United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EP AIROD/A05-91/154
November 1990

Cory (
pR q 1. - ':H~ 4 II g
oEPA
Superfund
Record of Decision:
Summit National Liquid
Disposal Service
(Amendment), OH
u, S. Environmenta' R t t. .
~egIO~ IU HUarcfous V::s't; 'on Agency
~1~_'nformat;on Center
Ph~:2tnutrtStreet t 9th Floor
.~~naB r'A 19107
Hazardous Waste Collection
Information Resource Center,
US EPA Region 3
Philadelphia. PA 19107
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107

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80272-101
REPORT DOCUMENTATION 11. REPORTNO. .
PAGE EPA/ROD/R05-91/154
.....
8IId S&mfle
PERFUND RECORD OF DECISION
Summit National Liquid Disposal Service, OH
First Remedial Action - Final (Amendment)
7. Authar(a)
I ~
3. Reclplenfa Acce88lon No.
5. Report Date
11/02/90
6.
8. Petfonnl"ll Organization Aept. No.
8. P8rfoImI"ll Orgalnlzallon Name 8IId Add....
10. ProjectlTuklWork Unit No.
11. ConIrIIct(C) or Grant(G) No.
(C)
(G)
1~ ~ Oreanlzatlon Nama 8IId Addre8a
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 RaporI& Period Covered
Agency
800/000
14.
15. SuppIamanIary No..
11. Aba.act (UmIt: 200 _1118)
The 11.5-acre Summit National Liquid Disposal Service site is a former liquid waste
disposal facility in rural Deerfield Township, Ohio. The site contains two ponds, an
inactive incinerator, and several vacant buildings. Surrounding the site are several
residences, two landfills, light industries, and farmland. Fifteen to twenty
~esidential wells are located within 1,000 feet of the site. From 1973 to 1978,
~it National operated a solvent recycling and waste disposal facility on site.
viI, resins, sludge, pesticide and plating wastes, and other liquid wastes were
stored, incinerated, and buried or dumped onsite during facility operations. In
1978, the State ordered Summit National to stop accepting waste material and to
remove all liquid waste from the site. In 1980, EPA removed three bulk tanks, which
contained approximately 7,500 gallons of hexachlorocyclopentadiene along with
contaminated soil, and treated some contaminated water. In 1981, the State and eight
of the potentially responsible parties removed additional drums, tanks, surface
debris, and a small amount of contaminated soil from the site. Subsequently, EPA
took interim measures to control the migration of contaminants offsite and excavated
an underground storage tank. During the RI/FS, conducted from 1984 to 1987, EPA
.
(See Attached Page)
17. Doct8n8nt Analyala L Dncripto18
Record of Decision - Summit National Liquid Disposal Service, OH
First Remedial Action - Final (Amendment)
Contaminated Media: soil, sediment, debris, gw, sw
Key Contaminants: VOCs (benzene, toluene, TCE, xylenes), other organics (phenols,
PAHs, PCBs), metals (arsenic, chromium)
... IdanIfl8n/Op8n-Endad T-
c. COSA 11 R8IcIIGroup
lilabllty Statem8nI
19. SeCl8'lty CI... (1hla Report)
None
21. No. of Pagea
44
20. Security Cia.. (1hia Page)
Nnno
n PrIce
CSae ANSl-Z38.18
SMlIM/rUclione on RevellJe
\W IIUNAL
..77)
(Formatty NTlS-35)
Depal1ment of Commerce

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EPA/ROD/ROS-91/1S4
Su~~it National Liquid Disposal Service, OH
. F : Remedial Action - Final (Amendment)
Abstract (Continued)
documented onsite contamination of soil, sediment, ground water, and surface water by a
variety of organic and inorganic compounds. Contaminated property outside the site
perimeters also was found. This Record of Decision (ROD) amends a 1988 ROD that provided
for remediation of contaminated soil, sediment, debris, ground water, and surface water.
Based on further site investigations, EPA modified their original goal of containing
contaminated media to one of long-term cleanup at the site. In both the 1990 proposed
remedy for this ROD amendment and the 1988 ROD, the remedy for the most highly
contaminated soil and sediment is excavation and treatment; however, the ground water
extraction method in the 1990 proposed remedy was significantly different from the 1988
ROD and employed a different technology that will result in long-term soil cleaning, thus
eliminating the need for containment of contaminants with a slurry wall and multi-layer
cap as provided in the 1988 ROD. The primary contaminants of concern affecting the soil,
sediment, debris, ground water, and surface water are VOCs including benzene, TCE,
toluene, and xylenes; other organics including PAHs, PCBs, and phenols; and metals
including arsenic and chromium.
The amended remedial action for this site includes expanding site boundaries to include
contaminated areas along the site perimeters; excavating and incinerating onsite 24,000
cubic yards of soil excavated to a depth of 2 feet, 4,000 cubic yards of sediment from
the site perimeter, drainage ditches and offsite ponds, and 900 to 1,600 buried drums,
followed by backfilling the residual ash onsite, or disposing of the ash offsite in a
RCRA facility if the waste does not meet EPA performance standards; regrading the site;
i aIling a permeable soil cover over 10.6 acres of the site with gas vents for treating
o ,nonitoring potential air emissions; dismantling and/or demolishing all onsite
structures, and disposing of debris onsite; collecting ground water from the upper
aquifer via pipes and drains, and constructing additional extraction wells in the lower
aquifer to augment the pipe and drain system, followed by treating ground water onsite;
collecting and treating onsite surface water from the two onsite ponds and drainage
ditches using precipitation, flocculation, coagulation, oil and water separation,
filtration, and carbon adsorption using a pipe and drain collection system; excavating
sediment after dewatering the ponds and ditches; relocating one vacant residence;
rerouting the south and east drainage ditches to an uncontaminated area beyond the site;
ground water monitoring; and implementing institutional controls including deed
restrictions. The estimated present worth cost for this amended remedial action is
$34,400,000. NO O&M costs were provided for this amended remedial action.
PERFORMANCE STANDARDS OR GOALS: Performance standards and goals were detailed in the
1988 ROD. Soil clean-up will attain a 2 x 10-5 cancer risk level. Discharge levels for
treated ground water and surface water will meet Federal and/or State water quality
standards. Individual clean-up goals for soil and ground water contaminants were not
provided.

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. "
~ OF IE:ISI~ AMEH:MENr
SITE IWm AIm JDCATI~

SUDmit Natimal site
Deerfield, ado
~ C1P MSIS AND ~ w:m
'!his decisiat docl1~11t p1:esents the selected ~j81 action for the SUImnit
Nat.ia1al site in Deerfield, arlo, develqm in aoccrdanoe with CERCIA, as
amended by SARA, am the National 0Jn'tin:;Jerx:y Plan. '!his decision is based

ell the adm:i.ni.strative record for this site. '!be attached index identifies the
items that c:xmprise the administrative record upon which the selection of the
~bl acticn is based. '!his decision amen:1s the Record of Decision dated
June 30, 1988.
'!be State of ado has concurred in the selected temedy.
I~~.~(fi OF 'DIE Dm\trFn ~
'Ibis ~~ will cxmplet.e the rerredial action for the site. '!he major
OJ"\~ of the selected Le1uedy are:
1. Exparx:lin:J site bc:AIrJjaries to include c:xmtaminated areas alCJn; the


perimeters and the scuth drainage ditch and constructin; an a-foot chain
link fence arcund this exparded ~.
2. Exravatin:J am incineratin::J (in an on-site facility) soils and sediments as
follows:
O:I1timIinated perimeter sedilnents:
(inclu:tirJ) drainage ditches)
24,000 c.y.
4,000 c.y.
O:I1timIinated soils at-Site:
o:mt:ents of bD:'ied drums
900-1600 drums
3. Dismantlin;J arxVor deril:>1i.shin;J all on-site structures for on-site c:ii.sp:6al.

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2
4. 0ill.ectin;J am treatin;l surface water fran two an-site p:n:ls am drainage
c:1itches. ~i~ WOJld be excavated after pc:nm am ditches are
cJewatered.
5. EKt:racti.n:J gramdwater for treatment fran the varicus levels of the water
table cm-site by two basic o.....'I.cnents:
8. A pipe am media drain system alm:] the scuthe.m bourxmy am lower
portia1S of the eastern am western bamdaries rather than a system.
of wells to extract am treat contaminated gramdwater.

b. Aatitia1aJ. extraction wells installed in the intermediate unit to
au;JIIIel1t the pipe am media drain system.
All water extracte::l will be treated with an on-site treatment system.
6. Relocatin:J CI1e vacant residerre.
7. Incinerated waste material will be tested to ensure it conforms with u. s.
EPA am Chio EPA standards am used as fill to regrade the site before the
final cx:wer is placed over the surface. If it fails the tests the waste
will be placed in an on-site RCRA landfill.
8. ~ site am installin;} a soil CXNer over 8R>roxima.tely 10.6 acres of
site. 'lhis cx:wer will consist of an IS-inch layer of loam am 6 inches of
tq:soil with gas vents installed for treatirg am m:mitorirg potential air
emissia1S.
9. R1er'a1tinJ scuthe.m am eastern drainaqe ditches to an Ul'1OCI'1taminated area
beyond the site.
10. '1he total CD;t of the remedial action defined in the 1990 pl~ is
$34.4 millim.

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3
IB::rARATION
'Jhe .selected .L~ is protective of human health and the environment, attains
~al and State requirements that are ~licable or relevant and awrq:>riate
far this ~b1 action, and is cxst-effective. 'lhi.s .L~ satisfies the
~ preference for remedies that euplay tteatment that ~~ toxicity,
18t'Jhn ity, or volume as a principal e1emer1t and utilizes penanent solUtions
am alteznative treat:De1t t:.ec:hooloqies to the max.iIIum extent practicable.
~~ this ldu=aly will result in hazarI::bJs S\Jbstargas remainin;; on-site
abcNe bea1th-based levels, a review will be conducted within five years after
n..._~t. of %8Dedi.a1 action to ensure that the lemedy continues to provide.
rotectian of human health and the environment.
fl t.£
tloV~ ~ Iffo.
I
Date
tor

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mcrsI~ SUfoW\RY
StHtIT NATIc::tU\L SITE
IEERFIEI.D, ano
SIB BIS.ltmr AND JWXa:Om
'!he Suamit Natiaal site, a fozmer liquid waste ni~l facility, is looatai
en an abamcned coal strip mine at the intersectioo of QUo Rcute 225 and u. S.
ID.1te 224 in Deerfield, QUo; 20 miles west of y~, and 45 miles
scut:heast of Cleveland. '!be 11.5 acre fenced site oart:.ains two pon:is, an
inactive incinerator, and several vacant tuild.in3s. T~j::!ltely surrcun:ti.n;
the site are several rural residerx::es, two landfills, light imustries and
fcmnland.
FraIl 1973 to 1978, SUnmit National aooeptej liquid wastes inclu:tin;J oil,


resins, sl\d:Je, pesticide wastes and platin; wastes in drums and tank tJ:ucks.
'1hese wastes were stored, incinerated, bJried or c:il.mped at the site. In June
of 1978, alio EPA ordered summit National to stq) reoeivin; waste and to
remcve all liquid waste stored at the site, and in 1979 filed a oarplaint
against the cparators for failin; to oarply with State regulations regardj.rq
the hardlin; of solid and liquid wastes.
arlo's sauplin; of cn-si te soils and surface water indicated the presence of
hazarcku; substances potentially harmful to pmlic health ard the envirtnnent.
In 1980, ado EPA aI1Structed a ferDe ara.n:1 the site, installed a drainage
system to CXI'1t::rol surface water flow crrt:o and off the site and six grcurd
water DD1itorin:J W1ells. '!be same year, urxler authority granted in Section 311
of the Clean Water Act, U.S. EPA rem::rved three liquid storage tanks and their
CD1tents and saDIe a:ntaminated surface soils fran the site. In 1981, an
¥-=uent between QUo and eight of the Potentially Responsible Parties

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2
resulted in a $2.5 millial surface clearmp vuch removed drums, tanks,
surface debris and a small amamt of oontaminated soil fran the site. In
1983, U.S. EPA p]~ the site al the Natia\al Priorities List, a federal
rester of the naticm's uncontrolled or aban::Ja1ed hazarda1s waste sites
eligible for clearJJp under the SUperfund ~l4w. Fran 1984 thrcu:Ih 1987,

U.S. EPA a:n:Jucted a ~ia1 Investigatial (a J'II~..r of scientific studies
CD1duct:ed to cIetemine the nature and extent of oontaminaticm prcblEIDS) am a
Feasibility St1.Jjy (an evaluation of remedial alternatives) to define am
evaluate the alternatives for addressin;J the existin;J oontamination identified
c:Jurin:J the .~;;., Investigation. u.s. EPA also took SCIDe interim measures
to oalt..lJl the migration of contaminants off-site am excavated an Ul'dergra.D1d
starage tank due to CXIDm1 that hazardOJS suI:st:aras CXI1tained in the tank
miCJbt leak and oontaminate the ~ter.
'!be ~Hal Investigation confirmed the presence of oontamination at-site in
the gramdwater, soils, pon:i ~iJIIP1'1ts am surface water. In acktition to 00-
site oontaminatia\, property outside the site perimeters was also fourx:l to be
CXI1taminated. A variety of organic am inorganic c:x:mpoun:is was detected that
CD1ld potentially threaten human health thrcu:Ih direct CCI1tact with sedi1nents
am soils or in;Jesticm of the gramdwater. u. S. EPA develc:ped nine
altematives for ~.L.:etin; and oantrollin; the oontaminatia\ and evaluated
these altematives against specific criteria to determine the best solution to
the prd)lem. '!be reo .,.,~.J'ded alternative was presented to the qenera1 p.1blic
in a fact sheet in FebruaIy 1988, and further ~la:i.ned at a p.Jblic meetin;J in
Deerfield al Feb%uary 29, 1988. Public ccmnents em the pI'q)OSed :teh6ly as


1IIell as the Feasibility St1.dy and all the alternatives presented were accepted

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3
by U.S. EPA at the meetirg am in writirg ~ March 21, 1988 am at a
PJblic meetirg. U.S. EPA then carefully evaluated those o.",.,~J'lts to detenni.ne
if there were ;IIIIIZI- or a:I1CemS that wculd cause a c::harqe in the prq'X)Sed
~;"1 plan of actia1. In June 1988, U.S. EPA Reqiat V Administrator,
Valdas Adam1cus, signed a Record of Decisia1 specifyirg U.S. EPA's preferred
altemative as the l~Y to be inplementecl for the CXI1taminatiCl'1 problems at
the SUllmi.t NatiCl1al site.
~ OF 1988 lcrA.ucu OF IB:ISICN
'!he objectiVe of the 1988 R:>D was to reduce am cxmtrol the threats am risks
to pJblic health and the envira1ment posed by the CXI1taminated soils,

-niments, debris and groundwater at the site. '!he altematives prq'X)Sed to
~lish this goal were carefully evaluated am considered. '!he l~Y
selected in::luded a plan to excavate am treat the highly CXI1taminated soils
and isolate the site area in order to prevent the CXI1tamination fran migratin:;J
off-site.
'1he ~ia1 actia1 selected in the 1988 R:>D consisted of the follCMirq major
O_lt~&rt:s:
1. Q:nsb:uctin;J a d1ain-link fence arcun:l the site perimeter. Seekin:J deed

%eSt:rictia1S frail prqmty owners to cxmtrol future use of the site.
2. Excavatirg and in::ineratirq (in an on-site facility) the follaorirg wastes:
cart:aminated "Hat Spot" soils
cart:aminated Off-site ~ i1l'E'nts
32,000 c.y.
1,500 c.y.
ccntents of au:ied Droms
900-1600 dnnns

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3. DisDantling' ard,Ior demolishing' all cm-site structures for m-site ni~.
4. Installing' a soil-bent.clU.te slurry wall ara.tn:l the site perimeter to

~tely a 40 foot depth to act as a vertical barrier Wich waUd
prevent lateral migratial of CXI1taminant:s off-site.
5. Q)llecting' an:! treating' surface water £ran two m-site pcnds and drainage
clitd1es. s-"i1'ftPl1ts wa1ld be excavated after pcn::1s and ditches were
dewatered.
6. Extracting' grc:undwater for treatInent fran the various levels beneath the
site by t:wD basic ~:
a. A system of 220 extraction wells installed on a 50-foot grid system
CNer the site to remove ocntam.inated water £ran the water table unit
(the most highly ocntam.inated level of the gm.n1water table closest to
surface) .
b. A system of 12 wells to extract the water fran the intermediate unit
(the less ocntam.inated portion of the gm.n1water table beneath the
water table unit) .
All water aA~-"'ted wa1ld be treated cm-site, with treated waters to be
disd1arged scutheast of the site.
7. Relcxating' me vacant residen::e.
8. creating' an cn-site lan:1fill, I:W.1t with an un:ierlying' dcuble synthetic
liner, to ,u ~ of the residue £ran incinerated waste material.
9. Regrading' site am installing' a m.1lti-layer cap CNer entire site. Cap
1«W.d c:xndst of a ~foot cx:II'pac:te1 clay layer ccvered by a high density
polyethylene liner, synthetic drainage net, me foot of clean earth fill,
am cme foot of tcp soil.

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5
10. ReraItin;J sa1them and eastern drainage dit.c:hes to an urx:art:aminated area
beya1d the site.
u. '!be total ~ l!elit worth cost of the ~ial actiat defined in the R:)D was
$25 milliat.
StIImRr OP 1990 HUu:iw IBtEmAL ACl'I~
'!be objectives of the 1990 proposed ~ial actiat are the same as in the
1988 lU): to reduce and control the threats and risks posed by site
a:r1taminatiat. 'Ihe primaxy goal, as in the 1988 roD, is to ~lement a
solutiat to a exmplex contamination pr'OOlem that is protective of human health
arxi the envU(Ma&eit and provides a lorg-tenn, as well as short-tent, solution
in keepin; with Chio EPA and U.S. EPA regulations. '!he major difference


between the 1990 ~qJOSal and the 1988 roD is that of lm;-tent cleanirq of
a:r1taminated media versus isolation. With both the 1990 plUy::6ed le!t~ and
the 1988 R:>D, the most highly contaminated soils and !l:Mi~J'1ts will be
excavated and treated. '!he grourx1water extraction callEd for by the 1990
}&UPJSed l.~y, however, will be acxx:lTplished by a different t.echnolcgy that
--
will result in a laq-tent cleanirq, thus eliminatin:.:J the need for isolation
by means of a sluny wall and m.1l ti -layer cap.
Far ease in cx:m:parisa1, the followiIg list of elements is ra.mi:Iered in parallel
to the listirr; urder the 1988 roD.
(Table 1, page 13, gives an abbreviated
side-by-side ~isa1 of key elements.)
1. Expand:in; site bcmdaries to include contaminated areas alorg the
perimeters and the south drainage ditch and oonstructin:.:J an 8-foot d1ain
link fence arcud this expanded bo1Jnjary.

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2. Excavatirg am incineratin; (in an cn-site facility) soils am sediJnents as
follow:
Q:I1taminated soils m-site:
C:ntaminated perimeter -n;~1'1ts:
24,000 c.y.
4,000 c.y.
(inc1ud.in1 drainage ditches)
CD1tents of b.u:'ied drums
900-1600 dJ:ums
3. ni!lZlMl1'1tlin; am,tor demoli..shi.n; all cn-site sb:uctures for m-site d;~.
4. No slurry wall wa.1ld be const.ructe:l under this ~ial action.
5. Q)1lectin;J am aeatirgsurface water fran two on-site pon:ls am drainage
ditches.. ~;~ wa.1ld be excavated after pon:ls am ditd1es are
dewatered.
6. EXtractin; groundwater for treatJnent fran the varia1S levels of the water
table m-site by two basic ~Ip.u lents:
8. A pipe am media drain system alon:;J the scuthem bcurdary and lower
portia'S of the eastern ard western boundaries rather than a system of
wlls to extract and treat contaminated grcundwater.
b. AdditiCl1al extracticm wells installed in the intenoedi.ate unit to
8ugmm1t the pipe am media drain system.
All water extract:.ed will be treated by a system to be enclosed in an 00-
site h1;1di1'1q.
7. Relocatirg a1e vacant residence.
8. No m-site lan:lfill wa.1ld be created unless the wastes fail a;prcpriate

testin:;J. Instead, ash fran incinerated waste material wculd be tested to
ensure it a:nfOI'DS with u.s. EPA am CtUo EPA stamards am used as fill to
regrade the site before the final Ct:Ner is placed over the surface.

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9. Regrad:i.n;J site am installin:1 a soil CCNer CNer 8l=Proximately 10.6 acres of
site. '1his caver will consist of an 18-inc:b layer of loam an::! 6 in:nes of
tqsoil with gas vents installed for treatin:1 an::! m:nitorin:1 patential air
sdssicms.
10. Reroutin; sart:h am east drainage ditd1es to un:xntaminated area beyon:l
the site.
u. '!be total CXISt of the ~ial actial is $34.4 millial.
u.s. EPA, CIlio EPA, am a large groJp of ~ially Responsible Parties
(PRPs) have signed a CCn;ent Deaee:, ~ the PRPs have agreed to design
am i:aplement this amerdment. R:>D. tJrder terms of the consent Dec:tee, the


respcI1Sible parties named in the agreement will retain the contractors who
will design am iDplement the remedial action. Before CX1I'1Stroctial begins,


U.S. EPA ard CIlio EPA DL1St review an::! 8l=Prove all design ~ an::!
spec-ificatia1S, am health ard safety, quality assurance, an::! c:paration am
maint.enarD! plans. u.s. EPA am alio EPA will oversee an::! m::nitor all
activities of the ran-iial action an::l m;JOin:1 operation an::! maintenance to
ensure CXI!pliance with all 8R'licable requirements.
~ OF SIQUF.IC'ANl' ~
'!be major diffe:r:euoes between the 1988 R:>D an::l 1990 pI'q)OSed ~Hal action
are as follows:
it '!be site periEter has been extemed to include sane areas of
CXI1taminaticn previc:usly cansidered "off-site." 'n1e site fencin:1 will be
expanjed to incl\XJe these areas. Contaminated soils will be rerrcved frcr.1
these areas for a\-site incineration.

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.
8
'!he methcd arx:l underlyin; ratia1ale for extract.irg an::! treatin; the
~ has c:ban;Jed significantly under the 1990 prr'I)06ed l~.

'!he 1988 Ja) called for a series of 220 extractiat wells to be installed
en a grid system at the site to extract oc:ntaminated gramdwater. Unjer
this methcd, it was also ~9a.ty to build a slurry wall to isolate the
site an::! prthibit clean gramdwater frail migratin; under the site ani
CD'1t.aminated gramdwater frail migratin; off-site. '!he slurry wall
afforded the protection ~ed to reduce or elbninate off-site risks by
iso1at1n;J the cx:ntaminants in plaO!.
'!he new ~,~ calls for a system that utilizes pipes an::! drains to
collect grcundwater aver an exterrled peric:d of time in plaO! of the
extractiCl'1 wells. under this system, the water that CXI'1tinues to slowly
infiltrate site soils ani ~irnents, c1issolviIg cx:ntaminants fran soil
particles durin; this pI~, will continually drain an::! be collected
fer trea'bDent. Because the pipe ani drain system collects frail the

sa.Jthem am lower east ani west perimeters, Which is the natural cxm-se
of the gramdwater flow, contaminated water will be collected ani treated
am will not migrate off-site, thus eliminatin; the need for the slurry
wall as a part of the leu-.ly.
. tl'1der the 1990 pl'~' contaminated soils will be excavated to depths of
two feet below the surfaO!, Wereas in the 1988 R:>D, SCIDe areas were to be
excavated to depths of 0-8 feet below the surfaO!. 'Jhis ctiffererre was


1&' t-,-"6ed basically due to the d1arge in the gramdwater extractia1 method.
'!he 1:q) two feet of surfaO! soils are generally the most highly
CD'1t.aminated arx:l pose the greatest threat to public health by contact ard
in;JestiCl'1. 'lhese will be excavated ani treated. 'n1e lower levels of

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CXI1taminaticm remainin; in soils below 2 feet will be flushed by rain an:i
snowfall infiltratin:j the site caver. '1hese CXI1taminants will then be
extracted with the gra.n:1water and treated. In the areas where b.1ried
drums will be ~ted, soils will be excavated to greater depths as
~"'ary.
* '!be CI1-Site landfill may not be neoessary un:Ier the 1990 ~. ~ reu.:s.1y.
'!be resultin:j ash. £ran incineratirq the CXI1taminated soils and -'i;1N=>1'1t.s
will be tested to ensure that it meets established standards and then used


as backfill to regrade the site before placirq the final site a::Ner. '!be
selected 1:e&6ly assumes that the characterization of the ash will allow
the State of QUo to waive their solid waste requlatia1 regardirg the
final depositia1 of the ash. '!be State of QUo has agreed to consider


sudl a waiver when the analysis of the ash is available. If the ash does
net meet the requirements, it will be retreated by the incineration
~~ until it achieves acceptable levels for organic cxrrt:aminants. If
the ash does not meet the U.S. EPA lardban requiIeDents because of


inorganic c:x:ntaminants it will need to be placed in a RCRA an-site
facility.
* '!be 1988 RX> called for an i1tpemeable cap aver the site to prevent
infiltraticm ard isolate the oantamination an-site. '!he 1990 prq>osal
iJlplements a site caver that will allow infiltration. 'Ibis controlled
infiltraticm will SUR'lement the J:E!'IX7Val. of CXI1taminants by the m;oin;
gra.n:1water Q)llectiCl1 and trea'bDent cycle.

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10
CXIBRATIVE »P.LYSIs OF ~
* ~ 1988 Ia) SCl.-ned alternatives based.al their ability to protect human
health and the envixa1ment; adlieve State and Federal MARs (awlicable or
relevant and appt~iate requirements); reductial in toxicity, JOObility,

ani volume; cost effectiveness; State and ~111i.ty acoept:ance. '!he 1990
~.~,6ed laall:lCly was also SCh-=:,m usin:J the same criteria.
CJVmAU., BuJ.n:J.'.1C1f OF IIM\N BEAtI1H AND 'DIE DMJaHNr
* ~ 1990 pl:(".)Sfd l:eu.eUY and the 1988 l:eualy wo.tld provide Protection for
IuDan health and the envixa1ment. Both remedies eliminate the exposure
rart:es to artj residual contamination whidl wo.tld result in eliminatirq any
residual risks associated with the site.
CXJIPL'I»a: 1il'DI AH'LtCAmE CR REU.VANr AND APRamAm ~
* ~ 1990 ~.~ l~ and the 1988 l'l:&lcity wo.tld cxmply with all
"R>licable or relevant and appI'qlriate Federal, and State laws. '!he ARAA.s
are listed in the 1988 ROD. 'lhe only aatitional ARAR is the larx:lban


~ of RCW\, which will awly and will be met.
IOI;JJUIf ~ AND HHIAlma
* ~ 1990 Ik'~.osed l~y wo.tld adlieve a higher deg1.e.:: of pemanenoe an:i
l~ effectiveness than the 1988 l:eucity.
Incineratial of soils wo..tld
~ virtually all organic contamination. '!he residual soil will be

tested for ino~c contamination and will be placed in a RCRA landfill
CI1-Site, if ~e!llY. '!he soils which remain wculd be flushed by


rairwater and all of the graJn:!water wculd be collected by the interceptor

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11
t.n:a.cbes and extractia1 wells. '!he water extracted wa.1ld be treat:a:i by an

a1-Site treatJDent plant to required CXI1taminant levels before being
J:eleasecl to surface waters. '1his system will be in place as l~ as


required to effect a cleamp of the gra.n:lwater to aooept:able levels. '!he.
1988 lesa-]y required isolaticm, rather than treatJDent, of CXI1taminated
soils that were not :i1x:inerated, making the l~ less permanent am less
effective in the lcn; teI'm.
- JCWI.-nCB C1P '1tJXICl'lY, II:>BIL1'lY CR VCIDm
* '!he 1990 pl' ~ ~a&8::dy wa.1l.d satisfy the statutory preference for
treatment as a pr:i1x:ipal element. Beth the :i1x:ineratioo of the soils arrl
the gra.n:lwater collection am treatment systems wa.1l.d provide a large
reducticm in the toxicity am ncbility of the CXI1taminated soil am
gra.n:lwater. '!he 1988 l~.edy wa.1ld not achieve as great a reduction in
the toxicity, 1IICi:>ility, or volume of CXI1taminatioo because it called. for
isolaticm, rather than treatment, of CXI1taminated soils that were not
:incinerated.
SBRl'-'JBII ~
* Both the ~. ~ l:e-.;1y and the 1988 l.~y coul.d result in short-tern
effects durin;J excavatia1, materials handling, :i1x:ineratioo am
gra.n:lwater treatment. With 00 am off site Dalitorirg of air emissions
and an effective safety plan for site work, no adverse iDpacts to workers,
the tYmm11"1ity or the environment will oco.lr.

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u
~
*. 1his pt. ~ l:emedy utilizes proven tedmoloqies for extraction and
treatment of soil and graIr'dwater. EquipDent and ~ to iJlplement
these ~-gs are readily available. It is in this area that the


~. ~ 1:ew.Jy is substantially better than the 1988 l:auedy. ~e the
tec:hnoloqi.es ci1csen in the 1988 ROD are proven tedmoloqies, they are rot

. '" ...j. ..uy eqUoyed in the cxmi:dnation required by the ROD. Specifically
the installatiCl'l of an iIrpermeable cap WtUld rot usually be
cxmbined with the installation of numero.lS extraction wells ~ this
cap. '!be~. ~ .La&eJy WtUld avoid the potential prci)lerns caused by
this cx:JIi:)ination of tedmoloqies which ccW.d limit the effectiveness of
the l~.
(D)'l'
* '!he cost of the 1990 p.L'~ u:medy is $34.4 million.
'!he cost of the
1988 lemedy is $25 million. 'lhese costs were estimated by different
cx:ntract:ors usirY;;J different criteria for exmtirY:Jencies.. Actual cost are
expected to be atolt equivalent.
mmE JaZP'mJa
* '!he state of ClUo has :in:ticated that they cxn::ur with the 1990 p~
.L~ am O:nsent ~~ and they are a signatoty to the Consent Decree.
A cxpy of the state's CXI'1Cl1rI'enOe letter is attad1ed.
CXJKHI.'lY JaZP'mJa
* u.s. EPA aooepted public cx:mnents on the p~ R:>D amen:!ment durin; the

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13
lem for the cx:mm.mity.
SJMUIt:Rr ~(H)
* 'lhis nllur:dy will be protective of human health and the environment. It
will greatly reduce the vol\mle, toxicity, and JDC:bility of hazarcb.1s
substances thraJgh incineration and trea'bnent of grcundwater. '!he 5i te
will be ~ to prevent aIry direct contact with the materials left on
site.
'lhis :t:e-:aly will attain all Federal, State and lccal ARARs. '!he ARARs

were listed in the 1988 R>D. '!he only aa:titiooal ARAR is the larXlban
requirements of RCRA~ which will be met.
'!he ~aaa1y is cmt-effective am will be i!plemented by the PRPs urrler a
a.. ----it I:b... t:II:.
'!be ~aaaly also uses pm:manent solutiaw am alternative treatment
tecbnologies to the JDa)l';1Inn extent practicable. '!he Pl.' ~ :t:ewerJy
utilizes permanent solutions to greater degree than the 1988 R>D thra.1gh

the use of a grcundwater a>llection and treatment system instead of
isolatin;J these CXI'1taminants.

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14
TABIE am
SOKtT NATIaaL, CllIO
Orlaiml 111) (~)
Access/I)eed Rest:rictia1s
Razing QH;ite stxuct:ures am Dispa;al
ReaDval am Incineratim of Drum an:i
Tank o:ntents
EUminate Q\-Site SUrface waters
Regrade the site

Water Treatment Plant to Treat
Gra1n:!water an:i Paned SUrface Water
O1aracterized and Close the TiR>le Well

1m;J Term ~a1 m1 Maintenance for
~; :'11 Actia'1S
Remediatim of Off-Site ~;~
Relcx:ate Residence
~;~m of Off-Site soils by Cover

Remediatim of cm-Site soils 32,000
c.y.
Dispa;a} of Incineratim Ash in On-si te
RCRA Iamfill
IDpmDeable CaYer
Install Extractim wells
Install Slurry Wall
Exterxl Site Bc:uXJaries
Revised RD
same
same
same
same
Same
Same
Same
Same
same
Same
Remediation by Irx::ineration
Remediation of 24,000 c.y.
Disposal as fill on-site if non-
hazarda.1s waste. If hazarc:k:us waste in
on-site ~ landfill.
Pe.nteable Cover

In.st.all oollectioo trerx:h in ~
aquifer an:i extractioo wells in l~
aquifer.
No slurry wall.
Exten:i site boun:3aries an:i renove
contaminated soil for on-site
treatInent.

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QiIEA.\
8t8te 01 0bI0 EMtronment.8I ProtectIon AQency

P.O. Box 1049. 1800 WaterMark Dr.
Columbus. Ohio 432~0149
(614) 644-3020 Fax (614) 644-2329
Richard F. Celeste
Governor
October 10, 1990
RE:
Summit National Superfund Site
ROD Amendment
Ohio ID 267-0779
Valdas V. Adamkus
Regional Administrator
United States Environmental
230 South Dearborn Street
Chicago, Illinois 60604
Protection Agency, Region V
Dear Mr. Adamkus;
The Ohio Environmental Protection Agency has reviewed the draft
Record of Decision (ROD) amendment for the Summit National Site in
Portage County, Ohio. Ohio EPA concurs with the remedy as
outlined in the Consent Decree and the amended ROD. The selecteQ
remedial alternative as described in the amended ROD includes:
Access and deed restrictions for the site
Surface and groundwater monitoring
Removal and disposal of on-site structures
Excavation and incineration of on-site soils as defined in
the' Consent Decree, SOW and appendices
Excavation and incineration of buried tanks and drums and
their contents
Excavation and incineration of contaminated off-site
sediments
Disposing of non-hazardous incineration ash on-site
Installation of a permeable cap over the entire site
Installation of a pipe and media drain system around the
southern half of the site
Installation of a groundwater extraction system for the
intermediate aquifer

Installation of a treatment system to treat extracted
groundwater and on-site surface water
.~.

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Valdas V. Adamkus
Page 2
Rerouting the perimeter drainage ditches to off site
locations
Regrading and revegetating the site surface

Relocating the Watson residence to another area not
affected by the site or removal of the residence
Operation and maintenance of the systems described above
The Ohio Environmental Protection Agency has been consulted
throughout the Remedial Investigation, Feasibility Study, and
Record of Decision process. The Agency has participated
. extensively in the development and negotiation of the three party
Consent Decree and attached Statements of Work for the site and we
have participated in the development of the ROD amendment for the
remedy proposed by the PRP group. Based on this history of
participation the Ohio EPA concurs with the amended ROD.

The present worth cost of the selected remedial alternative is
estimated at $34,400,000 including operation and maintenance
costs. These costs will be born by a Facility Trust Fund
established by the PRP group as outlined in the Trust Agreement
appended to the Consent Decree.
~in~~
'Q~
~hard Shank
Director
cc: Cynthia Lyman, AGO
Daniel Markowitz, NEDO
Kathy Davidson, DERR
Fran Kovac, Legal
Dave Ullrich, USEPA
Don Bruce, USEPA
Tony Rutter, USEPA
RS/DMI

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SUMMIT NATIONAL SUPERFUND SITE
DEERFI ELD, OH I 0
RESPONSIVENESS SUMMARY
EXPLANATION OF SIGNIFICANT DIFFERENCES

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I.
RESPONSIVENESS SUMMARY OVERVIEW
In accordance with CERClA Section 117, a public comment period was held
in February and March of 1988 to allow interested parties to comment. on
the United States Environmental. Protection Agencyls (U.S. EPAls)
Feasibility Study (FS) and Proposed Plan for a remedy at the Summit
National site. At a February 29 public meeting in Deerfield, Ohio, U.S.
EPA presented the Proposed Plan for the Summit National Superfund site,
and answered questions and accepted comments from the public. A Record
of Decision (ROD) documenting U.S. EPAls chosen site remedy was signed
in June 1988 by the Region V Administrator, Valdas V. Adamkus.
Following the signing of the ROD, U.S. EPA and Ohio EPA entered into
negotiations with the Potentially Responsible Parties to implement the
cleanup action defined in the ROD. These negotiations resulted in the
signing of a Consent Decree outlining the remedial action which will be
implemented to clean up the Summit National Superfund site. This
Consent Decree was signed by the U.S. Environmental Protection Agency,
the Ohio Environmental Protection Agency, and the parties potentially
responsible for the contamination at the site.

The negotiations resulting in the Consent Decree also resulted in some
changes to the initial ROD signed in 1988. Under Section 117 of CERCLA
of 1980, as amended by the Superfund Amendments and Reauthorization Act
(SARA) of 1986, U.S. EPA is required to publish an explanation of the
significant differences between the 1990 proposed remedial action and
the 1988 ROD. Under Department of Justice regulations, notice of the
Consent Decree was published in the Federal Register and public comments
regarding the decre~ were also received.
The public was notified of this Explanation of Significant Differences
(ESD) and the public comment period on these differences in a newspaper
advertisement published in the Ra.enna Rrcord-Cou~ier on July 16, 1990.
A fact sheet was mailed to site mailing list summarizing the significant
differences and a public meeting was held in Deerfield on August I,
1990. Public comments were received by U.S. EPA at the public meeting
and in writing from July 16 to August 17, 1990. These comments are
contained in Appendix A of this document. The purpose of this
Responsiveness Summary is to document the comments received and to
provide U.S. EPAls responses to these comments. All comments summarized
in this document were considered in U.S. EPAls final decision for the
Amended Record of Decision at the Summit National site.
II. BACKGROUND ON COMMUNITY INVOLVEMENT
Appendix B contains a summary listing of the community relations
activities sponsored by the U.S. EPA for the Summit National Superfund
site. The following is additional information regarding the community.s
interest and participation in site events.

The Summit National site is a former liquid waste disposal facility
located on an abandoned coal strip mine at the intersection of Ohio
Route 225 and U.5. Route 224 in Deerfield, Ohio. The site is 20 miles
west of Youngstown and 45 miles southeast of Cleveland. The 11.5 acre
fenced site contains two ponds, an inactive incinerator, and several

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vacant buildings. Immediately surrounding the site are several rural
residences, two landfills, light industries, and farmland.

Community concern about the site dates back to 1973, when residents
concerned about air pollution from Summit's incinerator contacted the
local Ohio EPA office. Resident concern increased throughout the next
five years, and in December, 1978, a community organization called
Concerned Citizens of Deerfield (CCD) held its first public meeting.
CCD collected donations from all interested parties and hired an
attorney to begin the legal action necessary to request that Summit be
closed.
In that same year, the Mahoning Valley Sanitary District (MVSD) joined
CCD's efforts when its chief engineer became concerned about potential
contamination of the MVSD-owned Berlin Reservoir, the main source of
drinking water for the Deerfield area. MVSD was successful in gaining
the attention of a number of state legislators, and in August, 1979,
CCD, MVSD, Ohio EPA, the Ohio Attorney General's office, and the area's
state representative brought a large group of state legislators to tour
both the site and the Berlin Reservoir. Shortly thereafter, the Ohio
State Assembly allocated the funds necessary to carry out emergency
cleanup actions.

Since the 1980 site action, the community surrounding the site has
maintained a consistently high level of interest in the site. CCD has
dismantled, and its key players have reorganized into a community group
called Residents Against Garbage Environments (RAGE). RAGE has been
extremely effective in bringing the site to the attention of the media
and in mobilizing the community to actively participate in the entire
RIfFS process.
U.S. EPA conducted the Remedial Investigation and ~easibility Study, and
in February, 1988, recommended a cleanup alternative and presented it to
the general public in a fact sheet. A public meeting was held in
Deerfield, Ohio that year and public comments on the proposed plan and
feasibility study were accepted by U.S. EPA at the meeting and in
writing. In June, 1988, EPA Region V Administrator Valdas V. Adamkus
signed a ROD specifying the remedial action to be implemented at the
site.
U.S. EPA and Ohio EPA's negotiations with the PRPs resulted in the
signing of a Consent Decree and significant changes to the 1988 Record
of Decision. (See Section I). Oral comments were accepted at the
public meeting. U.S. EPA also received several written comments in the
form of letters from the community (See Appendix A).

III. SUMMARY OF SIGNIFICANT COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES
The comments in the Responsiveness Summary are paraphrased in order to
effectively summarize them in this document. The reader is referred to
the full transcript of public meeting comments and written comments
received by U.S. EPA contained in Appendix A for further information.

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. .
. 2.
1.
Will the trench system and extraction wells impact the well water or
water table?
Since the trenching system and extraction wells have not been
designed, their effects on the groundwater table or any specific well
cannot be determined at the present time. The depth of the local
wells would also factor in determining the impacts on the wells from
the groundwater extraction system. The feasibility study indicates
that the effects of the groundwater extraction system must be further
addressed with pump tests before detailed design and implementation
of the selected groundwater remediation alternative.
Where will the east drainage ditch be located?
During the design phase of the remedial action, the plans for the
surface water drainage facilities will be finalized. It now appears
that the south ditch will be relocated further south. Presently:
there are not any plans to reroute the east ditch.
3.
How much water will flow in the east ditch? If the east ditch is
located in the Ringers' front yard, will the existing six-inch drain,
pipe in their front yard continue to overflow?
During the design phase of the remedial action, the drainage pattern
for the site and'the surrounding area will be evaluated in detail and
designed to ensure that there is adequate drainage for all of the
areas surrounding the site.
4.
How can U.5. EPA and Ohio EPA be sure the water will be treated
properly? How often will the wastewater be tested?
A complete water treatment plant will be constructed as described in
Appendix D of the Statement of Work. The discharge from the water

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treatment plant will meet State effluent discharge requirements. A
schedule for testing the water can be found in the Statement of Work.
5.
How soon will the cleanup of the site begin?
After the Record of Decision is amended, the Consent Decree will be
entered by the U.S. District Court for the Northern District of Ohio.
The design of the remedial action will begin and require
approximately one year. After the design is completed and approved
by the federal and state EPA, construction of the remedial action
wtll- begin. The estimated time required to remediate the upper
groundwater aquifer is 30 years and the estimated time required to
remediate the intermediate aquifer is 5 to 10 years.
6.
How often will the residential well water and soil in the surrounding
area be tested?
The residential well water will be monitored during implementation
of the remedial action. The State of Ohio will also monitor the
residential wells. The monitoring frequency has not been
established, but will be determined by site conditions. The soil in
the area around the site will not b~ tested again unless an unusual
event such as flooding occurs.
7.
How will citizens in and around the site be protected from exposure
to airborne vapors and toxic gases from the incinerator?
The incinerator will be equipped with air pollution control devices
to destroy toxic gases and remove particulate matter. The air
emissions from the incinerator will be monitored frequently to ensure
the incinerator is operating properly and that all air emission
requirements are met. Before contaminated materials are processed
through the incinerator, a trial burn will be conducted using the
incinerator to demonstrate that the equipment will perform within
acceptable standards and thus protect the surrounding community from
exposure.

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8.
Could the groundwater collected from the extraction facilities be

treated 80re safely and effectively?
The water treatment facilities will be. designed to safely and
effectively treat the contaminated water. The effluent discharged
from the treatment facilities will be monitored frequently to ensure
compliance with federal and state requirements.
9.
Since the prevailing westerly winds are directly in line with
residential housing and a State-operated reservoir, would a failure
of the incinerator produce harmful effects?
The incinerator will be closely monitored and would be shut down if
any problems developed. Air monitoring will also be performed in the
area around the site.
10. Are there any evacuation plans for the area residents?
u.s. EPA and Ohio EPA do not routinely require that evacuation plan~
be developed for remedial actions involving onsite mobile
incinerators. Evacuation plans may be required at the discretion of
U.S. EPA and Ohio EPA, depending upon the potential risks to nearby
residents from the remedial action. At the present time, a
determination has not been made as to whether an evacuation plan will
be required. Evacuation and other emergency plans would be closely
coordinated with local regional response authorities.
11. How many hazardous waste incinerators are operating in the United
States and in other countries?
There are approximately 150 hazardous waste incinerators operating
in the United States. The U. S. EPA does not have informat ion
concerning the number of incinerators operating in other countries.

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12. Why incinerate the wastes at all?
Section 121 of the Comprehensive Environmental Response,
Compensation, and liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986, indicates that
remedial actions in which treatment that permanently and
significantly reduces the volume, toxicity, or mobility of the
hazardous waste are to be preferred over remedial actions that do not
. involve treatment. This section of CERCLA also indicates that
offsite transport and disposal of hazardous wastes without treatment
should be the least favored remedial action. Consequently,
alternatives that incorporate treatment technologies such as
incineration are preferred over alternatives that do not incorporate
treatment.
Several treatment technologies were identified as potentially
applicable based on the site conditions, waste characteristics,
ability to meet the objectives of the National Contingency Plan,
implementability of the technology~ and demonstrated performance of
the technology. The treatment technologies identified as potentially
applicable were screened based on their effectiveness,
implementability and cost and then subjected to a detailed
evaluation. Incineration was selected as the preferred treatment
technology since it is a proven technology and would provide
protection to public health and the environment, significantly reduce
the volume, toxicity, and mobility of the contaminants, and be cost-
effective.
13. Why not transport the waste to an offsite incineration facility?
Since substantial transportat ion costs wou ld be incurred if the
wastes were incinerated at an offsite facility, onsite incineration
would be more cost-effective. Generally, if more than 5,000 to
10,000 cubic yards of wastes must be incinerated, it is more cost-
effective to bring a mobile incinerator onsite to treat the waste.

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Since approximately 27,000 cubic yards of waste will be incinerated,
it is more cost-effective to incinerate the wastes onsite.
. In addition, potential adverse impacts associated with offsite
transport and disposal of the wastes can be avoided by onsite
incineration. These adverse impacts include increased traffic and
noise near the site and an increased risk of traffic accidents and
spills of hazardous substances.
14. Is there an organized effort to build an incinerator at this site to
replace the incinerator that was constructed in Nova, Ohio?
This incinerator would not be constructed to replace
incinerator. It will be a mobile incinerator which will
to the site to burn products from this site only.
any other
be brought
15. After completion of the site cleanup, will the incinerator remain
active and incinerate hazardous wastes from other sites, including
aut-of-state wastes?
After completion of the onsite remedial action, the incinerator will

be removed from the site.
16. Would you live next to an incinerator?
If the incinerator was cleaning up a specific hazardous waste site,
was constructed using state-of-the-art technology, and was closely
monitored, living near an incinerator would be acceptable.
17. What will happen to the abandoned house adjacent to the site?
The house wi 11 either be removed or demo li shed. The potent i ally
responsible parties will make the necessary arrangements with the
owners of the house.

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18. Nfll U.5. EPA publish and distribute a monthly or bi-monthly
newsletter to the area residents?
U.5. EPA plans to publish quarterly updates to keep area residents
informed on the status of the site.
19. Are U.5. EPA testing methods for colloids and filtered sa,!,ples
acceptable?
U.5. EPA uses the most current analytical methods. These analytical
llethods are continually being revised to ensure that the sample
analyses are accurate. All analytical sampling and analyses are
performed in accordance wi th a comprehens i ve Qua 1 i ty
Assurance/Quality Control plan for the site.
20. Are there any plans to monitor the health of the residents living
near the site?
Because there is no known exposure of residents to the contaminants
from the site, the health of the residents near the site is not being
monitored. If residents near the site were exposed to contaminants
at a level of concern, a monitoring plan would be implemented.
21. What will be done with the Jones Landfill that is adjacent to the
Summit National site?
The Jones landfill is in the process of being evaluated by U.S. EPA
to determine whether the site meets the criteria necessary to be a
Superfund site. If the landfill meets this criteria, it would be
placed on the National Priorities List (NPL) as a Superfund site.
22. ..ill the previous mining activities at the 5umit National site
interfere with the site cleanup?
The effects of the previous mining activities were evaluated during
the RIfFS. The design of the remedial action for the site will allow

-------
'~
for necessary adjustments required as a result of the previous mining
activities.
23. A cOIIIIIent was received which said, "I donlt like your conceptual
..thod of setting up your program. I like my programs cut and dried;
.. will do this and we will do that. II
Since the Potentially Responsible Parties (PRPs) are performing the
design and construction of the remedial action, they will determine
the exact type of incinerator that will be used. For most of the
other activities, the work plan specifies how the construction will
be completed. The work plan and all of the work performed by the
PRPs will be reviewed by the U.S. EPA, Ohio EPA, and the U.S. EPAls
oversight contractor.
24. What will happen if the material from the 8FI landfill flows into the
trench that will be constructed at the Summit National site?
Because of the distance to the BFI landfill and the ty~~ of
construct ion used for the SF! 1 andf ill, mater i a 1 from the BF I
landfill would not migrate to the Summit National site. The BF!
landfill was constructed with a liner that would preclude leakage in
any significant amounts.
Q/A.SN3
7010Q.211

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APPENDIX A
Comments Received During the August 1, 1990
Public Hearing and Comment Letters Received
Subsequent to the Public Hearing

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August 9,1990
Richard V. Miller
1701 Alliance Rd.
Deerfield, Oh 44411
~EOEIVEmJ
AUG 1 0 ~
216-947-3736
OFFJeE OP
PUBUC AFFAIRS
U.S.EPA
Cheryl Allen
SPA-14
.230 S Deerborn St.
Chicago, Ill. 60604
RE: Summit National Dump, Clean up
Ms. Allen,
I have a few questions concerning the proposed clean up of
the Summit National Dump in Deefield, Ohio. Hopefully you could
find time to answer them.
1. How many incinerators are there operating,like the
one your proposing to build,at the Summit Natio~cl
Dump, in the U.S.A.? Other countries?
2. Why not transport this material to one of these
Incinerator sites?
other
3. I am aware that you are having problems with the :n-
stallation of an Incinerator in Nova, Ohio, Is t~lS
an organized effort to build an Incinerator in th:s
area to replace what has not been built in Nova, C~iQ?
4. After completion of tho clo~n up,will this inci~c~~:Qi
remain active incinerating other Toxic waste f~or
other areas including Out of state Waste?
5. Would you live next to an Incinerator??
Thank You for your time and effort. Any answers on these
questions would help me understand what is really trying to bE
done.
S1nz:fi4( ~

R1chardV. Miller .

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/1
-,
m? IE a; EBYIE ~
AUG 1 5 1990
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MS. ALLEN:
Okay.
We're going to take public
2
comments now.
As I stated before, they are statements not
3
questions.
You could put it as a question, but we will not
be answering them directly.
We will be responding to them
in the response and summary.
So, whoever wants to start.
We'll start on this side of the room and go to the middle
and then go to this side.
Anyone on this side?
Okay.
Please state your name for the court reporter.
MISS SAINTCLAIR:
Carol Saintclair.
I would like
to know what you're going to do with the abandoned house.
It's an eyesore to the community, the Watson property or
what
used to be the Watson property.
MR. MARKOWITZ:
We're not really supposed to
answer these questions, but the quick and dirty answer
is, it's going to be, it will either be moved or
demolished, depending on what the settlement has been
between the Watsons and the company.
MR. MALCHOK:
My name is Richard Malchok.
I wo ul d
just like to make a comment.
I think the questions here
tonight could be answered very easily if you could determine
a certain radius within the site, say about five or eight or
I
ten miles, and take a listing of all the people who live in !
I
I
I
that area and send out either a monthly newsletter or a
bimonthly newsletter telling them the status of what is
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happening so that they don't feel like they are uninformed
of what is going on.
MS. ALLEN:
Anyone else?
MR. COWDEN:
My name is Cowden.
Just to commen t
methods.
I
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!
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New YorK:
I
,
i
I
about groundwater quality and the current EPA testing
There are two areas of study that cast doubt on
current EPA methods as far as accuracy for testing
g roundwate r.
One is the work that has been done in
state that says particularly in areas where there are
chloric contents that you can't get accurate organic
readings unless you fully characterize the major lines
before you do that work.
There's also some very interesting studies just
reported this year, suggesting that filtration of samples
of groundwater is the wrong way to go.
The wo rst was done
in Los Alamos.
It has been reported recently in Science
News and other journals where they say, if you have any
organic fractions, they're liable to form colloids.
Those
are 50 small, that the usual theory of trapping sediment in
i
I
that, chemical-bearing sediment, just does not apply because'
the fractures are just so small that they carry both
organics and even metal lines through the ground wall.
They have found that Los Alamos is radioactive,
They found it with conventional testing, but they could not;
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find it off site.
This particular study, using different
methods without filtration on groundwater samples found
radioactives and fumes from over a mile away.
Now I I t h ink
that the Agency ought to investigate this very carefully in !
doing monitoring of this site.
MS. ALLEN:
Thank you, sir.
Anyone else?
MR. MARKER:
Okay.
My name is Bill Marker, and
I'm a resident up there.
I will say right now, I am dead
set against this incineration.
What's there, you got to
keep there.
I don't believe the incinerator is going to be :
99.9 percent effective, especially if you get some of the
things that are not working, like the heat, okay, and the
disturbance of that is as big a problem as any.
Also, in all of this planning, I didn't see
anything about local monitoring of health, either now or
in the future.
And some people do have complaints about the
water, that being one, now where you got to worry about t~e
air.
So asa far as residents, .the residents and the local s
are concerned, I think you ought to be concerned as much as
we are about health conditions right around here.
And I
haven't heard anything in this plan or in your plan abou:
that.
You haven't come to my door and said, "Hey, I'm
going to watch your health."
And that does bug me
a litt~e
bit.-
So I think you ought to take a step there.
Tha t ' s
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something that hasn't even been mentioned.
MS: ALLEN:
Thank you.
Anyone else?
MISS CARVER:
I have another question.
Doris
Carver.
Summmit National butts right up against
!
!
Jones' Landfill, and Jones' Landfill is every bit as bad as !
Summit National is.
Where are you going to draw the line?
It's like cleaning half of a barn and taking half of the
manure out of the barn.
I know it's not your job or
anything, but you guys really do know that Jones' Landfill
is bad.
It has the same chemicals, it's actually been
there longer, and it has leachate.
So, I'm just wondering,
I know that that's not Superfund site, but it really should
have been.
Call it a statement, a question, whatever you
want, you know, whatever you want, but it's a very -- it's
something that needs to be addressed.
You can't ignore it.
We only clean one site up here, and we have got the Jones
Landfill right next to it, and they accepted the same type
of things that went into Summit National.
And another thing, monorex is in Summit National.
And I read in the paper about a site in Salem, Ohio, where
there was mirex in it, it migrated at least 40-some miles
least down a creek, went into a farmer's fields.
The cat::e
cattle ate the pasture, and there was mirex in the milk, t~e
cow's milk.
This is something to think about.
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I know about the C56 and the mirex and stuff that
was at Summit National.
I just wonder if that can't be
removed.
Can it be incinerated?
Will it filter through the
ground if it's already saturated in there, those dn111s,
those buried drums that have been leaking since God knows
when they've been there, since about 19751
Anyone got an
answer?
MR. CARVER:
My name is Jess Carver.
I'm Mr.
Doris.
The problem I have with this whole thing is, we'vee i
got a mine behind our farm. We're a quarter mile east  of
this. '!hat mine goes we st. I know everybody, they say that
mine is not recorded, but there's a couple guys here, I know
back here in the corner, Bill knows about it.
He's been
around here longer than I have.
But there's also a mine
that comes north out of that cut that BFI runs into, down a~
the bottom of the strip level.
If they cut this ditch with this perforated pipe, I
whether you use big plastic or. whatever, I don't know what
you're going to use, you're going to be down at the same
level as a lot of these mines.
I mean this is a fact.
I
know these mines are there because a hole fell into the east
side of our barn, it went down about 25 feet right where we
have a driveway.
So I know the mines are there.
Now, the problem I have with this, we know that
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that land was stripped from right there, especially where
that pit was at.
That deep pit was full of all that stuff.
What was that 50 by 30, or something like that?
Now, the
bottom that is down quite a ways.
Are you going to
excavate all that?
Is that going to be excavated, because
that's got to be set free? That lays in there for ye a r s .
Be was hoping that it would leak out and he wouldn't have
to get rid of all that much. We know that to be a fact.
Tow feet is not going to eliminate that.
That '5 something
that is going to have to be done with all that ground
underneath that.
But the problem, what we're concerned
about, the facts that that land was all stripped from that
area clear south to the borderline of Jones Landfill.
I
know because when I was a kid I hauled junk back in there, I:
!
saw chemical tankers dumping stuff.
I had no idea.
I know I
I
it was really pungent odors, terrible stuff.
To me, in all,
I
I
reality, this 11-acre Summit National site, as far as I'm
concerned, is almost a nothini.
I feel that we have, that whole area has been
I
,
I
I
used:
illegally by people for years.
And I see that whole area
probably is just about as bad as what you people are
going to spend the $34 million to try to clean up.
And tha~
is, Jones Landfill has been turned upside down, the whole
thing, the whole perimeter.
I have been down them cuts.
I
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'.know., A,pd"those cuts:~~re deep._.,.,.
. . ~ :
.:. " ~;;:"; "'"
~ ,.
...
:If you're .~oing to dig down 70 feet, you will ,be
deeper than the cut. ; But I 1m just saying thi s is nothing
but just a minute part of that area that you're going to
touch.
And I'll tell you, in all reality, the way I feel
about it, it's almost a wasted $34 million bucks.
I say we
that welve got far worse than that to the so~th of ~s.
Now, that's being closed, covered up, capped.
They're walking away from it, event~ally just walking from
Jones Landill. This is the way I feel, and anybody's been
around here any period of time knows what I just said,
they're all facts.
I can prove everyone of them.
MS. ALLEN:
'!hank you.
Anyone else?
MISS KLINE:
Beverly Kline.
! don't like yo~~
conceptual method of setting up your prog ram when you 52.::'
that we may do this and we might have to do that, and we
I
have this great big s~rprise coming some place down t~e ~:c~.
I
I like my programs cut and dried; we will do t~is and we a~e:
90ing to do that.
MS. ALLEN:
All right.
Anyone else?
MR. HURST:
I got -- I have several questio~s
really.
11m Chuck H~rst, the township trustee here.
~'.....~ :
are yo~r intentions for that house just east of that
C':: ;. ;
, . .MR. MARKOWITZ:
We're doing p~blic comments ~:-,
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We did questions and answeres before.
I

These are comments tol
be taken for the record that are statements and comments
being made.
If you want to --
MR. HURST:
That's a comment.
MR. MARKOWITZ:
We did answer this question_before~
i
If you have specific detailed questions, we can sit and chat.
about them after the comment session.
MR. BURST:
The only thing is, I don't thnk you
know what you're doing, any of you.
I don't think you're
really qualified to do any of this type of work.
Tha t' s my ;
opinion.
MS. ALLEN:
If you would like to stay after the
comment portion to ask those questions and have those
questions addressed, we would be very happy to talk with yo~
about it.
Does anyone else have any comments?
MR. STONE:
Yeah, Bob Stone.
I just wanted to
know, a little bit further to ask this question here.
What
happens when you make this cut,- if the landfill next door,
BFI, all the barrels have been down there for 44 years,
t !"'Ia:.
have been decayed, if the flow suddenly comes into your
cut that you're trenching and it's really hazardous
materials, how are you going to stop it?
What are you goi~.::
to do with it?
And suddenly it might become very dangero~s
and you might have to evacuate most of the communities
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because there is a possiblity if you're down below where
they were dumped about 40, 50 feet, and you go down 70 feet,
and the flow is usually from the west to east.
Just a
comment.
MR. WEB~R:
I would like to comment.
Gordon
Webber again.
The sad thing of this whole thing, we '.re
spending $34 million on a Band-Aid.
It would have been
better if we would have given George Ott about $5 million
and told him to go down to the Bahamas and buy a condo.
He
would have made more money, and we wouldn't have lost
anything.
Even the sadder part of it is, rather than spend
all of this time in remediation, I think we ought to be a
little more energetic in prevention.
And while we're
sitting here arguing about how we're going to clean up this,
mess, we're still creating more messes.
And there's one
right across the road that's being created, you know,
4,000 ton a day, and nobody is. doing anything about it.
I realize this is not your problem, but it's
somebody's problem, and that after you get through with this
one, you can just go down the road and start cleaning up
another one that's being created today.
Until we get
ambitious about saying we're not going to let this stuff So
on anymore, we're going to be in this process, thousands
a~:
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thousands and millions and millions of dollars from now on.
And I think it's ridiculous.
It was ridiculous to start
with and it's getting to be ridiculous because we know what
the problem is now and we're not doing nothing about it.
MR. LYDEN:
I'm Carl Lyden again.
I appreciate
you folks being here tonight. I hope that five or ten years:
from tonight we're not here for the same topic. I thlnk I I
conveyed that to everyone. The place needs cleaned up. So I
study, study, study. Let's do something and let's clean it i
I
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up.
'!hank you.
MS. ALLEN:
Anyone else?
MISS SAINTCLAIR:
Cheryl Saintclair.
In the
I
future, do you know when you plan on having another meetin9 i
like this?
MS. ALLEN:
I'll talk to you after the meeting.
Anyone else?
If not, we'll close it now.
And I encourage
you, if you didn't make verbal comments tonight and you want,
. I
,
to make written comments and send them to me, my address is
on the baCk of the fact sheet, and you have until August 17 ;
to get them to me.
I would like to thank you for corning.
I
I
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'!hank you. '
* * *
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APPENDIX B
COMMUNITY RELATIONS ACTIVITIES
AT SUMMIT NATIONAL SUPERFUND SITE
Community Relations activities conducted at the Summit National
Superfund site to date have included:
10.
1.
U.S. EPA conducted community interviews and prepared the
Community Relations Plan in September, 1984.

U.S. EPA established the Information Repository in September,
1984.
2.
3.
U.S. EPA prepared and distributed a fact sheet updating the
community on the Remedial Investigation in July, 1985.

U.S. EPA prepared and distributed a fact sheet updating the
community on the Remedial Investigation in October, 1986.
4.
5.
U.S. EPA prepared and distributed a fact sheet updating the
community on the completion of the Remedial Investigation and
Feasibility Study, February, 1988.

U.S. EPA conducted community interviews for the revised
Community Relations Plan in February, 1989.
6.
7.
U.S. EPA prepared the revised Community Relations Plan in
March, 1990.

U.S.EPA prepared and distributed a fact sheet updating the
community on the significant differences between the 1988
Record of Decision and the Consent Decree in July, 1990.
8.
9.
U.S. EPA held a public meeting regarding the significant
differences between the 1988 Record of Decision and the
Consent Decree in August 1990.

U.S. EPA sent letters to participants who attended the public
meeting held in August 1990, thanking them for their'
participation in the public comment period. . The letter
encouraged the community to continue to communicate any
concerns to the EPA on Summit National.'
.. ..'
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