United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EPAIROD/R05-89/087
March 1989
~EPA
Superfund
Record of Decision:
Bower's Landfill, OH
u.s. Environmental Protection Agency
Region III 'nlormation Resour~
Center (3PM52)
841 Chestnut Street . . ,.:j
Philadelphia. PA 191Ql .:~#l;'!.
-,.
Hazardou$ Wa$te Collection
.lnformatiQn Resour~ ..C~oter
-. 'A~3
'~Q#PA 1911)1
EPA Report Ct!nBr.Uor~
Information Resourci Center
US E~A B't@~g~Q'8 3 -
Phiiada~~B1~iJi f~ 1~1~1
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50272-101
REPORT DOCUMENTATION 11. REPORTNO. 12.
PAGE EPA/ROD/R05-89/087
3. Redplent'a Acce88lon No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Bowers Landfill, OH
First Remedial Action - Final
AuthOl'(a)
5. Report Date
03/24/89
&.
8. Perfonnlng Organization Rapt. No.
8. P8rf0nnlng Org8lnlzatlon Nanw and Add....
10. ProjectlTaa\u'WortI Unit No.
11. Contract(C) 01' Grant(G) No.
(C)
(G)
12. ~ng Organization Nanw and Addre88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report . Period Covered
Agency
800/000
14.
15. Supplementary No..
11. Ab8trac1 (Umlt: 200 worda)
The 12-acre Bowers Landfill site is in rural Pickaway County, Ohio, within the Scioto
River floodplain. Fifteen residences lie within a 0.5-mile radius of the site.
Informa4ion on the types and quantities of waste disposed of at the site is not readily
available; however, landfill operations, which started in 1958, consisted solely of
municipal refuse disposal until 1963. From 1963 to 1968, however, industrial refuse
and chemical wastes were also disposed of at the site. Operations ended in 1968. The
primary contaminants of concern affecting the soil, sediment, debris, and ground water
Ire VOCs including PCE and benzene, other organics including PAHs and PCBS, metals
including lead and chromium, and other in organics.
The selected remedial action for this site includes removal of surface vegetation and
debris such as domestic waste and drums followed by offsite disposal at a hazardous
waste landfill or solid waste landfill if wastes are determined to be nonhazardous;
erosion controls including surface regrading in areas prone to flooding and erosion:
excavation and dewatering of drainage ditch sediment followed by onsite disposal;
repla~ement of the discharge pipe; construction of a soil and clay cap with quarterly
inspections for leachate and gas formation; implementation of site access and ground
water use restrictions; and ground water monitoring. The estimated present worth cost
fnr t:hi!': ,......."".....n~.,,' ",,..t-inn i!': S4100000 ",hi,..h -. -. :>nn11"" ()IVM nf Sllf>.nnn
17. Dclc:uMnt Analp\8 L DHcrIplora
Record of Decision - Bowers Landfill, OH
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: VOCs (benzene, PC E), organics
lead), in~~anics
b. Identifler8lOpen- Tenne
(PAHS, PCBs), metals (chromium,
Co COSA TI ReIdIGroup
18. Avli'abUl1y Sl8tement
18. ~ty Cia.. (Thla Report)
None
20. Security Cia.. (Thla Page)
Nnnp
21. No. of Pagea
197
22. PrIce
.
(See ANSl-Z38.18)
See Inll/ruclionll on Relf8ff1f1
..-
272 (4-77)
(Formerly NTlS-35)
Deper1ment of Convnerce
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o
RECORD OF DECISION SUMMARY
BOWERS LANDFILL
CIRCLEYILLE, OHIO
March 24, 1989
u.s. Environmental Protection Agency
Region V
"
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6.0
7.0
8.0
9.0
SectiOI)
1.0
2.0
3.0
".0
5.0
6.1
6.2
6.3
TABLE OF CONTENTS
SITE NAME, LOCATION, AND DESCRlmON
...... ......... ............
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . . . . . . . .. 3
COMMUNITY RELATIONS HISTORY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION. . . . . . . . . . .. 5
SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
5.1
5.2
5.3
5.4
Ground Water. . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . .. 6
. Surface Water and Sediment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
So ils . . . . . . . . 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0 . . . . . . . ... J 2
Air. . . 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Indicator Chemicals. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Exposure Assessment and Risk Characterization. . . . . . . . . . . . . . . . . . . . . .
6.2.1 Ingestion of Ground Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6.2.2 Ingestion of Surface Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6.2.3 Ingestion of Aquatic Animals. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6.2.4 Ingestion of Soils. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6.2.5 Direct Contact with Surface Water by Aquatic Animals. . . . . . . . . . .
Potential Future Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . . . . . . . . . . . . . .
DESCRIPTION OF AL TERNA TIVES ..................................
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
1.9
Alternative I
Alternative 2
Alternative 3
Alternative 4
Alternative 5
Alternative 6
Alternative 7
Alternative 8
Alternative 9
. . . . . . . . . . . . . . o. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.......... ... ............. .....................
....... ... ...... ................. ..............
... ....... ... ............. .....................
. . . '.' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.... ..... ...... ......... .... ...................
...... ..... ..... ... ........ ... .................
......... .... .......... ........................
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES.......
9.1
9.2
9.3
9.4
9.5
9.6
9.7
9.8
9.9
Overall Protection of Human Health and the Enyironment .............. 37
Compliance with Applicable or Relevant and Appropriate RequirementS. . .. 38
Long- Term Effectiveness and Permanence. . . . . . . . . . . . . . . . . . . . . . . . .. 40
Reduction of Toxicity, Mobility, or Volume. . . . . . . . . . . . . . . . . . . . . . .. 41
Short- Term Effectiveness. . . . . . . . . . . . . . . . . . . . . .' . . . . . . . . . . . . . . .. 43
Implementability ............................................ 43
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 44
State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 45
Community Acceptance. . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . .. 45
lm
u
14
14
14
19
21 -
21
21
23
23
24
2S
26
26
28
29
31
32
33
34
34
,)
3S
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Section
10.0
J 1.0
THE SELECTED REMEDY
10.1
10.2
10.3
10.4
10.5
10.6
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 .
Ground- Water Monitoring. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Site Access Restrictions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Management of Surface Debris. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Erosion Control and Drainage Improvements. . . . . . . . . . . . . . . . . . . . . . . .
Natural Clay Cover Over Landfill. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Reduction of Site Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ST A TUTOR Y DETERMINA TJONS . . . .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
11.1
11.2
11.3
11.4
11.5
The Selected Remedy is Protective of Human Health and the Environment. .
The Selected Remedy Attains ARARs ........... . . . . . . . . . . . . . . . . . .
The Selected Remedy is Cost-Effecuve ............................
The Selected Remedy Utilizes Permanent Solutions and Alternate
Treatment Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
The Selected Remedy Reduces Toxicity, Mobility, or Volume of Waste
Materials as a Principal Element. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
~
46
47
48
48
48
50
51
53
53
54
54
55
55
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I112k
Table 1
Table 2
Table 3
Table 4
Table S
Table 6
Fi2ur~
Figure 1
Figure 2
Figure 3
Figure 4
Figure S
Figure 6
Figure 7
LIST OF TABLES
Detection Frequencies and Concentrations of Indicator Chemicals in
Ground Water Near Bowers landfill. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Detection Frequencies and Concentrations of Indicator Chemicals in
Surface Water Near Bowers landfill. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Detection Frequencies and Concentrations of Indicator Chemicals in
SedimentS Near Bowers landfill. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Detection Frequencies and Concentrations of Indicator Chemicals in Soils
Near Bowers landfill. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Summary of Potentially Significant Risks Identified for Bowers landfill. . . .
Summary of Water Quality Sampling Results for the City of Circleville
Department of Public Utilities, Water Supply System, 1980-1987 .........
LIST OF FIGURES
Bowers Landfill, Circleville, Ohio
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Geologic Cross-Section of the Site Area. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Locations of Wells Sampled. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Surface Water and Sediment Sampling Locations. . . . . . . . . . . . . . . . . . . . .
Soil Sampling Locations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . .
Site Alternative 4 ......................;.....................
Detail of Natural Clay Cover. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
faG
15
16
17
18
20
22
fiG
2
7
8
II
13
49
S2
I,'
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,. .
~,~
RECORD OF DECISION SUMMARY
BOWERS LANDFILL
CIRCLEVILLE, OHIO
1.0
SITE NAME, LOCA nON, AND DESCRIPTION
"
Bowers Landfill is located in rural Pickaway County, Ohio, approximately 2.5 miles north
of the City of Circleville. The site is just northwest of the intersection of Island Road and
CircleviJIe - FJorence Chapel Road, on the east side of the Scioto River Valley. The landfill lies
within the Scioto River noodplain. Its northwestern and southern-most points. abut the Scioto
River (Figure 1).
The landfill occupies about 12 acres of a 202-acre tract owned by the estate of Dr. 10hn
M. Bowers. The landfill was constructed as a berm approximately 4,000 feet long with an
average width of 125 feet and a top height of approximately 10 feet above grade. The reported
waste volume of the landfill is approximately 130,000 cubic yards. The landfill has an
established cover of vegetation, including sman trees, but miscellaneous debris is exposed where
the landfm surface has been eroded. The area east of the site is a natural topographic high with
the e'levation on Island Road about SO feet higher than the landfill. This topography has been
modified by Quarrying activities to the east and northeast of the site. The north and west sides of
the landfill are bordered by agricultural fields.
Since the landfiJIlies within the Scioto River noodplain, it is nooded regularly. The field
west of the landfill is inundated an average of 29 days per year, and parts of the landfin are
overtopped by nood waters aD average of every 2 years. Flood waters and precipitation generally
now west and south toward the Sc:ioto River. A drainage ditch lies immediately east of the
landfill. Water in this ditch nows through a pipe under the southern end of the landfill and
discharges to the Sc:ioto River. A ditch on the west side of the landfill is not well developed and
does not discharge to the river. Water in this ditch tends to pond near the southern end of the
landfill.
'"
The site area is rural, with 15 houses located within a ;-mile radius of the landfill.
Houses in this area largely depend on private wells for water supply. However, no downgradient
wells are within 1 mile of the site. The City of Circleville's water supply wells are located about
1-1/2 miles south of the site.
A more complete description of the site can be found in the Remedial Investigation
Report (dated August 22, 1988) and the Feasibility Study Report (dated February 3. 1989).
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~~
~
FlGtlHl 1
BOWERS LANDFILl.. CIRCIEVlIIL OHIO
-------.- -----
fLOW
----
SCIOTO RI\lER
E XIS TING LANDFILL
-- .- -----..
o
300
SCALE (leet)
c
"
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1.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Dr. Bowers began operating the landfill in 19S8. Little information is available on the
types and quantities of wastes disposed of at Bowers Laodfill. Much of the information was
supplied by interviews with individuals familiar with landfill operations. However, these
interviews ""'ere conducted I S to 20 years after site operations ended. Information from Ohio
EPA (OEPA) files indicates that residential type waste, collectri by private haulers in and around
Circleville, accounts for most of the material in Bowen Landfill. No industrial dumping at the
site was reported before 1963. Between 1963 and 1968, in addition to general domestic and
industrial refuse, the site received chemical wastes originating from local iodustries, including
E.I. DuPont deNemours a: Company (DuPont) and Pittsburgh Ptate Glass, Inc. (now PPG
Industries, Inc.). DuPont and PPG reported sending 6,000 and 1,700 tons of waste, respectively,
to Bowen Landfm between 1965 and 1968.
Waste disposal practices consisted largely of dumping waste directly onto the ground and
covering it with soil. However, there are some indications that the southern part of the landfill
may have been excavated for waste disposal. Waste was also burned at the site; the extent and
dates of waste burning are not known. Landfitliog at the site ended around 1968. The site was
not secured when landfilling ended, and the cover material of sand, gravel, and some topsoil was
characterized as .not sufficient. during a 1971 inspection by the Pickaway County Health
Department.
In 1980, U.s. EPA collected and analyzed surface water samples from the site area; the
results indicated that some contaminants were being released from the landfitl. U.S. EPA
subsequently required Dr. Bowen to commission an environmental study of the site. During the
study, three wells were installed to monitor ground-water quality. These and a number of
existing private wells and surface water points near the site were sampled. Volatile organic
compounds (VOC), including ethylbenzene, toluene, and xylene, were found in down gradient
monitoring wells immediately west of the site. However, no VOCs were detected in an
upgradient well east of the site.
c
In 1982, based on the tevels of organic contaminants measured in water samples from the
site, Ohio EPA (OEPA) requested that the site be ptaced on the National Priorities List (NPL) as
. Superfund site. In 1985, U.S. EPA and OEPA signed a consent order with DuPont and PPG,
tWo of the potentially responsible panies (PRP). This order outlined the scope and schedule for a
remedial investigation (RI) and feasibility study (FS) at Bowen Landfill. DuPont and PPG have
assumed responsibility for the site investigation. Dames a: Moore, under contract to the PRPs,
conducted the RI and FS.
3
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RI field activities began in July 1986 and included two phases, a first phase to
characterize contaminant levels at the site and a second phase to answer questions raised by the
fint phase. During the fint phase, 18 monitoring wells were installed at or near the landfill and
sampled twice. Ground water from four off -site residential wells was sampled once. Sediment
and surface water were sampled twice, and surficial soils were sampled once. This fint phase of
sampling was completed in May 1987. The .second phase of the RI was conducted during
February and March 1988. The major purposes of the second phase were (I) to assess ground-
water now direction in the deeper of the two aquifen that underlie the site and (2) to collect
additional ground-water and soil samples. Two additional monitoring wells were installed during
the second phase, and five wells (including the two new wells) were sampled. In addition, soil
samples were collected from 10 locations. Dames &. Moore prepared a Remedial Investigation
Report (dated August 22, 1988) describing these activities.
u
Dames &. Moore began the FS in early 1988. The FS was based on the results from the RI
and also on the results of an endangerment assessment (EA) prepared by a U.S. EPA contractol'".
Nine remedial alternatives for Bowen Landfill, including the 8no action8 alternative, were
evaluated. in the FS. Dames &. Moore prepared a Feasibility Study Report (dated F~bruary 3,
1989) to describe the development and evaluation of these alternatives.
Following completion of the RI and FS, U.S. EPA sent a special notice letter to the PRPs
on March I, 1989. This letter indicates U.S. EPA's willingness to allow the PRPs to carry out the
design and implementation of U.S. EPA's preferred remedial alternative for Bowen Landfill.
During the FS process, both U.S. EPA and OEPA reviewed the PRPs' preference for a remedial
alternative. However, for reasons outlined in this decision summary, U.S. EP A has selected a
different alternative. Technical discussions between the agencies and the PRPs, concerning the
selection of a remedial alternative, are summarized in the Administrative Record for Bowen
Landfill.
3.0
COMMUNITY RELATIONS HISTORY
\i
U .5. EP A has conducted an extensive community relations program in conjunction with
the Bowen Landfill RIfFS. Between November 7, 1985, and November 2, 1988, 12 meetings of
the Bowen Landfill Information Co"'--nittee were held in Circleville, Ohio. The Information
Committee consists of representatives from U.s. EPA, OEPA, the PRPs, local (city and county)
government, and citizens' groups. These meetings were held at regular intervals to keep the
public informed of progress during the RI/FS and to discuss upcoming eventS. During the
meetings, U.S. EPA, OEPA, and the PRPs made formal presentations to the committee on topics
4
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such as well installation and sampling methods; sampling resultS for soil. ground water. surface
water. Ind sediment; endangerment assessment resultS; applicable or relevant and appropriate
requirementS (ARARs); and remedial Iiternatives developed in the FS. Following the
presentations. U.s. EPA. OEPA. and the PRPs discussed these topics with the committee and
answered questions from committee memben.
As part of itS community relations program. U.S. EPA has maintained an information
repository at the Pickaway County District Library. 165 East Main Street. Circleville. Ohio. All
formal reports submitted by the PRPs during the Bowen Landfill RI/FS are available It this
location. The information repository also. contains reports prepared by U.S. EPA. such as the
Endangerment Assessment Report and Proposed Plan for Bowen Landfill.
On September 14. 1988. U.S. EPA held a formal public meeting to present the resultS of
both the Remedial Investigation and Endangerment Assessment ReportS. This meeting was held
at the Circleville High School Cafeteria. 380 Clark Drive. Circleville. Ohio.
Finally. U.S. EPA notified the local community, by way of the Proposed Plan. of the
preliminary selection of a remedial alternative for Bowen Landfill. To encourage public
participation in the selection of a remedial alternative, U.s. EPA scheduled a public comment
period from February 14 to March 16. 1989~ Additionally, U.S. EPA held a public meeting on
February 28. 1989. to discuss the preferred remedial alternative. other alternatives evaluated in
the FS. and any other documentS previously released to the public. A transcript of this meeting
is included as part of the Administrative Record for Bowen Landfill. U.S. EPA's responses to
commentS received during this public meeting and to written commentS received during the
public comment period are included in the Responsiveness Summary.
4.0
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
"
The selected remedy for Bowen Landfill was developed by combining aspectS of source
control. site access restrictions, drainage improvementS. and long-term monitoring. In summary.
the selected remedy will include removing surface debris and vegetation from the landfill,
installing I 4-foot-thick clay and soil cap on the landfill top Ind side slopes, instituting erosion
control Ind drainage improvementS, fencing the site perimeter and restricting site use. and
conducting long-term ground-water monitoring. The components of the selected remedy are
described in greater detail in Section 10.0.
s
-------
The principal threats that the landfill poses are exposure to ground water immediately
downgradient of the site and exposure to contaminated soils on or near the landfill. The selected
remedy will address these threats by capping contaminated soils. limiting access to the landfill
area, and restricting future ground-water use between the landfill and the Sc:ioto River. Because
wastes will remain on-site, the selected remedy will provide for long-term monitoring and
corrective action measures should monitoring indicate increased contamination or threats. Also,
as required by Section I 21(c) of CERCLA. the site will be reevaluated each S years to determine
whether the selected remedy is effective.
v
5.0
SITE CHARACTERISTICS
The remedial investigation (RI). consisting of on-site scientific studies and laboratory
analyses to determine the nature and extent of contamination at the site, has been completed.
The first phase investigation took place from July 1986 to May 1987. A second phase
investigation was conducted in February and March 1988. During the RI, samples were taken of
ground water, surface water, sediment, and soil. The results of the RI are summarized below.
5.1
Crouad Water
The Bowers Landfill site is underlain by 40 to 100 feet of glacial deposits, which overlie
shale bedrock. These glacial deposits are part of an extensive aquifer system that underlies the
Sc:ioto River noodplain. In the site area, glacial deposits thicken to the south and west of the
site, and are thinnest at the northeast portion of the landfill. The glacial deposits include two
water-bearing zones -- (J) a brown sand and aravel deposit that lies approximately 10 feet below
the land surface and (2) a aray sand deposit with lesser amounts of aravel that lies just above the
bedrock. These two zones are considered the upper and lower aquifers over most of the site and
are separated by a low-permeability silt-clay deposit. However, the two aquifers may be
hydraulically connected at some site locations. The bedrock below the alacial depositS is
considered an aquiclude and is not used locally for water supply. Figure 2 illustrates an east-to-
west aeologic-cross section of the site area.
\)
Dames ad Moore installed 20 lround-water monitorinl wells at the site. These included
10 shallow wells,S intermediate wells, and 5 deep wells (Figure 3). Shallow wells were screened
It the water table near the top of the upper aquifer. Intermediate wells were screened within the
lower portion of the upper aquifer. Deep wells were screened within the lower aquifer. A
comparison of ground-water levels for each series of wells (shallow, intermediate, and deep)
indicated that ground water near the site is moving west or southwest.
6
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....,
:ooloo
SCAI t IN rrr r
VERTICAL [XAGGf IfA nOli ~ 5X
GEOLOGIC
FIGURE 2
-..----. -~
Cf~OSS-SECTION OF
AREA
TI IE
SITE
BOWlRS tAnOfll.1. -- CIRCI.EVlIJE. 01110
SOUtHEAST
720
CIRCLEVILLE
ESKER
~
......
700 -
LANDFILL
J 680-
1/1
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~
~
--=-
-
z
o
J=
-c:
>
~
-., .., .
-, ..., ..., -...
. ..................... ...
. . . - . . . . . . - . ..
600 -
580 -
560-
540 -
LEGEND
~
10
~
1 aORING/...ONI TORING
MU LOCA nON
~
,~ ~S i
SlL r AND etA Y
CD
~
CLAY
SAND
00
SAND AND
GRA V£L
CRA \'£L
SHALE
'of
t,
/lOk fJ nV[ ~ I
':'11
'1111
660
,
1/1
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- 660 .:
t'
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6-10 .....
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o
6:!0 J=
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600 ~'J
1.1
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-------
~~
FIGURE J. - tOCA TIONS OF Wl] 15 SAMPLED
---
~- ---
-". .- _. ------.-.~
FLOW
~ ---'
------
.&.~-+:-8B
"tJ-8A
SCIOTO RIVER
~---- .------
011
-+-W-11
Woo 9 +.
".
-
LEgEUQ;..
-+ r-4A
',-W-4
(2----1
./;~~~~'
~/..'~
-+-
.
o
[XISTING lAtlOflll.
MONITO~ING Wlt t
RfSIDENnAl WHl
JOO
~
. - -- - - 'to
SCALE ('..1)
,.
-------
Ground...water samples were collected from 18 monitoring wells in February 1987 and
May 1987 (Figure 3). Samples were also collected from four residential wells in February 1987.
Two additional monitoring wells were installed in February 1988. These wells and three of the
original II wells were sampled in March 1988. All samples were analyzed for VOCs, semiyolatile
organic compounds (SVOC), pesticides, polychlorinated biphenyls (PCB), metals, and cyanide.
Samples collected in February and May 1987 were also analyzed for dioxin.
VOCs including acetone, methylene chloride, tetrachloroethene, and benzene were
detected at low concentrations in some ground. water samples taken from monitoring wells at or
near the site. In all, 9 of the 20 monitoring wells contained VOCs in at least one sample. Most of
these positive results were due to acetone and methylene chloride, common laboratory
contaminants. Benzene and tetrachloroethene were found in one well each. Benzene was found
in well P-6B, downgradient of the landfill, in two of three sampling rounds. The highest
concentration detected was 6 ~g/L, slightly above the U.S. EPA drinking water standard of S
~g/L. Tetrachloroethene was found in upgradient well W-]2 both times this well was sampled.
The maximum concentration detected was 5.3 ~g/L.
Bis(2-ethylhexyl)phthalate, a SVOC, was detected in several ground-water samples.
Three other SVOCs, di-n-butyl phthalate, 2-methylnaphthalene, and n-nitrosodiphenylamine,
were found in one sample each. All of these chemicals except one (bis(2-ethylhexyl)phthalate at
21 ~g/L in well P-7A) wet:e identified at levels below U.s. EPA-specified detection limits. No
SVOCs were detected in residential well samples.
A number of metals were also detected in ground-water monitoring and residential wells.
All levels except those for barium were below U.S. EPA drinking water standards. Barium was
detected above drinking water standards in all three samples collected from well P-SB. This well
is screened in the lower aquifer near the south end of the site. Since barium was detected in all
ground-water samples, including samples from residential wells, some portion of the barium
found in well P-SB may be due to natura] sources.
"
Residential wells do not appear to be affected by releases from the site. Methylene
chloride, a common laboratory contaminant, was the only organic compound found in residential
wells, and no metals were detected above drinking water standards. In addition, sampling results
(rom the Circleville municipal well field, located] -1/2 miles south of the landfill, show that the
well field has not been affected by Bowen Landfill. Ground-water contamination resulting from
the landfill appears to be confined to the area between the landfill and the Scioto RiYer. The
Scioto River is the likely discharge point of these contaminated ground waten. Thus, the impact
of contaminated ground water appean limited.
9
-------
5.2
Surrace Water aad 5.dlmeat
Surface water and sediment samples were collected from 12 locations in the Scioto River
and nearby surface water bodies. These samples were analyzed for VOCs. SVOCs. pesticides.
PCBs. metals, cyanide, and dioxin. Samples were collected from all locations shown on Figure 4
during two sampling eventS.
Methylene chloride (5 samples). tetrachloroethene (3 samples). and 1,2-dichlor6ethane (2
samples) were found at low levels (up to 5.7 ",g/L) in the river downstream of the landfill or in
drainage ditches near the landfill. However. methylene chloride and tetrachloroethene were
found at similar concentrations in upstream background samples. Aroclor-1260. a PCB. was
found in two surface water samples collected from the Scioto River. one upstream and one
downstream. Several metals were also detected in surface water samples. However. many of
these metals occur naturally. Aluminum, barium, chromium. and mercury were found above
upstream background concentrations in at least one sample each.
Several SVOCs were detected in sediment samples collected from the Scioto River and
drainage ditches near the site. These include polynuclear aromatic hydrocarbons (PAH).
phthalate compounds, 4-methylphenol, chlordane. and PCBs. PAHs and phthalates were also
found at similar concentrations in upstream .background samples. PCBs were detected at three
locations in drainage ditches adjacent to the landfill (SE-27, SE-28, and SE-29) and appear to
have originated from the site. The maximum concentration detected was 2,300 ~g/kg.
Chlordane, a pesticide, was found at concentrations ranging from J 20 to 200 ~g/kg in three
locations. All three locations (SE-20. SE-21, and SE-22) were in or adjacent to the Scioto River.
near the southern end of the landfill. While chlordane may be associated with landfilling, the
occurrence of this pesticide could also be due to agricultural activities in the field west of the
landfill. The occurrence of 4-methylphenol appean to be concentrated near the southern end of
the landfiJJ and the drainage ditch to the east. This SVOC was found in seven sampling locations,
with a maximum concentration of 8.600 ",g/kg at SE-22.
SeveriLI metals were found above background levels in sediment samples. These include
aluminum, barium, cadmium, chromium. lead, mercury, vanadium, and zinc. However, these
metals were found at elevated levels in only a few (no more than four) sampling locations at
various locations OD the landfill.
10
-------
FIGURE 4. - SURF ACE V'lA TEH AND ~LDIM[N r SAMPLING LOCA HOr'l~
5W-2J
SE-2J
.
,
"
----------- . .--.- ---- - ..
---
---
SCIOTO RIVER
~-..--'-' .. --'-.
-'-"" -. - . -----
~ F~O'IJ - -_..-._--_..----~
--- -'SW--19 .-. -----.
---------- 5E--19
( Approximately
400 r eet Upstroorn)
"-.. "'- .
fr/-;,/.- S\V. -Hi
//J 5£-18
.,/~
.-/
-
-
5W-27
5E-27
-
LEG~~Q~.
. l~;;~.?
-.Ld
[XISnNG lAUOFII.l
.
SAMPLING tOCA notl
o
300
-
-- - -.,.
SCAtE
-------
5.3
Soils
/
Surface soil samples were collected from 22 locations in September 1986. These samples
were analyzed for YOCs, SYOCs, pesticides, PCBs, metals, cyanide, and dioxin. Additional
soilsamples were collected in March 1988 as part of the second phase of the RI. Ten locations
were sampled, including seven new locations. This second round of soil samples was analyzed
only for arsenic and lead. In all, 29 locations were sampled, including 7 off -site locations.
Figure 5 shows the soil sampling locations.
Three pesticides (B-BHC, dieldrin, and chlordane) were found in soil samples. The
pesticides were found at two locations in the field west of the landfm (SO-7 and SO-II), one
location at the western end of the landfm (SO-35), and one location south of the landfill (SO-44).
The maximum concentration detected was 210 ~g/kg of chlordane at locations SO-35 and SO-44.
The presence of these pesticides in the field west of. the landfm could be due to 'past agricultural
activities.
Three PCB compounds (Aroclors 1242. 1248, and 1254) were detected in soil samples at
nine locations. Eight of these locations are on or directly adjacent to the landfill, with six of the
locations clustered near the northeast corner .of the landfill. Thus, the presence of PCBs appears
to be related to landfilling activities. The highest concentration, 3,600 ~g/kg, was found at
location SO-34.
In the first round of soil samples, several metals were found near the landfill at
concentrations higher than off-site background levels. These include aluminum, arsenic, cobalt,
lead, vanadium, and zinc. A second round of soil samples was collected and analyzed for arsenic
and lead to determine whether these metals might be related to landfilling activities. The
combined resultS from the two rounds indicated that soil arsenic levels were similar for'samples
collected on the landfill, in the agricultural fields directly west and north of the landfill, and
(rom locations west o( the Seioto River. However, the results for lead indicated that soil samples
collected from the landfill had slightly higher concentrations. The maximum lead concentration,
179 mg/kg, wu (ound at location SO-35.
5."
Air
No quantitative air samples were collected during the RI at Bowers Landfill. Thus, the
extent of air contamination at the site is not known. However, air monitoring was conducted
during the RI for VOCs, radiation, and combustible gases. On-site concentrations were not
elevated above background levels.
12
-------
c
fiGURE 5. - SOIL SAMPLING lOCA llONS
(APPh .IA TEl'"
1200 fEU
UPSlH[At.I)
50- 46 .
SO..4S;>--
'-'
~~
SO-52
.
5CIOTO RIVER
~
-
.~
,.
\..
. 50-42
50-07
.
50--10
.
50-49
.
::..0 SJ.-JI
u;gENQ~
F~~ HI5T1NG lANDfill
.
SAMPJ.lNG lOCATION
o
Joo
~-
-- -,a
SCAlf ('881)
-------
Bowers Landfill has a low potential for VOC emissions to air because very few VOCs
were found in surface soils, surface water, Or sediments. Other contaminants found in surface
soils, such as PCBs, PAHs, and metals, could become airborne if dust is released from the landfill
surface. However, the site is currently covered with vegetation and has very little exposed soil.
6.0
SUMMARY OF SITE RISKS
PRC Environmental Management, Inc., under contract to U.S. EPA (No. 68-01-7331),
conducted an endangerment assessment (EA) for Bowers Landfill. This section summarizes the
findings of the EA and characterizes site risks.
6.1
ladic:ator Chemicals
The EA used standard U.S. EPA procedures. as outlined in the Superfund Public Health
Evaluation Manual, to identify indicator chemicals for Bowen Landfill. The EA focused on
potential exposure to and risks from these chemicals. The indicator chemicals were generally
those contaminants that exhibited the most toxic properties, were found in several environmental
media, or were detected at the greatest frequency.
The indicator chemicals included three metals (barium. lead, and mercury); two VOCs
(benzene and tetrachloroethene); two SVOCs (4-methylphenol and PAHs); PCBs; and one
pesticide (chlordane). The EA evaluated PAHs as a class of chemicals, focusing on those PAHs
that are known or suspected carcinogens. Tables I through 4 identify the detection frequencies
and concentrations (mean and maximum) of indicator chemicals in samples collected during the
RI. Results are organized by environmental medium (ground water, surface water, sediments,
and soil).
6.2
Exposure Assessmeat IDd Risk Chlr.cterlzatiol
"
The indicator chemicals identified in various environmental media during the RI were
evaluated to determine the level of risk they pose to public health and the environment. The EA
identified 10 potential exposure scenarios for contaminants at or released from Bowers Landfill.
Potential risks for each scenario were characterized for human and animal populations that could
become exposed.
The EA concluded that potential risks existed under S of the 10 scenarios evaluated.
These exposure scenarios include ingestion of ground water; ingestion of surface water; ingestion
14
-------
.........,
~ of I
I!!1J5!D
8Irium 16/16
teed 2116
NemllY 2/16
Benzene 0/16
Tel rKfIloroclhenc 1/16
Chlordane 0/16
PCHI 0/16
4-NelbJlphcnol 0/16
\A
PAIII 0/16
Notca:
(.
TABU! I
DP.W£I10N fRP.oUr~ap.5 AND CON~NTRATIONS OP INDlC'TOR
all!MlrAI.5 IN GROUND WAll!R NI!AR BOWI!RS LANOI'IU.
,.,..... W,III
Mi-
'NIIWWJ 0-*
of J .....
~ Iul1L
M-
c.-......
hall.'
~.. Weill ~.... w.1t
Adj- AdJ-
'''''''''' PNIIWWJ 0..-* M_- '''''''''' 'NIIWWJ 0..-... .--
of of Won c-........ of of ..... c-............
I!!!!eB I!!!!!!!!I i!&l1L (qJlI 2!!!!!EI I!£!!!!!!I (!aL1L (qJU
.
17/11 17/31 1]0 2010 S/S S/S 112 113°1
8/31 1/21 1.2 69 O/S
0111 O/S
1/11 1/17 0.10 60 O/S
0111 O/S
0/11 O/S
0/31 O/S
0/11 015
0/11 015
II P.atimaled valuc; compoulld foulld al eonccnualioll below U.S. ErA ~uired delectioa limil
- Not akulaled
16/16
IllS
lIS
U
:J68
1.0
frcqucDCJ 01 delecti08 .. defi8Cd .. alb. wMft -
a . number 01 tlmea a compound wu delected
b . 10481 number 01 ..mplca
Sample raulll wIIida weft idenlifled b, lhe laboralory 81 duc 10 blank contamination 8ft noC counled in eilher a or b.
Adj_eeI fftlll'lCDCJ 01 delectiollomil8 ..mplca from wIIicll ftlull8 weft quealionable due 10 OA/OC problems; onl, 18mplca included In lliia roIumn WCft used 1o delermine
pomclric 1ftC88 and ..uimum c:oncr:nlralionl.
2
0/16
1/16
0.89
H
-------
TARU! 1
Df!11I£I10N PRBQUENl1PS AND CONCP.NTRA110NS OP INUlCo\TOR
ClIP.MICAIS IN SURfAce WAl1!R NI!AR OOWl!RS LANlWIU.
1t!5'"". tIwI- ~o ,,",. 0-...... tl:3D\1ct101
Adj..
I'\o..-y ......., 0-. ....... ......., .........., 0-.. W- ........, .....887 0-. w-..
.. I .. J ..... c-..... .. .. ..... c-.... .. .. ..... c-......
1"- IlI!!IiII RIIaUIII: bIl1L (¥8lLl ~ I!!!!!!!!I i!84L (IIaIU I!!:!!!!!!II I!!!51i!!I &!Il1L (II&lLl
Bertllm 1/1 2/1 S6 1601 9/9 9/9 S4 1601 19/19 19/19 101 11991
l.cad 1/1 0/1 4/9 O/S 4/19 I/IS U 86
Nert'llry 0/1 1/9 1/) 0.1) 0.20 1/19 lIS 0.11 027
Benzene 0/1 0/9 0/19
Telncllioroclbcne 1/1 1/1 0.14 1.11 1/9 2/9 0.59 1.11 0/19
Chlordane 0/1 0/9 0/19
reo. 1/1 1/1 0.11 u 0/9 1/19 1/19 0.5' 16
4-Nelllrtphcnol 0/1 0/9 0/19
0\
rA11a 0/1 0/9 0/19
HoIca:
1 .. 1 PAai8l8ted ftJlIC; CI08pouM _lid .. conce.l..lioa below U.5o erA required delcc:tioa limil
- Not calculaled
PftIIIUCIKJ of detect.. II deli- . ./b. Mleft! -
. . ..mber 01 IImca . C'OIIIpound W8I delected
b . loul number oIumpla
588" IaUIIi wldeb -ft! idcnlirlCd b, 1M boon lOry .. due 10 blank coalaminllion 1ft! IlOl counled ia eilllcr a or b.
Adj81ed 'ftIII-1KJ 01 delectioa omill umpla from wIIicll ",ull' -we qualionable duc 10 OA/OC problem.; only umpl" included In Illi. mlum. _we IIICd 10 delermine
pomclric mean and Ihbimum COftCCnlnlioRl.
2
,.
-------
TADI.I! 3
DP.T1!cnON fRl!l}Up.Nnp.5 AND CONCf1.HTRAll0NS OP INOICUnR ClIP.MICAI.5
IN SI!I>IMI!M'S NI!AR HOWI!RS I.ANOPlIJ.
-~-lJwI- SQoeo f& - Du-.!-- ~- DIIdoo8
...... .... A..
........, 1'........, 0..-.. ....... ........, 1''''''1''''' 0.-.. """ ~ .""'1"" 0-...
01 I .. J .... C_....... 01 at .... C_.....- 01 ... .....
C--..t ~ ~ iEIDoIL (-.1....1 I!!!I!!!!!I ~ II!I&L (uJ~1 ~ ~ i8&L
8erium 2/2 2/2 113 118 9/9 9/9 106 312 19/19 19/19 128
tead 2/2 2/2 31 J8 9/9 8/8 34 )9 19/19 15/1' 39
Mem..y 2/2 1/1 0.40 9/9 4/4 048 0.59 10/19 6/85 014
Olordane 0/2 2/9 1/9 0061 0200 1/19 1/19 0055
reo. 0/2 0/9 '/19 '/19 0.105
Benzene 0/2 0/9 0/19
TelractalorocllM:ac 0/2 0/9 0/19
4-MelllJlpbuol 0/2 2/9 1/9 0.069 1.600 1/19 1/19 0091
.....
r&b
Beruo(a )anlbraccac 2/2 1/2 0.4U 0.420 J 1/9 1/9 0.256 3.600 11/19 11/19 om
Rcnro( a)pyftne 2/2 1/1 0.4011 0.4SO J 9/9 9/9 0211 0.)70 J 11/19 11/19 om
Ikn.w(b )nllOfllnlbcne 2/2 1/2 0.900 0.910 9/9 9/9 04,. 0.150 U/19 13/19 0.U1
Orywnc 1/1 2/1 UI9 o..s~ 9/9 9/9 0.281 0.480 12/19 12/19 009S
DlbcNo(a.lI)
anlhr8CCM 2/2 2/2 0.116 0.160 J 1/9 1/9 O.OJO O.IJO J 1/19 1/19 oem
Indeno( U.J.
-------
TABU! 4
DI!J11£nON PRP~Ul!Nap.5 AND CONCfNfRA110NS OP INDICATOR OIl!MICAI.5 .
IN SOIl.5 NI!AR IJOWI!RS IANUI'IIJ.
~ lOC8I... laaI.... ~ "4-.. 10 'M I.e...nu "=.... AlaI
,- Ad, A ..
........,' ''''''''''' 0-.- ......... F........, F........., ('-hi: M-- ........, FfWIIW8Y 0-.- M_-
.. 1 .. a "" c_...... .. .. Wfta c---........ .. .. ..... ('-...-
("---- ~ R!Iei1iII: i8I&IL f8&/U.1 R!!!5!iII I!!!!!!EI WlHL f!llalt.al R!!!!!!!I 2I!!!!aI i8lUL f8aAa'
Barium 2/Z 2/Z 152 1S6 IS/IS IS/IS 189 287 7/7 7/7 121 I~
l.cad S/S 5/5 47 74 P. 21/21 21/21 18 179 II/II II/II 59 102 I!
Melt1l1Y 2/2 0/2 IS/IS IS/IS 027 00 7/7 2/2 048 Oj8
Clllonl.ne 0/Z 2/IS 2/1S OOIS 0210 1/7 1/7 0014 0110
PCBI O/Z 9/15 9/1S 0.238 UOO 1/7 1/7 0061 0240
Benzene 0/2 OIlS 0/7
Telf'8ChloroclhcDC 0/2 OIlS 0/7
4-Melhylphcnol 0/2 O/IS 0/7
08 lMlI
Beruo(. )8nlhl'8CCDC 2/Z 2/2 0.1:10 0.140 J 14/IS 14/1S 0.116 4300 6/7 6/7 00111 0210 J
Beruo(. )pJrcDC 2/2 2/2 0114 O.ISO J 12/1S I2/IS o.m 4.]00 S/7 5/7 00118 02)0 J
Benzo(b )OuorllnlhcDC 2/2 2/2 0.26$ 0.280 J 11/14 11114 0.118 8600 7/7 7/7 0204 OjlO
ChlJlCne 2/2 2/2 0.160 0.160 J 14/1S 14/15 0.169 S.200 7/7 7/7 UJ6 OZ40J
Dibcruo(..b)
anlhrac:cDC 0/2 I/IS IllS 0.026 0.96OJ 0/7
Indcno(l,2,kd)
I'Jft nc 1/2 1/2 o.on 0.110 J II/IS 11/15 0071 2600 4/7 4/7 0054 0160 J
Hole&:
J &ti_led value; COIIIpound founcl 81 ('()II('Cnlrlllioli below U.S. I!PA ~uired delcction limil
I! Conccnlrlllioa ia cali_led due 10 prclClK'C 01 inlerferencc durinllll8lyais
- Not ukulalcd
PrcqllCftCJ' 01 delcctloe iI defined - 81b. wllcre -
a . .umber oIlimu a compound W8I delecled
b . loc.1 number of umplCl
Sample lUulll wIIich were idenlirlCd b)' Ihe I.bonlory u due 10 bl.nk conl.min'lion Ire nOC rounled in eilher . or b.
2 AdjU8led rrcqueftCJ' 01 delCdion omill 18m'" rrom wIIich lUull. were qllC&lionablc due 10 QA/OC problclRI; onl)' um", included in Illi. roIumn were used 10 delermine
pomclric mean .nd millimum conccnlnlionl.
_.
-------
. .,..).
of aquatic animals; ingestion of soils; and direct contact with surface water. The first four.
scenarios apply to humans living near Bowers Landfill while the fifth scenario applies to aquatic
species living in the Scioto River near the landfill. The potential risks associated with each
scenario are summarized in Table S and discussed below.
6.%.1
IDlfstiOD or GrouDd Water
The EA identified a potential risk from drinking ground water immediately down gradient
of the landfill. The area included in this scenario is the field between the landfill and the Scioto
River. Ground water in this area contains barium (a noncarcinogen) and benzene (a carcinogen)
at concentrations above U.S. EPA Maximum Contaminant Levels (MCL) for drinking water.
However, each contaminant exceeded the standard in only one well; samples from all other wells
contained barium and benzene concentrations well below MCLs.
The EA assumed that a 70-kg adult would drink 2 liters of ground water per day over a
'O-year lifetime. Probable case doses from this exposure were calculated using average barium
and benzene concentrations in downgradient ground water (Table I). Worst case doses were
calculated from maximum concentrations. The EA then used these doses to estimate potential
risks. Noncarcinogenic risks were estimated by calculating a Hazard Index (HI), the ratio of the
exposure dose to the acceptable chronic intake for barium. This ratio was 1.04 for the maximum
barium concentnuion. indicating that the estimated dose exceeded the acceptable dose. Probable
case risks were' much lower, with the HI equal to 0.17. Carcinogenic risks for benzene were
estimated by multiplyi~g the exposure dose by the carcinogenic potency factor (CPF). For worst
case exposure conditions, this risk was 9 x 10.'; the probable case risk was I x 10-'.
Although these risks are significant. exposure is unlikely to occur. Ground water
down gradient of the site. between the landfill and the Scioto River, is not currently used as a
drinking water source. Further. this area is often nooded and is not a likely location for future
drinking water wells.
In addition to these potential future risks, the EA looked at risks to current users of
ground water neat Bowers Landfill. AU existing residential wells near the site are upgradient.
Four residential wells were sampled during the RI and showed no effects of the landfill on water
quality (Table 1). The City of Circleville water supply is also of concern. Circleville obtains its
municipal water supply from a weUfield approximately'1+ miles south of the site. However, the
RI study of the area south of the landfill was limited. The EA considered the possibility of
regional ground-water now to the south. along the Scioto River basin. To investigate this
possibility, the EA reviewed water quality sampling data submitted by the city to the Ohio
19
-------
TAn...! s
SUMMARY OP P01'P.HI1AU.Y SIGNIfiCANT RISKS IDI!l'mflP..D fOR BOWERS lANDAU.
enx.un: Roule CAINCA' Conl.min.n.. Ili.k AlKamenl Commenl.
I. Inaali08 of OIOU8d W.ler NCA Beri".. lI~rd 1..2 . UN While baed OIl lbe "'''18'''' blri"m CiIJIK'e.lralion, lbe llaurd Indu
OIIIy .1111'1" ellnedl .ally. 1bc.dON, lbe 8dualaoncardftOlCnic riak
via IbillKCn.rio iI prob.bl, ftlJ 1m.11.
CA Bcftl.Cac lnae~'" Carriaopaic riak . The IMre"'!21a1 ca~aic riaU for bc8lcnc .re willli. lbe 11,,1
9 . 10' (_I f81C), I . 10" ..nlc 01 10 10 10 (- fooclIOIc No. )).
(problble cue)
1. Inaalloe of Sttlt< '"C W.ler CA I'CB8 M.limu.. PCB CilJlK'eDI..lioa ia lbe 1bc A Woe for I'CB8 ...mea liIellme elpol"re while Ibis lKCft8rio
drain.ac dilcba (Z.6 "8/1.) eacccdl ..lImea Infrequenl incideal.1 inplion; lberefore, Ibis romplriaon
Ibe .mbieal -In qualil' (rile no.. ovcrallmllea Ille lelual riat.
(AWQC) for COMumpilon of drinklnl
-Icr. This AWOC.~OOIJ "&I~.)
COnaponcllIO. 10 caMer ruk.
). la...108 of Aqulic AlIi...... NCA MCmllJ 1bc mn.illlum IDCmllJ CilJlK'enlralion T..uc ..mplcl 1Iaw: IlOl bee. 1,'e8 10 ftri" lbe el1enl oIllIis
(0.1111/1.) ea:ada lbe AWoe bucd elpolure. 1I0000r, Iftf8I'C IIICmllJ CO¥Cnlraliona ~re below lbe
N 011 Inplioa 01 aqua. Inlm.1I A WQC .nd IIICmllJ .. found In 0111, one IlirfICC _Ier ..mplc from
o (0.146 ua/l.). Ibe snoco RMr. nUl, Ibis riIk is limiled.
4. In..... of SoiIa NCA Lad llaurd I.. . ).10 nililuard Indu .., ovcrallllllie IIIe 8d1l81 ... bcca- II UllNllea
botll lhe 1lll1i..".. Iced CIOftC'Cal..li08 .nd . wun8 f8IC IOiI -.--
..Ie. Pllnber, Iced leftll In OII.;le .11 .re below Cenlen for Di8cuc
Co8II01 (CDC) lIIidelinea for rcaidcalw 'IUI.
CA ToIIIPAI..' lnae~'" CardlMJlC'ic IUA . 1bac two riIb ...., ovcrcali...le lbe 8dual riat bccalllC Iller .re bu.cd
Z.IO . 011 lIIIamli. CIOftC'C.I..ri0n8 .nd . wonl cue 1011 Inplion "Ie. Sc.c
PC8I Inaell!Cflai CardlMJlCnic Risk . .110 PoocllOle No. J.
1.10
S. Di... o.&8ct ..... SttrflClC NCA MemllJ Mui..... 8IC1lb1J ~""Ilon Adual riat .., be _"Ipble bu.cd on 8ft... IIICmllJ conccnl..liona.
W.ler by Aqualic: Aalllllll (O.Z ullL) elReClllbc 4-4a, A Woe Punber mcmllJ -- found In OIIIy one IUrflCC -Ier "lIIpIe from lbe
lor pmcUlion of aqUllic lile SrioIo River.
(0.012 u&/l.).
NoIca:
Z
)
C~ . Clrriqcnk:
NCA. NoIMardftOlCnk:
llIc haul'll indca (III) II calal18lcd - lhe ..180 of upolure .., 10 ICftpl''r dole; .a III> I Indic.l\, . poeenli.11y IipirlC.nl ...
u.s. P.PA pida~ ~. I'~I camnOICnic riak ..nac ~ ~O.~ 10 10. . ~ puler I"'a I~' .re. CONidcred 8liplir_al8, ""lie rilb < 10" .re C'OCIlidcled ialiplir_nl.
bb belwU8 10 .nd 10 .re Wllhln lbe 18.1 ranac; lheu' Ilpllr_nee will, In acne..I, reflect IIle IpearlC facton.
C..lnll.11ona Indudecllhe IoIlowinl cardnoacnic PAil.: bcnw(8)8nthran:nc, bcnzo(.)pyrcac, belWl(b)nUOl1lnlbenc, chlJlCnc, dibcnzo(',II)enlhran:nc, .nd indeno(l,2.J-c.d)PJ1'Cne.
llIc llICIemcn181 carcinosenic rilk for lot.1 PAil. -. clku18lc.d by mullifllyin,lhe m..imulII COIICCnlralion of eaeb PAil other I"'n bcnzo(')PJ1'Cne b,. rdAliYC f1'OIency factor 10
bclUo(.)pyrcnc. llIc adj...ted COIICCnlraliona ~re then lummed .Ion, wilh Ihe ronccnlralion 01 bcn'o(')PJ1'Cne IIKIf .nd, finall" mulliplied It, Ihe carcinogenic f'Olency '.clor for
bcnw(.)pyrcnc. 1)(lIil, of Ihi, cakulAlion PRIce.. .re ducnl>ed in Ihe I!nd~nlc:nnenl AsscSlme,nl Rc:pon for Unwen I..ndfill.
4
c
-------
Department of Health over an 8-year period from 1980 to 1987. Based on this review, there is no
evidence that Bowers Landfill has affected Circleville's water supply. Table 6 summarizes the
data reviewed. .
6.2.2
lalestloa or Surrace Water
The EA identified a potential risk from ingestion of contaminated surface water. This
exposure scenario was based on accidental ingestion of surface water near Bowers Landfill.
Access to the landfill is not restricted, and exposure could occur if people waded in or fell into
drainage ditches or the Scioto River near. the landfill. The EA evaluated potential risks by
comparing maximum surface water concentrations with U.S. EPA guidelines for acute or short-
term exposure. or the indicator chemicals found in surface water, only PCBs exceeded a
guideline. The maximum PCB concentration of 2.6 ~g/L (Table 2) was higher than the long-
term ambient water quality criterion (A WQC) of 0.0 J 26 ~g/L. However, the A WQC is based on
lifetime consumption of 2 liters of PCB-contaminated water per day. Thus, the A WQC is not
directly applicable to the infrequent exposure and small amounts of water ingested under this
exposure scenario. The EA concluded that risks from ingesting contaminated surface water were
limited.
6.1.3
lalestioa of Aquatic Aalmals
The EA identified a potential risk from ingestion of aquatic animals Crom near Bowers
Landfill. This exposure scenario was based on ingestion oC fish and other aquatic species taXen
from the Scioto River. The EA compared downstream surface water concentrations (Table 2) to
A WQCs for ingestion of aquatic species. Qnly one indicator chemical, mercury, was found above
background (upstream) concentrations in the Sc:ioto River near Bower Landfill. The maximum
mercury concentration in river water (0.2 ~g/L) slightly exceeded the AWQ!:. (0.146 ~g/L); the
average mercury concentration was below the AWQ!:.. This AWQ!:. was developed by U.s. EPA
to protect persons who consume 6.S grams per day of aquatic organisms taken Crom mercury-
contaminated water. The EA characterized risJu Crom this scenario as limited Cor two reasons.
First, mercury was found in only one sample from the Sc:ioto River. Second, the mercury
concentration in this sample only slightly exceeded the A WQC.
.-
6.2.4
lalestioa of Solis
The EA identified a potential risk from ingesting contaminated soils at or near Bowers
Landfill. Access to the site is not restricted, so small children could reach the site and ingest
contaminated soil. The EA assumed that a 20-kg child would eat contaminated soil 10 days per
21
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TABU! 6
SL'MMARY OP WA1C:R QUALm' SA.\4PUNCi RESt..1.TS FOR mE ern' OP CtRC1..EV1U.E
DEPARThtE....-r OF PUBUC t.."unes. WA"reR Sl..'PPLY SYSTE.\t. 1~1987
(CO~CE:."'oTRAnONS OF 11'oI'DICATOR CHE.\41CALS IN u&IL)
LcaIDa:
11. W,
FrulWn
#1
Well
#z
wen
#3
WeU
Weill 1.
2and3
o.US:
"f7A187
06/19/16
06/19/16
06/19/16
12/05/15
663
H&I&Ic Rd.
0A/%7/83
ComllOund
Barium 160
Lead 1
Mema!)' <0.2
OIlorGane
PCB5
cJQO c3DO cJQO cJQO
ND c5 <5 <5
-------
year over a 3-year period, and that SO percent of the contaminantS in the soil would be absorbed
by the body. Probable case doses from this exposure were calculated based on ingesting 0.1
alday of soil containing average contaminant levels. Worst case doses were calculated based on
ingesting 1.0 a/day of soil containing maximum contaminant levels. The EA calculated doses
only for those indicator chemicals found at or adjacent to the landfill at concentrations higher
than background. These chemicals included barium, lead, mercury, chlordane, PCBs, and PAHs
(Table 4).
'.
The EA used the resulting doses to estimate potential risks. Noncarcinogenic risks were
estimated by calculating a Hazard Index (HI), the ratio of the exposure dose to the acceptable
chronic intake. Under worst case cODditions, the total HI was 3.41, indicating that the estimated
dose for all noncarcinogenic indicator chemicals exceeded the acceptable dose. Most of the HI
was attributable to lead (HI. 3.20). However, the highest measured lead concentration at the site
(179 mg/kg) was well below Centers for Disease Control (COC') guidelines for acceptable lead
values in residential soils. These guidelines suggest that lead values between SOO and 1,000
mg/kg are unacceptable.
Cancer risks were estimated by mUltiplying the average lifetime exposure dose by the
CPF. For worst case exposure conditions, the total cancer risk for all chemicals was 3 x 10".
Most of this risk was attributable to ingestion of PAHs (2 x 10") and PCBs (7 x 10'1), with only
a small portion due to chlordane. The probable case cancer risk was S x 10".
6.2.5
Direct Coatact wltb Surface Water by Aquatic Aalmals
The EA also identified a potential risk to aquatic species living in the Scioto River. The
fA evaluated risks from this exposure scenario by comparing river water concentrations to
A WQCs for protection of aquatic life. Only one of the indicator chemicals, mercury, exceeded
an A WQC. The maximum mercury concentration of 0.2 ~g/L (Table 2) was higher than the 4-
day (chronic) A WQC for aquatic species of 0.012 ~g/L. This comparison most likely overstates
potentiaJ risks, since mercury was found in only one sample collected from the Scioto River.
6.3
'oCntlal Future Risu
Even though contaminant concentrations measured during the RI Ire relatively low, the
landfill represents a potential threat of future contaminant releases that may endanger public
bealth, welfare, and environment. A major remedial action objective for the site is to reduce this
threat of future contaminant releases in addition to reducing current risks identified in the EA.
Several factors contribute to the potential threat of future releases.
23
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First, portions of the landfill are poorly covered. The lack of adequate cover is described
in inspection reports by the Ohio Department of Health (February 1967) and the Pickaway
County Health Department (April 1971). These inspections were conducted shonly before and
shortly after waste disposal at Bowen Landfill ended. The lack of adequate cover was confirmed
by more recent measurements made in November 1988 as part of the feasibility study. These
measurements showed that wastes lie less tlian I foot below the cover in some areas of the
landfill.
Second, although operating records for Bowen Landfill are poor, evidence exists that
hazardous substances were placed in the landfill. Responses by DuPont and PPG to a 1978 House
Subcommittee on Oversight and Investigation estimated that these companies sent approximately
6,000 and 1,700 tons of waste, respectively, to Bowen Landfill from 1965 to 1968. The wastes
contained a variety of organic and inorganic chemicals. More recent 1988 responses by DuPont
and PPG to information requested under Section 1000e) of CERCLA confirmed the disposal of
hazardous substances at landfill. However, these responses contained little additional information
on the amounts and types of wastes.
Finally, semiannual nooding of the Scioto River, usually in the spring and winter, also
contributes to the threat of contaminant releases. Based on nood stage data for the river and the
height of the landfill, portions of the landfill are overtopped by 2-year noods. The entire
landfill would be covered by a 50-year nood. Flooding, in combination with trees growing on
the landfill side slopes, presents two significant concerns. First, tree roots most likely penetrate
directly into waste materials because of the shallow cover depth. These root systems provide a
direct pathway for flood waten and precipitation to contact wastes and increase the likelihood of
future ground-water contamination. Second, as the trees on the side slopes grow larger over
time, they represent a threat to the stability of the side slopes. The combination of nood
conditions, saturated soil, and high winds could cause larger trees to topple over, removing
portions of the side slopes and exposing the wastes underneath.
7.0
DOCUMENT A nON OF SIGNlflCANT CHANGES
This Record of Decision selects Alternative 4, as described in the Proposed Plan, as the
preferred remedial alternative for Bowen Landfill. U.s. EPA has reviewed and responded to all
comments received during the public comment period. Comments concerned Alternative 4 and .
other remedial alternatives. U.S. EPA has not made any significant changes to Alternative 4
based on public comments.
24
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J: °t
~t!.~
Alternative 4 includes the following components: long-term ground-water monitoring;
site restrictions and a perimeter fence to limit site access and use; removal of debris and
vegetation from the landfill surface; placement of a low-permeability clay cap (consisting of a
clay layer. topsoil layer. and vegetation) over the entire landfill surface; drainage improvements
to convey rainfall and nood waters away from the landfill; and erosion and nood control
measures on areas of the landfill subject to .damage from nood waters.
8.0
DESCRIPTION OF ALTERNATIVES
In response to the findings of the EA, the FS identified three potential risks that should
be addressed by remedial response actions at Bowen Landfill. These risks are associated with
ingestion of ground water immediately downgradient of the landfill, ingestion of soil from the
landfill, and future releases from the landfill.
The FS identified technologies that could reduce risks for each of these media. These
technologies were assembled into media-specific remedial alternatives. The FS then screened
these media-specific alternatives based on effectiveness in reducing risks, implementability, and
cost. Media-specific alternatives remainin8.after the screenin8 process were assembled into nine
site-wide remedial alternatives for detailed evaluation. This screening process was carried out
according to procedures specified by U.S. EPA in CERCLA, the NCP, and U.S. EPA guidance
documents including -Interim Guidance on Superfund Selection of Remedy. (OSWER Directive
No. 9355.0-19, December 24, 1986) and -Draft Guidance for Conducting Remedial Investigations
ancl Feasibility Studies Under CERCLA. (OSWER Directive No. 9355.3-01, March 1988).
The alternatives evaluated in detail include I no action alternative and eight alternatives
that rely on containment of waste, with little or no treatment, to reduce site risks. The FS looked
at alternatives involving treatment as I principal element to reduce the toxicity, mobility, or
volume of site wastes. However, these alternatives were screened out, based on implementability,
prior to the detailed analysis. The FS did not develop any remedial alternatives for source control
that would eliminate the need for long-term management, including monitoring. Treatment
alternatives of this type were not considered feasible because of the large volume and diverse
nlture of the waste materials in Bowen Landfill.
Each of the nine remedial alternatives evaluated in detail is described briefly below. The
descriptions include containment components, institutional controls, estimated time for
implementation, cost, overall protection, and compliance with applicable or relevant Ind
2S
-------
appropriate requirements (ARARs). Section 9.0, which describes the comparative analysis of
alternatives, includes additional detail on these subjects.
'.1
AUeraath. 1
Alternative I is the no action alternative. CERCLA requires that the no action alternative
be considered at every site. Under this alternative, no further action would be taken at Bowers
Landfill to reduce risks or to control the sources and migration of contaminants. The no action
ahernative will not modify the landfill in any way. Thus, it has no associated costs, and no time
would be required to implement this alternative.
Capital Cose
Present Worth Operation &; Maintenance (0 &; M) Costs:
Total Costs:
Time to Implemene
so
SO
SO
None
8.2
AU.raatly. 2
Alternatiye 2 includes the following components:
.
Ground-water monitoring
Site restrictions
.
Under Alternative 2, a long-term monitoring program would be implemented to monitor
contaminant concentrations and migration. This program would include the installation of
additional monitoring wells south of Bowers Landfill (between the landfill and the Circleville
municipal wellfield) and west of the landfill (between the landfill and the Scioto River). These
new wells, existing monitoring wells, and possibly residential wells near the landfill would be
sampled. The monitoring program would be designed to protect the Scioto River by sampling
ground water that discharges to the river. Additionally, the program would sample water from
the upper and lower aquifers that may now under the river and join regional ground-water now.
At a minimum, the pr08ram would meet the substantive requirements for 8round-water
monitoring under the Resource Conservation and Recovery Act (RCRA) as described in 40 CFR
264, Subpart F.
The installation of three addirionaJ ground-water monitoring well clusters is necessary to
develop I ground-water IDOnitoring pr08raJD that would adeq'.;ely detect potential future
releases of contaminants. These well clusters would consist of three wells; a shallow well that
would be located in the upper portion of the saturated alluvial aquifer, an intermediate well that
would be located between the water table and the bedrock. and a deep well that would be located
26
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just above the bedrock. Two of these well clusters would be installed west of the landfill. One
cJuster would be installed between well location S and well location 6 and the other between well
W-IO and the bend of the landfill (see Figure 3). The third well cluster would be instaJled off-
site between the landfill and the CirclevilJe municipal wellfield. The installation of wen clusters
in addition to these may also be considered.
The monitoring wells would be sampled on a bimonthly basis for the fint year and
quarterly for years 2 through 4. During the first year. samples would be analyzed for the full
Target Compound List (TCL). A reduced TCL may be considered after the first year. If the
levels of contaminants in ground water did not increase over this time period. the sampling
schedule would be reevaluated and a reduction in the frequency of sampling may be considered.
A statistical test would be developed .to determine when a significant increase in the level of
contaminants had occurred.
Should a significant increase in the levels of contaminants occur. it would automatically
trigger I RCRA corrective action. If the levels of contaminants in ground water exceeded MCLs.
where available. or health-based levels. where MCLs are not available. resampling would occur
within 14 days. (Health-based levels are concentrations corresponding to a cancer risk of 10-6 for -
carcinogenic contaminants and a hazard index (HI) greater than I for noncarcinogenic
contaminants.) If the resampling verified that there had been I significant increase in the levels
of contaminants. a corrective action program would be implemented. Corrective action may
include such measures as the establishment of alternate concentration limits (ACLs). the
collection and treatment of ground water. or the removal of the source of contamination.
The surface water in the drainage ditch to the east or the landfill would be sampled on a
Quarterly basis as part of the monitoring program. Monitoring would verify that discharges from
the ditch are in compliance with Ohio Water Quality Standards. as described in the Ohio
Administrative Code (OAC) 3745-01. A corrective action program would be implemented if
contaminant levels in the ditch exceeded these standards.
EffortS will be made to procure deed restrictions prohibiting ground-water extraction in
the field. west of the landfill and restricting disturbance of the landfill surface. The viability of
continued farming immediately west of the landfill would be evaluated. LDd. if shown to be
necessary. efforts would be made to prohibit such farming by imposition of deed restrictioDS. A
6-foot fence would be placed around the landfill. the drainage ditch to the east, LDd the field to
the west to limit site access.
Alternative 2 relies entirely on institutional controls and monitorinl to reduce risk and
does not include any containment or treatment components. Restricting ground-water use
27
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immediately down gradient of the site should be effective in eliminating risks from drinking this
ground water. However. while fencing is identified as a meaDS for limiting exposure.
contaminated soils would remain uncovered. Exposure could stHl occur through dispersal of soil
by erosion and by direct contact if persons enter the site despite the fence. Potential future risks,
as described in Section 6.3. would not be reduced. Further. Alternative 2 does not meet State of
Ohio closure requirementS for solid waste landfills. which has been identified as In ARAR.
The costS of Alternative 2 and the estimated time for implementation are as follows:
Capital Cost:
Present Worth 0 ct M CostS:
Total CostS:
Time to Implement
S 173.700
S 295.100
S 468.800
I Month
8.3
Alternathe 3
Alternative 3 includes the following componentS:
.
Ground-water monitoring
Site restrictions
Management of surface debris
Local repairs to existing landfill cover
Erosion control and drainage improvementS
.
.
.
.
Alternative 3 incorporates ground-water monitoring and site restrictions already described
under Alternative 2. The additional components of this remedial alternative are discussed below.
The landfill area and its immediate vicinity would be cleared of surface debris.
Nonhazardous debris would be disposed of at a nearby sanitary landfill. and any waste items
determined to be hazardous would be disposed of at a suitable hazardous waste landfill.
After surface debris has been removed, areas showing SigDS of erosion would be
identified. These areas would be cleared of vegetation and repaired with natural clay soil to be
uniform with the surrounding surface. Drainage patterns on the landfill would be surveyed. and
areas showina erosion would be repaired with rill. Areas prone to ponding would be regraded to
provide a uniformly sloping surface that would drain water ofr the landfill. The existing
vesetation cover of trees on the landfill would be maintained. As part of the maintenance
program, the cover woutd be inspected on a regular basis for structural integrity and vegetative
srowth.
u
28
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The drainage ditch east of the landfill would be improved to allow water to drain from
the field north of the landfill through this ditch. The pipe that runs under the southern end of
the landfill from this ditch would be replaced by a 36-inch-diameter corrugated metal pipe.
Erosion protection would be provided on those landfill areas prone to erosion due to
swift-flowing water from the river. This protection would include armor stone (ripnp) in areas
that abut the river. Stone would also be placed on the north-facinl slope of the western edge of
the landfill and at the southern edge of the landfill to dissipate the energy of river flow.
Alternative 3 addresses some containment aspects for contaminated soils by providing
limited repain to the existing landfill cover. However, since repain would be made on a visual
basis. this alternative cannot ensure that all areas of contaminated soil would be covered. The
landfill would remain largely unchanged and susceptible to erosion and infiltntion of
precipitation and surface water during flood events. Trees would not be removed from the
landfill surface, further increasing the potential for infiltration. As noted for Alternative 2, this
alternative does not address Ohio closure requirements for solid waste landfills.
The costs of Alternative 3 and the estimated time to implement this alternative are:
Capital Cost
Present Worth 0 & M Costs:
Total Costs:
Time to Implement
S 1,427,300
S 741,000
S 2,168,300
3 Months
8.4
Altern.the ..
Alternative 4 includes the following components:
.
Ground-water monitorinl
Site restrictions
Management of surface debris
Natural clay cover over landfill
Erosion control and drainale improvements
.
.
.
.
Alternative" contains the same site restrictions u described for Alternative 2. (n
addition, the ground-water monitorinl prOlram would be identical to the program described
under Alternative 2. Erosion and dninage control improvements would be similar to those
described for Alternative 3. However, instead of limited repain to the landfill cover, Alternative
.. includes a clay cover over the entire landfill surface. .AIl trees and other veaetation would be
cut down to the surface. and steps would be taken to prevent their Irowth throulh the new cover.
PrecautioDs would be taken to minimize exposure of buried waste durin a removal of vegetatioD.
29
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The new cover would consist of a well-compacted, low-permeability clay cover at least 24
inches thick. A top soU layer at leut 24 inches thick would be placed over the clay cover. This
top soU layer would be planted with Irasses or other shallow-rooted plant species. The cover
would exceed Ohio closure requirements for solid waste landfills. which call for only a well-
compacted 24-inch cover of suitable material. The clay layer would have a maximum
permeability of 10.7 cm/sec and would limit infiltration to less than 10 percent of precipitation.
Prior to cover instaJlation. I detailed leotechnical investilation would be conducted to
measure the properties of the soil Ind clay used to construct the cover. The purpose of this
investigation would be to determine the stability of these materials under nood conditions. The
cover would then be constructed with side slopes nat enough to protect the landfill from damage
due to nooding. Construction would be done in such I manner as to minimize potential harm to
the noodplain. as required by 40 CFR 6, Appendix A. Statement of Procedures on Ftoodplain
Management and Wetlands Protection. In addition. the cap would be constructed. operated. and
maintained to prevent washout of any hazardous wastes by a lOO-year nood. as required by .
RCRA General Facility Standards in 40 CFR 264.18. These regulations have been identified as a
location-specific ARARs.
The cap and fence would be inspected on a quarterly basis and repain of any significant
damage would begin within 30 days. The la!idfill would also be inspected for leachate and
methane gas production on a quarterly basis. If leachate production occurred that could
potentially advenely affect public health or the environment, a leachate collection system would
be installed and the leachate would be collected and treated. If methane 8as production occurred
that could potentially advenely affect public health or the environment. a gas venting system
would be installed.
The drainage ditch adjacent to the east side of the landfill would be improved by
removing sediments as necessary. The pipe that runs under the landfill from the southern end of
the ditch would be replaced by a 36-inch-diameter corrugated metal pipe. These improvements
would allow water to drain from the field north of the landfill through the ditch and into the
Sc:ioto River. During the design of this alternative, the feasibility of removing contaminated
sedimentS from the drainage ditch would be evaluated. These sediments could be dewatered as
necessary and placed on the landfill surface prior to installing the clay cap. The drainage ditch,
which is contiguous with the eastern side slope of the landfill, can be considered pan of the
landfill. Therefore, movement of sedimentS Crom the ditch to the landfill would consolidate
hazardous wastes within a single disposal unit. This would not constitute 8land disposal8 under
RCRA Subtitle C. so RCRA land disposal restrictions in 40 CFR 268 would not be ARARs.
Sediment removal, in conjunction with capping. would reduce the possibility of contaminated
surface water discharges from the ditch to the Sc:ioto River.
30
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'.~
Alternative 4 uses site restrictions to reduce risks from ingestion of ground water. Soil
ingestion risks would be areatly reduced because the entire landfill surface, where highest soil
contamination levels were found, would be covered. Long-term risks would be reduced by the
application of a cover that reduces infiltration through the landfill.
The costS and time to implement Alternative 4 are listed below:
Clpital Cost:
Present Worth 0 ct M Costs:
Total Costs:
Time to Implement:
S 3,173,000
S 1,094,SOO
S 4,267,SOO
10 Months
8.5
Aleera.dye 5
Alternative S includes the following components:
.
Ground-,water monitoring
Site restrictions
Management of surface debris
Natural clay cover over landfill
Erosion control and drainage improvements
Leachate collection system
Gas venting system
.
.
.
.
.
.
Alternative S is identical to Alternative 4, except that the landfill cover would incorporate
gas venting and leachate collection systems. The gas venting system would consist of a network
of perforated pipe, approximately 6 inches in diameter, laid at lOO-foot intervals in a 12-inch
layer of gravel over the landfill surface. The gravel layer would have I geotextile fabric placed
over the top to prevent spaces in the lravellayer Crom clogging. A 24-inch clay cover would be
placed over the gravel layer, followed by I 24-inch soilaad vegetation cover. Cias vents would
connect to the perforated pipe Ind exit vertically through the clay Ind soil covers. Gases
containing high concentrations of VOCs could be passed through I vapor phase carbon adsorption
system to remove these contaminants.
The leachate collection system, loeated It the toe ot the landfill, would consist of a
perforated pve pipe in a trench filled with granular drainage material. The pipe would catch
and direct leachate to I collection point. From there, the leachate would be pumped to a
temporary holding tank, treated, and discharged.
Alternative S would provide slightly greater protection than Alternative" because of the
Idded leachate and gas collection systems. It would also comply with ARARs Ind would exceed
Ohio solid waste landfill closure requirementS.
31
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The costS and time to implement Alternative S are as follows:
Capital CostS:
Present Worth 0 ct M CostS:
Total CostS:
Time to Implement
S 4,341,200
S 2,374,600
S 6,71S,800
10 Months
..,
Altern.tl., ,
Alternative 6 includes the fOllowing componentS:
.
Ground-water monitoring
Site restrictions
Management of surface debris
Natural clay cover over landfill
Drainage improvementS
Leachate collection system
Gas venting system
Flood protection dike
.
.
.
.
.
.
.
Alternative 6 is identical to Alternative S. except that additional flood protection would
be provided by constructing a flood protection dike. The dike would extend around the west and
north sides of the landfill. A concrete wall would be constructed at the south and northwest
corners of the landfill, where there is insufficient space for a dike between the landfill and the
river. The core of the flood dike would be constructed of an impervious clay material. and the
side slopes would be constructed from clean soil. The sides of the dike along the river would be
protected against surface water erosion by concrete riprap or rock fill. Stormwater within the
flood control dike and the ditch east of the landfill would be collected through a gravity drainage
system that discharges water to the river through check valves.
Alternative 6 addresses all site risks, including the potential risk of future releaSes from
the landfill. The flood protection dike would provide additional protection to the landfill. once
the new clay cover is installed. Alternative 6 would exceed Ohio solid waste closure requirementS
and would comply with ARARs for construction in floodplains.
The costs and implementation time for Alternative 6 are as follows:
Capital CostS:
Present Worth 0 ct M Costs:
Total Costs:
Time to Implement
S 9.094.300
S 3,060.000
S ) 2.1 S4.3oo
18 Months
32
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8.7
AiterD8the 7
Alternative 7 includes the following components:
.
Ground-water monitoring
Site restrictions
Management of surface debris
Synthetic membrane cap over landfill
Drainage improvements
Leachate collection system
Gas venting system
flood protection dike
.
.
.
.
.
.
.
Alternative 7 is similar to Alternative 6 except that I synthetic membrane cap would be
placed over the landfill rather than a clay cap. The design of the landfill cap would be similar to
the design specified in the Resource Conservation and Recovery Act (RCRA). A permeable
geotutile fabric would be placed over the gas collection and venting system, followed by a 2-
foot-thick layer of compacted clay with a permeability of 10.7 cm/sec:. A 20-mil (minimum)
synthetic membrane would be placed directly on the compacted clay layer. Finally, a 12-inch
drainage layer with a hydraulic conductivity of at least 10.] em/see would be placed over the
synthetic liner, followed by I 24-inch-thick vegetated soil cover. The FS estimates that this cap
would reduce infiltration through the landfill to less than 1 percent of precipitation. In addition,
the nood protection dike would minimize the chance of nood waten conta~tin8 the landf~ll
surface.
Alternative 7 addresses all site risks, including the potential risk of future releases from
the landfill. This alternative would exceed Ohio solid waste closure requirements and would
comply with ARARs for construction in floodplains.
The estimated costs and implementation time for Alternative 7 are:
Capital Costs:
Present Worth O.t M Costs:
Total Costs:
Time to Implement
S 10,367,400
S 3,449,300
S 13,116,700
II Months
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8.8
Alleralche 8
Alternative 8 includes the following components:
.
Ground-water monitoring
Site restrictions
Management of surface debris
Synthetic membrane cap over landfill
Erosion control and drainage improvements
Leachate collection system
Cias venting system
.
.
.
.
.
.
Alternative & is similar to Alternative 7, without the nood protection.dike. Instead of the
dike, this alternative provides erosion control at the ends of the landfill using riprap as described
under Alternative 3. All other components of this alternative have been described previously and
are not repeated here.
The synthetic membrane cap over the landfill would cover most contaminated soils and
would reduce long-term risks by reducing infiltration through the landfill cover to less than I
percent of precipitation. This alternative would exceed Ohio solid waste closure requirements
and would comply with ARARs for construction in noodplains.
The estimated costs and implementation time for Alternative 8 are:
Capital Costs:
Present Worth 0 Ii M Costs:
Total Costs:
Time to Implement:
S 6,228,500
S 2,328,400 .
S 8,556.900
10 Months
8.9
Alteralthe 9
AIt~rnative 9 includes the following components:
.
Ciround-water monitoring
Site restrictions
Management of surface debris
Natural clay cover over top of landfill
Improvements to landfill side slol)"!s
Erosion control and drainage improvements
.
.
.
.
.
Alternative 9 is similar to Alternative 3, except that a natural clay cover would be placed
on the top of the landfill. This clay cover would be similar to the cover installed over the entire
34
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landfm surface in Alternative 4. Under Alternative 9. side slopes would not be covered. but
would be repaired as necessary. These repairs would be made to increase the depth of the cover
and provide continuously sloping surfaces. The tree cover on the landfill side slopes would be
thinned out, but most trees would be left in place.
Drainage patterns would be surveyed. and areas such as erosion riftS and terraces would
be filled and regraded to match adjacent contours. The fill applied to the side slopes would be
compacted. Where side slopes are steep. additional stabilization would be accomplished by
placing riprap or by supporting the slopes using sheet piling or soil cement.
Drainage control berms would be constructed at the top of the landfill to collect
storm water runoff. The water collected by the berms would be directed to the base of the side
slopes by drainage chutes. The collection and drainage system would help reduce infiltration
through the side slopes by limiting the area contacted by runoff from the top of the landfill.
Alternative 9 addresses some containment aspectS for contaminated soils by covering the
top of the landfill and providing limited repairs to the side slopes. However. this alternative
cannot ensure that aU areas of contaminated soil would be covered. The landfill side slopes
would remain largely unchanged and susceptible to erosion and infiltration of precipitation and
surface water during nood events. Trees wQuld not be removed from the landfill surface. further
increasing the potential for infiltration. This alternative would not meet Ohio closure
requirementS for solid waste landfills because of the incomplete repairs to side slopes.
The costS of Alternative 9 and the estimated time to implement this alternative are:
Capital CostS:
Present Worth 0 & M Costs:
Total Costs:
Time to Implement:
S 2.483.500
S 9SS.9OO
S 3.439.400
8 Months
9.0
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
U.5. EP A used the following nine criteria to evaluate each of the alternatives identified in
the FS report. The remedial alternative selected for the site must represent the best balance
among the evaluation. criteria.
3S
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J. O~er.1I Protectloa or Humaa Healcb aad tbe [ulroameat addresses whether a
remedy adequately protects human health and the environment and whether risks are properly
eliminated, reduced, or controlled through treatment, engineering controls, or institutional
controls.
%. Compliaace with Applicable o~ Rele~aat aad Appropriate Require.eats addresses
whether a remedy meets aU state and federal laws and requirements that apply to site conditions
and cleanup options.
3. Loaa- Term [lleethoeaesl aad Per.aaeaee refers to the ability of a remedy to reliably
protect human health and the environment over time once cleanup goals have been met.
4. Reductioa 01 Toxicity, Mobility, or Volume are three principal measures of the overall
performance of an alternative. The 1986 Superfund Amendments and Reauthorization Act
(SARA) emphasizes that, whenever possible, U.S. EPA should select a remedy that will
permanently reduce the level of toxicity of the contaminants at the site, the spread of
contaminants away from the site, and the volume, or amount, of contaminants at the site.
5. Short-Term Ellectlnaess refers to the likelihood of any adverse impacts to human
health or the environment that may be posed during the construction and implementation period
until cleanup. loals are achieved.
6. Imple.eatabillty is the technical and administntive feasibility of a remedy. including
the availability of materials and services needed to implement the remedy.
7. Cost includes capital and opention and maintenance costs of implementing a remedy.
8. Scate Acceptaace indicates whether, based on its review of the RI, EA, FS, and
Proposed Plan, the State of Ohio (OEPA) concun with, opposes, or has no comment on the
alternative U.s. EPA is proposinl as the remedy for the site.
,. COlDlDualty Aeceptaace indicates whether the public COncurs with the remedy
presented in U.S. EPA's proposed plan.
After evaluating all the remedial alternatives developed in the FS, usinl the nine criteria
just described, U.s. EPA has selected Alternative" to address contamination at the Bowers
Landfill Superfund site. The ntionale for this selection is provided below.
36
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"';,~
9.1
O~erall ProtectloD or Huma. Hulth aDd tbe EDylrODlDe.t
Alternative 4 would protect both human health and the environment. This alternative
would reduce potential risks from ingestion of contaminated soil by installing a fence around the
site and by covering the most highly contaminated soils with 4 feet of clay and soil. The FS
estimates that probable case risks for soil ingestion would be reduced to zero. Some residual risk
would rem~in due contaminated soils in the "field west of the landfill. To estimate uposure to
this remaining contamination, the FS assumed that (1) SO-kg teenagen would scale the fence
surrounding the site 10 times per year over a S-year period, (2) these teenagen would ingest 200
mg of contaminated soil per visit, and (3) SO percent of the contaminants in ingested soil would
be absorbed by the body. Based on these assumptions and the maximum soil contaminant
concentrations in the areas not affected by the cover, the HI for noncarcinogenic risks would be
reduced from 3.48 to 0.24. The carcinogenic risk, based on average lifetime uposure, would be
reduced from 3 x 10-6 to 4 x 10-8. Risk reductions for Alternatives S through 8, which cover the
same areas of soil contamination, would be identical. In contrast. Alternatives 2. 3, and 9 do not
cover the entire landfill surface and would provide a smaller risk reduction. The FS estimates
that these alternatives would result in an HI of 0.28 for noncarcinogenic effects and a
carcinogenic risk of S x 10-7.
Alternative 4 would reduce risks from ingestion of ground water by placing access
restrictions on the area west of the landfill. These restrictions would prevent the use of this area
as a future ground-water source. In addition, the clay and soil cap would reduce infiltntion to
less than 10 percent of precipitation, reducing the likelihood of future ground-water
contamination. Alternatives Sand 6, which have a similar cap, would also reduce infiltntion to
less than 10 percent. Alternatives 7 and 8, which include a synthetic membnne cap, would
provide much greater reductions in infiltntion.
Ground-water users farther from Bowers Landfill would be protected by the monitoring
program included as part of Alternative 4. This program would include installing and sampling
additional wells south and west of the landfill. Expansion of the monitoring network to the south
would detect any future migntion of ground-water contamination toward the City of Circleville's
wellfield, I; miles south of the landfill. Alternative 4 would include a corrective action program
that would allow prompt response to any significant increases in ground-water contamination that
might occur in the future.
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Overall, Alternative 4 would be more protective of human health and the environment
than Alternatives I, 2, 3, and 9. These alternatives include either no modifications or limited
modifications to the existing landfill surface.
Alternative 4 would be somewhat less protective than Alternatives S, 6, 7. and 8, which
include more extensive remediation. For example. Alternative 7, the most protective alternative,
also includes a synthetic membrane cap, a flood protection dik~, a leachate collection system, and
a gas venting system. The overall effect of these additional measures would not increase
protection with respect to ingesting contaminated soils or ground water. The flood protection
dike included in Alternatives 6 and 7 may prolong the effective life of the landfill cap due to less
erosion from surface water. However. the cap iostaJled under Alternative 4 would be designed
and constructed to resist flood damage or washout of wastes by a IOO-year flood and would have
a minimum 30-year lifetime. The multilayer cap included in Alternatives 7 and 8 might provide
greater reductions in infiltration, thus providing greater protection against the generation of
contaminated leachate and future ground-water contamination. However. there is little evidence
of a leachate problem at Bowers landfill. and current levels of ground-water contamination are
low. Therefore. the low-permeability clay cap constructed under Alternative 4 would provide
adequate proteG:tion of ground water.
9.2
Compllaace wltb Applicable or Relenat aad Appropriate Requiremeats
Alternative 4 would comply with applicable or relevant and appropriate state and federal
requirements (ARARs). These requirements include action-specific ARARs related to closure of
Bowers landfill. location-specific requirements related to the location of the landfill within the
lOO-year floodplain of the Scioto River, and chemical-specific ARARs for contaminants
identified in environmental media at the landfill.
Alternative 4 is primarily a closure plan for Bowers landfill, and the major action-
specific ARARJ to be considered are those related to landfill closure. Waste disposal at Bowers
Landfill ended around 1968. before the effective date of RCRA. Thus. RCRA Subtitle C
requirements for the treatment. storage, and disposal of hazardous wastes are not applicable to
remedial actions at the landfill. Additionally. the wastes in Bowers landfill contain large
volumes of low-toxicity material, widely dispersed over a large area that bears little resemblance
to the discrete units regulated under RCRA Subtitle C. Nevertheless, portions of RCRA Subtitle
C requirements can be considered relevant and appropriate.
38
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The preamble to proposed revisions to the National Contingency Plan (53 Federal
Register, December 21, 1988) describes several options for closure of Superfund sites, based on
RCRA requirements. One option is .closure with wastes in place.. This option requires a final
cover over the contaminated materials and post-closure care, including maintenance oC the cover,
ground-water monitoring, and corrective action if ground-water protection standards are
exceeded in the future. A second option is -alternate land disposal closure.. Under this option,
landfill cover requirements are relued because (I) the cover will reduce risks due to direct
contact with wastes and (2) the wastes appear to pose I limited threat to ground water.
Alternative 4 falls between these two oPt.ions, but closer to the first option. The cl3y cap
installed as part of this alternative would have I permeability of 10.7 or less. This cap would
meet the requirements for the clay layer at the bottom of a hazardous waste landfill, as described
in 40 CFR 264.301. Because current ground-water contamination levels at Bowers Landfill
suggest a limited threat to ground water, a synthetic membrane layer is not considered a
necessary component of the cap. On the other hand, Alternative 4 would exceed the relaxed
cover requirements for -alternate land disposal closure.. These requirements are more similar to
State oC Ohio closure regulations for solid waste landfills, which call for a .well compacted layer
of final cover material. . . to a depth of at least two Ceet.. Alternative 4 would substantially
exceed this requirement by providing a 4-Coot-thick cover, including a 2-foot layer oC low-
permeability clay.
Alternative 4 would also comply with location-specific ARARs. Because Bowers Landfill
is located within the 100-year floodplain of the Scioto River, construction within the floodplain
is unavoidable. However, Alternative 4 would be constructed in I manner that would minimize
potential harm to the floodplain, as speciCied by floodplain management requirements in 40 CFR
6. In addition, the cap would be constructed, operated. and maintained to prevent washout oC
any hazardous wastes by a IOO-year flood, as required by RCRA General Facility Standards in 40
CFR 264.18.
Alternative 4 would attain chemical-specific ARARs for ground water by reducing
inCihration oC precipitation and floodwaten through the landfill waste. Ground-water results
Crom the RI showed that benzene sli&htly exceeded the MCL or 5 I£g/L in one sample from well
P-6B. Levels in other samples from this well were below the MCLt and benzene was not
detected in any of the remaining 12 down gradient wells. Barium also exceeded the MCL in three
samples collected Crom a single well, well '-5B. However, the average barium concentration was
well below the MCL. The ground-water monitoring program implemented under Alternative 4
would require regular and systematic sampling and would meet the substantive requirements for
39
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around-water monitorina under RCRA in 40 CFR 264, Subpart F. The monitoring program
would include provisions for corrective action should contaminant levels significantly increase in
the future.
Additionally, the monitoring program proposed for Alternative 4 would include collecting
surface water samples from the ditch east of Bowen Landfill. Surface water monitoring would
verify Ibat discbarges from tbe ditcb are complying witb Ohio Water Quality Standards as
described in OAC 3745-01.
Alternatives Sand 6 would .comply with ARARs 10 tbe same extent as Alternative 4.
Alternatives 7 and a, by including a synthetic membrane layer in addition 10 the low-
permeability clay layer, would come closer 10 meeting RCRA requirements for closure witb
hazardous wastes in place.
Alternatives I, 2, 3, and 9 would leave some or all of the current soil and vegetation cover
intact. These alternatives would not comply witb relevant and appropriate portions of RCRA
closure regulations or with Ohio closure standards for solid waste landfills. Furtber, tbese
alternatives would not meet location-specific ARARs because they would Dot be constructed,
operated, and maintained to prevent wasbout of bazardous wastes by I lOO-year nood. Also,
Alternatives I, 2, 3, and 9 would not significantly reduce infiltration of precipitation and nood
waters through the landfm, and may not result in attainment of MCLs in around water.
9.3
LODI-Term ErrectheDesl aad PermaDeDCe
Because of tbe large amount of material witbin Bowers Landfm, the small known
percentage of hazardous waste, and the limited risks identified in the EA report, it was not
feasible to develop a permanent remedy for Bowen Landfill. However, the low-permeability
clay cap specified by Alternative 4 would be designed for a minimum 30-year lifetime. The
long-term effecuveness of Alternative 4 would be ensured by ground-water monitoring and
maintenance of the clay cap. Monitoring wells downgndient of the landfill would be sampled on
I reaular basis to determine if contaminant concentrations in around water are increasing
significantly over time. The monitoring program would also include a corrective action
component, requiring furtber remedial action if I significant increase in around-water
contamination is detected. The maintenance program for Alternative 4 would include regularly
mowing tbe vegetation OD tbe cap; inspecling tbe surface for cracks, settlement, pondiD~, and
erosion; completing appropriate repain to the cap; and repairing the fence IS necessary. In
addition to regularly scheduled inspections, additional inspections would be made after noods.
40
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Similar monitoring. inspection. and maintenance would be needed to maintain the long-
term effectiveness of Alternatives S. 6. 7. and I. These alternatives include additional
components. such as I synthetic membrane cap or I nood protection dike. that may increase
lonl-term effectiveness. However. the additional components would not greatly increase long-
term effectiveness compared to Alternative 4. Current landfill conditions, 20 years after disposal
ceased. indicate that Alternative 4 would be-sufficiently protective in the long-term. Thus. the
slightly higher long-term effectiveness of Alternatives S, 6. 7. and 8 does not justify the
substantially higher costs of these alternatives.
In contrast. Alternatives I. 2. 3. aDd 9 would be much less effective in the long term.
Alternatives I and 2 do not include any repairs to the existing landfill cover. Alternatives 3 and
9 make limited repairs. but would not cover the enure landfill surface. Alternatives I. 2. 3. and
9 would also leave trees on the landfill side slopes. These alternatives would allow greater
infiltration of precipitation and nood waten than Alternatives 4 through 8 because of the
incomplete cover and 'because tree roots probably penetrate into waste materials below the cover.
These alternatives would also have a greater potential for long-term failure of the landfill side
slopes. Over time. the combination of saturated soil conditions during nooding and high winds
could result in complete uprooting of trees. exposing underlying waste materials.
9.4
Reduc:tioa or Toxicity, MobiJity, or Volume
None of the remedial alternatives evaluated in the FS report involves treating source
materials from Bowers Landfill. Thus, none of the alternatives would reduce the toxicity or
volume of hazardous constituents within the waste. Treatment alternatives for the source
materials were considered but were not evaluated in detail for several reasons. Fint. most of the
estimated 130,000 cubic yards of waste material in Bowers Landfill consists of general refuse and
municipal solid waste. Although the exact amount of hazardous waste placed in the landfill is not
known. it is probably a small percentage of the total waste volume. The large volume and
variable composition of wastes makes treatment impractical. Second. no operating records exist
for the landfill. Thus, it is not feasible to identify locations where hazardous wastes might have
been placed. Third, the relatively low levels of contamination found during the RI would not be
effectively reduced by treatment.
Alternatives S, 6. 7. and 8 include provisions for installing I leachate collection and
treatment system, which is a treatment alternative. This system may reduce the volume and
mobility of leachate if leachate contains hazardous constituents. However. ground-water analyses
from the RI did not indicate significantly elevated contaminant levels in the upper aquifer, which
41
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would be the first target of a leachate plume. Additionally. the low-permeability clay cap
installed under Alternative 4 should greatly reduce future leachate generation by reducing
infiltration through the landfill. For these reasons. the installation of a leachate collection system
was considered but then rejected.
Similarly. Alternatives S. 6. 7. and S include a collection system for sases generated by
the landfill. Collected gases could be treated, ir necessary. However, Alternative 4 does not
include gas collection and treatment for the following reasons. First, air monitoring results from
the RI showed that air concentrations or volatile organic compounds (VOCs) at Bowen Landfill
are similar to off-site background concentrations. Second, the landfill has a low potential to emit
VOCs to air because of the low concentrations of VOCs in soils, sediments, and surface water on
or adjacent to the landfill. Finally. because of the age of the laDdfill, most of the potential gas
generation may already have taken place. These gases would have readily escaped through the
highly permeable soil that now covers the landfill.
Alternative 4 would reduce the mobility of waste materials within the landfill. The FS
report estimates that the low-permeability clay cap included in this alternadve will reduce direct
infiltration into the landfill surface by over 90 percent. This is much more effective than the
current soil and vegetation cover. Reducing the amount of water that contacts waste materials
within the landfill should reduce the mobility of these materials. Alternatives Sand 6, which also
include a clay cap, would provide similar reductions in infiltration. Alternatives 7 aDd 8, which
include a synthetic plastic liner and a clay cap. would further reduce infiltration (estimated in the
FS report as greater than 99 percent). However, these much greater reductions do not appear
warranted by current levels of ground-water contamination at Bowers Landfill.
In contrast, Alternatives I and 2 (no repairs to the existing cover), Alternative 3 (limite:d
repairs to the cover), and Alternative 9 (application of a partial clay cover) would provide either
no reduction or less reduction in infiltration. Each of these alternatives would leave trees on the
landfill side slopes. Root systems of these trees would provide a direct path between flood waters
or precipitation and the underlying waste materials.
42
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r-. ..).
DECLARATION FOR THE RECORD OF DECISION
Sif~ Nam~ and Location
Bowers Landfill Site
Circleville, Ohio
.-
S(at~ment or Basis and PurDon
This decision document presents the selected remedial action for the Bowers Landfill site in
Circleville, Ohio, developed in accordance with CERCLA, as amended by SARA, and the
National Contingency Plan. This decision is based on the administrative record for this site. The
attached index identifies the items that comprise the administrative record upon which the
selection of the remedial action is based.
The State of Ohio concurs with U.S. EPA's remedy selection. A letter of concurrence is attached
to this Record of Decision.
DescriDtion or the Selected Remedv
The primary role of the Bowers Landfill RA is:
1.
To properly close the site that has evidence of hazardous waste disposal; and
2.
To address potential site risks.
Since the site has a very poor cover, site records indicate evidence of hazardous waste disposal
and low levels of contamination were found, the site will be closed in accordance with Ohio
Sanitary Landfill Closure standards. This will include installing a 4 ft. thick clay and soil cover
over the landfill. Erosion and flood control measures, and drainage improvements will be
included.
Potential risks are posed by ground water immediately downgradient of the site and exposure to
c:ontaminated soils on or neat the landfill. The selected remedy will address the ground water
threats by restricting future ground water use between the landfill and the Scioto river and by
installing a clay cap that will reduce infiltration, reducing the likelihood of future ground water
-------
contaminants. Additionally, because wastes will remain on-site, the selected remedy will provide
for long term ground-water monitoring and corrective action measures should monitoring
indicate unacceptable risks due to increased contamination. The selected remedy will address the
soil threats by cappina contaminated soils and limitina access to the landfill area.
The major components of the selected remedy are:
Monitoring ground water
Restrict site use and access
Manage surface debris
Improve erosion control, nood protection and drainage
Install natural clay cover over landfill
Dedaratloa
The selected remedy is protective of human health and the environment, attains Federal and State
requirements that are applicable or relevant and appropriate to the remedial action, and is cost-
effective. This remedy utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable for this she. Because treatment of the principal threats of the site
was not found to be practicable, however, this remedy does not satisfy the statutory preference
for treatment as principal element of the remedy.
Because this remedy will result in hazardous substances remaining on-site above health-based
levels, a review will be conducted within five years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection of human health and the
environment.
11'
~'-tl1.0~~~
Valdas V. Adamkus, Regional Ad nistrator
U.S. Environmental Protection Agency, Region V
'3(~ll~,
Date
2
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"'iO.~'
9.5
Short- Term Errectheaesa
The FS report estimates ~hat Alternative 4 could be constructed within 10 months; the
alternative would effectively protect human health and the environment immediately upon
completion. This construction period is longer than the I month required for Alternative 3.
which includes only limited repairs to the existing landfill cover. Alternatives S. 8. and 9 would
require construction periods similar to that for Alternative 4. :iowever. Alternatives 6 and 7
would require approximately 18 months to complete due to the more extensive construction
activities.
Alternative 4 and the other alternatives could be cODSuucted without significant adverse
impactS on the environment and people living near Bowers Landfill. However. all the
alternatives, with the exception of those requiring no construction, would present general safety-
related risks to construction workers. In addition. earth moving activities could generate dust
fr~m the landfill surface that could potentially affect workers and surrounding populations.
However. these effectS could be minimized by using standard dust suppression methods. such as
watering. Additionally. air monitoring would be conducted to measure contaminants released
during construction. Construction practices would be modified as necessary to prevent
unacceptable releases.
A major impact of Alternative 4 on the surrounding community would be increased truck
traffic near the site. The FS report estimates that approximately 8.000 truckloads of material
would enter and leave the site during construction. Over a 10-month period. this figure
corresponds to an avenge of 40 trucks per work day. This could inconvenience local residents,
adversely affect local roads. and present aO slightly greater risk of traffic accidentS near the site.
Increased truck traffic is also a component of other construction alternatives. The estimated toC\l
number of trucks varies from 1.225 for Alternative 3 to 12.000 for Alternatives 6 and 7.
9.6
ImplemeDtablUty
° Alternative 4, and all other alternatives evaluated in the FS report. could be implemented
using standard earth movina equipment and constrUction techniques. However, the primary
problem of nooding could aCfect the implementation of all alternatives except Alternative I (no
action). Construction activities would have to be scheduled around nood eventS. since the area
adjacent to the landfill is inundated approximately 30 days per year. Construction of
Alternatives 4 through 9 is estimated to require 8 to 11 months to complete. Thus. remedial
action would have to be segmented into work areas. Work on one area of the landfm would be
43
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completed before construction of the next area began. This method would minimize the area of
the landfill exposed to any particular nood event.
A second implementation problem. common to Alternatives 3 through 9. is the availability
of low-permeability clay near the landfill. These alternatives would require substantial amounts
(up to 50.000 cubic yards) of clay for construction. The FS report assumes that I suitable clay
source can be found locally. However. if a local source cannot be found. increased transport of
clay would be required. resulting in increased costs.
A third implementation problem affects Alternatives 3 through 9. These alternatives
would require removing existing vegetation from all or pan of the landfill. This activity,
especially the removal of large trees. could expose underlying waste materials. Precautions would
be taken to minimize this possibility.
None of the alternatives appears to present any major administrative problems that would
affect implementation. However. the nood protection dike included in Alternatives 6 and 7
would involve substantial construction in the Scioto River noodplain. Construction of the dike
would remove approximately 80 acres of land from the IOO-year floodplain. since the dike would -
prevent noodwaters from covering this area. This would increase the height of noodwaters
upstream and downstream of the landfill and may cause additional areas to flood. Because of this
potential problem. Alternatives 6 and 7 may be administratively more difficult to implement.
9.7
Cost
The estimated total present worth cost for Alternative 4 is approximately 54.3 million.
This estimate includes capital costs of approximately S3.2 million for fencing. drainage
improvements. erosion and nood control measures. and installation of the landfill cap. Annual
operation and maintenance (OctM) costs for this alternative are estimated It approximately
S116.0oo and include expenses related to Iround-water monitorinl and leneral maintenance of
the fence. drainage system. erosion and flood control measures. and landfill cap. The present
worth of annual 04M costs (over I 30-year period at a 10 percent interest rate) is approximately
S 1.1 million.
Alternative 4 would be more expensive to implement than Alternatives 1.2. 3. and 9.
However. these alternatives would not provide the degree of overall protection offered by
Alternative 4. Alternatives 5, 6. 7. and 8 would provide somewhat greater protection than
Alternative 4, but at a much greater cost. Estimated total present worth costs for these
44
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alternatives range from S6.7 million to $ 13.8 million. Increased costs are associated with more
sophisticated technologies such as a leachate collection system and gas venting system
(Alternatives S through 8), . flood protection dike (Alternatives 6 and 7), and a landfill cap with
a synthetic liner (Alternatives 7 and 8).
The total cost of Alternative 5 is approximately 50 percent higher than Ahernative 4 ($6.7
million compared to $4.3 million), while Alternatives 6 through 8 involve much greater costs
($ 12.2 million, $ 13.8 million, and $8.6 million respectively). Although these alternatives may
offer increased long-term protection. the relative cost increase outweighs the expected benefits.
For example. the installation of a gas venting system does not appear necessary. Several factors
indicate that gas leneration is. not a problem at Bowers Landfm. Such factors include the age of
the landfill, the porous nature of the current landfill cover. the frequent flooding of the landfill,
and the lack of elevated VOC and gas levels during the RI. Likewise, the installation of a
leachate collection system does not appear justified because of little evidence that leachate is
significantly affecting the upper aquifer. The low-permeability clay cap installed under
Alternative 4 would further reduce leachate generation. The installation of a RCRA cap and
nood protection dike are likewise not justified. A RCRA cap would decrease infiltration to less
than 1 percent of precipitation. However. at a much lower cost. the clay cap included in
Alternative 4 would decrease infiltration to less than 10 percent of precipitation. With respect to
the flood protection dike, the landfill's north side appears to be stable under current conditions.
It should be possible to install a new landfill cover that will resist nood damage without the
added expense of a nood protection dike.
u.S. EPA has made minor revisions to remedial alternatives based on commentS received
during the public comment period. As a result. costs may be slightly higher than the estimates
presented in this section.
9.8
State AcceptaaCt
The State of Ohio has concurred with U.S. EP A's selection of Alternative 4 as the
preferred remedial alternative for Bowers Landfill. A letter of concurrence is attached to this
Record of Decision.
9.9
Commualty Acceptaace
U.S. EP A 's preferred remedial alternative for Bowers Landfill was presented at the start
of the public comment period through distribution of a fact sheet, publication of display
45
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advertisementS in the Cirvleville. Ohio, Herald. and placement of the proposed plan in the site
information repositories. A formal public meeting to discuss the proposed plan was held in
Circleville on February 28. 1989. CommentS received indicate that many residentS are concerned
about U.S. EPA's preferred alternative.
These comments focus on three general areas. First. several residents commented that
V.s. EP A appean to be closing Bowen Lahdfill as a solid waste landfill. with no consideration of
the hazardous wastes that were disposed of at the site. These residentS prefer Alternatives 7 and
I. which include additional protective measures such as a synthetic liner (in addition to the clay
cap) and a nood protection dike. V.S. EPA has pointed out in this Decision Summary that
relevant and appropriate portions of hazardous waste regulations in RCRA Subtitle C have been
adequately considered in the design and selection of Alternative 4. This issue is discussed further
in the Responsiveness Summary.
Second. several residentS expressed concern about U.S. EPA's proposed ground-water
monitoring plan for Bowers Landfill. These concerns are directly related to protection of public
drinking water supplies -- specifically. the City of Circleville's wellfield located U miles south
of the landfill. To address these concerns. the ground-water monitorinl program will include
installing and sampling additional monitoring wells south of Bowen Landfill. Further. U.S. EPA
will require that corrective action program options be developed as part of the monitoring
program. This will allow prompt response if around-water contaminant levels exceed levels of
concern at any compliance point in the monitoring system.
Finally. several residents expressed concern that U.5. EP A 's preferred alternative
representS a conceptual design, specific elementS of which will be determined later with limited
input from local residents. To address this concern. U.S. EPA will consider extending the Bowers
Landfill Information Committee (see Section 3.0) through the remedial design/remedial action
phase of this project.
10.0
THE SELECTED REMEDY
After evaluating all the feasible alternatives. U.s. EPA is selecting a remedy that consists
or five componentS: (I) around-water monitoring; (2) site access restrictions; (3) management of
surface debris; (4) erosion control and drainage improvementS; and (5) a natura) cla;1 cover over
the landfill. These five components are described in detail below.
46
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10.1
Crouad- Water Moallorial
Under Alternative 4, I long-term program will be implemented to monitor contaminant
concentrations and migration. This program will include installing additional monitoring wells
south of Bowers Landfill (between the landfill and the Circleville municipal wellfield) and west
of the landfill (between the landfill and the Scioto River). These new wells, existing monitoring
wells, and possibly residential wells near the landfill will be sampled regularly. At a minimum,
the program will meet the substantive requirementS for ground-water monitoring under RCRA as
described in 40 CFR 264, Subpart F.
The installation of three additional ground-water monitoring well clusters is necessary to
develop a ground-water monitoring program that will adequately detec;t potential future releases
of contaminantS. These well clusters will consist of three wells; a shallow well that will be
located in the upper portion of the saturated alluvial aquifer, an intermediate well that will be
located between the water table and the bedrock, and a deep well that will be located just above
the bedrock. Two of these well clusters will be installed west of the landfill. One cluster will be
installed between well location Sand well location 6 and the other between well W -10 and the
bend of the landfm (see Figure 3). The third well cluster will be installed off-site between the
landfill and the Circleville municipal well field. The installation of well clusters in addition to
these may al50 be considered.
The monitoring wells will be sampled on a bimonthly basis for the first year and quarterly
for years 2 through 4. During the first year, samples will be analyzed for the full Target
Compound List (TCL). A reduced TCL may be considered after the first year. If the levels of
contaminants in ground water do not increase over this time period, the sampling schedule will be
reevaluated and a reduction in the frequency of sampling may be considered. A statistical test
will be developed to determine when a significant increase in the level of contaminants has
occurred.
Should I significant increase in the levels of contaminants occur, it will automatically
trigger a RCRA corrective action. If the levels of contaminantS in ground water exceed MCLs.
where available, or health-based levels, where MCLs are not available, resampling will occur
within 14 days. (Health-based levels are concentrations corresponding to I cancer risk of 10-6 for
carcinogenic contaminants and a hazard index (HI) greater than I for noncarcinogenic
contaminants.) If the resamplin& verifies that there has been I significant increase in
contaminant levels, a corrective action program will be implemented. Corrective action may
include such measures as establishing alternate concentration limits (ACLs), collecting and
treating ground water, or removing the source of contamination.
47
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The surface water in the drainage ditch to the east of the landfill will be sampled on a
quarterly basis as .part of the monitoring program. Monitoring will verify that discharges from
the ditch are in compliance with Ohio Water Quality Standards, as described in the Ohio
Administrative Code (OAC) 3745-01. A corrective action program will be implemented if
contaminant levels in the ditch exceed these standards.
10.2
Site Access RestrictiODS
EffortS will be made to procure deed restrictions prohibiting ground-water extraction in
the field west of the landfill and restricting disturbance of the landfill surface. The viability of
continued farming immediately west of the landfill will be evaluated, and, if shown to be
necessary. efforts would be made to prohibit such farminl by imposition of deed restrictioDS. A
6-foot fence will be placed around the landfill, the drainage ditch to the east, and the field to the
west to limit site access. The location of the fence is shown on Figure 6.
10.3
MaDalemeDt of Surface Debris
The landfill area and its immediate vicinity will be cleared of surface debris. Most of the -
currently exposed material consistS of shredded or rolled plastic Cilm. but rusted and partially
decomposed remains of appliances. discarded tires, domestic waste. and empty drums are also
evident. The visible waste items will be removed from the site by a front-end loader. placed in a
lined truck, and transported to a suitable hazardous waste landfill. If the debris is determined to
be nonhazardous, it will be disposed of in a solid waste landfill.
Trees on the landfill will be cut down with chain saws. and tree stumps will be ground
down to the land surface. Smaller vegetation. less than 2 feet in diameter, will be cut down with
mechanical equipment such as bush hogs. As much subsurface vegetation as feasible will be
removed, without exposing significant amountS of waste. Exposed cover will be treated as
necessary to prevent tree growth through the new cover. All vegetative material will be hauled to
. local landem unless tissue samples indicate that materials are potentially hazardous. If
potentially hazardous. this material will be disposed of in an approved off-site hazardous waste
disposal facility.
10.4
ErosloD CODtrol aDd Draiaale ImprovemeDts
Erosion control will be provided for those areas of the landfill prone to the scouring
effects of nood waters. The areas most likely to be subjected to these effects are the northwest
48
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FIGURE 6. -
Sill ALTERNATIVE 4
~
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-- ---
---
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------ SCI010 RIVER ~.- -. .~~.-q.. ..
---
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NA RIRAl CtA Y COVEH
o
SCAI [
-------
and southeast portions of the landfill that abut the Scioto River. A system of armor stone
(riprap) will be used in these areas to supplement the erosion resistance provided by the new
cover. This riprap will be placed on the landfill in areas shown on Figure 6. If riprap cannot be
effectively placed on steeper slopes. sheet piling will be used to anchor the riprap. If sheet piling
proves ineffective. a concrete wall may be used.
Site drainage will be improved to prevent ponding of water against the landfill. The area
between the landfill and the river will be regraded to allow water to drain away from the landfill.
The site will also be regraded to allow for drainage now from north to south to the river.
The drainage ditch on the eastern side of the landfill will also be improved. Where
necessary. side slopes will be improved to prevent erosion. The high point between the north end
of this ditch and the open field north of the landfill will be cut down to prevent ponding of
water against the northern part of the landfill during high-water conditions. High points within
the ditch will also be cut down to allow water to drain through the ditch. Sediments removed
during this prcx:ess. and possibly other contaminated sediments. could be dewatered as necessary
and placed on the landfill surface prior to installing the clay cap. Removal of contaminated
sediments will reduce the possibility of contaminated surface water discharges from the ditch to
the Scioto River. The discharge pipe at the southern end of the drainage ditch will be replaced
with a larger one. A 36-inch-diameter corrugated metal pipe will be placed under the southern
end of the landfill and will discharge to the river. The point where the ditch meets the pipe will
be lined with compacted clay and reinforced with riprap. The pipe will have a 2 percent slope to
prevent blockage with sediments.
10.5
Natural Clay Co.er Onr LaDdCm
Prior to construction of the landfill cover. a detailed geotechnical investigation will be
conducted to measure the properties of the existing landfill surface and of soil and clay used for
the cover. The purpose of this investigation will be to determine the stability of these materials
under flood conditions. The cover will then be constructed with side slopes nat enough to
provide adequate stabiJjty when the &:ioto River noods. Although there is no apparent need for
. landfill gas collection system. this determination could be reevaluated as part of the
aeotechnicaJ investigation. A soil gas study of the landfill could verify that VOCs are not present
in sufficient quantities to warrant collection.
The landfill cover will be constructed in segments to minimize potential damage due to
nooding during construction. Work on one area of the landfill will be completed before
construction of the next area begins. After each landfill segment has been prepared. a well
50
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compacted clay layer. It least 24 inches thick. will be placed on the landfill cap and side slopes.
The clay will be added in lifts. not exceeding 6-inches. and compacted before more clay is added.
The clay layer will have a maximum permeability of 10.7 cm/sec. Each lift will be tested
accordin8 to a stringent Quality assurance program to verify that this specification is met.
A top soil layer at least 24 inches thick will be placed over the clay layer (Fi8ure 7). This
layer will al50 be applied and compacted in.6-inch lifts. The final cover will have sufficient
horizontal-to-vertical side slopes so as to prevent faHure during worst case nooding conditions.
The entire surface of the completed cover will be reseeded. fertilized. and watered to assure plant
growth. The plant species used will have root systems that Ire not expected to penetrate below
the upper 24 inches of cover.
The cover will be inspected and maintained on a Quarterly basis. The maintenance
program will include regularly mowin8 the ve8etation on the cap; inspecting the surface for
cracks. senlement. ponding. and erosion; completing appropriate repairs to the cap; and repairing
the fence. Repairs to all significant damage will begin within 30 days. In addition to regularly
scheduled inspections. additional inspections will be made after nood events.
The landfill will also be inspected for leachate and methane gas production on a Quarterly
basis. If leachate production occun that could potentially adversely affect public health or the
environment. a leachate collection system will be installed and the leachate will be collected and
treated. If methane gas production occurs that could potentially adversely affect public health or
the environment. a gas venting system will be installed.
10.6
Reductloa of Site Risks
The selected remedy addresses the major risks for Bowen Landfill as identified in the
EA. Risks from ingesting contaminated soils will be reduced by covering the landfill (thus
covering most highly contaminated soils) and by restrictin8 Iccess to the site. Soils in the field
west of the landfill that contain lesser amounts of contamination will not be covered. The
residual risks from ingesting these soils include an insignificant noncarcinogenic risk (HI of 0.24)
and a carcinogenic risk of 4 x 10.8. Risks from in8esting contaminated ground water
immediately dowugradient of the landfill will be reduced to zero by future ground-water use
resuictioDS.
Alternative 4 also reduces potential long-term risks associated with the landfill. The low-
permeability clay cover wi11greatly reduce infiltration of precipitation and nODd waten.
compared to the current cover. Thus. the mobility of contaminants remaining in the landfill will
SI
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~;-Noturci Cloy Loyer( 1 x, 0 -7 cm/see) =--:
------------------------
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52
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be reduced. The cover will isolate waste within Bowen Landfill under a minimum 4-foot
thickness of cover material and will be designed to provide long-term stability during noods.
11.0
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Bowen Landfilt site satisfies the
statutory requirements of CERCLA Section '121. The selected remedy is consistent with the NCP,
protects human health and environment, attains ARARs, and is cost-effective. The selected
remedy does not satisfy the statutory preference for a permanent solution in that it leaves
untreated waste oD-site. Nor does the selected remedy reduce the toxicity or volume of wastes.
However. source control and containment components of the selected remedy should significantly
reduce the mobility of contaminants from the landfilt.
11.1
The Selected Remedy Is Protecthe or Humaa Health aDd the ID.iroameat
The remedial alternative selected for Bowers Landfill will reduce current and potential
future risks to human health and the environment by the following means:
.
Preventing exposure to contaminated soils by covering contaminated soils with a
4-foot-thick impermeable clay and soil cap and by fencing the site area. The cap
and fence will be maintained on a regular basis, with an increased inspection
schedule during noods.
Preventing exposure to contaminated ground water by restricting access to
downgradient property. Efforts will be made to obtain deed restrictions to
prohibit extraction and use of ground water from this area.
.
.
Limiting future ground-water contamination by reducing infiltration through
contaminated soils and the landfill. The effectiveness of the cover will be
evaluated by a long-term ground-water monitoring program. The program will
require regular and systematic sampling of monitoring wells west and south of the
landfill and possibly from residential wells soutb of the landfill.
Reducinl potential future exposure to wastes i.n Bowen Landfill by constructing a
stable cover designed to withstand frequent .nooding oC the Seioto River.
.
.
Reducing potential sources of surface water contamination Cor the Seioto River by
removing contaminated sediments from the drainage ditch that is contiguous with
the east side of Bowen Landfill. Discharges from the ditch wilt be monitored for
compliance with Ohio Water Quality Standards.
S3
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11.1
The Sel.cted R.medy AUalas ARARs
The selected remedy will meet or attain all applicable or relevant and appropriate federal
and state requirementS. These requirementS include:
11.3
.
Ohio requirementS for the closure of solid waste landfills (OAC 374S-27-09 and
OAC 3745-27-10). Tbe final landfill cover will exceed the required thickness of 2
feet and will meet all other ~ubstantive requirementS within these regulations.
Relevant and appropriate portions of RCRA requirementS for closure of hazardous
waste ~andfills with wastes in place. The low-permeability clay layer (maximum
of 10' cm/sec) will comply with portions of the cover requirementS in 40 CFR
264.301. The ground-water monitoring program will meet the substantive
requirementS of 40 CFR 264, Subpart F. The program will include a corrective
action component that will be triggered if around-water protection standards are
exceeded at any point of compliance in the monitoring system.
.
.
u.S. EPA requirements for noodplain protection, as described in 40 CFR 6,
Appendix A, Statement of Procedures on F100dplain Management and Wetlands
Protection. This regulation requires that construction in noodplains be done in
such a manner as to minimize harm to the noodplain. Construction within the'
Scioto River noodplain is unavoidable in implementing a remedial alternative for
Bowers Landfill.
.
RCRA requirements for construction, operation, and maintainance of hazardous
waste landfills in lOO-year noodplains. The cover installed during remedial action
will be designed and engineered to prevent washout of any hazardous wastes by a
lOO-year nood, as required by RCRA General Facility Standards in 40 CFR
264.18.
.
Maximum Contaminant Levels (MCL) promulgated under the Safe Drinking Water
Act. MCLs apply to public drinking water supplies serving 25 or more people.
While not applicable to ground water immediately down gradient of Bowers
'Landfill, MCLs are relevant and appropriate for assessing ground-water
contamination levels. Current contaminant levels exceed MCLs in two- monitoring
wells -- benzene in one well and barium in a second well. However. avt.rage
ground-water concentrations were well below MCLs. By reducing infiltration of
precipitation and nood waters through the landfill, Alternative 4 should eventually
reduce contaminant concentrations below the MCLs in all downgradient wells.
.
Ohio Water Quality Standards listed in OAC 3745-01. Discharges to the Scioto
River from the drainage ditch east of the landfill will be monitored to verify
cOmpliance with these standards.'
The Seleeted Remedy Is Cost-Erreethe
Alternative 4 represents a cost-effective remedial alternative for Bowers Landfill. This
alternative attains the same reductions in current risks from soil ingestion and grvudd-water
ingestion as Alternatives 5 through 8, which are considerably more expensive. Alternative 4 also
provides an adequate degree of long-term protection, compared to these more expensive
S4
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: ....l
alternatives. Although Alternatives S through a may offer slightly increased long-term
protection. the relative cost increases outweigh the expected benefitS. Additional componentS of
these alternatives. such as a gas venting system. leachate collection system. synthetic membrane
cap. or nood protection dike. do not increase the effectiveness of these alternatives in proportion
to the increased costS. These additional measures are not justified based on current site
conditions and contamination levels.
Alternative 4 has a higher cost than Alternatives 3 and 9. However. these alternatives do
not achieve either the short-term risk reductioDS or long-term protection offered by Alternative
4. By providing a degree or protection that cannot be achieved by less costly means. Alternative
4 is cost-effective.
11.4
The Selected Remedy Utilizes Permaaeat Solutloas aad Alteraate Treatmeat
TechDoloeles or Resource Reco'er)' Techaoloeles to tbe Maximum Extent Practicable
Alternative 4 is not a permanent solution to the public health and environmental problems
identified for Bowen Landfill during the RI. It was not technically feasible to develop a
permanent remedy for this site ror several reasons. Fint. most of the material in Bowen Landfill
consistS of general refuse and municipal solid waste. Although the exact amount of hazardous
waste placed in the landfill is not known. it is probably a small percentage of the total waste
volume. Second, DO operating records exist for the landfill. Thus, it is Dot feasible to identify
locations where hazardous wastes might have been placed. Third. the relatively low levels of
contamination found during the RI would not be effectively reduced by treatment.
Because the selected alternative is not a permanent solution and will leave wastes in place
at the Bowers Landfill, the effectiveness or this remedial action must be reviewed at least once
every S years.
11.5
Tbe Selected Remedy Reduces ToxIcity, Mobility, or Volume or Waste Materials as a
PrlDcipal Elemeat
Alternative 4 will not reduce the toxicity or volume oC contaminantS within Bowers
Landfill. However, this alternative will reduce the mobility oC waste materials within the
landfill. The FS report estimates that the low-permeability clay cap included in this alternative
will reduce direct infiltration into the landfill surface by over 90 percent. This is much more
effective than the current soil and vegetation cover. Reducing the amount of water that contacts
waste materials within the landfill should reduce the mooility oC these materials and the
likelihood of future ground-water contamination.
SS
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RESPONSIVENESS SUMMARY
BOWERS LANDFILL
CIRCLEVILLE, OHIO
March 24, 1989
u.s. Environmental Protection Agency
Region V
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4.0
5.0
Section
1.0
2.0
3.0
A otlend ices
~.,~
TABLE OF CONTENTS
fiG
INTRODUCTION
OVER VIEW
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
BACKGROUND ON COMMUNITY INVOLVEMENT. . . . . . . . . . . . . . . . . . . . . .. 2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3.1
3.2
3.3
Early Involvement. . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
Bo..-,'ers Landfill Information Committee. . . . . . . . . . . . . . . . . . . . . . . . . . .. 3
Concerns Raised During the RIfFS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES............ 6
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
Remedial Alternative Preferences. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
Technical Concerns Regarding Remedial Alternatives. . . . . . . . . . . . . . . . " II
Public Participation Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17
CostS A nd Funding Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19
Enforcement Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 20
Remedial Investigation Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 21
Endangerment Assessment Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 25
Other Issues. . . . . . . . . . . . . . . . . . . . . . . . .' . . . . . . . . . . . . . . . . . . . . . .. 29
REMAINING CONCERNS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Appendix A
Appendix B
Appendix C
30
Written Comments on the Proposed Plan for Bowers Landfill
Community Relations Activities at Bowers Landfill
Response to Public Comments on Consent Order for Bowers Landfill,
Circleville, Ohio, July 1985
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RESPONSIVENESS SUMMARY
BOWERS LANDFILL
CIRCLEVILLE, OHIO
1.0
INTRODUCTION
The U.S. Environmental Protection Agency held a public comment period from February
14 to March 16, 1989, to provide interested parties an opportunity to comment on the Agency's
Proposed Plan for Bowers Landfm. The purpose of this Responsiveness Summary is to identify
major commentS raised during the public comment period and to provide U.S. EP A's responses to
these commentS. U.S. EPA has considered all commentS summarized in this document before
selecting a remedial alternative for Bowen Landfm.
The Responsiveness Summary includes five sections plus three appendices. Section 2.0
brieny states public reaction to U.S. EP A's Proposed Plan. Section 3.0 contains a brief history of
community interest and involvement with the Bowers Landfill site. Section 4.0 summarizes
written and oral comments received by U.S. EPA during the public comment period. CommentS
were received from local citizens, environmental groups, local officials. state officials, and
potentially responsible parties. Section 4.0 also includes U.S. EPA's responses to these commentS. -
Section 5.0 identifies and summarizes issues that may continue to be of concern to the community
during the design and implementation of U.S. EPA's selected remedy for Bowers Landfill. U.S.
EPA will address these concerns during the Remedial Design and Remedial Action (RD/RA)
phase of the cleanup process.
The first attachment to the Responsiveness Summary is a list of community relations
activities conducted by U.S. EPA at Bowers Landfm. both before and during the public comment
period. The second attachment includes copies of all written commentS on the Proposed Plan
received during the pubHc comment period. Oral commentS, which were recorded at a public
meeting on February 28, 1989, are included within the transcript for that meeting. The transcript
is part of the Administrative Record for Bowen Landfill.
2.0
OVERVIEW
U.S. EPA's preferred alternative for the Bowers LandfilJ site was presented at the start of
the public c",Ulment period through distribution of a fact sheet, publication of display
advertisement in the Circieville Herald, and placement of the formal Proposed Plan in the site
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information repositories. The Proposed Plan was also presented and discussed during a public
meeting in Circleville on February 28. 1989. The recommended alternative addressed potential
ground-water contamination problems near the site, the risk of ingesting contaminated on-site
soils, and long-term risks from future contaminant releases.
The preferred alternative specified in the Proposed Plan consistS of monitoring ground
water at and near the site; restricting the use of the site so that drinking water wells cannot be
placed between the site and the Seioto River; placing a 6-foot-high fence around the site
perimeter to prevent potential trespassers from entering the site area; and installing a new clay
cap on the landfill to minimize the amount of contaminantS that could potentially be carried into
the ground water beneath the site. Erosion control and drainage improvementS wo.uld be made.
and riprap and sheet piling would be placed on the north and south ends of the landfill to
improve nood protection.
The comments received during the comment period indicated that residents have some
concerns about U.S. EP A's preferred remedial alternative. Some residents felt additional nood
protection measures were needed at the site. Concerns were also raised regarding the proposed
ground-water monitoring program and response contingencies. Specific details of such a program
are usually resolved in the remedial design phase. Several residents indicated concern that they
would have limited future opportunities for input into the cleanup process after the Record of
Decision (ROD) is signed. These residents strongly requested the continuation of the Bowers
Landfm Information Committee (see Section 3.2).
All written comments received by U.S. EPA are included in Appendix A to this
Responsiveness Summary. Verbal commentS recorded at the February 28. 1989. public meeting
are contained in the transcript of that meeting. which is pan of the Administrati-.'e Record for
Bowers Landfill.
3.0
BACKGROUND ON COMMUNITY INVOLVEMENT
3.1
Earl)' la.ohemeat
Community interest in Bowers Landfill dates back to the early 1960s when residents
complained to the Pickaway County Health Department about odors and fires at the landfill.
Sporadic complaints from residents continued throughout the 1960s and 19705.
2
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Local media covered the site during the early 1980s after Superfund was enacted and U.S.
EPA became involved at the site. In April 1984, Columbus television station WMCH (Channel 4)
mistakenly reported that Bowen Landfill was possibly contaminated with dioxin. The report
resulted in increased interest and concern about the site. Since that time, community interest and
involvement have been high. This level of interest was maintained during the remedial
investigation and feasibility study (RIfFS). Appendix B to this Responsiveness lists community
relations activities that U.S. EPA has condu'ted in response to this interest.
In early 1985, a consent order, allowing the potentially responsible parties to conduct the
RIfFS, was drafted. U.S. EPA held a public comment period on the draft consent order and
received written and verbal comments covering a wide range of environmental health and public
involvement issues. U.S. EPA responded to these comments in July 1985. The document
containing these responses (Response to Public Comments on Consent Order for the Bowen
Landfill, Circleville, Ohio, July 1985) is included as Appendix C to this Responsiveness
Summary.
Many of the comments on the consent order indicated an interest in areater community
involvement during RIIFS process. Residents and officials wanted to be kept well informed.
Some wanted representation in the decision-making process. In response to these comments, U.S.
EPA established the Bowen Landfill Information Committee.
3.2
Bowen Laadem laCormatloa Committee
The Bowers Landfill Information Committee was established in November 1985. The
committee consisted of representatives from U.S. EPA, OEPA, the PRPs, local (city and county)
government, and citizens' groups (ACTION and L-ECHOS). The committee met regularly to
discuss progress during the RIfFS and upcoming events. Draft reports were also provided. to the
committee for review and discussion. Committee meetings were open to any interested observen.
Twelve meetings were held between November 1985 and November 1988. The committee had
several major (uDc:tioDS: .
.
To disseminate reports, data, and other information related to the Bowen Landfill
RIfFS. During the meetings, U.S. EPA, OEPA, and the PRPs made formal
presentations to the committee on topics such as well installation and sampling
methods; samplina results for soil, ground water, surface water, and sedimen~
endangerment assessment results; applicable or relevant and appropriate
requirements (ARARs); and remedial alternatives developed in the FS.
To act as liaison between the agencies and the rest of the community.
.
3
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.
To provide input to U.S. EPA and OEPA on issues related to the site. However,
the committee was not a decision-making body and had no authority to override
agency decisions.
U.S. EPA and OEPA distributed draft versions of several documents to the committee for
review and discussion. These documents were generally distributed .at least one week (and often
earlier) before the committee meeting at which the document was to be discussed. Site reports
reviewed and discussed by the committee included:
. Work Plan . QAjQC Plan
. Site Safety Plan . Geophysical Survey Report
. Biological Survey Report . Technical Memoranda for Sampling
. RI Report Results
. Endangerment Assessment Report . Alternatives Array Document
. FS Report
3.3
Concerns Raised Durinl the RIIFS
The following community concerns were raised during the RIfFS. Many of these
concerns were expressed by the members of the Bowers Landfill Information Committee.
J.
Concerns were raised by the information committee about the health and safety aspects of
the RI field work. The concerns regarded coordination between agencies, PRPs, and local
emergency officials should an emergency occur.
u.S, EPA Response: U.S. EPA and OEPA officials met with local fire, police, hospital,
and other officials to explain the roles of the RI participants and to better understand the
jurisdictions and response capabilities of the local agencies. Response plans were
developed for the unlikely event of an emergency.
2.
Members of the information committee expressed a desire to physically observe .on-site
fjeld activitjes.
U.S. EPA Response: Due to liability concerns, this request was denied. However, slides
taken during RI field activities were shown at information committee meetings.
3.
Residen~ expressed concern that the site should be fenced to restrict site access during RI
field activities.
4
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V.S. EPA Respoase: The U.S. EPA Emergency Response Team evaluated Bowers
Landfill in May 1985 to determine whether site access posed an immediate health threat.
U.S. EPA determined that a fence was not Decessary because the only unnatural materials
observed at the site were empty drums aDd plastic nODhazardous materials. The site was
almost completely covered by vegetatioD (grasses, shrubs, and trees). However, as a result
of this evaluation. U.S. EP A installed additional warning signs at the site, particularly
near the southernmost access point along Island Road.
Before the start of RI field work, a .fenced area was constructed near the entrance
to the landfill. Equipment used during field activities was stored inside this fenced area
when not in use. The area also contained a support trailer for field activities.
4.
Concerns were raised regarding the differences between the RI results and the results
obtained by Burgess and Niple in 1981.
V.S. EP A RespoDse: U.S. EP A believes that the data obtained during the RI most
accurately represents current conditions at and near the landfill. The agency also feels
that the level of data quality assurance in 1981 was not as high as is present quality
assurance programs offer. Therefore, the 198 I results may be less reliable than the RI
results. The differences between current and 1981 results may also be explained by
changes in contaminant levels due to nooding at the site or volatilization of the chemicals.
Chemicals that migrated to the Scioto River would have been diluted to much lower
concentrations. This issue is addressed in greater detail in Section 4.7 of this
Responsiveness Summary.
s.
U.S. EPA was requested to provide the results of private well sampling to the appropriate
homeowners.
V.S. EPA RespoDse: U.S. EPAprovided the results of water testing to the appropriate
homeowners. The results were sent to the information repository and are also included in
the RJ and EA reportS.
6.
Residents were concerned that the Circleville water supply might be contaminated.
U.S. EPA RespoDse: OEPA. a party to the consent order. responded that the City of
Circleville must periodically test its water supply for the presence of huardous chemicals.
OEP A placed copies of test results from 1980-1987 in the information repository.
5
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I!-.~
S"mmaries of these test results are also included in the EA report. The results indicate
that the Circleville water supply is of high quality and has not been adversely affected by
contamination from Bowers Landfill. This issue is discussed further in Sections 4.2, 4.6,
and 4.7 of this Responsiveness Summary.
7.
Members of the group ACTION requested a formal 9O-day public comment period on the
RI report.
U.S. EPA RespoDse: While a formal comment period on the Bowers Landfill RI report
was not held, U.S. EPA pointed out that ciUzeDS may comment on technical activities at
any time during the RI/FS process. Any comments would be included in the Bowers
Landfill Administrative Record. In addition, comments on the RI submitted to U.S. EPA
by members of Bowers Landfill Information Committee were included as an addendum to
the RI report. A major function of the information committee has been to provide
opportunities for citizen input during the technical activities at the site, particularly
during the development of the work plan, and during the review of the RI, EA, and FS
reports.
4.0
SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
This section of the Responsiveness Summary summarizes comments received during the
public comment period for Bowers Landfill and provides U.S. EPA's responses to these
comments. Tbe Agency received comments from local citizens, environmental groups, local
officials, state officials, and potentially responsible parties. These comments concerned the
preferred remedial alternative (Alternative 4), as stated in the Proposed Plan, and other remedial
alternatives developed in the Feasibility Study (FS). U.S. EPA also received comments on work
conducted earlier in the RI/FS process, including the RI and endangerment assessment.
Attachment 2 to this Responsiveness Summary includes copies of all written comments
received during the public comment period. Oral comments, which were recorded at a public
meeting on February 28, 1989, are included within the transcript for that meeting. The transcript
is part of the Administrative Record for Bowers Landfill. Where several individuals or
organizations submitted similar comments, a single response is provided. U.S. EPA has grouped
the comments according to subject.
6
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4.1
Remedial Alteraathe Preferuce.
J.
Two residenu asked why a flood protection dike was not included as part of the preferred
remedial alternative.
v.s. EPA Respoase: Based on discussions with the U.S. Army Corps of Engineers, U.S.
EP A believes that the landfill cap i,nstalled under Alternative 4 can be designed and
constructed to resist flood damage or washout of wastes by a lOO-year flood. Alternative
4 would include flood protection, in the form of riprap, on the ends of the landfill most
prone to flood damage. Where necessary. sheet piling would be added to provide
additional stability. Landfill side slopes would be designed to prevent failure during
flood conditions. A safe horizontal-to-vertical ratio for the side slopes would be
determined by geotechnical studies of the landfill surface and the soil and clay used for
the cover. Wastes would be covered by at least 4 feet of new cover material and would be
isolated from flood waters. Any minor damage to the cap caused by flooding would be
repaired promptly as part of an ongoing operation and maintenance program.
"
The additional protection offered by the nood dike is not proportional to the cost -
of the dike. Although the dike would provide additional long-term protection from
noods. it would provide no additional r~duction in inriltration of precipitation through
the landfill. compared to the clay cap. The FS estimates the cost of the flood protection
dike as approximately 55.S million. This additional component would more than double
the cost of Alternative 4 while providing only slightly increased long-term effectiveness.
Further, construction of the dike would remove approximately 80 acres of land
from the lOO-year noodplain of the Scioto River, since the dike would prevent
noodwaters from covering this area. This would increase the height of noodwaters
upstream and downstream of the landfill and may cause additional areas to flood.
2.
Several residents wanted to know why hazardous waste landfill closure requirements were
not applied to Bowers Landfill. A citizen representing ACTION. a local environmental
group. asked: --rhe feasibility study states that Alternative 4 would comply with current
State of Ohio closure standards for solid waste landrills. Since hazardous waste was
dumped at Bowers. ( would like to know if any of the alternatives comply with State of
Ohio closure standards for hazardor- Naste facilities. If not. why not?-
7
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V.S. EPA Respoase: Ohio hazardous waste regulations are modeled after U.S. EPA
hazardous waste regulations. The Resource Conservation Recovery Act (RCRA). as
amended by the 1986 Hazardous and Solid Waste Amendments. regulates active hazardous
waste facilities. Hazardous waste facilities that were not operating arter November 19.
1980. are not required to comply with RCRA. Because of this. RCRA is not applicable to
remedial actions at Bowers Landfill.
U.S. EPA believes that site conditions. as currently defined by the RI. do not
justify closure of Bowen Landfill in compliance with state or federal regulations for
active hazardous waste landfills. The landfill was used primarily for domestic waste.
nonhazardous industrial waste. and construction debris. Based on site conditions and the
relatively low levels of contaminants in ground water. closure as a hazardous waste
landfill is not justified.
Nevertheless. the remedial alternative chosen for Bowers Landfill takes into
account several RCRA requirements for hazardous waste landfills. The low-permeability
clay layer installed over the landfill will have a maximum permeability of 10.7 cm/sec.
This cover would meet RCRA requirements for the clay liner at the bottom of a
hazardous waste landfill. as described in 40 CFR 264.301. In addition. the cover will
meet RCRA General Facility Standards in 40 CFR 264.18. The cover will be constructed.
operated. and maintained to prevent washout of hazardous wastes by a lOO-year nood.
Finally. the long-term monitoring program for Bowers Landfill will comply with the
substantive requirements for ground-water monitoring under RCRA in 40 CFR Subpart
F.
3.
Members of ACTJON expressed concern that .containment techniques are unproven and
unreliable technologies with specific implementation problems.. Concerns were raised
that containment remedies depend on expert installation. and even if properly installed.
clay or synthetic membrane caps will eventually leak.
U.S. EP A Respoase: Capping. with either clay or synthetic membrane layers. is a
standard procedure for closinlland disposal units that have reached capacity. The cap
serves two main purposes -- preventinl direct contact and exposure to waste materials
and preventing ground-water contamination by reducing infiltration of water through the
wastes. The low-permeability clay cap proposed for Bowers Landfill will serve both
purposes. The cap will prevent direct contact with and ingestion of contaminated soils.
8
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The clay layer of the cap will have a permeability of 10.7 cm/sec or less and should
reduce infiltration of precipitation and noodwaters to less than 10 percent.
U.S. EPA will take several measures to increase the effectiveness of the cap and
reduce the IikeliJ\ood of cap failure. First, the clay layer will be designed and installed
under a strict quality assurance program. The clay will be installed in 6-inch incrementS
(or liftS). Each lift will be compa~ted and tested for permeability before the next lift is
added. Second, the horizontal-to-vertical ratio of the side slopes will be designed to
prevent failure during worst case nooding conditions. Third, the cap will be inspected
and maintained according to a regular Khedule, with additional inspections Kheduled
after noods. If the cap leaks even after these precautionary measures are taken, the long-
term ground-water monitoring program, included as part of remedial action, will detect
increases in 'ground-water contamination before the contamination moves off-site.
4.
Several resideQtS were concerned that treatment technologies were not. considered for,
Bowers Landfm.
V.S. IPA Respoase: Treatment technologies were considered in the FS, but were
screened out due to effectiveness, implementability, and cost considerations. Thus,
treatment technolog.ies were not in.cluded in any of the remedial alternatives evaluated in
detail. The Superfund AmendmentS and Reauthorization Act (SARA) of 1986 expresses a
prefe~ence for remedial alternatives that include treatment as a principle element.
However, treatment is not always practical, especially at sites that have large volumes of
low-concentration waste materials.
Three specific factors make treatment impractical at Bowers Landfill. First, much
of the estimated 130,000 cubic yards of waste material in the landfill consistS of general
refuse and municipal solid waste, rather than hazardous waste. Second, no operating
records exist, so it is not possible to identify specific locations along the 4ooo-foot length
where hazardous wastes may have been deposited. Third. the relatively low levels of
contamination found durinl the RI would not be effectively reduced by treatment.
s.
The potentially responsible parties commented that Alternative 3 (limited repairs to
landfill cover) was adequately protective of public health and the environment, and that
t'te selection of Alternative 4 (clay cover over the landfill) was not warranted.
9
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u.s. EPA ReSpODSe: u.s. EPA.s rationale for selecting Alternative 4 over Alternative 3 is
clearly stated in the ROD Decision Summary. Brieny, Alternative 3 does not meet the
two threshold criteria for selection as a remedial alternative. Alternative 3 does not
provide adequate protection of human health and the environment and does not comply
with ARARs.
6.
One resident stated that cost should not be I factor in c~oosing a remedial alternative for
Bowers Landfill. He felt that the most expensive technologies should be chosen because
they are the most protective. He stated that -EPA's rightful job at this point is to cleanup
the Bowers site to the best of its ability, notwithstanding cost.- This resident believed
that the remedial alternative should include a synthetic membrane cover for the landfill,
construction of the most sophisticated drainage system possible, and construction of a
nood control dike.
U.S. EPA RespoDse: SARA specifically requires U.S. EPA to select remedial actions that
are cost-effective. Cost-effectiveness cannot be used to justify the selection of a
nonprotective remedy. However, U.S. EPA is required by law to closely evaluate the
costS required to implement and maintain a remedy and to select a protective remedy
whose costS are proportionate to itS overall effectiveness.
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
provides the regulatory framework for Superfund. Under the currently proposed
revisions to the NCP, cost is one of five primary balancing criteria for evaluating
remedial alternatives. Other balancing criteria include long-term effectiveness; reduction
of toxicity, mobility, or volume; short-term effectiveness; and implementability. To
select a remedial alternative, U.S. EPA must first determine that the alternative meets the
two threshold criteria -- the alternative must adequately protect human health and the
environment and the alternative must comply with applicable or relevant and appropriate
requirements (ARARs). U.S. EPA must then consider the balancing criteria and choose
the remedial alternative thar represents the best combination of these criteria. Thus, U.S.
EP A must consider cost in this analysis.
7.
One member of ACTION stated that a fence around Bowen Landfill, a component of
U.S. EPA's preferred alternative, should be erected as soon as possible. This measure
would limit exposure primarily to those who choose to become exposed.
10
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u.s. ErA Respoase: u.s. EPA Igrees that installing a fence around Bowen Landfill will
limit exposure to those who choose to become exposed. Fencing was included in all
rem~diaJ alternatives (except No Action) evaJuated during the FS. Fencing will be
implemented on a priority basis once remed.iaJ action begins.
4.2
Technical CODceras Re,ardlDI Remedial Alteraad.e.
1.
One member of ACTION, a local environmental group, asked about maintenance
procedures for the preferred alternative. He stated that the feasibility study report did
not adequately describe maintenance procedures.
u.s. EPA Response: The February 3, 1989, draft of the Feasibility Study Report, page 4-
25, states:
Maintenance of the cover would involve mowing the vegetation,
inspecting the surface for cracks, settlement, and ponding of water,
and making appropriate repairs. Maintenance requirementS for the
cover can be expected to be greater than the present cover after
nood events due to the limited subsurface stabilizing capability of
the grass. Damage to the cap could occur from erosion, from plant
rootS breaking through the surface, from subsidence due to
decaying roots, from penetration by burrowing animals, or from
vandalism. Direct exposure to wastes as a result of damage is
unlikely because waste materials would be isolated at least 4 feet
below the surface. If repairs to the clay or reseeding were
required, this would be carried out immediately. Repairs to the
clay would consist of patching with fresh clay.
The minimum effective design life of caps is generally 20 years (K.
Wagner et ai, Remedial Action Technology for Waste Disposal
Sites, Noyes Data Corporation, Park Ridge, N.J, 1986, pp. 19 et
seq.). Proper maintenance can maintain the former effectiveness.
If well maintained, there would be virtually no long-term threat to
public health or the environment.
The maintenance program would also include inspection of the
cover for structural integrity on a regularly sCheduled basis.
Following periods or flooding, the landfill cover would be
inspected for signs of erosion and repaired as necessary. This
program would include repair of riprap protection, as necessary,
aDd inspection for damage from scouring, wave action, and debris,
together with repair as necessary.
U.5. IP A believes that the intent of the maintenance program is clearly stated in
the above text. The purpose of a feasibility study (FS) is to provide I general description
of remedial action technologies and to summarize the implementation methods. Specific
11
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~it~
operational guidelines that would include inspection logs, inspection schedules, inspection
methods, and descriptions of corrective actions will be detaHed in the remedial design
(RD). The RD is intended to be a blueprint for implementation while the FS is a broader
conceptual study of remedial options for the site.
2.
Several residentS, ACTION, the Circleville City Council, and the City of Circleville Water
Department expressed concerns abo':lt long-c.erm ground-water monitoring at the site.
These concerns are related to protection of the city's water supply, which is obtained
from a weJlfield approximately It miles south of the landfill. Specifically, commenters
requested that new monitoring wells be installed between the landfill and the city's wells.
Commenters also wanted to know how the proposed monitoring program would detect and
prevent off-site migration of ground-water contamination. Finally, some commenters felt
that testing of private wells south of the landfill and testing of the city's wells should also
be included in the monitoring program.
u.s. [PA RespoDse: Long-term ground-water monitoring will be conducted at Bowers
Landfill as part of the remedial alternative. As noted above, the monitoring program will
be based on RCRA ground-water monitorin8 requirements for active hazardous waste
facilities. The monitoring program will include iostalling additional monitoring wells
south of Bowers Landfm (between t~e landfill and the Circleville municipal wellfield) and
west of the landfill (between the landfill and the Scioto River). The program may also
include sampling of private residential wells south of the site.
Testing of the city's wells is required by federal law. Testing was conducted
Quarterly during 1985 for a large list of volatile organic compounds (VOCs), including
eight VOCs for which there are federal drinking water standards. None of these 'VOCs
were detected in samples from the Circleville wells. In addition, none of the VOCs found
in 8round-water samples from Bowers Landfm were found in the Circleville water
supply. After reviewing the Quarterly sampling results for 1988, OEPA informed the City
that -no repeat monitorin8 schedule has been established by the Ohio Environmental
Protection Agency (Ohio EPA) but, it is anticipated that the submittal of Quarterly VOC
samples will be required again in 1991.-
u.s. EPA believes that the combination of these two programs (long-term ground-
water monitoring at Bowers Landfill plus testina of the Circleville water supply by the
City of Circleville) will result in monitoring that is protective of human health and the
12
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environment and sufficient to identify any future releases to around water from the
landfill.
3.
Several residentS requested that U.S. EPA provide additional details about the proposed
around-water monitorina program (for eumple, number and locations of wells sampled.
frequency of sampling. and chemicals measured).
u.s. EPA Respoase: AS noted above, ground-water monitoring will require regular and
systematic sampling. The monitorinB program will meet the substantive requirementS for
ground-water monitoring under the Resource Conservation and Recovery Act (RCRA) as
described in 40 CFR Subpan F.
The installation of three additional ground-water monitoring well clusters is
necessary to develop a ground-water monitoring program that will adequately detect
potential future releases of contaminantS. These clusters will consist of three wells -- a
shallow well located in the upper portion of the upper aquifer. an intermediate well
located between the water table and the bedrock, and a deep well located juSt above the
bedrock: Two well clusters will be installed west of the landfill. one cluster between well
location Sand well location 6 and the other between well W-IO and the bend of the
landfill. The third well cluster will be installed off-site between the landfill and the
Circleville municipal wellfield. The installation of additional well clusters may also be
considered.
The monitoring wells will be sampled bimonthly for the first year and quarterly
for years 2 through 4. During the first year. samples will be analyzed for the full Target
Compound List (TCL). A reduced TCL may be considered after the first year. If
ground-water contaminant levels do not increase over this 4-year period. the sampling
schedule will be reevaluated and the frequency of sampling may be reduced.
4.
Several residents requested additional information on the steps U.s. EPA would take if
long-term monitoring results showed increases in Bround-water contaminant levels.
U.S. EPA Respoase: The monitorinl proposed as pan of the remedial alternative for
Bowen Ludfill will be designed to detect increases in ground-water contaminant
concentratioDS due to the landfill. A statistical test wiD be develC'::" -:d to determine when a
significant increase in ground-water contamination has occurred.
13
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Should a significant increase in the levels of contaminants occur, the increase will
. automatically trigger a RCRA corrective action. If the levels of contaminantS in ground
water exceed MCLs, where available, or health-based levels, where MCLs are not
available, resampling wm occur within 14 days. (Health-based levels are concentrations
corresponding to a cancer risk of 10-6 for carcinogenic contaminantS and a hazard index
(HI) greater than 1 for noncarcinogenic contaminantS.) If the resampling verifies that
there has been a significant increase in contaminant levels, a corrective action program
will be implemented. Corrective action may include such measures as establishing
alternate concentration limits (ACLs), collecting and treating ground water, or removing
the source of contamination.
U.S. EPA will make every effort to minimize delays, should corrective action be
needed in the future at Bowers Landfill. Details on the scheduling, timing, and nature of
possible corrective actions will be addressed during remedial design.
s.
One resident wanted to know the estimated costs for excavating the landfm.
U.S. EPA RespoDse: Excavation costs at hazardous waste sites vary according to the type
of excavation equipment used, levels of worker protection required. and other site-
specific factors. However, a typical cost estimate for excavation in Level B protection is
approximately S60 per cubic yard. Using this figure, the total cost to excavate all of the
estimated 130,000 cubic yards of waste in Bowers Landfill would be approximately 58
million. This estimate does not include additional costS for removing excavated wastes
from the site, packing the wastes for removal, or treating the wastes.
6.
Several residentS expressed concerns that while a clay cap would reduce infiltration
through the top of the landfill, leakage was more likely to occur through the bottom.
Because no borings were drilled through the landfill. U.S. EPA cannot be sure that there
is an adequate confining layer below the wastes.
V.S. EPA RespoDse: An 8- to IS-foot-thick layer of silt or clay was observed at all
borings completed adjacent to the landfill. These borings indicated that a natural layer of
low-permeability material was present at the time of landfill construction. Information
available to U.S. EPA indicates that most waste materials were deposited directly on this
layer. although some portions of this layer may have been excavated during landfilling
activities.
14
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Because Bowers Landfill does not have an engineered liner below the wastes, there
is . potential for leaching from the bottom of the landfill. However, the major driving
force in producing leachate is infiltration of water. The low-permeability clay cap (10.7
cm/sec or less) will greatly re<;luce the infiltration of both precipitation and noodwaters
that might create leachate. Another factor that U.S. EPA considered was that leachate,
when generated. would first enter the upper portion of the aquifer down gradient of the
landfill. Ground-water testing during the R1 showed that contaminant levels in this
aquifer were very low and did nofidentify I leachate plume.
For these reasons, U.S. EPA believes that capping should be the first step in
lessening the pocential for leachate production. Capping will be coupled with frequent
monitoring for hazardous constituents in site ground water. Should further ground-water
testing identify leachate as a problem, then source reduction techniques, such as leachate
collection and treatment, will be implemented as part of a corrective action program.
7.
One member of ACTION felt that U.S. EPA's preferred remedial alternative was .the
equivalent of doing nothing while waiting for rainfall and noods to nush the
contaminants into the surface and groundwater..
u.s. EPA RespoDse: As discussed in the previous response, U.S. EPA believes that the
remedial alternative selected for Bowers Landfill represents an active measure to contain
contaminants within the landfill, rather than allowing these contaminantS to be nushed
out by rainfaJl and noods.
8.
One resident asked under .what circumstances have gas venting and leachate collection
systems been recommended and how do these circumstances differ from the Bowers Site?
u.s. EPA RespoDse: Gas can be generated within a landfm by microbial degra.dation of
organic materials or by volatilization of organic liquids. The period of active gas
generation within a landfill can vary widely depending on site-specific conditions such as
temperature. pH. moisture content of the refuse, oxygen content, and refuse composition.
In the absence of a low-permeability layer above the waste materials, most landfill
gases wm escape through the top of the landfill. This is most likely the case with Bowers.
Landfill. Wastes have been in place from 20 to 30 years and are covered with a thin layer
of highly permeable soil. Further. because wastes were piled on the around, rather than
placed in the ground, the landfill has a large surface area (relative to the waste volume)
15
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for gases 10 escape. These observalions, plus the low organic vapor concentrations
measured during the RI, suuest that Bowen landfill is not actively generating significant
quantities of gas.
Gas collection and venting systems are normally installed when landrills actively
generating gas are capped with low-permeability materials. Capping prevents gases from
escaping through the lOP of Ihe landfi11 and forces the gases 10 move more slowly in a
lateral direction. Typically, collection systems are installed al the perimeter of the landfi11
10 prevent gases from migrating off -site. However, collection systems can also be
installed in the inlerior of Ihe landfill. Because Bowen landfi11 does n,ol appear to be
actively generaling gas, a gas collection system was not included as part of the selected
remediaJ alternative.
Leachate collection systems are required for new hazardous waste landfills as par~
of Ihe bottom liner. These systems collect and drain leachate, preventing the leachate
from reaching the bottom liner, penetrating Ihe liner, and conlaminating ground water
below the landfill. Such a system cannot be constructed under the wastes already in
Bowers Landfill.
The leachate collection system proposed for Bowers landfi11 in the FS repon
differs from this design and would be much less effective. The leachate collection system
would consist of a l-foot-thick drainage layer of high-permeability sand and gravel.
This layer would be placed OD the landfi11 surface, before Ihe clay cap is applied. At the
edges of the landfill, where this drainage layer meets the existing land surface, a 2-foot
deep trench would be dug. The drainage layer would extend into this trench.
This type of a leachate collection system would collect most of the precipitation
and noodwater that passed through the landfill cap. However, only a small fraction of
this water would infiltrate the low-permeability cap. The collection system would not
extend down to the water table and would not collect ground water moving away from the
landfill. Thus, U.s. EPA has determined that the addition of a leachate collection system
would only marginally increase the effectiveness of the landfill cap.
9.
One resident commented that U.s. EPA's proposed plan .fails to address the fact that a
large diameter natural gas transmission line crosses the nonheast corner of the site:
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u.s. EPA ReSpODSe: u.s. EPA is aware of this gu transmission line. However, the
Agen~y does not believe that the presen~e of this line will interfere with remedial
~onstru~tion activities. U.S. EPA will review this issue further during remedial design.
Prior to constru~tion, U.S. EPA will condu~t a field survey to confirm the actual location
of the gas transmission line, as well as other underground utilities that might be present.
10.
The City of Cir~levjJJe commented that 8both the sheets: :Iing protection and the amount of
riprap to be installed is not suffi~ient. given the fact that during severe noods the entire
north leg of the landfill is at risk.- The City also commented that -sheetpiling needs to be
installed- at the south end of the landfill -to prevent undermining of the riprap in this
area and the riprap itSelf needs to be extended considerably.-
u.s. EPA RespoDse: U.S. EPA will consider the need to extend erosion protection in
greater detail during remedial design. Appendix D of the FS report contains a
preliminary erosion protection analysis. This analysis identifies several areas (including
those identified by the City of Circleville) that may require erosion protection beyond
that included in the conceptual design of the remedial alternative. A more detailed
erosion protection analysis will be conducted prior to designing and constructing the
erosions protection system for the landfill cap.
4.3
Public Partlc1patioD Process
I.
Several residents requested that the Bowers Landfill Information Committee, which met
regularly during the RI/FS process, be continued during design and implementation of the
remedial alternative selected for Bowers Landfill.
u.s. EPA RespoDse: U.s. EPA plans to continue the Bowers Landfill Information
Committee during remedial design and remedial action (RD/RA). However, the makeup
of the committee will vary depending on how design and construction is conducted.
Three possible options are:
-
Federal-lead, with the RD/RA conducted by the U.S. Army Corps of
Engineers or by I U.S. EP A contractor
PRP-Iead, with the RD/RA conducted by the potentially responsible
parties (PRPs) under a Consent Decree
-
.
PRP-Iead, with the RD/RA condu~ted by the PRPs under I Unilateral
Order
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J.,,~
Under the second and third optioDS, U.S. EPA would oversee the RDfRA. The (or mat of
the Information Commiuee will be determined by the option that is chosen. U.S. EPA
expects this to occur during the summer or CaU of 1989.
2.
One resident expressed concern that the public comment period of 30 days was not
adequate and that additional time was needed for the public to review and comment on
U.S. EP A 's proposed plan.
V.s. EPA Respoase: U.S. EPA believes that a 30-day public comment period on the
proposed plan is sufficient for Bowers Landfill due to the long-term involvement of
citizens and citizens' 8roups in the RIfFS process. The public comment period began on
February 14, 1989, shortly after the release of the Proposed Plan, and extended to March
16, 1989. Most of the comments received by U.S. EPA have come from individuals and
organizations that have attended the Information Committee meetings, commented
throughout the RIfFS, and been kept abreast of technical issues concerning Bowers
Landfill.
U.S. EPA offers the fOllowing information to support the adequacy of a 30-day
comment period. The Agency conducted an extensive community relations program in
conjunction with the RIfFS. This program included 12 meetings of the Bowen Landfill
Information Committee, where U.S. EPA, OEPA, technical representatives of the PRPs,
local government officials, and citizens' 8roups met to keep the public informed of
progress during the RIfFS. During aU of these meetings, individuals from the community
were allowed to ask QuestioDS through representatives on the Bowen Landfill Information
Committee. U.S. EPA has responded to these Questions and concerns on an ongoing basis.
A draft of the FS, on which U.S. EPA based itS selectIon of a remedial alternative, was
released to the Information Committee in September 1988. Results of the FS were
discussed at a committee meeting in November 1988, several months before the Proposed
Plan was released.
3.
One resident expressed concern that the public comment period did not offer the
Circleville community 8, genuine opportunity to change the EPA's position.8
u.s. EPA Respoase: As noted above, the public has been actively involved in all aspects
of the RIfFS process. U.S. EPA has received I number of comments and has seriously
considered these commentS. Several comments bave resulted in minor changes to the
preferred remedial alternative. The~ changes include:
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.
Expanding proposed ground-water monitoring at Bowers Landfill to meet
the substantive requirementS of RCRA.
Installing additional monitoring wells south and west of Bowers landfill
Ind possible inclusion of residential wells as part of the long-term
monitoring program.
.
.
Including surface water monitoring as part of the long-term monitoring
program to verify that the landfill is not affecting the Scioto River via
surface water discharges.
Lowering the permeability of the clay layer of the landfill cover to 10-7
em/sec. This revised permeability is based on requirementS for clay layers
installed as componentS of RCRA landfill liners.
.
4.4
CosU ADd FUDdlDI Issues
I.
local residentS expressed concern about the liability of potentially responsible parties
(PRPs) for implementation. monitoring. and maintenance of remedial actions at Bowers
landfill. Specifically, residentS wanted to know how this liability would be transferred if
PRPs were acquired by other companies or filed for bankruptcy.
V.s. EPA RespoDse: Superfund liabilities are treated in much the same way as any other
corporate liability. If a company with liability for a hazardous waste cleanup is sold, the ~
buyer mayor may not agree to take on the seller's liability. The debt, however, is not
extinguished by the transfer of other assetS. Similarly, a restructuring does not release a
company from liability.
Bankruptcy may relieve a compa~y or individual of certain debts. Debts owed to
the federal government for costs incurred during the cleanup of hazardous waste sites,
however, are gjven I high priority among bankruptcy claims. Any funds not recoverable
from the PRPs, for cleanup or operation and maintenance, would be provided from
Superfund monies or by the State of Ohio.
2.
A Pickaway County Commissioner expressed concern that the county did not have the
funding to pay for remedial action at Bowers Landfill.
u.s. IPA Respoase: U.s. EPA does not consider Pickaway County to be a PRP for
Bowers Landfill at this time. If the county is not a PRP, it will not be required to fund
any portion of remedial action costs.
]9
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3.
One member of ACTION wanted to know who would be financially responsible should
the chosen remedial alternative eventually fail.
U.S. EPA Respoase: The potentially responsible parties (PRPs) for Bowen Landfill
would most likely be financially responsible should the chosen remedial alternative
eventually fail. Section I 22(f) of th'e Superfund Amendments and Reauthorization Act
(SARA) allows U.S. EPA to grant PRPs a release from future liability at the completion
of remedial action. In granting such a release, U.S. EPA would consider such factors as
the effectiveness and reliability of the remedial action, the nature of remaining risks, and
the extent to which the remedial action represents a permanent remedy for the site.
Because the remedial action for Bowen Landfill is not I permanent remedy and leaves
wastes in place, U.S. EPA would not likely grant a release from liability.
4.
One member of ACTION stated that cost estimates in the FS 8do not take into account the
potential for astronomical increases when these impermanent remedies eventually fail.-
U.S. EPA RespoDse: The purpose of the RI/FS is to study current conditions of a
hazardous waste site, to evaluate the potential effects of contaminant releases from the
site, and then to propose remedial alternatives for the site that protect human health and
environment. While conditions may change in the future, the purpose of the RI/FS
process is to select a remedial alternative that will succeed in providing long-term
protection, rather than a remedy designed to fail. Thus, the use of theoretical future
conditions as a basis for estimating costs of remedial. alternatives is not the intent of
Superfund.
4.5
Enforcemeat Issues
I.
One member of ACTION expressed concern that the potentially responsible panies were
allowed to write the feasibility study for Bowen Landfill.
U.S. EPA Respoase: Section 104(a) of SARA gives U.S. EPA the authority to allow PRPs
to conduct I remedial investigation and feasibility study (I) if the PRPs demonstrate their
qualifications to do the work and (2) if U.S. EPA oversees and reviews the work. By
allowing the PRPs to conduct the RI/FS at their own expense, U.s. EPA is able to save
Superfund monies for sites where no PRPs can be identified.
The Bowers Landfill RI/FS was conducted under such an arrangement. In 1985,
U.S. EP A and OEP A signed a Consent Order with £.1. DuPont deNemours &: Company
(DuPont) and PPG Industries, Inc. (PPG), two of the PRPs. While Dupont and PPG
20
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conducted the RI/FS. all phases of the work were reviewed and overseen by U.S. EPA
and OEPA.
4.6
Remedial IDtestl&atloD Issues
I.
Several residentS expressed concern about the adequacy of the source investigation.
Specifically, they wanted to know why the amountS and locations of hazardous wastes in
BOVo'ers Landfill remain unknown. Without this information,'U.S. EPA does not have the
technical data to support itS choice of a remedial alternative.
U .5. EP A RespoDse: U.S. EP A believes that data in the RI and EA reports adequately
support the choice of a remedial alternative for Bowen Landfill. During the RI, a large
number of samples were collected from soil, sediment, surface water, and ground water
directly adjacent to the landfill. The resultS of all samples indicated relatively low levels
of contamination, and no clearly identifiable -hot spots.- Sampling resultS from this first
phase of the RI indicated minimal migration of contaminants from the landfill. Thus,
U.S. EP A determined that a second phase of the RI, which would involve collecting
samples of landfmed material, was not warnnted.
U.S. EPA used a variety of sources, other than sampling, to obtain information
about wastes disposed of in Bowers Landfill. These sources included historical aerial
photographs, information from OEP A' files, information provided by PRPs, and
interviews with former owners, operators, and users of the landfill. A complete inventory
of materials deposited in the landfill cannot be prepared because accurate, documented
records of landfilling activities do not exist. Additionally, interviews with former owners,
operators, and users were conducted IS (0 20 years after landfilling ended. Thus, the
information obtained from these interviews may not be completely accurate.
Persons interviewed stated that Bowers Landfill accepted industrial wastes,
including barrels containing liquids and liquids from tank trucks. Some of these liquids
may have been hazardous substances. Nevertheless, much of the industrial waste accepted
by Bowers Landfm consisted of general trash and other nonhazardous wastes.
Information from OEPA files (formerly the Ohio Department of Health) states that the
majority of materials placed in the landfill consist of residential wastes collected by
private haulers in the Circleville area.
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In response to . 1978 investigation by the U.S. House of Representatives ..
Subcommittee on Oversight and Investigation, DuPont and PPO reported disposal of 6,000
and 1,700 tons of waste, respectively, in Bowen Landfill between 1965 and 1968. U.S.
EPA requested additional information from DuPont and PPO in 1988 under Section 104(e)
of CERCLA. Both companies stated that they did not retain waste shipment records from
the 19605 and that previous estimates of waste volumes represented the best information
available. Each company interviewed employees who worked at the Circleville plants
during the 19605 to obtain additional information on waste disposal from that period.
DuPont stated that most of the 6,000 toDS of wastes sent to Bowen Landfill consisted of
Mylar polyester film. PPO responded that wastes sent to Bowers Landfill may have
included defective resin products, used filter materials, resin-saturated phosphate salts,
spent cleaning materials, and caustic solutioDS.
2.
U.S. EPA received several questions and commentS related to the potential migration of
ground-water contamination south of Bowen Landfill. These comments included
statements by several members of ACTION that one reason for the difference between
RIfFS results and the 1981 findings of Burgess and Niple may, in part, be the off-site.
migration of a contaminant plume to the south. Since the City of Circleville's water
supply wells are located 1 i miles south of the landfill, residentS were concerned about this
possibility. ResidentS were particularly concerned with movement of water in the lower
aquifer at the site, and suggested that it is unlikely that water from this aquifer discharges
upward into the Scioto River.
U.S. EPA RespoDse: The RI investigated two water bearing aquifen below the site.
These two unitS are separated west of the landfill by a low-permeability layer. Ground
water in the upper aquifer nows west toward the Scioto River and probably discharges
into the river. Ground water in the lower aquifer nows southwest toward the river. The
potentiometric surface (the level to which the water will rise) of the lower aquifer is
higher than that of the upper aquifer and about the same as the water level in the Scioto
River. Thus, ground water in the lower aquifer may move upward toward the river.
However. the low-permeability layer that separates the two aquifers may underlie the
river and restrict upward movement or around water into the river. In this case, ground
water from the lower aquifer will continue to move southwest. This around water may
eventually now southward along the Scioto River, which is likely. ground-water divide.
If the low-permeability layer is not continuous, around water in the lower aquifer would
likely discharge upward into the Scioto River.
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Circleville's water supply comes from a wellfield, located I t miles south of Bowers
Landfill. A number of private wells and the Sturm and Dillard Quarry are located
between the site and the city's water supply. Two private wells, located between the site
and the Quarry, were sampled durinl the RI. No contamination was detected in these
wells. . These wells and four additional wells, includinl three wells at the Sturm and
Dillard Quarry, were sampled durinl the 1981 Burgess and Niple study. Although the
validity of the Burgess and Niple data is not completely known, no orlanic contaminantS
were detected in samples from these wells. In addition, the City of Circleville has
analyzed samples from itS drinking ~ater supply wells from 1980 to the present. These
results were reviewed as part of the EA. None of the results indicate that Bowers
Landfill has impacted tbe city's water supply.
3.
One member of ACTION stated that the remedial investigation was conducted -in the
middle of the worst drought to affect this area in the past 60 years.- He felt that these
conditions could have affected the resultS and conclusions of the RI.
u.s. EPA Response: Climatological data from the Circleville area does not support tbis
statement. Data from tbe National Weather Service in Columbus, Ohio, approximately 2S
miles north of Bowers Landfill, indicate an avenge annual precipitation of approximately
36.97 inches. For the years 1985 tbroulb 1988, annual precipitation at Columbus was
38.67, 35.04, 26.70, and 36.57 inches, respectively. These data do not suggest extreme
drought conditions, and, with the exception of 1987, precipitation in the area near Bowers
Landfill was near avenle values.
The first round of ground-water, surface water, and sediment sampling was
conducted in February 1987; tbe second round was conducted in April and May 1987; and
the supplemental round was conducted in Marcb 1988. None of tbese events occurred
followinl periods of abnormally low precipitation. The first round of .samplinl actually
followed a period of relatively higb precipitation, as the landfill was nooded in December
1986. Additional information on precipitation and river stage data during samplinl eventS
is presented in Drawinls 3-15 and 3-16 of tbe RI report.
4.
One resident asked why the ground-water study during remedial investigation was
confined to tbe site vicinity and did not study regional ground-water now. ResidentS also
asked why the remedial investigation did not include (1) testing of wells south of Bowers
Landfill and (2) installatioD and testing of wells on the west side of the Scioto River.
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. ...,)
U.S. EP A Respoase: The RI was not strictly limited to studying the site. Off -site .
residential wells, including two wells south of Bowers Landfill (between the landfill and
the City of Circleville water supply), were sampled. Samples from these wells, as well as
samples from ground-water monitoring wells, showed very linle contamination. As a
result, the monitoring well network was not extended south or west during the RI.
U.S. EPA will extend the monitoring well network as part of the remedial action
for Bowers Landfill. The extended network will include additional monitoring wells
south of the landfill, additional wells between the landfill and the Scioto River, and, if
necessary, additional wells west of the river.
s.
One member of ACTION questioned a statement in the RI report about potential sources
of tetrachloroethene in an upgradient monitoring well.
U.S. EPA Respoase: Tetrachloroethene was found in two ground-water samples collected
from upgradient well W -] 2. ContaminantS found in this well are not likely to have been
caused by the landfill. The RI report (page 5-8) speculated that the tetrachloroethene
found in these samples may have originated from equipment maintenance activities
associated with the nearby sand and gravel quarrying operations. Tetrachloroethene is a
common solvent and is widely used as a degreaser for metal machine parts.
6.
One member of ACTION asked why the RI report did -not speculate what will happen to
groundwater flow and the contaminantS the water contains should adjacent quarrying
operations reach below the water table as they have south of the site.-
U.S. EPA Respoase: U.S. EPA does not believe that quarrying activities near Bowers
LandfilJ are likely to affect regional ground-water flow. Quarrying activities are
continuing east and northeast of the site. At the time of the RI, these quarrying activities
had reached the water table northeast of the landfill.. Potentiometric surface maps of the
upper aquifer indicate that flow is west toward the Scioto River, in spite of the quarrying
activities to the northeast.
Monitoring wells east and north of the landfill will be included in the long-term
around-water monitoring program for Bowers Landfill. Water level measurementS from
these and other wells in the monitoring netWork will detect any potential changes in
around-water flow direction caused by future quarrying activities.
.
24
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7.
One member of ACTION asked why ground-water samples were not collected from
monitoring wells that exhibited elevated organic vapor readings in the well casings.
U.S. EPA RespoDse: During the RI, a name ionization detector (FJD) was used to
measure organic vapor concentrations at the top of each well casing, prior to purging or
sampling the well. This procedure was used primarily to protect the health and safety of
workers sampling the wells.
Only one well, P-6B, showed elevated organic vapor readings. This well was
sampled in February 1987, April 1987, and March 1988. Only three organic compounds
were found during these sampling rounds: benzene (2 sampling rounds, maximum
concentration of 6 ~g/L); acetone (2 sampling rounds, maximum concentration of 64
~g/L), and 2-methylnaphthalene (l sampling round, maximum concentration of 2.8
~g/L).
8.
One member of ACTION suggested that 8background8 samples for surface water and
sediment were collected from locations that could have been affected. by runoff from the
landfill during heavy rains or nooding.
u.s. IPA Response: Background samples for surface water and sediment were collected
from the east side of the Scioto River, upstream of Bowen Landfill. Sample resultS from
these locations are not likely to have been iD.nuenced by the landfill. Surface water
samples were not collected during nooding, but at a time when water was nowing from
the background sampling location toward the landfill. Past noods could possibly have
carried contaminated soil from the landfill, contaminating sedimentS away from the
landfill. However, the background location would have been affected by this process only
if substantial back-mixing of nood waters (now in the upstream direction) occurred.
U.S. EPA considers this unlikely.
9.
During the remedial investigation, the Bowers Landfill Information Committee requested
that additional deep monitoring wells be installed to clarify ground-water now direction
in the lower aquifer at the site.
u.s. IPA Response: U.S. EPA responded to the information committee's request and
required the installation and sampling of two additional deep wells (P- J 28 and P- J 38).
These wells were installed in February 1988 and sampled in March 1988. Information
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from these two wells and other previously installed deep wells indicated that ground water
in the lower aquifer nows southwest from the landfill.
4.7
[oduaerlDeDt AsseSslDfDt Issues
I.
Two members of ACTION asked why the endangerment assessment (EA) did not consider
previous sampling results from 1981. These comments focused on a 1981 study of Bowers
Landfill conducted by Burgess and Niple. Ground-water samples collected during this
study showed high levels of toluene. xylene. and ethylbenzene immediately downgntdient
of the landfill. Commenten were concerned that inclusion of these results would greatly
affect the conclusions of the EA report.
V.S. EPA Response: As discussed on page 1-14 of the EA report. U.S. EPA did not
evaluate the Burgess and Niple data for two reasons. Fint. the data were collected 6 years
prior to the remedial investigation. While these data may represent past site conditions.
the RI data more accurately assess current site conditions. Second. U.S. EPA could not
assure the quality of the Burgess and Niple data.
Superfund endangerment assessments should be based only on validated sample
results. The Burgess and Niple results were not validated and were, in some cases,
contntdictory. For example, samples collected from downgntdient well MW-2 on July 17.
1981, showed high levels of ethylbenzene. toluene, and xylene when analyzed by gas
chromatography (GC). Concentrations of these three chemicals were 66.8, 43.4, and 27
mg/L. respectively. However. when the same samples were analyzed by a different
method, gas chromatography/mass spectro~opy (GC/MS), concentrations were much
lower. Ethylbenzene and toluene concentrations measured by CiC/MS were 2.48 and 2.53
mg/L, respectively. or IS to 25 times lower than the CiC results. (Xylene was either not
measured. not detected by GC/MS. or not reported.
However. even if the EA had included the Burgess and Niple data, the conclusions
of this report would not have been affected. The data would still show a potential risk
from usinl ground water between the landfill and the Scioto River as a drinking water
supply. If the highest o( Burgess and Niple's results were considered. risk levels would be
somewhat higher than those estimated in the EA. The hazard index, renecting
noncarcinogenic risks. would increase (rom 1.04 to approximately 29. Wont-case
carcinogenic risks would increase (rom 9 x 10" to 3x 10'5.
26
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An EA based on the Burgess and Niple results would still conclude that off-site
residential wells were unaffected by the landfill. Burgess and Niple sampled six private
wells south of Bowers Landfill shortly after high levels of ethylbenzene, toluene, and
xylene were found in on-site wells. The private well results showed no evidence of
con tamination.
2.
One member of ACTION wanted to know why U.S. EPA has compromised public safety
by allowing a cancer risk of 1 in 10,000 for the site, a level .up to 100 times greater risk
than that generally accepted..
U.S. EPA RespoDse: This question appears to be based on a misunderstanding of
information presented in the EA Report. U.S. EPA has not allowed a cancer risk of I in
10,000 for the site. The EA report stated that recent U.S. EPA guidance suggests that a
target range for carcinogenic risks of 10-4 (I cancer per 10,000 people exposed) to 10'7 (l
cancer per 10 million people exposed) should be considered at Superfund sites. Within
this range, a risk of 10'6 (I cancer per I million people exposed) is generally considered a
benchmark for determining whether site conditions pose a significant risk. However, U.S.
EP A policy is to evaluate risk levels at each Superfund site based on site-specific
conditions.
In the case of Bowers Landfill, the EA report estimated that worst case risks
(based on maximum contaminant concentrations and maximum exposure levels) were
within the target range. Carcinogenic risks were estimated at 9 x 10-6 for ingestion of
ground water adjacent to the site and 3 x 10-6 Cor ingestion of on-site soils. The remedial
alternative proposed Cor Bowers Landfill should eliminate cancer risks from ground-water
ingestion. By covering most contaminated soils, the alternative should reduce cancer risks
from soil ingestion to 4 x 10-'.
3.
One resident was concerned that while the EA report evaluated health effects of
individual chemicals, the report did not evaluate the effects of combinations of chemicals,
particularly synergistic effects.
U.S. EPA Response: Approximately 60 chemicals have been identified in samples
collected Crom various environmental media at Bowers Landfill. Because of this large
number, it is not possible to identify and characterize all possible interactions of these
chemicals, whether the interactions are synergistic, antagonistic, or otherwise. The EA
was conducted according to established U.S. EPA guidance. This guidance requires that
27
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was conducted according to established U.s. EPA guidance. This guidance requires that
when chemical interactions cannot be adequately characterized, additivity should be
assumed. That is, the combined effects of two chemicals should be estimated as the sum
of the individual effects of each chemical. The EA followed this procedure. For each
uposure route, the effects of uposure to multiple contaminantS were estimated by
summing the risks for each individual contaminant.
4.
One member of ACTJON upressed concern that the endangerment assessment did not
consider the possibility .that noodinl might distribute contaminants and contaminated soil
Crom the landfill..
U.s. IP A RespoDse: Contaminants Crom Bowen Landfm, particularly those in site soils
and sedimentS, could be distributed to off-site areas by nooding. However. transport and
distribution oC these contaminants by large volumes of noodwaten would greatly reduce
concentrations compared to on-site levels. Risks 10 human health and the environment
off -site would be correspondingly reduced compared to on-site risks.
The EA estimated on-site risks at relatively low levels, even under worst case
uposure conditions. OfC -site risks, due to possible contaminant distribution by noods,
should be substantially less and well below levels oC concern.
s.
One member of ACTION stated that worst case exposure scenarios evaluated in the
endangerment assessment weren't .really worst cases.. Inhalation or ingestion of dusts
while farming the field next to the landfill and ingestion of water from ditches next to
the landfill were mentioned as specific concerns. .
U.s. IPA RespoDse: The EA evaluated human exposure to contaminantS at or released
from Bowen Landfill under probable case and wont case conditions. Exposure scenarios
were developed to renect exposure conditions that might reasonably be expected to occur
at or near Bowers Landfill. This was done to identify. realistic range of risks to human
health posed by the landfill. .Really worst cases. could be developed which would result
in greater exposures and larger estimated risks to human health than ror the realistic worst
cases presented in the EA. However, such exposure scenarios are highly unlikely to
occur.
For example, extensive swimming in or lifetime ingestion of surface water from
on-site drainage ditches is theoretically possible. Howev(.. -the ditches are shallow and
28
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filled with debris, conditions that make them unattractive as a swimmingloc:ation or
drinking water source. Furthermore, the general public near the landfill is well aware
that the ditches are adjacent to a known hazardous waste site. Therefore, the theoretical
.really wont case. exposure is extremely unlikely. The infrequent and incidental exposure
to these waten, as presented in the EA, is a more realistic worst case exposure scenario.
As a second example, regular exposure to large yolumes of contaminated dust
(generated by agricultural activities in the field west of Bowers Landfill) is theoretically
possible. Soils from this field contained lead concentrations above background levels.
The National Ambient Air Quality Standard for lead of O.OOIS mg/mS represents a safe
level for the general population. However, the EA estimated that even if all agricultural
land was contaminated at the highest observed lead concentration, a total dust
concentration of IS mg of dust per cubic meter of air (mg/mS) would be needed before
lead concentrations exceeded safe levels. It is highly unlikely that such dust
concentrations could be generated for any length of time, and agricultural workers would
be exposed only intermittently. Exposure of off-site populations would be ev.en less
because dust concentrations would decrease during transpon. . Thus, as with surface
water, theoretical .really wont case8 exposure to contaminated dusts is highly unlikely.
6.
One member of ACTION asked why the endangerment assessment ignored the possibility'
of southward migration of ground-water contamination.
U .5. EP A RespoDse: The EA stated that off-site residential wells or the City of
Circleville public water supply wells have probably not been affected by southward
migration of ground-water contamination from Bowen Landfill. However, the EA did
not ignore this possibility. Table 3-1 of the EA presents water quality sampling results
for Circleville's water system. These results, collected t)etween 1980 and 1987, show that
water from Circleville's wells is of high quality and has not been affected by
contamination from the landfill. More recent and extensive data from 1988, unavailable
when the EA repon was written, confirm this conclusion. Sampling results from
residential wells south of the landfill were also presented in the EA report. Samples
collected from these wells in February 1987 showed no evidence of contamination.
".8
Other . Issue.
1.
One member of ACTION wanted to know why the size of Bowen Landfill was listed as
80 acres in 1980, but only 12 acres in'subsequent reports.
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;. ilJ,
U.S. EPA RespoDse: The J2-acre figure refen to the area where wastes were deposited.
This L-shaped area. shown in various site drawings, is approximately 4,000 feet long and
J 2S feet wide. The 80-acre figure ref en to the entire site area, including the landfill.
drainage ditch to the east. and the agricultural field to the west. This area will be
enclosed by a fence as part of the remedial action.
2.
One member of the community expressed health concerns about .a higher than normal
inc:idence of sickness. near the landfill. Another member of the community asked
whether U.S. EPA 8has done any studies to see if the incidence of cancer and leukemia in
the youth of Circleville is greater than in similarly sized towns elsewhere..
U.S. EPA RespoDse: U.S. EPA has not conducted any epidemiological studies of this type
at Bowen Landfill. These studies are normally conducted by the Agency for Toxic
Substances and Disease Registry (A TSDR). Based on S':!perfund AmendmentS and
Reauthorization Act of 1986, A TSDR is required to perform a health assessment at each
Superfund site. The health assessment is conducted independently of U.S. EPA's EA and
is a preliminary evaluation of risks posed by the site. Depending on the resultS of this
assessment. A TSDR can conduct pilot studies of health effectS for selected groups of
exposed individuals or a full-scale epidemiological study of exposed populations. A TSDR
maintains an office at U.S. EPA RegioD , headquarten in Chicago. Questions on
. .
A TSDR's role and on epidemiological studies should be directed to Louise Fabinski at that
office. She can be reached at (312) 353-1221.
5.0
REMAINING CONCERNS
U.S. EPA was unable to completely address several issues during remedial planning
activities associated with the Record of Decision. These issues and concerns are summarized
below.
Details or tbe IrouDd-wlter lDoDitoriDI prolrl.. u.s. EPA's Record of Decision
provides detaHs on several aspectS of the ground-water monitorinl program. These details
. include approximate locations of new wells, the list of chemicals to be sampled, and the sampling
frequency. Additional det3ils. including the exact number and locations of new wells and the
wells to be included in the Iround-water monitorinl program, will be developed during remedial
design.
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Respoose plaa ror detectloa or cootamioaats la moaitorlal wells. Concerns were raised
about the lack of a response plan if monitoring wells show increasing levels of contamination,
once the clay cap has been installed on Bowers Landfill. Major issues included the contaminant
levels that would trigger a response, the nature of the response, how quickly the response would
occur, and who would be technically and financially responsible for the response. U.S. EPA has
addressed these issues to the extent possible in the Record of Decision. Additional details will be
resolved during the detailed design of the site remedy.
Operatloa aad maloreDaace plaa ror laodrm cap. Several residents expressed concern
about procedures that will be used to ensure the integrity of the landfill cap. In the Record of
Decision, U.S. EPA has provided a general description of operation and maintenance
requirements for the cap. For example, the cap will be inspected quarterly, and repairs to all
significant damage will begin within 30 days. Additional specific details must be determined
after the cap is designed and constructed. Examples of such details include inspection methods
and reporting procedures.
Coostructloa or a react arouod Bowers LaDdrill. Residents requested that a fence around
the Bowers Landfill site, . component of the selected remedial alternative, be constructed as soon
as possible. U .S: EP A will construct the fence on a priority basis during remedial action.
However, the Agency cannot provide a specific schedule for fencing the site at this time.
CootlauatioD or the Bowers LaadrUlla(ormatioa Committee. Several residents requested
continuation of the information committee to facilitate citizen involvement in the RD/RA
process. U.S. EPA will continue the committee. However, the exact makeup of the committee
will depend on negotiations with the PRPs. The results of these negotiations will determine who
will be responsible for design and construction of the remedial alterative, and, thus, who will be
on the committee.
31
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APPENDIX A
.'RllTIN COMMENTS ()N
THE PROPOSED PLAN FOR
BOWERS LANDFILL
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;
CommfDts Submltttd .t the
Public MttUII 01
February 28, 1989
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DuriDI the Public Commeat Period
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~ec:o Regarclli:g Bower's Landfill Cleanup
To: U.S. Environmental Protec:Uon Agency
From: JohD Payne. Area Resident
1665 \\'iDding Road. Clrc:eville. Ohio 43113
~y n~e is Job.:l Payne, and I live in Clrclev;lle Township approximately 1/2 mjle
north of tbe City Lim.iLS. The pw-pose of this Jetter is to state my feelings with
respeC't to tbe options available ~o the USEP A ud the USEP A's preferred option
{or cleaniDg up tbe Bower's La.ndfill Site.
The ~ recently reported tbe consideration by th~ U.S. EP A oi r.ine
cJeanup options for the Bower's Site, ud it also identified the OPUOIl prefe:red by
the V.S. EPA. The purpose of the reponing was to make public nouce of the issue
and of a public beariDg to be held at 7 p.m. OD February 28 in Circlev;Ue. I
respedUlly request that you accept my commentS as pan of the record of the
February 28 meeting.
.
To respocd to this issue and the cleanup options presectec1.. I wouJd like to begin by
focusiDg oc the issues that appear to be realistically open to discussion. To do that.
I think it makes sense to eliminate options 2. 3.. and 9 from considerauon. These
options reponedly do not comply with Ohio's Ja%2dfill closure standards. I assume
there was a logical explanation for incJuding these options. but from a practiQl
standpoint it does Dot maJcesense 10 discuss them. OptiOD 1 is automatically
eliminated as it is provided only as a basis of comparison..
The remai.n.i.ng options 10 be considered are cumben 4, S, 6. 7, and 8. \\'it.'Un tbese
opriODS. the following manen appear to be the major dif!erences which deserve
fu:"tber exploration:
. Cost
. Covering
. Drainage
. Flood Control.
I assume the issue of cOst is very difficult to isolate. After all. I do DOt believe tha:
we bave had a great deal of experience in aCtUally c1ea..niDg up ba.zardow waste sites
as opposed 10 stUdying them. I am suggesting simply that cost should only be
considered m a very general natUre UDW evidecce is presented which justifies more
con.5decce m tbe numbers. -
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The cboice of a covering mecbanism esseI)tjally consistS of tWo options: 1. A 24
incb clay cover UDder a 24 incb layer of top soil. or 2. The same as tbe first option
except a synthecc membraJ:Je is installed over the clay a.cd UDder the top soil. The
U.S. EP A prefers the clay cover only optiOD. I believe that the fact that the
syntbetic membrane option exisu suggestS that it is a safer. more effeCtive method
for covering the site. Therefore. without consideration of cos~ the preferred option
(or area residentS is simple . ins~ the membrane cover.
Drainage options range from a simple drainage ditch with a new corrugated me:~
pipe to a leachate colleCtion a.cd gas venting system. The drainage pipe option
sbould u.cdou btedly be much less expensive. This is the option preferred by the t.: .5.
EP A However, seven) questions are raised by the simple availability of the othe:-
options. F'irs~ wbere will the drainage ctitcb take the runoff"! Does it matter'? Sex:.
what is the cost estimate for correCting a problem ten yean or so from now if the ga.s
coUec:tioD problem becomes serious? What are the possible bealth consequences to-
the Ciry? Finally, in wbat circumstances bave ga.s venting and leacbate colleCtion
systems been recommended and bow do those circumstances differ from tbe
Bower's Site? Again. the option most wanted by CU'cJevi1Je area residentS is simple
. constrUct the most sophisticated drainage system possible.
~
The f]ood control issue pertains mostly to the decision of wbether or not to build a
diJce to protect the site from the. $ciOto Rjver. The U.S. EP A does not prefer t.b.is.
Building a dike wouJd maease the cost of the cleanup considerably. Agair..
bowever, the fact that this option existS suggestS that the construction of a d.ike
improves the cleanup to some degree. Once again. without consideration of COStS.
the preferred option for area residentS ought to be to build the dike.
It is apparent that the U.S. EPA bas opted to recommend a cleanup procedure that
meetS the minimum Standards aJJowed by the Superfu.cd law and costS the least to
implement. This indicates to me that their primary decision point is money, whicb is
the lea.st imponant consideration (I bope) for area residentS. This difference
probably encapsuJates the conflict that I believe will exist at tonight's meeting.
Moving away from wbat appear to be the readily apparent discussion pointS. I would
like to make some commentS about my desires for the final option seleCted. First.
with respeCt to the DOtice in the &r:ild. it is stated that. ~ost contaminantS were
deteCted at levels considered safe_. This evokes the obvious questions concerning
wbo did the testing and. more imponamly, wbich chemjcaJs were found to be
unsafe. In addition to that rather frightening statement. the Doti~e assens th:1t. -me
endangerment assessment indicated that the overall risk posed by the site is low: It
goes on to say. -rhe landfill does pose a threat of fuTUre contaminant rele:1.Se.R
These statementS concern me.
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I assume the more exteasive the cleanup operation is. the lower the risk. U the EP A ,
is asking what level of risk we are comfonable with. the answer is. of course. the
least possible. I a1so assume that the threat of futUre contaminant release is
lessened with each additional cleanup measure adopted. Again- we are naturally
most com!onable with the cleanup option that leaves us with the le:1St threat
possible. 111is logic sbouJd prevail among Circleville area residentS. and it son of
begs the question of why we' are having a bearing process at a11. Are we to believe
this is a genuine oppommity to change the EP A's position?
Just in case the EP A is listening. I wouJd like to put this sitU anon in a more personal
perspeCtive. F1m.. my wife and son drink CircJeville water
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It is time for all ordinary citizens to stand up aDd fight. It is Dot what we ought to
do; it is wbat we have to do. We must push (or the most comprehensive cJeanup
possible. As a persoD like many others in this area wbo loves Qrc1eville. !be truth
behind this issue tears at my bean. allow the Bower's Landfill Site 10 show
dangerous levels of leakage in t~e futUre. and CircJeville will die completely. not
partially. .
'"
.
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. ...ft'-
:.o:-ge~-:. ::.~:I
:;S~A ~:.:r. 5
23' Sou~: jea:born
:~~:Li~.Ill. 60604
'sa: "I Nel:.,
3ec.u.e 1 have liye4 ~ the area called !overs Lan4f111 ~erOr8
AnT ~~~~g began, ~ a= great11 conc.r.ned acout clean up being den.
cor:.c~l1 t=r ~rotect~o: or tne ~eeple ~ tbe ij~va1 :o~tl area.
~iltr1:~ So~l .:~ Va~er reprelect&tlve MarE Sc&rpi~~i presente~ vali~
con!lic~tng .videnc. about .ro~dY&ter flov Ofr-8~~.. ~h. £Pi ::.~
not .~ud1 groundvater rlow D~~8~d8 ~h. 1~.d1&~. area of ~b8 Sl~. and
couli b. =aktng a .erlOUI tDacc~t. .'Iumptlon about pot.ctlal :-:'ICI
~e ou: vater .up~11.
Xontor~ vell1 Iboul~ be 1:.talle4 be~ween the lite and c1~1 vel~..
P~V10U' '1It1ng at 'b. I~~. .hoY.4 high l.v.ll ot con~amlC&tl 1n
l.&c:&~' an4 groundvat.r in 1980 and 1981.
.
EPA hal not d~ll.d into thil I~t. to d.'.rmtD. thl 10ca~ioD ot
Yal'UI but i. ilropo'~ a rem.~ to contaU1 .olft.'h~. 'rhil Il~.
flood' r~~u.nt11 which pre.ent. ~reat ~ot.nti&l tor contamiDant
!liiration IU1C. it. cll.ure ia 1966. EP.&. .bou.l4 req.uir8 tllt~
t~ther out trom the .1'. UD'il contam~tl are 10catl4 11 DOt
10catl4 at thl lnit1al tilt .1tl..
It no turth.r ~'Ittnc i. ,oine to be.conductld at 1.a.t a flood
~:'Ot8ctlon 4i.k1 .how.4 be a.tallid.
S1n:e 1P1 admitl that it lover. L&c4t11l ba4 op.ratld atter nlV
law. h&4 bleD put 1Dto IttlCt l' wou14 bl 8Ub~lct to Itrictlr
cllanup req.u1re:lct...-, Dot U88 thl.1 DIV req.uirem.ct. OD 70ur
own to protlCt tbl 4ri ~r ~r watlr ot tbl p.op11 iD C1rclev11111
If ou.: local and Itatl laeUt.h 4lpaZ"tmlDt8 11&4 40ci tlalir .1ob .
Itart1D8 1D 1958 thl r80lct tl.tiDe &cd tuzthlr '1"iDe would. cot
be DICI..ar:r cow. P11..1 40 a complltl ~ob ""I"L
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Ann Short
P .0 . '10. )01
ClroleYllle, Ohio ~Jl1)
-
Me. O.Ol~.". 1.18.
U«JEPA ..slou 5
2JO 80uiD ~arborn
C.hioaco, .111. 61'604
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GF\AlC CIRCLEVILLE JUNIOR WOMEN'S CLUB
CONSERVATION COMMITIEE
~1ar=h , 2. , 9B9
;'.ar ~s. Se"1ms.
r1ea5e take note t~at as a member or the :ircleville Ohio
:o~~nity, I am very concernea about the ~ro~osal ror the
c~ntiin=ent or the Bowers Lana:ill.
I have worke~ with a number
or the ~eo~le wbo liv8 close to the landfill and they all have
nc):~ing looa to 181 about the area.
lhe1 also seem to hsve a
~
hi;her than normal inci4ence of sickness.
It this is a~e
~irect11 to the landfill I cannot say tor certain t~t
trom what I have rea4 on the topic, fOU dO not knov that it is
not making them more at risk. .
I urge fOU to 40 ever1t~1ng in lOur ~ower t~ make the
clean-u~ ot the siSht, tbe toughest P088ible.
In the lens
run, it v111 be cheaper to do it now than to have to pa1
to do it again later.
It will al.o ce cheaper 40 tbe best p08.ible
job now, then it vill be to pal tor tbe 118dical bill. lncurred
down the road trom the re.ident..
rhis i. the on11 America" we bave an~ to de.tro1 it bJ
careless dumping and then to not ta~e eve~
.e..ure to correct
our mistake 1. real11 Itupid.
it the1 can't drink the vater'
Vhat are we leayina our children
-
~.L
H. Pat ~halen-Shaw
@I"IIC"f"W~
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C; CIACUVll.II. CJH -'88
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Oeorgette Nel1118
USEr, Region 5
2,O:.Jouth Denrborn
Chicago, JL60604
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JOHS E. BO\\'£RS
ATTO~SEY AT &.\W
:u IIoUATH \.U\,;aT STa£E't
ClaCLEVILU. OHIO .U U
"I.I.~~.'~I
Karch 13. 1989
U.S. Envlronmental Protectlon Agency
ATTM: Hr. navld Wilson CSHS-ll)
~emedlal and Enforcement Response Branch
230 South nearborn
Chicago, Illlnols 60604
Re:
Bowers Landfill site. Pickaway
County, OhlO
Dear Hr. Wl1son:
.
The following commen~ is submltted re9ardiDg proposed plan
and feaslblllty study for the above referenced ait.:
The proposed plan fails to address the fact tha~ . large
dia~eter nat~:a~ 9a5 transmisslon line crossea the Dor~heast
corner of th. alte. This line il owned ~y Colum~ia Gas
Tranamiall0n Corp. and 11 deS19nated al LiD. A-120. A aap
indicatlng the location of this line is attached bereto.
P1ea.. contact .. if you wish to diacula thil .atter further.
Yours truly,
JES I c~
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U.s. Envlr=nmental PrOtect10n Aqency
A8C;lon 5
Off1ce of ~lic Affa1r. C5PA-1C)
230 South %)eartlO:n Street
~icaC;o, %~ 1060C
March 15, 1189
o.ar c.orc;et~ t
~e DA .tw!ie. of ~e 8ow8rl hazarcSous landf111 .i 1:e have dealt almo.t
exclUSlvely with ~. C;roundwatar fl~ &t t.~e .ite and hA". fail.d to account
for th. likely .vent a food port10n of the chemical. have 8O".d off.1~.
Dua to the' fre~nt flOOdtA, of the area and due the poroua na1:v. of
1~.tr.tUID belov the d\1llp, 1.. ,ra".l and .and, th.r. 18 . lU.,h pr0bah11ity
thAt luC;. aaount. of the toxic. IlClved off.1t. ~ar. afO. S1nc. t.ha
CDnt&mlnanta ha". a half l1f. of huniUede of feu, and U8 not cu'lut.a!:lla 1n
wa tar, they .t111 8&1lt. Add1 1:10ftal1y, the.e ch.mical. tancl to !)1ncS to on.
anot.h.r 1:1 a 8pluq of canc8ntzat10n8. Wh.r. 18 the 1ov8r. laru!f111 plU; of
c:cncefttzat10n?
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~e cleanup plan acScSr..... ~ 01'1,1:1&1 ctwap .ite only and doe. n01: .af8f\a&rc!
the c11:y of C1rc18Vil1.'. vatar .upply froa thU pluq of concantzab.OD.
%t 1. a ~.tak8 to can'ider . tz.atact of the ori,illa1 .11:8 .. & .01U1:1on.
C1%cl.V1118 VAtar _118 8I8t be .at8fU&Z'ded With a r1n, of 8OftitoriftC; "u.
&rouncS the C11:y "11 f181d.. 8ftcS con.tant analYli. of the paped vatar.
Without the.. .af.fU&~, ~ phYlical &Ad .COft~c health of (:1rcl..1118
i. 1ft j8opazdy.
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U.s. En.i~onMental P~otection Agency
Ae910n 5
Office of Public Affaire (SPA-i4)
2]0 South Dearborn ~t~eet
Chicago, IL 60604
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S 1b SPA I NGHOLlOW AD
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Commrats from ACTION
(a Local Ea\'iroDlDratal Group)
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ACTIVJ8TI C'OHC!:~t:t) WI", T'CJC lca IN 001 '4IICHao,,~.
111 I'!&nd ~.d. ~.rc!.v~!l.. Oft10 4J11J
otUce Hoy,r.' I "d.ne~y 9 a.a. - .: p.a.
ott1oe 'hafte. l"lC-.'.-l~.O
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'1'0.
Erin Moran, Projeo~ Dir.c~or, USEPA Regiqn 5
PROM. Cary L. Gillen, M.D.
ACTION Repr,s.ntative on the Bowers Landfill CQmm~ity Intormation
Comm.1 t t.e
, INRE.
~owers Landt111 Superfund S1te
Comments on the Remedial Investigation Report
and Endan,.rment A...llment Crar~ Pinal Report
Jan\a.ry 6. 1988
Dated 11-18-87
~
DATE.
The tone ot the d1scuss1on ot the 1981 9urless and Niple rlPort .~r1k,. .
me as unusual. The discussion questions the validity ot ~he t1n41nc. 1n
the ~urgesa and N1pl. report and discussed the d.teriorated cond1t10n ot
the wella that .ere dr111.d 1n 1981. I have several rlaction. to that
discussion. Buree.. and'Hiple 1. known ~o me a. a ,enerally..ell r..peot~~
engine.rinl t1~ whrch Circl.vi11e C1ty has u.ed tor their ..'er te.t!n&.
If 1i~ that 'ea'f to qUI.t10n thl results ot a well r..pected fir. in a
study, how .a8f w111 1t b. to br1ng 1n question the re.ult. ot the Dame.
o and Moorl report 1n S or 6 year.? It all that 1. required 1. ap8nd1ne
I
:3 or 4 t1m.. the IIrOn~ to do that, then .e are 100k1nl at co1ne thro~h all
this aga1n in the 1990'. at a coat ot 1 or 2 81l110n dollar. to throw out
much ot what ls tound today. 8.1ng. lenerally respected firm, I also
assume that Burle.s and Nlpl. took some k1n~ ot.precautio~s that the
we~ they dr11l.d were ..11 constructed an~ secure to protect
their reputat10n and our groundwater. The condit1on ot thosl ..11. as
describe~ in thl Dame. and Moor. report is appalling. Either the1r
precautions wer. inadequat., or they w.re constructed in an 1rr.sponslble
tashion. How do Dame. and Moore'. precautions oompare in the oon.~ruc\1on
ot the new well.? Ho. quickly will history repeat ltselt? Why..hould
we not beli.ve that el.v.tec1 reacUnp ot organic, vapors tound in thole w.115
represent a serious contamination pro~lem? Th. water trom thol' w.lls with
the elevated readings was not teste~.
-1-
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:ur other major Observation abOut the Remedial =nve~tieation is tha~.'
well plaoement and groundwater tlow have oombined to pernaps miss maJor'
\
areas ot. oOntamination of the groundwater. Plow in the deeper aquifer was
founo to be close to straight SOuth, but there are no Sampling w~lls in
the deeper aquifer south or the nOrth-sOuth leg or the landfill; . thie
obeervetion alao ha. impact On tha andang8rmenta.ae~cment in that the on.
route w'ich Will expoa. large numbera ot people to a contaminant releaee
is to the eOuth where the city at CLrclevill. ha. ita w.ll tiald i~ mil..
tram the landfill. rhi. POt.ntial exposure is minimi.ed in the .ndanger-
ment asses.m.nt in .pit. at the fact that no .ampling was don. in that
'directicn and Claw rate. are £iven that would plac. any Contaminants ..
; far as ! to 2/3 at a mil. .0Uth at the landtill,
. . e Oe 11 eVe tlu..: background contaminati On at the Sci 0 to Ri v... ~ edi8811 t
probably is very bad as tOund in the Remedial Investigation report becau..
cf m~ny year. at Pollution at the river by Wast. disposal practices within .
the city at COlumbus. lIowever, the .ample. done tor background are clo..
enou~h to the landfill that they could heve been attected by run-ott tram
the landfill during very heavy rains or CloOding.
'.e otter the tOllowing Criticisms at the endang.rment A'''''..ent
havine already noted that we b.li.ve that in.uttici.nt weight i. Civen
to Possible SOuthward miaration at contaminant. in the grOundwater to th.'
Circleville well tield in the deeper aquiter. Som. at the "or.t ca..
scen';rios' cit.d .ren't r.ally wor.t ca.e.. Por exampl., the r.pOrt ~it..
. same studi.s at Pica in Chil~en a. the heavi.st po..ible axpo.ur. by
inse~tion or .Oil., but having done .om. ti.ld CUltivating "Y..lt, I
would be reaSOnably ""r. that tarlll1ng the land at the landtill COUld
easily result in gr.ater than 0.6 gm ing..tion d.pending on wind .peed
and uirection. rh. scenarios given alao don't r.view the poa.ibility
ot a Concentr.t.d exposure oVer ti... that mlSht occur it a s..pag.
woulo! occur into the clrainage ditCh and a child epent SO..e ti... wading,
sWimllling in, and drinld.na tro.. it. Ci ven a sudden release at mat.rial
durine the trequent CloOding Cited, What would b. the r.aUlting .xpo.ur.
to areas also 1100ded downstre.. aUCh aa Circl.vill.'a w.ll ti81d?
The ~d&n£ermant AsS.ssment does not'addr.sa What Chang.. ~Aght occur
at the sit. due to grav.line operations. rhes. are occuring adjacent to
the ,;!te and could cause Changes in the_groundwater lIIoVe8ent it large
quantities or gravel are removed.
.-;.
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'. )
: he !')ec~ion 01 t~.e report on cancer ri.~1Cs Give:; .: .. :~l't:et rar.ge" c;."
10." <0 10-7 a= Clgur., for rl =k of addi tlunal cano,.,.". "hey 'ry '0
hedGe by :tay1nB that 'the::;e art:' flot intended to lie "OtCc;l.:rJ~~ulc: l~vels".
but it clean-up is to these levels they will have to Ut: ilCCQPted as
'the rtHlult ot clean.up. As I understand these dlscu::i~ion:s. the "target
' 4
Ange" of 10. i. up to 100 't1mes greater than that "genernlly acCepted".
-
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In summ~ry. W. find the following:
. 1. ~e find Soma difficulties with the Remedial Investigation if
addi~ional ~.s~ing i. no~ done ~~ ~~e sou~~ 0: ~h. landfill in ~~e deap aquire.
2. Ae find tha't inadequ3te explanations are offered tor .
~ di=cr~~~ncies betwoen present test results and earlier testing done at
the ;~itt.:.
3. '1ackground levels of sedimt!nt contamination may have been
afracL~u by contaminants trom the landfill.
4. \"le find the -'target ran~e" for risk of cancer to be highar
than w~ ',Jould con8idl!r acceptabl~.
,
..~ would respectfully reque~t that consideration De civen to additional
c!eep ..ells near to the Site and at a distance to confirm the hypothesis
'that r.:ulI\..:1minAtlon has not m1~rated in a SOuthern c11r.ction 'towarc1 the
;).ret:1 of potent1ally e;reat.Dt exposure to the nearby population.
",'w \Jould also requeSt t~at sampline Continue ~etor. i&nd dur1nc the
"'~Iasi iJi 1 i ty ~tuc1y and any prOposed 'clean-up 'to protect the surro\mc11ng
1
p.a froln any migrating cont~inants not identified in the 1n1 t1al
c)(;un.l'l~tion sine. ;it dirfers dramatically trom earlier studies at the site.
La!':t 1 Y. we request that 1n 'adc11 tion to the pUblic ques'tion/an~wer
oI;l:\!t~:ll~ ~hat 'there tie a public written formal comment pt!rioc1 ot 90 days.
~ CiT',' .'wnr~ thlit publ! c wr1 tten formal comments have been allowec1 at
IItht!r ::1 t'!!':. At Strinafellow 1n California tte Feaai ~il.l ty ~tuc1y began
durirl{~ tile \Vri tten comment period for the Remedial Investi~"''tion. The
r~sj d~rlts of Pickaway County w111 be most atfected by anu have t.o live
w.i th ":ih3 t results tr-om 'the Remedial Investigation anc1 should have the
onpor~unity to submit the1r cor~nents to be part ot the formal record.
It i~ too late t.o exp~ct citizenD to comment on the Remedial Investi~ation
aft ~r th.~ Fea~i bili ty .') tudy. I r ci tiz ens ~ Conunents are ei Vt!n serious
(:otl~i\J""':& Lion. then they should be wel cOlued when they UI! the most. reI evant
:It e:~t~1a pnase of the ~uperfund proce~s.
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TO.
~CTr~rST9 CONCERNED .rT~ TOXICS IN OuR ~EI~~&OR~OOOS
111 rsland Aoaa, C1r~le~llle, On -~11~ _7_-1~_~
~rln ~ora~, PrOJe~t Dlre~tor,
USEPQ Re; 1 or. ~
FRO"':
Gary ~. G'llen, ~.O.
~CTrON Aepr.sentatl~e on the &~-ers L.naflll CO"'M~n'ty
rn~orm.'io~ COMM,"ee
Willi.. A. "'yer., "'.0.,
i
IN REI
Bo.er. ~.na'il1 S~~er'~na 5aCe
Comme...,s on t~e ReMedaal In~e.tl;atao~ Re~ort Dated --28-88
ana Endangerment A..e.....en, ~an.l Repor,
QCTION Qlt.r~.te Repre.e...t.tlve
. OA TE :
J~ne 2.
1988
.e ~ont,n~e Co be Over.nelm.a by t~e ~roe... of e~alu.tl~; .nd
re~aewan; a S~P.""una .,C.. O~r pr..e,.., .Y.'em r.lie. 0", ".d~er.arae." loItf'\o
arg~. OCp~.ln; po,~t. o~ vae.. E.~~ ~.. the ObJe~tl~e.o' "wInning" theIr
ar;~'''.'''t 0,.. Obeau"n; a C:CWllprOftll.e 'h., .all ~c:ufte ~l~.e to .ha, they ..nt to
.e~C:>fnpla.h. So..Ci8Ie. Che ObJ.~tave .1. .'..ply to preve...t the .Other .Ide"
from wannlng. An adea1 .y.tem .0~ld 'Ina 'na~st,..y 1nterest.d i" ldentl'Ylng
~rOblem. b.for. Ch.y c:a~.. trO~ble a".a 'aki,..; ~are e~ Che", before anYOP'le ge,s
,
n~r'. Q gOOd .y.t.m wo~ld have an ampar'aal ;~vernM.n' a;en~y 'hat wo~la
lce...tlfy a prObl.. a...a ... Co IC Chat the.. res~on.lble '0'" th. probl... dld
'''.a,o be., to Cak. ~a.... '0' 1C. I"'.'eaa,.., h.ve haa . .ystem i... w~u:~
Ina~.try ha. Co avola Cakin; any ...e.PQn.lballty '0... a p...ob1em .0 Ch.y a...e not
put at a... e~onOMU: cU.aa..,an,a;. 0... ras" ;.'t1".; .u.a '0... 8a"I1CC1"8
respon.lblliCy. The "'.QulaCors hav. .0 fa... '.1' a ...espon.ablli~y I"
protW~"n; Ch~ 1a."'Clfi.a ,naW.t"'I.. (potentially re.pon.abl. pa"'Cl..~ ~"'om
~"'neces.a,..y 'inanclal ha.... D.~a~.. of Che wnJu.t"i.a f.a.... O~ A"
"hy.terl~al" publ1c. 80.. hav. 'h. l~al~rc~. .Itwation 0' c:tt1l.n. bean;
for~wa to be~om. ..P."". ,,,.t"el,.. loeal a...eas '" 0"'0.'" Co adeQuat.ly OV.r.~-
the ...egulaco.... OV."'...i"8 ,~. "'..pon.lbl. P....ti... w. 0~8ht \0 A11 b. mOf
Int.r.st.a 1~ ...'n; 'hat OU'" "'a"'lo~. eOMm~n'ty prOblem. a.... solvea Q~lcki>
and eomp1.'.ly. W. ha..,. .any NO"'. ante"'.."n; .ay. th., w. ~o~ld .p.nd t"~.
t1m. t"." ~...,a..'''8 th. 15 ,"e".. of a~~um.nt. .0 ,.... ;.~.~atea O~ .penain;
Over 2 ho~.... O~ 'h. p~on. w,'~ "'."',ous ..pe...c. .~c don.'e '~.I'" t1m. ~or e~F
bene~lt. Th.~. a. no b.t'.~ .ay we c:o~la .p."a C~.C "~me ~o... 'h. b.n.~it o~
o~~ ~o"'ffl~n'ty 'hOW8~~
w. w.~. g...a"~i.a '"a, aadational .811. ..r. plae.a '" the d..~ .Q~i~....
~s .e h.d .u;;e.tea. w. "'..al" .k.P'I~al abo~t 'h. 10ea',on ana ..t.nt 0'
.a'ftpl ,,..; b.~au.. 0# ,"'. appa...."t al.pa...'ty ire fi".chng. b.t..." ~". p,.....,..t
.'~ay ana .a...li.~ on.. wniC:h ~ad i"al~.t.d h.av,.... ~on'aftllnatiO" than nas
b..n '~~na i" ,,,. P"'...ft' .tuay. w. ....maan un''''p~e.s.a .i'h 'h. a"'au..nt
that pr.v,ou. .'w~i..' ~ult. ."ould .0..hO. b. i8"O~.d b.~Aus. of pos.'Ql~
U"I8d.QUAte quality cofttl'"Ol. Th. CO.pOund. (Mi..a .ylen.., tOlu.,., .
.t"ylD.nl.~) 'ha~ ..,... ~OuP\d i" 'ho.. .'~dle. in .';ni'i~ant amo......c. are ACt
one. thai woula lik.ly 08 due '0 lab .......o~ 0,.. ..'...."al ~ontam'nat'o". The
pr.V10~. "'8.wl~. woula ..~lou.ly c:"an;e t". "'e.~lC. 0' 'h. Endang.rm.n,
~...5.m.",. au~ Co"sultAn'. a1.0 r.~l...d \h..datA ~..d ~o a.'.,...an. th.
dl....~tlo" 0' 8"'ound.at.~ ~lo.. T". aata a.... "ot totally ~on~i"c:ing '''at 'h.
~lo- 1. a.~i"i\.ly ~o the ...C. Th. .~."'.1.v.l. and ..11. are ~10.. enougn
to .ac:n o'h.~ to .ak. it dlf'lc:ul\ to s.y. Th. addlt'o~al .o...k plan .tated
t".re would b. '''r.. .dai~ional ..11s a"'1l1ed Into the deep aquife,... Only
t.o w....e done .it" no ..plana'10". As.. hav. p"'.vlo~.ly .~;;.st.d. ..11s
f~...th.r ''''08 th. .it. eo~ld b. h.lpf~1 In tnat ....;a...a.
Chapte... ~ ef the Remed~al In~.stlgataon (AI) n~te. that
t.t~~cnloroeth."e .1;"t b. ...elat.a to &etavatles at the ..nd a"d g...avel
Qyar,'yU',; Op.....tlon aaJac:.nt to t"e larldf!ll. S,,..c. It 1. a sol..,ent
-------
"
QCTIVI5T5 CONCE~NED ~tT~ T~xICS IN OWR ~~IG~&OR~OOCS
111 I.l.na ROAa, C:~"'e1."111., 0'" ...311.3 ..74-1'::..0
g.""."'.lly ~..d 1'" d"'y e1.."'ln; e1C1t"'1""9 .,.a 1,.d'.15t"'1.1 .~1:I11c:.'tl0"'5, ... dC.~Ct
t !"IAt 1 t ..o~ 1 d 11 "".1 Y OCCu,.. .cout .A",d .,..a g"'A",.l QIJ."''''y 1 ,.,; u'f"ll... t h.y ...,...
"'1:1."'lm.",t 1"'; ''It''' d"'y c:1..""1"'; t"'. g,...",.l. S~e,., c:c:.mrn.,.,t. a,.,d 10;lC c:au..
I'. tc. PA~.. and pO"d.,.. th. ,...al mot 1",. c.~ t"'c:... dOl"'; t". ...."alua'1"'8.
.... "ot. ''''a' t"'l. d,..aft c.f ,"'. ".pc....t .tat.. ''''at ..t~.1"'. .a"d a"'a
;,..a".l QU."''''Yl'''CiI ao.. OCC:U'" about tl"l. 51t..T"'. "'.pc...., al.o .p.culat.. t!"lat
tnc:... .-pc...d .....a. of "'1;'" ..at.... p.,..m.acullty '''ay a1d i,., C'I".at1n; p.,..t of
tn. "'tc,..aul1c p,.....u,... MO"'~~; t"'.. ;"'c.~"'d..at.... to t". ...t. Th. "'.po",t do..
"'ot 5p.culat. ."'at .111 happ.n tc. g,..ou",d..at.,.. f1c.w and tl"l. eo"'taMl"'Ant. tl"l.
..At.,. c:c.",tal"'. ."'ould tI"lO.. QU."''''Yl~; c.p....at1c:.",. "'.ac'" b.lo. th. .at.r tab1.
a. t"'.y l"Ia",. a~ 10c.tlon. .outl"l of tl"l. .1t..
T!"Ie RI .tat.. 1'" Chapt.... ~ t"'at th. t"''''.at to the Ci,..el.vll1. ..11
1'1.10. 1. proba~ly ""'."'y .1ignt bec:aus. tl"l. ..~d a~d ;",a",.l at the .It. i.
"'."'y pe,.m.ael. a",a r.latl...".ly ~"'co",fl"'ed, y.t .. a,... told that th8 SC10to
~1"'." aet. a. a ~a,..rl.r to ...t..,..d ml;",atlon c.f contamInant. b.c:au.e th.
liI"'o~,..c..at.,.. dl.C:l"la"';.. up"111 1""0 th. "'1"'.'" f...c.m t". 8"'0~nc:I.at8'" 2~-68 f..t
ac..",. T"a' .o~nc. fa,..-f.tch.d.
,"'. "'.po,..t co"'tl"'U.. to ac.c~m.nt "'.,..y ..11 that th. la"'dfjl1 i. flc.c.d~d
f"ec"..r,tly anc f~,..,I"1.'" that th. "c:lay 1.y...." ~r,c.... tl"l. la"'CIi'111 'Iught .10.
mc.....rne",t 1""0 th. g,..ound.a,e,.., but ... .tl11 ha"e "'.,..y l1ttl. C:OII"".",t .~out
l"Ic:.w tl"lat floodl"'8 M18"" d1.t"'1~~t. co~taMl~.~t. ana contaMinat.a .011 froM
tn.la",df111. Th. Er,da",;....,"."" A.....m.".t al.c. gl"'.. 1ittl. .pac. to th.'
QU..tlc:.~ - ."'.'1"1 thou;", .hat.",.", 1. dc.n. to th. .1t., it i. .af. to .ay that
1t .111 co,",t l"'u. to c. floOd.d ",.,..y f....qu.",' 1y aft.... ao"'. .,.....ay i. pe,..fo...m.a
Cotn tl"l. .lt8.
.
~. fou",d 1t ...".,..y 1"".,....t1"'g tl"lat the E~da~g.,..m."'t A..e..m.n, M.de a
--4c1. .:', P"'OPc...d .C.I"I."'10. 0' Ulpact 0' ou,.. .1t. c.' p......"'t .nd i'utu.,..
da~g."'.. Qf the 1e .c.",arlO. .it.d, 7 ..,... Clt.d a. pO..1bl. aa",g.,... to
",...c,.e~tlo"'a1 u..r." oi' the .1t.. Th. RI o~cu'"."'t.d u.. or th. .1'. by
1'1.1"\.,.,,,..,,, ar,d u..r. of al1-'.,..ral'" ""'.l"Ilcl... W. ha"'. atatea 0'" nu"'."'ou.
oeca.l~~. .1"'C8 1984 'hat the la"'Ofl11 ahould ha...". a f.l"lc. ..,.oynd it. A
.11111'1. f."'e. arouP'ICI 12 ac.,... I'" 1984 .oula ha",. r.duced all of tho..
.MpO.~"'.. a"'d fytu.... ..po.u..... to or,ly t"'o.. .n~ ..,... l",t.",' 0'" ~.ln; ..1'0..0
at f~r 1... co.t than a 8Ma11 f,..actl~~ Qf w"at t"'l. .tuay ~.a co., .0 i'a,...
Nc.. .. l"Ia...". a atudY that.. .till have tro~Dl. .1th, a"'d all thO.. ..po.u,....
a,... .tl11 contInuIng. We propo.. that tn. al",;l. MO.t c~.t--ff.ctl""'.
p,..oc.Ou,.. t"a' could ha...". b..n dO"'. to "'.duC. pa.t and futy.,.. ..po.u..... to
cont.,nlna",ta in the la",ai'il1 .ould c. to l1M1' ",.c"'.at10,",al ~a. of ,,,. a,...e
Oy m.a~s of,. f8nc..
w. .il1 continU8 to r.qu..' that pr~""'lalort. ~. ,.,ad. to 'est nita,..by
.at.,.. ...11., lncl~dlng tho.. 1'0'" th. Clty of Cl...cl.v1lle, on a regula... ba.l.
f(Jr "p~"c::.pr1at8 cont..1na",t. a,.,d that .ald testing s"'ould oc~u'" quar,.rly.
w. al.~ uncle....tand th.t at ot"'.,. Supe...fur,d .1t.. "'.Q'.u,...",."'. of aaf. -clean-
up" "'.",. be.'" d.'ln.d at the pOlr,t of .)I~..~,..e. W..i 11 ha"". gr.a'
d1"lculty .1th ."'y pla", ..touch propo... tc, aehle...". ",...l...."ant.",d app,..op...lat.
"'.QU 1 r.,n.nt s" ~y a ,.,atl'\."'a' 1 c.l fo...,,,ula.t t h. Cl ,..el...." 1118 _11 '1el da or
"'.."'Cy ..11..
. 1"" ~umm.ry, .. 1'1 nd tl'\. Rt a"'d E""a."tlil.,..",~,..,t Assessm."' flawed, ,
"'aOIo!'QI~.t. and ~nacc:epta~l. by the ce,r.tlrluea atte'''pts tc::. ....k. the "'.'!Iu1t. f1t
'at the regul.to,..s and ,..sPCof'tS1ble partIes .a,.,t te:. do .:.... not do to the SIt.,
by a~ attempt t~ Ml~l"'lze MaJo", p,..Ob1.ms tl"l...,..t1~g c:1.a",-yp at the .1t.
o.c.~."1r they de.n't ""'0. ."at te. dCl abc.ut It, by."', att.Mpt 'Cot ml"'l"'l%.
-=~, c' t.-. .."".\1'1 f'-)Qntf'r.\,..g '1.;.(".1 re~Ir1~,.,tS. .,..d Oy '~d. .1tt."'l"'t teo ,.,1"'lMlze
'I J-, i<: '!
i.V ! ..... I J ;)
-------
'w"'.'-w
.'. '-''-I~
"'Co. -.;I"" CU "''''1.; I.. iJ =
4074-1':..0
.-
111
I.lane ROAC,
c: ~ ,-c: 1.", ~ 1 1.,
UM ..3113
I.-
p'-~QI.m. ~o ."'Ola p~~tlnQ t~~ MuC:r'\ ~c:~n~M.~ ~t,-.s~ ~n ~". '-..p~n.1Ql.
pa'-C1... W. hA"'. mAny 0' th.S~ .aw. c:~nc:.'-ns. O~t .~t.MPt1n; to t1ptO.
.'-c.~',a th.se .,...s ..111 c.r.1 y '-.CUC:. C'I.I" .cn 11 t Y t c. sed..,e the p,.001 ems .t the
lilt. te. the I:»..t 0' O~,. aI:»111t1.". T"'At c:.:.,.da I"I~,.t O~,- c:omm"''''lty, 0...,.
lr'duSitrl.., and ou,. l.gac:y tc. fu~u'-~ ~.r'.'-Atl0".,
TI"I... ,,"ltten ,.emar.s .,-. to Oe publlSil"lec -~th the Final R.M.alal
Ir,,,,..t 1 gat lon ".port .. ag,...a upor, 0)' ,.,.... ;.P"P"l f.p" P'4all, USE~A R.;10n :.
c:c::
VAle.... Ad.mk...., USE~Q R.glon ~
Alc:hard Shank, OE~Q Cl".C:~O"
G,...,.,.no,. A u:l'la,.a C.l..te .
S.nato,. F,.ank R. La...tenc.,-g
Att",.,..)' Ger,.".l Ar.Cne...)' C"l..c,..~z.,
~l~ka..ay Co...nty Comm1..lon.,..
St.phen Le.t.,., CCMW
Rep. ~lke De.l~.
Se~Ato" ~an LOhg
Rep. ~\ke Sheemake,.
"'ayo,. "h k. Log.,..
Senato,. JOhn 018nn
S.~.to" Mo..a,.C ~.t:enba...m
J,. ,
~ /).J-S::
J
-------
':'C-;.'::75 :\JNCE:=NE!) \.0.117;" 78'tj:5 :'J ~,:_IC;
:l: ~s:~"'o 1=:~.ClC:. ':1r'~levllle. u~ ..ji.3
'.E: S~E-O~"'GC= S
- -; .. - i ~ '- ,,.
-
~~~ ~~~~e~~ = ~~~~~~ b~~9!111 ~~e~~!~~g ~1~~ ~~~ll~ ~~~!l~g
:~~~g~~L ~~~!~ 1~~ l]~~~ Z eL~~~ ~!~~l~~lll~ ~19~ ~~C~~l ~~!~!~~!~
,~~~~: QCTI0N. ~74-1~4~; Sc~~~so~r~~~~: ~~~1 T~r~~r. 3e3-a17~ ~~c
-:v 1.:... r;111~",. M. D.. ~74-21~G '='''' 474-~e18 0:'" ~74-531213
/ 'l~d t~~ R@M@dlI11 I~v@stlQ~tl'='~ (RI) ~~d E~dll~gerM.~t
;es'S",~,.,t f"lll"'~d. l"'~d~o'.J.t~. eI"'d ',''''''''~~~ct.:!lcl~ by tne ~.:''''t1rl','~tI
e~~ts t~ M.k~ tne results fit ...n~t tne regYl~t~",s IInd r.so~nSl~le
't..les wllnt t~ d~ ~,.. ~~t Co t~ tn~ ~lte. by ~~ ~tt~Mot t~ MinlMl:~
,:.,- o'.C 01 .'ltS t nw.,..t 1'" g ~ 1 ..,. "'-',1 C "" t t ~" 5 1 t e be~ ~ '.IS. t n.y do:>r,' t '" ,.'-:'...
It t~ do aboyt It, by IIn att.rnct to M1~lMl:. n.:~'ds t~'av~1d
cnt."'lr,g 1 O:'C=I!\ 1 ,-@slder,ts. IIr,d by ~,., att.'''ot t,,:, '''i'''oi'''i:. ~"'c'bl~'"1IJ t-:,
.'lC c'.lttlr'9 to:'-:, ''''.1c=n ec=c.r''':''"ic= stress ':'''' tne "~so~"'sl~le oll,'f;1~5. i'-'e
.1~"'1~g IIr. e~.Mc1es of tne f1.wed l~gl~ c=~nt.1~ed in tn. t...o
)~,rt . :
1. w@ "'.'''1I1ro '.1ni'''o,...e5Sl!d ...ith tnl! a,...g'.nll.r,t that orI!V1-:".IS G~I.ld1P.5'
~'.tlt. (OE~Q ,r, 1'380 a"'d Etu,'gl!ss & Niole 1r, 1'391> sh'=".Ild se:.'".",=,,,, be
,~r~d b~cay~. o~ c,=,.slble l~adeoYate ou.lity c~ntrol. Th. c~~c~y~dw
.Med ~ylene.. tolYen~. ethylb.~;e~e) tn.t ...ere f~und in those StYd1~S
~lg~lfic=a~t aMo:>unts are ~~t ~~es th.t ...~uld likely be dUI! to l~o
-~r ~,... .~te,..n.l c=o~taMl~atlon. .
2. Sinc=e t.t,...ac=hlo,...oethene is II s~lvent u~ed in d,...y c=le.roing
:,tnl"'~ ar,d ir'dust""ial acclic=.tie:,r,s, ...e d~'.Ibt that it w'=".I1d -:'c=c='.U' ~r,
! .dJllc=ent s."'d and g,...lIve1 QUar"'Y1~g as Chaot.,... ~ ~f t~. RI stlltl!S
.~s~ they were e.ce""lMI!~ting wlth dry cl.an1ng the g,..avel.
~. The reo-:.,..ts de:- "'~t soec=ulate what wi 11 haooen t,=, ~"'o'.lr'd...~te,..
~w ~nd the c=,=,"'taml~ants the wate"" c=~ntalns sh,=,uld adJac=ent Q~.r"'Y1~9
!rati.C'~ r..c:" b.low th. wat.,. .table .s UH!y ~.v. s,='uth (of tl'\e site.
4. The data a,.... n,=,t totally c=o:>~vincinq that the g,...,=,u~d"'lIter ~l~w
d( ~it.1y t~ the ....st si"'c=e wat.,.. levels a~d well. a""e cl~se .",e:-ug~
.~ , ~the"" to make it diffieylt t~ .ay. Q. we ~ave previ,=,u.ly
!;@sted, ...el1. fu,.the,.. from the site c=~uld be helpful i~ tl'\at ,....ga""d.
::J. Ir. Chaote,.. 2 of the RI ...e a""e tt.:l1d that the Sc=iott.:l Rive,.. ac=ts
~ b~rrle'" to westwa,...d mi;rati,=,~ of c=ontam1~ants becayse the
'ynd~at.r disc=ha,...;e. uphill into the river fr'='M the gr~und...atl!'" a~-6~
.t d~w",. That sounds far-fete".d.
G. ~oth ,...eoC',..t. d,=,eument very well that the la"'dfi 11 fl,=-,':'ds
'ouently but ~eithe"" addresses h~w that f1oodln; might di.tr1bytl!
Itaml"'~nts and e~ntaminated soil fr~M the la~dfil1.
7. Of the 10 present and futu,...e d."'ge"'~ sited, 7 ....~I! sitl!d .~
51b1e dangers to "rec=r.ational us.rs" t:.f thl! .ite (fish.rml!" I'r.d
-tl!r""ain vehiel.s). We have stated on numerous oc=c=asio",. Slnce 1~e4
t the landfill should have a fenee ."",=,u~d it for this ""easo"'. The
'ql~ most eo.t-eff.etiv. p,.oeedu,.e that c=ould hav. b.en dC'nl! to
UCI! cast and future e.p~su"es to eontaminant. i~ the la~dfill ...,=,uld
t~ liMit r.c=,...tional u.e 0' the a,...e. by means e:-f a fenc=e. Q c=~.tly
deQ'Jate study was ee,.tainly not nec=essary to dete,...mi.,.,e this.
I
.
. I
In conelus1on, suc=n c=omment. and "logi~' cau.e us t~ pause and
de"" the ,.eal motive. ofth,=,.. doi~g thl! evaluating. It aCoears we
. a Syst.M 1n whieh the regulators 'e.l . resoo",.ibi1ity to pro:>tec=t
""I!~oon.ibl. partie. f,.o", the uroJ'.Istifil!d fe~,...s of IIn "hysteric=~l"
lic=. 50 we have the ludicrous situatio", o~ c=iti:.",s beirog forc=ed to
~M@ .~pert. in tnei" l~c=.l .r.as in ~""de" to adeQ~at.ly OVl!rsel!.t~.
u7 ,,.... overseeing th8 ,...esoon.ible oartie.. To tiot~e .""~und
l~.- .""eaS ~f c=onc=e,...n will only "".duc~ o:>y"" IIbl1ity t~ ~olve ~h~
clel"~ .t t~e slte te:' th. beost o:>f t:"Jr abilities. That c~uld nl.lrt 0:",\1"
Munlty. CU"" lndust"'l.S. .nd cu,.. leaac=y t~ future gen.r~t1~~S.
-------
.:.cr.Vlsrs =~NCER"',-... -. ,'" "::",1.::- ." .....'"
~ 11 Isl.ne I;.:..e. C.r.t=.e,,,,!. .rd. ,;,; 1.' -~~:~
.~: ~~J::oG"~caDS
";"-1.':'4121
TO:
E'-lr, ""o'-ar,.
~., '.:. J ti'C t Li 1 "ect .:. r".
W~c..;"I~
~ IS.' g 1 .;,,,, ~
FRO",:
G.ry ~. Gl1len, M.~.
~CTION R"~r~ser.tatlve ,,'r. t"e ~":.we,-= L.ar,ef1l!
COmmY"lty In~orMAt1on COWM1tteu
IN RE:
~.:....,-s L..r'dfI11 S'.Ip~,'f,.L".e ~ltlo:'
ComMe"ts on the F..~lbl11ty ~tuey,
D.ted ~ugu.t 19, 19GO
Stlc: ';,".0
C'-A ft Re~o'-t
DATE:
November a,
1988
~
Ou.. ~omme~ts On the S~cond draft ot. tnw Fe4Slblllty Study should
not be taken to lm~ly that ..e have .~cepted tntl fIndIngs .:.f the
R~Medlal Inve.tigation and ~nd.ngerm.nt ~5GeGSMent. We C~ntlnue to
find those ..eports serIously f1...ed In t..o Main .re.s. First, the
flndlngs a..e si;nl~i~antly dlf~erent frOM ..ork o~ne ea..lie.. at the 5lte
by5yrg..s & Nlple a"d by Ohl0 E~A ..~thoYt any .deQuate .Mplanatlon. I
can suggest two Possibilities th.t are at I.A.t .s g~od as those glven.
There MAy have been signlfic~nt l~.~hln~ wf cont.Mlnants Into the
~rour,d...te,.. at the tu..e o~ the e"'-luu- tat'.Ich.. ""'Il~h .... QUiet .t the
tlMe .:.f the present study dy~ to l~C~l hYdrog".:.1.:.g1~ factors "'elated to
the re~"nt two ye.,.. d"~ught conUltlonu, or tn" ~.r1~e,.. ~indlngs Mlgh~
hAve been related to a Mlgr.tlng ~l~M. ~, cont.Mlnants that has now
"loved -:;.ff-slte. SecOndly, \:.,..., C:ar,'.-:;.t ~ete'-r.llr,,, thAt grour,d.ate,.. flow
f'-':",I th., site is only to the west wlthc,."t AOdltlo:.nal .tudle. off-sit"
~o ~.t.rMlne wheChe.. groundwater flo.. ~n tne west b,ank o~ the Sc~oto
Rlvwr hllght be COm1"; ..st t~ ~':'mblne "lth Material ~~om the 8lt. .nd
the~ fOllo.. the river ~10. to the South to...rd the city well fields.
~tt.cned t~ my stateme"t is . letter frOl.I "'ark Scarpltti o~ our
Dlstrlct Soil and WaCer ~o~servatlon O~~lC. confirM In; that othe,..s with
tr.lnin; in .011 and wat.,.. agr.e that the.e are valid ~oncerns not
..ddt-essed 1 r, the ReIned i al I nv.st 1 g.t lor.. 5p.,cl f Ically, St.anley No..ri.'
re~ort on the groundwate,.. .1tU,atlon In the Circlevllle are. (6)
verlfles that a .outhe~ly f10w could Oceyr In this ~rea.
.
In ,...g.rd to the F.aSlblllty StUdy, S~eon~ Uraft, p"'..ented tQ
'.I!oo. 1 t Appe.t-s that onc:e .gA~ rl. AS hAI8 h.pper,ed f'-eq'"ent 1 y .~,-os. the
c:,.f.lrlt tOy, the ~~nt~a~to~ and the EPA at'e chc,':'SI rig A "~ontal nment" "'etho:.d
f~r our Silt. even t~ough the 1.w .. r.~l.ed 1~ 1364 ~~w r.QU1~e5 th.
CPA to prefer perNane,.,t reMedIes tor sit.~. A rvc~nt report by
tradltlor..l environ",en'.l grou~s .r.d the t~a:a'-CS';""5 Waste Tr..tmer,t
C~uncll (1) e...ined 7~ records of declsl~n (ROD's> prOduceCS by EP~ In
1987 .r.d 'OUnd that 'u11 .a.te tl'e.t,,,e,.,t ..1. I-ec.:.r.If'1erlcsed in only 6
ea.es,p.rtial treatment ..s ".~QMMende~ In 1~, .nd no treatm""t at .11
..a5 recommended in S1 c:.ues or ~8~ of the 5lt.,S. They ""COm~enoeCS a
~lay .:.r asphalt c:ap 'o~ .0Rle, a slu,..,'y .a11 t.:. ~ontaln some, or
eMcavatln; tne .astes .nd '-etolu"Ylr,g ther., lr. ar..:.ther land~ill cre.tlr1g a
to)Cl~ .ne"'t'y-go-rour,d ~o'" other's. We flrld .that th. present document
define. containMent .it~ even l.ss .tru~tYr.
-------
t
. .. . - r'g
--. '-" 1"-'''''"~UUU=-
'"'eag,
~ ~ '" C 11!" 1 1 1 ... ,
0,., 1;,
"'.;,ll~
"7"-1.::1t'"
.1te, ,""d flcOdlr,; 1. t,.,. It'a).;.,- e)Ct.t"r'Co\l 'Ii':;....,"!:£, .;.f ....te,- "'.""'l",g out
the lA,.,afl11, the,., the ml~lM~M ~ontAl~M~~t method "'o~ld hA"e tc ~rotect
the Slte from f100dln;. O~ly the ~ro~osed floOd dlk. would do th.t cf
the methods eXAmIned .hl~h ...as 1!11Ml~.ted beCAuse It ....S not ~o.t
effe~tl"a fo~ ou~ .1ta.
Ir, t"'.l'. ~a"le. of llll4i:' Super-fur,o !o>ltes, the Offl~e of TeC:h",ology
~ss.ss"'e,.,t ~Ubll.h.d a SUftlft'.'"Y '-.po,.t I'" .]u,.,., 1'388, (~> .hiC:h .a.
c:rltl~.1 of £PA's freque~t use of u~pro,,£'~ teC:h~ologle.. The ~ro~o..l
to ','alr,tAl", t"'e ~r.sen~ ~o".". 0,.. the 1."ofl11 .s . c:or,t.l,.,mer,t method
lS O~e ~~Ch ~~P~o"e,., tec:nnology. I Must ~dMlt SOMe dl.C:OMfO~t in
b~ln;ln; ug the POint beC:"'.I~e the O".ly .,;,the,- p,-.jpoSAls 'or co"'e~
In''ol''e a clay c.p o~ a PlA.tlC: C:.P. ~ot. of those h."e been p~oven to
'f.l1 to permanently Cont.ln at .1tes .here they MA"e been u.ed. I
de.~~lbed thl. Fea.lbl11ty Study prO~o..l to Dr. Peter ~ont.gu., .~
.~p.rt In haz.~dou. .....t. .ltes .11 O"er th. C:Q~nt~y. He b.lle..... thl.
~ou~ds Ilk. a "'a~lation of sev.r.l propos.l. h.ppa~l~~ .t .ome sites
whICh h.s b..n d.SC:~lb.d as "nAtural '1~5hlng". He thought this
propo~.l 1. the eq~1....1ant of dOing ~otha~g .hl1. ..ltl~g fo~ ~.lnf.ll
.nd floOd. to flush the C~~t~Mln.nts Into the surfA~e .na ground.ater.
So, the propo..l 1. not e"e~ .. ~o~t.a~",e~t Mathod, but. tr..tment
'"eth.:>d .p~Arently de.lgneCl t.:. '-&"d'~c:. ~.jhle ~.:.r'tA"l1nant. At the .1te by
._tihl,.g them a...ay to pa,-ts ur.kr..:....".. I",. l~e.l .tudy (7), the U.S.
PublIC: He.lth Ser"lce IS c:rltlc:.l of the c~~c:e~t th.t diluting
grOu".d....t.,... ...'11 '-.duc:e C:O:''''C:It"t,'.t 10,.,... Thuy r,.:.te that c-ften ehemi~al.
.111 Mlgrat. an ground.ater "'lthout ~hanglng ~O~c:entration .. ean
"'A~~en ,~ .~rfa~e .ate,.... Soma e.n ."en eo~c:entr.t. unCler ~.,...taan
~~rC:~M.t.nc:e., The ~o.t e.tlm.te. also do not take l~tO aeCOunt 'h.
potentlal '0,... a.trono-acal iner.as.. ...hen the.. aMp.rma~ent ~emedae.
e".ntually f.11 (:5>.
.
Th. P""OPO..l fol'" Mor'lto,.,r.g .e115 ,s ,r'.d.quAte .lth no P""o...i.ion
for ..11s f~I"'thel'" ~ff-'at. and ~ath no P~Ovlsaon for determinIng wh.n,
."'a"e, "",d ho... a".y aet ~on might oc:~u,. es . ~eG~lt of the monltO~inCl O~
wh.;. Itl1gt,t be re.pon.lbl. f':'r' th. ~Otit:i ~.f '~r.the.- a~tl";'n .t t"e .ite
.,.,.,,., .. fell ur. l' docu",.r,t"d. F.,u-the,-, tha,'v 1. r.o dvflnit 10n of .nat
1."eL5 of ~hle~ ehema~al. M'ght be 1~.~tl~l.~ a~ . ruaso~ '0,... fu~t"e,...
~~tl0n. Will~. go throug~ More Studl.S to determl~. a ne.t st.p? Th.
~PA has pr."'io~.ly acc.pted ~~c:h P"oP~s.ls f~r ",o~'torlng a sIte to
O...tect a "'a,lu""." ...athout defl",ar,g ...,.,.t . f.l1u,.. lS (~). W. '''ould
n~t rep..' that ma.tak.. ,
w. are plea.ed to s.v . pro~osal for ~lt. ,...trac:tl0n ...hieh
1 r,c: 1 '.Id.s . '.ne. as ... h."8 '-.e,;.',u".',ded s, I",C:. 1 'J84. I su.peet it
be At 1..st 1990 be'o,...e that fe~c:. aXlst.. .t the SIt.. That is
~nfort~nat., ..p.eial~y for- tho.. .ho ~nknO"'l~Qly ....nd.,... on-'lte.
..,111
In the p..t, EP~ hes ~u.had Most re~ord. of d.el.ion to me.t '
thel,. .nnua1 report deadlin., .hlC" h.~ 1.~ t~ poor- ~leanup dec1.ion.
(~). We do r,ot "'ar,t te, be .r,cther P'jC'" deClsaon st.tl.tic. If this
F.aslbl1Jty Study IS appr~"ed "'itho~t C:hang~s, loll. req~e.t that the 30
d.y p'.&blle '..Vl.... .".d ~O''''.u'nt perl.:.d ':'~C'"1t" ette.- the busy holiday
~eA~O~ (afte,... the flr,t 0' the y..ar). W.. eMpec:t our "'''ltten c:~mment.
,to be publashed "'lth th. fl~dl FltdClbl11ty StuCly -5 they .a,...e "'lth the
R~M~dl~L I~""~tlg.tlO~-
/II;.!./~~
-------
1
( '3)
~CTIVISTSCONCE~NE~ ~IT~ rG~ICS ~N OUR ~E1G~&O~~OCD5
111 151.".0 Ro.O,Clr'C:le""ll.~, I:Jrq.,;. "';11: 474-1~4~
c:c::
"'.lous QO.'''k'JS, USEI='~ Rf:!'!,jl':''', ~
Rlc:h.rd ShA~k, OEPA Dlrec:t~r
Governor Rich.rd Cel~~te
Sen.tor Fr.nk L.utencerg .
Att~rn.y Ge~.r.l A~tho~y C.l.b".~:e,
~lek.w.y C~unty C~MM15s1~~ers
St.p~.~ Laster, CCHW
Lee ThomAs, USEPA
S.~.t~r HO.Aro ~etze~CAUM
Jr' .
Rttp. "'1 k~ Ce""H".
5e~.tor J.n Lon;
R~p. Mlk~ ShoemAker
"'.yor Mi~e LogAn
S~~ator John Gle~n
~"'t"'r "'ontAg'Je
Joel ~lrsehorn, OTA
J .:oh". AOk 1. ns
MArk SC:Arplttl
&I&LIOGRAPHY
.'
(1)
Blg~~ !r~lD~ ~~~~g !~~~~, Gu~tl\I~U "r~11.~ Le.derShlp In the
Sup.rfur'.cs C 1.Anup s:lrog"A'''" , HA:..,-O.:;.I.IS WAst e Tr..t,,,.,..t Coune 11,
Jl.ln., 1966.
(.;.)
"HA:A'-CSc:.uS W.ste N.""s .07", July':::,
FounOAt10n, Pr1.nc.t~n, N.w J.r~.y.
l~aa, Env1r~nM.~t.l Res..rC:h
( ~)
"HAz.rdous W..te Ne""s -8£", Ju!y la,
FounCS.t1?n, Prlnceten, N~"" J~r~~y.
l~aa, Env1ro~ment.l R....reh
.
(4 >
""'.:A'-CSC.US W.ste N.ws .';)8", UI.:t..:.b..r- l~l. l'~uu,
~es..rch FounCSAt1on, Pr1~ceto~, New J.rsey.
c: ,..v 1 ,-or'"".,.,.t .1
( :>
8~~ ~.. 'l..~l~g UgZ l~ 5~g.~!~~g ~~i. at~g~.., Offic. of
Technology Asse..ment, Co~;r.s. of the U~lted StAte., June,
1968.
( e. )
'NorrlS, StAnley E., I~. g~~~~g~~!~~ ~J!~~t~~~ 1~ t~. 'lc;l.x~ll.
~~~~~ ei;~I~lx '~YC!X~ ~~~t~=~.~1~el Q~l~, ODNR, Divis10n of
0.Q10;1CAI Survey, 197:.
(7 )
G~~~~~ ~et.~ ,~~!.~~~~!~~~. U.~. ~ubl~e ~c.lth S.rv1~., Rob.r~ A.
T.ft SAnltAry Engl~eer1n; Ce~ter, C1nc1nnAtl, OhIO, 1'361.
(a)
~~~~~s~!~~x ~1~~x~ ~~;~~g Q~~!~ B~H~~~a. ~~~g~~ ~e~~!~11~
~!~~1~~~11.~ Qb~~~ ~~~ ~~~ ~~~~~=~~~~~lZ, C~hI.- , "'~or., August
1'3, 1'368.
I!l~~g 821G ~Icg!ill~ ~~~~1~~~11~~ gbl~. ~yt';.s. & N1p1e Limited
£ng1~.er., Columbus, Ohl~, DeceMber, !~al. .
(1~) ~.r.o".l .C~mMU"je.tlo~, Peter ~o~t.gue, ~h.D., Envlronment&l
Res.Arch FoundAtion, Prine.ton, New ~.rs.y, October, 1988.
(1 U
~~rs~nAl COMMunie.tl~n, M.rk A. ~C~rp1ttl, Dl.tr1ct
C~n~erV&tl0n1st, U~ltVCS St.tes D.~.rtM.nt ot ~gr1~ultur.,
ConservAtion S.rvl~e, Clr~1.vl11e, Qhi0, OC~~ber, 1986.
S011
1/ /J-r~~
-------
-
GJ UM"", SIA,..
o.panmenl of
AgrlC..."Y18
Soli
Con.ervauon
Service
Dr'. Gary Q111.n
Ac~1on JWp. Bcve.. L&ndt 1.11
111 Ialand &cad
C1rclev111e, Oh10, 43113
October 25. 1988
"(
o.ar Dr. 0111en,
...
I a~~.nded the Ohio BPA Remedlal Inves~i8a~ion publ1c
informAtion meet1na of the Bowerslandf1l1 on Sept. 14. 1988.
At that meet1n8 the en8lneer reprsaentlna iPA atated that
accordina to the1r atudy, the around wa~er 1n the v1c1n1ty at
~he landfl11 on tha .aa~ alde of the Sc1o~o Riv.r flowed 11"08
.aet to we.t or toward the river. It was .~pha.1zed that
aroundvatar aenerelly flow. downh!ll. Th. conclu.10n w..
drawn that any po.a1ble seepa.e from ~he Bower. landfill would
a180 flow toward the river and would th.refor. pc.e no threat
of cont..inat10n to municipal water .upp!1.e. The municipal
wella are' looated approximately 1.5 811.. .outh (downatre..>
ot the landfill adJacent to the &eloto Rivar.
.
When I a.k hi. it it va. lo.ical to a..ume that ,round..tar
ve.t of the &cloto River flowed .aat toward the river, he
atated it va. po..Lble but that no atudy of aroundwater
mcv.m8nt bad been oonducted ve.t of the river.
1 a.ked hi. turther if .roundva~er on .ach aide of the river
were in tact 8Gvin, from the upland. to the river (downhill)
wouldn't it be likely that the watar would meet at the rival"
and turn aouth or down.tre... He .tated that it wa. po..ible
but the .roundwater mevemant v.. not .tud1ed to that d.,ree.
Since.that ..etln. I have tried to re.earch the aa.ertion
that the .roundwatar in the Circlev1lle area doe. move fro.
the upland. to the floodplain toward the Sc10to River. And
that a. it approaches the r1ver it turn. in a southerly
direction with tha flow of the river.
I have been in contact with the Uhl0 Department ot Nat~ral
Resource.. Diviaion of Water. ~.ct.ion of Ground Wat.er. They.
1nd1cated that it i. COl\lDOn for t.he around wal.er to aenerally
follow .urface Water unle.s reet.r1cted by aome 1mperv1oua
layer. And that it 1e likely that the ar~und water doe. move
toward the river. They indicated it i. a180 likely that &ODe
of the around water surface. at. the river whiLe t.~e othar
pQrt.ion reDains in the .ravel aqulter unuer tne rlverbed and
DOves p&r~llel with the river. .
() TII. Soot eo....",..- S8noc8
.1 In I~' at Ift8
~ Yf\I- SI£8I ~ at AoenC"""'"
,:SQ J
'....../
-------
&
They reterredm. to several publications concernina the
.round w.ter flow 1n the Scioto River ba.in. On. 8Uch atudy
fro. the Oh10 Department of Natural Raeourc... D1v1.1on of
0.010.10&1 Survey 1e Report of Inv..t1.at.1one No. 96. "The
around-Water 81~uat1on in the C1rclev111. Ar.a. Pickaway
County. South-Central Ohio". Th1. report wae vritten in 1&75
by Stanley I. Norr1a. Hydroloa1et aa a reeul~ of . atudy
conduoted of the ,round water eupply in the C~~clav111a are..
In th1a r.port Hr. Norria .peaka of t~. principal aouree of
rechar.e into the aquifar 1n the ar.a of C1rcl.v1l1e:
,.,
"The principal aource of r.char,. to the aqu1.far
.upplY1~ the industrial well. is precipitation. SO..
precipitation entera the aquif.r within the are.
underlain by the cone of depres.ion. but moat ent.r.
up,radi.nt from the cone and flowe into it in r.eponae
to the r..1onal ,radient. aenerally the potentiometric
eurfac. in the C1rclevi11e .r.. ia hiaher in upland
area.. Con.equentlv. around v~ter movee from the uplanda
toward ~he Sc1oto River v.!ley. Thia component of
reohar.a. DeVin, in r..ponse to the r..1ona1 .r&4ien~. .
1. retarred~o hare a. undertlow.
.
Where the 8&n4 and ,ravel d.pca1ta are aeparated by a
ae.1oonf1n1na bed. water froe precipitation r..cn.. ~b8
well. attar 8Cv1n. downward ~hrou,h the ..e1cont1n1ft8
bed. Or. water aay enter the lower .quif.r d1rea~ly ~
are.. where the aemicanf1n1n. bed 1a ab.ent and maye
latarally ben.ath tha ..m1confinin. bed. Water .180
entera the aqu1!er froe the Sc1oto River by influent
aee~. where the water table 1a below the atre....."
After talk1n. with the Diviaion of Water and atudyin. the
report. available. I believe the saf. assumption i. that
hazardou. ehe.1cal waste from the Bowerslandtill do.. have
the potential of eontaminatin, downatream water .uppliea and
any landfill clean-up effort. .hould consid.r thi8 pct.n~1al.
I am . l1ttle'8urpr1sed and disappointed that the
1nv.ati.ation. conducted bV KPA did not atudy around water
flow aurround1na the landfill a8 well aa in the 1mm8d1ate
are. of the landfill.
It, ~ou hav. any qu..tions please let me know.
;?;;f'
Hark A. E:arpitti
District Conservationist
/Q(~'I'S!
-------
MCTIvIS7S CONCERNED ~:7H TCXICS IN OUR NEl~HBCRHOODS
111 Isl.nd R.:..d. Cl,..c:levllle, Onl':' ~3l13 ~7~-12~0
TO:
E,..ln ~oran, PrOject 01,..ect~r.
USEI='A R~g I ,:I'" ~
FROM:
G.ry L. Gillen, M.D.
QCTION Repr~sentatlve ~n tne Bowers L.ndflll
Community Informatl~~ COMMlttee
IN RE:
Bowers L.ndflll Supe,..fund Site
COfflMRnts on the FeaSlb~llty Study,
Dat.d February ~. 1969
Thl,..d Draft Repo,..t
'I.
DATE:
Febr'.Jary a6,
1989
Most or the comm.nts 0' our letter or November a, 1966,
C.tt.cned> still .pply to thIS thIrd d,..art 0' the F..Slblllty Study.
was ple.sed to SR. much bett~r dlScU5sl0n 0' tre.tment o~tlons. I
reM.ln dls.ooointed that SOM~ .lternative to containment ha. not been
ldentlfled for our site. Ther~ 15 better diSCuSsion of how groundwater
MonItoring might be done. There 15 .till ~~t syfficlent clarirication
~s to .n.t will h.~pen and .ho .111 be res~onslble .h.n variOUS
contaMln.nts are Identified. I will eMpe~t th~5. details In the Record
0' Declsl~n but I .ou1d have app,..ecl.ted the opportunity to comment o~
them In the Feasibility Study. W. still believe that some monitoring
""e11s r.eed to b. Install.d off-site in the dir.~tiorl of Cirel.vill.
City'S wat.r ..11s. Q~eording t~ our lo~a1 $011 and Wat.r Cons.,-vation
,.ep,.eser,tat ive (statement attached>. or.e ca",",ot determlne that
g"'~undwater flo"" frOM the. site is only to the west .ithout additional
studies off-site to det.~mlne .hether ground.at.r flo. on the .est bank
0' tne SC10tO Rive,- is ~omlng .ast to ~~mbin. .ith mat.'-ial f'-om the
sIte .nd then f01lo. the rl~er flow to the south to.a"'d the city ..11.
fields. A fence remains a ~rot.ction factor whl~h has yet to be
c" rlS t r uct.d.
I
~
The diScussion or the alternatives which mention.a ~lay ca~
c:.:.r','ec:t ly ,:Ibs.rves tnat the ca~ w'="Jld 'prc,vldlt some ~rot.ct ion from
flooding by covering tne landfill to prevent flood .at.rs from .roding
aw.y the surfac. and tnat flood .aters will infiltrate less if a cap is
in ~lac:e. Tnere is no discussl~n, h~.ever, t'.garding maint.nance of
the c:lay c:a~ througn .rep.at.d flood events which occ:urat our sit..
bellev. that the ~osts of maintaining a ~a~ and ground ~ov.r tnrough
repeated flooding could make a flood control dlk. look much more ~ost
."ectlv.. A flood contre1 dike will also.require malnt.nanc. but not
the kinds of eMt.nsiv. re~airs that the clay cap wl11 require when it
IS ov~rrun completely ev.ry ~ y.ars Cas r.ported in this study) and at
least ~a~tial1y ov.rrun ev.ry y.ar. It should b. kept in mind that all
of the t.sting data and observations 1n t~lS rep~rt were made early and
in the mlddle Qf the worst drought t~ a'fect this ar.a in the pa.t 60
years.
I Th~ study continues t~ spe~ulate about the ~o.slbility of
"r,1al".talnlrlg th~ ~r.s.r'lt c':lv~r" as a ~ontainment strategy. . I agr.e
~hat It IS a~ idea .orthy.of speculatlor'l given th~ known ~robl.ms of
c: lay caps and synthet 1 c ft1.n1brane caps, but OI.It" site is not a ~ro~.r ~nil
I
1=' i' 9 ~ 1
-------
QCTIVISTS CONCERNE~ ~r~H T~XICS IN OUR NEIGHBORHOODS
111 Isl.r.c Rc:>ad, Cu'e:le"'11le, OM 1.:' ..3113 ,-7'--1'::'-0
for s~c:h spec:ul.t10n .1th e:ontaMln.nts poorly IdentIfIed as to l~c:.tlon
arid c:,:,r,c:er,tratlc:or.. We agr"ee that tMe,'e IS r,co r'eas.:.r, t.:. c:h.jOse bet.eer,
. c:l.y e:ag ar.d a Sy".thet Ie: rner,lbr'ar,e e:ag. They are both grone to
deter1orat10n and entIrely dependent ugon eMpert lnstall.t10n and
M.lnten.nc:e. &oth c:.n leak .1thOyt Obvl~~S .ppearanc:e, and both .111
leak everltually.
~ e:.g alQne .111 not adeQuately protee:t our sIte from erOSIon and
1,.,f11t,'.t 1'='''' c.f ..ter durl",g freC::I'.~e",t fl.:..:.ds. Q f1.:.od c:c:ontrol d1ke
would be an Important safeg~.rd to the lntegr1ty 0' the remed1al
ac:~ i or..
1
We c:onc:lude that the Remedl.1 Investlgatl0n, Endangerment
Assessr'lent, and FeaS1b111ty StlJdy ar'e fla.ed, lnadequa'te, and
unac:e:eptable. They make repe.ted .ttempts to M.ke the results fIt wh.t
the regylator~ .nd respons1ble pArt1es (PPG & Dupont) .ant to dO or not
do to the sIte. They attemgt to M1n1M1:e m.Jor problems thwarting
e:le.n-up .t the sIte bec:.use the c:ontrac:tors and the .genC:1es don't
~now what to do about 1t. They attemgt to mln1ml:e ha:ards to .v01d
fr1ghten1ng loc:al res1dents and to M1n1mi:e problems to avoid putting
too muc:h ec:onom1C: stress on the responS1ble pArt1es. We believe th.t
any c:~ntalnment plan 1S dOOMed to 'all and that suc:h plans must be
,'e1r,'c:.rc:ed to the ,.1.Munurn a".d rn.:.r'1t,=,red e:.refully to d1sc:ove,.. the
fal1~"'e wMen it o~~urs .nd sho~ld Gpe~1'y .ho .111 be fin.n~i.lly
resporS1ble when the '.ilu,..e ~~c:urs. We belleve the ,..esponsible
p.,'t1es shc'Jld be.,.. the c:~'st. o:.f c:ontalnment f.ilu,..e and m.U'Itenance
and ln c:orrec:tlng any c:ontamlnatlon problems.
c:e::
Wl11i.m Ael1ly, USE~Q
'V~l~u. Qdamkus, USEP~ Regron ~
Go",e,..no,.. Aic:ha,..d Celeste
Senator F,..ank Lautenberg
Rttorney Gene,..al RnthOny Celebrez:e,
~l~~a.ay County Commlssl0ners
Stephen Lester, CCHW
SenAto'" Ho.a,..d ~et:enb.uM
.Jr".
Rep. ~ike Dewine
Senator Jan Long
Rep. ~ike Shoemake,..
~ayo,.. ~ike Logan
Senato'" .John Glenn
C:'et er ~or1t.; ue
Joel Hi~sc:hho,..n, OT~
Jc:ohrl Rdk i ns
M.,...,. SC:Arp 1 t t i
.-
~age .::
.1/)6137
-------
. .
. . .
'. -.)
~C~:~:~7~ ::NCE;NE: wi ,- ~~x:CE
:s1a~c ;:;-ac. Cl"=~e'll. ~e.. :'hl-:'
-Zll~
:'. :WP
I\jE1~~CoOF(...OC::
~-':.:--_7...-..:.-~
''''EI'''O -0:
USE;'~ ;:(eg 1 (:Ir. ~
';';:(QM:
Cy~thl. Gl11e~. ~CT.UN
:~ ;:(E:
Eo':.""ers Lar'd of 111
Ref"ed 1 a 1
Ir.vestlgatl.:.r, t. F"eaSlbl1lty Stuc:--,
u':'7'E:
Febt"~.t'Y 28.
1'38'3
! ~i\ve several ~~n~erns ~b~ut ""nat IS beIng proposed
L.~cfl11 and the Syperfund process ~h.t has tranSPired.
f ,='r Bc'''''e ,os
The Eo.:o"".rs L~",dofill ""~s lr.~ll.lded as ,=,r,e .:,f 1'3 Ohl'=' sltes ':'1", the
Natl~~.l Prlorl~y LIst f~r Superfu~d ~le~~up In 198a. A~ong those
sltes. It hll1ld .. "'a:.r~ Ri\r,"lr.g S~I:''''e C.r p(:lte~tial tc, ~al.lse ~.r'n o:,f 3rd
""lt~ln ~~e state. The hIghest ha:ard SCOre was 'or pote~tlal
grouncwater contamInatIon. In 1'380, OEPA ~dentlf~ed toluene, ben:ene.
ane etnyl~en:e~e In leachate frOM Sowers Landfill. In 1981, Eourgess ~
Nlcle found ~lg~ concentratIons of ethylben:ene, toluene, and mIMed
Mylenes In downgradient wells.
The present s~udy has Slgnlfl~antly dlff.,..ent flndi~gs ',..om
prevl~us testing and att.Mpt~ t~ l;nore preV10us find1ngs 0'" speculate
a~~ut cro~l.ms .lth laborato,..y Quality control and possible lab
c.:ontamlnatlon ~~ samples. This logic is flawed for several reasons.
The labs d01ng the p,..evl0us testIng were both OE~Q app,..oved chem~cal
lab.:o,..atorles. Byrgess & Niple's work .as also coordinated and approved
by USE~Q Reg10n V. The kinds and amOunts of ~ontaminants found in the
~amples are not likely to have OCcurred from laboratory p,..ocessing and
~ndllng. There are at least t.o more logical reasons which are g1ven
no ~o"slderatio". Th.,..e may h.ve been significant l.achlng of
contaMlnants int~ the ground.at.r at the time of the earlie,.. studies
~hlCh was QUlet .t the time of the present stYdy due to local
hydrogeologIc factors related to the recent t.~ y.a,.. d,..ought
COndltl0~S. 0'" the ear11.r findings might have been related to a
-MIgratIng plume of contaminants that has no. moved off-sit.. Will EP~
oe able t,~ so .as11y disc,..edit tne present "'esY1ts also done by EPQ
a~pr~.ved com~an1es if c~ntamlnat10n problems occur in the fYtu"'e~
When tne Bo..,... Landfill was listed on the National P"'lorlty List
In Oecember, 1~82. the conditions at listing by USE~Q stat.d the
. l~nd~lll covered 80 acr.s (attached). No .Mplanation is g1ven for why
thIs Slt. has d-indl.d to only 12 acres. In the same USE~Q statement,
It states that in .Mce.. of 7500 tons of chemical wastes we,... disposed
c.f at the .ite. No. the present study states that ~he eMact amount of
ha~.rdous .ast. placed in the landfill is unknown, and specYlates that
It was probably a small p."'centage of the total disposed mate"'1al.
Even 1f tnis i. true - and USEPQ themselves stat. they don't know fQr
sur. - many hazardous chemicals of the kinds dumped at Bow.,..s nave the
pot.ntial to caus. harm to hyman health arid the environment in v.ry
small amounts (i..., parts pe,.. billl~~or million). Fla..d logic
again. The present report also states that the amount of ha:ardous
w.st. remaining there is unknown. .
The RI has failed to locat. and identify contaminants and is
~roposlng containment while at the s~me time acknowledging that the
~cation and Quantity of .astes a,... unknown. How ~an one contain
something without knowing the location and Quantity to be contained~
It sounds like a stab 1n the dark to me. Qccording to an O'fi~e of
Tec~"ol~gy ~ssessment report o~ June, 1388, which ass.ssed the
Superfund Implementatlon, one crltlC1SM IS that~ "It IS not uncommon t~
~a!;le 1
.
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rsl.",',c :;.:ao. ;:l,'~levl ~ ~e. O!"'q'='
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declS1~n M~Oe wlt~~ut ~ny tecMnl~~l
::~ta t.:. S'.Jppo:.,'t It..''
" The Er,dar.ge,.,ne!"',t ~ssessrl'erlt lS I",,=.t relevar,t bec~'.lse .:.f the
f~11ure of the RI t~ 1dent1fy and l~c~te contaM1nants. It uses ~
c~ncer r1sk factor ~f I 1n l~,~0~. An~ther OTA cr1tlClsm states t~~t
"S,:",'et 11,'e5 c,:.mpr~nuses a"e ','~de t.:. "ed'.Ice clean'.IC c.:.st by all,:,w1n9 f!
~lg~e~ r15k t~an the 1 1n 1 Ml1:1Qn c~ncer r1S~ comMonly used ln
S~cer'und. ~ W1th th1S study, USE~A ~as comcr~mlsed our rlS~ ~~d
~ll':.wed '.10 t.:. iI l~0 t 1I"es !:p'eilt.er '.lS'" thil!"" t~~t ;er.e'..lly accepted.
~hy~ ~gal~, OTA states t~at env1r~nMental rlSiots seem t~ take a cac~
seat to c~nstra1nt5 1mposed by seek1ng fundS fr~M responSible partles.
USEPA and OE~A have ch~sen to 19nore a statement subM1tted by
ACTION at the COMMunity InforMat10n COMM1ttee meeting on November a
~r~m our Dlstr1ct S~ll and Water Co~servat1~n representat1ve which
=resents V.l1d conflictlng eV1dence about groundwater flow. It lS
~~sed YPon hlS diScuS510ns w1th the Div1s1on of Water and a study d~ne
1n l37~ by Stanley NorrlS for ODNR, Divisl0n of Geologlc Survey (.9~)
ab~ut the gr~undwater s1tuat10n 1n the Circleville area, Pickaway
C':".Ir",ty. In the RI, it is deterMlr",ed tl"lat grol.lndwater fl<:.w ur.der the
slte 15 to the west downhill and tQward the rlver. However, the
ge~loglC and groundwater cond1tlons on tl"le west side of the river could
~lso be downhlll and toward the rlver Slnce accord1ng to ~r. Norr1S,
... "groundwater moves frOM the uplandS toward tl"le SC10to River vAlley"
and Moves in,response to the reg10na1 grad1ent. In concluslon,
groundwater on the west slde of the r1ver c~uld be moving east and
d~.n~111 to cOMblne w1th the westerly flow frOM the .ast and follow tl"le
river toward the south. T~is would dramatlcally chAnge the
EndangerMent ~ssesSMent and the potentiAl for contamlnAtion of
Circ1evllle's w.ll field, I l/~ mlles south And downstream. The study
done f~r ODNR was Much More .Mtenslve thAn the present Remedial
Investigatl0n whlCh relied o~ly on conditions in the immediate area of
the slte.
Out' request to do furth.r studies off-slte to better determine
groundwater flow ln lie~ Of this eVldenc. h.S be.n ignored. Tnus far,
~ur request for monitoring wells off-sit. between the landfill and the
clty'S wells has Also b..n ignor.d. What is the 1~;.!I~!~I!.g reason
for i9nor1n; this .videnc. And for not placin;tnes. wells'
. For the pr~t.ction of our community And people whO live near the
landfill, I b.li.ve thAt groundwAt.r monitoring snould b. done
1ndefinit.ly on A QUArt.rly basls for priorlty pollutAnts and l"Ieavy
Metals a5 l~n; .s there i. any Qyestion .. to the eNAct location,
amounts And kinds of contAminAnts .mAnAting from the slte. Tnere must
be provision. for monitoring All potential contaminants emanating from
the site .nd not just the few identified in the RI. This test1n;
shc,.",ld b. don. 0" the r.sidential wells n.Ar the lAndfill, Circleville
City water ..11., and monitorlng w.lls off-site betw.en the lAndfill
and the City wat.r w.11. in Addition to those includ.d in the FS. I
don't understAnd why th.r. is A r.duction in monitor;n; After the first
year. How can EPQ .ssume th.re will b. . sudden reduetion in risk
after the first yeAr with All the unknQwns in the RI' It would Appear
they Ar. relying on public disinterest with tim..
Tne FS states thAt Alternatlve 4 would comply with current State
of Ohio closure standards for solid waste landfills. Since hazardous
waste was dumped at Bowers, I would like. to know if Any of the
~lternatlv.s comply with current State of Ohio closure standards for
ha:ardous waste facilities. If not, why not?
It would appear that USEPQ has conducted a useless study that l"Ias
~~ conclusive data. Could this be because tl"le regulators and the
respons1ble parties want to avoid finding contam1nants 1" order to fit
.
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eC:'I"":",'lC st,;.ess ':'1", tt':e '-esP,:,',sl01e CeI"t1eS"' ~he"e:s S.:.,neth11",g ""'<:'1"'9
"'11~:"'\ a system that allows the .-esc.:.nSl01e p",,-ties t.:. oe du-ectly
.-esP~~sl01e f~r the wr1ti~g of t~e F5 alo~g w1th the co~tr"'ctors.
~ny ~ther system woyld cIa 1M th1S as an ObV10US conflict of 1nterest.
To fyrther add to thlS flawed 10glC, '" contal~Ment systeM lS
el~g ~roposed to conta1n un~~ow~ wastes 11"1 "'1"1 un~nown aMoynt and
'.''',I-I'''':'Wl'',l.:.catl.:.rl. Qcco:,rdir,g t.:. OT':::'. the,'e lS S'.lbSt"'I",t1&\1 e"1t~er,ce tM"'t
=~~t&\~nMent techn1~ue$ are YncrOVe~ "'~d y~rell"'ble technolog1es w1th
- =1;I"'lf1c",r,t ~"'plel,'e,..,tat1.:.r, P,',:.ble','s. AI", e)(C\I,'ple 115 tt'1e RCR':::' cl",y cap
at the Io.Il"tn,-.=,p Landf11l slte 1r. M"'lr,e wn1cn f"'11ed 1r. Septe,,'ber', 1~6'i,
before 1tS constryct1on W&\S cOMPleted. The OT':::' also states
"ln1pe,'m&\r,er,t "en1ed1es, wh1Ch p,-':'v1de less ~'-.:.tectl.:.r, t~ar, I:e",,'ar,er,t
~I",es and d~ not assuredly Meet cleC\nyp goals, are often selected purely
beca~se they are ct':eaper ln tne short run; in the long ~un they ar~
ve'-y I i~e:y t,=, be me.re e)(penS1ve." The,-e a,"e va,"l'=".IS t"eatlnerlt
";ec~~~l~gles availaol. wh1Ch could offer a ~erManent reMedy but Wh1Ch
d~ rely on specl'ic 1dentificat10n and locat10n 0' contaM1nants.
Beca~se ~, USE~Q's 1nade~uate study which falled to do .1ther,
;:::e"'''&\I'',er,t ,'emedles wn1CI"I a,"e I.,.:.,-e e)(pel",SlVe in tl"le sl"I<:.rt-te.-,n are I".<:,t a
c~~sl=erat1on 11"1 tl"le FS. The 1mpermanent remedy proposed for our site
lS generoysly estlmated to have a ll'e of 30 years. The ma1ntenance
anQ Mon1tor1ng costs 0' th15 remedy which 15 doomed to 'all, have been
grossly ynderestiMated. No provis10n lS Made as to who will b.
responS1ble for such costs 1nclud1ng any furthe~ cleanup. F~r that
M~tter, lt lS n~t clear wh~ lS pay1ng for the proposed reMediation. We
bellev8 the ~espons1ble pa~tles shoyld be finanC1ally ~e5PonS1ble for
any ~resent and futY~e costs - not our stat. or COynty or cOMmunity -
~nd .t~on;ly ~bj.ct to any condition in the ROD that woyld rem~ve that
res~on51b1l1ty and liability from theM.
OT~ also states that "E~~ is less responsive to commun1ty
,neerns about a ~.medy being impermanent than t~ inte~e.ts wh1~h 'avor
o lower cost impermanent remedy." The incentives fo~ this are to keep
the costs low for the respons1ble parties and the state that has to
prov1de 10% of the cost if the responsible p~~ti.s don't pay and
~ecause E~Q w.nts to distr1bute ava1lable funds as broadly.. P05s1ble
and wants to obta1n settlements with responslble pa~tles to reduce
=a115 on Superfund money.
~cccrding to OT~, "E~~ pushes most ROD's to eompleti~n by the end
0' the fiscal Yea~ and this kind 0' byreaucratic pressure can l.ad to
poor cleanup decislons. Typically, th.re is less than one month
betw.en the .nd of th. public comment p.ri~d and the issuance 0' th.
~OD." I was told by M.. Nelms that the USE~~ wants to make a ROD
befo~e the end of March for its Quarterly rep6rt. It's evident that
USE~~ do.. not give public comment much consideration because of the
"t1me allotted ~ 30 day. to review and comment on d~cuments that have
taken USEPQ three y.ar. to study and approve. Iron1cally, ev.n though
E~~ is 'am1liAr with th. work and documents, th.y have ~ar~ly taken'
less than ~0 days to ~eview and ~evise them themselves during the
RI/FS. Evidently, I can only assum. tbat EP~ i. Just going th~ough the
motio,"ls of "acting" like they want our opi!"lion and will give it
consideraion.
During this three year process, the only continuity has come frOM
our ~ommYnity. We now hav. oyr 4tl"l USEP~ community r.lations
'coord1n.to~, and the OE~Q pe~sonnel assigned to ou~ sit. have a150
"',hanged at least twice. From the beginning, ,=,ur Remedial P~oject
,rl~ge", EriY, Moray" has not irlstilled 1.15 with the utrnost c-:,r,'ider,ce 11"1
~ne USE~Q .s an agency. Qt one p01nt in the beglnnlng of the pr~ce5s.
we reQyested a d1'ferent prOJect d1rector but were assured by Ms.
~. age :)
6
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MS~ M~ran ~as QUal1f1ed eve~ ":~~~g~ s~e a~cears ~esl~a~t a~d y~syre ":~
f'esC':'I",d t,=, sceC:1f1C: questl':'I"'S aO':".lt ':".IP' slte at ~'.tOll= rl,eetu'lgs. ~t
p,":'st r,'eetl!"1gs, she's .~~ea"ed ~1"'C:lffe"!!rl't arid S.:.r,'ew~at $I.\r'e :'I",ly wher,
ene reads ~recared stateMe~ts. I. theref~re, request that the
~~MM~~lty In1'ormatl0~ C~MM1~~ee -!!Ma1~ 1~ e~lste~c:e d~"I~g a~y remedial
.;Ic:t l':.r, al",d r"c,r'lt':"'l1",g t.:' faC:ll ~t...te c:.:,roHl".II".Ic:at 1.:.1", wIth the c:,:.rnm'JI"'lty :.1",
:I "e 9 '.\ 1 . r b. 5 1 S.
II". c':.I",c:l',IS1':'I",. I d.:. I"..:t =el ~eve ....~...,: L.!SE;:'CI calle a "clet!\r".tC
,-er,'.dy" ;lves .:.ve'-al~ C".:.te:t1':'!" .:.1' C'.'bl:.c ~ealt~ al",ld th. .",vu":'!"Ir"el",t.
WSE;::~ has all.:.wed t.:..:. ~.1al".y ~':'lr,ts t.:. :;'e vag'.le arid 1.II",c:1ear' 11", th1S FS
loin 1 c:~ we ""':".11 d 1'1 a ve a ~ C '-ec: 1 at ec:. t!-l e .:. ~ C.:.,-t '.1 r..l. t y t .:. c.:.rttrner,t ':'1", a!"ld w~ 1 c:~
are .v1de~tly gOl~g to be decIded =y E~~ In the ROD. I Must agree IoIl~!-I
Se~.tor Fra!"l~ Laute!"lber;. !-Ie.d of the Se~ate EnvlronMe~t a~d ~ubllC
W~r~s SUbc:oMM1ttee o~ Sy~erfu~d a~d the e~vlro~me~t, t!-lat t~e EPA
"lr,stead .:.1' acti!"lg as a watc:hd.:.g f.:.r 1r.d'.Ist,.y is actl!"lg as 4;~e,u' l.~
d.:.g." TMe 1'388 OTA st.,tdy verlfles that "The S'.I~I".1'urtd t.:.)C1C: waste durnc
c:lea~uc program IS l!"1e1'fectlve, lnef1'lC:lent, a!"ld uses ~ennYlollse, pou!"ld-
1',:,,:.1151'1 r,'ethc'dS that may have't.:. be ,'ew.:.rj.,ed at great eM::;)er,se." Et':'we,'s
La~cfl11 1. evide!"ltly Just another statIstic 1'~r another OTA study
aO~ut the 1nef1'ec:tlveness of the Su~erfu~d pr~graM.
Cc::
WIlliAM Rell1y, USE~A
Valdus ~dam~us. USE~~ Regl~n ~
Gover~o~ Richard Celeste
5e~ator Fran~ Laute~berg
Qttor!"ley Ge~eral ~nt~o~y Celebre::e,
~lc:~awAY C~u~ty COMmlss10~ers
5te~he!"l ~este~, CCHW
Se~Ato~ HOwArd ~et:enb.UM
~.ge 4
..
Rep. ~ij.,e Oelol1ne
Senator Ja~ Lon;
Rep. Mi~e ShoemAker
~ayor ~lke Logan
Jr.Se!"lato~ John Glen"
C:'et er Me.r.t a g '..Ie
Joel Hirschhor!"l, OT~
John ~dk1~S
Mark Scar;u t t i
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Co~ditio~' It l;stine (C~t!~b~r 19~Zl: ~c.~rs landfil,. ,1so known 's Isl,nd
_Qold L.na'''', CCh.rs ov 'trps ,oOuto 1 nule nort" of CirdfY"h. 01'\;0. wHnin tn,
Sc,oto R'wer flo~G~l.tn. The ,it' is ,'tu.ted oyer, very pro<,uct;ve 'Qu,rer
(c.p.ble 0' 1i,lo, of 1.000 9"'0"' p,r ~'~ute) th.t ~upol;es both i~du~tr'al .no
do~\tic -at,r. In 19~e. I 9r'.f1 p,t st.rtPd o~!rltions on the site. Shortly
lhtrt.fter, . ',nOfill1"9 OQfr.t,on st.rttd ,n wniCh so,1 (rom the nf,rby pIt was
J\fd to co.er re'u\, dU~~IO 0" tOD o( the ,.isting surface. L;ttle is ,nown of
tn, tn'tial If.r, of t~. '.nOf11', but from 1963 to 1968. it .cc,pted or9'";C ,nd
;"or9.nic Cht~'c'" ,nd g,n,r.' do~'tic ,nd inOustrta' r,fuse. In response to a
:0l"9r,ss,on,1 inQui,.,. two 10c.1 ehennc.l ~nuflCtur'rs stattd th,t 1" IICt'SS 0'
7,~OO ton, or c~'~'e" -.tt. (ph",c.' st.t, '"0 concentrltton, unknown) h'd bee"
disposed 0' .t th11 ,itl. In Jw'y 1980, CPA ident,'ied tolue"e .nd et~1'b@~z@ne
in w.ter rro~ thl '.naft". Th. St.tt -or\.a w;t~ t~, current owner, wno nired In
t~g;neertn9 fir. to e."u.t8 thl sitl. The Stlte rfy;@.ed thl report .no "'ed
(or 'dait;onal tn(or~t;oft.
StatuI lJu1y 19831: The State re.icw.a tht .ddtt;on.' 1"'or~t10n from the
~"er ,na " .."ting the f;n,' Rt~d1al Action ".'ter P1.n EPA is prePlring. It
~,11 out11~1 t~, tn.'Ittgat'O"I ne'ded to deter~'ne the fu" ext,nt of "tlnup
~~qutred ,t th, sitl.
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t~e Superfund prccess.
We, the".f.:.,'., '-cr~~",~: ',..11/ '-.c.'.UIst th.at tne E<.:...ers
~.ar.="'111 C.:-',H."Jr1lty Ir".:.,-r,'.':l-:''', C.;.,.lI.l1ttelf bu e:.,.,t:.r...:c== so:. th.at
...~, tno C:~MMYn~ty, M.y ~~ ~~~rl~~d ~f .Jl w~r~ .~d
ce"el':.pnleP'lts .at the Slte. Tn. C':"",lIitte. sh-:,yld not t::e
C~S~.~ded untl1 .a mutuo111y .gre.d u~~~ d.te lS deelded by the
C:,='fo1r.,~ttee th.at it is r..:. l:,".~~t' r'C!lfce~ fo:.,. c:.:.nlt"'~r,it;t
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~CTI\lISTS CONCERNI.;C ~ITH TO;ncs IN O'JF~ N~IC,H&OR"IOOOS
111 151.~d RO.d, Cjrcl~vtll~, Onto 43113 1-£14-474-1~40
"'EMO TO:
\1.1 dus t:.d .1,.". 'AS,
US£J:.~ Regtcr,"~
D i '"ect cr"
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Rep~.s."'t.ti,'e~ of MCTION
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Ccrnl,1U r, it y J r, f w~m. t i.:.,., C';"1I1n t t t QIi1
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F.b,.u.,.y 28,
1'38'3
We h.v. bee", teld by "~'~~bara e.,.nett that the
C'.~,.,ti"'uo1tior'\ 0' the &0....,.. La"'dfi\l CC4"".lnity In,..,~"'.t:ic",
Ct:.ft1mi t t.. cfu"i"'Q the ,..,,,ed i al AC't i':;;,..~ ."'d cr'\Qoi ",g A1a i nt ."'.".c:.
""'de,- the ReC'o,.d 0' D.C'i"Si,')I'" in ""'Lle~ C':)l"lsidCl~at i.:.r'\. W.. h.v.
also:> bee,., told thAt US£~.~ has C'o;.,slCtered 0"" C'ommitte. to'be
. Y Ah." I. ....t '0.. "".'''..r. i". U on '... t h t h. "...,.... nit y . d u.. i ng '", . ..., .
t h. Sup..., urod P"""...o . '. ',' . ' . - ~~'.. .~;,..~ -'; ""~'..
W.. * h...., 0.... ... .p.~ ~~ \,1 y ;'~q .... t t h. t t h. Ifow...... .. - '" ''''~'.&r
L. r.d.. j 11 C.......unl t y r n' """;U on Co.... It t.. b. "onU n uod 80 t ". t . ';:". ~
"". t h. 0;0;;';',,,, i t y. '01. Y b" . PP'" ..If '0' 811 ;;0.. k 8nd . '. ." . ~- '. '''',0'
d.Y.1 ep...;,.. . t ,,,. . i h. -. Ib.~. it t.. -"ou I d net b.. , ,.::. . ' .,..,.;::,
d j .".na.!I. uJ1Tfl -.liiUt u..:t 1 y ~P~..ti,- I. "d." I d.er ;toY~J:I~, "7;::--:.:;
C e.... i tt .. ~tl:>. t it i. no 1 eng... . n..dR -''''' "-un i t y . ;;."'''''',' ':, :,:-:1::';' w .0:\,,": -. ',....- ~
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:::f:\mer.t ~Clr..,:':3 .:.f tnc:!' f4.:."",£',..C L.rlcfll: ~'-Ip",.f'.:r,o 51tc:.
~: IJ::; 1 1 ~
~.h~... '.~ n.pp~r'lr.g t.:. the r~':lwet.~ '..oI".df111 '~qlJf;1I0f'.'l"'Id ~..ite: The
...IS:::r.'A .:Ir.., ~..,~ p.jter,t10111yr~!Sor:'r'S:;1~lii P..,'t1t?~. r-'r.'G o1r.o D'.I~',='r.t, ~~a",~
j .:::,:: ~":O:'Mpl,'?,:~c '.\ !it 'oldy th.t co~~ .3~Pt"~'I(i.n1.;ataly ...70~, 12100 ar,d -"'v ur'oilr.llc
~~ ;lV~ U~ ~~YM~r. cO~~lu~lve l~'crmetl~~ ab~ut th@ gita. Volumes ~f
o~t~ .n.ve ~~~I"'I ge~e~at~~ ~l"'Id ~ c~~talI"'1M~nt !OeM~dy P~~~os~d whi~h stl11
;;;r":"I'~ p.:'t"'r'1:~L\l t~"~ats ""'(?!8er,ted by thl:-~ Maz.:\r'dOll'i:. waGte ~1tc? The
'JS::;:ln ~a!: a;t~tcsd :~.1t oJ fi1"al c:lg~Td.tp C:~r:l:;ll:,rl ~I] 11 !ij(@ly ~e rllad~ 0)'
I"1c,"C" ~l.
:. GROUNDWATeR iLCW. ~~c:o"dlr/; t.:. tMe ~r."(.~ ~tIJcy, :;"':"l.lrrc~Wll":e""
~l~w under" :Me ~~t~ l~ dete~Mined t~ ~~ to t~~ ~est tOWd,...d tM& 5;10t~
R1V@,... ~r,d. tMR'''CJfore. the Circ:lI'''d le rl'uni~ipAl ;,afll field l':'I:~tI!O 1. 5
'1111~~ '~':".Itn iR r;':It e)(pp.~":ed t.:. be ..ff'c-It:tnd by p,:'tent tal 9?'I:I.lrldw~tet'
~':,r,t .'1f.11 r.&\t i ,:,rl.
The tlGU'lCt 5C11! .r.Q Wi\tlil" r51'pt'@s.r.t.atl'''W, Me.t'j.f S~."P1"'~0. !.,.::o
p~e~e~tad inf~rM.tl0n frOM a ~ep.,...tMent ~f N.ty,....l Res~Yrc:e~ study
~hll:~ pr~se~tG v~lid CQnflicting RV1C9nce about g~~undwAter -low 0"-
!j\"':~,o ~i,',c:liP the ;rc'~"'d""'..te'" "'0".5 (0".:.,., th@ y~l~rlcG t.:. t!"l~ 5=1-:,t.:, Rivfi'o
.'c.] :~yo it: :5 P'''':;'O''bly Cf;".'bu',ing Pit thCJ I'lv.r .:1rld fl.:.wirlg r;Ol.ltP'l t~wo1'''d
tn~ ~ell~ ~~d tQ fill 1n the de~""e~!Slon c,...eated by tMD hoavy 1I"'1dust""i~!
P~i'''Q)r:cr :r, tt-,e Circ:l.,Vl11e ""va. Th8 USEJ:I~ did r,~t !:tudy g"~'''lr.dw~te''
flc~ Qyt~i~q the imMediate ~re~ 0' tM8 site And COyld be M.~in; ~
c" ~~ 1 e...1 G .. "'MC C I.lt. i=' t. .. SI;a.If,'pt i ~r. .. bc:.'.1 t P~lt 8'r.t i .a 1 r 1 c. ~ s t~. ~. U,... "Hit e,...
sy~~ly. They have i~n~""ed and h.v~ n~t ,...efYt~d thlS eY1d~nee ~~d hav~
?"1o:-' p]ap','5 t.~1 il"'lGt.ll rnor,ite.."ir'.g ..,811. Cfltwllvn tMR Gito .and' tho c::y
"""" 11 G. .
.
i. LOC~TION OF WQST~S. ~~.vicu~ t.s~ing .t the sitG showed hi;M
~ov5iPl!8 .:., c;'I".t.n1ini'r,ts 11"\ l~ec:h.t:e And ;""o'~ndw..4;e,. 11"'1 1'300 ar.d :;'Ol.
::'.'£'!;aEtrrt tlP~t t-~s'~ltG ;er.er&lly che,w 10.... lO".lG ':0" ::or'.tafl'lir.al"'lts. The'
E~R ~tudy ~t~t85 th8\t .bout 4~- 0' t~. wAste """.~ gan~~at.d ~y Y.~lQU~
1ndu£tl-le~ ~~&r8\ti~e in tho are., i1"'l~lud1l"'1g ~PG A~d DuPont, ~M~ng
~tM~~~o Re~~onse5 by ~~G And Dupent to . ~ed.r.l ~urv~~ ir 1~7a
lr'rd:l:L\te they d'.IM~.d 170Q1 .al"'ld E.00~ to'l"'G .:., ','atcn-i.al ,'p.ti.pe~'t~v..lv.
CtHer 1~=~1 lndustries eVld.ntly dId ~Qt r..p~nd t~ tne u~rv~y-
USEj:'Q ~.G ",ot dt'.il1ad i"t(:. the lii.tI' .:.r ir.st.l1ea f.10,..lt-:.rll"'1g wel1:;
.:".:t:'i.ce the t;:,te t.:. detp.~Ml"tt tMe lOC:oIt1t='1"'I ~f wa'3tl!~ b'.lt it; pr,:..,.:..:nQ ..~
"r'r'IC'dy t 0 ~cr,tA i '0, ~e,rn.t ro.l r,g. 01'.0 rnAjQt" sarg. i ;n.:-red hy ,: I'H S ::t i.lc)' :!:
t~.o1'- tn.. ~~ta ~l':'';'d. 1'reque",tly wh!ch has P""I1"::,!'~t"'= gre.t pr:ltentli11
~~r e~l"'Itamin.nt m1gr.t1on cine. its closure jn 19~a. In ~ 19a~ m..t1nQ
~ith l~c.l cit1ze1"'lG, Mt". Roger HannAhs of OE~~ .Ck~Qw18dged thi~
=c~~~,..~ and promi..d that "CEP~ will require testing fU"'~her ~ut 'rQm
:Me sit. u~til eont.m1~.,...ts .r. lac4t8d if not located At tne l,..itial
:est !Sites." ~here i. Mr. Hannahs now'
3. "'ETH~NE GAS. The EP~ study I"\I!Qate. any t~"II.t f,.cn1 r,,~4:~aYI. gc1';i
l~d tn~ ~e~d 1'0" Any g8S venti",; .y.t~M ~i~:e th~g s1te M.~ b~~1"'1 C:Q~Cd
r-:,t' ~0 Y".""~- HQweva~, spacific: oiIir '"...st,. 1'"or n'et~i!ln. ail,. "'."0 ..,.jt
)Ii'r"fr.'rmed at the.- site- ' -
~c~'="-d i n9 t w .1'". ~"my Coro~ 0" Er'g 1 r,eer!: ""e~,.~t (Jarrua,"y, 1984),
~ndfil: slteG can give ~" Methan. ;~S f~r ~0 ym.r"S or M~re .ftsr
:l~~u""e, e~~eC1411y 5it~~ ~onstructed p~i~r t~ 1~70, lika Do"""er~, t~~t
ad p'",,:. ;41.. "'8n4: 11"'1g Gyst.m~. The propcliisd ~ont.inn'l!:nt ~'it,., r.e, g.:1C
'~rl-t i"'.; co:)l..ild c:.suse rnetnL\?'tC!.' Siam tr:l Mi;,...t\t~ latEPt-ul1y, CiH"""y
~~t~M1na~~~ to "e~rby ~cMes ~nd p~.aent 4 public ~Ii'.lth ~Me~;~~~y. A~
><:c"'ncl~ :1"'1 ':'I.I~ ,:"",1"'1 st.t!!' i:: th~ :~du~tri.:ll E)(c:es!3 :"~r,dfill ::'lte:- :1"1
r'~':I.:t':lwr. ....ne,'o f,'e~ha"'lliJ g.3~ ....~» f.:.\,o.'r,j \:r=, be trl1gt'63tll"'l!; l"tQ\'.lly al"\d
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. '.. 7~E ~U~'E:~i-~'ID ~_.~'.ol ~ND ;;:"'IZAi\lU~' ~TANr>~RD~. !.:~::::.~ .:I"d r:~r'~ t-..:t.':,
1r".C?I'''t'et~c t,.,~ ::'.IP&t'~ II!",C! c:lH.2"IIJ~ ~t.rld';\t"d$ f,=,,... B,='wQtO~ :':' hUla!", 1"~l!t 11;;
"C"Jr',"~;.,t C'~11':' '!..:.11d W.liit~ :,lr,df'i 11 c:l'='~hU"e ~t.l"'\C::ta""d~". i..c'='wever', ';ao: ~;.,
"cHit ~ C 1 r::'': '.WI! 1.10"1& . "0 I",.:;,t loe 1 "va I".t ~l"'Id n P !:)T''='P,'l at 8 f.:.," ,., oS;: ~""d ou ': w.;.$t t:'
/1 t ~~.
~h~ SUC8,ofund l~w ~t~t~5 th~t t~e ~~M~Oy wu~t ~~~p!y wltM ~l"'Iy
'3";.te R"""'l"'':''''I.U!I'',t:.1 .:.,- f"C'll:.~y Law thfi$t :";:j ,.,,:,t lC!"3!1 ..tt"irlg~I"I1,; thian C-\r".y
f~ce~al :.~ £~~ th~ ~~~~r~~u~ ~ub!lt~ncc ~r ~~l~~se In QYc~t~~n. 5~11~
wastft c:~~Yre law~ ere ~ot ~ol~v~n~ and ~~~~~P""l~t~ f~r h~za,...o~ys wdG~~
$ltHIii. Th15 ~lt~ liihoul~ "ot u~t . pr.c~den~ f~,... ot~~r ~a:.2rdou= w~:te
!ute:s, G1J=~.!J tne ~~,.t~clr"..= l...1nofill, t-:' b~ t"Qotod 1~1tc! ~,:.llC: "'~$~e
'51tes.
USE:PA .r,d OEPA tU'9 '.I!iH,g !$.:ol1d waster l~"",s ,OOC'.J'.I6t? they it....&'
rel~v."t And ~~pr~~'late ,~,... w~.t t~ey want to do t~ t~e sitae U.l~;
~~l~d ~~~te lAw~ f~" & h~:a""~ou!l w.~te ~ltQ is ~Qt in ~~Mnlia~c~ with
"=~(! :3'Jt);Hof'.I1"I~ l.~,..j 1'~!tl'.d "OCWlfI!r",'t th~t a fil'$t c:rlt~r:'4 :it''''''.dd ~'''' the
..;, V~I' ~ ~. ~,'c,,, .~t 1 c,r, '.' f t i"I~ puu 1 ~ c he.l t h ,:'I".d t h. .rw i !"c,r.lftl8'r,t .
In ~YMMary. a fln.l cleAl"'\up d~Clsicn =.nnot ,....ly ~I"'\ a study that
;,11'1(C!S r,'CI)':''''' 45S~II"p'tlt;;1"IG b6'Ged .;,r, speculAtic;,n C'r !Suc:h lir.nt~c: datta.
~~C~A ~~~'t~s t~el"" ~eMedy addr~~~elii ~ wc,rgt ca~e ~e"~r~: 3]tYut~~n.
....-:.I'!;'t C':1.a !lc::vn~""l'=' ~~t'.I.a'tl':''''' would r.Qt ignt:,t"&' m.j.:,.,... c:-:,r,fl.c::tl:":;
eVlde"",c:e 0"" '.II"."u.......,'"a ,-,r.AG .:.f C::OI"IC:I!"""" It 1!1 nQt ~'.H"~""ls1rlg t~at ~'JC~:
little c,'''' jjQQr ':''o'&t'!U;~t ,=,f tl'H' ",,:,'"k L't 80...&t'S OC:C:'..i"",...ed with the-
cc:.r,st..'l"'It t'.&r"Qv."" ", ~lh'.':OI",r'81 at b.:.t~ UaE~~ .."d CE~A. Ol..i?" c,=,nll'I'.Inlty
=ff~""wd ~ maJ~r ~C!.d ~Qr c:~~ti"ulty to thi~ pro~a5G. H~w~va,..., if U5C~~
Mad ~ea~ r~c:.ptlv~ ~~ Oy,... c:~mmu~ltyts su;;e~tloI"'lS dY""1~9 t~i~ ~t~dy, w~
c':l\.dc: n.'o'C! nad a mQ'"C' Ct-gdible st'Jdy .nd be eC'f.f1dartt abO:&I.It rIlO:''o'l7',;
fo:,,...,,,,..,= ':c ,'esljJ ve the po:>ter,t i&l prObhtr'15 !:,""~se1"\ted by E<,=,wer~.
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1'3e9
-------
~CTIVlS7S_CONCE"NE~ .IT~ i~XICS ;~ uUR NEIG~=O"~GODS
111 Zsl."c ROAC. CU"Cie"111e. OM10 ...311.3 1-6i~-"7"-1'::4~
~RESS RELE~SE - StOWERS L~NDFrLL SU~ERF'UND SITE - jjRO~OSED "~LE~NUP"
----- ------- ------ -------- --------- ---- -------- ---------
We Celle"e the only con.cl.n~lous .PP~e.cn to tne pot.ntlal p~oClem.
C~.S."~.d Cy ou~ nelghco~nood Sup.~fYnc Sit.. th. &o..~s LAndfill,
should c. .. '0110...
Fi~.t And 'o~.most, a f.nce a~Ound tne sIte and mOnlto~lng .e11.
bet.e." tne SIt. .nd tne City'. ..11 fleld should b. lnstAlled
lMmedlately "'JgA~dles. 0' any Cl.Anup deCISion. Common se"s. tells us
tnese pUblic P~O~.CtIV. measu~.. snould ha". C..n Installed fi". y.a~.
ago P~IO~ to Any Sup.~'u"a StUdy.
~
~ 'inal d.cislon about tn. cleAnup At Bo~.~s L.ndfill Should b.
postpon.d until S.~10U. Q~..tl0ns .~. AnS..~.d ~.g.~ding g~ound..t.~
flo., locatio" And n.tu~. 0' .ASt.S, A"d methan. gAS. In additiOn. any
"cl.anup" d.CISlon mAde uSing Ohio solid wAste lA.S IS not In
CompllAnc. .lth th. Supe~'und la~ ~.QuI~.ment thAt P~otection 0' th.
puCllC n..lth And the envi~onm.n~ Should b. A 'i~st P~lo~lty. Solid
...~. 1..s a~. not ~.levAnt And .PP~OP~IAt. 'o~ h.Z.~douS ..st. slt.s.
It
We b.li.v. P.~M.nent cl.anup t~.at..nts could be conSlde~8d i'
th.se m.Jo~ A~.as 0' co"c.~" .e~. add~e..ed. This ~eQuest IS not .ade
lightly. We wAnt. 'i"Al solution A. MUCh A. A"ybody. Th. P~oble. i.
that the~. A~e mA"y ~eAson. to Question the sen.lbllity 0' EPA's pl_n.
w. A~. not Questioning EPAts deCIsion Just ~o be di"icult and ou~
PO.ltlon i. not unique a. I. eVlden, in the a"ice 0' Technology
As.e..ment stUdy about the ine"eCtivene.. 0' the Supe~'und P~Og~AM.
We 'eel st~ongly thAt EPA snould answe~ all intelli;ent Questions
and O".rcome the .Any Cont~AdICtion. in thel~ S'udy ~Athe~ thAn leAve
u. with A 'aulty "cleanup" At Bowe~. NobOdy in this County .An's to
be 'ightlng this bAttle AgAin In IS YeA~S. EPA's P~Oposed ~."dy does
net ;1". us the 1.A.' ~isk Po.slble And .e think thei~ deCISion i.
lnfluenC.d by cost. PiCkA.AY COuntiAns should not .AC~I'ic:. thel~
QUALity of 1i'e 'o~ ~on081CS.
We have not heA~d '~om Anyone In the County who ~ik.s the EPA's
proposed decIsion. Sen.to~ JAn LonQ, the PiCkA.ay County CO"isSione~s
.r,Q s."'er.l City o"i~ials And CounCilmen hA"'e .i.iIA~ conc.~ns ana
Are suC~tting thel~ stAtements to USEPA. Ohio EPA r.p~..."t.tiv..
even .;~.ed that all ou~ ccnc.~". .~. valid in a Meeting on TU.sdAy
.ath Se~.to~ ~.n Long Ana ACTION r.pres.n'Ative.. In 'AC', they .tAtee
th.l~ ~omments About the P~OPosed plan would i~lude SiMl1A~ c:once~n..
Mo.."'e~, it .PPeA~. they a~e ~esl;ned to .O~king .ith,n the
inAdequaCies ana politi~. 0' the .yste. ana .UCCC8bing to USEPA's
ha.te to meet it. hal'-yeA~ ~epo~t deAdline 0' "A~en 31. 1989.
W8 think USEPA should ~eAs.es.
to Add~ess AdeqUAtely the cl.anup 0'
should ~.a...ss the'~ P~lo~ities - a
Su~e~'und ~O~k A. the 1.. Intended. .
A. PiCk..AY Cou"ty ~.sidents. .. "..ill not SAc~i'tc. ou~
.n"lrOnment to become A~othe~ st.tlstlC 'O~ Anoth.~ study About
l~.ff.ctl"en.ss 0' the Supe~'u"d P~og~... We will ~ot stAnd by
poo~ O.C1510". cost YS Ma.ery .nd mon.y I" the 'utu~e.
thei~ p~io~ities - A '1~s'
Supe~'und sit.s. We think
'i~st being to in.i.t tnAt
bei"Q
OEPA
the
the
.hl1.
ThurSday, MArch 16.
1'38'3
-------
.~.)
~Ci:VISTS C~~C~~N£C _IiM iO~IC5 i~ uUR N£r~~~O~-~c.CS
111 lsl~~,a "t:laa (""."'. CU'Cl""'l!!.. O/"ll/j "~44':':'
l-~1..-_7"-1.a..-a
QCTION 15 a ~Uolle lnte,..~t .n"'l,.t:lnM.~tal ~"g.nl:.C1cn fo,.m.a ln
5 '1:.rno.,.. 1';6-. 'fc,,. t,.,. .".elf1C: ou"cC'SIt c.., ...r.'''''\'',g c.", t,.,. &,=.""..,.. .no
t ;~.l,"." L...~'Ofll15 "'''ac:n tn,.".t.n to CO~lt.mln.t. t"'. T..y. QQUlf.,.. t:lu,.
....t.,. SUCC4Y. aP'lO tn. SelotCl "1"'.". 51",e:. QCiION'. C''''191n, .... "'."'. b.cClm.
1P'1vol~.a 1~ .aO"...1P'19 .11 ~ot.P'ltl.1 .~Vl,.t:lnM.P'lt.l C"~Ol.,". ...,t"ln ou,.
~oun1:y. QCTION's ~"OJ.e:t. ana .."V1C.. lncluae Out a"'e not llM1t.a.to tn.
f"11':."'1~'9: &0..,... L..anefi11 Suae""IJ~la slte, 6a,.t/"\elma. lane1'i11.
se...age/slya;e .~01icat1on on 1'a,.m1a"0. ...at.,. And s011 monitO"ln; 1n
Cc:.Q"01~.at1on ...,th t"'. Stua.nt EnV1,.'=''',,,,.ntal lot.aIth jj"~J.ct ~1' V.",a."o11t
UnlV."'S1ty. ~jjG'. ".;10na1 "'a:a,.aous ...a.t. 1ne:1n.,..to,.. pPG's ~lant Slt.
g,..c:.unO....te,. CO"Cam1natlon, Solla ...t. man.gement ana ,.ecycllng, .c"'~cl
~ =ro;,..,,,.. .".0 t"'. ACTION o1'''l.ce ...h1en "'a. eMte"'.lV. en"'1,..c.n",e1"'lta1 "..o:.'.I"e..
lnelu01ng ne.... .,.t,c1e., bOOk.. "'la.oe.a... ma;.:11"'1.., l.g,.laC1v. allIs,
;c"'."'''~ent cucl1eatlo"., a"d ne....lette,.. f,.om othe,.. e"v,,.onmenea1
0";.P'l1 zat 10"'..
~CTION "'.. work.a h.ro to bring. gr..te,.. ..are"... to our CCI",mu"lty 0"
our ,."vl"OP'lm."t.l probl.m. Ana the "'any th,...t. to the County's a,,., ...at.,.
.na .011. &y atte"di"Q e"vlr-~"m."tal e:o"".rene:e., .a..Nl"; to tn. you,,;
=.OO!. 1~. t,.,. .e/"\ool. "'''0 "'111 e...entually ,nn.rlt t/"l... a"~Olem., wor.1";
"'ltn t/"le E~Q. lnaust,.y ."a ot,.,.,.. ;o...e,.nme"~ 01'~:~la1. 1'0~ Mo~e cli':e"
~a,.tle:laa~10". and s~eaki~Q to a,... o,.;a"l:aCions, .. t~i"k .. a,.e mak1"; a
.1;"'ll'lea"l~ lmoae~ "0,. ;ooe 1'" Pi~ka...ay County.
ACTION'. memO.,.. a~e h1;nly motlvat.a a~d aeCleat.a to cle."l"; 1.10'
..1S~ln; ~~oQlems ."d ~~om o~eVe"'~lng ot~e~ pr-oOlem. ""'~M eve,. mate~1.11zing
Oy m..1n; ;ove~"me"'~ ~.SPO"Slble to those people .no .~. most .".cted by
~o11utlor,. E"v,~onm."'c.l Impacts ".ed ~o be . ~aJo~ cC",s10e~.~ion ...n.n
=1'~n1n; g"o...~n 1'o~ ow,. e:OMMU"lty 1" o~ae,. to "ot JeOp.,.alze o~,. ~"..e"t o~
" ~e eeo~omy. I~u.~~y e.", be a ".sPo".lb1e a"d con.1Ce,..te ne1;~bo,. by
our 1~IS1Stl"; that the 1... be en1'orced .nd that "e. 1... be ~a..ea that gi...e
lP'1Centl...e. 1'0,. e1iml"a.lon 01' bot~ solid .nd haza,.dou. ...a.t.. by .a1'e met/"locs
.uen a. "'A.~e ..e~.~ge, ".~tr-.1l:.tlon, SOU,.c. ~.duetl~", O.e~e"'.l
t,..~~tm.nt. a"a "ecYC:ll"'Q.
QCTION NEEDS YOUR HE~pl We need you i~ thas Imme".e t..k.
your tlme ana eont"lcutl0~. to e~ntlnue a"d 1'ur-the,. ou" ...or..
..
w. "'tt.~
1
----------------------------------------------------------------------------
w Q N T
-----
!Q
l.Qlet
e~~~!~~g~~
Cc""alete t~l. 1'o~", .nd ...al1 to ACTtON. 111 Island Road, Ci,.cle...,lle,
-------
~~ac I' ~aoo'nlng Co C~. ~O..r, Land.111 SuOer.und '"C." T"e
USEP~ ana t~. POC.nClall. re'Oon'lbl. parCI." PPG and DuPonc, ~aw.
Ju,t compl.t.d a 'cua. C~aC cO'CapprO.I.ac.l. '700,000 and ar. unaale
Co glw. u, an..or. concl..lw. In.ormaclon aaout t~. '"C.. VOlum., a.
aaCa naw. be.n g.n.rated and a conCalnm.nc r.m.ay propo..o wnlc~ 'CIII
.qnOr. OO'.nClal t~rea.. or.,.n"d by C~I' na.ardou. .a.c. '"t.. Th.
USEP~ ~a. 'CaC'd tnac a .Inal cl.anup d.cI'lon ""II 'I..,y b. .aa. by
"'."c:" 31.
I. GIIOUNDW~TEII FI.OW. : ~cc"ralng to t~. EP~ .tudy, ground..aC.r
.10.. und'r the ,"t. I. d.cermln.a to b..to the ...c to..ara t~. SCIOto
IIlw.r ana, th.r..or., the ClrCI.wlll. munlCIoal -II .i.ld locat.d I.~
.11.. 'Outh. I. noc '.P.ct.d Co b. a...ct'd by pot.ntlal grouna"at.r
c:c:....t."'l".tIO....
Th. Di.trlCt SOil ana Wat.r r.pr'..ntatIW., Mar. ScarPltti, ha.
pr'..nt.a In.Or.ation .ro. a D.partm.nt o. Natural IIe,ourc.. .tuay
WhIC~ pr'..nt. walia con.llctlng 'Vla.nc. about grOUnd"at.r .10.. 0..-
'"t.. Sinc. the grouno"at.r .ov.. .ro. the uplana. to t~. SCioto IIiw.r
Y-II.y, it I. PrObably CO.Olnlng at the r,v.r ano .Iow.ng 'outh to..ard
the w.ll. ano to .111 In the a.pr'...on Cr.at.a by the h.ayy Indu.Crl,1
pu.o.ng .n the Circl.v.ll. ar.a. Th. USEP~ ala not .tuay grouna..at.r
.I..w out..a. the I~.aiat. ar.a o. the ..t. ana could b. .a.ing a
'.rIOu. Inaccurat. a"U8Pt'on about pot.nt.al ri.k. to Our ..t'r
'uPply. Th.y haw. Ignor.a ana hay. not r'.ut.a th.. ,vla.nc. ana h.w.
no plan. to ..n.tall monltOr.ng w.l1. b.t"..n the .It. ana the City
"'.1 1 ..
C. I.OCATIDN OF WASTES. Pr.v.ou. t..t.ng at the ..t. Sho...a high
l,w.l. o. conta..nant. in l.aChac. ana grounowat.r in 1980 ana 1981.
Pr'..nc t..t re,ult. g.nerally '~ow low l.v.l. o. conta..nant.. Th.
EP~ .tuay .tat.. that about .~K o. the wa.t. ... g.n.ratea by wariou.
Inau.tr"'oP.rat.ng In th. ar'a, inclua.ng bPG .na DuPont, a80ng
ot~'r.. ",.pon... by PPG and Dupont to a ..a.ral .urv.y in 1'78
Indlcac. th.y aump.a 1788 ana 6~00 Con. o. .at.r.al r',p'ctlw'ly,
Oth.r local inau.tri.. .v.a.ntly aia ~t r"Pona to th. .urv.y,
USEPA ha. not arilled .nto th. ..t. Or '",tall.a aon.tor.ng ".11.
o..tua. the .It. to a.t......n. th. l_a"on o. ..a.t.. but I. propo..ng a
r.m.ay to conta.n 'O..thlng. On. .ajor area .gnored by this .tuay ..
that th.. ..t. .1000. .r.qu.ntly wh'ch ha. pr'..nt.a gr.at pot.nUal
.Or conta..nant .'9ration '.nc. it. clo,ur. .n 1964. In a 1'8~ ...ting .
...th local C.tl:.n., Mr. Aog.r Hannah. o. OEPA aCknOWI.dg.a th..
conC.rn ana prO."'d that .OEPA w'lI ...qu.... t"hng .u..th.r out.ro.
th. s.t. until eOnt..in.nt. .r. loc.t.a i. not loc.tea .t th. .n.ti.1
t..t Slt...- Wh.,.. i. M,.. Ha......ans no.?
3. METHANE GAS. Th. EOA ,'uay n.g.... any th...at .ro. ..th.ne ga.
ana th. n'.a .Or any ga. v.nt.ng .y.t.. '.nc. th.. ..t. ha. b..n clo..a
.or ~0 y'.r.. How,v'''' 'P'C'.lc a... t..t. .Or ..Ch.- ga. -... not
p.r.or..a at th. ..t.. .
Acco..alng to .n Af'My Co..p o. Eng.n..... ...po..t (J.nu.ry, 198.1,
lana.. 11 . It.. e an 91 v. ~". _t h an. gi. .0.. ~0 y.ar. - 8Or. a.t.r
cl0'u..., "P.cially ..t.. COn.t..uct.a prior to 1'70, lik. 80w...., tha.
h.a no ga. v.nt.ng .yst.... Th. p..opo..a Cont.in..nt with no g..
v....tsng ~ould ~Au.. ..tna". ga. to Mig"At. lAt.,.ally, e.,.,.y
cont.m.n.nt. to n.arby hom.. ana pr".nt a pUblic h.alth ...rg.ncy, An
.M.M~l. i" ou,. 0...... .tat. s. tn. Indust,.ial Exc:... lanc~tll .it. in
Unlonto..n ..h.r. m.than. ga. wa. .Ouna to b. .'9rating I.t...ally .nd
una.,. ".."by hom... .
4. T~E SU~ERFUND L~W ~ND CLE~NUP ST~ND~RDS. USEPA.nc OEPA n.v.
lnt.roretea the SUP.r.und cl'.nup .t.ndara. .or Bo...r. to m.an ...tln;
"CuI-rent Oh.o ...1.0 ..a.t. land.ll1 clo.u.-. ,tand"rdS". Ho",v.r, ,011d
QCTIVISiS CONCERNED ~ITH TOXICS IN OUR NEIGH&ORMOOOS
III 1,1.a,.0 IIoao, ClrCI,woll., OhIo "3113 1-,;&..-..7"-1':.'"
.
.
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~CTIVIST5 CONCERNED wIT~ TaXIes IN OUR NEIG~&OR~OODS
111 18l.no R~.o, C~rel.vI1l., Ohio -3113 1-6l~-~74-l~4~
w.st. elosure 1A.. .re ~ct r.lev.~t .nd .pproprl.te for h.zAroous ..ste
sit e..
The Super~und 1.. st.tes thAt the remeoy must Comply .,th Any
stAt. envlronment.l or f&el~lty 1.. thAt IS n~t 1... stringent thAn Any
reO.rAl 1.. for the hA~ArdOu, SUbst.~e. or rel..se 'n que.tlon- $Olld
w..t. elo.ur. 1... .re not ".l.vAnt .na .pproprlAte 'or hAzArdOus ...te
Sit... This Sit. should not s.t . pr.eedent 'or other hAzArdous .A.te
sites, sue" .s t". &Art"el,,,.s 1..."'C11'11l, to be t,...ted Ilk. .olid ...te
.1 t...
USEPQ .nd OEPQ .re ~SI~g S~lld ..ste lA.s b.e&us. they Ar.
,'elev.nt And .ppropr'.te fOr .hAC they ..nt to do to the site. USing
SOlid "A.ce- 1... '0"'" A h8ZArdo,-.s ..ste .1te 's not l'n eO'lipliAnC'e .lth
the Syperfund lA. requirement thAt. 'ir.t er'te""'lA .hould be the
Qveral1 pr~tectl0n ~, the public health And the envir~nment.
In SummAry, . '1n81 ele.nup decl.lon c.nnot rely on a .tUdy thAt
M.~.. MAJor ..sumptl0n. bA.ea on specu1.tlon Or .uch liMlt.d dAtA.
USEPQ stAte. their rem.dy .dar....s . .orst e&se ..nArlo .ituation.
worst e... .cenAriO .ltuatl0n .ould r~t l;nor. "'aJor eon'lictlnQ
.vldent:e or '4na"...e...0 Area. o~ eonce""'n. It 1. not surprl,slng t"at such
little 0.. poo,. OV.".lQ"t 0' the .o"k at 80...,.. OCCU,.red .1th the
eon.tant tu"~ove,. 0' pe".onnel at bot" USEPQ And OEPQ. Our CO"unlty
O".red a maJo" n.ed tor eontinulty to thl. p"oc.ss. Ho.ever, if USEPQ
".d b.en receptive to our cOMnau~lty's syggestl0n. during thl. .tudy, ...
could have "ad a "'o..e credible study And be COnfIdAnt about MOvinO-
'O"..,-d to "..olve the potent 1.1 prOble.... pre.ented by &o.e,...
Q
.
'9'.... .
-------
"I""" 0 '
,,,"" ,. .
- ...... "
,~
,
,
OBITUARIESiP4QE I
VIT4~ STATISTICSiP4GE a
TAKINQ.. CL.OSER L.OOKJP4GE 8
...
1 PI~n-,t9.'~I:~j!)J'liYP;ci
. Circlevine~~:qprii:p'~~~.
'pr.om pts-.q:9"lipts.' '~:.
S,ome wonder hov-:. t" ~I;B nT JlU'pl. 0
"clty water supply~ ~,
might be affected...
'. . . ".. ~~:
0,0.08,1" ' ,'''~
0..- SittII ..... ' ., ~ '1-
C1RC1.EVIU,E. Ohio -.1118
Jl80" ho,., ind"lii"" "a,or JiIi. '
cl...1 i:: l.otIall. are 'I",.&.&oni... 0 \
o Cod",1 cl"",,,. 1>l1ft pI'IIl-W Cor .~
a -""",..,,,.1 Luaic ...w Ii"...... )I
Th& U.s. &A"arOllln,"&Ai ",.. I', .
t.ee\lo, AI"'" .ilI "0. ItlMt.lie " . '
com""n'" '" \11, pia. 0& 0 T ~"" .
h..,iIIl Tllawar io CUU,,,,",
, H1Ih Idtoo!. " '
, " Tho EPA .all'" \8 eo, &he ,..... ~
aa,ulClonod Bow,,. 1.&MIl1U. .i&A, , A .rwl '~L
. COO& 01 chi' and \.OpoaiL Co.... t"~, '.:
&he OIU ami 111011,&0' ",.110... "!It,w.;
\8' .iLII \n\ .,11.. Th, 10.dfiU i8. . \I!!fI5f!i . '.
.'LIIIII, :l nlll" oC Circ.lo"ilJo'o few" "~ . . ."
",,,II'CIIJa' .0"" ..II.. ..
Tho EI''' h.. ..Lim."" u..
el'''"lo "OIIld I.U8 10 "D""
CDI& M.:llDUlioo. .
TU EEl'" o,;~" ~a&811 u.o ...."" ~
. iLl.Of,'h. IandCiII 0& '81, .li,hU ,t
1...1' Lho,,'ttaat" or'th. '111(...0118 ' '"
I..... CuaI .,.. ..., ~;...-. ~ ,., -.............
'01.. - CJ ....- ' ,
Sian 11CL. Ute Bo.o,.'J..aM-., ........ ,"
. nu baa ,,"n o. 1M Su..,-fuftd .............
Jlfou8MI Priori~. L.i8' .r 1M ..
"0,., ullcao"",Uod ud aI8&a. ~ ~ 1i8¥1
doft- hlllrOoua ...'" ej.... . ----...
tAlan .al&l \.0 1Lao" ...0 ..au ..... u.&
pa, so ",O'ULlt' LIIe MNUftd "OLll' 1..4- JII ;: ,
afL" Lal "P" fi.i.b.o Llilo "'--...... c:a-.-:a
,CI..IIUp. UI II. QII88U8U u.. ..'
£Pl.', ....,Li.. Uao& UIo 1aMQU..-. . --'j
ptI88t .. LArn~ \8 liL, ..,..' ' . .' ' '0 .
-1\ _W _L ..,I3G.OUU IJIU""&AaL -W par....."'" prolo8&l..;',
W 18..I&or &.1,..1\88&.1"'''' &.00' '.",-, " ,', "- -
.... _ilL -WI ....L &h.. ....Ii. ,:- ' " . ':.
ta,ed. DuL U\o cit, doaIa"'" &08; 'nil ErA ,I.. dooI .. caU, ,-
, ..ria LhI -~.. ' lilt ~"III\O'IIII" aU tallC mo..,;.I;, ":
n. &J' A ~n .ocIua. Uaa' a. IL ,..k.I UOL prgLK' LiI8 ~...
mUDiciool ...11. are aUo from." nu lto.. ~... ~hlch..... .
&.uIillLion u..c.... I""*' wo"'" ""11&11,, he IlUIL A ,hk. an..W 18' ,
1l'81li Lb, lancUUI no.. ..~.... builL arDUlIII UIo IU&lCW. be IIAcI. '
ward &.1\0 Stiu... W..., iulMd ~..., ..Bo..CIo WMtWo.ia .,LA'"
'8IUa \.Ow"" UI8 weJ~""" et laiaIMI 0l1li ClRlo8Yiu..,I.....- ..
.' -I DoII'L Ualllk al,.boII1""" 0.&1181 rMWI aIMI ..&Ill ~ ~ 1&.
"""'. Laa' aqllillr.-""''' ..id. .,.,.. '0 18611 .... cI-.!11 11&1:,'
Tt.. 1111'''' IlUW be il .iLJat*CI- CUI.. -- t..bo U" ol 0'" '
iI, jallilm..t OIl \M tP It. pIaA. -i' ...ptJ"l "Y lalaLaiM IIMorU ~ ~ I
, ...., \.0 - ..hIL -- 011' oC~ '...,..'CrllbI8iDl.\aaI ,....\I,~"
~LI... - be 00& ,,68d &0 .illl",- CI"IOtoaa... 0"',: .
PhT"a.. Co"7 L. CUlon'" ""WD, c.. -\Ida __.18 ~. .
, lLAO" ill 0 eiLiu... "NUP, "ctJ... . ,U8 LAo rwl'fM&lilMo ,*,,& - .::'
1...- CoftCl",8IIwl&h ToEica ia Our ' -"'a, nnw.....,I.. II \
, N,i,lIborllooc1a. nayo mod . ..rit, ' dooIud ta taiL aad ...1IICi. 1M'" i.
. ' Lol objecLion, I&)'in, .s.ho ploD Ia 18.,1L 18 rsialo"*, &08 1JIo~. :.
l.adtqu8Lo. T1Ie, pf~ ~ '..... ~ JIm.", ud aoaiLo,..j CIIftl r,:
: J~' boar'.I. ,. ,\' ... ..... 1UIcD..., 'w C&iJI&ft'wb' , '(
t', ".1\ Call. lhe",,8' Cman oaici.;'''Nft.-''1 u.Id.. ";,,.''''' ..oo,
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,,."m,"t'l propoNd p'.lr'm Lo cl.all liP' ' 'l'hl,tudnll,'lIorUt_t ot 1,Ialld allll CI,.:
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Ian ot Cirr'IWIII,. alld £;1. dll PODL'd. N,mo..r. . Co. aa parll"
WII.II ~Lola,., a.IIM ..h'tll.r och,re amOIlC rUPDllllbl, 10' CD.1.&I81I1a~oll .n 1JuIlanalilL :
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Lb. plall r.u 11'. 'ami "I', mOI~ ,.I..ad LIa8&r oil,".. poaed'Dy Yi. II~ I. low," Oil t;PA
bU\JI .1111 10m. ,,,"Ia..ald 0' cJlMNI1. rlpon aid.' !:ull.r 1.8" rel.8Cl LoI'CIL, ot Lh,
SLolo,. 11101&0 ot 0 .....Iic h.arloa h'ld bJ' 101llllill ot 001, .IiIIlU, 10..' than LhaL 01 LI"
LII. U,S, t':1I",rolllllllltal ProtairhOIl AII."c, aL jolamou.:L.o,,~ COlla! IIMr Nlallar. ~ollL N.Y.'
Ci"I"IIi. lIilCh 5ch_1 ,...tarIJa, 1.0 m'aa..... C,IIU"a CIII.II, a 'po..,mall ror AILI,,"ta,
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th, 1111111£811811 Uo..,. l.aa&&liJJ .ILA 4 1_, el .aiel OIa UA pion I'a"" Loo mall1 qlleeuolI,
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MOIL 1'8OI'Ia who a""lIa triti.i&td tile £PA'a be mKill' i&l -, ",a"l'O..nll wI~r 1.0 Circl..
rhoiee 01 ,.III.uI". wh,ch carr'18 ""~II\O~ .,illa', lIIullieipal walla, l.war Lh&A :l !lWU
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f'II8L lor tlIUIII(. /la aCL,on t.o mort' 'baa 11:1 90. I -""11 II ml
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Cl6€P11... CH;
To:
The ~re81dent and me~bers of Clty Counc1l,
C1rclevillo, Ohl0
Whereas, in the opinion ot many conc~rned inforMed
citizens, it has ~ been conclusively demonstrated
t~at the well field which supplies water for the
City of Clr~levl1le ls completely sare traM contaMina-
tlon by hazardous wastes depoaited in the Super~~~d
S1te known aa the Bowftra tandfill, I stron~ly ur~e
that the Preaident ot Clt1 Council wr1te the Ohio
and U.S. Environment Protentive Aqenc1el expresaing
our concern, end requeatin~ that ad,~uate ~round
monitorin~ wells bft placed in locat1ons appropriate
to assuring proter-tlon ot our water supoly,l.e. ~etwe.n
our well bed and the tandti11~and that th1. act10n
be taken as part or that remedial action which 1s
.0,'- . .
eventually .elected.
Such wrltten comment mu,t.btt 8ubrttltted to the U,S,
Georgette Nelms
Community Relations Coordinator
Ottice of Public Arralrs
EPA by March 16, ~9Bq~.
R8a~ecetully sUbmitted,
..... h ~ -
Robert N. Phi11i~.
Councilman, Firlt Ward
U.S. EPA R8~1on ;
2)0 South D~arborn
Chicago, Il 60604
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ROBERT N. PHil '.IP . 0.0.... INC. .
I..., PINC..-~\ 'lien.
CIIICLIVILLI. O' '..alia
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C l'\t.::a g':-. Ill. AO 1;1)4
:\!:Ir~h C? 1989
De~u ~t!s. Nelms:
The point of U-.i~ letter is root necess#1r:ly to communicate my
r.isag''rC!emp.r't over the n1cthod in which the EPA hO!5 recommended to
"remecy" the problem at the site of the Bowers LandfUJ 8S much 85 it is
to t!xpress my disple:J.sure over the mannp.r fn which tha aItp.rnaUve was
prp.sented to local cit1zens.
I feel the EPA was ill-prepared to fully respond to many of the
questic:r:s posed by rr.emb«!rs of the communit}. who attendcd the public
ir. {or::-::ltion meetin g on Feb. 28 t 1989 lit CircleviI1e High School.
As 8 Circleville city councilman. J teel taxpayers deserve and
should expect better rcsponse trom governmental hodies thnn what they
rp.ceived from the EPA. In particular. inquiries concerning the decision
root to phyc;ic311y remov~ wo~te from the site werp. met with the respc)nse
that total rt!moval of the waste was simply not on~ of the options
investigated.
The remedy recommended by the EPA his aome merit but J teel it
doesn't go tar enough to provide tor the tuture safety ot the 13.000+
citizens who depend on the CircleviUe water 8upply. Many members of
this community. including myself and other counciJmen. feel additional
monitoring precautions should be included in your remedy.
One such precaution would be to locate ground water test wells at
strategic points between the landfill and CirclevfUeta water field. As
your plan presently states. most test wells are In the immediate area of
t he Ian dfiU.
( realize the £1' A becomes involved In battles on many (ronts when
making decisions that may .aUsfy IOme group. but could cost others
millions of dollars. Nevertheles.. It ia important not to misjudge the
impact your declldon will have on thole who Uve and raise their families
here. It il hoped your final solution ref1ecta at least some of this
community'. tntereata.
Sincerely t
~.;.J#!~
David M. Crawford
Circleville Ci ty Councilman
431 N. Court St.
CSrclcv111e t Ohio 43113
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Jan Michael LOfit1
State Senaror
0"10 S.nl'.
, 711'1 O.$t'ICI
MEMORANDUM
TO:
Ohio Environmental Protection A,ency
United States Environmental prote~tion A cy
, fi~
Jan ~ichael Lone I .. I
5 tat e 5 e n at 0 r \....;:ZI~"":' f-
11th District Ohio Senate.
FR:
RE: Bowers Landfill Super Fund Si,ht/Public Comment
!
'-
DATE: ~arch 14, 1989
Thank you for the opportunity to allow me to submit to
you this date my public comment tor the record and to be
reviewed by the respective Environmental Protecti~n Aeencies
in their consideration of renderin, a record of decision on
the closure and cleanup of the Bowers Landfill Super Fund
Sleht. I sub.it these coaments not on17 as the State
Senator who represents the .eo.raphic area known as
Circleville and Pickaway County in the 17th Ohio Senate
District, but also as'a citizen of the City of Circleville.
While our community and indeed our state is moat
interested in tor, in, a remedy to the Bowers Landfill
problem, all of us want to assure ourselves that such a
cleanup is one that is safe, protects the environment for
present ,eneration, as well as future lenerations, and also
is one that we will not have to revisit in the near future.
Based on these underlyinl premises, m7 public comment is a
request for the US EPA re.ion 5 and the Ohio Enviornmental
Protection A,ency to withhold -or postpone any recorda of
decision on the Bowers Landfill cl08ure until some major
areas of concern are addressed and sati8factorily examined
by a thorou,h study of additional information necessary to
make a permanent environmentally sound decisions.
J.n Mlc:",.., Lon;
State Senator
OhiO Senate
Statehouse
CollolmoUs, 0""' 4J~
Scon E. Ensa,
LI!'9ISI8"V. A1I2.
Pam SOMel.,
Committ...:
e~U~IIO" 8"0 R.I"tmef"lt
(Ranlllf"l9 M,norsty MtmDef)
I='in."ee .
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rt..""
Havin. attended the hearin, on the public comment and
question session some two weeks a,o, there .ere some matters
that came to my attention and that raised some concerns on
my part. For example, the Bowers landfill is perhaps one of
the most toxic and hazardous in this state, if not in the
~nited States. Yet, the closure standards that would be
applied to the Bower~ Landfill w~uld be those closure
requirements that lovern the closure of a solid Waste site.
It is my understandin. that this is acceptable because of
the technical requirements of the law as it relates to the
time of the last use of Bowers Landfill. Certainly, if the
landfill contains materials that would qualify it as a
hazardous or toxi~ waste landfill in 1989, then it seems to
only make sense that the closure should be made pursuant to
the luidelines and relulations .overnin. hazardous waste
landfills. The mere fact that termination of use was some
t.o decades alo should not remove the closure from the
hazardous waste closure requirements.
,
,
Secondly, it was my understandin. at the public hearin,
that the alternatives for closure need only satisfy a
thirty-year life span requirement. From the public safety
standpoint, as well as from the public fundin, standpoint,
it seems as thou.h a permanent solution should be pursued
and not one that may require additional closure remedies in
twenty or thirty yea~s. As a lerislator who is most
concerned with fundin, issues, I can assure you that I would
applaud efforts that deal with one time permanent coats, as
opposed to future potential unknown monetary costa for
intermedial work.
Next, I would like to comment on areas that appear to
not have been thorourhly examined in the initial alternative
propo.als. The issues that should be more thorourhly
atudied and further data collected, would be iasues dealinl
with the Iroundwater flow outside the immediate area of the
site. Perhaps the installation of monitorin, wells between
tbe site and the city wells would adequately address this
issue. Additional11. there appears to have been limited if
any. testin, at areas outside the site to determine the
location of an1 mi,ratin. waste. Before we can talk about
total contain.ent, it would be helpful to fullr understand
the extent of the contamination.
FinallT. the threat of methane ,as .ieration aeem. to
be one that has not been adequatelT exaained in the process
of formulatin. these porposals. The question of the absence
of .a. ventinl .ystem. to prevent lateral .ieration of
methane .as should be addressed.
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Thus. considerin~ all of the unknown and unans~ered
variables in this very complex problem. I would stron~ly
urge the US EPA to postpone any record of decision untll
these questions are sa~isfactorilT examined and answered.
A,ain. thank you for allowin. me the opportunlty
this additional public comment.
for
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~qr a::itu of Cl:irc1luillt
OEPARTMENT OF PUBLIC UTILITIES
,,. WEST FRANKL.IN STREET
POBOX 209
CIRCLEVIL.L.E. 010410 ':1"3
O!..! ~to()"'l 16"\.77.255 1
MICMAEL. E ~OGAN
"..01'
.. TWCCO P JONES P E.
::'.!C.~. 0' ~.I.IC: U8v,c:!
:-1a;::,c:~ 15, 1989
~. E:'l..., Moran
R~ial p;::,o~~ ~ger
~~ial and ~:=;::,=emen~ Branch (E?~-")
::5 E:wiror'lJTer.U\l ?ro~~..J.on ~e..,r::i
230 Sou~~ OeAr!:lO~ St:ee~
C1icaqo, IL 60604
;)ea: E:r 1..., :
.
.
~is le,:-:e: will serve to ~.1.:y t.~ USEPA of :he Ci -:: of
C~rc:leville I s came."1U on :."\e "Feasibility Stu:y for t."e 3owe..""S
!..and! ill, Circlev:.lle, Ohio" da~ed Febr.Jarf 3, 1989.
On t=a?e 1-5 of t."e reFO~ ~"e firs~ paraqraph su~es "Ac:a)rdi.~g ~o
lnfor.Ta~ion on file wi1:h t.~ OEPA, the majority of was':e mat.e.:'ials
de;:csi:.ed on 1:he si~ ccnsis~ed of residential refuse collec:.ed by t.~
Ci ":."1 of Circ:leville as well as by several private haulers in the
Clrc:leville area." ~t part of the stater.em refen-ll'Iq to ref~
.beJ.nq collec:-...ed by the City of Circ:leville is inccrrect:. 'Ibe Ci~ of
Ci:c:leville has never collec:.ed residential ref-.:se with. Ci ~ c::'ews and
eqt.Uprent ncr has the Ci ty c:cnua~ed SUCh work to pri va~e
conuaC"l;ors. Reside."1tial ref-.:se collection wi t.h.1.n the Ci t:1 of
Circ:leville has been and c:cn~inues to be the responsibili-:/ of . each
inch vidual pr~ owner and as such each p~ owner ~s
an-a.nqEm!nU with individual haulers to haul their trash.
On paqe 3-38 under the. puaqraph entitled "Erosion Control and
Drai2qe ~CV8r8\U" the repon disC'.lSSeS 1:he inswlation of shee~-
piling p~on at the north end of 1:he landfill adjacen~ to the
SciOU) River in order to provide contairJnent for the stOne riprap to
be insulled at that location. 'n1e City's position is that ec,,:.., the
sheetpilinq protec!:icn and the ancunt of riprap to be inst:a.lled is. ~
suffici~ qiven the fact that durinq ~ floa:!s the entire nonh
lee; of the landfill is at risk. Accordinq to a repo~ prepared in
October 1966 by the Depan::nent of the ArmJ, Huntinqton DistriCt, Corps
of E:1gineers entitled "Floc:d Plain WOI:mation, SciOtO and Olenunqy
Rivers, Ohio, Main Repctt", the 100 year flc::cd elevation a~ the ao.ers
Landfill site is approxima~ely 675 feet atxJve nean sea level (msl).
'nUs 100 year flcx:d will be over t.~ t.cp of the exitting larxifill by
approx.Una1:ely 10 feet.. 'nv! City requesu that the shee~ilinq
prOt.ection be extemed to t."\e eas~ on the up river side arxi tha~ t.~
le.'1gT.l1 of t."e r:..prap be ~en:ied considerably to prete<=:. the nor:.." leg
of ':..~e la.nd:ill that proa-.Jdes ou~ lnto tl,e flcx:d plain area.
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The sO\,;":..~ e.'"'.d := ':..~e la.nci£ i.ll lS deSlogiled ~o have s'tone r:.::)rac on ':.~e
em ':."'1a~ ;ro't.r.Jcies l!'l'to t."1e flocxiplal.n. Since this' aIea is
i"~1T'IE!Cia~ely adJace..,'t <:::) ':..~e Flor~ce C".apel Road bridge (Red River
Bn.c:ige) over ':.."e ScloOt.O fU. ver ':.~e en~l.re flow of wat.er l.n t..~e SClOt.O
ru...-er ~st. ;:ast. '.Jl"'.de~ea':..., ~".s ondge and severe scourl.nq proclems
may oc:::'~ <:: ':..~e edge of t.."'le landfill at. "I:."'1is locat.l.l")~ under 3evere
flocxi concii <::'::'15. The Ci <:y' s ;:OSlo t.1.on is t..~t. shee'tpl.li.-,q needs ~o be
lnst..alled :...~ ':.."'11.S aIea ~o ~reven't ':.."'le undermiru.nq of t.."1e ri?ra? in
this aIea and t.."1e riprap 1 ':Self needs to be ~ended consider~l y in
order to provlde adeqlola'te ?r~ectl.on in this area.
The fi.~ major area of concern of the City of Cir~leville Wl ':.~ t."1e
report.. involves the lack of speclfic re<:amendations for a q:'ound
wa~er l'I"Onl torl.."q sys'tE!T\ t.."1a't will serve to prOt~ t."e Ci ':y of
Cir~levllle's publi~ wa'ter s~pply. The City's exis~ well field is
loc::a~ed adjace..,t. 1:0 t."e wa'ter tteat:Tent plant apprCDWnately 1 1/2
nules sou1:h of t.~e Bowers Larxttill. Approximat.ely eight years aqo the
Ci-:y of Circlevl.lle under:.Oj)( an enq1neeriJ?q invest.igation to
det.ermi..,e W'het.~ a f'.1't~e well field could be lcx:ated at the old
~J..nq station site on the west. side of t.~ Sc:iotc River off of River
Road. The slte is identl.!ied on Drawing .N\mi:)er 1 Vicinity Map as
"?.m;>inq Sta~on". '!he City's repon indicated thAt the area arouna
t."e old p~inq stauon, which is CU%Tently still owned by the City of
Circ:levl.lle would serve adeqt:at:ely as a fUture well field site for t.~
Circ:leville water t.:'eame..,t. plant.. 'Ib!re exists a 16" wat.eIm!~ that.
rJr'.5 iran t."e old ~i.~ Station site to the current water t.:'eat:rer1t.
pla..'i:: on Island Road t."1a't CQUld transnit raw wa'ter to t.~ treat::en't
plant..
.
.
~e City feels that it is absolutely essential that. adecr.;ate
rronitorinq for both of t."ese lcx:ations is necessary in order t:o
adequat.ely p~~ the City of Cir~leville's. public: water supply. 'nv!
Ci ty is of the opinion that additional rraU torinq wells need to be
ins21led off site of the ao.ers tanafill and an a~rcpriate
r!'CIn.i t:or1.:~ prO9%' am J::e devised so that these ~ . sites \IiOJld be
adeq.Jately prOt.eCt.ed fran any migration of ~ mat.erials fran
the Bowers Landfill. I wculd SU99ett that the ~on of
addi tional ncni tcr1nq wells and and an adequate ncni torine; proqram be
developed as ~ of t."w work to be done on whichever alternative the
USEPA selects as to the proposed solution to the problems at ~
Landfill. 'lb! City of Circ:leville will want to be involved in the
developL~t am review of such an adderx:tJm to the proposed plan.
If you have any que:stia1s on the a.bcve mat;ters, please de not hesitate
CXlntaC'tinq rre.
Very truly yours,
A~~.
Direct;or of PUblic Service
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Since the south end of the landfill is im~ediately
adjacent to the Florence Chapel Road bridqe ~ver the
Scioto River, t.he entire f 10'" of ",ater in the Scioto
River must pass beneat.h this bridge and serious scouring
problems may occur to the edge of the landfill at this
location under serious flood conditions. The City's
vie"'point is that additional sheetpiling needs to be
installed in this area to prevent the underrnlning of
the riprap and the riprap itself needs to be extended
considerably in order to provide adequate protection
in this area. ..
A major interest of the City of Circleville concerns
the lack of specific recolNllendations for a ground vater
moni toring system that vill serve to protect the City
of Circleville's public ",ater supply. The City's existing
well field is located adjacent to the water treatJllent
plant approximately 1 .1/2 miles south of the Bowers
Landfill. Approximately eight years ago the City of
Circleville undertook an engineering investiqation to
establish whether a future "'ell field could be located
at the old pumping station site on the west side of
the Scioto River, off of River Road. The site is
identified on drawing number 1 on the Vincinity Map
as "PuJllping Stat.ion". The City's report implied that
the area around the old pwnping st.ation, part of which
is eurrent.ly still owned by the City of Cireleville
would serve adequately a. a future well field site for
the Circleville "'ater treatJllent plant. There exists
a 16" ",aterlllAin that. runs from the old pwnpinq stat.ion
site to the current wat.er treat.Jllent plant on Island
Roa~.
'.- ._or ..;... .~-. I
. '.,.....
I ",ould like to stress that the City is extremely
concerned in havinq adequate monitoring for both of
t.hese locations in order to sufficiently protect the
City of Circleville's public "'ater supply. The City
strongly suggests that monitoring wells b. installed
off site of the Bowers Landfill in such a manner that
would detect any migration of hazardous materials in
the direction of t.hese facilities.
-------
-
. -.. ,-"
. -~
~y O?lnlOn lS ~ha~ additional ~onl~orlr.q wells ~eed
tc te crllled a~c a~ appropria~e monltorlng program
~e ce"'lsed so ~ha~ ':.~ese ~wo slteS woulc be adeq;Jately
Fro':.ectec from a~y ~~gra~lc~ of ~a~erlals fro~ ~he Eowers
:~~=!~::. :woul~ suaaes~ tha~ ~he cor.s~rUC~lC~ of
aci':l':.lc~Al mon1~orlna '~ells and adecuat.. monltorlna
wells and a suffi.clent :nonltorll':; progra::-. !::e developed
as yart of the work to be done on whichever alternatlVe
that the USEPA selects as to ~he suggested SolutlOn
to the proble~s at Bowers Landfill. The City of
Circleville wlll 18ant to be involved in the rev:.e18 a::c
development of such an addendum to the proposec plan.
If you should have any questions reqarding
concerns, please do not hesltate contact~n~ me.
the
above
Very truly yours,
~ hael E. L~~
M yor of Circlev~lle
.
-------
George~~e Nelme
Ottlce ot PU=l1C Att.lr:
U. S. E?A, Reql0n V
Paqe ~
~arCh lS, 1989
!he Proposed Plan also ~Qes .no~ adequa~ely descr~be the qround
wa~er mQnl~Orlnq proqram ~ha~ w1l1 =e es~abliehed as par~ ot the
preterred remedlal alterna~lve. !haretore, ~he ROD neede to
speclty wh1ch veIls vl1l be sampled, how ott.n~he wells wlll be
eampled, and tor wha~ param.~.rs the wells will be campled. The
wells should be sampled on a monthly or b1mon~hly baS1s tor ~h.
t:rst year and on a quarterly basls t~r the next tvo ~O tive
years. It the levels ot con~amlnatlon 1n the qround Water do not
~ncrease over thls time perlod, then a redUc~10n 1n the trequency
at samplinq may be eonsldered. The samples trom the wells should
=e analyzed tor all tarqet Compounds each time ~he welle are
sampled.
The 1nstallation ot add1t1onal qround wa~er monitcr1nq wells 1s
alco necessary to develop a mOn1tor1nq well system that will
adequa~ely detect potent.al tuture releases ot contam1nants tram
the Site. Well clusters Shoul~ be 1nstalled 1n the tollow1nq
locat1cns:
I
,
..
Betw.en Well Locat1on 5 and Well Location 6.
2. Between Well W-10 and the bend at the landt1l1.
3. Otts1te, between the landtill and the Circlevill. munlc1pal
well field.
Because at tloodinq at the SC1ato River and unc.rtainty about the
amount, COmposltion, and mObility at waste. 1n the landtill,
conditions at Baver. Landt111 are likely to chanqe. In order to
tully comply v1th State law and protect the env1ronment, the ROD
must have a continqene, plan that ean bl ..C11, and rapldly
1mpl...nted and a qround wa~er mOn1tor1nq .yst.. that viII
ad.qua~ely detect any potential tuture releas.s at contam1nants.
Sincerely,
~s~~~i~
attic. ot Correctlye Actions
Central D1~trict Ottice
cc Erin Horan, O.S. EPA, R.q1on V
Maury Walsh, OEPA, Deputy Dlrector
Dave Strayer, OEPA, OCA
Kathy Davidson, OEPA, OCA
Cindy Hatner, OEPA, Leqal
Jack Van Kley, OAG
ChrlS KorleSki, OAG
:an Michael Lenq, OhlO Sen.~e
-------
COM M' SSIO H E "5
GEO"OE H. HAliI"'CK
JOHN F. FISSEL1-
"UTH HEFF
PICKAW...., COUNTY
CUR I( .,iOMIHI$T"" TO"
TERAEPilCE J. IER'UO"PiI
T.,.p"O"- ., '-'74-t013
. , '-"&.tON
8''-''4-6011
BOARD OF COUNTY COMMISSIONERS
!=100M 5. COU!=IT ~OUSE
CIFICLEVILL.E. O~IO £3"3
Ma:'ch 15, 1989
Georget:e Nelms
Office of Public Affai-~
Chicago, Illinois 60604
Ms. Nelms,
\
After reviewing the EPA' s planned response to the Bowers Landfill problsn,
~ feel it is OJ%' obligation to offer our caTments for the public reccrc1.
Many citizens of Pic:kaw8y County h.sve devoted a great deal of t~ and -
ef:on in studying the technical aspects of the EPA' s stUdies and I"e\..uu..cudatials.
':'hey r.ave presented to us their conce.rn~ and after o:I'\sidering the info::m!lticn,
we \oIOUld strongly request the USUA Region 5 ana the Ohio E:PA to po5tp:X1e
a Record of Decision until the following four major areas of concern are re-
considered:
1. We have received confliC'ting accounts as to the direction of the
groundwater flaw. If the USUA cUd net s~ gro.Jn(twlSter flaw outside the
~te area of the site, an inaccurate as~titz of the potential risk
to our water supply cculd be made.
2. AcccrtU.ng to reports, t!s05 to c:1isc:cver the o:I'\taninants have ~eral.ly
been restriC'ted to around the site. Without testing larger areas around the
landfill, no evidence of off-site migraticn c:culd be detemunec1.
3. We hsve been 1nfo%med that landfills can exhaust mathane gas as IS
by-prcduC't. If 80, without IS gas venting system, surromding haTes ~ld
be exposed to IS riak of n8t.hane gas ccnt5r\ination.
4. Ccncems h8ve been raised that the tPA is planning to use c::leanup
standards ~ged at 8c:urnnt au.o solid waste landfill c:losures standards..
We also share tb:8e ccnce.ms as solid waste c:iosure laws are not appropriati::'
for hazardous waste sites.
-------
-~ CO"W'UlOHIJtI
QEOIIIQ( H. HAil"'"
JOHN ,. ,'saILL
IIIUTH NU'
P'CKAWAY COUNTY
BOARD OF COUNTY COMMISSIONERS
Cl£"K.,iD..'NIS'TJ.., TO"
TUIIIEHcr J. IEJUUQI
T.~.. 11'-47"",
"'-47W08C
"'-47~
ROO.. S. COURT HOUSE
CIA~lEVfLLE. OH'O ~113
. ',.
~
Maren 15, 1989
Page 2
In c.Iosinq, the PicJca\ey County Board of Camussioners U%1]eS Y\2J to not
<=mit to a>e pJAn of ac1:ion unt>.l aU these matters have been I'\JbUely addnuea
in grouter detaiJ..
S1ncere.1.y,
'%HE PIOCAWA't a::un-t ~ OF a::I+USSICNERs
John F. F.'-U
~th E. Neff
Cieorge If. Iiarnridc
jm
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Aflil. 'IYI DAY.. ...,..... '0
PICK AWAY COUNTY
80ARD Of COMMISSIONERS
IAIIMENT. COUll' HOUlE
C'"CUVlUE, OHIO UII'
.
Georgette Nelms
Community Relations Coo~inator
USEPA Region 5
Office of Public Affairs
5PA-14
2]0 South Dealborn Street
Chicago, Illinois 60604
'- ./
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St.&e elOIUo ~ ~ ~88CT
c.ntra. Dratr1ct 0fftc8
PO 80. '0.' '800w~Or
COI",~ 0/'110 ~'.i
(6'.1 S44-205.S
R.cnaro F Celes:f/
Go".rl'lor
!1Arc~ 15. :989
RE: Bowers L&ndtlll
Geo rget. t.e Ne hu:
~t!~~e ot Pu=l1c Afta.rs CSPA-14)
U. S. EPA. Req10n V .
230 Sout.h Cearcorn Street.
Ch1caqo. 1l11no1s 60604
:ear Ms.
Nelms:
Enclosed are t.he or191na1s ot t.he cOID.ent letters that. Ohio EPA
sent. t= you cy FAX on March 15. 1989. These letters include Oh10
£PA's ~olD~ent. letter on the Proposed Plan and State Senator Jan
Michael Lon;'s cOlDment let.ter on the Feasib11ity Study and the
Proposed Plan tor Bowers Landtill.
,
It you have any questions. plea.e contact .. at (614) 644-2055.
S 1. n c ere 1 y ,
~t~~o~
Ottice ot Correctlve Actions
Cant.ra1 C1st.rlct. Ottic.
..
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.
pO .~.,..."
Commnts rrolD Poenetally
R~SpODSibl~ Parties
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: _:"0"'''''' "..'
@J POR])
. '-.'..
E. I. Ou PONT DE NEMOUAS & COMPANY
- ~..
CllIICU\IIUL o.c an,
March 15, 1989
Ms. Georgette Nelms
Community Relations Coordinator
Office of Public Affairs
US EPA Region 5
230 South Dearborn
Chicago, Illinois 60604
Dear Ms. Nelms:
,
Enclosed is a copy of the remarks I made regarding the
Bower's Landfill durinq the public meetinq held at the
"".~.\' ....t= n.\:ICl ~""4'''''''.,
March 28, 1989.
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It' you have
"'...i -s--.; ~~"..~,
plf:~se c_.~tact .e.
Sincerely,
-
,.
,.
~~~~.
R. E. Berlin
Site Services Super~n~endent
Du Pont Circleville Plant
c
.IaIX8/8fI
Etcl_~.
Thert', . wond 0' things wer, aOlng somethIng abOut
-------
CONTACT:
Ron Berlin. Sice Services Superincendenc
rI.. D...-.. ri..,.1.,,; I'. D'......
Phone:
614.474.0240
It ... ... ... ... ...
, .
DU PONT STATEMENT OR BOVERS LANDFILL
- .
. -. . I
Fro. 1965 to 1968 we ciisposed of Kylar8 polyester .crap. and rolls that
didn't lIIeet custC'l",~T'. ~n~c1flcation in tha landfill. Va a180 dllpo.ad of
Kylar. polymer. wn1ch UlOW\ts to tha 8azaa aaur1al aoUdined in larla
phce.. Kylare. al you probably alraady kNnr. 18 a,,J;biD .beat of f118
with a variaC)' of everydAy use. 8uch .. food wrap 81\C! packastni.. Cbeaically.
Kylar8 18 tha 8&11e a. tha polyutar f1bar that 1. 1D 8UCh of our cloth1q. .
Su 11 quanti t188 of u uriah 8uch as paint. delrea.ara. lab ch..icala. aN!
maintenance .u~~lies have sone to the landfill, but the bulk of our .ater1al.
, ~
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.
, . ~
\lhan concerns de"elc,;cd over tha landfill. va falt it va. 18portant "that a
atudy ba done to daunaina vbather tha l&DoCiflll presantad any threat to hulth .
or th8 aurlrO'ml8Dt. For that r.u=. ':" asr..4 ~oDl .Y1t11JPC. ~.Jo$.Dt.;1 f\ml1
the $700,000 f.a.1b1lity .tudy. . ~ , ' ~
-. ..
tha f.as.ibll1ty .tudy lht. n1na alt.rnati~.. for dealine with the l.ndfill.
~A has alr.adY .tateci that it prafera Altarnativa No.4. Wa 1.al Alternativ,
Mo. :5 18 tha aore a1)1)ropriat. ..thoeS to acSdr... 8ZI'f concanw about the
landflll. Lat.. re.ind you of tha provisiona oftha cwo.altarD8t1va.. loth
of tha alternativa. call for p-oundvatar 8On1tor1n&. 'r..tr1ct1ns \l8a of and
ace... to tha .1te, "Meine aurfaca cSabr1a, aN! fJlprGYtnc aro.ion control,
flood protaction aN! drainaee. , ,
. :..t~ a. ..-';'. .".. i:,.
ID additioD. Alternative No, 3 call. for area. of the a1Cbt1n, landfill c:&~
which .h0'W8 aro.1on CO b. ident1fiad aDd rap.iraci vim natural clay 8011.
'. AcSd.1t10D&l
-------
r
. ..
.,
DU POt."'T !TAT~N1' ON BOVERS L\NDFru.
C!:aUDII8d )
Yh1le ~he cos~ of Alternacive No.4 is higher dhan chac of Al~erna~iv. No.3,
our main concern 18 noc che cosc but the environmental intrusion that
A' '"'- --..r;~ve !'to. .. 1111ghc ca~... In o~r opinion, removing existing vegetac10n
doe. not appear to be varranted;,vill dIsrupt ch. ecological .y.te~ currencly
in place.; v111 have & detrimental effect on the stabillty of the fl11 dde
.lopa; and vill create a contlD~ng, lone-tara 881DtaDADC. proble..
~
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Tha rt.ll8dlal 1nv..tlgatton Indicate. that there u no contInuing relea.e of
conC&llinant. froll the aite. Tha atuc1y..doa. DOt iDdicat. th&t dhe landflll
presenta a aUbatantlal threat whIch vould raqulre the aevere remedial mea.ures
called for 1n Alternat1ve No.4. 8ased on currantly avallabla 4ata, securing
che site and providing resular, long-tara 8Onltoring 1a all chat 1s called for
at the _ita. In ~e unlikely event that .onitoring {ncUcate. that a problem
18 ci8va10p1ng, prollpt relledIa1 action C&A.~~ t&Un.
Alchoush ch.ra 1- no Imm1nant h.alch or envlronmencal ris~ ~osed by the .ice,
",a feel 1t 18 prud.ent to 8Onltor ch. att.. to .._ure c...., enere 18 no future
problem. Ye feel thae AlternatIve No.. S :1a . 8Or. than aci8qUAte .ethod to
...ura chat ch. healch and emr1ronzaant of.ithe cpl8l\m1ty 1. protected.
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APPENDIX B
COMMUNITY RELATIONS ACTIVITIES
AT BOWERS LANDfiLL
/'
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COMMUNITY RELATIONS ACTIVITIES
AT BOWERS LANDFILL
Community relations activities conducted at Bowers Landfill to date have included the
fOllowing:
.
.
.
.
.
.
U.S. EPA conducted community interviews with local officials and interested
residents (March 1983).
.
U.S. [PA established an information repository at the Pickaway County District
Library in Circleville, Ohio (July 1984).
.
U.S. EPA held a public meeting to discuss and solicit public comments on the
consent order (March 1985).
.
u.s. [PA held a comment period on the consent order (February 22 to March 25,
1985).
.
U.S. EPA prepared a community relations plan (May 1985).
.
U.S. EPA developed a response to public comments (responsiveness summary) OD
the consent order (July 1985). .
u.s. EPA held a public meeting to discuss the responsiveness summary (August
1985 ).
u.S. EPA distributed an update on activities at Bowers Landfill (November 1985).
The Bowers Landfill Information Committee was established. Twelve meetings
were held before and durinl the remedial investigation and feasibility study
(RIfFS) (November 1985; January, March, June, August, and October 1986;
March, June, and September 1987; and January, June, and November 1988).
U.5. EP A developed and distributed a alossary and other materials to assist people
with non-technical backgrounds in understanding sampling results presented in RI
technical memoranda (May 1987).
u.S. [PA developed and distributed a fact sheet on applicable or relevant and
appropriate requirements (ARARs) (April 1988).
-------
. .
~ .""
.
U.S. EPA developed and distributed a fact sheet uplaining the preliminary results
of the RI (June 1988).
.
U.S. EP A developed and distributed a fact sheet uplainina the (inal RI results
and the results of the endan'serment assessment (EA) (September 19&8).
.
U.S. EPA held a public: meeting in Circ:leville to discuss results of the RI and EA.
Approximately 70 people attended (September 14. 198&).
.
U.S. EPA released the FS report and Proposed Plan for public review and
comment (February 19&9).
.
U.S. EPA held a public comment period on the FS and Proposed Plan (February
14 to March 16. 1989).
.
U.S. EP A prepared and distributed a fact sheet on the FS and Proposed Plan
(February 1989).
.
U.S. EP A held a public meetina in Circleville to present the results of the FS.
describe the Agency's preferred remedial alternative for Bowen Land(iU. respond
to citizens' questions. and record public: comments on the FS and Proposed Plan.
Approximately 70 people attended this meeting. A transcript of the meeting is
available in the information repository (February 21. 19&9).
-------
St.It.e of 0tU0 ~ ~OII ~e8CJ
Cent,.., Clstnct Omc.
PO ao. 'o.g 180C Wat~ Or
c::o.~mOUa 01110 ~56~"9
:6"\644-2055
~'c"'.rc F C~"f.
GC"""'or
~arc~ :5, :98;
RE: C~mments on ~~~posed
tor Bowers Landfill
~lan
Geo r qet. t.e Nel.ms
Ot~~ce of Public Atfalrs
Ue S. EPA, Reql0n V
230 So~t~ Dearoorn St~eet
Chicaqo, Ill1nols 60604
Dear Ms. Nelms:
Ohl0 EPA has several comments on the Proposed Plan tor Bowers
Landt1ll, tirclevllle, Oh1o. Secause ot uncertalntles not
addressed or answered in the Remedlal Inve.tlqation (RI) or
Feasl0i11ty Study (:S), Alternatlve . may be vlewed as an interlm
actlon rather than a tinal remedy. State ARAR's vlll only be met
:y Alternatlve 4 lt the conditions at the slte remain stable. If
the cond1tlons chanqe, State ARAR's may not b. m.t by th18
alt.ernatlve. Theretor., a more deta1led cont1ngency plan tor
emerqency removal and a more detaLled qround water 80nltorlng
proqram-are necessary lt the select.d re.edy 1. to b. accepted as
the remed1al action.
"
A detailed cont1nqency plan and a more extensive ground vater
.onltorinq ~roqra. 8ust be 1ncluded 1n the Record ot Cecls10n
(ROC). Secaus. U. S. EPA maintalns that the States have only
those rlqhts c.t torth ln Sectlon. 113 and 121 ot CERCLA and that
the State. are so.ehow precluded tro. entorc1nq Stat. lavs at NPL
sltes, addres.1nq th... i.su.. durin; the d..1qn pha.. vlll not
attord the State ot Ohl0 .ubstantlai .ean1nqtul 1nvolve.ent 1n
the lnlt1ation, dev.lop..nt, and sel.ctlon ot the re.edlal action
or lnsur. that the r...dy co.pll.. wlth.Stat. lav. Given the
limlted role a.slgn.d to the Stat. by U. S. EPA, conslderable
d.tall in the r...d1al alt.rnatlve must be aqreed to 1.medlately
it Ohio EPA 1. to concur wlth the ROC.
Th. Propo..d Plan do.s not describe the contingency plan that
will be implem.nted 8hould the pret.rred remedlal alternative
tall. Theretor., the ROC should acdre.s those 8ituation.
-------
APPENDIX C
RESPONSE TO PUBLIC COMMENTS ON
CONSENT ORDER FOR BOWERS LANDFILL
CIRCLEVILLE, OHIO
JULY 1985
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UNITED STATES ENVIRO~MENT At PROTECTIO~ AGE~CY
REGION 5
230 SOloTH DEARBOR~ ST.
CHICAGO. Illl~OIS 60604
If'" \ T" '14' . r"1 f' "')' O~
RESPONSE TO PUBLIC COMMENTS ON
CONSENT ORDER FOR THE BOWERS LANDFILL
CIRCLEVILLE. OHIO
JULY 1985
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INTRODUCTION
This report contains U.S. EPA Region V and Ohio EPA's response to pub'~c
comnents received on the consent order between U.S. EPA, Ohio EPA, E.I. du
Pont de NeMours and Company, and PPG Industries, Inc., under which Du Poct
and PPG will perform a Remedial Investigation and Feasibility Study of the
Bowers Landfill in Circleville Ohio. .
Included are the public comments received during the comment period, and the
Agencies' responses to them. The comments are condensed and paraphrased in
Section I for clarity or to combine similar comments. The full text of each
written and verbal comment is included in Appendix D. Because numerous detailed
comments were received on the subjects of community involvement and splitting
samples, specifically, the Agencies' response to those are detailed in Appendices
A and B.
As called for in the consent order, a 30-day public comment periOd was held.
The comment periOd began February 22, 1985. In response to requests to extend
the COMment periOd, written co~ents were accepted until April 24, 1985. A
pUblic meeting was held on March 14, 1985 in CirClevi11e, at which oral
comments were received.
CONTENTS
Sect~on I
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Agency response to comments
Response to comments on comnunity involvement
Response to comments on split sampling
List of commenters
Written comments and transcript of March 14
pUblic meeting
U.S. EPA memo of 10/84 regarding release of unreviewed
data, and Hazardous Substances List
-------
Comments from ACTION
1. Contaminant plumes may have moved off site. and so would not be
detected in the sampling plan as proposed.
RESPONSE:
It !s unlikely that the conta~inant plumes have moved entirely off
the site, 50 the sampling sites in the immediate vicinity of the
landfill are appropriate for this stage of the investigation. However
if the investigation should indicate a need fOr sampling farther off-'
site, the workplan allows for that. (See pages 4 and 15 of the workplan
dated 5/29/84, which say that additional monitoring wells or surface
water sampling can be added. The Quality Assurance Project Plan of
8/15/84, page 4 also says further investigation may be needed to
define the extent of contamination. The need for further investigation
will be determined as part of the RI report.)
so samplin should
g, ve a better
RESPONSE: The workplan (page 15) requires sampling during low and
moderate flows, so that samples will not be taken during drought
conditions. The agencies want to find maximum levels of contaminants, so
it isn't advisable to sample during flood times when contaminants
would probably be diluted. Also, the sampling points may be inaccessible
during flood times. . However, if the initial rounds of sampling
indicate a need for sampling during the spring, and the sampling points
are accessible, that wi11 be required.
3. Why isn't long-term sampling included in the agreement?
RESPONSE: The consent agreement COvers only the work needed during the
remedial investigation/feasibility study phase of the project. The
RI is intended to characterize the contamination from a site so th~t
a decision can be made about the best actions to take at the site. By
necessity, the investigation is limited in time. However, long-term
monitoring is a very important consideration for the future, and will
be considered during the feasibility study.
the cost of
or any costs
RESPONSE : There 1 s no ceiling of $400,000 phced upon the cost of the
RIfFS. The respondents' obligation is~o complete a remedial investigation
and perform a feas1bilty study of the site in acCordance with the RI/FS
workplan.
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BOWERS
pg. 2
5. The activities are strung-out over to long a time period. The
act;v,t,es should be scheduled s1multaneously.
RESPONSE: Some activities are overlapped to limit the amount of
time the study will take. Our experience shows that it.s difficult
to complete a remedial investigation in less time than is currently
scheduled, and we bel~~ve the schedule is realistic in light of the
complex nature of the work.
prior to the
RESPONSE: Background samples (baseline data) are part of the proposed
investigation. Surface water and sediment samples will be taken
from the Scioto River upstream from the landfill. At least one
monitoring well (W-9) will be located upgradient of the landfill
site, from which 50il and groundwater samples will be collected.
?rivate wells located in the area also will be sampled. 25 soil
samples, a number of which are located away from the l~ndfill,
should provide a reasonable basis to determine background soil
inorganic concentrations near the site.
Most of the organic contaminants of concern at the site do not occur
naturally. Therefore, any occurrence of the manufactured chemicals
would be above natural background levels. If upgradient sampling
locations are also significantly affected by these contaminants, then
further investigation might be warranted to differentiate the site-
related contaminants.
7. Split samples should be provided to the community.
RESPONSE: Addressed in attachment on split sampling.
8. Citizens must be notified prior to changes in samplin~ points, and should
be able to prov1de input.
RESPONSE: Addressed in attachment on cOmmunity involvement
RESPONSE: The Consent Agreement contains the correct CAS numbers for
vinyl chloride and dichloroethane. The most recent HazardOus Substance
List, and the detection limits for those substances, i5 attached.
All parties analyzing samples during the_site investigation will be
required to use this most recent list. In addition to the substances
listed, dioxin will be sampled for, using detection limits of 100 ppt
for water, sediments and 5011. O-xylenes will be analyzed under
total xylenes. Endosulfan I and II are listed as Endosulfan alpha
and beta, respectively, on the HSL. Clorodibromomethane is listed on
the HSL as dibromochloromethane. 1,2 diphenylhydrazine won.t be
analyzed because it breaks down easily during extraction so results
aren.t meaningful. Analytical methods for acrolein and acrylonitrile
are not effective. Flurotrichloromethane (referred to as dichlorodifbrono-
methane in the comment) does not appear in water samples. All samples will
be disposed of according to applicable state and federal laws.
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30WERS
pg 3
10. There should be quarterly public meetings.
RESPONSE: Addressed in attachment on community involvement.
RESPONSE: As part of the administration of the Superfund program,
Region V has resou~ces (ie. staff time, travel budget) allocated
to conduct community relations. Because there are so many sites,
the Agency has contractors to assist the region's community relations
staff. The contractors primarily prepare fact sheets, graphics aids
for public meetings, etc. The $11,000 budget for contractor support
for the Bowers site is separate from the RI/FS budget, and has
already been obligated. Money not used one fiscal year is carried
over to the next year. In our experience, $11,000 is more than
adequate to supply the community with materials; the typical budget
is $9,000. If more funds are needed, the region can request supplemental
funds from Washington, or the work can be supplemented by in-house
writers and graphic artists. The region has not found it appropriate
to give the Respondents responsibility for producing community
informational materials. It is U.S. EPA's policy to attempt to
recover all costs for a site, including community relations funds.
14. There should be an evacuation plan and a warning system for the
surrounding residents.
RESPONSE: Investigators from the Region's Emergency Response Section
visited the site in May 1985 to assess whether any immediate threat may
be posed by the site. The Agency concluded that there isn't a need
for an evacuation plan during the RI/FS portion of the project.
This decision is based on the following:
1) no air contamination was detected with specialized equipment used
during the recent investigation;
2) the large distance on the downgradient side of the landfill between
the drilling locations and the residences;
3) a11 drilling will occur outside the landfill boundaries so that any
containerized ..terial will not be affected;
4) because any gases encountered f n the subsurface dur; ng dri11i. n9
will be uncontained they will dissipate;
5) if any gases are released to the surface during drilling, the
wide open area in which the landfill i.s situated allows for sample
dissipation of gases, and - .
6) during drilling, the air will be continuously monitored.
A specialized Health and Safety Plan will be prepared for the site
which will include an evacuation plan for site workers, consultation
with the closest fire department, hospital, etc. A copy of the site-
specific plan will be made available when it is completed.
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B OWE RS
pg 4
landfill in various
an f1ll 1S referred
RESPONSE: The area to be investigated is the area of the property that
was used for disposal of waste. That area is 12 acres, according to
site records. On the long leg of the uLM shaped site, the landfill
is 3000 ft north/south; it is another 1000 ft. in length on the short
leg, which totals 4000 feet. The other dimensions are approximately
120-125 ft and 10-15 ft. The agencies consider 1958 or 1959 to be the
year the site began operating, and 1968 as the year the site became
inactive, although new information appears to show that the site
closed in 1969.
emer ency criteria of the NCP
unt1ng, children's play an
RESPONSE: As a result of this comment, Region V's Emergency Response
team evaluated the site in May 1985 to determine whether site access
does pose an immediate health or environmental threat as defined by
the National Contingency Plan. They determined that a fence is not
neces sary because:
l} the only unnatural material observed at the site was drums which
all appeared to be empty, and plastic nonhazardous material, and
2} the site held a full spr-ead of vegetation, which indicates that
the topsoil may not be contaminated.
U.S. EPA wil' erect additional warning signs at the site, particularly
at the small access paths along the west side of the site.
17. What is meant by trade secret? What ty es of information does this
nc u e. at recourse 0 c1t,zens ave to obta1n 1n ormat10n
classified as CBt. All data should be released to ACTION.
RESPONSE: No information is being withheld regarding the site because
it is considered a trade secret or business confidential, and we do
not expect that any information generated during the RIfFS would meet
the criteria for business confidentiality. The regulations explaining
these concepts can be reviewed under Section 2.201-2.215 of the Code
of Federal Regulations, and Section 149.43 of the Ohio Revised Code.
18. Any place the word 8memorandum" is mentioned in the consent agreement,
ft should be replacedby -reports, documentat10n or sampling oata."
RESPONSE: Whether a document is desc~ibed as a memorandum or a report
does not affect its confidentiality or make it exempt from disclosure.
A document is judged on its content and not on its title. U.S. EPA
does not withhold information only because it is labeled 8memorandum.1I
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BOWERS
pg. 5
19. Raw data snould be provided to ACTION and tne county health department
at t~e same time EPA and industry receive it. Prior notice should be
prov1ded of any changes to the various plans.
RESPONSE: \ddressed in the attachment concerning community involvement.
20. What are the standards for treating volatile samples?
RESPONSE: Volatile organic analysis of water samples must be performed
within 7 days of the sampling date, and soil sample analysis must be
performed within 10 days of the sampling date. Acid and base neutral
extractable compounds, pesticdes and PCB water samples must be extracted
within 5 days (10 days for soil) of sampling date and completely analyzed
within 40 days of extraction. The holding time for low and medium
concentration inorganic compounds, along with sample handling requirements,
are listed in Appendix B, Table 1 of the Quality Assurance Project Plan.
A holding time is the period in which a sample remains stable enough
to be analyzed, and therefore can be used to represent its source.
"Not established" means the time is not a clearly defined number or
a universally agreed upon number. In those cases, the agencies require
that samples be analyzed in a timely manner that will allow the project
to progress. .
All samples will be taken, preserved, shipped and packed as indicated
in Appendix B, Table I of the QAPP, as noted in the consent agreement.
21. Work should not continue unless EPA roject directors are onsite. If not,
1n ustry shou d payor a c1t1zen representative to be ons, tee
RESPONSE: As a result of this comment, and others received, U.S.
EPA has arranged to have a representative from PRC Environmental
Management, Inc. onsite overv;ewing all field activities to
ensure that the PRPs comply with the Administrative Order and the
National Contingency Plan. One representative will be on site
during all field activities. An additional person will be on site
when samples are taken. Ohio EPA plans to have a representative
onsite during important field activities.
. 22.
ACTION questions the U.S. EPA project mana~er's expertise.
RESPONSE: Erin Moran has an exc~llent .educational and professional
technical background, and is one of the ~~n.ior members of Region
V's Superfund staff. The role of the Remedial Project Manager is to
manage and coordinate a number of technical projects and evaluations
that are needed to successfully investigate a site. For specific parts
of an investigation, the project manager may call upon the expertise
of specialists who have specific training for that part and who can
spend a great deal of time on that particular aspect. This is
especially true for complex sites. It is not at all unusual for EPA
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BOWERS
pg. 6
project managers to seek assistance from a number of hydrogeologists,
biologists, chemist~ or soil scientists, for example, to aid in a
site investigation. At the March public meeting, Ms. Moran deferred
Questions to the hydrogeologist present because some citizens had
specifically requested that a hydrogeologist attend the meeting. The
region believes that Ms. Moran is able to fulfill the demanding jOb of
project manager.
RESPONSE: A steel cable with U.S. EPA warning signs has been placed
. at the southern entrance to the site, which limits access to the Bowers
Landfill and to Quarry B. OEPA has observed the site, and has determined
that the cable prevents removal of gravel from the site. Because the
gravel pit is upgradient of the fill, it is unlikely that the gravel ;s
contaminated by the site. To be sure, the RI/FS workplan calls for one
surface water sample to be taken from the quarry east of the site.
RESPONSE: The National Contingency Plan requires U.S. EPA ,to solicit public
comments on its recommended remedial action for a site, and to consider
those comments in making a final decision. EPA guidelines suggest a three
week public comment period; however, the region can provide more time at
its discretion, if it won't significantly interfere with the agency
being able to take action at the site. A pUblic meeting definitely will
be held to discuss and take comments on the various cleanup alternatives.
U.S. EPA and OEPA are required under law to dispose of hazardous waste
in a safe and proper manner, and both agencies will go beyond what is
minimally required to be sure hazardous wastes are disposed of properly.
26. A public meeting should be held to explain decisions made on the basis
of the comments.
RESPONSE: A public meeting will be held to describe the final consent
agreement, and to explain how the comments have been responded to.
TRINITY LUTHERAN CHURCH
ALFRED KREBS
1 .
problems at Bowers cannot
RESPONSE: The Superfund law allows U.S. EPA to have the parties considered
potentially responsible for hazardous materials at a site to pay for and
conduct investigations and clean ups under the close supervision of EPA.
In fact, the agency is required to try to recover any money it spends from
private parties. Having the responsible parties conduct the investigations
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BOWERS
pg. 7
saves public monies for those sites where no potentially responsible
parties can be found. However, the agency ~till maintains control over
the objectivity of the investigations. The parties enter into a legal
agreement with U.S. EPA (and in this case, Ohio EPA also) that requires
them to perform the work using plans approved by the agencies, to follow
EPA quality assurance guidelines, and to submit all information to the
agencies for approval.
MURIEL WRIGHT
1.
RESPONSE: U.S. EPA and Ohio EPA extended the comment period on the
consent agreement because of numerous comments received that 30 days
was insufficient time to evaluate the complex workplans. The agencies
determined that extending the comment period would not significantly
affect the inYes~igation schedule.
CITY OF CIRCLEVILLE, DEPT OF PUBLIC UTILITIES
JOHN A. JORDAN
1.
Who will actually be doing site work needs clarification.
RESPONSE: The work will be done by a contractor or contractors hired by
PPG and duPont. As soon as the names of the specific contractors are
known, they will be made public.
2.
CH2M Hill and Warzyn have contracts with the federal government, and
have worked on this project until the present time. Another U.S. EPA
contractor, Camp, Dresser, MCKee, and PRC EnYironmental Management, Inc.
will function as consultants to U.S. EPA and Ohio EPA as the agencies
overview the work performed by the respondents and their contractors.
Has U.S. EPA received permission from property owners to do testing on
the site and adJ01n1ng areas?
RESPONSE: Under the consent agreement, Part II, the Respondents are
required to 9ain access to the property to do the required work. Access
to the landfill has been achieved, and that agreement is attached to the
consent agreement in Appendix A. The Respondents a1so are required to
obtain any agreements necessary to provide access to U.S. EPA, Ohio EPA
and their authorized representatives.
Who will be on the project team?
3.
RESPONSE: Erin Moran is the Re~edial Project Manager for U.S. EPA for
the Bowers Landfill project. Lundy Adelsburger is the project manager
representing Ohio EPA. Also, U.S. EPA has contracted with the firm
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BOWERS
pg. 8
4.
PRC Environmental Management, Inc. to represent Ms. Moran on site
during all field activity to ensure that the Respondents comply with
the consent agreement and the National Contingency Plan.
The city should have access to test data as it becomes available. .
particularly groundwater analyses. Who will do analyses for the agencies.
and other part,es.
RESPONSE: Addressed partially in attachment on community involvement.
U.S. EPA and Ohio EPA contract with labs to ~erform the analyses. Other
parties can have any lab that follows the Quality Assurance Project Plan
for the site perform their analyses.
5.
RESPONSE: We" dri111ng causes only very localized turbidity in the
groundwater; any disturbance would be right at the installation point.
. Drilling wells through the landfill could potentially make conduits
for contamination, so no wells will be drilled through the sit!.
Based on existing information on the site's hydrogeology and
predominant types of contamination, the contaminated groundwater from
the site is probably flowing into the Scioto River near the landfill.
The proposed m~n;tor1ng we" system ;$ designed to detect contamination
going that way. There is a potential for contaminants that are
heavier than water, such as chlorinated organic compounds, to sink
within the groundwater flow system beneath the site. To ensure that
this type of situation is adequately investigated, the Work Plan and
Quality Assurance Project Plan will be modified to change the location
and depth of the deep wells. Monitoring well P4B will become P5B at the
southern tip of the landfill. All of the d~ep monitoring wells (P5B,
P6B, and P8B) will be drilled to the underlying shale formation instead
of to the 100 foot depth limit. The well screens will be placed just
above the shale unless contaminated zones are detected above the shale
as noted in the Work Plan and QAPP.
(j
If sampling results are inconclusive or contradictory or are
1~suff1c1ent to allow the agencies to develop a plan for remedial
action at the site. additional sampling wil' be required.
RESPONSE: The infiltration gallery was abandoned since the site Workplan
was written. The plan will be changed to reflect this comment.
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BOWERS
pg. 9
7.
off ponded water alon the western
th1S .done and what were the resu ts?
8.
RESPONSE: During a site visit by U.S. EPA, OEPA, CH2M Hill, and
Warzyn on FebrLJ'y 23, 1984, an HNU photoionizer detected low levels
(2.2 parts per million) of 'volatile organic gases immediately above a
leachate seep on the west side of the north-south landfill berm. No
other readings above background were reported during the site visit.
Will U.S. EPA split samples with Pickaway county, and if so, who will
do analyses?
RESPONSE: Addressed in attachment on split sampling.
9.
Has U.S. EPA abandoned theory of one upgradient and three down gradient
mon1tor,ng wells?
RESPONSE: The three downgradient, one uP9radient well is a requirement
for monitoring sites under the Resource Conservation and Recovery Act.
The quanity and location of wells installed during remedial investi-
gations of CERCLA sites is based on the scope of investigation needed
to identify a re~edy for the site.
10. What will the monitoring wells be cased with?
RESPONSE: All monitoring wells, except W-l2 and W-13, will be
constructed of threaded PVC well casings and stainless steel well
screens. Monitoring wells W-l2 and W-l3 will be constructed with
stainless steel.
11. The City wants a list of detection limits for samples.
RESPONSE: The list is attached.
PICKAWAY COUNTY BOARD OF COUNTY COMMISSIONERS
DONALD STRaUS, RALPH ANKROM
u
1 .
The county wants to submit names for citizen representation on the
research project team.
RESPONSE: Addressed in attachment on community involvement
2.
Split sampling should be conducted ~uring the:testing.
RESPONSE: Addressed in attachment on split sampling.
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BOWERS
pg. 10
ORAL COMMENTS RECEIVED AT PUBLIC MEETING, MARCH 14, 1985
Most comments received at the pUblic meeting were repeated in the written
comments, and so are addressed in the preceding pages. The following comments
were presented at the meeting, but not in writing:
1. .Page 42, Cynthia Gillen. Ohio EPA sHould send ACTIDN results from
previous samp11ng.
2.
RESPONSE: Ohio EPA sent Ms. Gillen copies of sampling results from
C1rclevil1e and Earnhart Hill Water District.
Page 79 Linda King. Will dioxin be tested for?
RESPONSE: Dioxin will be sampled for in the first round of
and groundwater testing.
soi 1, sediment
3.
Pa e 86, David Cannon. It is a ropriate to extend the comment eriod
Y ay s .
RESPONSE: U.S. £PA and Ohio EPA extended the pUblic comment periOd
by 30 d.JYs.
4.
Pa e 87-88, Linda Kin ~ Air monitorin should be addressed in the a reement.
RESPONSE: Monitoring of air quality will be performed while investigators
are onsite. This is primarily for the safety of onsite workers because
of their close proximity to site contaminants, especially during well
drilling and other activities that disturb existing conditions. However,
the air quality monitoring will also be applicable to evaluating conditions
that could affect the safety of nearby residents.
The air quality monitoring consists of measuring volatile organic gases
and explosive mixtures of 9as. All soil borings will be monitored for
volatile organic gases. as specified in the Work Plan, page 11.
5.
RESPONSE: U.S. EPA and Ohio EPA's goal is to get the site investigated
and cleaned up if necessary, and we appreciate everyone's support.
6. Page 90 Ral~h Dunkle. There is evidence that material 1$ still bein~
disposed of at the site. .
-
RESPONSE: U.S. EPA and Ohio [PA have no evidence that dumping is still
occurring at the site, but any infonnation to the contrary should be reported
immediately to one of the agencies.
. page numbers refer to the pages of the official transcript
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BOWERS
page 11
7.
contaminants
8.
RESPONSE: Contaminants during drilling are very unlikely to reach any
citizen not actually on the site near the drilling. See also response
to written comment on page three.
Page 95 Marsha Schneider. The order should inclu~~ provisions to protect
the rights and property of ad~acent land owners.
RESPONSE: Under the consent agreement, the respondents are responsible
for contacting the landowners and making arrangements with them for
access to their property. By signing the consent agreement, the respondents
have no more rights than they had previously concerning access to any
. land, including the Bowers Landffll ftself.
9.
RESPONSE: Ms. Beck was responding by telephone in February 1985
to members of ACTION who were very concerned that the Bowers site was
flooding. Ms. Beck indicated that unfortunately many landfills were.
put into wetlands and floodplains, so that the region has several cases
of flooding Superfund sites. In saying that we had successfully dealt
with the s;tes, Ms. Beck meant on an emergency basis, such as erecting
berms or dikes, draining a sfte, or diverting water, in cases where
contaminants threatened a water supply. Examples are Seymour and
Enviro-Chem in Indiana, and A&F Materfals fn Illinois.
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BOWERS
pg. 12
the spread of contaminants already in the groundwater or 50;1. That
problem would be addressed with another option.
12. Page 116-117 David Cannon.
commun1ty. prOV1S10ns S au
results will be useful.
----.
RESPONSE: Addressed in attachment on split sampling.
13. Pa e 117 Mary Anne Edsa11. The pUblic conrnent period ,should be extended.
RESPONSE: The public comment period was extended by 30 days.
RESPONSE: All viable alternatives must be considered in evaluating the
best method for cleaning up a hazardous waste site. Even if incineration
is considered, it doesn't mean it will be chosen for this site. We can't
speculate on future local laws that may come into effect, but every
effort will be made to accommodate local concerns, and to clean up the
site in a safe and environmentally responsible manner.
v
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Bowers
pg. 1 3
APPENDIX A: RESPONSE TO COMMENTS ON COMMUNITY INVOLVEMENT
Many of the comments received on the Bowers consent order concern citizen
involvement in the investigation. The county commissioners requested that
U.S. EPA and Ohio EPA include citizen representation on the -research
project team.M The citizens' group, ACTION, had several comments. They
requested: prior notification of r~1nges in any plan and in sampling
poi nts, quarterly publi c meetings, .representati on on the project team
(they prefer a rotating membership), and all raw data. Other commenters
suggested the public be involved in the project to the extent possible.
Both U.S. EPA and Ohio EPA believe that community involvement is a critical
element in the success of a Superfund project. The agencies discussed the
comments at great length, and have developed the following plan for
fulfilling the residents' desire to be informed and involved in the
project, and the agencies' obligation to keep the project scientific,
on schedule and consistent with agency pOlicies:
Information committee. U.S. EPA and Ohio EPA will develop a committee
representing the county, city, citizens' groups ACTION and L-ECHOS to
meet regularly with project staff and to provide documents for discussion
and review. The meetings would occur at least every other month in
Circleville, and would be open to anyone else who wished to observe.
Purpose: To disseminate reports, data, and progress reports related to the
remedial investigation and feasibility study of the Bowers Landfill. To
provide liaison function with the rest of the community. To provide input
to U.S. EPA and Ohio EPA, although the committee will not be a decision-making
body and will not have authority t~ override any agency decision.
Structure: One member Should represent the Pickaway County Board of
Commissioners, the city of Circleville, the Pickaway County Board of Health,
ACTION, and L-ECHOS, Ohio EPA, U.S. EPA, the Responde~ts and perhaps one
at-large position. Each organization would choose its member, but for the
purposes of consistency and effectiveness, the agencies ask that-the same
member (and a designated alternate, if desired) serve throughout the life
of the project.
Format: Throughout an RIfFS a number of documents and reports are generated
that generally are not reviewed by the community. However, U.S. EPA and
Ohio EPA are able to disseminate the documents under certain conditions.
- We anticipate that we would provide them to and discuss them with
the commmittee. The following are documents that the Respondents will be
required to provide to the government, and that EPA would then provide to
the cOlYl11ittee:
Work plan
QA/QC plan
site safety plan
geophysical survey
biological survey
-more-
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Bowers
Pg. 14
We will make
reviewed) of
available second drafts (ie. after U.S. and Ohio EPA have
the fo11 ow; ng:.
RI report
Exposure Assessment (EPA will actually do this report)
Feasibility S~udy (this is always made available for
pUblic conment)
Raw data. We cannot provide raw data that has not been through quality
assurance/quality control procedures. Attached is an October 4. 1984
memo from William Ruckelshaus, then administrator of the agency, which
describes the Agency's policy regarding the release of unreviewed material.
This policy is still in effect. Once the data from the site has been
through the required quality assurance/quality control procedures, the
agency can provide all data and not just summaries.
Representation on the project team. Several of the comments asked that citizens
be put on the "project team." The information committee is in lieu of that
request because U.S. EPA and Ohio EPA cannot put a citizen on the project team
for the following reasons:
Members of the .project team" as defined by the consent order are authorized
to 1) take samples or direct sampling, 2) stop work, 3) make minor changes
in field work, 4) observe, record or photograph the work, and 5) review
records, files and documents.
We are not able to give citizens the authority for numbers 1,2,3. Number 4
could be allowed only at I distance, as we are not able to allow citizens
on the site for safety and liability reasons. Number 5 will be accommodated
by the information committee.
5. Quarterly pUblic meetings. ACTION requested that the agencies hold quarterly
pUblic meetings to inform the community of the progress at the site. If there
appears to be need for the meetings, they will be held. However, it may be
that the more regular meetings with the information committee will fulfill
that function. In addition, U.S. EPA will provide regular written updates to
the conununity.
"
-
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,- I
.,.. ...,,:
Bowers
pg. 15
APPENDIX B: RESPONSE TO COMMENTS ON SPLIT SAMPLING
In addition to the comments received during the comment period on the
consent order. U.S. EPA received a petition from Circleville residents
and a letter from William A. Myers. M.D.. Pickaway County Health Commissioner,
requesting that split samples be provided to the residents.
As allowed under the consent order. U.S. EPA wi" provide a representative
of the Pickaway County Board of Health, a set of split samples. Dr. Myers
offered his assistance in facilitating the provision of split samples
from u.S. EPA.
u.S. EPA and Ohio EPA request that the analysis of these split samples strictly
adhere to all the requirements of the Quality Assurance Project Plan for
this site, which has been approved by EPA's Quality Assurance Office. The
Respondents' samples and U.S. EPA and Ohio EPA's samples must also adhere to
the requirements of the QAPP. The QAPP contains highly sophisticated, state
of the art technical requirements which must be observed so that contamination
at and from the site can be successfully classified. EPA will acknowledge
only those samples that have followed the QAPP for this site.
ACTION further requested that industry assume financial responsibility for
the citizen's splits. Respondents are only required to undertake the
measures that EPA would undertake if EPA was conducting the RI/FS with
federal money. EPA does not fund citizens' split samples because the
scientific quality of the project is ensured by a QAPP. and citizen samples
are redundant. EPA will not require the Respondents to finance the citizens'
samples. .
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B owe rs
pg. 16
APPENDIX C: LIST OF COMMENTERS
Oral Comments were received at t~e Ma,.c~ 14, 1985 public meeting from:
1. David Cannon, PPG Industries, .Inc.
Z. Cynthia Gillen, ACTION
3. Linda J. King
4. Garry Betts, ACTION & self
.5. Ralph E. Dunkel, ACTION & self
6. Mary Anne Edsall
7. Mark Scarpitti, Soil Conservation Service
8. Marsha Schneider
9. William A. Myers, M.D., Pickaway County Health
Commissioner
Written comments were received from:
1. Linda King (December ZZ, 1984 letter regarding split samples)
Z. William A. Myers, M.D. (January 9, 1985 letter regarding split samples)
3. Linda King, Mary Anne Edsall, and Cynthia Gillen, ACTION
4. Pastor Alfred Krebs, Trinity Lutheran Church
5. Muriel Wright
6. John. A. Jordan, City of Circleville, Department of Public Utilities
7. Donald E. Straus and Ralph W. Ankrom, Pickaway County Board of Commissioners
-------
Appendix 0: Written comments and transcript of March 14 public meeting
.
(NOTE: The transcript includes only those portions with pUblic comments;
a complete copy of the transcript is available from EPA.)
~
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