processea. Landfill contents placed
In a controlled and enclosed environment such as
a digester. to allow microbial degradation In the
absence oC oxygen. '
I.andfar-mlng. Landfill contents spread over land
In a licensed landfarm. Biological degradat Ion
with mlcro-organhma In aerated and nutrient rich
aol1s.
PIIYSICAL TREATMENT
Adsorption. Hlx adsorbent material with land-
fill contents or sediment to concentrate or
Inunoblltze contamlnanta.
Aeration. Inject air Into landfill contents to
drive off volstlle and semlvolatlle compounds.
Retained
for
Funher
Analysts
Yea
Yes
Yes
Yea
No
No
No
No
No
Applicability Screening Commente
Potentially feasible.
Potentially feasible.
Potentially feasible.
Possibly needed. TSCA permitted fscility
re,ulred for PCB contaminated waste (>50
109 kg). Waste mass not analyzed yet' Arochlora
were possibly disposed.
','
Inappropriate for landfill waste .Ix.
waste handling would be iQfeaslble.
Physical
Inappropriate for landfill waste mix.
waste ~andllng would be Infeasible.
Physical
Inorganic compounds may be toxic to vegetation.
Not applicable to wide range of organic con-
taminants; and completely Inappropriate for
nondegradable wastes euch ae metal refuse and
plaatlcs.
Not appropriate for all contanllnants. Not
applicable to waste mix at the site. Does
not chemically llIIIIIOblltze contaminants.
Not applicable to chemical mix found onslte.
-------
General Respon~e
Action
.
"
Table ]-2 (Page 4 of 6)
Remedial Technology and Process Option
QIDUCAI. TRUTHENT
Chcmical Degradat ion. Add oxidizing, reducing,
or polymer agentll to result in the breakdown of
contaminants. .
Neutralization. Introduce sublltsnces into the
waste to reduce acid or base ions.
Dechlorination. Chemical reagents (usually
sodium) used to strip chlorine atoms from
chlorinated hydrocarbons.
Solvent Extraction. Solvent is introduced into a
cont.ctor where it mixes with so11 and elutriate
INCINERATIOO OR I1It:RHAL DESTRUCTION
Wet Air Oxidation. Oxidation of wastes in a
reactor under high temperature and pressure. ,
Rotary Kiln. Combustion of aolids in a
horizontally rotatinB cylinder designed for
uniform heat transfer.
Electric Reactor. Landfill contents fed into a
6igh temperature electric reactor which usea
radiant heat and pyrolysis to destroy
contaminanta.
Multiple lIearth. Combustion of waates moving
slowly through vertically .tacked hearths.
Fluidi~ed Bed. Landfill COntents added to hot
agitated bed of aand where heat transfer and
combustion occur.
Retained
for
}o'urther
Analysis
No
No
Yes
No
Yes
No
No
No
No
Applicability Sc reening COIIIUIents
Inapplicable to both inorganic and organic
cont8lllinants found at the aite.
Not applicable to waste type or contaminants
at the site.
Not applicable for inorganic contaminanta or
most of the'organic cont8lllinanta found
onsite.
Hay add additional contamination through sol-
vent addition. Also, waste handling and volume
of waste at the site may render this opt'on
impractical.
Not appropriate.
and sludges.
Potentially feasible. Poss'bly practical
thermal destruction technique for landfill
waste mass because of relatively less
stringent size reduction con~traint8. Several
c088ercial unita are' availabie.
Limited to liquid wastes
Not appropriate thermal destruction technique
for dissimilar waste and debria because of .
relatively Ught she reduction constraints.
Potentially feasible. (Similar screening
opiniona as Rotary Kiln above.)
Not appropriate thermal destruction technique
for mixed landfill waste because of relatively
stringent size reduction constraints. .
-------
General Response
Action
Treatment (Cont'd)
In Situ Treatment
.
In Situ Treatment
Tallie j .! (Page 5 of 6)
Remedial Technology and Process Option
Holten Salt Reactor. landfill
furnace with a molten aalt bed
catalyst snd diaperslng medium
wastes by oxidation. .
Plasma Arc. Destruction of contalllinants using
high energy feee electrons for molecular fracture.
contents fed Into
acting as a
for destroying
BIOLOGICAL TREATMENT
Bloreclamation. "andUll contents seeded with
microorganisms native to the site, nutrients, and
oxygen to enhance biological degradation.
Bioharvestina. Use of plant and snlalal apeclea
to accumulate contaminants In their tIaauesj
species are harvested and disposed of.
Air/Oxygen Inlectlon. Introduction of air to
enchance aero Ic biological activity. .
PHYSICAL TREATMENT
Soil Aeration. Introduction of air to transfer
volatile and semlvolatlle organic compounds from
soil to air.
Adsorption. Landfill contents mixed with
adsorbent material which will concentrate or
Immobilize contaminant..
Soil-Vapor Extraction. Removal of volatile
organic compounds from the unsaturated soil zone
by application of a vacuum on a ayatem of wells.
Retained
for
Further
Analysts
No
No
No
No
No
No
No
No
Applicability Screening Comments
Laboratory stale of development. No comner-
clal unit available. Solids must be reduced
to small size be Core Ced to reactor.
No commercial units available.
liquids not bulk solids.
Appilcallie to
Not. prsctlcal method with the waste volume
and lib at the site. Hay be effective for
some base neutrals, but Inorganlcs m~y be
toxic or inhibl.tory to orsanism.. .
Not a practical method with the waste volume
and lIIix at the site. Hay be effective for SOllIe
base neutrals, but Inorganics may be toxic
to organhms.
Not a practical method with the waste volume
and IIIlx at the site. Hay be effective for some
base neutral a , but Inorganlc9 may be toxic
to 8lcroorganlBIIIB. .
Not. practical method with the wast. volume
snd IIIlx at the .Ite. Not applicable to chem-
Icala found onalte.
Not a practical method with the waste volume
and mix at the site.
Not a practical lIIethod with the waste volume
and mix at the site. Not applicable to con-
taminants at the site (baae/neutral organic
compounds and metala).
-------
: I
,: I
Table )-2 (Page 6 of 6)
~ne~al Response
Action
Remedlill Technology and Procesa Option
Vitrification. Contaminated landfill contenta
ara fuaed ioto a gleesy stall Ie Dlatrix by heatina
them io' place with an electric current.
In Situ Treatmcnt (Cont'd)
.
ClIEHICAL TREA'lHENT
Chemical Degradation. Add oxidizing, reducing or
po1ymer agent to result in the breakdown of
contUlinanta.
Solvent Extraction. Application of solvent
either via surface flooding or Injection and
collection of elutriate at extraction wella
followed by treatment.
I~otolysis. Photodegradation of landfill
contents contUllnanU via liolar eneray and the
application of polar solvents.
CU147/9
Retained
for
Further
Analysts
No
No
No
No
Applicability Screening Comments
Not demonstrated for heterogeneous landfill
material containing large amounts of conductive
material. Il1gh probability of causing
uncontrolh:1J cOlllbulition because of h1gh-lrru
waste masses.
Inapplicable to both inorganic and organic
types of wastes onsite. Added chemical Dlay
pOlie a threat of additional groundwater
contamination.
Hay be effective for inorganic8j however,
site conditions inhibit flushing capabili-
ties. Solvent may become a groundwater
contaminant.
Shallow penetration depth not applicable to
deep landfill. Only applicable for some
organic compounda.
-------
.Ceneral Response
Action
I~achate/Groundwater
Collection
..
Leachate/Groundwater
On~ite Treatment
. Table ]-] (Page 1 of 3)
APPLICABLE TECIINOLOGIES AND PROCESS OI''1'IONS FOR TilE COSIIOCTON LANDF1LL/GROUNDWATEH. AND CAS
Remedial Technology and Process Option
WEUS
Use of numerous regularly spaced wells to pre~ent
horizontal migration of leachate/groundwater fro.
the bottom of the lal1df1l1 at the Middle Kittan-
ning clay.
DRAINS
Uae of . contlnuoua trench
fOnD a preferred flow path
leachate/groundwater.
filled with gravel to
for intercepted
BIOLOGICAL TREATMENT
Aerobic. Leachate/groundwater mixed with a
concentrated population of microorganisms and
oxygen to promote biological decomposition.
Anaerobic. Leachate/groundwater mixed with a
concentrated population of anaerobic
microorganisms in the absence of oxygen to
promote biological degradation.
PIIYSICAL/CIIEMICAL
precisitation. Alteration of chemical equilibria
to re uce solubility of target constituents and
remove by precipitation from solution.
StrillPinf' Mixing of liquid with air or steam to
drive vo atile constituents into vapor phase for
removal.
Adsorption. Passing liquid over solid media to
allow constituenta to sorb onto the active sites
of the aoUd media for remova 1.
Oxidation/Reduction. Chemical breakdown of
organic compounds or valance change of inorganic
constituents to promote destruction or removal.
Membrane se~aratlon. Physical removal by
diffusion t rough a semlperulealJle membrane.
Retained
for
Funher
Analysis
No
Yes
Yes
No
Yea
No
Yea
No
No
Applicability Screening Comments
Die Middle Kittannln, clay and underlying ahale
are low-yield unlta with lome degree of
fracture flow expected. Wella are not prac.
tical for interception in these materials.
Media drain II practical and effective In the
fractured clay and shale expected at the toe of
the landfill waste mass.
Hay be applicable to both typical landfill
pollutants and some IISL organic compounds.
Anaerobic treatment 18 Impractical for dilute
low-temperature liquidti treatment.
Potentially feaaible.
Stripping Is not applicable to f)rganic
constituents observed.
Potentially feaaible
Not demonstrated for the contaminants
identified in leachate/groundwater.
Not practical for dilute solutions as expected
In the landfill leachate/groundwater.
-------
, .
General Retiponae
Action
Leachato/Croundwater
Onsite (Continued)
.
leltchate/Croundwater
Ufhite Treatment
leachate/Croundwater
Discharge
Cas Collection
)able 3-3 (Page 2 of 3)
Remedial Technology an~ Process OptIon
Jon Exchan~. Physical removal of ionic
constituenta by pauing Hqui~ over media which
exchanges innocuous ions for target ions.
Evaporation. Separation of
constituents by transfer of
leaving target constituents
fOI"lll.
water from
water to vapor phase.
ill a concentrated
Photo:y.i.. Chemical degradation of organic
const tuenu by light energy. commonly applied
with ultraviolet light.
Filtration. Physical rellOval of suspended
particulates by pasaage of liquid through
granular media that entraps particulates.
1'00fW
Use of the publically.owned wastewater treatment
works (POTW) to remove and manage the
constituents in leachate and Hroundwater.
RCRA FACILITY
Use of a HCRA-permitted
manage the conHtituents
groundwater.
facility to rellOve and
in leachate and
SURFACE OUTFALL
Discharge of properly treated leachate/
groundwater to receiving stream at the site.
DEEP WELL INJECTION
Discharge of leachate/groundwater to a deep
(possibly aaline) bedrock aquifer for disposal.
VERTICAl. WELLS
. Uae of vertical wells inatalled into the waste
mass or the perimeter in granular backfilled
media to extract vapor by negative pressure
through a manifold collection system and blower.
Retained
for
.'urther
Analyais
Yes
Yea
No
No
Yea
Yea
Yea
Yea
Yea
Applicability Screening Connents
l'otentially feasible
Potentially feasible.
Not demonstrated for the constituents observed
ill leachate/groundwater.
Suapended solids are not a problem.
not applicable.
Filtration
Potentially feasible
Potentially feasible
Potentially feasible
l'otentially feasible
Potentially feasible
-------
Ceneral Response
Ac tion
. Gas Co Ilec t ion
(Continued)
Gas Treatment
.
GLTl47/52
Table ]-J (Page J of ])
Remedia I Technology and Proceas Option
IIORIZONTAL COLLECTOMS
U.e of horizontal perforated pipe. installed
immediately below an impervious cap to extrsct
vapor by negstive prcssure through a manifold
collection system and blower.
TlIERHAL TREATHEHT
Uae of high temperature and retention time to
chemically decompose organic constituents to less
harmful constituents.
ADSORPTION
Passage of gas through a porous aolid media or
liquid media to sorb conatltuents onto active
sites of the eolid media.
-.t
1.
Retained
for
Further
Andys"
Yes
Yes
Yea
Applicability Screening Comments
Potentially feasible
Potentially feasible.
Potentially feaaible
"
c
-------
Law, Regulation,
or Standard
FEDERAL
Resource Conservation and
Recovery Act (RCRA)
.
RCRA Standards for Owners and
Operators of Hazardous
Waste Treatment, Storage,
and Disposal Facilities
Standards Applicable to
Transporters of lIazardous
Waste
.
EPA Administered Permit
Programs: The Hazardous
Waste Permit Program
GLTI47/44-1
Table (Page 1 of 8)
COMPLIANCE WITH APPLIC,,_..£ OR RELEVANT AND APPROPRIATE
LAWS, REGULATIONS, AND STANDARDS
Sourco of Regulation
RCRA Subtitle C,
40 CFR 260, et seq.
RCRA Section 3004,
40 CFR 264 and 265
RCRA Section 3003,
40 CFR 262 and 263,
49 CFR 170 to 179
RCRA Section 3005,
40 CFR 270, 124
Applicability or Relevance
and Appropriateness
RCRA regulate. the generation,
transport, storage, treatment,
and disposal of hazardous
waste. CERCLA specifically
requires Cin Section I04(c)
(3) CD» that hazardous sub-
stances generated from
remedial actions be disposed
of at facilities in
compliance with Subtitle C of
RCRA.
Regulates the construction,
design, monitoring, operation,
and closure of hazacdous waste
facilities.
Eetablishes the responsibil-
ity of transporters of haz-
ardous waste in the handling,
transportation, and manage-
ment of the waste. Requires
a manifest, recordkeeping,
and immediate action in the
event of a discharge of .
hazardou8 waste.
Covers permitting, applica-
tion, monitoring, and report-
ing requirements for hazard-
ous waste management
facUitie8.
Alternative
I
,
!
Affected
None. No haaardous waste
would be removed from the
site.
AA-4 and AA-5. The cap-
ping systems with gas and
leachate collection would
comply with the regula-
tions for closure of an
existing facility.
None. No hazardous sub-
stances would be tran-
sported from the site.
AA-2 through AA-S. All
action alternatives would
include monitoring &uffi-
cicnt to meet RCRA
requirement..
-------
Law, Regulation,
or Standard
Hazardous and Solid Waste
Amendments C/lSWAt of 1984
(1984 amcndJocnts to HCRA8
.
Toxic Substances Control Act
(TSCA8
Statement of Procedures on
Flood Plain Management and
Wetland Protection
Table 4-2 (Page 2 of 8t
Source of Regulation
PL 98-616, Federal Law
~1113101, 40 CRF 264
40 CFR Part 161
Appendix A to 40 CFR 6,
Executive Order 11988,
and 11 990
Applicability or Relevance
and Appropriateness
The currently applied form of
the -Land Disposal Dan-
(effective May 8, 1985t pro-
hibits the direct placement
of any bulk or noncontainer-
ized liquid hazardous waste
in landfills. .These rules
will also restrict the land-
filling of most RCRA-listed
wastes by 1991 unless the
U.S. EPA promulgates appli-
cable treatment standards for
these wAstes (40 CrR
264. 3148.
Applies to the disposal of
liquid waste containing PCB
concentrations at or greater
than 50 ppm and PCB's that
have migrated from the origi-
nal source of contamination.
I'CB concentrat ions greater
than 500 ppm must be incin-
erated in an incinerator
that complies with 40 crR
161.10. PCB's less than
500 ppm and greater than
50 ppm may be disposed. of in
a landfill that complies with
40 CFR 161.15.
Requires federal agencies to
avoid wherever possible
adversely affecting flood
plains or wetlands and to
evaluilte potential effects of
planned actions in these
designated areas.
Alternative Affected
None. Provisions of "SWA
do not apply to onsite
landfill closure and
postclosure monitoring.
Waste disposal records
indicate that PCD's may
have been disposed of at
site. RI data did not
show PCB releases.
..
None. Site is not in a
wetlAnd or floodplain.
-------
Law, Regulation,
or Standard
Safe Drinking Water Act
H~ximum Conl~minant Limits
(HCL's)
National Environmental
Policy Act (NEPAt
.
. Intergovernmental Review of
t'ederal Program
National Pollutant Discharge
ELimination System (NPDESt
Permit
Pretrcatment Regulations
'for Existing and New
Sourccs of Pollution
Toxic Pollutant Effluent
Standards
GLT147f44-3
<;0
Table 4-2
Source of Regulation
Safe Drinking Hater
Act, 40 CFR 141
through 14 3
NEPA Section 102(2)(c)
Executive Order 12372
and 40 CFR.29.
(Replaces state and
area-wide coordina-
tion process required
by OHB Circular A-95.t
CHA Section 402,
40 CFR 122, 123,
125 Subchapter N
40 CFR 40) Subchap-
ter N, FWPCA
40 CFR 129
Je 3 of 8)
Applicability or Relevance
and Appropriateness
The Interim HCL's are
enforceable standards tor
ambient drinking water
quality. Recommended,
Proposed, and Secondary HCL's
are also applicable as
advisory drinking water
standards.
CERCLA actions are exempted
from the NEPA requirements to
prepare an environmental
impact statement lEIS)
because US EPA's decisionmak-
ing processes in selecting a
remedial action alternative
are the functional equivalent
of the NEPA analysis.
Requires state and local coor-
dination and review of pro-
posed EPA-assisted projects.
The EPA Administrator i8
required to communicate with
state and local officials to
explain the project, consult
with other affected federal
agencies, and provide a com-
ment period for state review.
Regulates point source dis-.
charge of water into public
surface waters.
Regulates the quality of water
discharged into publicly
owned treatment works (paTH).
Regulates the dischargc of
the following pollutants:
aldrin/dieldrin, DOT,
endrin, toxaphene, benzidine,
and PCB's.
Alternative Affected
AA-2 through AA-S. All
alternatives are designed
to protect existing drink-
ing water sources from
contamination by means of
monitoring, lcachate col-
lection or both.
I.
I
i
I
AA-l through AA-S.
"
"
ii
'I
"
':
AA-I through AA-5.
...1
I
I,
'1
:1
"
..!
AA-4 and AA-5.
..
AA-4 and AA-5.
r
,:,
I
!
. ~
-------
Law, Regulation,
or Standard
OCCuPAtional Safety and
lIealth Act IOSUA)
STA'rE
-.
Ohio NPDES Permit
.
Ohio NPDES Permit
Ohio Water Quality
Standards
Ohio Pretreatment
Regulations
Ohio Water Pollution
Control Act
~
CL1'147/44-4
,..,., -
c
Table 4-2 Ipage 4 of 8)
Source of Requlation
29 CFR 1910
OAC 3145-31-05 IA)13)
Ohio Administrative
Code: 3145-33-01
through ]145-33-10.
Authority granted by
Ohio Water POllution
Control Act,
ORC 6111. 03.
Ohio Administrative
Code: 3145-1.
Authority granted by
Ohio Water Pollution
Control Act,
ORC 6111. 041.
Ohio Administrative
Code: 3145-3
Authority granted by
Ohio Water Pollution
"Control Act,
ORC 6111.0].
Ohio Rcvised Code:
6111.01 to 6111.08
Applicability or Relevance
and Appropriateness
Regulates working conditions
to assure safety And health
of workers.
Establishes criteria for
decision by OEPA Director on
discharge permits. Require-
ment specifies OAT to be
applied on new permits.
Regulates point Source dis-
charges to surface waters of
the State. Establishes terms
for the receipt and mainte-
nance of discharge permit.
Establishes water quality ~
crileria applicable to all
waters.
Regulates the introduction of
pollutants into POTW8s by
industrial users.
Prohibits discharge of waste
which violates water quality
standards or effluent
. limitations.
Alternativc Affected
AA-], AA-4, and AA-5.
This applies to all workers
on the site property during
excavations, construction,
and operation of
facilities.
Possibly AA-4 and AA-5.
Direct surface water
discharge of collected
leachate/groundwater may
be Possible after
treatment. .
Possibly AA-4 and AA-5.
Direct surface water
discharge of collected
leachate/groundwater may
be possible after
characteri~ation or
following treatment.
AA-2 through AA-5.
Possibly AA-4 and AA-5.
Pretreatment may be needed
to reduce concentrations
of substanccs that would
pass through, inter fore or
cause discharge of toxics
in toxic amounts from the
POTW.
AA-4 and AA-S.
I
'-'
-------
TallIe 4-2
I.aw, Regulation,
or Standard
Source of Regulation
Ohio Hatr.r Pollution
Control Act, Ohio
Revised Code: 6111.03
Ohio State Construction
Permit
Ohio General and
Miscellaneous Air
Pollution Regulations
Ohio Administrative
Code: 3745-15-04
Ohio Administrative
Code: 374~-15-07
.
Ohio Administrative
Code: 3745-15-08
Ohio Air Pollution
Control Laws
Ohio Revised Code:
3704.03
Ohio'Regulation on Air
Permits to Operate
and V~riances
Ohio Administrative
Code: 3745-35
Ohio Solid Waste
Disposal Hegulations
Ohio Administrative
Code: 3745-27-06(8)
3745-27-09 (G)
( ; J .'1' 1 4 7 I 4 4 - 5
A'le 5 of 81
Applicability or Relevance
---~nd Appropriateness
Authorizcs issuance of per-
mits for installation or modi-
fication of disposal systems.
Provides authority to require
measurement of the emission
of air contaminants from any
source.
Prohibits the release of con-
taminants into the open air
in amounts which endanger the
public.
Prohibits the use of dilution
to meet air emission require-
ments.
Authorizes adoption of
ambient air quality standard
and air emission standards,
grants authority to issue
permits for installation and
operation of any air contami-
nant source or emission con-
trol device, provides author-
ity to require monitoring of
air contaminant source,
grants Aite access, and pro-
vides authority to require.
air emission controls.
Outlines application proce-
dures and term and conditions
of operating permit for air
contaminant source, describes
procedure for obtaining
,'ar i ance.
Requires all monitoring wells
to conform to Chapter 3745-9
of the Regulations of the
Ohio EPA and s(~mi-annual
monItoring for chlorides,
COD, TOC, TDS, and methylene.
blue active substancC!s
(MUAS). Other parameters may
be added at the request ot
the OEPA Director as deemed
to be required.
Alternative Affected
AA-4 and AA-5.
AA-4 and AA-5.
AA-4 .and AA-5.
AA-4 and AA-5.
AA-4 and AA-5.
AA-4 and AA-5.
AA-2 through AA-5.
-------
I.aw, Retjulation,
or Standard
Ohio Solid and Hazardous
Wdste Disposal Law
.
\
, ,
(;1.1'147/44-6
~
Table 4-2 (Page 6 of 8)
Source of Regulation
Ohio Administrative
Code; 3745-21-06(")
Ohio Administrative
Code: 3145-21-06(1)
Ohio Administrative
Code: 3745-21-09 and
3145-21-10
Ohio Revised Code:
3134.02
Ohio Revised Code;
2134. 02 CII)
Ohio Revised Codel
J134.02(Jt
Ohio Revised Code:
3734.05CCt
Ohio Revised Code;
3134.12(0)
Ohio Revised Code;
3734.12(11)
Applicability or Relevance
and Appropriatene~s
Describes criteria to be used
to evaluate solid waste
facil iLy construction permit.
Criteria for siting solid
waste facility.
Closure requirements for
solid waste facility.
Grants rulemaking, permitting,
and enforcement authority.
Prohibits earthwork and con-
struction, on land where a
hazardous waste facility or a
solid waste facility which.
received significant amounts
of hazardous. waste was oper-
ated, without prior authori-
zation.
Grants authority to i~sue an
emergency permit to treat,
store, or dispoae of hazard-
ou~ waste at an unlicensed
location where imminent and
suustantial danger to the
public is present.
Creates lIazardou8 Waste
Fbcility Board and defines
criteria to be used for
evaluating installation and
operating permits.
Provides authority to develop
performance standardo for
hazardous waste treatment,
tilorage, and disposal
permits.
Grants authority to prohibit
disposal of specific hazard-
ous waste in state.
"
Alternative Affected
AA-3, AA-4, and AA-5.
None. The site already is
a solid waste facility.
~-3, AA-4, and AA-5.
AA-2 through AA-5.
AA-] through AA-5.
None.
None.
AA-2 through AA-5.
None. All wastcs are
already onsite. No new
wastes would be"' 'OUlJlat to
the Bite.
~
.>
-------
Table 4-.
Law, ReC)ulation,
or Standard
Source of Regulation
Ohio Hazardous Waste
HanaC)emcnt NeC)ulations
Ohio Administrative
Code; 3745-50
Ohio Administrative
. Code: 374S-Sl
Ohio Administrative
Code; 314S-S2
.
Ohio Administrative
Code; 314S-S3
Ohio Administrative
Code; 314S-S4
Ohio Administrative
Codel 314S-S4-92
through 314S-54-94
Ohio Administrative
Code; 3145-68-10
Ohio Administrative
Codc; 3145-66
Ohio Administrative
Code; 3145-55-10
through 3745-51-5J
G/.'r141/44-7
..i>aC)e 1 of 8)
Applicability or Relevance
and Appropriateness
Provides definition of terms,
permit information and over-
view information applicable
to the hazardous waste rules.
Identifies wastes subject to
regulation as hazardous
wastes.
Establishes standards for
generators of hazardous
waste.
Establishcs standards for
transporters of hazardous
waste.
Minimum standards which
define acceptable manaC)ement
of hazardous waste. Stand-
ards include criteria for
security, inspections, per-
sonnel training, location,
communication, emergency ser-
vices, continC)ency plans,
emerC)ency procedures, ground-
water protection, corrective
action, and recordkeepinC).
Hazardous waste facility
C)roundwater protection
standards and concentration
I imi ts.
Closure and postclosure care
requirements for hazardous
waste landfills.
Closure and postclosure
requirements for a hazardous
waste facility.
Defines operating require-
.~nts for containers~ tanks,
surface impoundments, piles,
land tredtment, landfillu,
and incinerators.
Alternative Affected
AA-2 throuC)h AA-5.
AA-2 through AA-5.
None. Hazardous waste
would not be generated.
'Possibly AA-4 and AA-S
because of transport of
collected leachate/ .
groundwater.
AA-2 through AA-S.
AA-2 and AA-S.
AA-2 through AA-5.
AA-2 throuC)h A~-5.
AA-2 through AA-5.
-------
Law, Regulation,
or Standard
Ohio Permit System
Regulations
.
GLT1411H
I . i
! . ,
i (a.1'147/44-0
/'
: d
Table 4-2 Ipage 8 of 8)
Source of Re9ulation
Ohio Adminislrative
Code: 3145-31-02
Ohio Administrative
Code: 3745-31-05
.'
Applicability or Relevance
and Appropriateness
Grants authority to issue
construction permits for
installation or modification
of air contaminant sources,
wastewater treatment systems,
and solid waste disposal
facilities.
Defines criteria for evaluat-
ing installation and opera-
tion of air contaminant
sources, solid waste disposal
facilities, and water pollu-
tion sources, ~nd treatment
systems.
Alternative Affected
AA-2 through AA-5.
AA-2 through AA-5.
..
-------
Table 5-1
SUMMARY OF COMPLIANCE WiTH
FEOERAL AND STATE AHARs
Selected Rem~dlal Action
Chemical-Specific ARARe
1.
Site fencing and p08tlna
None
2. Attachment of re8trlcted Hone
use note to deed or title
.
3. Site grading None
4. Site capping with clay None
and 8011 to . permeability
le88 than the natural
base material
5. Landf1l1 ga8 collection and Air pollution nulsance8 prohibit Ion
venting OAC 3745-15-07
6". Leachate/groundwater Hone
collection and onslte
storage
7. OfCslte leachate/groundwater POTW Pretreatment regulations
treatment at the POTW OAC 3745-03-01
8. Monitoring groundwater. Hazardou8 wast. facUlty standard.
collected leachatel OAC 3745-54
groundwater and gas
GLTl47/48
Action-Specific ARARs
allo aolld wsste landfill closure
OAC" 3745-27-10; Ohio hazardous
waste landfill and post-closure
care OAC 3745-68.
Ohio hazardous waste facility
post-closure planning and care
OAC 3745-66-20 RCRA 40CFR264.116
and 4OCFR264.117.
OAC 3745-27-10; OAC 3745-68-10
OAC 3745-27-10; OAC 3745-68-10
RCRA 4OCFR264.310
OAC 3745-27-10; OAC ]745-68-10
OAC ]745-27-10; OAC 3745-68-10
Ohio POTW Pretreatment regulatlona
OAC ]745-03-01.
Solid wa8te facility monitoring
OAC 3145-27-10, Hazardou8 wsate
facility groundwater Plunltorlllg
OAC ]145-65-90.; OAC ]745-68-10;
and hazardous waste facility
8tandard8 OAC 3745-54.
location-Specific ARARs
Hone
Hone
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