United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EP AIROD/R05-93/232
September 1993
PB94-964116 -
&EPA
Superfund
Record of Decision:
Carding ton Road Landfill (aka
Sanitary Landfill),OH
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Informotloo Resource Center
US EPA RegIon 3 ",'
Philadelphia.. PA 191Q1
EP A Report Collection
Information Resource Center.
US EP A Region 3
Philadelphia, PA 19107
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. . 2. 3. R8c1plent'. Acc8aion No.
PAGE EPA/ROD/R05-93/232
4. TIt. and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 09/27/93
Cardington Road Landfill a.k.a. Sanitary Landfill, OH 6.
First Remedial Action - Final
7. Aulhor(.) 8. Perfarmlng Organization Rapt. No.
II. Pertormlng Organization Name and Add- 10 Project T88klWork Unit No.
11. Contr8ct(C) or GI8~G) No.
(Q
R
12. ~ng Organization Name and Addras 13. Type of Report . Pertod CovW8d
U.S. Environmental Protection Agency
401 M 'Street, S.W. 800/800
Washington, D.C. 20460 14.
15. SupplamerUryNol-
PB94-964116
16. Abatrac:t (Umlt: 2IDO worda)
The 36-acre Cardington Road Landfill a.k.a. Sanitary Landfill site is part of the
53-acre Cardington Road Landfill located in Moraine, Montgomery County, Ohio. Land use
in the. area is mixed commercial, light industrial, and residential. The site borders
residential properties to the northeast, with the closest residence within 200 yards of
the landfill property. The landfill is located above a kame terrace in the Great Miami
River valley buried aquifer system, which has been designated as a sole-source aquifer.
All area residents are provided with municipal drinking water, and there are nine
commercial production wells within the study area. Throughout the 19605, the site was
mined primarily for sand and gravel, although some landfill activities may have
occurred. Beginning in 1971, the site was operated as a solid waste disposal facility,
and the excavated sand and gravel pits were filled with commercial, industrial, and
municipal waste. In 1980, after waste disposal activities terminated, the site was
covered with soil ranging in thickness from two to eight feet. In 1987, EP A and the
State conducted a RI, which revealed that adverse environmental impacts were the result
. of prior onsite solid waste and hazardous waste disposal practices. This ROD addresses
a first and final action for the landfill source material and gas to prevent them from
(See Attached Page)
17. Document Analysla a. 08scrlpton
Record of Decision - Cardington Road Landfill a.k.a. Sanitary Landfill, OH
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, sw, landfill gas
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics, metals
.( arsenic, chromi urn, lead)
b. IcIantlfl8ralOpen-Enda T-
c. COSA11 FIakUGroup
18. Availability Statement 111. Security Class (This Repolt) 21. No. of Pages
None 108
20. Security CIa. (Thi. Page) 22. PrIca
None
(s.ANS~II.18)
SN/lJ8ttUCtioM on ~1fWN
OPTIONAL FOAII272 (4-77)
=..~
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EPA/ROD/R05-93/232
Cardington Road Landfill a.k.a. Sanitary Landfill, OH
First Remedial Action - Final
Abstract (Continued)
migrating offsite. The primary contaminants of concern affecting the soil, sediment,
debris, surface water, and landfill gas are VOCs, including benzene, TCE, toluene, and
xylenes; other organics; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes capping the entire landfill area with
a low permeability vegetated cap; actively collecting landfill gases and treating them
using flaring, thermal destruction, or carbon adsorption, with subsequent release into the
atmosphere or collection and sale of the gases to a local utility, if determined feasible;
installing additional gas controls and gas collection trenches along the
eastern/northeastern boundary, if necessary; conducting a Supplemental Site Investigation
to further define ground-water flow directions and to determine whether the contamination
found at the southern end of the landfill is coming from the landfill or another source;
implementing surface water runoff and engineering controls, including site grading,
diversion berms, storm water drainage channels, collection systems, and energy dissipation
controls; monitoring ground water, surface water, landfill gas emissions, and air;. and
implementing institutional controls, including deed, ground water, and land use
restrictions. The estimated present worth cost for this remedial action is $8,145,300,
which includes an estimated total O&M cost of $2,125,900 for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Collection, treatment, or flaring of landfill gas will be in compliance with
chemical-specific ARARs of the Clean Air Act and the APEN Air Pollution Emission Notice.
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ATTENTION
Portions of this report
are NOT legible. Due to
the importance of the
material, it is being made
available to the public.
It is the best
reproduction available.
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Declaration for the Recore of Decision
site Name and Location
san~~ary Landfill Company (IWD)
(a.k.a. carding~on Road Landfill)
Mora~ne, Ohio
statement ot Basis and PUrDose
This decision document presents the selected remedial action for
the Sanitary Landfill Company (IWD) site, in Moraine, Ohio, .
developed in accordance with the comprehensive Environmental
Response, compensation and Liability Act of 1980 (CERCLA) and is
consis~en~ ~ith the National Oil and Hazardous Substances
?ollut~on Contingency Plan (NCP) to the extent practicable. This
jec~sion document explains the factual and legal basis for
selecting ~he remedy for this site.
This decision is based upon the contents of the administrative
record for the Sanitary Landfill company (IWC) site.
The State of Ohio concurs on the selected remedy.
Assessment ot the site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment. .
Descri~ti~n of the Remedv
This is the first and only operable unit for the site. The
selected remedial alternative for the sanitary Landfill company
(rHD) site is to perform active landfill gas collection and
treatment, cover the landfill with a low permeability cap and
undertake other actions required by State sanitary landfill
closure requirements. The major components of the selected
remedial alternative are:
Solid Waste Landfill Cap
on-site Subsurface Gas controls
Surface Run-off controls
Long-term Monitoring
Institutional Controls
supplemental Site Investigation
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7he t~llow~ng componen~s ~~ll be r~r~her evalua~ed dur~ng ~~e
~emeaial ~es~gn (~D) and Remedial Act~on (?~) and, ~: necessary,
~~ll be lncluded as par~ or the remedy.
~atural Attenua~ion of Contaminated Ground Water
Ground Water Extraction and T=ea~ment
Declaration of statutorY Determinations
Consistent with CERCLA and, to the extent practicable, ~he NCP,
40 C.F.R. Part 300, the selected remedial action is protective of
human health and the environment. The selected remedy attains
Federal and State requirements that are applicable or relevant
and appropriate to this remedial action and is cost effective~
This remedy utilizes permanent solutions and alternative
treatment technologies, to the maximum extent practicable.
3ecause this remedy will result :n hazardous substances remaining
~n-site above health-based s~andards, a review will be conducted
~ithin five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment. . .
f27;/J. ita;iJ
A Valdas v. AdamXus
t'\ Reqional Administrator
~'" 71¥ ~
DATE
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Cost. . . . . . . . . . . . .
State Acceptance
community Acceptance. . . . .
. . . .
. . . . .
. . . .
. . . .
. . . . .
. . . .
. . . . .
IX. Selected RemedY. . . . . . . . . . . . . . . . . . .
Solid Waste Cap. . . . . . . . . . . . . . . .
Subsurface Gas Controls. . . . . . . . . . . . . . .
Surface Water Run-off Controls. . . . . . . . . . . .
Monitoring. . . . . . . . . . . . . . . . . . . . .
Institutional Controls . . . . . . . . . . . .
Supplemental Site Investigation. . . . . . . . . . .
Evaluation of SSI . . . . . . . . . . . . . . . . . .
Ground Water Treatment. . . . . . . . . . . . . . .
X. Statutorv Determinations. . . . . . . . . . . . . . .
Protection of Human Health and the Environment. . .
Compliance with Applicable or Relevant and Appropriate
Requirements. . . . . . . . . . . . . . . . . .
Cost Effectiveness. . . . . . . . . . . . . . .
Utilization of Permanent Solutions and Alternative
Treatment (or resource recovery) Technologies to
the Maximum Extent Practicable. . . . . . . . .
Preference for Treatment as a Principal Element. . .
XI. Documentation of Sianificant Chanaes
. . . .
. . . . .
Responsiveness Summary for the Record of Decision.
. . . .
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TABLE OF CONTENTS
RECORD OF DECISION
SANITARY LANDFILL COMPANY (IWD) SITE
I.
site Name. Location. and DescriDtion
. . . . .
. . . . .
II. site Historv and Enforcement Activities
. . . . .
. . .
III.
Hiahliahts of Community ParticiDation
. . . .
. . . .
IV.
ScoDe and Role of ReSDonse within site Strateay
. . . .
V. Summary of Site Characteristics . . . . . . . . . .
a. Soils (surface and subsurface) ..........
b. Ground Water. . . . . . . . . . . . . . . . . . .
c. Surface Water and Sediments. . . . . . . . . . . .
d. Air Qual i ty . . . . . . . . . . . . . . . . . . . .
e. Cap (cover) Integrity Study. . . . . . . . . . . .
f. Waste Characterization. . . . . . . . . . . . . .
VI. SummarY of Site Risks. . . . . . . . . . . . . . . . .
a. Human Health Risk . . . . . . . . . . . . . .
b. Ecological Risk. . . . . . . . . . . . . . . . .
c. Conclusions of the Risk Assessment. . . . . . . .
VII.
DescriDtion of Alternatives. . . . . . . . . . . .
1. Institutional controls. . . . . . . . . . . . . .
2. Monitoring. . . . . . . . . . . . . . . . . . . .
3~ Surface Water Run-off Controls. . . . . . . . . .
4. On-Site Subsurface Gas controls. . . . . . . . . .
5. Supplemental Site Investigation. . . . . . . . . .
Alternative 1: No Action. . . . . . . . . . . . . .
Alternative 7: single Barrier Cover (Solid Waste
. Landfill Cap) .................
Alternative 8: composite Barrier Cover (Full
RCRA Cap) ...................
Alternative 10: Natural Attenuation. . . . . . . . .
Alternative 11: Ground Water Extraction and Treatment
(On-site or Off-site) . . . . . . . . . . . . . .
VIII. SummarY of ComDarativeAnalysis of Alternatives
criteria for Evaluation of Alternatives. . . . . . .
Threshold Criteria. . . . . . . . . . . . . . .
primary Balancing Criteria. . . . . . . . . . .
Modifying criteria. . . . . . . . . . . . . . . .
Evaluation of Alternatives. . . . . . . . . . . . . .
Overall Protection of Human Health and the
Environment . . . . . . . . . . . .. .
compliance with ARARs .............
Long-Term Effectiveness and Permanence. . . . .
Reduction of contaminant Mobility, Toxicity, and
Volume (TMV) Through Treatment. . . . . .
Short-Term Effectiveness. . . . . . . . . . . .
Implementability . . . . . . . . . . . . . . . .
.
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Decision summary for the Record of Decision
I.
site Name. Location. and DescriDtion
The sanitary Landfill Company (IWD) site is located at 1855
cardington Road, Moraine, Ohio, in Montgomery County,
approximately one mile south of the City of Dayton (Figure 1).
The property parcel on which the site is located encompasses
approximately 53 acres and is bounded on the South by cardington
Road, on the east by Lance Drive, on the north by Calvary
Cemetery, and on the west by active and reclaimed sand and gravel
quarries. The actual site area used for waste disposal has been
estimated to be about 36 acres. The site is approximately 2,200
feet in length on the west boundary and 1,000 feet wide at. the
northern boundary (Figure 2).
The property surrounding the site is zoned commercial, light
industrial and residential. Residential properties border the
site to the northeast with the closest resident within 200 yards
of the landfill property.. All residents in the study area as
defined in the RI/FS Work Plan are provided with municipal
drinking water. Nine commercial/production wells were identified
within the defined study area.
The site is located at the top of a kame terrace in the Great
Miami River valley buried aquifer system, which has been
designated by the U.S. EPA as a sole-source aquifer. Glacial
materials deposited in the valley system, which are the primary
source of ground water, can range from 100 to 300 feet in
thickness. The Great Miami River, which flows in a southerly
direction, lies approximately 2,500 feet north and 4,000 feet
west of the site. No surface water streams are present near the
site. Topography of much of the.site is gently sloping to
relatively flat.
II. site Historv and Enforcement Activities
The site is' situated on property owned by two trusts controlled
by the snyder family. The property was leased.to Moraine
Materials Company, which mined the site for sand and gravel
throughout the 1960's. Records indicate that some landfilling
activities may have occurred at the site in the middle to late
1960's. In January 1971, the State of Ohio licensed operation of
the site as a solid waste disposal facility. The site was leased
for use as a landfill to the Sanitary Landfi.ll Company'
(subsequently Qwned by Danis Industries corporation), which
operated the facility during the entire licensed period. During
landfilling operations, the excavated sand and gravel pits were
filled with commercial~ industrial and municipal wastes. . In
January 1980, the Sanitary Landfill company requested lease
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termination and indicated to the State of Ohio that waste
disposal activities were complete. Later in 1980, the site was
covered with soil ranging in thickness from two to eight feet.
The sanitary Landfill Company (IWD) Superfund Site (a.k.a.
Cardington Roa~ Landfill Site) was included on the National
Priorities List (NPL) in the Federal Register on June 10, 1986.
U.S. EPA, the state of Ohio, and a group of potentially
responsible parties (PRPs) entered into a three-party
Administrative Order by Consent (AOC) effective
December 16, 1987. The PRPs which signed the AOC are Danis
Industries corporation, General Motors corporation, Firestone
Tire & Rubber company, and NCR corporation. Reynolds and
Reynolds was subsequently added as a Respondent to the AOC on
October 18, 1989. Under the terms of the AOC, the PRPs agreed to
conduct the Remedial Investigation and Feasibility Study for the
site with oversight by U.S. EPA and Ohio EPA.
III.
Hiahliahts ot community particiDatioD
The Feasibility Study and the Proposed Plan for the Sanitary
Landfill Company (IWD) site were released to the public for
comment on March 31, 1993. These two documents were made
available to the public in the administrative record and
information repositories maintained at the EPA Docket Room in
Region Five, Chicago, Illinois, and at the city of Moraine
Library in the Moraine Municipal Building, Moraine, Ohio. The
notice of availability for the documents was published in the
Davton Dai1v News, Dayton, Ohio on Monday, March 29, 1993. As
required by CERCLA Sections 113 and 117, a public comment period
on the documents was held from March 29, 1993 to April 30, 1993.
A public meeting was held on April 14, 1993 at the Southdale .
School in Kettering, Ohio. At this meeting, representatives from
U.S. EPA and Ohio EPA answered questions about problems at the
site and the remedial alternatives under consideration. The
proceedings were transcribed by a court reporter. A response to
the comments received during this period is included in the
Responsiveness Summary,. which is part of this Record of Decision
(ROD) .
IV.
SCODe and Role ot ReseODse within site strateav
As with many Superfund sites, the problems at the sanitary
Landfill Company (rWD) site are complex. Adverse environmental
impacts are derived from solid waste and hazardous waste disposal
practices which have occurred at the site.. The remediation at
the. sanitary Landfill ~ite is required to further control the
infiltration of contaminants into area ground water, prevent
direct human contact with landfill waste, and to control landfill
gases from migrating off-site. current and potential risks to
human health and the environment are shown to be posed by the
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contamination found on-site. This ROD selects a remedial action
for the site which addresses risks posed by all identified
pathways.
v. SummarY of site Characteristics
The Remedial Investigation (RI) was designed to determine the
nature and extent of contamination at the site through a sampling
program for ground water, soils, surface waters, sediments and
air quality. Also included in the investigation was a cap
integrity study and a waste characterization program consisting
of geophysical surveys, vent gas surveys, soil gas surveys and
intrusive borings into and leachate sampling from the landfill.
a.
Soils (surface and subsurface)
Eight surface soil samples were collected from two off-site
areas. Four samples represent upslope and background and four
were located downslope in areas adjacent to the site. No
volatile organic compounds (VOCs), pesticides, or PCBs were
detected in the soil samples. Semi-volatile organic compounds
(SVOCs) were detected in one upslope sample. Inorganic compounds
were found in both upslope and downslope samples.
Seventeen borings were drilled at nine loca~ions around the
perimeter of the landfill. Subsurface soils were collected and
submitted for chemical analysis and to determine subsurface
geology. organic and inorganic compounds were detected in these
samples. No pesticides or PCBs were detected. In general the
concentrations of organic contaminants were low and no pattern of
detections was identified. Inorganic contaminants were generally
within an acceptable range. The thickness of the unconsolidated
glacial materials varies from 250 to 300 feet. An unsaturated
zone of-glacial materials ranging from 55 to 80 feet in thickness
is present between the-base of the landfill and the water table.
b.
Ground Water
A network of 17 monitoring wells were installed around the
perimeter of the landfill (Figure 4). Water bearing units
sampled include the unconsolidated material above a continuous
clay layer to the west of the buried waste which supports a
perched zone of saturation (shallow wells or A-wells),
unconsolidated saturated material at the top of the regional
water table (intermediate wells or I-wells), unconsolidated
saturated material at a mid-depth between the top of the regional
water table and bedrock (mid-zone wells or M-wells), and
unconsolidated material at or near the base of the glacial
deposit/bedrock interface (deep wells or R-wells).
The flow direction from the shallow wells appears to be to the
west and may be hydraulically connected to and/or discharge at
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the seeps west of the landfill. The regional flow system, which
the intermediate wells bisect, generally flows to the
south/southwest. The deep wells generally follow the regional
flow system toward the south/southwest but also show a tendency
toward a more southerly directional flow. Since only two wells
were installed in the mid-zone, insufficient data points are
available to determine the potential flow direction at this
depth.
organic and inorganic compounds were detected in both upgradient
and downgradient perimeter monitoring wells. Detected organic
compounds ranged from 1 ug/l to 210 ug/l. Most of the organic
compounds found were at low concentrations of less than 10 ug/l.
Twenty-three metals (inorganics) and total cyanide were'detected
in monitoring wells. There is an even distribution of organic
and inorganic compounds found between the different aquifer zones
(depths) that were sampled; however, there is no pattern of
consistent detections between individual monitoring wells. The
available data is not sufficient to determine if there is a
defined plume of chemical contamination in the ground water. No
pesticides or PCBs were detected in the ground water samples.
One well cluster (MW-9I and MW-9M) located at the southern
boundary of the site showed one volatile organic compound
exceeding the Maximum Contaminant Levels (MCLs) over two
consecutive sampling rounds. However, inspection of the ground
water flow maps indicates uncertainty related to whether these
wells have been impacted or not impacted by the landfill. '
Four production wells in the vicinity of the landfill were also
tested to determine if the site was impacting drinking water
supplies. Eight organic compounds were detected in the samples
at concentrations ranging from 0.5ug/1 to 30 ug/l. Eleven
inorganic compounds were detected in the wells. Two of these
wells are considered upgradient and two are dowrigradient. The
two downgradient wells are located approximately one half mile
south of the landfill, however, the flow direction at these
locations were not conclusively established ,and other potential
sources have been identified between these wells and the site.
c.
Surface Water and Sediments
The investigation included the collection of liquid and sediment
samples from ten sampling locations, both on-site and off-site,
and three downgradient seep locations.
No VOCs, SVOCs, pesticides, or PCBs were identified in any of the
surface water samples ,above the required detection limits.
Numerous inorganic compounds were detected in' the surface water
samples collected. Numerous organic and inorganic compounds were
detected in upqradient, on-site, and downqradient sediment
samples.
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Three VOCs and twenty-one inorganic compounds were detected .in
the seep liquids. Thes~ seeps are downgradient of the landfill,
found at the same relative elevation as the landfill, and may be
hydraulically connected with the shallow monitoring wells on the
western perimeter of the site. No SVOCs, pesticides, or PCBs
were detected in the seep liquids. No SVOCs, pesticides, or PCBs
were detected in any seep sediment samples. Chloroform was
detected below the required quantitation limit. Numerous
. inorganic compounds were detected in the seep sediments.
Selected Summary of the Seep Liquid Sample Results (Maximum)
CONTAMINANT
CONCENTRATION
Methylene chloride
1,1-Dichloroethane
1,2-Dichloroethene
. Chromium
Cobalt
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
(total)
.002 parts
.02 ppm
.005 ppm
.0806 ppm
.111 ppm
244.00 ppm
.0546 ppm
496.00ppm
33.45 ppm
.00035 ppm
.117 ppm.
per million (ppm)
d.
Air Oualitv
The air investigation was conducted to determine the migration
and dispersion of potential chemical constituents in the ambient
air on-site and along the perimeter of the site (50-foot radius).
This investigation included an ambient air survey conducted.over
the entire site and perimeter areas located within 50 feet of the
site, and the collection and analysis of perimeter air samples.at
nine locations along the perimeter of the site .(Figure 5).
Several VOCs were detected both on-site (Table 1) and along the
perimeter (Table 2) during this portion of the investigation.
organic compounds detected include but are not limited to
trichlorofluromethane, toluene, 1,1,1-TCA, acetone, 2-butanone,
chloromethane, ethylbenzene, and methane. Many of the organics
detected were found in both upwind and downwind locations. Some
mechanism of movement such as dispersion or other physical
process may be occurring. No SVOCs were detected in upwind or
downwind samples.
As part of the air quality investigation, chemical analysis of
indoor air for workers in the Snyder Concrete Products Company
were performed. This company's operation occurs on and next to
the landfill. The chemical concentrations recorded in the single
grab sample were taken under worst case conditions. 1,1-
dichloroethylene and methylene chloride were two organic
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compounds that were detected. These two compounds were used to
assess the risk posed by the site and helped establish in the
risk assessment that the principal threat was landfill gas.
e.
CaD (cover) Inteqrity Study
The cap (cover) integrity study was conducted to determine the
nature and/or physical characteristics of the cover materials.
The study also assessed the overall effectiveness of the landfill
cover in preventing infiltration to the waste and the subsequent
rate of leachate generation, and the net drainage from the base
of the landfill. .
It was found that the existing cover materials are comptised of
varying contents of silt or clay, sand, and gravel size
particles. Comparison of field density measurements to
laboratory compaction test results indicates limited compaction
of the cover soils was achieved upon placement. Through the
application of the Hydrologic Evaluation of Landfill Performance
(HELP) computer model it was determined that the average net
drainage from the base of the landfill into the unsaturated zone
is approximately 4.0 inches per acre per year. It was found that
the existing cap allows for the infiltration of water into the
landfill and allows for the production and escape of landfill gas
in an uncontrolled fashion. .
f.
Waste Characterization
The waste characterization program was conducted to determine the
lateral extent of the waste placement boundaries, the depth of
the waste materials in the landfill, the composition and the
extent of migration of gases emanating from the landfill, and the
composition of the waste materials and leachate in the landfill.
The waste 'characterization investigation consisted of geophysical
and radiological surveys, on-site gas vent screening and sampling
surveys, installation and screening/sampling of on-site and off-
site soil gas probes, and intrusive drilling into the landfill.
No landfill volume estimates were performed for this site.
It was found that the landfill area encompasses approximately 36
acres and varies in depth from 45 to 75 feet. Gases emitted from
the on-site gas vents contain a high percentage of methane (5 to
61 percent). Several VOCs and SVOCs were detected both on-site
and off-site'in vent and soil gas sampling (Tables 1 and 3). The
extent of gas migration .off-site was found to be approximately
200 to 500 feet from the landfill boundaries. Visual inspection
of the waste material revealed paper, wood, plastic, metal and
foam rubber. In general, the waste has decomposed into a black
sludge-like semi-solid mass that contained several VOCs, SVOCs,
heavy metals and other inorganic compounds. The results did not
indicate the presence of pesticides, PCBs or radiological
materials in the landfill. .
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.
Selected Summary of the Leachate Sample Results (Maximum)
CONTAMINANT
CONCENTRATION
Volatile organics
1,2-Dichloroethene (total)
2-Hexanone
4-methyl-2-pentanone
Benzene
Chlorobenzene
Ethylbenzene
Methylene chloride
Toluene
Xylene
.001 parts
L 5 ppm
.076 ppm
.018 ppm
.014 ppm
.36 ppm
.24 ppm
.26 ppm
4.1 ppm
per million (ppm)
Semi-Volatile organics
Benzo(a)pyrene
Benzoic acid
Fluoranthene
Naphthalene
.012 ppm
.26 ppm
.037 ppm
.062 ppm
Inorganics
Arsenic
Cadmium
Chromium
Cobalt
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Cyanide
VI. Summary of site Risks
.62 ppm
.365 ppm
2.22 ppm
.437 ppm
2110.00 ppm
7.28 ppm
1960.00 ppm
20.6 ppm
.0021 ppm
1. 56 ppm
.0513 ppm
a. Human Health Risk
Based on the results of the RI, u.s. EPA and Ohio EPA directed
the PRPs in calculating the risks that the site would pose to
human health and the environment if no remedial actions were
taken at the site. This process is called the Baseline Risk
Assessment (Risk Assessment). Risk assessment involves assessing
the toxicity, or degree of hazard, posed by the substances found
at the site, and the routes by which humans and the envi~onment
could come into contact with these substances.
The NCP requires that the Risk Assessment consider exposure
scenarios for both current land use and for a conservative
9
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reasonable future use. Since the area surrounding the site is a
combination of both light industrial and residential within the
city of Moraine, and one mile from the city of Dayton, it is
appropriate to assess potential risks which would occur if no
action was taken at the site and the site was converted to
residential use sometime in the future.
The Risk Assessment, included as a separate document of the RI
report, examined the potential risks which the contaminants at
the site pose to human health and the environment. Based on
frequency of detection, concentration relative to background, and
toxicity, the list of contaminants found at the site was screened
to 81 chemicals of concern. These substances, which are listed
on Table 4, include 14 inorganics and 67 organic compounds. .
1,1-dichloroethylene (1.78 X 10-3 current use air pathway)
contributed to elevated site risks. Some other contaminants
which contributed to site wide risks for human health include:
methylene chloride (1.16 X 10-4 current use air pathway),
trichlorofluoromethane (670 ppbv air pathway), benzyl chloride
(3.12 X 10'5 current use air pathway), vinyl chloride (8.84
X 10-6 current use air pathway), 1,1,2 trichloroethane ( 1.17
X 10-6 . future use groundwater pathway), and arsenic (4.48 X 10-4
future use groundwater pathway). Table 5 summarizes the
chemicals of concern by media.
Routes of exposure were identified through which the chemicals of
concern could corne in contact with the public. Both current-use
pathways and future-use pathways were examined. Under current
conditions at the site, the existing routes of exposure include:
1-
2.
inhalation of VOCs in indoor air and outdoor ambient air;
incidental ingestion of surface soils, surface sediments,
and seep sediments; .
dermal contact with surface soils, surface water, and seep
water, and;
dermal contact with surface sediments and seep sediments.
3 .
4.
Potential, or future-use, exposure routes may evolve if the land
upon which the landfill. is situated is used for. different
purposes. In the future-use scenario, the Agencies assumed that
the site was developed for residential housing, as a means of
assessing a worst case situation. The potential routes of
exposure under these conditions may be:
1-
2.
3.
4.
5.
inhalati~n of VOCs in ambient air;
ingestion of onsite groundwater;
inhaiation of VOCs while showering;
dermal adsorptiQn of contaminants while showering;
ingestion of contaminants in surface sediment, surface
water, and seep sediment, and;
dermal adsorption of contaminants in surface sediment,
surface water, and seep sediment.
6.
10
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.
There are two types of health risks that contamination from a
site may pose to humans; carcinogenic (cancer-causing) and
noncarcinogenic. All people are assumed to have an average risk
of suffering from cancer in their lifetime. The Risk Assessment
estimates the excess risk, posed by the site, of getting cancer,
over and above the average risk. Cancer risks from various
exposure pathways are assumed to be cumulative. Acceptable risks
are those that may result in less than one additional cancer case
in 10,000 (less than 1. 00 X 10-4) to 1,000,000 (less than 1. 00
X 10-6) people exposed over a lifetime (70 years). For the
current-use scenario, potentially exposed populations are:
3 .
residents (both adults and children) living to the northeast
of the site:
workers at the Snyder Concrete Products Building on
Lance Drive:
workers at other commercial establishments along Lance
Drive, and:
children who trespass on and in the vicinity of the site.
1.
2.
4.
For the future-use scenario, the Risk Assessment assumed that the
site would be developed for residential use including the
installation and use of on-site ground water wells for drinking
water. The potentially exposed populations for the future-use
scenario include:
1.
2.
3 .
children and adult residents on the site;
residents drinking on-site ground water, and;
children who trespass on and in the vicinity of the site.
Risk calculations for current-use pathways and future-use
pathways showed unacceptable excess cancer risks. Current use
excess cancer risk estimates were identified for exposures to
indoor air at the Snyder Concrete Products Company (1.89
X 10-3). Other risk estimates were identified for outdoor
workers at the snyder Concrete Products Company (4.69 X 10.s),
adult and children residents off-site air (1.76 X 10." and 2.13 X
10.") children on-site air, trespassing (1.64 X 10.6) and
children dermal contact with seep water (1.55 X 10.6). Future-
use excess cancer risk estimates were identified and are shown on
Table 6.
Noncarcinogenic risks, or hazards, are evaluated with respect to
a hazard index, which represents the sum of all ratios of the
level of ~xposure of the contaminants found at the site to that
of contaminants' various reference doses. If this level exceed~
1.0, there may be a potential for the occurrence of
. noncarcinogenic health risks. Noncarcinogenic health risks were
identified for current resident children and adults for off-site
inhalation of volatiles at 6.0 and 2.9 respectively. For future
use, resident children and 'adults exceeded the hazar~ index for
11
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ingestion of ground water (6.1 and 4.2 respectively) and resident
children for dermal contact with surface sediments at 1.5.
b. Ecoloaical Risk
Ecological impacts from site-related contamination were also
evaluated. Due to the site's proximity to industrial and
residential development, the lack of suitable aquatic habitats,
and the limited size and diversity of possible habitats on-site,
the area does not support an abundance of terrestrial and aquatic
life. No endangered species were identified to be associated
with the site. The maximum detected concentrations are less than
on site-specific values and are less than published guidelines or
standards for ecological risk. The ecological assessment found
that the site does not pose a significant ecological risk.
c. Conclusions of the Risk Assessment
One conclusion of the risk assessment is that the principal
threat presented by the site is landfill gas. Actual or
threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in
this Record of Decision, may present imminent and substantial
endangerment to human health, welfare, and t~e environment.
VII.
DescriDtion of Alternatives
Alternatives for the remediation of the Sanitary Landfill site
have been evaluated in a Feasibility Study, which is available
for review by the public at the City of Moraine Library in the
Moraine Municipal Building, Moraine, Ohio. The Feasibility Study
was conducted to identify and screen technologies and .
alternatives for addressing the contamination problems at the
site. .
The remedial alternatives were first evaluated
ability to meet the remedial action objectives
protective of human health and the environment
Risk Assessment.
based on their
.and to be
as detailed in the
The remedial action objectives are the media-specific goals that
must be achieved to protect human health and the environment. An
environmental medium or physical area (e.g. air, soil, water), is
identified as a principal threat when it is contaminated with
unacceptable concentrations of toxic compounds, liquids, or
highly mobile materials. Based on the detection of organic.
gases, one of the principal threats is in on-site gas vents, off-
site soil gas samples, perimeter air samples, with VOC. ..
concentration exceeding acceptable risk levels. One remedial
action objective is to control the subsurface migration of gases
from the landfill to off-site locations and to control the
emission of landfill-gases on-site to the ambient air.
12
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The remedial action objectives for ground water are to limit
infiltration into the landfill to minimize the mobilization of
contaminants in the waste and limit direct physical contact with
the waste. If a defined plume is identified in the future,
another remedial action objective is to restore the ground water
to a useful, less threatening state by reducing the levels of the
contaminants present and preventing exposure (ingestion, dermal
contact, etc.) to those contaminants. .
CERCLA provides a preference for remedial actions which achieve
protection of human health and the environment through treatment
that permanently and significantly reduces the volume, toxicity,
or mobility of hazardous substances, pollutants, or contaminants.
The preamble to the NCP states that treatment is the preferred
alternative for the remediation of hazardous substances. The
preamble also states that solutions will most often involve a
combination of methods of protection, including treatment,
engineering controls, and institutional controls. u.s. EPA
guidance specifies that containment is the most likely response
action at CERCLA municipal landfills. The NCP also contains an
expectation that treatment should be considered for identifiable
areas of highly toxic and/or mobile materials that pose potential
principal threats. Treatment of mobile materials (landfill
gases) has been evaluated along with the containment part of each
appropriate alternative.
Once the applicable technologies have been selected, remedial
action alternatives were developed by combining two or more of
the screened technologies into specific remedial action options.
These alternatives address the media of concern and the remedial
action objectives for the site and are compared to specified
evaluation criteria.
All of the alternatives described in the following paragraphs,
except for the No Action alternative, include the fol~owing five
(5) common elements. .'
1. Institutional controls
Institutional controls 'will be used to restrict access to and
limit future use of the site, as well as to prevent use of ground
water beneath the site as drinking water. Use of the site will
be limited to prevent uncontrolled disposal of wastes, damage to
the cap and exposure of contaminants to humans or the
environment. The fencing network will be expanded.
Institutional control options include deed restrictions, and
enforceable access and land use restrictions.
2. Monitorinq
Monitoring is the basis for determining whether the remedial
actions conducted at the site are effective. Monitoring will
13
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encompass landfill gas emissions and ground water. Monitoring
will also consist of water level measurements of monitoring wells
and the leachate head wells which are currently drilled into the
landfill. As a base, the post-closure, long-term ground water
monitoring program will incorporate thirteen (13) of the existing
wells present at the site and two (2) new wells (figure 4). The
number of monitoring wells may change depending on changing site
conditions. Monitoring (which includes water level measurements
of monitoring wells and the leachate head wells) would commence
after the cover system has been in place and be conducted
quarterly for the first two (2) years, semi-annually for an
additional thirteen (13) years, and then annually for the
remaining fifteen (15) years, for a total of thirty (30) years.
3. Surface Water Run-off Controls
Surface water run-off controls include site grading, diversion
berms, stormwater drainage channels, collection systems, and
energy dissipation controls. Erosion control systems can also
protect the landfill slopes from damage due to erosion. The
design of these types of controls will be consistent with and
incorporated into the design of a cover system.
4. On-site Subsurface Gas Controls
The gas management system would consist of the installation of
approximately thirty (30) new active gas wells. The actual
location of the gas wells will be determined during the design
phase of the project. Higher gas concentrations and proximity to
residential/commercial development will be design considerations.
If it is determined that additional gas contro~s are necessary to
prevent migration of landfill gas off-site into
residential/commercial developments, a series of collection
trenches along the eastern/northeasternboundary.of the site
would be included as part of the gas control system.
The collection trenches can be passively vented or connected to a
main header and blower ~ystem for active extraction. The
collected gases would be flared, thermally destroyed or treated
by carbon adsorption and released by emission, thus resulting in
risk reduction.
5. Supplemental Site Investigation
The Supplemental Site Investigation (55!) will involve the
installation of two additional monitoring wells. These wells will
. be installed during the design of the cap and gas extraction
. system. The purpose of the 55I will be to further define the
flow gradients at the southern end of the landfill and attempt to
determine if the chemical contamination detected at the MW-9
cluster is coming from the landfill. .
14
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Alternatives 2 through 6, and Alternative 9 have been screened
out in the FS. Please refer to the FS for more details
concerning these alternatives.
Alternative 1: No Action
Months to Implement Action:
Estimated'Capital Cost:
Estimated 30 Year operation and Maintenance
(O&M) Costs:
Estimated Present Net Worth Cost (30 years):
None
$ 0
$
$
o
o
CERCLA and the NCP require that a "No Action" alternative be
considered as a basis upon which to compare other alternatives.
Under this alternative, no additional cover system or landfill
gas collection systems would be constructed, no additional ground
water monitoring would take place, and the conditions at the site
would remain as at present. No O&M activities. are included to
prevent further deterioration of present site conditions over the
long-term. This alternative would not adequately protect human
health or the environment. There is no cost for this
alternative.
Alternative 7: single Barrier Cover (Solid Waste Landfill Cap)
Months to Implement Action:
Estimated Capital Cost:
Estimated 30 Year operation and Maintenance
(O&M) Costs:
Estimated Present Net Worth Cost (30 years):
12 to 24 months
$6,019,400
$2,125,900
$8,145,300
Under this alternative a solid waste landfill cap would be
constructed, consisting of a one. or two foot bedding layer of
compacted. select native soil or sand sub-grade, two feet of
impermeable clay, a one foot minimum drainage layer of sand, and
a vegetated and protective top layer capable of supporting
vegetation with a minimum thickness of two feet (Figure 3). At a
minimum, a solid waste landfill cap will meet Ohio laws and
regulations for design .and operation of solid waste landfill caps
(ORC 3734.041, OAC 3745~27-11 and 3745-27-14). Finally, as
described above, necessary institutional controls, monitoring,
surface run-off controls and subsurface gas controls will be
implemented. The FS report provides a complete breakdown of cost
estimates for this alternative.
Alternative 8: composite Barrier Cover (Full RCRA Cap)
Months to Implement Action:
Estimated Capital, Cost:
Estimated 30 Year operation and Maintenance
(O&M) Costs:
Estimated Present Net Worth Cost (30 years):
15
12 to 24 months
$7,328,600
$2,188,000
$9,516,600
-------
Alternative 8 replaces the single barrier cover with a composite
barrier cover. Under this alternative, a composite barrier cover
would result in a greater reduction in the infiltration of
precipitation into the landfill. A typical composite cover would
consist of one foot of soil or sand sub~grade, a two-foot
compacted low permeability clay layer and a synthetic
geomembrane, one foot of sand, and a vegetative and protective
topsoil layer. At a minimum, this landfill cap will be designed
and constructed to meet Ohio regulations for design and operation
of hazardous waste landfill caps (OAC 3745-68-10, OAC 3745-65-90
through 3745-65-94, OAC 3745-66-17 through 3745-66-20). Again,
as described above, necessary institutional controls, monitoring,
surface run-off controls and subsurface gas controls will be
implemented. The FS report provides a complete breakdown of cost
estimates for this alternative.
Alternative 10: Natural Attenuation
This alternative is concerned only with ground water and assumes
that one of .the capping alternatives has already been chosen.
The following costs are in addition to the costs found in
Alternatives 7 and 8.
Estimated capital
Estimated 30 Year
(O&M) Costs:
Estimated Present
Cost:
operation and Maintenance
$116,000
Net Worth Cost (30 years):
$328,000
$444,000
This alternative assumes that the Supplemental Site Investigation
(S5I) is complete, a ground water plume is identified at the
site, and that natural attenuation is the appropriate response
action. There is a question as to whether the contamination
found in the monitoring wells at" the southern boundary of the
site has been caused by the contamination at the site. At this
time, no defined ground water plume has been identified migrating
from the landfill. This alternative allows, through natural
processes and without the imposition of additional remedial
measures compounds which may leach from the landfill to either
adsorb onto organic carbon particles in the soil or degrade by
physical and chemical reactions into less concentrated forms.
The net result of these processes, in conjunction with other
technologies such as capping, are to reduce (attenuate) the
concentrations of contaminants in ground water while capping
prevents further leaching of contaminants into groundwater.
The base monitoring plan as described above and incorporated into
ali alternatives would be expanded under this alternative. If a
"defined plume is found migrating from the site, additional
monitoring will be used to identify the extent of contamination.
This would involve the installation of additional ground water
monitoring wells and the evaluation of the effectiveness of
natural attenuation as a continued remedial option. For the
16
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purposes of this ROD, a ground water plume is defined as the
presence of the same compound (or sister/daughter compounds)
exceeding MCLs or risk based levels in the same downgradient
monitoring well over a period of at least two consecutive
sampling events. The completion of the 55! will be necessary to
evaluate the need to address ground water at the site, and, if
so, whether Alternative 10 or 11 is the appropriate ground water
response action.
Finally, as described above, necessary institutional controls,
monitoring, surface run~off controls, subsurface gas controls and
installation of a cap will be implemented. The FS report
provides a complete breakdown of cost estimates for this
alternative.
Alternative 11: Ground Water Extraction and Treatment (on-site or
Off-site)
This alternative is concerned only with ground water and assumes
that one of the capping alternatives has already been chosen.
The following costs are iri addition to the costs found in
Alternatives 7 and 8.
Estimated capital
Estimated 30 Year
(O&M) Costs:
Estimated Present
Cost:
operation and Maintenance
Net Worth Cost (30 years):
$1,139,000
$2,023,000
$3,162,000
This alternative assumes that the SSI is complete, a ground water
plume is identified at the site, and that ground water extraction
and treatment is the appropriate response action. As with
alternative 10, a ground water plume will be defined based upon
. the presence of the same compound (or sister/daughter compounds)
exceeding MCLs or risk based levels in the same downgradient .
monitoring well over a period of at least two consecutive
sampling events. This alternative involves the installation and
operation apd maintenance of extraction wells, pumps and a piping
system to allow for the collection of contaminated ground water.
The exact size, configuration and type of extraction and
treatment system would be determined during the design stage when
additional data has been obtained.
Finally, as described above or in other alternatives, necessary
institutional controls, monitoring, surface run-off controls,
. subsurface gas controls and installation of a cap system will be
implemented. The FS report provides a complete breakdown of cost
estimates for this alternative.
17
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I
VIII. SummarY of ComDarative Analvsis of Alternatives
criteria for Evaluation of Alternatives
The NCP requires that the alternatives be evaluated on the basis
of the nine evaluation criteria listed below. These criteria
were used to compare the alternatives and select a preferred
alternative:
Threshold criteria:
1. Overall Protection of Human Health and the Environment
Addresses whether a remedy provides adequate protection and
describes how risks posed through each exposure pathway. are
eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.
2. Compliance with ARARs
Addresses whether a remedy will meet all of the applicable
relevant and appropriate requirements of other Federal and
environmental laws and regulations and/or provides grounds
invoking a waiver of such ARAR.
or
State
for
primary Balancing criteria:
3. Lona-Term Effectiveness and Permanence
Refers to expected residual risk and the ability
maintain reliable protection of human health and
over time, once cleanup levels have been met. .
of a remedy to
the environment
4. Reduction of Toxicitv. Mobilitv. or Volume Throuah Treatment
Assesses the degree to which a remedy utilizes treatment to
address the principle threats at the site.
5. Short-Term Effectiveness .
Addresses the period of time needed to achieve protection and the
potential adverse effects that implementation of a remedy may
have on human health and the environment, i.e~ during the
construction and implementation period, until cleanup levels are
achieved. .
6. Irnplementabilitv
Addresses the technical and administrative feasibility of a
remedy, including the availability of services and materials.
7. Cost
Includes the estimated capital and operation and maintenance
costs for a remedy, as well as net present worth costs.
18
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. .
Modifying criteria:
8. state Acceptance
Indicates whether the state of Ohio supports the alternative.
9. Community Acceptance
Addresses the acceptability
community based on comments
period. "
of the alternative to the local
received during the public comment
Evaluation of Alternatives
Threshold criteria must be met in order for an alternative to be
eligible for selection. Primary balancing criteria are used to
assess the technical and administrative trade-offs between
alternatives. As a result of the assessment of primary balancing
criteria, u.s. EPA determines which alternatives satisfy the
statutory requirement for cost-effective and permanent solutions
which utilized treatment to the maximum extent practicable.
Comments received during the public comment period will form the
basis for evaluating the alternatives relative to the modifying
criteria described above. "
The following discussion summarizes the compliance of
Alternatives 1, 7 and 8 with the nine criteria. For a more
detailed discussion of this evaluation, please refer to the
Feasibility study. Alternatives 10 and 11 are not evaluated at
this time because a decision to implement either of these
altern~tives will be made after completion of the SSI.
Overall Protection of Human Health and the Environment
Based on the results of the RI and the Risk Assessment, the
inhalation of contaminated air from the landfill presented a
current-use pathway posing a risk to human health. Ground water
presented a future use risk if one assumes the leachate in the
landfill were to migrate into the regional water table and that
ground water were to be consumed as part of a" residential
development of the site.
All alternatives under consideration except Alternative 1 (the No
Action alternative) provide some degree of overall protection of
human health and the environment in the long term. Each of the
alternatives 'under consideration provides a base of protection
due to the subsurface gas control/treatment portion of each
alternative.
The two capping alternatives (alternatives 7 and 8) provide high
degrees of protection" through risk reduction. Both alternatives
help to control migration of landfill gas, the potential
inhalation of landfill gases, reduction or minimization of
surface water infiltration to reduce leachate production and
19
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subsequent migration into the regional aquifer, and the potential
exposure and direct contact with the waste material. .
compliance with ARARs
Federal and State ARARs are listed in Appendix A (Tables A-3 and
A-4) of the Feasibility Study Report and are provided as .
Attachments 2 and 3 of this ROD. ARARs are addressed in three
categories: chemical-specific, action-specific, and location-
specific. Alternative 1 (the No Action alternative) does not
satisfy any of the federal and state ARARs identified for this
site.
Chemical-Specific ARARs: Alternatives 7 and 8 will comply with
applicable or relevant and appropriate requirements under state
law and the Clean Air Act limiting emissions of landfill gases.
Landfill gas that is vented to the air will be destroyed or
treated with carbon adsorption to meet these limits.
Action-Specific ARARs: Alternative 7 satisfies federal Subtitle
D and state closure requirements of a two foot soil cover with a
maximum permeability of 1 X 10'7. Alternative 8 requires a RCRA
Subtitle C cap. Both capping alternatives will comply with OAC
3745-27-11, which requires, among other things, that a landfill
cap have a minimum slope of five percent and 'a maximum slope of
twenty-five percent or some alternate slope based on stability
analyses. Because of the topography of the landfill, stability
analyses will have to be conducted pursuant to
OAC 3745-27-11(G) (1) (c) to establish alternate slope requirements
for portions of the cap which do not allow for a slope between
five and twenty-five percent.
Though this alternative does satisfy federal and state closure
requirements, results of the RI indicate that Alternative 8's
level of protection is not necessary, because the wastes in the
landfill contain low levels of hazardous constituents. No hot
spots of hazardous wastes or constituents were identified in the
landfill.
Alternatives 7 and 8 will meet state ARARs for operation of a gas
collection system.
Location-Specific ARARs: No location-specific ARARs were
identified for the alternatives presented. .
Long-Term Effectiveness and Permanence
Alternative 1 is not. considered effective or permanent. . The two
capping alternatives (Alternatives 7 and 8) are considered
effective in the long term and provide a permanent remedy for the
site by containing the landfill contents and preventing the
migration of landfill gases and infiltration of precipitation
20
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. .
through the landfill. Given the characteristics of the site,
primarily the low levels of contamination and the absence of a
defined ground water plume, no significant difference in the
ability of the single barrier cover versus the composite barrier
cover to protect public health and the environment over the long
term was identified.
Reduction of contaminant Mobility, Toxicity, and Volume (TMV)
Through Treatment
Neither alternative 7 nor 8 reduces the toxicity or volume of the
landfill contents since treatment of the waste material does not
occur. The No Action alternative would not reduce the TMV of the
chemicals of concern identified for the site. Both capping
alternatives would reduce the TMV of the principal threat, the
landfill gases, through installation of a gas extraction system
and thermal destruction or carbon adsorption of the generated
gases.
Short-Term Effectiveness
I
Alternatives 7 and 8 are expected to be effective in the short
term, since the alternatives could be implemented in less than
two years. These alternatives would begin to reduce or minimize
landfill gas migration and infiltration thro~gh the waste
material immediately upon implementation. Both alternatives will
increase short-term exposure of human and environmental receptors
to contaminants which may be released through vaporization,
surface runoff, or fugitive dust emissions as a result of
remediation activities. Measures necessary to minimize these
impacts during remediation activities will be incorporated into
these alternatives.
Implementability
Both capping alternatives can be implemented using established
technology. The two capping alternatives are easy to implement
using available equipment and technologies. .
Cost
The No Action alternative would not entail any cost at the
present time, but may result in the need for very costly
remediation in the future. capital and annual operation and
maintenance costs increase from Alternatives 7 and 8 due to the
increase in complexity of these alternatives. Total costs for
the two capping alternatives range from $8,145,300 in Alternative
7 (single barrier/gas controls) to $9,516,600 in Alternative 8 .
(composite barrier/gas controls). .
21
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state Acceptance
The State of Ohio supports the preferred alternative as stated in
this Record of Decision.
community Acceptance
Community acceptance of the alternatives has been evaluated after
the public comment period ended and is described in the
Responsiveness Summary section of this Record of Decision.
Responses to all public comments are also contained in the
Responsiveness Summary. If evaluation of the ground water
remedial alternatives is triggered by the results of the SSI, a
public meeting and public comment period will be held.
IX. Selected Remedy
The selected alternative. detailed descriDtion
The selected alternative at the Sanitary Landfill Company (IWD)
site is Alternative 7, which involves the following:
Solid Waste Landfill Cap
On~site Subsurface Gas Controls
Surface Water Run-off Controls
Long-term Monitoring
Institutional Controls
Supplemental site Investigation
Also included with this remedy is:
concerning Ground Water
Possible Future Ground Water Remediation
Details on each component of the alternative are given below.
Solid Waste CaD
This alternative involves leaving the waste material in place and
covering the entire landfill area with a solid waste landfill
cap. The purpose of the cap is to minimize human and animal.
contact with the landfill material, minimize leachate generation
by controlling infiltration of precipitation through the
landfilled material and controlling erosion. Based on available
site data, a solid waste cap is preferred over a cap with a
geomembrane because, it is equally protective of human health and
the environment, and less costly to construct, inspect and
maintain.
A solid waste cap (Figure 3) consists of a vegetated top cover, a
middle drainage layer, a low permeability layer, and subgrade
bedding layer. The clay material constituting the low
permeability layer must not exceed 10.7 em/see permeability.
22
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- -
This design for a solid waste landfill cap is specified by the
Ohio Administrative Code (OAC) 3745-27-11. All solid waste
landfills in Ohio closed after April, 1990 must be closed in
accordance with this regulation. The vegetated layer will have a
minimum thickness of two feet and consist of fertile topsoil that
can support vegetation. A well-mixed cover of grasses and
legumes such as Kentucky bluegrass, clover, and red top will
provide a dense root system to anchor the soil and minimize wind
and water erosion and protect the soil barrier from damage due to
root penetration and frost. The granular drainage layer is
located directly below the vegetated top layer and is at least 1
foot thick, with a minimum permeability of 10'3 cm/sec (sand).
The low permeability layer will consist of a low permeability
soil layer (clay) at least 2 feet thick. This low permeability
clay layer minimizes the amount of infiltration to the capped
material. The bedding or sand subgrade layer will consist of
compacted select native soils, one to two foot thick.
Post closure care for the cap will continue for a minimum of 30
years after the closure date as outlined in OAC 3745-27-14. Post
closure care involves surface water management, ground water
monitoring, maintenance of the gas system, regular inspections of
the cap for erosion, subsidence, and/or settlement, and periodic
maintenance such as repair of any erosion damage to the cap or
any of the drainage channels from surface water runoff. The
maintenance program will be developed in a site operations and
Maintenance Plan as part of the remedial design/action.
Subsurface Gas controls
The subsurface gas controls/management system are to be
integrated with the solid waste cap outlined above. These"
controls will collect subsurface gases through an active pumping
system from gas extraction wells. "The property boundary and/or
fence line will be th~ compliance point for ambient air related
standards. The gas management system will consist of
approximately thirty (30) new active gas wells. The actual
location of the gas wells will be determined during the design
phase of the project. Higher gas concentrations and proximity to
residential/commercial development will be design considerations.
During the design phase, it may be determined that additional
subsurface gas controls are necessary to be protective of human
health and the environment. These additional subsurface gas
controls would consist of a series of collection trenches along
the eastern/northeastern boundary of the site. The trenches will
be passively vented or connected to a main header and blower
system for active extraction.
The existing passive gas system will be removed during"
construction of the new solid waste cap and active gas well
management system. The collected gases will be destroyed or
treated through the use of thermal flares or carbon adsorption.
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. I
If determined to be economically and technically feasible, the
collected gases can be sold to a local utility.
Surface Water Run-off Controls
Surface water run-off controls will include site grading,
diversion berms, stormwater drainage channels, collection
systems, and energy dissipation controls. The design of the
surface water run-off controls will be consistent with and
incorporated into the solid waste cap and active gas management
system mentioned above. .
Monitorinq
Long-term monitoring will be conducted for landfill gas emissions
and groundwater. Monitoring will also consist of water level
measurements at ground water monitoring wells and the leachate
head wells which are currently drilled into the landfill. The
monitoring system for gas emissions will be incorporated into the
new gas management system and be designed in conjunction with the
capping phase of the project. As a base, the post-closure, long-
term ground water monitoring program will incorporate thirteen
(13) of the existing wells present at the site and two (2) new
wells (Figure 4). The number of monitoring wells may change
depending on changing site conditions or other design
considerations. Monitoring (which includes water level
measurements of monitoring wells and the leachate head wells)
would commence after the cover system has been in place and be
conducted quarterly for the first two (2) years, semi-annually
for an additional thirteen (13) years, and then annually for the
remaining fifteen (15) years for a total of thirty (30) years.
The monitoring portion of the preferred alternative will be
carried out independent of the outcome of the SSI.
Extensive monitoring .of all media will be required during the
remedial design and remedial construction.
Institutional Controls
This remedy includes institutional controls to limit future use
of the site. This includes all areas covered by the cap, surface
run-off areas and the gas management system, etc. The
restrictions must prevent the use of this site for any activity
which will interfere with the performance of the remedy, or which
will result in the exposure .of contaminants to humans or the
environment. Such activities include residential or recreational
use, excavation, or construction of wells. U.S. EPA will seek to
prevent all individuals from traversing the cap, once completed,
so that the cap will not be damaged. Access restrictions, deed
restrictions, and land use restrictions are all institutional
controls to be used to control use of this site.
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The site fence (and warning signs) will be completed, which will
restrict access. In order to complete the site fence, at least
one business will have to be scaled back and partially relocated.
Deed restrictions from the site owner(s) will be obtained as a
means to impose these limitations on the use of the property.
In the event
effectively,
necessary to
term basis.
that institutional controls cannot be implemented
the u.s. EPA will consider additional actions as
ensure that the remedy remains effective for a long-
Supplemental site Investiaation
The Supplemental site Investigation (SSI) will involve ~he
installation of two additional monitoring wells. These wells will
be installed during the design of the cap and gas extraction
system. The purpose of the SSI will be to further define the
flow gradients at the southern end of the landfill and attempt to
determine if the chemical contamination detected at the MW-9
cluster is coming from the landfill.
The scope of the initial SSI (phase I) will include the placement
o~ a new intermediate well (MW-10I) and a new mid-zone well (MW-
10M) to the southeast of the landfill near the intersection of
Lance Drive and Cardington Road. The collection of monthly water
level measurements and the collection of quarterly ground water
samples for chemical analysis will be used to evaluate the
subsurface conditions at the southern end of the landfill. This
monitoring will continue for a period of up to one year. Ground
water samples collected for analysis (full CLP scan) will be from
the newly installed MW-10 wells and the existing MW-9 wells. The
collection of monthly water level measurements will be from all
existing monitoring wells and will commence when the new MW-10
wells are installed.
If the results of the SSI indicate that the presence of chemical
contamination can be attributed to the landfill then a second
phase of the 551 will be initiated to define the vertical and
horizontal extent of the plume. Phase two of the SS1, if
necessary, will involve the installation of additional ground
water monitoring wells and/or other hydrogeologic investigative
measures and will continue until the contaminated plume has been
delineated. Documents will be created that present the results
of both phases of the 551.
Evaluation of 55I
The U.S. EPA and Ohio EPA will conduct an' evaluation of the Phase
I and Phase II 551. As part of this evaluation Alternative 10,
Natural Attenuation and Alternative 11, Ground Water Extraction
and Treatment will be examined. This evaluation will be based on
25
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"I
the remedy selection criteria as defined in the NCP. This
evaluation may involve modeling to illustrate the effects of
natural attenuation versus active extraction on contaminant
levels, time estimates demonstrating natural attenuation versus
active extraction, and costs associated with each alternative.
Field work related to Phase I and II SSI must be completed prior
to an evaluation of either Alternatives 10 or 11.
Ground Water Treatment
The implementation of a ground water remedial action assumes that
Phase I and II of the SSI are complete, a ground water plume has
originated from the site and that ground water remediation is an
appropriate response action. Further evaluations will be
required of Alternative 11 (Ground Water Extraction and
Treatment) so that a comparison can be made to Alternative 10.
This comparison will be conducted or directed by the Agencies as
part of the Evaluation of SSI mentioned above. Discharge options
for the treated ground water will also be a part of this
evaluation. The treated ground water would be 'required to meet
ARARs. The goal of any ground water action will be to restore
the resource to its beneficial use, which, in the Great Miami
River Buried Valley Aquifer System, is drink~ng water.
Summarv
The u.S. EPA and Ohio EPA prefer Alternative 7 for the
remediation of the Sanitary Landfill (IWD) site. Also included
with this alternative is a Supplemental Site Investigation (SSI).
The Agencies may at a later time, depending on the results of the
SSI and/or the long term monitoring program re-evaluate the
possibility of groundwater remed'iation. Alternative 7 involves
the construction of a solid waste landfill cap" on-site
subsurface gas controls, surface water run-off controls, long
term monitoring and institutional controls.
The u.s. EPA; and Ohio EPA, believe that the chosen remedy, as
described above, is the best balance of desirable characteristics
with respect to the nine criteria. Based on information
avaiiable at this time, the u.s. EPA and Ohio EPA also believe
the chosen remedy offers the best protection of human health and
the environment. This remedy also complies with ARARs (e.g. Ohio
solid waste regulations), eliminates long-term risks, reduces
toxicity, mObility or volume of principal site threats through
treatment, is easily implemented and is cost effective.
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Cost of the Selected Remedy (does not include SSI or ground water
remediation)
capita'l Costs: $6,019,400
30 Year 0 & M Costs: $2,125,900
Present Net Worth Costs: $8,145,300
x. statutorY Determinations
u.S. EPA's primary responsibility at Superfund sites is to
undertake remedial actions that are protective of human health
and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences.
The following is a brief description of how the selected remedy
meets the statutory requirements of Section 121 of CERCLA.
Protection of Human Health and the Environment
The selected remedy provides for protection of human health and
the environment by limiting the potential for migration of
contaminants off site. This is achieved through capping and
subsurface gas controls and, if necessary, ground water remedial
action. The implementation of Alternative 7 will place site risk
within acceptable risk range for carcinogens.and the Hazard Index
for non-carcinogens.
The potential for direct exposure of the waste to humans, or
release into the environment, will be limited by the physical
barrier of the cap, and through deed restrictions, which will
limit inappropriate activities on the site.
. The selected remedy should not cause any unacceptable short-term
risks or cross-media impacts to the environment because only'
minimal movement of in-place wastes will be necessary.
ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements
Applicable requirements' are those cleanup standards of control,
and other substantive requirements, criteria, or limitations
promulgated under Federal or State environmental or facility
siting law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site. Relevant and appropriate
requirements are those cleanup standards, standards of control,
and other substantive requirements, criteria, or limitations
promulgated under Federal or state environmental siting law that,
while not "applicable",to a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance at
a CERCLA site, address problems or situations sufficiently
similar to those encountered at the CERCLA site that their use is
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well suited to this particular site. ARARs are divided into
chemical specific, action specific, and location specific groups.
All ARARs will be met for the selected remedy.
CHEMICAL SPECIFIC ARARs
The selected remedy will achieve fence line compliance with
chemical specific ARARs relating to the collection and treatment
or flaring of collected landfill gas. . Federal and State ARARs
relating to air emissions and the quality of ambient air will be
met during and after construction of the remedy.
Other ARARs (if deemed necessary) include Maximum Concentration
Limits (MCLs) established pursuant to the Safe Drinking Water Act
(SDWA), Ambient Water Quality criteria, and State standards which
give concentration limits for drinking water and surface waters.
MCLs and State drinking water standards are relevant and
appropriate based on the possibility that groundwater beneath the
site might eventually be used as a source of drinking water. The
other water quality standards and limits will be applicable in
the event that treated groundwater will be discharged to
infiltration ponds or used in ground water re-injection.
ACTION SPECIFIC ARARs
The cap shall be constructed in accordance with the requirements
of Ohio Administrative Code (OAC) 3745-27-11, other Ohio Solid
Waste Laws, and with RCRA Subtitle D specific requirements. .Most
RCRA requirements are administered under the State of Ohio's
implementing regulations. Because of the topography of the
landfill, stability analyses will have to be conducted pursuant
to OAC 374S-27-11(G) (1) (c) to establish alternate slope.
.requirements for portions of the cap which do not allow for a
slope betWeen five and twenty-five percent.
The RCRA Land Disposai Restrictions will apply to used carbon, if
carbon adsorption is chosen as the means to tre~t contaminated
landfill gas. If needed, discharges from the treatment system
will meet Federal and state ARARs relating to discharges of
contaminants. .
LOCATION SPECIFIC ARARs
No location-specific ARARs have been identified for the selected
remedy.
Cost Effectiveness
The U.S. EPA and the State of Ohio believe that the selected
remedy is cost-effective in mitigating the risks posed by the
site contaminants within a reasonable period of time. Section
300.430(f) (ii) (D) of the. NCP requires U.S. EPA to evaluate cost-
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effectiveness by comparing all the alternatives which meet the
threshold criterion; protection of human health and the
environment, against three additional balancing criteria: long-
term effectiveness and permanence; 'reduction of toxicity,
mobility or volume through treatment; and short term
effectiveness. The selected remedy provides the best overall
balance of these criteria and provides for overall effectiveness
in proportion to the cost. The additional costs of the SSI and
potential ground water remediation are not included in the
figures list below. The estimated cost of the selected remedy
(Alternative 7 only) is:
capital Costs: $6,019,400
30 Year 0 & M Costs: $2,125,900
Present Net Worth Costs: $8,145,300
utilization of Permanent Solutions and Alternative Treatment (or
resource recoverv) Technoloaies to the Maximum Extent Practicable
u.S. EPA and the state of Ohio believe that the selected remedy
represents the maximum extent to which permanent solutions can be
, utilized in a cost effective manner to address the potential
migration of contaminants away from the Sanitary Landfill site.
The selected remedy provides the best balance of tradeoffs in
terms of long-term effectiveness or permanence; reduction of
toxicity, mobility or volume through treatment; short term
effectiveness; implementability: cost; and State and community
acceptance. The criterion of long-term effectiveness and'
permanence is addressed by the installation of a solid waste cap
and a gas extraction system.
Based on the results of the RI/FS, it can not be determined if a
pump and treat ground water extraction system is warranted at .
this time. If the results of the 55I and/or other future
analytical results ind.icate the presence of a plume of
,contaminants emanating from the site, the groundwater portion of
the remedy may be re-evaluated. Ground water' remediation, if
needed, will provide a permanent solution for contaminated ground
water.
If feasible, the selected remedy may utilize resource recovery
technologies by cOllecting and selling usable landfill gas.
Preference for Treatment as a Principal Element
The selected remedy satisfies, in part, the statutory preference
for treatment as a principal element. On-site subsurface gas
controls will be utilized to collect and treat contaminated
landfill gases. However, selling the collected gas to a utility
company is also an option. Not all of the waste materials on the
site will be treated; the majority of wastes will be contained.
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XI. Documentation of sianificant Chanaes
The Proposed Plan for this remedial action was released for
public comment on March 29, 1993. The Proposed Plan identified
Alternative 7, combined with the Supplemental site Investigation,
as the preferred alternative. The Proposed Plan also included
the possibility of future ground water remediation. No .
significant changes have been made since the release of the
Proposed Plan. .
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Responsiveness summary for the Record of Decision
This responsiveness summary has been developed to document
community involvement and concerns which occurred during the
Remedial Investigation/Feasibility study and proposed plan phases
of the Sanitary Landfill Company (IWD) Superfund site process and'
to respond to comments received during the public comment period.
Public comments for the sanitary Landfill site were received by
the united states Environmental Protection Agency (U.S. EPA) at a
public meeting on April 14, 1993 and through the Region V chicago
office until April 30, 1993. All of the comments received are to
be considered prior to U.s. EPA's final decision embodied in the
Record of Decision (ROD) for a site.
I.
overview
Based on the findings of the remedial investigation and
feasibility study, the U.S. EPA and Ohio Environmental Protection
Agency (Ohio EPA) recommended in a Proposed Plan; institutional
controls, long-term monitoring, surface water run-off controls,
on-sight subsurface gas controls, solid waste landfill cap and a
supplemental site investigation. This Proposed Plan generally
received approval from those who commented during the public
meeting and the 30-day comment period. .
The responsiveness summary contains the following sections:
Backgr?und on community Involvement
Summary of Public Comments and Lead Agency Response
Remaining Concerns
II.
Backaround on Communitv Involvement
The U.S. EPA and Ohio
activities throughout
Study (RI/FS) process
officials information
EPA conducted community relations
the Remedial Investigation and Feasibility
to provide interested citizens and
about progress at the site.
The first public meeting occurred May 24, 1989. At this time the
U.S. EPA and Ohio EPA discussed with the community the sanitary
Landfill site and the Superfund program. corresponding with this
public meeting, a summary fact sheet providing background
information about the site was distributed. Discussions centered
around the remedial investigation which began in the summer of
1989.
A community Update (september 1990) fact sheet and two public
meetings were held to discuss on-site investigation activities.
Of particular interest to the community was the activity referred
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to as intrusive drilling. These meetings were well attended by
the community with health and safety concerns being the primary
issue.
Summary fact sheets describing the results of the RI were
distributed in April 1992. A fact sheet about the FS and
Proposed Plan was released in March 1993. The RI and FS reports
and Proposed Plan were released to the public in March 1993.
These documents were made available to the public for review and
copying in the administrative record maintained at the U.S. EPA
offices in Region V and in the City of Moraine Library.
Consistent with Section 113 of the Comprehensive Environmental
Response, compensation, and Liability Act (CERCLA), the.
administrative record includes all documents such as work plans,
data analyses, public comments, transcripts, and other relevant
information used in developing remedial alternatives for a site.
To encourage public participation in the remedy selection process
consistent with section 117 of CERCLA, the U.S. EPA set a 30-day
public comment period from March 31, 1993 through April 30, 1993
for the Proposed Plan. A formal public hearing was held on April
14, 1993, to accept verbal public comments on the Proposed Plan.
Interested parties were given the opportunity to make comments on
the alternatives presented in the Proposed Plan and elaborated
upon in the FS. . .
III. Summarv of Public Comments Received and Lead Aaencv Response
Comments 1 through 6 were raised as either oral or written
comments at the April 1993 public meeting or as written comments
received in the Region V Chicago office:
1. comment: Alternative 8, which includes a synthetic liner,
is arguably superior to Alternative 7. The additional expense is
not an issue. The potentially Responsible Parties should bear
these costs.
Incorporating a synthetic liner into a cap system is arguably
superior to a cap system without the liner. However, after the
u.s. EPA and Ohio EPA evaluated the data concerning the contents
of the landfill, it was felt that cost is a very relevant issue.
The addition of a synthetic liner will not give any more
appreciable protection than just a clay liner. The added cost is
not justified when comparing the difference in protection to
human health and the environment between these two alternatives.
The Potentially Responsible Parties ultimately will bear the
entire cost, regardless of the alternative.
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2. Comment: Alternative 10 for the cleanup of groundwater
should be rejected because it is as unacceptable as *1, No
Action. The fact that it costs the least is, once again, not the
point. why wait for a plume of contamination? Act with.
foresight, not hindsight.
At this time, Alternative 10 is not being selected as a remedy
for this site. The ground water alternatives will be evaluated
for future considerations only. The U.S. EPA and Ohio EPA have
determined that additional work related to ground water needs to
occur at the site. Therefore, as part of the selected remedy, a
supplemental site investigation (SSI) will be implemented to
determine whether a site-related contaminated ground water plume
does exist. If a plume of contamination is found to be emanating
from the landfill then the ground water alternatives will be
evaluated for appropriateness.
3. Comment: Are these materials (in the landfill) responsible
for the death of my first wife, who died of cancer at the age of
29? We resided on W. Bowman Ave. at the time she died in 1954.
A next-door woman also died of cancer at the age of 34. or 35
about the same time. .
It is very difficult to determine what causes cancer, especially
since so many lifestyle factors (such as smoking and occupational
exposure to chemicals) have been implicated in cancer cases.
Health risk assessments performed at Superfund sites, however,
have commonly looked at how the chemical reaches the person
(pathways), how much of the of the chemical the person is exposed
to, how long the exposure has been, and how carcinogenic the
chemical is.
An investigation into the Sanitary Landfill site history tells us
that the. property was mined for sand and gravel throughout the
1960's. Records indicate that some landfilling. activities
occurred at the site in the middle to late 1960's. The site was
not licensed as a solid waste disposal facility until January.
1971. Theretore, it is highly improbable that cancer deaths in
1954 can be correlated to the landfilling activities associated
with this site. '
4. Comment: Montgomery county Solid Waste Advisory Committee
and the Moraine city council passed a motion in support of
Alternative 7 as the selected alternative.
The U.S. EPA acknowledges the Montgomery County. Solid Waste
Advisory Committee and the Moraine City Council for their
support.
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. I
5~ Comment: An unsolicited contract proposal was submitted as
an ofter to erase all landfills. The proposal is to 'use a steam
retort to change trash back into its basic elements.
The U.S. EPA acknowledges the receipt of this unsolicited
contract proposal. However, the scope of this proposal is
outside the parameters that have been established for this site.
6. Comment: I'd like to say with respect
see nothing that (is) wrong with it. To me
job well provided that the clay is properly
design is proper. I don't see the worth of
in addition to it.
to Alternative 7, I
it really does the
selected and the
the plastic blanket
The u.s. EPA acknowledges this comment.
Comments 7 through 27 were submitted by the cardington Road
Coalition (the PRPs) over the signature of Steven M. Jawetz
(letter dated April 30, 1993). Because most of these comments
are lengthy and tend to overlap with regard to subject, they have
been summarized in this responsiveness summary. The complete
comments can be found in the administrative record for the
Sanitary Landfill Company (IWD) site.
7. comment: Alternative 7 Fully Addresses 'potential site Risks
Over the Long Term and Meets ARARs
There still remains additional work which needs to be performed
for ground water. since Alternative 7, in and by itself, does
not fully address gll potential site risks over the long term
(i.e. ground water), it is incorrect to state this. Future data
collected during the supplemental site investigation is designed
to answer questions related to ground water.
8. Comment:
Slope Cover
Alternative 7 Meets ARARs With A ,1% Minimum
The u.s. EPA believes that Congress intended that cleanup
activities conform to state laws which are implicated by remedial
actions. For example, remedial actions occurring in wetlands
must presumably comply with state wetland regulations.
Similarly, remedial actions occurring on solid waste landfills
must, at a minimum, comply with the state solid waste standards.
Both capping alternatives will comply with OAC 3745-27-11, which
requires, among other things, that a landfill cap have a minimum
slope of five percent and a maximum slope of twenty-five percent
or some alternate slope based on stability analyses. Because of
the topography of the'landfill, stability analyses will have to
be conducted pursuant to OAC 374S-27-11(G) (1) (c) to establish
alternate slope requirements for portions of the cap which do not
allow fora slope between five and twenty-five percent.
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since the Sanitary Landfill has been closed for over 10 years and
the initial waste placement began over 20 years ago, most of the
waste consolidation and settlement in the waste material has
already occurred, thereby making a stability analysis relatively
easy to accomplish.
9. comment: The PRPs think that the Selected Remedy Should Not
Include A Groundwater Element, Whether Or Not The Element Is
contingent
Additional work related to the ground water needs to be performed
at this site. until this work is performed and 30 years of
ground water monitoring (without a defined plume) has occurred
the Agencies are not willing to wholly abandon the ground water
issue. Any decision to implement a ground water remedial
alternative will be subject to public comment.
Nature and Extent of contamination
10. comment: The description in the proposed Plan stating that
the flow gradient of the regional flow system is to the "south/
southwest" is misleading and not consistent with the RI or FS.
The regional flow system was described by Norris and Spieker
(1966) and was modeled by Fidler (1975). Those studies indicated
that regional flow is to the south. The gradient and flow
direction has changed slightly through time, but the general
direction of the regional flow system remains toward the
southwest. Three wells were completed just above the bedrock,
deep in the regional flow system. The flow direction as
indicated by water level measurements, in these three wells
varies from southwest to south and southeast. On August 27,
1990, the flow direction was to the southeast. Water reaching
the aquifer would therefore travel to the southwest at the water
table and toward the south or southeast as the water t~avels
deeper within'the flow system. .
11. comment: The characterization of the "continuous clay layer
to the west of the landfill" in the Proposed Plan is not entirely
consistent with the RI.
There were four shallow wells installed on the west side of the
landfill. All four of these wells are screened in a clay layer
that is relatively at the same depth. The soil borings on the
east side of the landfill did not show that ,same clay layer. The
RI indicated that the clay layer is not continuous across the
site. This is true for the east/west direction but not true for
,the, north/south direction on the west siqe of the landfill.
, .
o
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12. Comment: The proposed Plan refers to a variety of ground
water sampling results, without indicating which results were
from upgradient wells, and results from the four production wells
may mislead the reader by oversimplifying the presentation.
The Proposed Plan is a document that, in part, summarizes the
results of the.RI and FS. The ROD can incorporate expanded
discussions when it is deemed necessary to support the selected
remedy. In this case, u.s. EPA directs the PRPs to section 4.0
of the RI for more information.
13. Comment: The discussion in the Proposed Plan of the surface
water and sediment investigation portion of the RI does not
sufficiently and accurately present the findings as they relate
to the site.
The 'Proposed Plan is a document that, in part, summarizes the
results of the RI and FS. The ROD can incorporate expanded
discussions when it is deemed necessary to support the selected
remedy. Since surface water and sediments, at this site, are not
considered a risk to human health and the environment and are not
incorporated into the selected remedy, the u.s. EPA directs the
PRPs to section 4.0 of the RI for more information.
14. Comment: The discussion of the air sampling results does
not accurately define the context or the conclusions of the air
investigation.
The Proposed Plan is a document that, in part, summarizes the
results of the RI and FS. The U.S. EPA, again, directs the PRPs
to Section 4.0 of the RI for more information. However, due to
the more serious implications of the air results and the
significant part that these results play in the selected remedy,
the u.S. EPA has expanded the discussion of air sampling results
in the ROD. .'
Baseline Risk Assessment
15. Comment: The reasons for assessing site risks based on a
future residential use scenario are contravened by the weight of
the data in the record.
The residential exposure scenario results in the highest risk
numbers. In this case, the baseline risk assessment assumed that
no action was taken on the site, and that the site was used for
residential purposes in the future. This evaluation is performed
in order to determine what could happen in the future if the site
were uncontrolled. This is a standard procedure which has been
performed at many superfund sites, and is considered proper
methodology.
o
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16. comment: The proposed Plan listed multiple contaminants
without specifying the environmental medium in which they were
found, and proceeded to make a number of general broad
statements.
The U.S. EPA disagrees that many of the statements in the Risk
Assessment are "general" or "broad". However, to satisfy this
comment, specific media of contamination have been included in
the Risk Assessment section. Nevertheless, these types of
statements are standard EPA language that is appropriate for this
site and have been used at many Superfund sites. The U.S. EPA
directs the PRPs to the Baseline Risk Assessment for more
information.
17. comment: Note (1) in both Table 1 and Table 2 of the
proposed Plan incorrectly states that the cancer. risks shown
represent the number of "expected" lifetime cancer cases for
particular exposure routes.
U.S. EPA presents data in a risk assessment as a worst case
scenario. This allows for the most protection of human health
and the environment and presents to the public the worst
potential exposure from the site. By definition, expected,
"t9 consider likely or certain", "to consider reasonable or
"to suppose". As the PRPs correctly stated, 'the numbers in
tables are the upper bound estimates. The tables are not
intended to predict specific numbers but demonstrate a risk range
for each exposed population. The upper bound is the worst case
scenario in this case and is "reasonable" or "likely".
means
due" ,
these
18. comment: The U.S. EPA's conclusion that actual or
threatened releases of hazardous substances from the site may
present a current or potential treat to human health, welfare,. or
the environment is not well supported by the evidence.
U.S. EPA considered the potential threat of future releases as
one of the major factors in the selection of the preferred
remedy. The evidence of actual releases overwhelmingly favors
the selected remedial a~tion. This is demoristrated, in part, by
the 10-3, 10-4 and 10-5 risk numbers for inhalation of volatiles,
and from the results of the HELP model that shows up to 4 inches
per acre per year of potential leachate is exiting from the base
of the landfill. Other major factors were the infiltration and
runoff of surface water was uncontrolled, and site monitoring was
. not established.
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'.
. I
Feasibilitv study
19. Comment: The PRPs opposed the Proposed Plan Description of
Alternative 10.
The Proposed Plan correctly states that: "Based on available
information, ground water contamination currently found at the
site will naturally attenuate or diminish over time posing no
additional risk to the community." Benzene was found at 19 ug/l
in the fourth quarter sample from the downgradient well number
4I. This contamination is clearly attributable to the site.
20. Comment: The PRPs opposed the Proposed Plan Definition ot
the Ground Water Plume.
The U.5. EPA and Ohio EPA believe that the definition of ground
water plume, as described, is appropriate for this site. The
last ground water samples collected were in November 1990. The
sample results taken during the RI provide a base for comparison
for all future evaluations of ground water. The detection of
contamination over MCL's or risk based numbers on two consecutive
scheduled sampling events would be an indication that a release
has occurred from the landfill. The PRPs may immediately
resample the welles) in question to verify the results and
validity of a particular round of sampling. 'However, two
consecutive detections of contamination over MCL's or risk based
numbers is the chosen method to document contamination.
If a release becomes verified, there are established procedures
in both the 55I and long term monitoring to determine the extent
of contamination. Part of the evaluation of natural attenuation
or active restoration will include the magnitude of the release
. and whether the contamination is increasing or decreasing over
time. . .
21. Comment: The PRPs opposed the Proposed Plan Description of
Alternative 11.
The PRPs comments regarding Alternative 11 suggest that
performance of a technical evaluation of existing ground water
data should be a prerequisite for selection of Alternative 11.
The Agencies will in fact perform such an evaluation prior to
selection of a ground water response action. In order to
consider selection of Alternative 11 certain assumptions must be
made. It must be assumed that the other investigations/options
have already been exhausted. As the Proposed Plan (and ROD)
states, "this alternative assumes that the 55I is complete,
ground water plume is identified at the site, and that ground
water extraction and treatment is the appropriate response
action. II This description clearly defines, up front, the
conditions that must be met before this alternative is even
38
-------
considered. Ground water remediation will not be evaluated if a
ground water plume emanating from the landfill has not been
identified for this site. And finally, in order to consider a
ground water pump and treat scenario, the other ground water
options will also have to be evaluated.
Evaluation ot Alternatives
22. comment: The proposed Plan inappropriately concludes that
Alternative 11 would provide the highest level of overall
protection.
Each alternative, by design, builds upon the previous
alternative. Alternative 7 (a solid waste landfill cap) is more
protective than Alternative 1 (no action). This same type of
reasoning is used for all alternatives that are considered.
Again, it is important to remember that Alternative 11 is based
upon the assumptions that are mentioned in comment 21. In the
Proposed Plan, the evaluation of "protectiveness", states that
Alternative 11 requires further data collection before it can be
said to be completely protective of human health and the
envir~nment. The ROD does not include any evaluation of ground
water remedies. This evaluation will take place if additional
data collected confirms the existence of a ground water plume at
the site.
23. comment: The proposed Plan incorrectly implies that only
Alternatives 10 and 11 comply with ground water ARARs and that
the description of the state slope requirement is inaccurate. .
Before any ground water remedy can be chosen, further data
collection, analysis and evaluation would have to occur,
including an evaluat~on of compliance with ground water ARARs.
As a further response, U.S. EPA refers the reader to Comment 8
for more details about the state ARAR on slope requirements.
24. Comment: No evidence exists for the statement in the
proposed Plan that the No Action alternative "may result in the
need for very costly remediation in the future."
The evidence used to support the selected remedy as outlined in
the ROD can be used to justify the need for a remedy to prevent
future, costly remediation.
DescriDtion ot Preterred Alternative And SSI
25. comment:
be clarified.
The PRPs .feel the consequences of the SSI should
U.s. EPA agrees that the SSI should be expand upon, and has used
the ROD as the means to accomplish this task.
39
-------
'I
26. comment: The PRPs believed that no basis exists for a
contingency remedy for ground water.
Additional work related to the ground water needs to be performed
at this site. Until this work is performed and 30 years of
ground water monitoring (without a defined plume) has occurred
the Agencies are not willing to wholly abandon the ground water
issue.
A well designed monitoring program would serve to verify the
effectiveness of remedial actions and trigger additional actions
as needed. This ROD allows the U.S. EPA to address future ground
water problems, should they arise. .
27. comment: The PRPs ~hink that trigger levels for ground
water response action should not be established at this time.
The most appropriate time to establish trigger levels for ground
water response action is during the ROD stage of any such ground
water response action. U.s. EPA has used the ROD to incorporate
expanded discussions in support of the selected remedy. However,
the selected remedy does not include any ground water response
action, therefore trigger levels have been removed from this ROD.
IV. Remainina Issues
At the public meeting, a resident expressed concern about the
landfill gas being collected and treated or collected and burned
versus. collected and sold to a utility. U.S. EPA responded that
the selling of landfill gas is a viable option. However,
additional information needs to be obtained regarding the amount
of gas available. This information will not be available until
the design phase of the project. . If selling the landfill gas is
both economically and technically possible, the U.s. EPA is
willing to support this activity.. .
40
-------
TABLE OF CONTENTS
FIGURES, TABLES AND ATTACHMENTS
SANITARY LANDFILL (1.0) SITE
RECORD OF DECISION
FIGURE 1 -
LOCATION MAP
FIGURE 2 -
SITE MAP
FIGURE 3 -
CROSS-SECTION SOLID WASTE CAP
FIGURE 4 -
LONG-TERM POST-CLOSURE MONITORING NETWORK
FIGURE 5 -
PERIMETER AIR SAMPLING AND GRID MODE LOCATIONS
TABLE 1 -
SUMMARY OF ANALYTICAL RESULTS FOR THE ON-SITE GAS
VENT AIR SAMPLES
TABLE 2 -
SUMMARY OF RESULTS FROM PERIMETER AIR MONITORING
STATIONS
TABLE 3 -
.
SUMMARY OF RESULTS FOR OFF-SITE GAS PROBES SAMPLES
TABLE 4 -
SUMMARY OF SELECTION OF CHEMICALS OF CONCERN
TABLE 5 -
SUMMARY OF CHEMICALS OF CONCERN BY MEDIA
TABLE 6 -
SUMMARY OF HEALTH RISKS - FUTURE USE
ATTACHMENT 1 - ADMINISTRATIVE RECORD INDEX
ATTACHMENT 2 - FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) .
ATTACHMENT 3 - STATE APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs)
-------
?EF"E~ENCED U.S.G.S. ~AP
-..... .,.....,
-
DAYTON ~OUTI1.
~ iOI4J2 - rr -<:124
OHIO
:HIO
.
--
-'
.,..
;;HOTOREVISED 1981
- ,
--....J'-
OUAORANGU: ~cc... nON
112
SCALE 1: 24000
o
1 IIU:
fOGO
o
'oaD
2000
JOIIO
o
.coo
!ODD
8OCIO
1'000 nrr
!
,~
SANITARY LANDFILL COl\fi'ANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
:\fORAINE. omo
I~
I
I CHKO
N.T.S.
, APPO
I DATE
LOCATION MAP
, FIGURE 1
-------
. .
f
N
A,.,.OXIMAT£ ~ANDFILI..
BOUNDARY
Sea1.: 18 IpproX. 400'
SANITARY LANDFILL COMPANY awn) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
MORAINE. omo
ORWN
SCALE
I CHlCD
I APPD
1 DATE
SITE MAP
nGtJRE 2
-------
Clay Layer
(2 Feeu
. "'" . '.
.. . ,- -. .,'A"'. ,", .,-"-,,, ..,~. I' ,'-', '.
. '..' ..' . " ::,',. "., ".," :.'.':.' . . '.,' ..' . " ~:.' . '",.,:: :,' ,':. .~ ','
I.. '.., .'., ..~.., . .' "".. ": I .
'P'~.'. ..~~ "':"';""'-':." :,', .~~.. :.: 1"""";,:.
. .' . .~...' " . . . . .. I . . ,,-' . . '-.'., .
. ~ . 'I . ..- .
'""It"",;,",, '" ,":\..,...-:..",
0. " ,: 0, ,', Waste' ,.iI,- 'e' 0,',
:.:: "" ',',', " '.:.:~:..::
..~. to . '. " . . " ..,.... .
. .. . . ... . .
I. ..~... " "",,.,"
II '. '. ... .,
~. .' ." - "'.. '.' .'..' . II - '. '. .'. ',1" . 'I'
: '. I' ',,' 'I .' ~. . .::. . . : '. , ',,' " .' ~. . . .." .
~ -,,' .' . . ',':''" . . '. . .,' : :.'.".'.: " ',1' .' . . I,::," . . '. . .,' : :,'.". ',: ~ '"
I ... ~. " .. . II' . \.... . " . I. . ". . II . . \..~ . I.
1.- '. ~--.. ." . .'.. v;. .'. ..~;.... ," . .'..~..". .
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
MORAINE, OHIO
DftWN
SCA&.£
CHKO
N,T,S.
CROSS-sEcrION
SOLID WASI'E CAP
M'fIIO
I DAtE
I
I .
. fiGURE 3
-------
.%:-
t
N.
A"Z
An
. p-"'''' =--~ W8i1s
A r...-....'" 1I'oOG8IGIm. ..us
8N.. -
.. ...
Seal.: 18 IlIPraz. 325'
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
MORAINE, omo
GINN I OICD I AIIfIO
~ I DAtE
LONG-TERM POST.ct.OStJU I FIGURE 4
MONlI'OJUNG NElWORE I
. I .
I
-------
I
I
--
.., ,
I ,." , ,
I
I
.'
j- ~:'r
I
I APPROXIMATE 1.ANOFILL
I BOUNOARY
I
I
I
i
I
MOOS
LEmrD
-=
. PERI)E1EI Ant SAlFLELDCATIOHS
I .
T BID JlGDE lCCATIDIS
- - - - ""ROIIMTt PROPEITT
BOUKDART
."&..
o 1= IDa raT
t
S
I
I
I
II
~. -
IORWN , OOCD I APPO
1;~~~iO:G~S
I ~
I
SANITARY LANDFILL COMPANY awn) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
:\IORAINE.OmO
Ii
-------
TABLE 1
SUMMARy OF ANALYTICAL RESULTS FOR THE
ON-SITE GAS VENT AIR SAMPLES
SANlT ARY LANDFll..L C01\1P ANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
MORAINE, omo
...Id SlmDI8I 3IIn". I
::rT'IDounD I Un,t. sat.. Max Min ~'"Q\llncY Max I M.n I :,eau.ncv .
Volltill O'OMlC8 I
Oiclllo'ooifluo,omltlllnl IIlItly 80 1500 95 8110 . . . . .. 0:2
1 .2.0iclllo'0-1. 1 .2.2-tltrlfluo'oltlllnl IIlItly 80 130 93 £/10 ... ... C:2 \
Vinvt CNonell IIlItly 100 1100 190 8/10 ... ... 0/%
B'omomltlllnl IIlItly 1 %0 4&0 4&0 1/10 ... ... 0:%
Clllo'oltnlnl IIlItly %00 £5000 190 9/10 . .. . .. 0:%
T,icN,ofluo,omltl\8nl IIIIDV 4.0 250 5£ %/10 ... ... 0/%
1 .1.2.TricNo'o- 1 .2.%.trif!uO'Oltl\8nl IIlItlv 80 £20 £20 1/10 ... ... 0:2
ACltonl IIlItlv £00 510 510 1/10 ... ... 0/% I
","."nl IIlItlv 320 18000 1100 10/10 ... ... 0/%
1 .1 -O,clllo,oltnln. IIIIDY 100 5100 150 5/10 ... ... o:% !
Vinvt IClt11l IIIIDY 100 4&0 4&0 1110 ... ... 0:2
, . 1.0,clIlO'oltlllnl ootlY 80 700 220 2/10 ... ... 0:2
1.1.' .TncNO'O.tllln. ollDY 80 14.00 770 2/10 ... ... 0:2
Blnu". ollDY 120 980 £70 "10 ... ... 0,'2
T,;cnloro8t"'8n8 IIlItly 100 210 290 1110 ... ... 0:2 I
4-Mltllvt-2-".ntlnOnl IIlItly 120 1.0 180 1/10 ... ... 0:2 I
I
Tolu.n. ootlY 1%0 20000 110 9/10 ... ... 0/2 I
TIUlcNoroltMnl IIlItlY 1%0 200 200 "10 . . . . .. 0/2 I
2,"'".lnonl IIlItly 200 ~1oo 380 10/10 ... ... 0/2
CNo,oo.nl.". IIlItlY 100 £10 120 8/10 ... ... 0/2 I
Etllvttllnun. IIIIDV 100 17000 120 9/10 3.7 3.7 11% I
1.4- .nel 1.3.(m.ol Xvtlnl ollDY 200 S4.000 210 10/10 11 " 1.'2
1.2'(01 Xvten. IIDtlY 10 12000 120 10/10 1.1 4.4 1:2
a.nlV' cNondl IIlItlY 10 21000 250 8/10 10 10 1/% I
4-EtllY! tolu.". IIlItly 180 14.00 200 8/10 ... ... 0/2
, .3.S.Tnrnltllvttllnz.n. IIlItlv 100 110 100 9/10 . . . . .. 0/% I
, .2.4-Tnmltllvttl.nzlnl PIIDY 120 1500 250 8110 ... ... 0.% I
I
!
M.mln. "4 fvol/'WI! e1 5.3 10/10 2.4 2.4 , ':
IIlItly. Plru lI.r !liWo" tlv voIum8
. .. . No MulMin d,," to no .ltlcOON!
. . Sempll Qu8ll0ll1l0n Ur'ftIu. Thl limiu lilted 8bOV8 Ire for IN fl8IcI 18mII111 only.
1'1 I f8CtOt 0' 40 IINII8r.
Tho QIIlnliulion limitl fo' tll. tlll""
-------
Field Samples Snyder Uowind Samples 81anks
ComDound Units SOP Mall Min Freo.' Buildinn Max Min FreQ.' Mall Min F.eq.'
Vol.... 0,.......
Dlchlorodilluoromethane ppbv 2-100 2.2 .2.2 3/12 NO 22 2.4 2/6 ... ... 0/3
Chloromethlne ppbv 2.5-125 ... ... 0/12 NO 4.3 4.3 116 ... ... 0/3
1.2-Dlchloro-I.I.2.2-teualluoroethane ppbv 2-100 ... ... 0/12 NO 4.9 4.9 116 ... ... 0/3
t rlchlorofluoromethlne ppbv. 1-50 320 2.1 12/12 22 2000 5.3 5/6 2800 210 2/3
1.1 .2-Trlchloro- 1 .2.2-trllluoroethln. ppbv 2-100 31 1.8 3/12 NO 46 3.2 3/6 ... ... 0/3
Acetone ppbv 10-500 13 10 4/12 21 15 12 3/6 ... ... 0/3
Methylene chloride ppbv 4-200 48 8.3 3/12 60 34 20 2/6 ... ... 0/3
1.1 -Dlchloroethene ppbv 2-100 ... ... 0/12 9.4 ... ... 0/6 ... ... 0/3
2-Butlnone ppbv 3-150 23 3.1 5/12 NO 11 9.6 2/6 ... ... 0/3
1.1.1- T rlchloroethlne ppbv 2-100 3.8 2.8 4/12 1.5 6.6 2.3 4/6 ... ... 0/3
4.M.thyl- 2 -pentlnone ppbv 3-150 10 7.8 3/12 10 7.1 1.1 116 ... ... 0/3
Toluen. ppbv 3-150 6300 4.8 4/12 6.9 1600 8.9 4/6 3800 3.6 2/3
2.H.llloon. ppbv 5-250 16 16 1112 NO 12 12 116 ... ... 0/3
Ethylbenzene ppbv 2.5.125 ... ... 0/12 NO 6;3 6.3 116 ... ... 0/3
1.4-lnd 1.3-lp.ml Xylene ppbv 5-250 7.2 5.4 3/12 1.2 ... ... 0/6 .., ... 0/3
- >
btI.c..b18 Gr,enlee
1.2-Dichlorobenzene ppbv 5-250 ... ... 0/12 6.3 ... ... 0/6 ... ... 0/3
M."'.... ppbv NR 28000 2800 11/12 14 91000 2100 6/6 4900 4900 113
F".. If/eel NR 0.01 0.0018 1/12 NA 0.003A 0.0028 3/6 .. . . . . 0/3
TABLE 2
SUMMARY OF RESULTS FROM PERIMETER AIR
MONITORING SfATIONS
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAn LANDFILL)
MORAINE, 0100
B - Below qUlntilicltion limit Iless than 5.5 libe.. per 100 heldsl
NA - Simple not lubmltted lor Inlty,11
ppbv - Plrt. per billion by volume
lice - Flb.r. per cubic centimeter
NO - Non-detect
NR - Not reported
. - Simple OUlntitation limits
. .. .. No Max/Min due to no detections
-------
. TABLE 3
SUMMARY OF RESULTS FOR OFft'-SITE GAS
PROBE SAl\1PLFS'.
SANITAltY LANDl.'LL COl\fl)ANY U\VD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
MORAINE, 0100
-"_.
fi
Mall
250
12
1500
210
noo
1200
triO
1400
6100
010
!)UOO
57
4UO
210
:J.I
58
J:W
2100
100
43
--
~ Unils SOL.
VoIatlll Orglnlc,
Chlofomelhilnl ppbv 2.5-225
Chloroform ppbv 2-180
Dlchlorodilluoromethanl ppbv 2-180
1.2-Qlchloro-1.1.2.2-letrafluorolthane ppbv 2-180
Vinyl Chloride ppbv 2.5-225
Chlor08thane ppbv 5-450
T ,'chlrofluo,omlthan. ppbv 1-90
Acetone ppbv 10-900
H..ane ppbv 8-120
1.1-DlchIorOlthan. ppbv 2.5-225
Vinyl acelale ppbv 2.5-225
tranl-1.2-Dlchlofoelhene ppbv 4-360
1.1-Dichlo'0IIhen. ppbv 2.180
I. 1.1- T rlchloro.thane Pltbv 2-180 -
Benzene Pllbv 3-270
T richlo,oelhene Pltbv 2.5-225
T etrachloroelhene ppbv 3-270
2-H..ilnone flpbv 5.450
2-0ulanone ,tpbv 3-210
Melhene "'-I vol/volt NR
@ ~ . Resulls in ppm Ivol/voll
, - F,equencv
. co Sample Ouanlilalion limils .
.. - Samples afe adjacenl 1o Lanclt O.ive buildings
. .. D No MaxiMin due 10 no delltclions
NR. NOl reponed
----.- - -
chi Sam les Uldllk
Min rrllq.! - ~ _Min ffIJ'l.!-
15 3/11 . . . . . . 011
12 1/11 ... ... 0/1
4.2 4/11 . .. .. . OIl
16 5/11 . .. ... 0/1
400 2/11 .. . . .. 0/1
620 2/11 .. . . .. 0/1
1.3 10/11 6.9 6.9 1/1
1400 1/11 . .. ... 0/1
48 3/11 . . . . .. 011
160 2/11 . .. . .. 011
1400 2/11 . .. ... Oil
42 2111 . . . . . . 0/'
200 3/11 . . . .. . bll
2.4 9/11 2.7 2.J '11
23 2/11 . . . . .. 0/1
23 2/11 . . . . . . 0/ I
4 5/11 . . . . . . 0/1
b60 2/11 . . . . . . 0/ I
180 1/11 . . . . .. 0/1
2JO@
11/11- - !1C!,iI .J!C!.iI -!n-
-------
TABLE 4
SU~L\IARY OF SELECTION OF c~,nCAL OF CONCER'f
SANITARY LANDFILL COl\1PANY (I\VD) SITE
(a.k.a. CARDINGTON ROAD LANDFll.L)
:\fORAINE. OInO
Chemlcai Reasons
of for
Comcounc Media Detected .:oncern Elimination
INORGANICS
Aluminum surlace sOli No A
seee water No A
surface water No A
seep sediment No A
surface sediment No A
ground water (T) No A
leachate Yes
Antimony surface soli No A
seee water Yes
seee sediment No A
surface sediment Yes
ground wate'r (T) Yes
leachate Yes
.
Arsenic surface 5011 No A
seep water No A
surface water Yes
seep sediment No A
surface sediment No A
ground water (ij Yes
leachate Yes
Barium surface sod No A
seep water No A
surface water No A
SHP sediment No A
surface sediment Ves
ground water (ij Ves
production wells Ves
leachate Ves
I eerytUum seep water VIS
ground water (ij No A
leachate Ves
I Cadmium seep water No A
SHp sediment No A
ground water (T) No A
leachate Ves
A - Backaround: B - Fr8t!uen~ nf ~iDt8M. ,.. - =_..._i_1 h.._... ... .......-. " - en...&-
-------
. I
TABLE 4 (continued)
SU1\Il\tIARY OF SELECTION OF cHtMlCAL OF CONCERN
I
Iron surfaca soil No A,e
seep water No A,e
surface water No e
seep sediment No A,e
surface sediment No e
ground water (T) No C
production wells No Ate
leachate No C
Comoouno
Calcium
Media Detected
surface 5011
seep water
surface water
seep sediment
surface sediment
ground water (T)
. production wells
leachate
surface soli
seep water
seep seaiment
surface sediment
ground water (T)
leachate
surface soil
seep water
. seep sediment
surface sediment
ground water (T)
leachate
surface soil
SMp water
surface water
seep sediment
surface sediment
ground water (T)
production wells
leachate
ground water (T)
leachate
Chromium
. Cobalt
, Copper
I
I CyanIde
,& - eJ..............._... II t!'--..---. -~ ..8-6 - _A.'-' -
ChemIcal
of
Concern
No
No
No
No
No
No
No
No
No
No
No
No
Yes
Yes
.
No
Yes
No
Ves
No
Ves
No
No
No
No
No
No
No
No
Ves
No
Reasons
for
Elimination
A.C
C
A,C
A,C
A.C
C
C
C
A
A
A
A
A
A
A
A,C
C
A,C
A,C
C
Ate
A,e
C
o
-------
TABLE 4 (continued)
Su~IMARY OF SELECTION OF cllliMICAL OF CONC~~
ChemIcal Reasons
of for
Comccuno Media Detected Concern Elimination
-
Leao surface soli No A
seep water Yes
surface water No A
seep sediment No A
surface sediment No A
ground water (T) Yes
production wells Yes
leachate Yes
MagnesIum surface soil No A.e
seep water No C
surface water No A.e
seep sediment No A.e
surface sediment No C
ground water (T) No C
production wells No C
.
leachate No C
; Manganese surface sod No A.e
seep water No A.e
surface water No e
seep sediment No A.e
surface sediment No C
ground water (T) No C
production wells No A.e
leacnate No C
Mercury seep water No A
I seep sediment No A
I
surface sediment Yea
ground water (T) No A
leachate Yes
Nickel surface sod No A
seep water No A
SMP sediment No A
surface l8diment Yes
ground water (T) No A
leachate Ves
A - Background; S - Frequency of detect: C - EssentiaJ human nutrient: C - elanks
-------
TABLE 4 (continued)
SIDrIMARY OF SELECTION OF CHI-.!\fiCAL OF CONCERN
ChemIca! Reasons
of for
Comcouno Media Detected Concern Elimination
?otasslum ;urtace soli ,- No A,e
seep water No C
seep seaiment No A,e
surface sediment No C
ground water (T) No e
production wells No e
leachate No e
Selenium surface sediment No A,e
Silver seep water Yes
surface sediment Yes
Sooium surface sod No A.e
seep water No C
surface water No A.e
seep sediment No A,e
surface sediment No C
ground water (T) No A.e
production wells No e
leachate No e
. Vanaoium surface soil No A
5.ep water Yes
surface water Yes
seep sediment No A
surface sediment No A
ground water (T) No A
leachate Yes
. Zinc surface sod No A,C
SHp water No A,e
surface water No A,e
seep sediment No A,e
surface sediment No Ate
ground water (T) No cte
production W8Us No A,e
leachate No C
ORGANICS I
Acenapnthene surface sediment No A,S I .
I.achate Yes
I Acenaonthylene surface sediment No B I
A - Background: S - Frequency of detect: C - Essential human nutrient: 0 - Blanks
-------
TABLE 4 (continued)
SlThIMARY OF SELECTION OF cliliMICAL OF CONC~'I
Chemical Reasons
of for
Comcouno Media Detected Concern Elimination
Acetone perimeter air Yes
gas vent Yes
off-site soil gas Yes
ground water No 8,0
leachate Yes
indoor air Yes
Anthracene surface sediment No A,S
leachate Yes
Benzene gas vent Yes
off-site soil gas Yes
ground water Yes
leachate Yes
SenzOI a)anthracene surface soil No A,S
surface sediment No A
leachate Yes
, Benzo~a)pyrene surface sod No A,S
i surface sediment No A
leachate Ves
Senzo~b )fluroanthene surface soil No A,B
surface sediment No A
leachate Ves
8enzo~ghl)perylene surface soil No A,B
surface sediment No A
leachate Ves
8 enzot k}fluroanthene surface soil No A,B
surface sediment No A
leachate Ves
I BenzoIc acid leachate Ves
surface sediment Ves
I Benzyl alcohol leachate Ves
Benzyl chloride gu vent Ves
bis(2- Ethylhexyt)phthalate surface soil Va
surface sediment Va
ground water No 0
leachate Yes
Bromomethane gu vent Ves
.
A - Background; B - Frequency of detect: C - Essential human nutrient: 0 - Blanks
-------
TABLE 4 (continued)
S~IMARY OF SELECTION OF cllliMICAL OF CONCERN
Chemical Measons
ot for
Comcouno Media Detected :oncern :!imination
2-Butanone penmeter aIr Yes
surface sediment Yes
off-site soil gas Yes
leachate Yes
SutylbenZYlphthalate surface sediment Yes
leachate Yes
Carbon cisultide ground water No D
Chlorocenzene gas vent Yes
leachate Yes
Chloroetnane gas vent Yes
off-site soil gas Yes
ground water No S
leachate Yes
Chloroform seep sediment Yes
surface sediment Ves
off-site soil gas Yes
Chloromethane off-site soil gas yes
: Chrysene surface soil No A,e
~ surface sediment No A
! leachate Ves
;
. Dibenzo~ah)antnracene surface soil No A,e
I surface sediment No A
Dibenzoturan surface sediment No A,e
leachate Ves
., ,2-Dichlorobenzene indoor air Yes
i 1 ,4-Dichlorobenzene leachate Yes
I Dichloroaifluoromethane perimeter air YII
I gas vent Yes
off-site soil gas Ye.
1 ,1-Dichloroethane gu vent Yes
SMp water Va
off';'site soil gas Va
ground water Ves
production wells Ve.
A - Background: B - FreQuency of detect; C - Essential human nutrient: 0 - Blanks
-------
TABLE 4 (continued)
SlThIMARY OF SELECTION OF CHEMICAL OF CONCEIl'l
Chemical Reasons
of for
Comcound Media Detected Concern Elimination
, . , -~ichjoroetnene indoor air Yes
gas vent Yes
off-site 5011 gas Yes
, ,2-Dichloroethene ttotal) grouna water No D
seep water Yes
leachate Yes
production wells Yes
trans-' .2-Dichloroethene off-site soal gas Yes
, .2-Dichlcro-1 , , .2.2- gas vent Yes
tetrafluoroethane off-site soil gas Yes
Di-n-outylphthalate surface seoiment Yes
ground water No B
leachate Yes
DietnY1pntnaiate ground water Yes
leachate Yes
,2.4-0imetnylphenol leachate Yes
: Di-n-octYl-phthalate leachate Yes
Ethylbenzene gas vent Yes
I ground water No B,O
leachate Yes
production wells Yes
4-Ethyl toluene gas vent Ves
Fluroantnene surface soil No A.S
surface sediment No A
leachate Ves
I Fluorene surface sediment No A,S
leachate Yes
i Hexane gu vent Ves
off-site soil ~as Ves
!2-Hexanone perimeter air Yes
gu vent Ves
off-sit. soil gas Ves
leachate Ves
Indeno( 123-cd)pyrene surface soil No A,S
surface sediment No A
leachate Ves
A - Background: B - Frequency ot detect: C - Essential human nutrient: C - Blanks
-------
TABLE 4 (continued)
SilltlMARY OF SELECI'ION OF cflliMICAL OF CONCE:Rl~
Chemical Reasons
of for
Comcound Media Detected Concern Elimination
\1etnane perImeter air Yes
gas vent Yes
off-site soil gas Yes
indoor air Yes
MetnYlene cnlonce perimeter air Yes
seep water Yes
ground water Yes
leachate Yes
indoor air Yes
production wells Yes
2 -Metnvtnacnthatene leacnate Yes
~-MethYI-2-pentanone perimeter air Yes
gas vent, Yes
leachate Yes
indoor air Yes
,2-Methytphenot leachate Yes
; 4-Methylphenol surface sediment Ves
leachate Yes
Nacnthalene leachate Yes
'n-N itrosociphenylamlne surface soil Yes
leachate Yes
. Pentacnlorocnenol leachate Yes
Phenantnrene surface soil No A,S
surface sediment No A,S
leachate Yes
I l.aChate V..
:Phenol
,
i Pyrene surface soil No A,B
I surface sediment No A
leachate Ves
IT etrachloroethene gu vent va
l off-site soil gas Yes
ground water No C
leachate Va
A - BacJcground: S - Frequency of detect: C - Essential human nutrient: 0 - Slanks
-------
TABLE 4 (continued)
StThIl\IARY OF SELECTION OF cH.tJ\1ICAL OF CONC~~
Comcound
Toluene
T r ichlo rotluoro m et nane
1.1. , - irichloroetnane
I
:,., .2- Trichloroetnane
I Trichloroethene
i
1.1.2- Trichloro-' .2.2-
trifluoroethane
11.3.5- Trimethylbenzene
11.2.4- Trimethylbenzene
Media Detected
perimeter air
gas vent
surface sediment
ground water
leachate
indoor air
oroduction wells
perimeter air
gas vent
off-site soil gas
indoor air
perimeter air
gas vent.
off-site soil gas
ground water
indoor air
leacnate
gas vent
off-site soil gas
ground water
le.chate
production wells
perimeter air
gas vent
gas vent
gas vent
Chemical
ot
Concern
No
Yes
Yes
No
Yes
No
Yes
. Yes
Ves
Yes
Yes
Yes
Yes
Ves
No
Yes
Ves
Ves
Ves
Ves
Ves
Ves
Ves
Ves
Ves
Ves
Reasons
for
E!iminauon
D
8.0
D
B
Vinyl acetate gu vent Ves I
off-site soil gu Ves
Vlnyt chloride gu vent V.. I
off-site soil gas Ves
, ,4 and' .3(p,mpcytene perimeter air Ves.
gu vent Ves.
indoor air V8S+
1 ,2-{o)xylene gu vent Vu+ I
xytenes (tota!) ground water No . a,e
leachate Vu+
A - Background: a - Frequency ot detect C - Essential human nutrient: 0 - BlAnks
-------
'I
TABLE 4 (continued)
Sm-IMARY OF SELECTION OF t;H.tJ\fiCAL OF CONCERN
~Jates:
. - see OISCUSSlan In text
- - ""Iii be treateo as total xYlene
T - iotal ,.
Reasons for E::minatian or Selection as Chemical of Concern
A - All detects were below cacKgrouna concentrations. Approplate bac)(ground
was defined as:
- site-specific background were only used if the compound was detected
in more than 50% of the background samples. or if the frequency of
detects in background samples was at least as high as field samples..
- for soils. the backgound values were either site-specific soil
background or Ohio-specific soil background,
- for surface ana seep water. cackgraund values were either site-specific
surface water backgrouna or based on comparisons of data from unimpacted
streams In Ohio.
- for surface and seep sediment. the background values were site-specific
surface seaiment background data. . .
- for ground water and private wells, the background values were
site-specific data from upgradient groundwater wells.
8 - Frequency of detection defined as: .
- compound detected infrequently in 1 or 2 environmentaJ media «solD of the
samples of that media).
- compound was not detected in any other media or at high concentrations.
C - Essential human nutrient defined as:
- compound found at low concentration i.e., slightly above naturally ocurring.
- compound is toxic at only high doses i.e., much higher than those associated
with site.
o - Detection in field blanks defined as: .
- if common laboratory contaminant is found <10 times the concentration
found in blanks or found at low concentrations in field samples .
- tor other compounds, if found <5 times the concentration found In blanks.
-------
TABLE 5
SUMMARY OF ClffiMICALS OF CONCERN BY l\IEUIA
SANITARY LANDFn~L COl\ll)ANY (lWD) Sn'E
(a.k.a. CARDINGTON ROAD LANUFII..L)
MORAINE, 0100
----- ----- ._-.
a.-iaI ...... Su.lecc See, Su.l..e I",,"cl& Su.I... Ci.. ... ri_I.. Seep HlrS.le (;ruund '"I..)U...II..u
Air Soil -~ W.I.. Sc dimc II' Ve... Air W.I.. S.." G.. w81Cf Well.
-- -- - - -
1 _I. T tic... u-.. X X X X
I-Y"""" I J --
X X
I-T.""""'" -
. X
.Diet~- --
. K X X X II:
. -Dlc"""'~- X X X
. I 4-T""'''''- - ---
X
. I-Die""'" .11......... ...- --
X X
. I.DIc'''I1'I- X --
. I-PktIIlIl"8ltl' X X "
. J S- T-- X
. ..Die......._- X
1 4-01816""""- --
X
1.""" --
X X X X
1.118- X X X X
1-"" X
1."""""";"""- X
............ X
"""' ''1 X X . X X
"""1 "'" X X
X
Ac-- X X X X X \
At IT~ X --
A86r-.,. X -
X . X X X
A..- X X X
...... X X X II:
"-. -- - ---
X X X X
X ---
. --
.. - --
. X
..... I'~- -- - - ---
X
.. -- -
- X
....... Mill.""'''' X -- --
.... AcW - - - -- --
X X
.... Ale""" - -- - -- ----.
X
.... cw..w. - ---..
X
X - --- --u .
X
Iw.n........ X X - --..--
X
---..... - ---- --
)(
"'''''''.''''''','''e - - ----A ---
X X
eM...... --- - - --- --
X
01.......... 1M -- ---- - -- ------
X )(
01""'.- --- - - - -- ----
x x -!-
--..- - ..
-------
TABLE 5 (continucd)
SUl\fl\tARY OF cnEMICAI~ O"~ CONCERN BY I\tEOIA
SANfrARY LANDrn~l~ COI\f1tANY (IWD) sn'E
(a.k...o CARDINGTON ROAD LANDFIIJ~)
MORAINE, 01"0
-. -- - --.--
a..ic.. I-'- Surf.ce Scep SUI'..e l.c..h..e S".'ue (i.. Penlnc'er Seep 1I1f- SlIe (in...ud 1'.,..1....11.'"
Air SoIl Se.illlt.1I We,." Scdimenl Vel" Ai, W,'er S..il G.. ".'t, Wdlo
_. ---- - ----
O.......ron. X X X
-
""I II r'ftM X
0....... X X
X
c.lJeli X X X
cruw. X
....... X X
De-. .0'" .O.A. X
.......... X
~I "'''' IIIT6... X X X
DIe6 X X
... X X X
.... ~. X
....... X
He- X X
U X
..... X X X X
X X'
........ X X X X
....... cw.w. X X X X X X
. X X \
X
Mini X X
X
... ~n. X
...... X
...... X
U- X X
" X X X
T"'" X X X X
~12-I'irtl. 6.. X
T"""" X X X X X
T""""... -... X X X X
VI""" X X X
I".... Ac8I8II X X
. Viall c:w.w. X X
x X X J( X
-------
.'
.
. . TABLE 6
SUMMARY OF HEALm RISKS - .'UTURE USE
SANITARY LANDFILL COMPANY OWD) SITE
(a.k.a. CARDINGTON ROAD I.ANDlt"II..L)
MORAINE, 01110
EXPOSURE
ROUTE
CANCeR - iiAZA~if
RISK ( 1 ) INDEX( l
...... & . &-- ......~ ~-
EXPOSED
POPIA.ATION
-w- r
fUIURB USB
~.
. - .. ..~ .- .......--
I .
.......dDn .. on-II,. .......
.....18100 01 around .ller
blttlla"" 08 vola.... .hIe show.dng
dermal COnllct wNIIlhowerIng
8ncId8n18l ""'1011 of swtlce Idne"
dennel conllci wIIh iudlel ..clmenl
.
MIl Rill...
InIi8i8iIon qt_-III voI88l1.
Inglstlon 01 around wele.
.......8Ian of va"'''' will. ihowellnll
dlRnll conlaclwh18 .......
1ndd8nI8I...... .. ,,".cel8dlmenl
dermll contld wlh surtlC' I8c1menl
~=-
1.85E-05 0.16
4.52E-04 8.11
5.IOE-Oe 0.25
l.12E-Oe 0.33
4.J8E-09 0.58
t.nE-08 1.54
ItOTAl i.ie:iii "i.i
liie=iis o~oj
5.15E-04 419
4.48E-08 0.82
..81E-08 0.24
1.86E-09 004
1.84E-08 035
I!0TAl .!j~:~~=-,j~
4.02E-Ol 0.pQ1
'.14E-06 0003
6.l8E-11 0.003
4.48E-14 3.96E-09
t.41E-09 0.010
t.51E-12 8.39E-Ol
2.83E-07 0.008
1.55E-OB 0.029
Jt~r~L ~~!~:~!~ -~H
. Rnl"'" CIIIdr-
....-ssIna an-II.
incwe..... In8e88Ion 01 ...1.. .18e.
'thal,11on DIoo-dl vola' In .
IncIdlnal'''IIISllon allUlflce ..dI108I18
IncIciln8a1lnglsllon II ... seclme...
d.rml' co"'lC8 wIh ""',celedlmlna
dllmal con..ci .." ......clm8n1
d......1 conl.et ..h IUdlce wa8e,
dl.ml' canllct ","" ..ep walBf
-.- - -_._---~_._--
(1) Nullber of expected) i feti.e cancer cases per number of exposel) popu) ace.
Exa.ples - Residential Children - 5.6£-04 .. !>.6/10,OOO or 5.6 in ten th(III:.>.lIut.
Adultnesldent - 6.1E-04 .. 6.1/111,000 01" 6.1 III Ie II thoun.lhll.
(2) NU8erlcal valuu shuwing hazardous index lul illdicdtetJ expu9un~. 'l'he tutdl hdOl.1I11
Index 18 cU8ulative lor each exposed population and is expresseLi au d total nll""UI.
-------
ATTACHMENT 1
ADMINISTRATIVE RECORD
(Index and Documents)
for the
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
REMEDIAL ACTION
MORAINE, OIDO
SEPrEMBER 1993
UDIi8d S&ata Ea.~ Prat8dioa A.-,
. ...... V
71 W...I.u-
CIIcqo, IL 60QM
-------
.;~ n....~
.. ft r.
l~;
\.~ ~!
.,~
UNITED STATES ENVIRONMENTAl. PROTECT10N AGENCY
REGION 5
71 WEST JACKSON BOULEVARD
CHICAGO. IL 60604.3~90 .
:-1-7~
:~~..,... ':"~~!J ~AI!-
=.E'!f.~"l =~~E:"'=~
=~G(]ES-~:)
~EPlY TO n;e ATTE~ OF
~arc~ :'3. :'393
~eaci L.brarian
City of ~ora~ne Library
~oralne Mun~clpal Building
4200 ~ryden Road
~ora~ne. QH 45439
Subjec~: Sarciing~on Road Landf:ll--Qriginal
:ear ~ead ~ibrarlan:
~nclcsed is a copy of the Administra~ive Record file which
iocumen~s selec~ion of remedy by the United' States Environmental
?rotection Agency (U.S. EPA) for the above-captioned site. The
U.S. EPA :s required to establish administrative records at or
near the facility at issue. It is U.S. EPA"s intent to make the
Administrative Record available eo that the public may have the
opportunity to comment constructively on site activities and to
unders~and the issues relating to the selection of the responee
action a~ the site.
The encloeed record files. alona with any future documents
relating to technical activities at the site should be placed in
the repository and be available ae reference materials for public
review and photocoPYing during your normal business hours. We ask
you to maintain the Administrative Record indefinitely or until
~ontacted by U.S.,EPA. Periodically. we will be updatina the
Administrative Record by addina more documents as they become
available to U.S. EPA. and ask YOU to include the updates with
this Administrative Record at the time they are received.
We appreciate your cooperation in servina as an administrative
record repository. Althouah we ask you to use all due care in
handlina the Administrative Record. we want you to know that U.S.
EPA does maintain another copy of the Administrative Record at
the reaional of~ice in Chicaao. Il.. and neither the repoeitory
nor any individuals associated with the repository shall bear any
liability ,for servina as the repository for this Administrative
Record. '
Aaain. we thank YOU for your cooperation. If you have any
questions or comments, please contact me at (312)353-5821.
Sincerely,
l:?~
Janet/ifundheller.
~ R~ords Manaaer
~Gft ~ P2l/l8r
-------
- .
u.s. EPA ADMINISTRATIVE RECORD
CARDINGTON ROAD LANDFILL
SANITARY LANDFILL CO. \ IWD) SITE
MORAINE. OHIO
ORIGINAL
()3/24/93
A~:A
: :: i
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~tt.cnl,nt ~ to uSEPA/OEPH ResDan" to CRC
jlsDutes re: int~uslve ~rllllna investigation
lort Pi,n. ~"ith .na ~afety Flan. ,na
COllunl:' Notlflc.tlon rlan
;'Oi001:!1 ;~rve~ aT Lanatlll 5ite ~rea
",na.rlt:,n: Caicui.tIOr., fer Ke~laentl.i
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~.a: ~rcoo"o Intrusive DorIno/.ell l::atIOr.~
~"ld.ntli~ E%oasur,: ir.;e5tlcn OT ~~ellciI5
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QacuI.nts D..ea 1/:7;i0 - iiij~i6.
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::v.r lett'~ In a z;a1/74 R,oart at COlaon.nts
In urUls .t ~ortn .no South lanatliis
6rauna W.t,r tVIlult10n Tor South S.nlt.ry
Llnifill
L,tt,r r,: Dlsaos.! ot llQUla or 5'11 L1QUla
WiltiS
~oYtr Letter Ind 10i02/74 An'!"l' at LiQUld
Wilt' 51ud9' S'ID!"
Lib AnllYlll of Soluble Chrailul 'Iste
'6lftfrltea by Deleo Products
~tau'lt for rerllillan to DilOos' at
Pol'I'rl%l~ Phenolic COloauna
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:anlcaclon veo~.
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Cafltern
Hddrenees
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U.S. EPA
Van dlr Kloot. J.,
U.S. EPA and AYlnl..
E.. OEPA
:nyilr. L.. ~nyi.r
Concret, Products
-:7LE/OESCRiPT!ON
=:=:8============
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=0I'ler1:eo ~"e~Oll: ::Ioouno
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COllUnlty R~lation5 rlan
Fact Sheet: Envlronllnu1 Invesug.tlon to
a"in
Fact Shift: SUD.rtuna ActIvIties: uivton.
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Letter rl: Sitl Sicurity II Dra.lnq,
Indicitinq LOCltlDn ot Proool.d Ne. ;enc.
Lltt.r re: Site Security ., "i~ Showlnq
ProDOI.d LOCitlOftI at Flnel5
laior.tory RI~ort of Albilnt ~ir Salole
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COlllftts an tnl Intruslvi urillln~
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JEPA Co..lfttS for IncluSIon 11th '~ttlcn..nt
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USEPA/DEPA RllDonl1 to CRe R,au.st for
DisDUtl R.solutlon rt: Intruslv, urillin~ .nd
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-------
ATTACHMENT 2
FEDERAL APPLICABLE OR RELEV ANT AND APPROPRIATE
REQUIREMENTS (ARARs)
for the
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
REMEDIAL ACTION
MORAINE, OIDO
SEPfEMBER 1993
u.wsua. ~ 1\-' J- A.-,
. ...... v .
T7 W8ItJ.u.
Qiap, IL ...
-------
APPUCABLE OR RELEVENT ANn AI)PROPRIATE
REQUIREMENTS (ARARs) - CIIEMICAL SI)ECIFIC
SANITARY LANDFILL COMI)ANY (lWD) SITE
(a.k.a. CARDING TON ROAD LANDFILL)
FEI>ERAL REQUIREMENTS (and to hp considp.ted)
PARAMEtERS REFE~~NCES __MCL~ MCLG PMCL
INORGANICS (ug/l)
Alumhum a
Anllmony a 10/5
Arsenic c 50 50
BariJm c 2.000 2.000
Beryllium a
Cad'nium c 5 5
CalciJm'
Chromium c 100 100
Cobat
Copper d 1.3JO 1.3JO
Iron
lead d 0.015 0
Magnesium
Manganese
MelCury c 2 2
Nickel a 100 100
Potassium
Selenium c 50 50
Slifer b 50
Socium
Thallum c 2/1
Vanadium
Zinc
Cyanide a 200
------------ . -
REFERENCES:
PMCLG
..--.-- AAg~ - --
3
o
50
.5
200
-------
MQS - Ambienl Ai' Quality Siandards; (1) 24 hour av..age with no morelhan one exceedence per year; (2) Annual Arithmellc Mean.
8 = USEPA (Onlce 01 Drinking Waler). 1990. Drinking Water AegtAaiioos and Hoallh Advisories. Washington, D.C.
b = USEPA (Onice 01 Emergency and Remedial Response), 1986. SuperfundPublk: Heath Evaluallon Manual, Washin{lon. D.C.
(10 be considered).
c = Federal Register. 1991. VukJlne 56. No. 20. p. 3528.
d = Fedelal Regisler, June 7,1991. Acl.... level (10% of 100atnumber 08 re
-------
API)LICABLE OR RELEVENT AND APPROPRIATE
REQUIREMENTS (ARARs) - CIiFAiICAL SPECIFIC
SANITARY LANDFILL COMPANY (lWD) SITE
(a.k.a. CARDINGl'ON ROAD LANDFILL)
FEDERAL REQUIREM ENTS (and to be
(continued)
considered)
PARAMETERS .~EFERENCES MCL MCLG
ORGANICS (ug/l)
Benzene c 5 0
Bis (2- elhyl1exylph""'e) 8
Cis 1.2 Dlchloroethe08 a 10 10
Chlorobenzen8
Dlchloroelhane (1.1) c
Dlchloroeth- (1.2) c 5 0
Dlchloroelhylene (1.1) c 7 7
DI-n-bulylphf1a1ale b
DlelhylphlhalUe b
ElhylJenzen8 c 700 700
T elrzhlor0811 'vlene c 5 0
T okJene c 1.000 1.000
Trans 1.2 Dichlor08'88f18 c 100 100
Trlchloroelh- (1.1.1) c 200 200
T rlchloroelhylene c 5 0
Vinyl Chloride c 2 0
Xylenes c 10,000 10,000
Particulale Maller e
REFERENCES:
PMCL
PMCLG
hAAQ~L -
4
o
4
4
150 uglml (1)
50 uglml (2)_-
MQS = Aml:ienl ~ Oualily Siandards; (1) 24 hour average wilh no more Ihan one exceedence per year; (2) Amual Ar""mellc Mean.
8 - USEPA (Offlee 08 Drinkk1g Waler). 1990. Drinking Water RegLlailons and Healh Advisories. Washington. D.C.
b = USEPA (OIIlee o' Emergency and Remedial Response), 1986. Superfund Public Healh Evaluallon Manual.
Washington. D.C. (10 be corlsidere~.
c = Federal Register. 1991, VotJme 56. No. 20, p. 3528.
d = Federal Reglsler. June 7, 1991. AClion Level (10% ollotalnumber of req..alred samples).
e = Nallonal Air Quality Sialdard - 40 a= n Pari 50
MCl = Maximum Conlamlnanl Level
MCLG = Maximum Conlamlnall Level Goal
PMCL = Proposed Maximum Comlaminanl Level (10 be considered).
PMCLG = Proposed Maximum Conlamlnanllevel Goal (10 be considered).
-------
APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWO) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
FEDERAL REQUIREMENTS
Action
Closure - Solid Waste
Landfills
Closure of Waste in Place
(Capping)
Requirement
A final cover system for a
solid waste landfill will be
at a minimum comprised of an
infiltration layer of 18
inches of earthen material
covered by an erosion layer
consisting of 6 inches of
earthen material capable of
sustaining native plant
growth.
The cover will be designed
to promote drainage and
minimize erosion. .
Placement of cap over
hazardous waste (e.g.,
closing a landfill, or
closing a surface impound-
ment or waste pile as a
landfill, or similar action)
requires a cover designed
and constructed to:
Citation
.
40 CFR 258.60(a)
40 CFR 264.228(a)
(Surface Impoundmenls)
40 CFR 264.258(b)
(Waste Piles)
40 CFR 264.310(a)
Landfills)
-------
Action
Closure of Waste in Place
(Capping)
APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
. (a.k.a. CARDINGTON ROAD LANDFILL)
FEDERAL REQUIREMENTS
(continued)
Requirement
.provide long-term
minimization of infiltration
liquids through the capped
area.
. function with minimum
maintenance.
. promote drainage and
minimize erosion or abrasion
of the cover.
. accommodate settling and
subsidence so that the'
cover's integrity is
maintained.
. have permeability less
than or equal to the
permeability of any' bottom
liner system or natural
subsoils present.
Citation
40 CFR 264.228(a)
(Surface Impoundments)
40 CFR 264.258(b)
(Waste Piles)
40 CFR 264.310(a)
(Landfills)
Eliminate free liquids,
stabilize wastes before
capping (surface
40 CFR 264.228(a)
-------
- - - - --.- -- .- -
Action Requirements Ci ta tion
-.. .. .-- ---------- - _. ..-
Closure of Waste in Place impoundments) .
(Capping)
Restrict post-closure use ot 40 CFR 264.11"I(c)
p~operty as necessary to
prevent damage to the cove.'.
Prevent run-on and runoff 40 CFR 264.117(c)
from damaging cover. 40 CFR 264.310(b)
40 CFR 264.310(1))
Protect and maintain
surveyed benchmarks used to
locate waste cells
(landfills, waste piles).
Dispose or decontaminate 40 CFR 264.111
equipment, structures, and
soils.
Eliminate free liquids by 40 CFR 264.228(a) (2)
removal or solidification.
Stabilize remaining waste 40 CFR 264.228(a) (2) and
and waste residues to 40 CFR 264.25B(b)
support cover.
- - --
APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDPILL)
.FEDERAL REQUIREMENTS
(continued)
-------
APPLICABLE OR RELEVANT AND APPROPRIATE
REQOIREMENTS (ARARs) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
FEDERAL REQUIREMENTS
(continued)
Action
Closure of Waste in Place
(Capping)
Requirement
Install final cover to
provide long-term
minimization of
infiltration.
Post-closure care and ground
water monitoring.
Operation and Maintenance
(O&M)
Post-closure care to ensure
that site is maintained and
monitored.
Discharge to POTH (d)
Pollutants that pass through
the POTH without treatment,
interfere with POTH
operations, or contaminate
POTH sludge are prohibited.
Specific prohibitions.
preclude the discharge of
pollutants to POTHs that:
Citation
40 CFR 264.310
40 CFR 264.310
40 CFR 258.61
(RCRA Subtitle O. SUbpiHl
F)
40 CFR 264.118 (RCRA
Subtitle C, Subpart G)
40 CFR 403.5
-------
APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILl.)
. FEDERAL REQUIREMENTS
(continued)
Action Requirement Citation
--------
Discharge to POTH (d) .create a fire or explosion
hazard in the paTH.
.are corrosive (pH<5.0).
.obstruct flow resulting in
interference.
.increase the temperature of
wastewater entering the
treatment plant that would
result in interference, but
in no case raise the POTW
influent temperature ahove
l04.F(40.C).
Discharge must comply with
local POTW pretreatment
program, including.POTW- 40 CFR 403.5 and ] OCd] L'UTW
specific pollutants spill regulations.
prevention program
requirements, and reporting
monitoring requirements.
-------
APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) - ~CTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
FEDERAL REQUIREMENTS
(continued)
Action
Discharge to POTW (d)
Discharge to Surface Water
Requirement
RCRA permit-by-rule
requirements must be
compiled with for discharges
of RCRA hazardous wastes to
POTHs by truck, rail, or
dedicated pipe.
Discharge must comply with
conditions established under
NPDES Program, including
limitations, standards' and
other permit conditions.
Establishes technology-based
effluent limitations and
standards. .
Monitoring results must be
reported at specified
intervals on a Discharge
Monitoring Report (DMR).
Citation
40 CFR 264.71 and
40 CFR 264.72
40 CFR 122.44
40 CFR 131
40 CFR 122.44(a)
40 CFR 122.4(j)
reporting requirements
40 CFR 136.1 - 136.4
(testing procedures)
-------
APPLICABLE OR RELEVANT" AND APPROPRIATE
REQUIREMENTS (ARARs) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
FEDERAL REQUIREMENTS
(continued)
Action
Discharge to Surface Water
. .
Requirement
Requires a Best Management
Program that:
a) shall be developed in
accordance with good
engineering practices.
b) shall establish specific
objectives for control of
toxic and hazardous
pollutants.
c) shall establish best
managment practices (BMPs)
to meet objectives.
d) reflect requirements of
Spill Prevention Control and
Countermeasure (SPCC) Plan.
e) examine for potential
releases to surface waters.
f) ensure proper management
of solid and hazardous
waste.
Citation
40 CFR 125.100 through 104
-------
APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
FEDERAL REQUIREMENTS
(continued)
Action
Gas Collection
Requirement
Standards for control of
emissions of volatile
organics
Design system to provide
odor-free operation.
File an Air Pollution
Bmission Notice (APBN) with
state to include estimation
of emission rates for each
pollutant expected.
Include with the. filed APBN
the following:
. .modelled impact analysis of
source emissions.
.a best available control
technology (BACT) review for
the source operation.
Citation
November 15, 1990
Federal Register
CAA Section 101(a) and 40
CFR 52 Subparts A and KK
40 CFR 52 Subparts A and KK
-------
APPLICABLB OR RELEVANT AND APPROPRIATB
REQUIREMENTS (ARARs) - ACTION SPECIPIC
SANITARY LANDPILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
PEDBRAL REQUIREMENTS
(continued)
Action Requirements Citation
Gas Collection Predict total emissions of 40 CFR 52 Subpart A and KK
volatile organic compounds
(VOCs) to demonstrate
emissions do not exceed 450
lb/hr ., 3,000 lb/day, 10
gal/day, or allowable
emission levels from similar
sources using Reasonably
Available Control Technology
(RACT) guidelines.
Verify through emission 40 CFR 61
estimates and dispersion
modeling that hydrogen
sulfide emissions do not
create an ambient
concentration greater than
or equal to 0.10 ppm.
-------
APPLICABLE OR RELEVANT AND APPROPRIATE
RBQUIREMBNTS (ARns) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
FEDERAL REQUIRBMBNTS
(continued)
Action
'Gas Co!lection
Requirement
National Emission Standard
for mercury, vinyl chloride,
and benzene in order to not
exceed levels expected from
sources in compliance with
hazardous air pollution
regulations.
If'carbon adsorption is used
to control the subsurface
gases, and the spent carbon
becomes.a characteristic
waste, the spent carbon must
be disposed as a hazardous
waste.
.
If hazardous wastes-
materials, which require
disposal off-site, are
generated during remedial
response activities, then
DOT transportation
requirements must be
followed.
Citation
40 CFR 61 Subpart A, E, F,
and FF
49 CFR 264
(Subpart x - miscellaneous
units)
40 CFR 100 thru 199
40 CFR 263
-------
Action
Surface Water Controls
Occupational Safety and
Health Administration
APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARe) - ACTION SPECIFIC
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
FEDERAL REQUIREMENTS
(con tinued)
Requirement
Prevent run-on, and control
and collect runoff from a
24 -hour, 25-year storm
(waste piles, land treatment
facilities, landfills).
Establishes NPDES stormwater
permit requirements for
discharges of stormwater
associated with industrial
activity. Discharge must
comply with conditions
established under NPDES
Program including effluent
imitations, monitoring
requirements, reporting
requirements ana best
management.
Regulates worker health and
safety
Citation
40 CFR 264.251(c) (d)
40 CFR 264.273(c) (d)
40 CFR 264.301 (c) (d)
40 CFR 122.26
40 CFR 300.38
-------
NOTES:
a) All of the Clean Air Act ARARs that have been established by the federal government may
be covered by matching state regulations. The state may have the authority to manage.
these programs through the approval of the implementation plans (40 CFR 52 Subpart G) .
b) Action alternatives from ROD keywork index. -
c) Bulk storage requires the preparation and implementation of
control, countermeasures (SPCC) plan (see 40 CFR 761.65(C) (7)
container sizes that are considered "bulk" storage containers.
may be ARARs if bulk storage is performed onsite.
d) These regulations apply regardless of whether the remedial action discharges into the
sewer or trucks the waste to an inlet to the sewage coveyance system located "upstream" of
the POTW.
a spill prevention,
(a) for specification of
Substantive requirements
-------
ATTACHMENT 3
STATE APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs)
for the
SANITARY LANDFILL COMPANY (IWD) SITE
(a.k.a. CARDINGTON ROAD LANDFILL)
REMEDIAL ACTION
MORAINE, OIDO
SEPrEMBER 1993
Ualt8dS&818 ~ ~,....,
.... V
71 w. J8CkMa
aaiap, IL 606IW
-------
8TATE CHEUICM.-8PEClfIC ARAR.
AND GUIDANCES '08ECON~ (nIC.)
CMOINOTOH ROAn lMIFtL sire
UOfUUtE. OtflO
PARAMEtER8
Ma. PMa. ~~Q9
-
5
70
7
Ii
5
700
5
1.000
100
200
5
2
10.000
150 uglm' ell
50 uglm' ~
240 UgJlII' (5)
160 ug/m' (31
365 uglm' (II
80 uglm" ~
I ()() "Utlll' (~
10 uglm" 841
40 ~ I!L
OAOAHICS (IIUII)
BInnn.
We tZ- ""wI"..ylphlh.1al"
... l/l DlcNcNo.lha...
Dlcllloroethwl."e 11.11
DcHmCII"", (1.1)
IJcHIIOI',,,. (I.~
IJ-n- bulVlph81a1al8
Dle1flwlllblt8lal.
E..,..,.....
, 8118cNOIO.ltylena
,~.
.... 1,2-OIchlaoelhen.
'IIeNo,......... (1.1,1)
'."'0'''''''''.
~ CHo'"
XVI"'. (brill)
P.'cu". U.n.
Dran.
Non-.....n.llrd,oca,bo... .
Sulu, Ololld.
"'Dg8n Dllaklu .
Ca,bo.. Monoxld.
NOTE.,:
AAQS - Ambient AIr Qually Stand".i OAC 3145-11-02.
OAC 3745-1I-G2. (MC 1145-21-02 8nllQAC 3145-23-01.
MCl - U.xlmum COntamlnanllev8lai 0N0 AchI"""" eo. 3745 - 81
PMa.. - PropoS8d Maximum ConIamI."'l... ('lobe CXlnIld8'd)
11) 24 -hcu .,. 8ge COf1C8Qr.lan.
121 AMUIII .........10 me.... .
PI I-hour ".""8 conoa"',allon 01 0.024 ppm vol..... ......ad e. c:e.bon.
"I .............. - hot' ............ .....
I~ Maximum 1- hOt. ."hmele ma.n.
-------
(continued)
STATE CHEMICAl- SPECIFICARARs
AND GUIDANCESTO BE CONSlnEAED(TBCs)
CARDING TON ROAD LANOFIt t SITE
MORAINE. OHIO
PARAMETERS MCt. PMCl AAQS
---------- - .. ------ --.- .------------..----
INORGANICS (ug/l)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobolt
Copper
Iron
lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver. .
Sodium
Thallium
Vanadium
Zinc
Cyanide
50
100
200
10
5
50
100
50
2
2
10
50
50
---.----- ..- -
-+--~ -- -- -- --------- - - --
NOTES; .
.MaS - Ambient Air QuaUIy Standards; OAC 3745 - 17 - 02
MCL - Maximum Contaminant Levels; OAC 3145 - 81
PMCl - Proposed Maximum Contamlnent Levels (to be considered); OAC 37-15 - 81.
-------
AC'11OH
Sui&uJ ......fi.
a-...
STATE ACTION.SPECIFIC All AI" 1'1111 lilt:
CAaDIHOTON IIOAO LAMDfltJ. SI11i
t.tOR.Wtl. 01lIO
aliQUaEMBNT
,....a.II", .... .~ .......-.. b pI8c'-ni o' . elf -..
.. ..... ........ ,... ...,tn_.. i.lDcI8:
. eove. ...0 eouirl 01.. .... a.o Icel o. aon'pullClCible
-w. ..... ....... .1 ill, . ."'. pod eCMllpllibilil,.
........... ....... ...... a,--.
. AI Ie" ......, .... ...cle. ao "opu o. no Ie.. &haa . S
... - 1-"" 2)..
. AI."",,,, ,..".111 f08di8I of ..... .1Ie.e .oIicI ...,
.... .... ,......
AI Ii... eloeun 01, 8IIIiI81J ""fill. ,lie_III o. . elf "".. ..
... ...... ........ . . .. m. . ..... ....... ...
~J*'"'''''''''''''''''''' cOMl.a of:
. A nCClql""'''' ~. ",er. , ..ulli...... u' 8W~ ,..a "k.
....... ...",. ., ,........., 011 "I~ 1~"'..c.n4S.2'
..)(1)(.).. (It;
. A ........ .nina., Ie,,,. . --- o. - i0oi Ibid;.
.- J 1I...................laJ8li J1U.2'-G8Ce)(J)(a);
...,
. A vcp111iw8 ..,.. r~"'iIiat o. - ... "'ICIIIMNt ,..cc4 M
................;.. .......... ......., tllkt...
... .. ...... ............... ,....ce... l1li. b8rriIt lar-
... ....... ... .. ..... ,......... ... ,..... .
A --_1ft .... of five. ,.ICelll .... . -Ii..... ....,. 01
.....,........., - ........ .... ........ .....,
....,.. ... .. _..a...' . wiIIII . ---- pmjccle' e--
.... of 6.. 108 ... ... .. ,n..
o...i., oIa' I'" ..."... 10 ,nv.... ~i.. o' ..a.e. whe..
... -..... ....,......
Deli... ...... a" -inial. I ..-a4 .a... .-Murin. .,......1.
---..... 1145-21.10.
CITATION
QAC )14'.)}.
09(1)( J)<,)
QAC J14U}.1I
(IMI elo8.. 0'
"""IJ lullfll)
114S-11.0I(cMIMI.
... (c) all4 (eH]HI)
(ee. ......
.....in_..)
J14J-JJ.lO
(pau" ..cr
--on"
114'-11-12
(.xpIoaiv. . aa
--..u.)
-------
ACTION
SuiIarJ .....U
0-... (coadnuc4)
o,.ndoM ...
N."""-. (OAM) 0'
s...." ......r..
aa... af u
w...1n ....
ST AT Ii AC'fION SPECIFIC AltAR. I-Oil lilt:
CARDINOTON aGAD LANDFILl. Inti
MOItAINI. 01110
UQU8EMEHT
II. ......, ....fiU i. ... llilU8lCd dI.. . l'uidclK:e o. uIhc.
DCellfle' ...... .. IocatecI widai. - Ihou... r...1Iorizooaat
""'e r- ..lee.. 8IIIid -".. III. n.-i..I. ,..., ...
...... i"" ... ........ .. .qIoeiY. ... rnoNIor.. 8)..m
..... oa .. .... af.. .-,......" _..n. 10 ..... 08
....... .. L- .'... 08 ......... 0' uploUwc ,.. moni.orin.
-, .. ft,-"'.
Eel8llliehce n,_....... ro. .. U,IoeiVl ... rnoni.urin. pl.. for
......., ......
............ '" . --....10 JO ,.... 10 ....... .... ... it
.......1.. ... 1h08II1OId. Po-.clotur. 8Ct1vl.inlac"":
. Co.-~ 0' lucb... mana.emenl, ..d.ce ".'e.
,,., r4. .1fIociw ... clll8Cdo8lc:eaual.,.... .nd
....... ... puund .'''1' rnonit0ria8 '10"'-.
. M.ll1IIi. errecllve..ellnle."" 01 up.
. Qu.rtcd, Inopcc:lio/18 .nd Rpodin.-
'1 I
. ......... 0' c.III&... .ac. compktioa 01 ,...-cao.... c....
AI .... .--. af. ....... ...- af. ... - CGftIOMr
........... ...-.. .11... C- *ei."'''' COIII8ftlCl84
...:
~
. ................ .....811&81108 0' -....108 0' Ii",W. duaup
...... .......
. fUIKIio. willi- mini- _ialc..neei
. ~ .nlll.e .nd rninillliu cl'O.IOII 08 ebneiort 01 ~
00Nr;
. ~CD fui ....... .... _.we DC' ... ..... 11M coven
......, .. """"'i ....
. HIV. . ....--lIiI, k.. th.. 08 ...... 10 ... "l1IMebilil, 0'
.., ........ .,.... .... ...........-.
CRATIOM
ORC )7U 041
OAC )74S-1J-I4(A)
OAC J14'...O(A)
(CIoeun 0' "'''''88)
-------
ACfION
Ofcnu-."
NeI--. o'
HUM'IIau8 w...
a..-Ifin
~.".....
ActIwiIIu
STATIi ACfIONSPECIFIC AltAR, .1111 1111:
C ARDItfOlOH ao.\O LANDFIlL sm
MoaAlNE, 0100
UQUIREMINT
Ala. .... cloeluw. pcNII-cloeluw c... of... """1, iIKluoIilll
............. _i_MIK."'''''','''''''' po8II-clu.n can
"",1. ........ to:
. ~.i...ia !be ......riI, ... .lIacliv..... 01 lb. 6-1 cover II,
..... ....... .. .. ...., - .. , ~ COIftC8 .. .IIICII 01
......, ......... .... 01 adMr ,wlII8j
. M.i8Iaia .nd moIIiaor .... ....... w8IC. moaiIorina .,8CID ....
......... .1 ... ................... ........ ---
.... ............;
. PrcVCal cua- ... nllIOli r.- .104i.. or odac.,.,ilC d._,in,
.. .... -er. ...,
. froIcc. ... .......ia --,... ......d. ...... 10 Wealil) ....
....Iocadue 01... ......
a'lIUiR 8414i1ioaa1 po8.clolun c..., if .,,1ic"Ic, 10;
. ...... ... ..... .. Ie."... coIIcclioe. RD'V" ...
...-... .,.... U ........ . .,.......... ill lie
....... 10,.."........ .-...... 01..... .. ...
.,......
. ............ --or ... ,.. coIIcc_'" control "".. if
......... . ...... ..... .. ....-. .. CCl88aa1 ...
"..Ie" ... .................. 01 ..... ..., .'
. 8''''1 poII-
-------
ACTION
0.. Calleelloa aAli
0...... W8I.,
T...I..III S,lIem.
STATE ACTION SPECIFIC ""'Alh I lilt 1111:
CAJtDINOION lOAD LAMlJlllLI. SR1I
MOItAIML OHIO
11!QU8ENEHT
1"0+11"'. ...... --.... nquiremcllla fIN ai. poIlulion
CC8nII............ -..cd.. aclion ,lOCC4urc. for
_lftln..:llonI. .1. poll""" 1_,01 ecauop'nc...
.......ibil.1hc ellli..a.. Of -1pI IllIG the open ai. frum an, IOUree
01 ...... III --....... ..., ..., ...., ICicle, la_I, ,...,
npon, .... . ..., .. - -. or CU8lW8MioII 0( "'...aca ...
.... . --.WeII -, ......, ........, .lClr 0{ -If... or
.... ..... 01 '''''' II ....., "'10 k -Wen" . public
--..
All DC- ... .111.... . '_._A.'" IOURCI ...11 fulluw .004
..........a:..... II f lrunllh.
Emi... limilatione impo..4 upon . IOUICC ...11 ft08 be affcclc'
., -... III.., 118Ca:.......... C.... pod ....-dnt
,nedell 80r ., ....r .,....... IIclllII4pIc8.
Si.aific... ... avoW"" 4c1.rioralilNl of ai. ,...IiI, ........
....... . ....., Ie ..... II or ..... ... ... 01.... air
...., ........ 1IiaI1.. ,....il&'.
All DC- II8IionarJ _II 0' pIaotoclletaicall, nacliva ...l&ri.18
.......... , -- . "....,_flt................
CG111rC11II iI ~fl'N ... ......... pr8Cdcc. In KCO".' wlab be..
clllft1818d1...eoa.
Ho pc-- ...11 cmil .... ....criale l1li0 .... 'IQaOIfhe.. r- .
..... .. ... .,........ ... ......... .. ........~, .
. .n aa:... Ian. or""" .dIcth. COllI'" ...ipmclll.
frubibil. daa",c.la openlioaa whcRb, .. indu."i., -.... I.
pi a 1iI.1. . ......., - ..... ..... b ............ 01'
..... fit .., ... ..... ..... ,1.. ...~.lIcc" ""'IC. a04
........... ., .c .."c8CW.
An, pc-""" .caenl&. a .....c nu.. 4cl&nnillc if .uch .......
Ie. ~......
EIIabliehCl.i"..lcr pcrmll crileria ... PH .AII BAT..
crrATIOH
OAC 114'-U06
IAI, AJ)
OAC J14HU
IA,D)
OAC 110.16 OJ
OAC )14'11 0'
OAC 110-1I-01(A-
I)
ORC 6111.4'
OAC 114U111
OAC nO.)1 0'
-------
AcnoH
DUe..... DiNed, 10
Surfecl Vi.....
. .
STATE ACTION SPECIFIC AllAR, Folt 1111:
CARDINCJTON ROAD LANDFILL S~
MORAINE. 0810
REQU8ENIINT
~. .. '_~'''I or ~1118 10 ..rfac. ....Ie.. of dli 5".1
8II6ouI . ,.nnII
~.. -- eo89I, willi ... "tOIlS ,...... iKludin.
...... ......... ......... .......--... nportl",
....-......
Ell8WU.ce ~ ..... ..... ..,.ail, ..adanlalcrileri. fur
--.c. WII... ........... .
........ ...... ..... ....., ..........wela would inlerfc..
wiIII- ..... ...... .. ........ ...... .n t ..'0
&tabu.. - die.... .... dIc...llRiaillllonc requiremenl'
-..... willa ........ ... ..... ...,.
....Ii... ..... u.. "".IIIIIoaa.... erillri. IlK ...f.ca ....n
.. .. .....
&tabillb.. ...nI..... ..alii, crilcn.. Surfac. .I.en ....U be
... 01:
. 5...,.-.4........ GdMr ............ ecule 10 r...m alud.e
...... .......,......... ...
-
. fIoaIiaa 4Icbrie. oil. KUIII, or odic. ao.u., III;!Ilcri,11 call.",
..... 1- .&0"",".
. Mile"'" ,roduci.., color, Ollar. o. adM. ...nee nulin.
....."'-' ..
. ~""el ill _8InIiOM 10- ... ........ 10 ~u_n. .nimal
... ....... Ii. ...,. ... ..,wI, Ie"" .... .ad.. _.
. HIllricIll8 ia cOIM:e.nIioaa dI.. ueale ..Ii..nee ,,,,...111 of
..... ....... ......
.-
crrATION
ORC 611104
ORC 61n O4J
OAC J1U ))
OAC nU-01
OAC )}U~I-OJ
OAC UU 01 06
OAC HU ~I OJ
OAC nu I 04 (A-
I!)
-------
STATE ACTION SPl£lFlC ARAlto 1'1111 lilt
CARDINCnI, OAC Jl4).)
........ ..... fOI"W.....
-------
ACJION
......... W...
0.......
a....eI. ..'1".
W.. 'lCiII,
-
........ ... ......
a.. V 0.-.. Wall.
W..
STATE AcnON S'tiC.HC AllAR. 1-1111 1111:
CAllDINCJION .GAD UUIDI'ILL sm>
MOIlAIHI, OHIO
IEQUIUMEHI"
Oa.nIan 01........ .... -.. 1-.1, ",ilia ...,Iie.....
"""'.. -.... - .opouI ..............
....... ...i..~. ".....e, ,..II_al. ... ...,-10'
~.......,
0........ of ...... .... ......... If .''''1 ... 11818""""
.... ..,..., --......-.
............. _ill, - l-.a, willi ---- .......
..ltfii" fa..C4fI8Ma -.- ..,........--.
......... .... "'-1 01 ....iW ...~ ..lIea 0. ..,....
.......... . - 1I.......we1l ""'.'11' ..... -, lie.....
....-,.
....... ilia ........ of ,..icula... ....., "-'. "', .11. .not
..... ... ."" In ,.... ...., .. -........ wi. ..
.... ......
.... - ........ "8 .............. kilil, .... lluaa ..
IM8, ..:
. .......... .. ... for ...... m.inll""u.
. c..d. ....... - ........ .... .... -c-rr 10
..... a.-.......... ~.fOII.-.-......
.,......... -- ....-.......-...10 I""" .IIe,. or
...... ..... - ... .. I t ""I.
. c:..,.I, willi ........ c..... ",,"IC_"'I~
Duriat ...liII or ... """"'. .1 loaIamiaalC' c........
. JIlL" ... IIiI .... lie ..-..It, ...,... ., ""' . -..
........ tile ........ ., ..-... ........w ..... - a6et.-
... .... ...... ........ . UIC ....... Iu ..... 01 IrIIO c ......
.... - ,.."IauaI, ... lit ... ,....-.
,.. &on.... erile'" .... .............nI 0' .... ....... .... ........
I -.....
t:J
crrATION
OAC )14'.'1
UIC ) '4' OJ(I')
OAC UtUHI
OAC ntUJ.lI
OAC )1U-\t
OAC )14'.19
ORC )JJ4 010)
OAC J14S~1I
OAC U4U61t
OAC JJ4'.)4-U
OAC JJ4' , 10
(A.I.e)
-------
STATE ACTION SPECifIC AIIAIIII.IIK 1111:
C ARDIN<1ION ROAD LANDFILL Sin
MOIt.AINB. 0"10
ACJION REQUlaBtEHJ CITATION
Air EmiNioa. E.8IIWitk. R'fIircmc... ncce_" ... _i...i. level. 0' .,. OAC 11.,-U-01
......, ...... ... c-'rle. ~ ... plCllccdort 0' ,.blle ....II"
.... pft"enlio.1 of Injury 10 ....... .ni_1 or ,...pc.t, I.. U,e _c
Pn>hibil. .i. poII..io.. ..1..~e.IUC"" .,....h. ,.... dual. 01..1. OAC un IS 01
..... ...., ..... .-.. ........ ..... 8ro8 .., -ftc 1M
---I III -. I _MI' Of .. -. -.... 10 e"'., die
...... .r., Of _1&.. vi... pulllio Of C- UlWe....wc
IIIjury t. "_,e 10 ,.......,.
E8u8l1itk. criteria for me.__" of .......... 0' .i. OAC nu U 04
...-a......., lac"., ........ .10...... ....
OAC nu n01
PtoII.I. ai,.rlC.. end ."aid"''' llelcriontioe of uieliat.ir OAC JJU-IJot
...., ..... ..... .,., II .... 10 ., ...., ... ........ ....
Ii. .-1iI, .......... OAC nu 1) IH
E8u8lIilhc. IItqui.e.nc... for ..,ilivi ... _ree. cu....ibuli... or OAC nU.l1o.
....... I --..
E".""". IItllrieli- - ,...icu"', ......... from "el bumi... OAC )141.1110
. . It.....
p.. 0.11.......... - "..... ,....... ...........,..... OAC J145-1101
..~ ...." _II. (A.8)
F""'*" ~... - ........ 0' woIaIiII OIl'. co..,..."', OAC J14S.)I~
'- ..........., -II. (A.8,C)
PtoIIiIIi.. ape. ......... .. .. 1ft. wile.. 8ir ale.., .,.mi.., o. OAC H4t 1901
I_..a, - .-em.... OAC JJ4t-2) Ire .. elr...'1. (A.I)
ErI.blilhe'lC4Iui.emCIIII fur ",en bumin. in .uloide" 1...1. nAC JJ45 190)
(A.DI
Erleblilhcl requilltmcnll 'or open bumin. in u",collided ""1. {)AC UU 1904
/ IA-DI
ErIe...i... crileri. fur lied...... "'''''' II, the di..tl... eOl8c:emi.., OAC JJ4SJI OS
1-'.......- .. ........... ... ......... ..r - aI. COMa_.... (A)
-., ....... .",-Illcilil" ..t.. ,onudo.. -', ......
.,,1Ic.llo..r....... 01 ..... .11.. .,.....
All AclioM .."it. 0' New s-.c.. 0' Ale To.1e Emi........ OEPA DAPC 1191
AI AelioM 01110 '11- ctc..I. ek.. 1'ioIic:,' DU.ro..OI"
,.
-------
STATE ACTION-SPECifiC AJlAJb fOR ruE
CAaDINOTON .OAD LANDFILL III'ti
t.IOItAItl. OHIO
ACI10N I.EQUIUNENT CITATION
All Aclioa8 USEt'" ~."'r I'nIkcIioe Stnte"
All Acllone Ie. ""Ii"'" T....... T"hnulo.ic. (.ATO fur Icmc4iel DEaa-OO U~16
Ic...- SII..
All AcIioN ........ .. .. L . ".8" ....fill .CIpOO8C AllcrMlivCl'" DEJUI-oo.U~19
a.-4, IIIIc8i88 fir 'W fill .1..... --.... Sic..
------- |